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Home My WebLink AboutNCG030486_SWPPP with Outfall Info_20231020 STORM WATER POLLUTION PREVENTION PLAN (SWPPP) • S m 'l' t Innovation has a name. WATER SYSTEMS DIVISION — STATE INDUSTRIES DIVISION OF A.O. SMITH WATER PRODUCTS COMPANY 4302 RALEIGH STREET CHARLOTTE, NORTH CAROLINA 28213 J U LY 2023 TABLE OF CONTENTS INTRODUCTION......................................................... 1 ..................... Regulatory Background SECTION 1 — RESPONSIBLE PARTY........................................... 2 Pollution Prevention Team Management Certification SECTION 2 — GENERAL FACILITY INFORMATION................................ 3 Facility Information General Location Map (Figure 2-1 SECTION 3 — SITE DRAINAGE.. 5 ......................................................... Potential Pollutant Sources (Table 3-1) Drainage Basin Characteristics (Table 3-2) Site Ma (Figure 3-1 SECTION 4 — DESCRIPTION OF POTENTIAL POLLUTANT SOURCES...... 8 Description of Industrial Processes Inventory of Exposed Materials Table 4-1 Summary of Significant Potential Pollution Sources SARA 313 Water Priority Chemicals SECTION 5 — FEASIBILITY REVIEW OF CHANGING OPERATIONS 10 SECTION 6 — EVALUATION OF STORMWATER OUTFALLS 11 SECTION 7 — STORMWATER BMP SUMMARY...................................... 12 Summary of Existing Control Measures (Table 7-1 ) SECTION 8 — SECONDARY CONTAINTMENT PLAN............................... 14 SECTION 9 — SPILL PREVENTION AND RESPONSE PROCEDURES........ 15 SECTION 10 — SOLVENT MANAGEMENT PLAN 16 .................................. SECTION 11 — PREVENTATIVE MAINTENANCE AND GOOD 17 HOUSEKEEPING.............................................................................. Preventative Maintenance and Good Housekeeping Program Sediment and Erosion Control SECTION 12 — EMPLOYEE TRAINING.. 19................................................ SECTION 13 — REPRESENTATIVE OUTFALL STATUS........................... 20 SECTION 14 — ANNUAL SWPPP REVIEW AND UPDATE........................ 21 SECTION 15 — ANNUAL ON-LINE SWPPP CERTIFICATION..................... 22 SECTION 16 — NOTICE TO MODIFY THE SWPPP.. 22 ................................. SECTION 17 — SWPPP DOCUMENTATION............................................ 22 SECTION 18 — STORMWATER MONITORING PLAN .............................. 23 Qualitative Monitoring Requirements (Part D) Analytical Monitoring Requirements (Part E) Pollutants to be Sampled Storm Parameters to be Recorded Sample Location Sample Type and Frequency Benchmark Values for Analytical Monitoring Requirements Submission of Analytical Monitoring Requirements APPENDICES A — CERTIFICATE OF COVERAGE NCG030486 B - GENERAL STORMWATER PERMIT NCG030000 C - RESPONSIBLE PARTIES D — NOT USED E - SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN F - PERIODIC INSPECTION CHECKLIST G - ANNUAL PLAN REVIEWS FORM H - QUALITATIVE MONITORING REPORT FORM SWU-242 I - ANALYTICAL DISCHARGE MONITORING REPORT FORM SWU-264 J — TIER 1 RESPONSE LOG K — TIER 2 RESPONSE LOG Introduction REGULATORY BACKGROUND In 1972, the Federal Water Pollution Control Act (also referred to as the Clean Water Act [CWA])was amended to provide that the discharge of pollutants to waters of the United States from any point source be prohibited, unless the discharge is in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. The 1987 amendments to the CWA added Section 401 (p) which established a framework for regulating municipal and industrial stormwater discharges under the NPDES Program. On November 16, 1990, the EPA published final regulations which established application requirements for stormwater permits. These regulations required specific categories of industrial facilities which discharge stormwater associated with industrial activity, either directly to surface waters or indirectly through municipal separate storm sewers to obtain an NPDES permit for these stormwater discharges. Facilities operating under Standard Industrial Classification Code 3443 are required to obtain a stormwater discharge permit if they have industrial activities actually exposed to stormwater. The A. O. Smith Water Systems Division of State Industries has specific industrial activities exposed to stormwater, and therefore, must obtain NPDES permit coverage for their stormwater discharges. The State of North Carolina Department of Environmental Quality (DEQ) has been delegated the authority by the USEPA to administer the NPDES permit program. The DEQ has elected to regulate the majority of industrial stormwater discharges under a series of general permits. Permit No. NCG030000 applies to facilities operating under SIC Codes 3398, 335, 34, 35, 36, 37, 38. Since the original issuance of General Permit No. NCG030000 in the early 1990's, this permit has expired and been reissued a number of times. Each time this permit expired, the facility has submitted a timely reapplication for coverage under the next reissuance of the permit. The current issuance of General Permit No. NCG030000 has an effective date of July 1, 2021 and an expiration date of June 30, 2026. A copy of the notification letter from DEQ received by the facility under the reissued permit, No. NCG030486 is provided as Appendix A. A copy of the current issuance of General Permit No. NCG030000 is provided in Appendix B. Part B of General Permit No. NCG030000 (dated July 1, 2021) requires each permittee to develop, implement and maintain a Storm Water Pollution Prevention Plan (SWPPP). Facilities with an existing SWPPP are required to update this plan to address the provisions of the new general permit. Due to the extensive updates required between the previous (2008) permit and the current permit, the facility has decided to submit an entirely reconfigured and updated SWPPP. 1 Section 1 RESPONSIBLE PARTY Pollution Prevention Team Part B-1 of Permit No. NCG030000 (dated July 1, 2021) requires the identification of specific positions responsible for the overall coordination, development, implementation, and revision of the SWPPP. For purposes of this plan, Ms. Alexandra Rice, Environmental Coordinator, serves as the overall Pollution Prevention Coordinator. She is supported by Laura Viers, Plant Manager, and Brandon Woo, Senior Project Engineer, and assisted on an as-needed basis by representatives from the following departments. • Production • Maintenance • Buildings and Grounds • Wastewater Treatment • Shipping • Engineering Responsible parties for all components of the SWPPP are provided in Appendix C. Management Certification In accordance with Part H Section H-1(b) and (d) of Permit No. NCG030000, the following certification statement is provided with respect to the development of this SWPPP — "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." Signature: Date: Laura Viers, Plant Manager Water Systems Division State Industries 2 Section 2 GENERAL FACILITY INFORMATION Facility Information NAME OF FACILITY: A. O. Smith Water Systems Division of State Industries PLANT LOCATION: 4302 Raleigh Street Charlotte, North Carolina 28213 LATITUDE & LONGITUDE: Latitude 35' 15' 11" (35.253281) Longitude 80' 47' 23" (-80.789798) OWNER OF FACILITY: A.O. Smith Corporation 11270 West Park Place, Suite 170 Milwaukee, Wisconsin 53224 (414) 359-4100 FACILITY CONTACT: Ms. Laura Viers Plant Manager (704) 597-8910 TYPE OF INDUSTRY: SIC Code 3443 Fabricated Plate Work NAICS Code 332420 Metal Tank Manufacturing OPERATING SCHEDULE: 8 hours/day, 5 days/week RECEIVING WATER: Little Sugar Creek, Class C waters in the Catawba River Basin, via City of Charlotte storm sewer system NORTH CAROLINA NPDES GENERAL STORMWATER PERMIT NUMBER: NCG030000 DATE OF PERMIT ISSUANCE: July 1, 2021 DATE OF PERMIT EXPIRATION: June 30, 2026 CERTIFICATE OF COVERAGE NO.: NCG030486 3 Figure 2-1 — General Location Map SITE OUTFALL TO CITY OF CHARLOTTE MUNICIPAL COLLECTION SYSTEM Iti RALEIGH STREET ULTIMATE OUTFALL 70 LJTZLE SUGAR CREEK MW - 'All N,TRFON STM E At i ■ - �* _ A:O:9MfTH WATEF�SY8TEM3 # diVI�IONOF STATE INdUSfpIES - y � �, G 434P RAL�IGIi ST�I�ET - 1 � GHARLDTTE:NG�9213 * _.R' THREE❑hI51TE OUTFACES '' �+ yr•� ■ 7 Little Sugar Creek, the receiving water for the site's stormwater discharge, is currently considered impaired. A TMDL exists for Dissolved Oxygen and Fecal Coliform. 4 Section 3 SITE DRAINAGE A. O. Smith Water Systems Division of State Industries is located at 4302 Raleigh Street in Charlotte, North Carolina. In accordance with Part B-3 of Permit No. NCG030000 (dated July 1, 2021), a Site Map of the facility that clearly depicts all required features is provided in Figure 3-1. This map identifies the drainage patterns and drainage area of each stormwater outfall, the location of existing structural control measures used to reduce pollutants in stormwater runoff, locations where significant materials are exposed to stormwater, and all locations where potential pollutant sources could be exposed to stormwater. As shown on the Site Map, all of the stormwater which falls onto the site enters a City of Charlotte municipal storm sewer that transects the site from approximately the midpoint of the rear property boundary and flows in a northwesterly direction. The facility has three (3) separate connections or outfalls to this storm sewer. Outfall 01 is located south of the facility in a railroad right of way and captures sheet flow runoff from the southern portion of the site, as well as runoff in the railroad right of way. It should be noted that there are no industrial activities present in the drainage area for Outfall 001. Outfall 002 is a storm sewer inlet that is located in the southwestern portion of the yard that captures runoff from the yard and a portion of the roof runoff from Buildings A, B and C. Outfall 003 is a storm sewer inlet that is located in the northeastern portion of the yard that captures runoff from the yard and a portion of the roof runoff from Buildings A and C. The City of Charlotte municipal storm sewer to which Outfalls 002 and 003 are connected ultimately discharges into Little Sugar Creek which is located north and west of the subject site. It should be noted that portions of Little Sugar Creek are on the State of North Carolina's 303(d) list of impaired waters for ecological and biological integrity, and a TMDL (Total Maximum Daily Load) has been established for portions of Little Sugar Creek for Dissolved Oxygen and Fecal Coliform. Table 3-1 Potential Pollutant Sources 1 Pole Barn 2 Air Compressors 3 Cooling Tower 4 Empty Washer Chemical Tote Storage Area 5 Wooden Pallet Storage Areas 6 Scrap / Solid Waste Storage Luggers 7 Material Handling Bin Storage Area 5 Table 3-2 Drainage Basin Characteristics Outfall Impervious Pervious Total 001 48,350 sq. ft. 179,650 sq. ft 228,000 sq. ft. 002 199,500 sq. ft. 0 sq. ft. 199,500 sq. ft. 003 142,500 sq. ft. 0 sq. ft. 142,500 sq. ft. TOTAL 390,350 sq. ft. 179,650 sq. ft. 570,000 sq. ft. 6 Figure 3-1 — Site Map SW SCALE.t4 *I 'la .. ... ...... � y. w i - 1 d f 0 * i $L is A Z # +. 96 NEIGHBORING TORE-5 ULJOO 042� T " LLUWNUM AND METAL P9PE$D1 • ODI PAVEMENT.SOME RUNOFF ENTERS SUBJECT PROPERTY A 0. SMITH WATER SYSTIFUS DIVISION OF$TATE INOUSTRI ES �* &302 RALEIGH STREET C RARLOTTE-NC 213213 � 1H9EE ONME OklrFtALLS LEGEND PROPERTY BOUNDARY PIPED STORMWATER INFRASTRUCTURE - - - - - - - - - SITE OUTFALL DASIN BOUNDARY AND LABEL Q STORMWATER STRUCTURE SITE OUTFALL PLOW DIRECTION aLOCATION OF P07ENTIAL POLLUTANT SOURCE 7 Section 4 DESCRIPTION OF POTENTIAL POLLUTANT SOURCES Description of Industrial Processes In accordance with Part B-4 of Permit No. NCG030000 (dated July 1, 2021) the following is a narrative description of the industrial processes present which have the potential to expose polluting materials to stormwater discharges. These activities are summarized in Table 4-1 and are shown on the site drainage map (Figure 3-1). Table 4-1 also identifies the potential pollutants associated with each industrial activity. Table 4-1 — Inventory of Exposed Materials Potential Pollutant Source Potential Pollutants 1 . Paint Shed Oil & grease 2. Air Compressors Oil & grease 3. Cooling Tower Water treatment chemicals 4. Empty Washer Chemical Tote Storage Area Phosphates & alkaline cleaners 5. Wooden Pallet Storage Areas Solids 6. Scrap / Solid Waste Storage Luggers Solids, oil & grease, metals 7. Material Handling Bin Storage Area Solids, oil & grease 1. Paint Shed — The Paint Shed is located east of Building A and is used for the storage of 55-gallon drums of hydraulic oil, lubricating oils, used oils and hazardous and nonhazardous chemical wastes. It got its name because it was previously used to store drums of liquid coatings prior to the conversion to powder coating at this facility. 2. Air Compressors — Several air compressors are located outside to the east of Building A. 3. Cooling Tower — A small cooling tower is located outside at the southeast corner of Building A. 4. Empty Washer Chemical Tote Storage Area — Empty 275-gallon plastic totes equipped with steel cages are stored at the southeast corner of the site. 5. Wooden Pallet Storage Areas — Wooden pallets are stored near the southeast corner of the site and along the east side of Building C. 6. Scrap /Solid Waste Storage Luggers— Luggers are used for the collection of scrap 8 metal, trash/rubbish, wood and cardboard. These are staged in the southeast corner of the main yard area south of Building A. 7. Material Handling Bin Storage Area — Empty metal material handling bins are stored at the southwest corner of the site on an impervious surface. Summary of Significant Potential Pollution Sources Based upon a review of the inventory of exposed materials, it was determined that the following areas have the greatest potential for contributing significant pollutant(s) to stormwater discharges: • Paint shed — Source 1 • Scrap / solid waste storage luggers — Source 6 SARA 313 Water Priority Chemicals Based upon a review of 2007 manufacturing operations, the facility does not use any SARA 313 chemicals in amounts that exceed the TRI reporting thresholds. Because of this the facility is not required to submit a Toxics Release Inventory. Therefore by definition, the facility does not handle any SARA 313 water priority chemicals. 9 Section 5 FEASIBILITY REVIEW OF CHANGING OPERATIONS According to Part B-5 of Permit No. NCG030000 (dated July 1, 2021), a review of the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to rainfall and runoff flows must be performed. Wherever practical, the permittee shall prevent exposure of all storage areas, material handling operations, and manufacturing or fueling operations. In areas where elimination of exposure is not practical, the review shall document the feasibility of diverting the stormwater runoff away from areas of potential contamination. The facility already employs a number of traditional stormwater management practices to control and manage the quality and quantity of stormwater runoff. These include: • Covering of potential pollutant sources • Grading of industrial activity areas to divert storm flow from material exposure • Use of grass lined channels for stormwater conveyance • Containment basins or diking around chemical storage areas Based upon a thorough review of site operations, no evidence of additional practices are needed at this time; however, although no leaks were observed, the site has several dumpsters without covers which could lead to future leaks if not addressed. 10 Section 6 EVALUATION OF STORMWATER OUTFALLS As required by Part B-6 of Permit No. NCG030000 (dated July 1, 2021), the permittee shall evaluate all stormwater outfalls on an annual basis for the presence of non- stormwater discharges. If no non-stormwater discharges are present, the permittee shall certify the evaluation results. This certification shall be dated and signed in accordance with the requirements found in Part H-1 (Signatory Requirements) of Permit No. NCG030000 and retained with the SWPPP. If non-stormwater discharges are present, the permittee shall identify the source and record whether the discharge is otherwise permitted by rule or a different permit. The permittee shall evaluate the environmental significance of the non-stormwater discharges. A summary written record shall be dated and signed in accordance with the requirements found in Part H-1 (Signatory Requirements) of Permit No. NCG030000 and retained with the SWPPP. Because all discharges from the site that enter the municipal storm sewer system must first flow over land into an rm drain, any non-stormwater discharges that occur will be visually observable. One source of a non-stormwater discharge that may periodically be present is water used for the pressure testing of water tank diaphragms. An examination for the presence of non-stormwater discharges is made during the routine monthly inspections (See Section 11 Preventative Maintenance and Good Housekeeping and Appendix F). 11 Section 7 STORMWATER BMP SUMMARY There are existing stormwater best management practices (BMPs) associated with each of the specific potential pollutant sources previously identified in Section 4. These specific stormwater control measures are summarized below in Table 7-1. As required by Part B-7 of Permit No. NCG030000 (dated July 1, 2021), the installation and implementation of BMPs is based on the assessment of the potential for sources to contribute significant quantities of pollutants to stormwater discharges and on data collected through monitoring of stormwater discharges. The BMP Summary shall be reviewed and updated annually. The BMP Summary shall include: • Written record of the specific rational for installation and implementation of the selected site BMPs. o Outfall 001 is located south of the facility in a railroad right of way and captures sheet flow runoff from the southern portion of the site, as well as runoff in the railroad right of way. Outfall 002 is a storm sewer inlet that is located in the southwestern portion of the yard that captures runoff from the yard and a portion of the roof runoff from Buildings A, B and C. Outfall 003 is a storm sewer inlet that is located in the northeastern portion of the yard that captures runoff from the yard and a portion of the roof runoff from Buildings A and C. Each of the outfalls is located to collect runoff from the site. • Structural and nonstructural practices to minimize the exposure and transport of materials in stormwater. o At this time, Outfalls 001, 002, and 003 do not have structural practices being implemented on site. The facility has recently replaced/repaired their roofs, which was a previous source of pollutant contamination in the stormwater runoff. The facility also performs periodic sweeping and has dumpsters located from outfall locations. • BMPs for vehicle maintenance activities. o No vehicular maintenance is performed at the subject facility. Maintenance by a third party is performed on forklifts internal to the buildings. 12 Table 7-1 — Summary of Existing Control Measures POTENTIAL POLLUTANT SOURCE EXISTING CONTROL MEASURE 1. Paint Shed a) Canopy roof over entire area b) Adequate secondary containment c) Control measures handled in SPCC plan d Periodic inspections of area 2. Air Compressors a) Canopy roof over compressors b) Scheduled preventive maintenance c) Periodic inspections of area 3. Cooling Tower a) Canopy roof over tower b) Scheduled preventive maintenance c) Periodic inspections of area 4. Empty Washer Chemical a)Bungs and valves tightly closed Tote Storage Area b)Periodic inspections of area 5. Wooden Pallet Storage Areas a) Good housekeeping is practiced b) Periodic inspections of area 6. Scrap / Solid Waste Storage Luggers a)Good housekeeping is practiced b)Luggers have sealed bottoms c Periodic inspections of area 7. Material Handling Bin Storage Area a)Good housekeeping is practiced b Periodic inspections of area 13 Section 8 SECONDARY CONTAINMENT PLAN In order to prevent leaks and spills from contaminating stormwater runoff, Part B-8 of Permit No. NCG030000 (dated July 1, 2021) requires secondary containment for: • bulk storage of liquid materials including petroleum products; • storage in any amount of water priority chemicals listed in Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA); • and storage of hazardous substances in any amount. For facilities subject to the federal Spill Prevention, Control, and Countermeasure (SPCC) regulation, the SPCC Plan may be used to support compliance with this requirement. The Secondary Containment Plan shall include: • A table or summary of tanks and stored materials equipped with secondary containment systems; • Manually activated valves or other similar devices that are securely closed with a locking mechanism if the secondary containment devices are connected to the stormwater conveyance system; • A commitment to visually observe any accumulated stormwater prior to release for color, foam, outfall staining, visible sheens, and dry weather flow; • A commitment to only release accumulated stormwater that is uncontaminated by any material; and • Records on every release from a secondary containment system that include: the individual making the observation, a description of the accumulated stormwater, and the date and time of the release. These records shall be kept for a period of five (5) years. The Paint Shed, located east of Building A, is used for the storage of 55-gallon drums of hydraulic oil, lubricating oils, used oils and hazardous and nonhazardous wastes. The entire area is provided with a canopy roof and the drum storage area is surrounded by two-inch angle iron that provides approximately 2,500 gallons of secondary containment. The hazardous waste storage area is fenced and surrounded by a twelve-inch concrete containment curb. Access to this area is via a concrete ramp. Other than the Paint Shed, there are no other outside chemical storage areas. A copy of the facility's Secondary Containment Plan is enclosed in the Spill Prevention Control, and Countermeasure Plan enclosed in Appendix E. 14 Section 9 SPILL PREVENTION AND RESPONSE PROCEDURES Part B-9 of Permit No. NCG030000 (dated July 1, 2021) requires that a responsible person shall be on-site at all times during facility operations that have potential to contaminate stormwater runoff through spills or exposure of materials associated with the facility operations. The Spill Prevention and Response Procedures (SPRP) shall include: • An assessment of areas of the facility where there is the potential for spills; • A list of trained facility personnel responsible for implementing the SPRP; • A signed and dated acknowledgement in which staff members accept responsibilities for the SPRP; • An inventory of spill response materials and equipment and the locations for storing these items; • Written procedures for proper cleanup and disposal of spilled materials; and • A list of significant spills or leaks of pollutants that have occurred during the previous three 3) years and any corrective actions taken to mitigate spill impacts or the notation that no spills have occurred. This list shall be updated on annual basis. The facility's Spill Prevention Control and Countermeasure (SPCC) Plan describes the preventive measures in place to prevent the release of oil and other petroleum products to the environment and contains established procedures for responding to releases that may occur. This Plan fulfills the federal SPCC regulation compliance requirements of the permit. See Appendix E for the facility's SPCC Plan. There are three (3) areas at the facility where oils or chemicals are stored in quantities where the potential for spills to occur exists. These include: 1. Paint Shed — Source 1 2. Washer Chemical Tote Staging Area — not identified previously as a stormwater source because these chemicals are staged inside Building C prior to being used. 3. Empty Washer Chemical Tote Storage Area — Source 4 The Paint Shed is designed to provide adequate secondary containment for all materials stored in this area. The washer chemical tote staging area is provided with secondary containment by means of a concrete containment berm. Totes of washer chemicals are stored in Building C and are provided with adequate secondary containment by virtue of the absence of floor drains within the building. 15 Section 10 SOLVENT MANAGEMENT PLAN The Solvent Management Plan, also known as the Toxic Organic Management Plan, is required by Part B-10 of Permit No. NCG030000 (dated July 1, 2021) and shall include: • an annually updated and quantified inventory of solvents present on site during the previous three years; • a narrative description of the facility locations and uses of solvents; • the method of disposal, including quantities disposed on -site and off-site; and • the management procedures and engineering measures for assuring that solvents do not spill or leak into stormwater. The facility's Plan contains procedures for managing the use and handling of toxic organic chemicals to prevent their release into either the sanitary or storm sewer systems. A Toxic Organic Management Plan (aka a Solvent Control Plan)for the facility is enclosed with the SPCC in Appendix E and contains procedures for managing the use and handling of toxic organic chemicals to prevent their release into either the sanitary or storm sewer systems. 16 Section 11 PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING Preventative Maintenance and Good Housekeeping Program Part B-11 of Permit No. NCG030000 (dated July 1, 2021) requires a preventative maintenance and good housekeeping program (PMGHP) to be developed and implemented for any stormwater management control systems or plant systems which have the ability to impact stormwater discharges. The PMGHP ensures that good housekeeping practices are incorporated into the facility's stormwater management programs and that the facility practices good housekeeping in those areas where significant potential exists for material contact with stormwater. The PMGHP shall include: • A schedule of inspections, maintenance, and housekeeping measures for industrial activity areas. For the facility these areas include: o Material loading and unloading areas o Pallet storage areas o Empty washer chemical tote storage area o Scrap material storage luggers Periodic inspections will be made of these areas to assure that they are maintained in a clean and orderly manner. The need to practice good housekeeping in these areas will be incorporated into appropriate employee training programs. Inspections shall occur at a minimum on a quarterly schedule (January - March, April - June, July - September, October - December). These monthly inspections are documented on a Periodic Inspection Checklist (see Appendix F). These checklists identify the date of the inspection, the person(s) conducting the inspection, areas inspected, problems or deficiencies found, and appropriate corrective actions. The Pollution Prevention Coordinator retains the completed Periodic Inspection Checklists in a separate file. Any exceptions noted during these inspections are documented on a written exception report and distributed to appropriate personnel for corrective action where required. • A plan for disposing spent lubricants and fuels properly and in accordance with applicable federal disposal regulations. • A record of inspections, maintenance, and housekeeping activities. The facility does not currently have any stormwater management control systems in place that require periodic preventive maintenance. There are several air compressors and a small cooling tower that are located outside that have the ability to impact stormwater discharges. These devices are periodically inspected in accordance with the facility's preventive maintenance schedule for all major pieces of operating equipment. 17 Sediment and Erosion Control There are presently no areas on the site where erosion can occur to any significant degree. The majority of the land surface is either paved, grassed, or occupied by a physical structure. Filters installed at outfall structures should be inspected quarterly and after significant rainfall events for sediment collection from the paved vehicular areas. Sediment should be removed from the filters as needed to ensure the filters function as designed. 18 Section 12 EMPLOYEE TRAINING Part B-12 of Permit No. NCG030000 (dated July 1, 2021) requires that periodic training be developed and provided on an annual basis with respect to the content of this plan for facility personnel responsible for operations that have the potential to contaminate stormwater runoff. Employees are trained at the time of hire if appropriate and annual reviews on the procedures identified in this plan are conducted thereafter. All aspects of this and any associated documents are reviewed during these training sessions. The members of the Pollution Prevention Team (as presented in Appendix C) and any employee who is involved in the use, storage, or transfer of materials outside the facility or within the loading/unloading areas at the plant will be familiar with the contents of this plan. Records from the training sessions are retained by the Pollution Prevention Coordinator, and include the date of the training session, leader of the training session, attendees' names and signatures, and a brief description of the topics covered. As situations change and the plan is updated, the employees will be informed of the modifications to the plan by means of such training sessions. These annual employee training sessions will, at a minimum cover the following topics: • General stormwater awareness; • The provisions of the current NCG030000 general permit. • Spill response training; • Used oil management; • Spent solvent management; • Secondary containment releases; • Fueling procedures; • Disposal of spent abrasives; • Sanding, painting, and blasting procedures, and • Used battery management. 19 Section 13 REPRESENTATIVE OUTFALL STATUS If a facility has multiple discharge locations with substantially identical stormwater discharges that are required to be sampled, the permittee may petition the Director for representative outfall status ROS). If it is established that the stormwater discharges are substantially identical and the permittee is granted representative outfall status, then analytical sampling requirements may be performed at a reduced number of outfalls. If the Division has granted ROS, documentation from the Division shall be part of the SWPPP. The permittee shall notify the Division of any site or activity modifications that result in a change to ROS. The permittee must request reissuance of ROS by submitting a written request to the Division's Central Office within thirty (30) days prior to the expiration of this General Permit to maintain ROS. At this time, the facility feels it is reasonable to monitor Outfalls 002 and 003 and is not seeking Representative Outfall Status. If after continued sampling it is determined that pollutants are substantially identical, the facility may opt to seek ROS. 20 Section 14 ANNUAL SWPPP REVIEW AND UPDATE In addition to the periodic inspections discussed in Section 11, an annual comprehensive plan review is conducted in order to assure that all components of this plan remain current and accurate. This annual review is required by Part B-14 of Permit No. NCG030000 (dated July 1 , 2021). The annual SWPPP review shall include a review and comparison of sample analytical data to benchmark values over the past year, including a discussion about Tiered Response status. The Division's Annual Summary Data Monitoring Form shall be used. Where revisions or modifications to the plan are deemed necessary, they are incorporated into this plan and implemented as soon as possible. A report summarizing the results of this annual review and any necessary follow-up actions is prepared and maintained by the Environmental Coordinator. An example of this form is provided in Appendix G. In accordance with Part B-14 of Permit No. NCG030000 (dated July 1, 2021), this Storm Water Pollution Prevention Plan will be amended in accordance with the following requirements: 1. Whenever there is a change in design, construction, operation, or maintenance of the facility, which has a significant effect on the potential for the discharge of pollutants to surface waters; or 2. If NCDEQ provides notification that the plan does not meet one or more of the minimum permit requirements. Within 30 days of such notice, the facility must submit a time schedule to the NCDEQ for modifying this plan to meet the minimum permit requirements. The facility must also provide written certification to the NCDEQ that the required changes have been made. 21 Section 15 ANNUAL ON-LINE SWPPP CERTIFICATION After the Division's ePermitting system develops the capability to receive this information, the permittee shall submit an on-line certification that the annual SWPPP review and update has been completed in a manner that meets the conditions of this permit. Section 16 NOTICE TO MODIFY THE SWPPP The Director may notify the permittee when the SWPPP does not meet one or more of the minimum requirements of the permit. Within 30 days of such notice, the permittee shall submit a time schedule to the Director for modifying the SWPPP to meet minimum requirements. Upon completion of the modifications, the permittee shall provide certification in writing in accordance with HH1 and HH7 of this permit to the Director that the changes have been made. Section 17 SWPPP DOCUMENTATION The Environmental Coordinator/Pollution Prevention Coordinator will retain a copy of all Periodic Inspection Report Sheets, Preventive Maintenance Report Sheets, Employee Training Records, Spill Reports, and Annual Site Compliance Evaluations. Part B-17 of Permit No. NCG030000 (dated July 1, 2021) requires copies of the SWPPP to be maintained on-site and be available electronically to the Division upon request. These records or copies shall be maintained for a period of at least five (5) years. This period may be extended by request of the Director at any time [40 CFR 122. 41]. 22 Section 18 STORMWATER MONITORING PLAN Although not specifically required by Permit No. NCG030000 (dated July 1, 2021), A. O. Smith State Industries believes it is appropriate to include within this plan a summary of the stormwater monitoring plan developed for the facility. This monitoring plan was prepared to comply with the monitoring requirements found in Parts D and E of Permit No. NCG030000. QUALITATIVE MONITORING REQUIREMENTS (PART D) In addition to the quarterly analytical monitoring requirements described above, visual inspections of stormwater runoff entering Outfalls 002 and 003 must be made during the same storm event from which samples are collected for analytical monitoring purposes. These visual inspections must consider the following parameters: ➢ Color ➢ Odor ➢ Clarity ➢ Floating solids ➢ Suspended solids ➢ Foam ➢ Oil sheen ➢ Erosion or deposition at the outfall ➢ Other obvious indicators of stormwater pollution The results of this qualitative monitoring must be recorded on Stormwater Discharge Outfall Qualitative Monitoring Report form SWU-242 (Appendix H). These results do not need to be submitted to NCDEQ but must be maintained on-site as part of this SWPPP. If the qualitative monitoring indicates that the SWPPP or existing stormwater BMPs are ineffective, or that significant stormwater contamination is present, then the permittee shall investigate potential causes, evaluate the feasibility of corrective actions, and implement those feasible corrective actions withing sixty (60) days. ANALYTICAL MONITORING REQUIREMENTS (PART E) Pollutants to be Sampled At a minimum, Part E-2 of Permit No. NCG030000 requires monitoring for the following pollutants: ➢ pH ➢ Oil and Grease ➢ Total Suspended Solids (TSS) 23 ➢ Chemical Oxygen Demand (COD) ➢ Lead ➢ Copper ➢ Zinc ➢ Total Rainfall Storm Parameters to be Recorded For each storm event sampled, the following storm parameters are recorded and reported: ➢ Date of storm event ➢ Duration of storm event (in hours) ➢ Total precipitation received during storm event ➢ Time duration since last measurable storm event (greater than 0.1 inch rainfall) Sample Location Samples will be collected from Outfalls 002 and 003, as these are the outfalls that receive the majority of stormwater runoff from areas where industrial activities are present. Sample Type and Frequency Grab samples of the stormwater discharge entering Outfalls 002 and 003 must be collected within thirty minutes of the time stormwater begins to flow into the outfall. The samples must be collected during a storm event that meets the definition of a representative storm event. A representative storm event is defined as a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to ten (10) consecutive hours of no precipitation. Samples must be collected quarterly from four separate monitoring periods per year unless the facility is in Tier Two or Tier Three status. A minimum of 30 days must separate each sample event during the following periods: ➢ January 1 — March 31 ➢ April 1 — June 30 ➢ July 1 — September 30 ➢ October 1 — December 31 Benchmark Values for Analytical Monitoring Requirements The results of all analytical monitoring must be compared to the benchmark values contained in the following table. 24 Parameter Benchmark Value pH Within range 6.0 — 9.0 Oil and Grease 15 mg/I Total Suspended Solids (TSS) 100 m /I Chemical Oxygen Demand (COD) 120 mg/L Lead T 0.075 m /I Copper (Cu) 0.01 mg/L Zinc (Zn) 0.126 mg/I An exceedance of any benchmark value shall require a tiered response for that outfall. A single exceedance of a benchmark value shall require a Tier One response for that outfall. Two benchmark value exceedances in a row shall require a Tier Two response for that outfall. Four benchmark exceedances for a parameter within the permit term shall require a Tier Three response for that outfall. Tier One (Section E-5) — Single Benchmark Exceedance The facility will remain in Tier One status until three consecutive samples are under the benchmark or are inside the benchmark range for all parameters. a) If any sampling result is above the benchmark value for any parameter at any outfall, then the permittee shall respond in accordance with Table 3 in Section E- 5 of Permit No. NCG030000 (dated July 1, 2021) to identify and address the source of that exceedance for that parameter. b) Each required response shall be documented in the SWPPP as each action occurs including; the date and value of the benchmark exceedance, the date the Division' s Regional Office was notified of the exceedance, the inspection date, the personnel conducting the inspection, the selected feasible actions, and the date the selected feasible actions were completed. A response log is included in Appendix J. c) Each exceedance of a benchmark parameter shall individually require a Tier One response. d) The Tier One response shall be in accordance with Table 3 in Section E-5 of Permit No. NCG030000 (dated July 1, 2021). Tier 2 (Section E-6) — Two Consecutive Benchmark Exceedances The facility will remain in Tier Two status until three consecutive samples are under the benchmark or are inside the benchmark range for all parameters. a) If any two consecutive sampling results in a row for the same parameter are above the benchmark value at an outfall, then the permittee shall respond in accordance with Table 4 in Section E-6 of Permit No. NCG030000 (dated July 1, 2021) to identify and address the source of exceedances for that parameter. Immediately institute monthly monitoring for all parameters at every outfall where a sampling 25 result exceeded the benchmark value for two consecutive samples. Monthly monitoring (both analytical and qualitative) shall continue until three consecutive sample results are below the benchmark values, or within the benchmark range. b) After implementing the specific feasible courses of action, perform monthly monitoring at every outfall where a sampling result exceeded the benchmark value for two consecutive samples for all parameters until three samples in a row are below the benchmark value or are inside the benchmark range. Maintain a record of the Tier Two response in the SWPPP (Appendix K). c) Each required response shall be documented in the SWPPP as each action occurs including; the dates and values of the benchmark exceedances, the date the Division's Regional Office was notified of the consecutive exceedances, the inspection date, the personnel conducting the inspection, the selected feasible actions, the date the selected feasible actions were completed, and the monthly monitoring results. d) Each pair of two consecutive exceedances of a single benchmark parameter at a single outfall shall constitute an event that requires a Tier Two response. e) The Tier Two response shall be in accordance with Table 4 in Section E-6 of Permit No. NCG030000 (dated July 1, 2021). f) Alternatively, in lieu of the Tier Two response, the permittee may, after two consecutive exceedances, implement a Tier Three response. Tier 3 (Section E-7) — Four Benchmark Exceedances Within the Permit Term The facility will remain in Tier Three status until three consecutive samples are under the benchmark or are inside the benchmark range for all parameters. a) If any four sampling results within the permit term for any single parameter are above the benchmark value at a sampled outfall, then the permittee shall respond in accordance with Table 5 in Section E-7 of Permit No. NCG030000 (dated July 1, 2021) to identify and address the source of exceedances for that parameter at that outfall. b) The permittee shall prepare a written Action Plan and submit to the Division' s Regional Office for review and approval within thirty (30) days of receipt of the fourth analytic monitoring data point that exceeds the benchmark value. At a minimum, the Action Plan shall include: i. documentation of the four benchmark exceedances, ii. an inspection report that covers the industrial activities within the drainage area of the outfall with the exceedances (including the date of the inspection and the personnel conducting the inspection), iii. an evaluation of standard operating procedures and good housekeeping procedures, iv. identification of the source(s) of exceedances, V. specific actions that will be taken to remedy the identified source(s) with a schedule for completing those actions, and vi. a monitoring plan to verify that the Action Plan has addressed the source(s). c) The permittee shall keep the Action Plan in the SWPPP and document when each 26 specific action was carried out and by whom. d) The permittee shall contact the Division' s Regional Office when all actions in the Action Plan are completed. e) The Tier Three response shall be in accordance with Table 5 in Section E-7 of Permit No. NCG030000 (dated July 1, 2021). SUBMISSION OF ANALYTICAL MONITORING RESULTS In accordance with Part F of Permit No. NCG030000, all samples analyzed in accordance with the terms of Permit No. NCG030000 must be submitted to the Division of Water Quality on the Stormwater Discharge Outfall Monitoring Report form SWU-264 provided by NCDEQ (Appendix 1). These monitoring reports must be submitted no later than 30 days from the date the facility receives the sampling results from the laboratory. The DMR shall be signed by a person meeting the Signatory requirements in Section H-1 of Permit No. NCG030000. In accordance with Section F-2, paper reports should be submitted to the following address: Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, North Carolina 28115 Electronic submittal of the DMR forms is available at this time. The permittee shall register in eDMR and begin reporting discharge monitoring data upon completion of the registration. 27 APPENDIX A CERTIFICATE OF COVERAGE NCG030486 APPENDIX B GENERAL STORM WATER PERMIT NCG030000 APPENDIX C RESPONSIBLE PARTIES RESPONSIBLE PARTIES Name Title Alexandra Rice Environmental Coordinator Laura Viers Plant Manager Brandon Woo Senior Project Engineer Kevin Clark Distribution Manager Scott Vernon Maintenance Manager Bradley Crosby Production Manager Kurt Sala EHS Manager APPENDIX D NOT USED APPENDIX E SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN APPENDIX F PERIODIC INSPECTION CHECKLIST STATE INDUSTRIES —CHARLOTTE MONTHLY STORMWATER INSPECTION POTENTIAL POLLUTANT SOURCE STORM WATER CONTROLS (See Map Below) ADEQUATE (Y/N) Pole Barn ➢ All drums stored within containment area ➢ All drums properly sealed & labeled ➢ Any leakage from stored drums ➢ Adequate spill response supplies available ➢ No evidence of chemical sheen on any ponding water ➢ Canopy roof over entire area ➢ Adequate secondary containment Air Compressors ➢ No evidence of oil leakage from compressor ➢ Canopy roof over compressors ➢ Scheduled preventative maintenance as needed Cooling Tower ➢ No evidence of chemical leakage from tower ➢ Canopy over tower ➢ Scheduled preventative maintenance as needed Empty Washer Chemical Tote Storage Area ➢ All bungs properly closed ➢ No leaking valves ➢ No evidence of chemical leakage on surrounding ground surface ➢ No cracks in storage containers Wooden Pallet Storage Areas(s) ➢ No oil or chemical soaked pallets stored outside ➢ General housekeeping of areas Scrap/Solid Waste Storage Luggers ➢ All scrap materials placed in appropriate lugger ➢ No evidence of fluid leakage from luggers ➢ No evidence of scrap materials on surrounding ground surface ➢ No evidence of leaking from storage luggers Material Handling Bin Storage Area ➢ No evidence of fluid leakage or staining on surrounding ground surface ➢ General housekeeping of areas NON-STORMWATER DISCHARGES Were any non-stormwater discharges present at Outfall 002? Yes No Were any non-stormwater discharges present at Outfall 003? Yes No OUTFALL FILTERS PERIODIC INSPECTION AND MAINTENANCE OUTFALL ADEQUATE? Y/N Outfall 002 Filter ➢ Is filter pulled taut on all edges (there should be no evident edges of the filter where water can bypass) ➢ Is filter cleared of sediment? ➢ Perform monthly maintenance to remove sediment and debris from within filter. Inspect replacement of filter to ensure correct installation. Outfall 003 Filter ➢ Is filter pulled taut on all edges (there should be no evident edges of the filter where water can bypass) ➢ Is filter cleared of sediment? ➢ Perform monthly maintenance to remove sediment and debris from within filter. Inspect replacement of filter to ensure correct installation. N � , •� - C�6W~ ' Vim via- y � 003 + BLDG A 2 • � r • 1 BLDG C 00 6 55 4 6 IRT C w t U BLDG B , 001 LRQAD , A.O.SMITH WATER SYSTEMS DIVISION OF STATE INDUS I HIES 4302 RALEI6M STREET CHARLOTTE.NC 28213 f THREE ONSITE OUTFALLS - Table 3-1 Potential Pollutant Sources Pole Barn Air Compressors Cooling Tower Empty Washer Chemical Tote Storage Area Wooden Pallet Storage Areas Scrap / Solid Waste Storage Luggers Material Handling Bin Storage Area COMMENTS: Conducted By: Date: APPENDIX G ANNUAL PLAN REVIEWS ANNUAL PLAN REVIEW Water Systems Division of State Industries 4302 Raleigh Street Charlotte, North Carolina 28213 Has the SWPPP been amended for any new construction that YES NO would affect the site map or drainage conditions at the facility? Has the SWPPP been amended for any change in facility operations that could- be identified as new source areas for YES NO contamination of storm water? Are there any maintenance of material handling activities YES NO conducted outdoors that have not been addressed in the SWPPP? Are outside areas kept in a neat and orderly condition? YES NO Are regular housekeeping inspections made? YES NO Do you see spots, pools, puddles, or other traces of oils, grease, or YES NO other chemicals on the ground? Are particulates on the ground from industrial operations or YES NO processes being controlled? Do you see leaking equipment, pipes or containers? YES NO Do drips, spills, or leaks occur when materials are being transferred YES NO from one source to another? Are drips or leaks from equipment of machinery being controlled? YES NO Are cleanup procedures used for spilled solids? YES NO Are absorbent materials (floor dry, kitty litter, etc.) regularly used in YES NO certain areas to absorb spills? Can you find discoloration, residue, or corrosion on the roof or YES NO around vents or pipes that ventilate or drain work areas? Are Best Management Practices implemented to reduce or eliminate contamination of storm water from source areas at the YES NO facility? Are Best Management Practices adequately maintained? YES NO Are there significant changes that will have to be made to the SWPPP to correct any inadequacies that the Plan may have to YES NO effectively control a discharge of contaminated storm water from your facility? ANNUAL PLAN REVIEW - PAGE 2 Comments: Name of Person Conducting Job Title: Inspection: Date of Inspection: Certification of Permit Compliance: YES NO Will SWPPP require updating as a YES NO result of this Annual Plan Review?: Signature: APPENDIX H QUALITATIVE MONITORING REPORT FORM SWU-242 APPENDIX I ANALYTICAL DISCHARGE MONITORING REPORT FORM SWU-264 APPENDIX J TIER 1 RESPONSE LOG TIER 1 (SINGLE BENCHMARK EXCEEDANCE) RESPONSE LOG DATE OF DATE OF NOTIFICATION INSPECTION INSPECTION SELECTED COMPLETION DATE PARAMETER VALUE TO DIVISION'S DATE PERSONNEL FEASIBLE FOR REGIONAL ACTIONS FEASIBLE OFFICE ACTIONS Kimberly Seddon Mark Van Auken 1/17/2023 Zinc 571 ug/I 2/24/2023 1/09/2023 Alexandra Rice Install Filter Mats at (Outfall 002) Outfall March 2023 Laura Viers Brandon Woo Kimberly Seddon Mark Van Auken 1/17/2023 Copper 10.3 ug/I 2/24/2023 1/09/2023 Alexandra Rice Install Filter Mats at (Outfall 003) Outfall March 2023 Laura Viers Brandon Woo APPENDIX K TIER 2 RESPONSE LOG TIER 2 (SINGLE BENCHMARK EXCEEDANCE) RESPONSE LOG DATE PARAMETER VALUE DATE OF NOTIFICATION TO INSPECTION INSPECTION DIVISION'S REGIONAL OFFICE DATE PERSONNEL