NCS000233_CEI_20201118

ROY COOPER
GoVernor
MICHAEL S. REGAN'
Secretary
BRIAN WRENN
Director
NORTH CAROLINA
Environmental Quality
November 18, 2020
Trinity Manufacturing Co., Inc.
Attn: Daryl Mitzel
PO Box 1519
Hamlet, NC 28345
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000233
Trinity Manufacturing Co., Inc.
Richmond County
Dear Mr. Mitzel:'
On November 13, 2020, a site inspection was conducted for the Trinity Manufacturing Co., Inc. facility located at 11 E.V.
Hogan Drive, Hamlet, Richmond County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your
review. Mr. Andy Borgstrom, EHS Manager, was also present during the inspection and his time and assistance is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit
NCS000233. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as a
UT to Falling Creek, a class WS-III waterbody in the Yadkin River Basin;
As a result of the inspection, the facility was found to be in compliance with the conditions of NPDES Stormwater Permit
NCS000233. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made
during the inspection.
Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up
to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with
understanding any aspect of your permit, please contact me at [phone] or via e-mail at [e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
Enclosure: Compliance Inspection Report
ec: Andy Borgstrom, EHS Manager —Trinity Manufacturing Co., Inc.
cc: FRO — DEMLR, Stormwater Files
C.�!�'" ` �`.-� ,..� North Carolina Department of environmental Quality I Division of Energy, Mineral and Land Resources
Jjj Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
NORT I CAR(A NA
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Compliance Inspection Report
Permit: NCS000233 Effective: 03/01/12 Expiration: 02/28/17 Owner Trinity Manufacturing Co Inc
SOC: Effective: Expiration: Facility: Trinity Manufacturing Co Inc
County: Richmond 11 EV Hogan Dr
Region: Fayetteville
Hamlet NC 28345
Contact Person: Andy Borgstrom Title: EHS Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Andy Borgstrom 910-410-2702
Related Permits:
Inspection Date: 11/13/2020 Entry Time 02:15PM
Primary Inspector: Mike Lawyer Nt
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Exit Time: 04:25PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000233 Owner- Facility: Trinity Manufacturing Co Inc
Inspection Date: 11/13/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Permit expired on February 28, 2017. A permit renewal application was received by the Division on August 31, 2016 and the
permit has been administratively extended with the same conditions until a new permit is issued. Inspection conducted to
evaluate compliance with current permit conditions prior to re -issuance of a new permit. Met with Andy Borgstrom, EHS .
Manager, who provided the facility's Stormwater Pollution Prevention Plan (SPPP) and monitoring records for review. The
SPPP is well -organized, complete and updated per requirements. Documentation associated with employee training, facility
inspections, significant spills (none) and non-stormwater evaluations are included with the SPPP. Monitoring records from
2017 through 2020 for the facility's one stormwater discharge outall indicate that there have been no exceedances of the
benchmark values associated with the discharge characteristics. Per Mr. Borgstrom, no onsite vehicle maintenance is
conducted. After the records review, site observations were made of the facility's ASTs with appropriate secondary
containment, material storage areas, stormwater drains/ditches, stormwater retention pond and stormwater discharge
outfall. As a reminder, the permit contains second ary.containment requirements for bulk storage of liquid materials (single
above ground storage container with capacity of greater than 660 gallons or multiple containers in close proximity with a
total combined storage capacity of greater than 1,320 gallons), storage in any amount of Section 313 of Title III of the SARA
water priority chemicals, and storage in any amount of hazardous substances.
Page 2 of 3

Permit: NCS000233 Owner - Facility: Trinity Manufacturing Co Inc
Inspection Date: 11/13/2020 Inspection Type :Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USES) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0 ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0 ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
N ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
E ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
#'Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
E ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan -been implemented?
❑ ❑ ❑
Comment:
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitorinq Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ M ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
# Were all outfalls observed during the.inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3