NCS000057_Monitoring Plan_20141201

CHEMICAL SPECIALTIES
November 25, 2014
Mr. Robert Patterson
Wetlands and Stormwater Branch
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Status Report — NPDES Stormwater Permit Monitoring Plan
Permit No. NCS000057
Chemical Specialties LLC
Harrisburg, NC
Dear Mr. Patterson:
The purpose of this status report is to update the Division of Water Quality on Chemical
Specialties' assessment of BMP's (Best Management Practices) and progress in identifying
sources of copper and zinc in stormwater at our Harrisburg, NC facility. This requirement is
found in Part II, page 12, item 5 in the facility's stormwater permit. The status report is
required to be submitted by November 30, 2014 (two and half years after the issuance of the
Permit).
An initial monitoring plan was submitted on August 21, 2012 that described the actions that
would be taken to determine the sources of copper and zinc in the facility's stormwater.
Below, is a summary of the actions taken since the new permit became effective and the
submission of the initial monitoring plan:
�0
1) Semi -Annual sampling: As described in the initial plan, representative samples are being
taken on a semi-annual basis throughout the facility. Please see attached list that
includes all sampling locations and estimated percentage contribution from each area.
Instead of 5 samples taken semi-annually, 21 samples are being taken to better help
delineate the sources of zinc and copper. Areas include downspouts, storm drains,
outfalls, and upstream and downstream of the Rocky River.
PO Box 1330 — 5910 Pharr Mill Road — Harrisburg, NC 28075
Phone-704-455-5181 Fax-704-455-6507

a. Testing dates include:
i. 1/17/2013
ii. 11/26/2013
iii. 5/15/2014
iv. 11/17/2014
b. In summary, the following items have been noted during the four sampling
events:
i. Zinc is being consistently found in the downspouts that were sampled
from the roof. Zinc is found in the galvanized metal used in the gutters
and downspouts. In addition, zinc is commonly found as an ingredient in
tires. (both forklifts and trucks) . The zinc levels have remained
consistent during the 4 sampling events
ii. Copper levels have decreased from the initial sampling event to the most
recent. The storm drain behind warehouse #4, the main drive bypass,
and the two curbside sampling points adjacent to the ACQ plant have all
shown a decrease in copper during the last 4 sampling events.
iii. Outfall # 1 has been statistically unchanged for zinc and copper for the 4
sampling events.
iv. The copper and zinc levels for Outfall #2 have decreased during the
course of the 4 sampling events.
v. Upstream/Downstream Rocky River has remained consistent during the
four sampling events for both zinc and copper.
2) Best Management Practices -
a. Chemical Specialties formed an employee task group in 2012. The task group is
comprised of employees in operations that handle copper and zinc products.
This group has identified ways to help minimize tracking of copper. Items
identified and implemented during the course of the last two and half years
include:
i. A spill pallet has been constructed of wood. This pallet is used to
transport bales of chopped copper and scrap copper from Warehouse
4/5 to the ACQ plant by forklift. This impervious pallet captures small
particles that might fall out of the pallet when transported across the
drive. The particles that that are captured are used back into process.
ii. A copper/zinc spill cleanup procedure (Housekeeping Program) has been
PO Box 1330 — 5910 Pharr Mill Road — Harrisburg, NC 28075
Phone — 704-455-5181 Fax — 704-455-6507

written and implemented. All employees in operations at the facility
have been trained on the procedure. This procedure has been posted in
strategic locations throughout the facility. All copper spills and cleanups
require documentation.
III. Additional signage has been posted in areas that require immediate
cleanup of any copper spills.
iv. This program is audited on a frequent basis.
In conclusion, the four sampling events have identified the areas that are potential sources of
copper and zinc in stormwater. In addition, Chemical Specialties has implemented additional
facility wide Best Management Practices in order to decrease copper and zinc in stormwater.
Moving forward, Chemical Specialties will continue to sample the two outfalls as required by
the permit in order to determine future trends unless otherwise directed by the Division of
Water Quality.
I can be reached at [phone] for any questions or additional information.
Sincerely,
O-V r-/Z
Dave Haley
Safety Health and Environmental Manager
PO Box 1330 —5910 Pharr Mill Road —Harrisburg, NC 28075
Phone — 704-455-5181 Fax-704-455-6507

Sampling Area (Average from 4 sampling Copper Zinc
events) (mg/1) (mg/0
#1 Tanker Parking (at gate valves) 0.042 0.047
#2 ACQ Tank Farm roof drain (NW corner of roof) 0.000 0.096
#3 Storm drain behind #4 Warehouse
0.383
0.192
#4 Main drain by-pass at QC Lab (6" pipe)
0.246
0.504
#5 Run off pipe at fire water tank
0.042
0.254
#6 Downspout Bldg.001 (NE corner)
0.011
0.146
#7 Downspout Bldg.001 (NW corner)
0.000
0.187
#8 Downspout Dock 3 (S. side of Bldg.036)
0.016
0.089
99 Downspout in front of T-142 (E. of AA Plant)
0.016
0.355
#10 Downspout in front of Bldg.023
0.012
0.334
#11 Downspout pipe west of T-138 (Chiller Room
Area)
0.008
0.105
#12 Downspout at SW corner of Bldg.024
0.012
0.220
#13 Drain at north side of Bldg.230/231
1.319
0.992
#14 Downspout at W. side of loading dock roof
(Bldg.230)
0.000
0.064
#15 French drain (open end) SE corner of Bldg.231
0.070
0.176
#16 Curb -side drain at ACQ drive (North/Upstream
drain)
0.079
0.105
#17 Curb -side drain at ACQ drive
(South/Downstream drain)
0.077
0.109
#18 Outfall 1
0.060
0.235
#19 Outfall 2
0.027
0.120
#20 Rocky River (Upstream)
0.027
0.058
#21 Rocky River (Downstream)
0.014
0.062