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HomeMy WebLinkAboutNCG030070_COMPLETE FILE - HISTORICAL_20181119STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. /V C& O3n o '7 0 DOC TYPE $HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ j[]�� YYYYM M D D ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR. Interim Director November 19, 2018 ABB Motors and Mechanical Attn: Jeff Moore 70 Reems Creek Road Weaverville, North Carolina 28787 Subject: Inspection and Regulatory Relief from Monthly Monitoring ABB Motors and Mechanical Inc. NPDES General Permit NCG030070 Buncombe County Dear Mr. Moore: Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection Isaiah Reed conducted at the subject facility on October 2, 2018. During the inspection, your facility was evaluated for continued regulatory relief from monthly monitoring due to exceedances of the benchmark value for Cu and Zn. The Industrial process observed was found to have a high potential to cause an impact to stormwater runoff that could result in the benchmark exceedances observed. Therefore, this facility does not currently meet the requirements necessary to obtain tier exceedance relief. As such, the permitee shall immediately investigate the exceedances and begin responses in accordance with the Tier Response procedure outlined on pages 9 and 10 of the General Permit (NCG030000) beginning with Tier 1. If the permitee can demonstrate that the Zn and Cu exceedances are due to something other than the industrial process, investigative research and monitoring to support that conclusion must be undertaken by the permitee to show what the non -industrial source of the benchmark exceedances is. The permitee can then petition the Department for regulatory relief, and a follow-up inspection will be performed. Please retain and append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit. If you have any questions or concerns, please contact Isaiah Reed at (828) 296-4500 or by e-mail at Isaiah. reed@ncdenr.aov or contact Stan Aiken at Stan. aiken .nedenrgov. Sincerely, Stanley E. Aike , GA Regional Engineer Division of Energy, Mineral and Land Resources Enclosure: Inspection Report North Carolina Department of Environmental Quality I Division of Energy, Mineral and land Resources Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778 828.296,4500 Permit: NCG030070 Owner - Facillty: Abb Motors and Mechanical Inc Inspection Date: 10/0212018 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 (USGS) map? ® ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ® ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? E ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? E ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? M ❑ ❑ ❑ # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? S ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® ❑ ❑ ❑ # Does the facility provide and document Empfoyee Training? ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ® ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ® ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Comment: Permit and Qutfalls 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? ❑ ❑ 0 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? M ❑ ❑ ❑ Comment: Page: 3 Permit: NCG030070 owner - Facility:Abb Motors and Mechanical Inc Inspection Date: 30102/2048 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? 91 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ® ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ® ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ® ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ® ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ® ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ® ❑ ❑ ❑ # Does the Plan include a BIVIP summary? ® ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? E! ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® ❑ ❑ ❑ # Does the facility provide and document Employee Training? ® ❑ ❑ ❑ # noes the Plan include a list of Responsible Party(s)? 91 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ® ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? 11 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ®❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? 90 ❑ ❑ ❑ Comment: Analytical Monitorinq Yes No NA NE Has the facility conducted its Analytical monitoring? ® ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑ Comment: Permit and Outfallis 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? ❑_ ❑ Im ❑ # Has the facility evaluated all illicit (non stormwater) discharges? B ❑ ❑ ❑ Comment: Page: 3 Permit: NCG030070 SOC: County: Buncombe Region: Asheville - Contact Person: Jeff L Moore Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Compliance inspection Repoli Effective: 11/16/17 Expiration: 10/31/18 Owner: Abb Motors and Mechanical Inc Effective: Expiration: Facility: ABB Motors and Mechanical 70 Reems Creek Rd Weaverville NC 28787 Title: Phone: 828-645-17013 Certification: Phone: Inspection Date: 10102!2018 Entry Time: 02:OOPM Exit Time: 04:OOPM Primary inspector: Isaiah L Reed Phone: 828-2964614 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater discharge COC Facility Status: ® Compliant Not Compliant Question Areas: ® storm Water (See attachment summary) Page: 1 Permit: NCG030070 Owner - Facility: Abb Motors and Mochanicai Inc Inspection Date: 10/02/2018 inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On October 2, 2018 this facility was inspected for compliance. Stan Aiken and myself met with Jeff Moore and Gary Massey on site. No major issues were observed during the review of the SWPPP. During the inspection, the following items were noted: 1) During the inspection, your facility was evaluated for continued regulatory relief from monthly monitoring due to exceedances of the benchmark value for Cu and Zn. The Industrial process observed was found to have a high potential to cause an impact to stormwater runoff that could result in the benchmark exceedances observed, Therefore, this facility does not currently meet the requirements necessary to obtain tier exceedance relief. As such, the permitee shall immediately investigate the exceedances and begin responses in accordance with the Tier Response procedure outlined on pages 9 and 10 of the General Permit (NCG030000) beginning with Tier 1. If the permitee can demonstrate that the Zn and Cu exceedances are due to something other than the industrial process, investigative research and monitoring to support that conclusion must be undertaken by the permitee to show what the non -industrial source of the benchmark exceedances is. The permitee can then petition the Department for regulatory relief, and a follow-up inspection will be performed. 2) The site map for the facility was not accurate to the conditions on site. The permitee is directed to develop a more accurate site map to appropriately describe the facility, and meet all requirements outlined on page 3 of the General Permit (NCG030000). If you have any questions, please contact this office at (828) 296-4614 Page: 2 Compliance Inspection Report Permit: NCG030070 SOC. County: Buncombe Region: Asheville Contact Person: Jeff L Moore Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Effective: 11/16117 Expiration: 10/31/18 Owner: Abb Motors and Mechanical Inc Effective: Expiration: Facility: ABB Motors and Mechanical 70 Reems Creek Rd Inspection Date: 1010212018 Primary Inspector: Isaiah L Reed Secondary Inspector(s): Title: Entry Time: 0ZOOPM Certification: Weaverville NC 28787 Phone: 828-645-1709 Phone: Exit Time: 04:OOPM Phone: 828-296-4614 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COG Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NCG030070 Owner - Facility: Abb Motors and Mechanical Inc Inspection Date: 10/02/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On October 2, 2018 this facility was inspected for compliance. Stan Aiken and myself met with Jeff Moore and Gary Massey on site. No major issues were observed during the review of the SWPPP. During the inspection, the following items were noted: 1) During the inspection, your facility was evaluated for continued regulatory relief from monthly monitoring due to exceedances of the benchmark value for Cu and Zn. The Industrial process observed was found to have a high potential to cause an impact to stormwater runoff that could result in the benchmark exceedances observed. Therefore, this facility does not currently meet the requirements necessary to obtain tier exceedance relief. As such, the permitee shall immediately investigate the exceedances and begin responses in accordance with the Tier Response procedure outlined on pages 9 and 10 of the General Permit (NCG030000) beginning with Tier 1. If the permitee can demonstrate that the Zn and Cu exceedances are due to something other than the industrial process, investigative research and monitoring to support that conclusion must be undertaken by the permitee to show what the non -industrial source of the benchmark exceedances is. The permitee can then petition the Department for regulatory relief, and a follow-up inspection will be performed. 2) The site map for the facility was not accurate to the conditions on site. The permitee is directed to develop a more accurate site map to appropriately describe the facility, and meet all requirements outlined on page 3 of the General Permit (NCG030000). If you have any questions, please contact this office at (828) 296-4614 Page: 2 April 257 2014 Department of Environment and Natural Resources Division of Water Quality Central Files 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Baldor Electric Company 70 Reems Creek Road Weavervilie, NC 28787 General Permit No. NCG0030070 Dear Sirs: Attached is a Tier I stormwater discharge monitoring report for Baldor Electric Company. Tier 12014 Stormwater Results Samples were collected on March 3.2014, during a `Representative Storm Event' from the four Discharge Points that have had metals benchmark exceedances. This sampling demonstrates that non -process related zinc continues to be a challenge for us to control, al! four Discharge Points exceeded the benchmark value. Baldor Electric Company believes that the stormwater metals concentrations at the Discharge Points are less than discharges at the three facility Outfalls due to adsorption in the vegetated areas between the two. Figure 1 shows the locations of Discharge Points and Outfalls. A co -current investigation showed that galvanized roofs and gutter/downspout systems that feed Discharge Points B, C. D, and G contributed significant zinc amounts to the March 3 stormwater event. Table 1 compares metals concentrations from the three roof sources to four Discharge Points. Table 1. Zinc Roof Contributions to Stormwater Discharge Point Stormwater Discharge Concentration (m /L) Roof Discharge Zinc Concentration (m /L Roof System Section B 4.429 0.0993 Casting Building (6) C 0.132 D 0.653 0.212 Main Building 10 & 7) 1 0.476 N/S 2012 Addition 12 6 N/S <0.010 Receiving Dock 5 & 11) Table l shows that the galvanized roof and gutter/downspout system for the Casting Storage Building contributes 23 to 75 percent of the zinc found in stormwater discharges. The Main Building gutter/downspout system and other equipment located on the roof (i.e., heating/air conditioning, ventilation stacks and fans, and flashing) contribute 32 percent of the zinc found in stormwater discharges. Please contact me with operational or compliance issues. Otherwise, contact Dan March of Pisgah Environmental Services at 828-768-3335 or via e-mail at Pisgah-air@vt.edu if you have questions or comments concerning technical aspects of this report. Sincerely, Baldor Electric Company Gary Massey Safety & Environmental Coordinator 828-645-1718 Attachments: Discharge Monitoring Report Analytical Report Stormwater Volume Calculations Baldor Clectric Company — Storm%vater Herbert, Laura C From: Daniel March < Pisgah -air@vt.edu> Sent: Monday, March 17, 2014 10:02 AM To: Herbert, Laura C Cc: Gary Massey Subject: Fwd: Baldor Electric Company, NPDES Stormwater Permit: Request for Regulatory Relief Attachments: 03132014111242-D00031314.pdf Laura, Thank you for your and Darlene Kuchen's stormwater guidance at Baldor Electric Company last month. You met all of Gary Massey's expectations for providing a clear summary of Baldor's status and what to expect in the future. Gary is very impressed Mth your letter as am I. We understand the conditions in the letter: i) Regulatory relief in the form of a collapsed Tier II - Tier II response for Outfalls B, C, and I for copper and zinc benchmarks only. 2) Continue Tier II monthly sampling for Outfall D for zinc and copper only. 3) DLR .rill consider regulatory relief for Outfall D for zinc and copper once the Babbitt Room control device is installed and analytical monitoring demonstrates compliance. 4) Baldor lA ill continue the industrial Best Management Practices and housekeeping activities to control metal discharges. If this practices are discontinued or copper or zinc discharges become significant stormwater exposure risks DLR v611 consider withdravring the Regulatory Relief provisions of your letter and re -instate the permit specified tiered response. Thanks, Dan ---------- Forwarded message ---------- From: Briggs, Magdalene <mandalene.briggs@ncdenr.yov> Date: Thu, Mar 13, 2014 at 11:19 AM Subject: Baldor Electric Company, NPDES Stormwater Permit: Request for Regulatory Relief To: "Georgoulias, Bethany" <bethany.geor og ulias@ncdenr.goN,>, " is ah-air c vt.edu" <p_i_sgah-air@vt.edu> Cc: "Herbert, Laura C" <laura.herbertc ncdenr. ov>, "Kucken, Darlene" <darlene.kuckennncdenr.gov> Magdalene Briggs - Mapdalene.Briggs@ncdenr.gov North Carolina Dept. of Environment and Natural Resources Asheville Regional office Division of Administration 2090 U.S. 70 Highway Swanmanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7043 Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third parties. Pisgah Environmental Services, LLC 9 Woodvale Avenue Asheville, NC 28804 www.pisp,ah-air.com 828-768-3335 - Cell 828-255-1092 - Fax 0 AAA NCDENR North Carolina Department of Environment and Natural Resources Division of Energy, Mineral, and Land Resources Land Quality Section Tracy Davis, PE, CPM Director March 13, 2014 F Pat McCrory, Govemor John E. Skvarla, Ill, Secretary Baldor Electric Company ATTN: Mr. Gary Massey, Safety and Environmental Coordinator 70 Reems Creek Road Weaverville, North Carolina 28787 SUBJECT: NPDES Stormwater Permit: Request for Regulatory Relief — Copper and Zinc Sampling Baldor Electric Company General Permit No: NCG0300001 COC No: NCG030070 Buncombe County Dear Mr. Massey: In response to your request for regulatory relief, NCDENR-Land Quality Section staff conducted a site inspection on February 28, 2014. The primary goal of the inspection was to evaluate the drainage to Outfalls B, C, D, and I and to insure that there are no illicit discharges at your facility. At the time of this inspection the facility was found to be in compliance with permit NCG030070 and no illicit discharges were discovered. Monthly monitoring has been triggered by two consecutive exceedances of the .zinc (Outfalls B, D, C, and 1) and copper benchmarks (Outfall C) at your facility. Please keep in mind that benchmark exceedances are NOT limit violations or violations of permit conditions; however, you are obligated to follow the tiered response actions outlined in your permit. Baldor Electric Company has been following the tiered response actions and therefore is in compliance with the permit. As part of tiered response, Baldor has initiated robust housekeeping actions that appear to have addressed some of the exposures (reference January 24, 2014 letter from you). An additional air control device is planned for the Babbitt Room in 2014 to address potential zinc exposures to stormwater as monitored in Outfall D. Based on this, your materials inventory review, and certification that industrial activities at Baldor pose little to no potential for release of copper and zinc into stormwater, with the exception of the Babbitt Room Zn-Cl process, we are granting regulatory relief in the form of a collapsed Tier 2 — Tier 3 response for Outfalls B, C, and I for the copper and zinc benchmarks only, for the remainder of this permit, set to expire on October 31, 2017. Asheville Regional Office, 2090 US Highway 70, Swannanoa, North Carolina, 28778-8211 Telephone 828-296-4500 Fax 828-299-7043 One httP://portal;ncdenr.oralweb/Ir/land-quality North Caro ina An Equal Opportunity / Affirmative Action Employer Naturally Mr. Gary Massey March 13, 2014 Page 2 of 2 Upon receipt of this letter, Baldor may resume the permit specified semiannual analytical monitoring for Outfalls B, C, and I. A benchmark exceedance of any other parameter listed in your permit will trigger tiered response actions as described in the general permit. You are instructed to continue Tier II analytical monthly sampling for Outfall D for zinc and copper only. All other benchmarks (pH, TSS, O & G, Lead) shall be monitored on a semiannual basis, unless a tiered response is triggered for these specific benchmarks. Once the Babbitt Room control device is installed and monthly analytical results are available demonstrating effect of this control, we will consider a review of your request for regulatory relief of Tier 2 monitoring for Outfall D. This decision only applies to the copper and zinc benchmarks. A benchmark exceedance of any other parameter listed in your permit will trigger tiered response actions as described in the general permit. You must notify this office in writing, within five business days, if you become aware of any significant source of copper or zinc at your facility that has the potential to be exposed to stormwater. The relief granted in this letter is contingent upon the current industrial practices and housekeeping actions at Baldor. If industrial practices change and copper or zinc does become a significant stormwater exposure risk then this office reserves the right to withdraw this decision and reinstate the permit specified tiered response or other actions that may be warranted by the new set of circumstances, Attached is a copy of the February 28, 2014 inspection report for your review. Please retain and append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit. If you have any questions or comments concerning this letter, please contact Darlene Kucken or me at (828) 296-4500. Sincerely, Laura Herbert, PE Regional Engineer Enclosure ec: Bethany Georgoulias, RCO Dan March, Pisgah Environmental Services, LLC ([pisgah-air a@vt.edu) Permit: NGG030070 SOC: County: Buncombe Region: Asheville Compliance Inspection Report Effective: 11/01/12 Expiration: 10/31/17 Effective: Expiration: Contact Person: John Reno Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Title: Inspection Date: 0212812014 Entry Time: 01:00 PM Primary Inspector: Darlene J Kucken Secondary Inspector(s): Laura C Herbert Certification: Owner: Baldor Electric Company Facility: Baldor Electric Company 70 Reems Creek Rd Weaverville NC 28787 Phone: 828-645-4235 Exit Time: 03:30 PM Phone: Phone: Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ■ Compliant ❑ Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCG030070 Owner - Facility: Baldor Electric Company Inspection Date: 0212812014 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Copper, Zinc and Lead benchmarks were exceeded and Tier II monitoring was initiated for Copper and Zinc. Baldor initiated several internal houskeeping practices that resulted in lower values in subsequent sampling. Baldor asked for relief of some of the Tier II monitoring. A letter was sent by Laura Herbert allowing for some relief of parameters. Outfall D remains in Tier 11 response pending the installation and evaluation of the air control device on the Babbitt Room. Tha facility is in compliance. Page: 2 Permit: NCG030070 Owner - Facility: Baldor Electric Company Inspection Date- 0212812014 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? ■ ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ■ ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ # 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? ■ ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ■ ❑ ❑ n # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevendon and Response Plan (SPRP)? ■ Cl ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ Cl ❑ ❑ # Does the facility provide and document Employee Training? ■ ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ■ ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? IeJ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ Q Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ■ ❑ D ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ■ ❑ ❑ ❑ 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? ■ ❑ 0 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ Comment: Page: 3 AF ` NCDENR North Carolina Department of Environment and Natural Resources Division of Energy, Mineral, and Land Resources • Land Quality Section Tracy Davis, PE, CPM Director March 13, 2014 Pat McCrory, Governor John E. Skvarla, III, Secretary Baldor Electric Company ATTN: Mr. Gary Massey, Safety and Environmental Coordinator 70 Reems Creek Road Weaverville, North Carolina 28787 SUBJECT: NPDES Stormwater Permit: Request for Regulatory Relief — Copper and Zinc Sampling Baldor Electric Company General Permit No: NCG030000; COC No: NCG030070 Buncombe County Dear Mr. Massey: In response to your request for regulatory relief, NCDENR-Land Quality Section staff conducted a site inspection on February 28, 2014. The primary goal of the inspection was to evaluate the drainage to Outfalls B, C, D, and I and to insure that there are no illicit discharges at your facility. At the time of this inspection the facility was found to be in compliance with permit NCG030070 and no illicit discharges were discovered. Monthly monitoring has been triggered by two consecutive exceedances of the zinc (Outfalls B, D, C, and 1) and copper benchmarks (Outfall C) at your facility. Please keep in mind that benchmark exceedances are NOT limit violations or violations of permit conditions; however, you are obligated to follow the tiered response actions outlined in your permit. Baldor Electric Company has been following the tiered response actions and therefore is in compliance with the permit. As part of tiered response, Baldor has initiated robust housekeeping actions that appear to have addressed some of the exposures (reference January 24, 2014 letter from you). An additional air control device is planned for the Babbitt Room in 2014 to address potential zinc exposures to Stormwater as monitored in Outfall D. Based on this, your materials inventory review, and certification that industrial activities at Baldor pose little to no potential for release of copper and zinc into stormwater, with the exception of the Babbitt Room Zn-CI process, we are granting regulatory relief in the form of a collapsed Tier 2 — Tier 3 response for Outfalls B, C, and I for the copper and zinc benchmarks only, for the remainder of this permit, set to expire on October 31, 2017. Asheville Regional Office, 2090 US Highway 70, Swannanoa, North Carolina, 28778-8211 Telephone 828-296-4500 Fax 828-299-7043 htti3i//portal.ncdenr.org/web/lr/land-aualitx N nehcarofina An Equal Opportunity ! Affirmative Action Employer No Mr. Gary Massey March 13, 2014 Page 2 of 2 Upon receipt of this letter, Baldor may resume the permit specified semiannual analytical monitoring for Outfalls B, C, and I. A benchmark exceedance of any other parameter listed in your permit will trigger tiered response actions as described in the general permit. You are instructed to continue Tier II analytical monthly sampling for Outfall D for zinc and copper only. All other benchmarks (pH, TSS, O & G, Lead) shall be' monitored on a semiannual basis, unless a tiered response is triggered for these specific benchmarks. Once the Babbitt Room control device is installed and monthly analytical results are available demonstrating effect of this control, we will consider a review of your request for regulatory relief of Tier 2 monitoring for Outfall D. This decision only applies to the copper and zinc benchmarks. A benchmark exceedance of any other parameter listed in your permit will trigger tiered response actions as described in the general permit. You must notify this office in writing, within five business days, if you become aware of any significant source of copper or zinc at your facility that has the potential to be exposed to stormwater. The relief granted in this letter is contingent upon the current industrial practices and housekeeping actions at Baldor. If industrial practices change and copper or zinc does become a significant stormwater exposure risk then this office reserves the right to withdraw this decision and reinstate the permit specified tiered response or other actions that may be warranted by the new set of circumstances. Attached is a copy of the February 28, 2014 inspection report for your review. Please retain and append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit. If you have any questions or comments concerning this letter, please contact Darlene Kucken or me at (828) 296-4500. Sincerely, "� Laura Herbert, PE Regional Engineer Enclosure ec: Bethany Georgoulias, RCO Dan March, Pisgah Environmental Services, LLC ([pisgah-air@vt.edu) r Compliance Inspection Report Permit: NCGO30070 Effective: 11/01/12 Expiration: 10/31/17 Owner: Baldor Electric Company SOC: Effective: Expiration: Facility: Baldor Electric Company County: Buncombe 70 Reems Creak Rd Region: Asheville Weaverville NC 28787 Contact Person: John Reno Title: Phone: 828-645-4235 Directions to Facility: System Classifications: Primary ORC: Certification: Prone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 02/2812014 Entry Time: 01:00 PM Exit Time: 03:30 PM Primary Inspector: Darlene J Kucken Phone: Secondary Inspector(s): Laura C Herbert Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: © Compliant ❑ Not Compliant Question Areas: E Storm Water (See attachment summary) Page: 1 Permit: NCGO30070 Owner • Facility: Baldor Electric Company inspection Date: 02/2812014 Inspection Typo: Compliance Evaluation Reason for Vialt: Routine Inspection Summary: Copper, Zinc and Lead benchmarks were exceeded and Tier 11 monitoring was initiated for Copper and Zino, Baldor initiated several Internal houskeeping practices that resulted in lower values in subsequent sampling. Baldor asked for relief of some of the Tier II monitoring. A letter was sent by Laura Herbert allowing for some relief of parameters. Outfall D remains in Tier 11 response pending the installation and evatuaiic)n of the air control device on the Babbitt Room. Tha facility is in compliance. Page: 2 Permit: NCG030070 Owner - Facility: Baldor Electric Company Inspection Data: 02/28/2014 Inspection Type: Compliance Evaluation Reason for Viait: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ■ ❑ ❑ ❑ # Does the Plan include a "Narrative Descrlption of Practices"? a ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ■ ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ■ ❑ ❑ ❑ # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ®❑ ❑ ❑ # Does the facility provide and document Employee Training? ■ ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ■ ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted Its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facll€ty conducted its Analytical monitoring? WOOD # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ■ ❑ ❑ ❑ 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? ■ ❑ ❑ ❑ # li the facility has representative outfall status, is it properly documented by the Division? ■ ❑ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ Comment: Page: 3 Compliance Inspection Report Permit: NCGO30070 Effective: 11/01112 Expiration: 10/31/17 Owner: Baldor Electric Company SOC: Effective: Expiration: Facility: Baldor Electric Company County: Buncombe 70 Reems Creek Rd Region: Asheville Weaverville NC 28787 Contact Person: John Reno Title: Phone: 828-645-4235 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Certification: Phone: Inspection Date: 02128/2014 Entry Time: 01:00 PM Exit Time: 03:30 PM Primary Inspector: Darlene J Kucken Phone: Secondary Inspector(s): Laura C Herbert Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COG Facility Status: ■ Compliant Not Compliant Question Areas: E Storm Water (See attachment summary) Page: 1 Permit: NCGO30070 Owner - Facility: Baldor Electric Company Inspection Date: 02/28/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Copper, Zinc and Lead benchmarks were exceeded and Tier II monitoring was initiated for Copper and Zinc. Baldor initiated several internal houskeeping practices that resulted in lower values in subsequent sampling. Baldor asked for relief of some of the Tier II monitoring. A letter was sent by Laura Herbert allowing for some relief of parameters. Out -fall D remains in Tier II response pending the installation and evaluation of the air control device on the Babbitt Room. Tha facility is in compliance. Page.: 2 Permit: NCG030070 Owner - Facility: Baldor Electric Company Inspection Date: 02128/2014 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? # Does the Plan include a General Location (USGS) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfall locations and drainage areas? # Does the Plan include a list of significant spills occurring during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? # Does the Plan include a BMP summary? # Does the Plan include a Spill Prevention and Response Plan (SPRP)? # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? # Does the facility provide and document Employee Training? # Does the Plan include a list of Responsible Party(s)? # Is the Plan reviewed and updated annually? # Does the Plan include a Stormwater Facility Inspection Program? Has the Stormwater Pollution Prevention Plan been implemented? Comment: Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: Permit and Qutfalls # 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? # Has the facility evaluated all illicit (non Stormwater) discharges? Comment: Yes No NA NE ■❑❑❑ Yes No NA NE ■❑❑❑ ■❑❑❑ Yes No NA NE Page: 3 44f.r _ a-4,6c y. Cc clf p',•c.�-�-- Alt *0-f15C — 1� �� f 1" . 1� - Y a J m 5loS '7 Gcrrj os i..-c. / N c lrt�a.� � l� �'°�wKGi � .G 6G4�A--- h-oryt",v� Ald-- 5 rw r„y�< eZ A-uk'll # - low "pt, i 771�0 AC.A k-A I �6� ba vfv 6V f 5f«6'-T QO V bi . 1 - ✓ F _._.,_ ...... .,.ram H f-er AL cl is }} P •i4 f �Lu FNW ® © I ROOFRD ROOF 8 FLLOF FLOW FLOW ROO I FLOW FLO EGEND {S ` ROOFROD ura kca R FLOW FLOW `�\ ve FLOW ` wr+ a19 r E-8JO ti c-5AI G gip,\ �} Y [ i;Storm water flow / 1 ® ROO r... .N L 1 C- B •. � R �+ - yA1�� ��S G u it k ` \� Baldor Electric s V Stormwater Summary OUTFALL Sample Type B C D Benchmarks 50 6-9 15 0.007 0.03 0.067 50 6-9 15 0.007 0.03 0.067 50 6-9 15 0,007 0.03 0.067 Sampe Date TSS pH O&G Cu Pb 2n TSS pH O&G Cu Pb 2n TSS pH O&G Cu Pb Tn 12/10/08 <.005 <,005 <.005 03/14/09 <,005 <,005 <.005 09/26/09 Semi -Annual 0.0132 0.074 0.118 11/10/09 0.0064 0.0906 0.111 _06/10/10T ._ _ 0.02D9- 07/12/10 Semi -Annual 0.0222 0.196 0.203 08/21/10 -- 0,0094 0.0181 09/26/10 0.0072 0.0302 75/10 0.126 0.0394 15/10 0.11 0.011 01/01/11 Semi -Annual 0.0292 0.13 0.0762 01/25/11 0.0911 0.0286 02/28/11 0.0204 0.0167 03/05/11 <.005 0,0239 05/03/11 <.005 0.023 0.0172 11/21/11 Semi -Annual < 005 0.0423 0.0098 04/17/12 0,0052 0.0362 0,0594 07/06/12 0.173 0.0982 08/28/12 Semi -Annual <.ODS 0.0066 0,423 12/10/12 0.025 0.14 28 <.01 0A32 0.06 01/30/13 Semi -Annual 142 6.4 <5 0.0181 0.0598 0.3 23.9 6.5 <5 0.0184 .0298 .072 <2.5 7.1 <5 <.005 0.0398 ,089 02/07/13 OMO <,005 0.137 0.0474 N/C 0,184 N/C 0,0096 '0.109 04/04/13 <,005 <,005 0.226 0.021 0.0838 0.129 <.005 0.0309 0,155 05/18/13 N/C N/C N/C 0.0097 0.009 0.0373 N/C 0.0527 0.214 06/13/13 <.01 <,005 1.2 0.013 0.058 0.17 <.01 0.036 0.33 08/07/13 <.005 0.0059 0.054 0.028 0,064 0.2 <.005 0.1 U6. '17/13 Semi -Annual 13 6.3 <5 <.005 <,005 .278 2,7 6.5 <5 0.0071 0.0098 0,0489 18.9 6.5 <5 1 <.005 0,0085 0.154 26/13 v it 1 <.005 <.005 0.269 0.006 0.0349 0.0767 <.005 0.0085 0.11 f- r f 2 .&"W 0 Baldor Electric `V � �� l Stormwater Summary (t OUTFALL Sample Type E F G Benchmarks 50 6-9 15 0.007 0.03 0.067 50 6-9 15 0.007 0.03 0.067 50 6-9 15 0.007 0.03 1 0.067 Sampe Date TSS pH O&G Cu Pb Zn TSS pH 0&G Cu Pb Zn TSS pH 0&G Cu Pb Zn 12/10/08 <.005 0.0123 <.005 03/ 14/09 <.005 <.005 <.005 09/26/09 Semi -Annual 0.008 0.0105 0.0088 11/10/09 06/10/10 <.005 07/12/10 Semi -Annual <.005 <.005 0.0645 08/21/10 09/26/10 10/25/10 11/15/10 01/01/11 Semi -Annual <.005 <.005 0.173 01/25/11 0.153 02/28/11 0.0267 03/05/11 0.0231 05/03/11 <.005 <.005 0.0096 11/21/11 Semi -Annual <.005 <.005 0.0115 04/ 17/12 <.005 0.0132 0.0962 07/06/12 0.222 08/28/12 Semi -Annual 0.0077 0.0236 0.0144 12 10 12 0.014 0.068 0.2 01/30/13 Semi -Annual <2.5 7.3 <5 <.005 <.005 0.0313 <2.5 7.2 <5 <.005 <.005 0.0256 69.3 6.4 <5 0.0087 0.0446 0.0604 02/07/13 N/C N/C N/C N/C N/C N/C 0.0111 0.0502 N/C 04/04/13 N/C N/C N/C N/C N/C N/C <,005 0.0245 0.048 05/18/13 N/C N/C N/C N/C N/C N/C <.005 0.0147 N/C 06/13/13 N/C N/C N/C N/C N/C N/C <.01 0.014 0.079 09/07/13 N/C N/C N/C N/C N/C N/C 0.0069 0.026 0.11 11/17/13 Semi -Annual 3 6.7 1 <S 1 <.005 <.005 1 0.0632 2.7 1 6.5 <5 <.005 1 <.005 0.0915 3.5 6.4 <5 <.005 0.0111 0.0417 11/26/13 N/C N/C N/C <.005 <.005 0.039 N/C I N/C N/C or .1 8aldor Electric Stormwater Summary OUTFALL Sample Type l Benchmarks 50 6-9 15 0.007 0.03 0.067 Sampe Date TSS pH O&G Cu Pb 2n 12/10/09 03/14/09 09/26/09 Semi -Annual 11/10/09 06/10/10 <,005 07/12/10 Semi -Annual <,005 08/21/10 09/26/10 '25/10 15/10 01/01/11 Semi -Annual <,005 01/25/11 02/28/11 03/05/11 0S/03/11 <.005 11121/11 Semi -Annual <.005 04/17/12 <.005 07/06/12 08/28/12 Semi -Annual 0,0063 12/10/12 01/30/13 Semi -Annual 10.2 6.5 <5 <.005 <,005 k.0747 02/07/13 N/C N/C -M2 04/04/13 05/18/13 N/C N/C 1 0.141 06/13/13 N/C N/C 08/07/13 <,001 '17/13 Semi -Annual 6.7 6.6 <5 <.005 0.17926/13 4N//C <.005 2K G1L Herbert, Laura C From: Gary Massey <Gary.Massey@baldor.abb.com> Sent: Monday, March 10, 2014 4:06 PM To: Herbert, Laura C Cc: Kucken, Darlene Subject: Baldor Inspection Update Attachments: Chip Shed_xlsx.pdf Laura, 1 confirmed that the 4" clean outs we found outside the fence are for the sewer lines that come from the rear of the plant. This line connects with the main sewer line near the driveway. I have also attached a brief summary of the outside chip shed. I felt like you had some concerns with this area and wasn't sure we addressed them well enough. We haven't had any issues with oil and grease which would be the pollutant of concern if we had any stormwater runoff from the sump area. If there is anything else that you have questions about please don't hesitate to let me know. Thanks, Gary Massey Safety & Environmental Coordinator Baldor Electric Company 70 Reems Creek Rd Weaverville , NC 28787 828-645-1718 828-645-5211 (Fax) Sump r a in t o a s raI bae i to a pi Inside h p! nt. The area and r he ro t a slo ed to drat aek to e s area is rie i &I'D Man (j�QkIFe735eA�LlJM1!J PUG6H! ENTRONMENT6L SLRQICLJ, LLC 9 WQQDV6LE MVENU § AMNILU, NC 25804 § PHQNL 828-768-3335 § Fex 828-255-1092 § PUG9H-91R*QT,EQV MEMORANDUM VIA E-MAIL Date: March 7, 2014 Subject: Stormwater To: Gary Massey From: Dan March Re: Analytical Results Below arc analytical results from Pace. Table I. February 19, 2014 Discharge Point Copper rri 2 Lead yn /L Zinc m TLL B <0.005 <0.005 0.390 C 0.0067 0,0244 0-0751 D 0.0087 0.0102 0.458 1 <0.005 <0.005 0.242 Benclimark 0.007 0.030 67 Compliance Inspection Report Permit. NC0000070 Effective; 1 i101112 Expiration: 10131117 Owner: Baldor Electric Company SOC: Effective: Expiration: Facility: Baldor Electric Company County: Buncombe 70 Reems Crook Rd Region: Ashevilte Weaverville NC 28787 Cent-crPerlonrt John -Reno - — _- TTtfo. - - — — -- -Phone: 82fM,45-423j Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Repress irtative(s): Related Permits: Inspection Date: 02128/2014 Entry Time: 01:00 PM Exit Time: 03:30 PM Primary Inspector; Darlene J Kucken Phone: Secondary Inspector(s): Laura C Herbert Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type; Metal Fabrication Stormweter Discharge COC Facility Status: ® Compliant 0 Not Compliant Questlon Areas, 0 Storm Water (See attachment summary) Page: 1 e ParmiC MCG030070 Ownar - Facility: Beldor Electric Company Inspection Date: 02128/2014 Inspection Typo: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Copper, Zinc and Lead benchmarks were exceeded and Tier II rnonitodng was initiated for Copper and Zinc. 9aldor initiated several internal houskeeping practices that resulted In lower values In subsequent sampling. Saldor asked for relief of some of the Tier it monitoring_ A letter was sent by Laura Herbert allowing for some relief of parameters. Qutfall D remains in Tier It response pending the Installation and evaluation of the air control device on the Babbitt Room. Tha facility Is in compliance. Page: 2 e Permit: NCGO30070 Owner • Facility: Saldor Electric Company Inspection pate: 02/2812014 Inspection Type: Compliance Evaluatlon Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ®❑ ❑ ❑ # Does the Plan include a Generai Location (USGS) map? ■ ❑ ❑ ❑ #'Does the Plan include i "Narrative I)esc_ript& of Prac{ices"? ®❑ ❑- ❑- # Does the Plan Include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ # Does the Plan Include a list of significant spills occurring during the past 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ®❑ ❑ ❑ # Does the facility provide all necessary secondary containment? 8 ❑ ❑ ❑ # Does the Plan include a BM summary? ®❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? in ❑ ❑ # goes the Plan include a Preventative Maintenance and Good Housekeeping Plan? © ❑ ❑ ❑ # Does the facility provide and document Employee Training? ®❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ® ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ® ❑ ❑ ❑ } # Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Poilufion Prevention Plan been implemented? ®❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? Is ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA, NE Has the facility conducted its Analytical monitoring? ®❑ ❑ ❑ I i # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ®❑ ❑ ❑ Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? m ❑ ❑ ❑ i # Were all outfalls observed during the inspection? ®❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ®❑ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ®❑ Cl ❑ i Comment: Page: 3 aceAnaly ical wmpacefabsCam March 11, 2014 Mr. Dan March Pisgah Environmental Services 9 Woodvale Asheville, NC 28804 RE: Project: 907089 Baldor Pace Project No.: 92191654 Dear Mr. March: Face Analytical services, lne. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 Enclosed are the analytical results for sample(s) received by the laboratory on March 03, 2014. The results relate only to the samples included in this report. Results reported herein conform to the most current TNI standards and they laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report. Analyses were performed at the Pace Analytical Services location indicated on the sample analyte page for analysis unless otherwise footnoted. If you have any questions concerning this report, please feel free to contact me. Sincerely, jam_ (J .,,4 Tabitha M Dacal tabitha.dacal@pacelabs.com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 1 of 17 Herbert, Laura C From: Gary Massey < Gary.M assey@ bald or.abb.com > Sent: Monday, March 03, 2014 930 AM To: Herbert, Laura C; Kucken, Darlene Subject: Baldor Stormwater Inspection Attachments: ECOCOOL 7330-55GL DRUM.pdf; Fuchs Ecocool Syn 7050.pdf; Baldor Sampling 8.07.13.pdf Good Morning Laura and Darlene, I have attached the following information. • MSD sheets for our machining fluids • Sampling results as requested: On August 7, 2013 I collected a stormwater sample directly from the gutter that drains the galvanized roof of the casting storage building. The drainage from this roof flows into conveyance points B (about 25% of the roof area) and C (50% of the roof area). These results are included along with samples collected from the conveyance points during that same event. Conveyance point I only carries runoff from the galvanized roof over the storage area at the back of the plant. If you have any questions or need any additional information please let me know. Thanks again for your input and review of our program. I do have one question. Will we get an inspection report for your visit ? Best Regards, Gary Massey Safety & Environmental Coordinator Baldor Electric Company 70 Reems Creek Rd Weaverville , NC 28787 828-645-1718 828-645-5211 (Fax) Environmental TestingSolutions. Inc- Certificate Of Analysis Project name: Saldor Dodge Reliance Collection date: 7-Aug-13 Date received: 8-Aug-13 Sample identification: R - Grab Po Box 7565 Asheville, NC 28802 Phone: (828) 350-9364 Fax: (828) 350-9368 Project number: 130808.505 Sample number: 108578 Parameter Method Result RL Units Date Analyzed Analyst Footnotes Copper 200.8 <0.0050 0.0050 ing/L 19-Aug-13 P.1P 1 Lead 200.8 0.0059 0.0010 mS/L 19.Aug 13 PA. I ,Zinc � 200.8 0.054 0.0050 mg/L 19-Ate t3 PJF I T Sample identification: C - Grab Sample number: 108579 Date Parameter Method Result RL Units Analyzed Analyst Footnotes Copper 200.8 0.028 0.0050 mg/L 19-Aug-13 PJF 1 Lead 200.8 0.064 0.0010 mg/L 19-Aug-13 Pill' 1 Zinc 200.8 0.20 0.0050 mg/L i9-Aug,i3 PJF 1 Sample identification: D- Grab Sample number: 108580 Parameter Method Result RL Units Date Analyst Footnotes Analyzed Copper 200.8 <0A050 0.0050 mg/L i9-Az-o PJP 1 Lead 200.8 0,10 0.00I0 mg/L 19-Aug.13 PJF I Zinc 200.8 0.56 0.0050 mgk 19-Aug-11 PJF I Sample identification: G - Grab Sample number: 108581 Parameter Method Result RL Units Date Analyzed Analyst Footnotes Copper 200.8 0.0069 0.0050 mg/L. 19-Aug•13 PJF I Lead 200.8 0.026 0.0010 mg/L t9-Aug-i3 .PJF 1 Zinc 200.8 0.11_ _-0.0050 mg/L19-Aug-13 PJF I Sample identification: I - Grab Sample number; 108582 Parameter Method Result RL Units Date Analyst Footnotes Analyzed Copper 200.8 <0A050 0-0050 mg/L 19-Aug-13 PJF I Lead 200.8 <0.0010 0.0010 mg/1, t9-Aug-a PJF I Zinc 200.8 0.50 0.0050 rne&tg-Au -13 PJF I This report should not be reproduced, exept in its en6rery, without the written consent of Environmental Testing Solutions, Inc, The results in this report relate only to the samples submitted for analysis, Collection date: 7-Aug-13 Date received: 8-Aug-13 Sample identification: Storage Building Roor- Grab 110 Box 7565 Asheville, NC 28802 Phone: (828) 350-9364 Fax: (828) 350-9368 Project number: 130808.505 Sample number. I08583 Parameter Method Result RL Units Date Analyst Footnotes Analyxcd Copper 200.8 <0.0050 0.0050 mg/L 19.Aug.13 PJF I Lead 200.8 <0.0010 0.0010 mg/L IMus-13 PJF 1 Zinc 200.9 0.31 0.0050 roil . 19-Aug-13 PJI' 1 Footnotes: RL = Reporting Limit. Values are reported down to the Reporting Lit -nit only. I. Analyzed by Prism Laboratories, Inc. Date reviewed- Data reviewed by: Kelley E. Keenan Signature: {J� NC Certification Number: 600 SC Certification Number: 99053 NC Drinking Water Certification Number., 37786 This report should not be reproduced, exept in its entirety, without the written consent of Environmental Testing; Solutions, Ina. The results in this report relate only to the samples submitted far analysis. ?001.., FUCHS LUBRICANTS CO. FUCHS SECTION 1 - PRODUCT AND COMPANY IDENTIFICATION PRODUCT IDENTIFICATION MANUFACTURER IDENTIFICATION Company Name. . . . . . . Address . . . . . . . . . Telephone . . . . . . Emergency Contact _ . Emergency Telephone ECOCOOL SYN 7050 FUCHS LUBRICANTS CO. 17050 LATHROP AVE. HARVEY IL 60426 708-333-8900 Regulatory Compliance Department 708-333-8900 (8am - spm CST, M-F) 800-255-3924 (24 Hours) MSDS PRINT DATE . . . . . . : 02/08/2013 * EMERGENCY OVERVIEW This product is a water soluble liquid. Direct eye contact may cause temporary irritation. Short term skin contact is not expected to be irritating. Inhalation of high mist or vapor levels in poorly ventilated areas may cause minor upper respiratory tract irritation. Ingestion is not an anticipated route of exposure. * HMIS Rating: Health- 1 Flammability- 0 Reactivity- 0 PPE- X SECTION 2 - COMPONENT DATA Components listed in this section may contribute to the potential hazards associated with exposure to the concentrate. The product may contain additional non -hazardous or trade -secret components. Tri.ethanolamine Cas#: 102-71-6 Percent: < 5 Exposure Limit: OSHA PEL/ACGIH TWA: 5mg/m3 - Carcinogenic Components: This product contains no carcinogens. SECTION 3 - HAZARDS IDENTIFICATION POTENTIAL HEALTH EFFECTS and SYMPTOMS from SHORT TERM/ACUTE EXPOSURE: - EYE EXPOSURE - This product is not expected to cause eye irritation under normal conditions of use. Symptoms of temporary eye irritation and redness may result upon_ direct contact or when exposed to high mist levels in poorly ventilated areas. - SKIN EXPOSURE - Short term skin contact is not expected to cause skin irritation. Prolonged or repeated direct exposure to the skin may result in symptoms of irritation and redness. /Or� FUCHS LUBRICANTS CO. FUCHS PRODUCT NAME: ECOCOOL SYN 7050 --------------------------------------------------------------------------- - INHALATION - This product has low volatility and so is not expected to cause respiratory tract irritation during normal conditions of use. Exposure to high mist levels in poorly ventilated areas may cause temporary irritation to the upper respiratory tract. - INGESTION - Ingestion may cause slight stomach irritation and discomfort. POTENTIAL CHRONIC HEALTH EFFECTS: No further data known. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: No further data known. CARCINOGENICITY: This product is not listed as a known or suspected carcinogen by IARC, OSHA, or the NTP. SECTION 4 - FIRST AID MEASURES EYE CONTACT: Upon direct eye contact, hold eyelids open and flush with a steady, gentle stream of water for at least 1.5 minutes. If irritation is due to exposure to mist or vapors, remove the individual to fresh air. If irritation persists, flush the eyes with clean water until the irritation subsides. If symptoms persist, contact a physician. SKIN CONTACT: Remove product from the skin by washing with a mild soap and water. Contaminated clothing should be removed to prevent prolonged exposure. If symptoms of exposure persist, contact a physician. INHALATION: Inhalation is not an expected route of exposure. If respiratory irritation or distress occurs, remove the employee to fresh air. Contact a physician or other medical professional if irritation or distress persists. INGESTION: If small amounts are ingested, first aid measures are not likely to be necessary. If larger amounts are ingested or if symptoms of ingestion occur, dilute stomach contents with two glasses of water or milk. (NOTE: Do NOT give anything by mouth to an unconscious person.) Do not induce vomiting without medical supervision. If vomiting occurs spontaneously keep airway clear. If symptoms of ingestion persist, seek medical attention. /0014, FUCHS LUBRICANTS CO. FUCHS PRODUCT NAME: ECOCOOL SYN 7050 --------------------------------------------------------------------------- NOTE TO PHYSICIAN: No further data known. SECTION 5 - FIRE FIGHTING MEASURES FIRE AND EXPLOSIVE PROPERTIES: Flashpoint . . . . . . . . . . . . . -N/A 'DF Flammability Limits . . . . . . . . . LEL -N/A UEL -N/A EXTINGUISHING MEDIA: This product is not combustible but water fog, dry chemical, foam, and CO2 fire extinguishers may be used in areas where it is stored. UNUSUAL FIRE & EXPLOSION HAZARDS; No further data known. FIRE -FIGHTING PROCEDURES AND EQUIPMENT: The noncombustible nature of the product creates no need for special fire fighting procedures and equipment. SECTION 6 - ACCIDENTAL RELEASE MEASURES CLEAN-UP MEASURES: Important: As with any spill or leak, before responding ensure that you are familiar with the potential hazards and recommendations of the MSDS. Appropriate personal protective equipment must be worn. See Section 8 of this MSDS for PPE recommendations. It possible, safely contain the spill with dikes or other spill response equipment appropriate for releases of water -based materials. Prevent spreading of product and/or release into the environment, Large volumes of material should be collected in an appropriate waste container for proper disposal. Small volumes or residues may be soaked up with absorbent material. Disposal of any spill response materials should meet appropriate waste regulations. SECTION 7 - HANDLING AND STORAGE HANDLING: As with any industrial chemical, handle the product in a manner that minimizes exposure to practicable levels. Prior to handling, consult Section 8 of this MSDS to evaluate personal protective equipment needs. Open containers slowly to relieve any pressure. Follow all other standard industrial hygiene practices. Empty containers may contain product residue. All safety precautions ?0=41' Fuchs LUBRICANTS co. FUCHS PRODUCT NAME: ECOCOOL SYN 70SO --------------------------------------------------------------------------- taken when handling this product should also be taken when handling empty drums and containers. Keep containers closed when not in use. STORAGE: Protect product quality by storing indoors and away from extreme temperatures. Close all containers when not in use. SPECIAL COMMENTS: Do not mix with nitrites. This product contains an amine that may react, under certain conditions, with nitrites to form nitrosamines. No further data known. SECTION 8 - EXPOSURE CONTROLS, PERSONAL PROTECTION PERSONAL PROTECTIVE EQUIPMENT: Selection of personal protective equipment should be based upon the anticipated exposure and made in accordance with OSHA's Personal Protective Equipment Standard found in 29 CFR 1910 Subpart I. The following information may be used to assist in PPE selection. - EYE PROTECTION - wear eye protection appropriate to prevent eye exposure. Where splashing is not likely, chemical safety glasses with side shields are recommended. Where splashing may occur, chemical goggles or full face shield is recommended. - SKIN PROTECTION - Gloves are not normally needed during normal conditions of use. If health effects are experienced, oil or chemical resistent gloves such as butyl or nitrile are recommended. Where splashing or soaking is likely, wear oil or chemical resistent clothing to prevent exposure. - RESPIRATORY PROTECTION - A respirator may be worn to reduce exposure to vapors, dust, or mist. Select a NIOSH/MSHA approved respirator appropriate for the type and physical character of the airborne material. A self-contained breathing apparatus is recommended in all situations where airborne contaminant concentration has not been confirmed to be below safe levels. Respirator use should comply with the OSHA Respirator Protection Standard found in 29 CFR 1910.134. ENGINEERING CONTROLS: Normal general ventilation is expected to be adequate. It is recommended that ventilation be designed in all instances to maintain airborne concentrations at lowest practicable levels. Ventilation should at a /01r� FUCKS LUBRICANTS Co. FUCHS PRODUCT NAME: ECOCOOL SYN 7050 ---------------------------------------------------------------------------- minimum, prevent airborne concentrations from exceeding any exposure limits listed in Section 2 of this MSDS. The user may wish to refer to 29 CFR 1910.1000(d)(2) and the ACGIH "Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indicies" (Appendix C) for the determination of exposure limits of mixtures. An industrial hygienist or similar professional may be consulted to confirm that the calculated exposure limits apply. SECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES Physical Appearance . . . . . . . . . Clear dark green Odor . . . . . . . . . . . . . . . . Mild Physical State . . . . . . . . . . . Liquid Water Solubility . . . . . . . . . . Soluble Specific Gravity . . . . . . . . . . 1.058 SECTION 10 - STABILITY AND REACTIVITY INCOMPATIBILITIES: This product is incompatible with strong oxidizing agents. DECOMPOSITION PRODUCTS MAY INCLUDE: The product, as sold, is not expected to thermally decompose. Product residue however, may burn. Thermal decomposition products are highly dependent on combustion conditions. A complex mixture of airborne solid liquid, particulates and gasses may evolve when the residues burn. Byproducts of residue combustion may include: oxides of carbon, traces of formaldehyde, ammonia and oxides of nitrogen, incompletely burned hydrocarbons as fumes and smoke. CONDITIONS TO AVOID: Avoid contact with incompatible materials and exposure to extreme temperatures. POLYMERIZATION: This product is not expected to polymerize. STABILITY: This product is stable. SECTION 11 - TOXICOLOGICAL INFORMATION EYE EFFECTS: FUCHS LUBRICANTS CO. FUCHS fir✓ PRODUCT NAME: ECOCOOL SYN 7050 -------------------------------------------__------------------------------ No further toxicological data known. SKIN EFFECTS: Contact with a component of this product may cause an allergic skin reaction in a small percentage of the population. No further toxicological data known. ORAL EFFECTS: No further toxicological data known. INHALATION EFFECTS: No further toxicological data known. OTHER: No further data known. SECTION 12 - ECOLOGICAL, INFORMATION ECOTOXICOLOGICAL INFORMATION: This product has not been evaluated for ecotoxicity. As with any industrial chemical, exposure to the environment should be prevented and minimized wherever possible. ENVIRONMENTAL FATE: The degree of biodegradability and persistence of this product has not been determined. SECTION 13 - DISPOSAL CONSIDERATIONS WASTE DISPOSAL: Ensure that collection, transport, treatment, and disposal of waste product, containers and rinsate complies with all applicable laws and regulations. Note that use, mixture, processing, or contamination of the product may cause the material to be classified as a hazardous waste. It is the responsibility of the product user or owner to determine at the time of disposal, whether the product is regulated as a hazardous waste. SECTION 14 - TRANSPORT INFORMATION DOT HAZARDOUS MATERIAL INFORMATION: * Not otherwise DOT regulated. SECTION 15 - REGULATORY INFORMATION FEDERAL REGULATIONS: SARA 313: This product contains NONE of the substances subject to the reporting FUCHS LUBRICANTS CO. FUCHS PRODUCT NAME: ECOCOOL SYN 7050 --------------------------------------------------------------------------- requirements of Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 and 40 CFR Part 372. CERCLA Reportable Quantity: Any components listed below have been assigned a reportable quantity (RQ) by the Federal EPA. Releases of the product into the environment that exceed the RQ for a particular component must be reported to the National Response Center at 1-800-424-8802. Component RQ Toxic Substances Control Act: The components of this product are listed on the TSCA Inventory. Ozone Depleting Substances: This product contains no ozone depleting substances as defined by the Clean Air Act. Hazardous Air Pollutants: Any components listed below are defined by the Federal EPA as hazardous air pollutants. Component STATE REGULATIONS: California Proposition 65: WARNING: This product contains a chemical(s) known to the State of California to cause cancer and birth defects or other reproductive harm. No further data known. SECTION 16 - OTHER INFORMATION Prepared by . . . . . . . . . , . . Date of issue . . . . . . . . . . . Last Revision Date . . . . . . . . REG-450203 Corporate Regulatory Compliance 02/08/2013 02/08/2013 NOTICE: This MSDS provides a good faith representation of information believed to be accurate as of the last revision date. This document does not create any express or implied product warranties. Since conditions of use are beyond the control of Fuchs Lubricants Co., all risks associated with product use are assumed by the user. fUCHS L UBRICaNTS C9. FUCHS SECTION 1 - PRODUCT AND COMPANY IDENTIFICATION PRODUCT IDENTIFICATION: . . : ECOCOOL 7330 MANUFACTURER IDENTIFICATION Company Name. . . . . Address . . . . . . . . . Telephone . Emergency -Contact . . . . Emergency Telephone . . . FUCHS LUBRICANTS CO. 17050 LATHROP AVE. HARVEY IL 60426 706-333-8900 Regulatory Compliance Department 708-333-8900 (8am - Spm CST, M-F) 800-255-3924 (24 Hours) MSDS PRINT DATE . . . . . : 01/07/2011 * EMERGENCY OVERVIEW This product is a water soluble liquid. Direct eye contact may cause temporary irritation. Short term skin contact is not expected to be irritating. inhalation of high mist or vapor levels in poorly ventilated areas may cause minor upper respiratory tract irritation. Ingestion is not an anticipated route of exposure. . * HMIS Rating: Health- 1 Flammability- 0 Reactivity-0 PPE= X SECTION 2 -.COMPONENT DATA Components listed in this section may contribute to the.potential hazards associated with exposure to the concentrate.. The product may contain additional non -hazardous or trade -secret components. Mineral Oil Cas#: Proprietary Percent: <. 20 Exposure Limit: ACGIH TLV: 5 mg/m3 (as mist) ACGIH STEL: 10 mg/m3 (as mist) OSHA PEL: 5 mg/m3 (as mist) - Carcinogenic Components: This product contains no carcinogens. SECTION 3 - HAZARDS IDENTIFICATION POTENTIAL HEALTH EFFECTS and SYMPTOMS"from SHORT TERM/ACUTE EXPOSURE: - EYE EXPOSURE' - This product is not expected to cause eye irritation under normal conditions of use. Symptoms of temporary eye irritation and redness. may result upon direct contact or when exposed to high mist levels in poorly ventilated areas... - SKIN EXPOSURES Short term skin contact is not expected to cause skin irritation. PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- Prolonged or repeated direct exposure to the skin may result in symptoms of irritation and redness. - INHALATION - This product has low volatility and so is not expected to cause respiratory tract irritation during normal conditions of use. Exposure to high mist levels in poorly ventilated areas may cause temporary irritation to the upper respiratory tract. - INGESTION - Ingestion may cause slight stomach irritation and discomfort. POTENTIAL CHRONIC HEALTH EFFECTS: No further data known. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: No further data known. CARCINOGENICITY: This product is not listed as a known or suspected carcinogen by IARC, OSHA, or the NTP. SECTION 4 - FIRST AID MEASURES EYE CONTACT: Upon direct eye contact, hold eyelids open and flush wi.th-a steady, gentle stream of water for at least 15 minutes. If irritation is due to exposure to mist or vapors, remove the individual to fresh air. If irritation persists, flush the eyes with clean water until the irritation subsides. If symptoms persist, contact a physician. SKIN CONTACT: Remove product from the skin by washing with a mild soap and water. Contaminated clothing should be removed to prevent prolonged exposure. If symptoms of exposure persist, contact a physician. INHALATION: Inhalation is not an expected route of exposure. If respiratory irritation or distress occurs, remove the employee to fresh air. Contact a physician or other medical professional if irritation or distress persists. INGESTION: If small amounts are ingested, first aid measures are not likely to be necessary. If larger amounts are ingested or if symptoms of ingestion occur, dilute stomach contents with two glasses of water or milk. (NOTE: Do NOT give anything by mouth to an unconscious person.) Do not induce vomiting without medical supervision. If vomiting occurs spontaneously PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- keep airway clear. If symptoms of ingestion persist, seek medical attention. NOTE TO PHYSICIAN: No further data known. SECTION 5 - FIRE FIGHTING MEASURES FIRE AND EXPLOSIVE PROPERTIES: Flashpoint . . . . . . . . . -N/A OF Flammability Limits . . . . . . . . . LEL -N/A UEL -N/A EXTINGUISHING MEDIA: This product is not combustible but water fog, dry chemical, foam, and CO2 fire extinguishers may be used in areas where it is stored. UNUSUAL FIRE & EXPLOSION HAZARDS: No further data known. FIRE -FIGHTING PROCEDURES AND EQUIPMENT: The noncombustible nature of the product creates no need for special fire fighting procedures and equipment. SECTION 6 - ACCIDENTAL RELEASE MEASURES CLEAN-UP MEASURES: Important: As with any spill or leak, before responding ensure that you are familiar with the potential hazards and recommendations of the MSDS. Appropriate personal protective equipment must be worn. See Section 8 of this MSDS for PPE recommendations. If possible, safely contain the spill with dikes or other spill response equipment appropriate for releases of water -based materials. Prevent spreading of product and/or release into the environment. Large volumes of material should be collected in an appropriate waste container for proper disposal. Small volumes or residues may be soaked up with absorbent material. Disposal of any spill response materials should meet appropriate waste regulations. SECTION 7 -- HANDLING AND STORAGE HANDLING: As with any industrial chemical, handle the product in a manner that minimizes exposure to practicable levels. Prior to handling, consult Section 8 of this MSDS to evaluate personal protective equipment needs. Open containers slowly to relieve any pressure. Follow all other standard industrial hygiene practices. PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- Empty containers may contain product residue. All safety precautions taken when handling this product should also be taken when handling empty drums and containers. Keep containers closed when not in use. STORAGE: Protect product quality by storing indoors and away from extreme temperatures. Close all containers when not in use. SPECIAL COMMENTS: Do not mix with nitrites. This product contains an amine that may react, under certain conditions, with nitrites to form nitrosamines. No further data known. SECTION 8 - EXPOSURE CONTROLS, PERSONAL PROTECTION PERSONAL PROTECTIVE EQUIPMENT: Selection of personal protective equipment should be based upon the anticipated exposure and made in accordance with OSHA's Personal Protective Equipment Standard found in 29 CFR 1910 Subpart I. The following information may be used to assist in PPE selection. - EYE PROTECTION - Wear eye protection appropriate to prevent eye exposure. Where splashing is not likely, chemical safety glasses with side shields are recommended. Where splashing may occur, chemical goggles or full face shield is recommended. - SKIN PROTECTION - Gloves are not normally needed during normal conditions of use. If health effects are experienced, oil or chemical resistent gloves such as butyl or nitrile are recommended. Where splashing or soaking is likely, wear oil or chemical resistent clothing to prevent exposure. - RESPIRATORY PROTECTION - A respirator may be worn to reduce exposure to vapors, dust, or mist. Select a NIOSH/MSHA approved respirator appropriate for the type and physical character of the airborne material. A self-contained breathing apparatus is recommended in all situations where airborne contaminant concentration has not been confirmed to be below safe levels. Respirator use should comply with the OSHA Respirator Protection Standard found in 29 CFR 1910.134. ENGINEERING CONTROLS: Normal general ventilation is expected to be adequate. It is recommended PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- that ventilation be designed in all instances to maintain airborne concentrations at lowest practicable levels. Ventilation should at a minimum, prevent airborne concentrations from exceeding any exposure limits listed in Section 2 of this MSDS. The user may wish to refer to 29 CFR 1910.1000(d)(2) and the ACGIH "Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indicies" (Appendix C) for the determination of exposure limits of mixtures. An industrial hygienist or similar professional may be consulted to confirm that the calculated exposure limits apply. SECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES Physical Appearance . . . . . . . . . : Amber Odor . . . . . . . . . . . . . . . . . Mild Physical State . . . . . . . . . . . . Liquid Water Solubility . . . . . . . . . . : Complete Specific Gravity . . . . . . . . . . . .997 SECTION 10 - STABILITY AND REACTIVITY INCOMPATIBILITIES: This product is incompatible with strong oxidizing agents. DECOMPOSITION PRODUCTS MAY INCLUDE: The product, as sold, is not expected to thermally decompose. Product residue however, may burn. Thermal decomposition products are highly dependent on combustion conditions. A complex mixture of airborne solid liquid, particulates and gasses may evolve when the residues burn. Byproducts of residue combustion may include: oxides of carbon, ammonia and oxides of nitrogen, incompletely burned hydrocarbons as fumes and smoke. CONDITIONS TO AVOID: Avoid contact with incompatible materials and exposure to extreme temperatures. POLYMERIZATION: This product is not expected to polymerize. STABILITY: This product is stable. SECTION 11 - TOXICOLOGICAL INFORMATION PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- EYE EFFECTS: No further toxicological data known. SKIN EFFECTS: No further toxicological data known. ORAL EFFECTS: No further toxicological data known. INHALATION EFFECTS: No further toxicological data known. OTHER: No further data known. SECTION 12 - ECOLOGICAL INFORMATION ECOTOXICOLOGICAL INFORMATION: This product has not been evaluated for ecotoxicity. As with any industrial chemical, exposure to the environment, should be prevented and minimized wherever possible. ENVIRONMENTAL FATE: The degree of biodegradability and persistence of this product has not been determined. SECTION 13 - DISPOSAL CONSIDERATIONS WASTE DISPOSAL: Ensure that collection, transport, treatment, and disposal of waste product, containers and rinsate complies with all applicable laws and regulations. Note that use, mixture, processing, or contamination of the product may cause the material to be classified as a hazardous waste. It is the responsibility of the product user or owner to determine at the time of disposal, whether the product is regulated as a hazardous waste. SECTION 14 - TRANSPORT INFORMATION DOT HAZARDOUS MATERIAL INFORMATION: * Not otherwise DOT regulated. SECTION 15 - REGULATORY INFORMATION FEDERAL REGULATIONS: SARA 313 : This product contains NONE of the substances subject to the reporting requirements of Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 and 40 CFR Part 372. PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- Clean Water Act / Oil Pollution Act: This product contains mineral oil and is subject to regulation by Section 311 of the Clean Water Act and the Oil Pollution Act. Releases of the product into or leading to surface waters must be reported to the National Response Center at 1-800-424-8802. CERCLA Reportable Quantity: Any components listed below have been assigned a reportable quantity (RQ) by the Federal EPA. Releases of the product into the environment that exceed the RQ for a particular component must be reported to the National Response Center at 1-800-424-8802. Component RQ Toxic Substances Control Act: The components of this product are listed on the TSCA Inventory. Ozone Depleting Substances: This product contains no ozone depleting substances as defined by the Clean Air Act. Hazardous Air Pollutants: Any components listed below are defined by the Federal EPA as hazardous air pollutants. Component STATE REGULATIONS: This product contains mineral oil, and as used, may be regulated by state used oil regulations. Check with the appropriate state agency to determine whether such a regulation exists. California Proposition 65: WARNING: This product contains a chemical(s) _known to the State of California to cause cancer and birth defects or other reproductive harm. No further data known. SECTION 16 - OTHER INFORMATION Prepared by . . . . . . . . . . . . . Corporate Regulatory Compliance Date of issue . . . . . . . . . . . . 01/07/2011 Last Revision Date . . . . . . . . . 01/07/2011 REG-450193 PRODUCT NAME: ECOCOOL 7330 --------------------------------------------------------------------------- NOTICE: This MSDS provides a good faith representation of information believed to be accurate as of the last revision date. This document does not create any express or implied product warranties. Since conditions of use are beyond the control of Fuchs Lubricants Co., all risks associated with product use are assumed by the user. aceAnalykal www.pamiabs.com ANALYTICAL RESULTS Project: 907089 Baldor Pace Project No.: 92191654 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 Sample: 13 Parameters Lab ID: 92191654001 Collected: 03/03114 14:50 Results Units Report Limit DF Received: 03/03114 17:41 Matrix: Water Prepared Analyzed CAS No. Qual HEM, Oil and Grease Analytical Method: EPA 1664B Oil and Grease ND mg1L 5.0 1 03/05/14 09:48 200.7 MET ICP Analytical Method: EPA200.7 Preparation Method: EPA200.7 Copper 6.8 uglL 5.0 1 03/04/14 08:50 03/05/14 22:49 7440-50-8 Lead ND uglL 5.0 1 03/04/14 08:50 03/05/14 22:49 7439-92-1 Zinc 429 ug1L 10.0 1 03104414 08:50 03/05/14 22:49 7440-66-6 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids 4.9 mglL 2.6 1 03/08/14 04:36 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, Date: 03/11/2014 02:05 PM without the written consent of Pace Analytical Services, Inc.. Page 4 of 17 ace Analytical "m..pacelabs.com ANALYTICAL RESULTS Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 Project: 907089 Baldor Pace Project No.: 92191654 Sample: C Lab ID: 92191654002 Collected: 03/03/14 14:55 Received: 03/03/14 17:41 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Anatytical Method: EPA 1664B Oil and Grease ND mg/L 5.0 1 03/05/14 09:48 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Copper 12.6 ug/L 5.0 1 03/04/14 08:50 03/05/14 22:52 7440-50-8 Lead 56.4 ug1L 5.0 1 03/04/14 08:50 03/05/14 22:52 7439-92-1 Zinc 132 ug1L 10.0 1 03/04/14 08:50 03/05/14 22:52 7440-66-6 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids 17.4 mg1L 3A 1 03/08/14 04:36 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, Date: 03/11/2014 02:05 PM without the written consentof Pace Analytical Services, Inc.. Page 5 of 17 aceAnaVical www.pwebbs.com ANALYTICAL RESULTS Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 Project: 907089 Baldor Pace Project No.: 92191654 Sample: D Lab ID: 92191654003 Collected: 03/03/14 14:58 Received: 03/03/14 17:41 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Analytical Method: EPA 1664E Oil and Grease ND mg/L 5.0 1 03/05/14 09:48 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Copper ND ug1L 5.0 1 03/04/14 08:50 03/05/14 22:56 7440-50-8 Lead 70.5 ug1L 5.0 1 03/04/14 08:50 03105l14 22:56 7439-92-1 Zinc 653 uglL 10.0 1 03/04/14 08:50 03l05114 22,56 7440-66-6 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mglL 2.7 1 03108/14 04:36 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, Date: 03/11/2014 02:05 PM without the written consent of Pace Analytical Services, Inc., Page 6 of 17 aceAnalyilcal www.pacelob.v.com 1 ANALYTICAL RESULTS Project: 907089 Baldor Pace Project No,: 92191654 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 Sample: I Lab ID: 92191654004 Collected: 03/03/14 15:00 Received: 03/03/14 17:41 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qua] HEM, Oil and Grease Analytical Method: EPA 16546 Oil and Grease ND mglL 5.0 1 03/05/14 09:48 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Copper ND uglL 5.0 1 03/04/14 08:5D 03/05/14 23:08 7440-50-8 Lead ND uglL 5.0 1 03/04/14 08:50 03/05/14 2$:08 7439-92-1 Zinc 476 uglL 10.0 1 03104/14 08.50 03/05114 23:08 7440-66-6 2640D Total Suspended Sclids Anatytical Method_ SM 2540D Total Suspended Solids ND mg1L 2.7 1 03108/14 04:37 Date: 03/11/2014 02:05 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc - Page 7 of 17 aceAnalytical mwpaeelabawm ANALYTICAL RESULTS Project: 907089 Baldor Pace Project Na_: 92191654 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, RC 28804 (828)254-7176 Sample: B ROOF Lab ID: 92191654005 Collected: 03103/14 15:04 Received: 03/03/14 17:41 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Zinc 212 uglL 1 D.0 1 03/04/14 08:50 03/05/14 23:11 7440.66-6 Date: 03/11/2014 02:05 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in fall, without the written consent of Pace Analytical Services, Inc.. Page 8 of 17 aceAnalytical wwwpacelabs.com ANALYTICAL RESULTS Project: 907089 Baldor Pace Project No.: 92191654 Pace Analytical Services, Inc. 2225 Riverside Qc Asheville, NC 28804 (828)254-7176 Sample: C ROOF Lab 10: 92191654006 Collected: 03103114 15:06 Received: 03103/14 17:41 Matrix: Water Parameters Results Units Report Limit OF Prepared Analyzed CAS No. Qual 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Zinc 99.3 ug1L 10.0 1 03104/14 08:50 03l05114 23:14 7440-66-6 Date: 03/11/2014 02:05 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc Page 9 of 17 ® Pace Analytical Services, Inc. 2225 Riverside Dr. aceAnalytica! Asheville, NC 28804 www,pacelabs.com (826)254-7176 ANALYTICAL RESULTS Project: 907089 Baldor Pace Project No.: 92191654 Sample: G ROOF Lab ID: 92191654007 Collected: 03/03114 15:10 Received: 03/03/14 17:41 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed GAS No. Qua] 200.7 MET ICP Analytical Method: EPA200.7 Preparation Method: EPA 200.7 Zinc ND ug/L 10.0 1 03/04/14 08:50 03/05/14 23:18 7440-66-6 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, Date: 03/11/2014 02:05 PM without the written consent of Pace Analytical Services, Inc.. Page 10 of 17 • Gary Masse From: Kucken, Darlene <darlene.kucken@ncdenr.gov> Sent: Monday, March 03, 2014 10.02 AM To: Gary Massey; Herbert, Laura C Subject: RE: Baldor Stormwater Inspection H i-Gary, - - Thank you for your time on Friday and for such thorough reporting. I enjoyed seeing your facility also. I will take a look at this as soon as possible and we will get hack to you with a report and letter. Darlene Kucken - Darlene.Kucken@ncdenr.gov North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Energy, Mineral, and Land Resources 2090 U.S. 70 Highway Swannanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7043 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. -A Go Green! print this email only when necessary. Thank you for helping NCDENR be environmentally responsible. ;From: Gary Massey[mailto:Gary.Massey@baldor.abb.com] Sent: Monday, March 03, 2014 9:50 AM To: Herbert, Laura C; Kucken, Darlene Subject: Baldor Stormwater Inspection Good Morning Laura and Darlene, I have attached the following information. MSD sheets for our machining fluids Sampling results as requested; • On August 7, 2013 I collected a stormwater sample directly from the gutter that drains the galvanized roof of the casting storage building. The drainage from this roof flows into conveyance points S (about 25% of the roof area) and C (50% of the roof area). These results are included along with samples collected from the conveyance points during that same event. Conveyance point I only carries runoff from the galvanized roof over the storage area at the back of the plant, If you have any questions or need any additional information please let me know. ,hanks again for your input and review of our program. I do have one Question. Will we get an inspection report for your visit ? EM a EnvlronmentalTesting Solutions, Inc. Certificate of Analysis Project name: Baldor Dodge Reliance Collection date: 7-Aug-13 Date received: 8-Aug-13 Sample identification: Storage Building Roof - Grab PO Box 7565 Asheville, NC 28802 Phone: (828)350-9364 Fax: (928)350-9368 Project number: 130808.505 Sample number: 108583 Parameter Method Result RL Units Date Analyst Footnotes Analyzed Copper 200.8 <0.0050 0.0050 mg/L 19-Aug-13 PJF 1 Lead 200.8 <0.0010 0.0010 mg/L 19-Aug-13 PJF 1 Zinc 200.8 0,31 0.0050 mv/L 19-Avg-13 PJF Footnotes: RL = Reporting Limit. Values are reported down to the Reporting Limit only. 1. Analyzed by Prism Laboratories, Inc. Date reviewed: 09-23-1-3 NC Certification Number: 600 Data reviewed by: Kelley E. Keenan SC Certification Number: 99053 NC Drinking Water Certification Number: 37786 Signature: (A— This report should not be reproduced. exept in its entirety, without the written consent of Environmental Testing Solutions. Inc The results in this report relate only to the samples submitted for analysis. s Baldor Electric Stormwater Summary a- CoRaen 2 and 3 Ter II Required OUTFALL Sample Type I B C D Benchmarks 50 6-9 0.007 0.03 0.067 15 so 6-9 0.007 0.03 0.067 15 50 6-9 0.007 0.03 0.067 15 Sample Date 155 pH F-Cu-7 Pb "tZW -7 0&G TSS pH =Cirl: Pb "Zoe O&G T55 pH Cu Pb Zn O&G 1/13/2016 Tier 11 0.0461 4.005 0.0713 2/15/2015 Tier 11 0.0332 0.0136 0.554 3/12/2015 Tier ll 0.0642 0,0074 0.271 4/12/2016 Semi -Annual 79 6.2 <.005 <.005 0.508 <5 14-9 63 0.0111 0.052 0.171 <5.0 <4 7.2 0.0127 0.0132 0.158 <5-0 4/22/2016 Duplicate samples 0.133 0.133 5/5/2016 Tier 11 0.0521 Jun-16 Tier II no flow 7/5/2016 Tier 11 0.0218 <.005 0.13S Aug-t6 Tier II no flow 9/27/2016 Tier 11 <005 O.00ss 0.113 10/7/2016 Tier it 0.0229 0.0146 QM55 11/29/2016 Semi -Annual 9.7 6.4 <.005 <.005 0.215 <5.0 33.5 6.4 0.0293 0.0288 0.18 <5.0 8.9 6.6 0.03 0.0601 0.16 <5.0 12/12/2016 Duplicate Tier II 0.298 0.017 0.181 0.0127 <.005 0.068 1/23/2017 Tier II 0.0107 0.0822 2/7/2017 Tier 11 0.0875 0.166 3/1/2017 Tiede O.00s3 0.0847 4/1/2017 Did not Sample 5/1/2017 Did not Sample 6/8/2017 Semi Annual 15.8 6.4 0.005 e.005 0.709 <5 <2.5 6.6 0.0068 4.005 0.436 <5 <2.5 7.2 0.0262 0.0175 0.136 <5.0. 7/15/2017 Tier II 0.0122 0.181 8/4/2017 Tier 11 0.0084 0.239 9/1/2017 No Sample 1012312017 Tier II <.005 0.0826 11/7/2017 Tier It 0.005 0.085 12/5/2017 Tier 11 0.0186 0.0211 1/22/2018 Tier 11 0.0892 0.371 2/7/2018 Tier 11 <.005 0.129 3/24/2018 "tier II 0.0073 0.257 4/112018 No Sample 5110/2018 Tier 11 0.0106 0.1571 6/21/201S Semi -Annual 7.2 6.3 0.0081 <.005 0.955 <5 14.8 6.4 0.026 0.0199 0.176 <5 <3.5 7.1 <.005 0.0115 0.146 <5 7/24/2018 Tier II 0.0063 0.0306 B/1/2018 No Sam le 9/15/2018 Tier II <.005 0.035 Baldor Electric Stormwater Sumrr OOTFALL E F G Benchmarks 50 6-9 0.007 0.03 0.067 15 50 6-9 0.007 0.03 0.067 15 S0 6-9 0.007 0.03 0.067 15 Sample Date TSS pH Cu Pb Zn O&G T5S pH Cu Pb Zn O&G TSS PH Cu Pb Zn O&G 1/13/2016 0.09 2/15/2016 0.13 3/12/2016 -- 0.0944 4/12/2016 <2.9 73 c.005 <.005 0.143 <5 <3.6 7.1 <.005 <.005 0.0485 <5.0 <3.6 6.3 <.005 O.D077 0.0507 <5.0 4/22/2016 5/5/2016 0.063 Jun-16 7/5/2016 0,0838 Aug-16 9/27/2016 0.135 10/7/2016 0.0981 11/29/2016 11.7 7.1 <.005 <.WS 0.073 <5.0 6.6 7.2 <_005 <.005 0.0407 <5.0 75.3 6.3 0.0138 0.0463 0.276 <5.0 12/12/2016 34.4 0.0058 0.0166 0.104 1/23/2017 O.G65 0.104 2/7/2017 0.0775 0.134 3/1/2017 0,0739 0.0818 4/l/2017 - 5/1/2017 6/8/2017 0.5 7 0.0115 <,005 0.152 <5.0 <2,S 7 0,0138 0.0122 0.133 <5.0 <2.9 6.4 0.0153 0.0231 0,197 <5.0 7/15/2017 0.0711 0.0473 8/4/2017 0.107 U93 911/2017 10/23/2017 0.091 0.0452 11/7/2017 D.0374 0.0839 12/5/2017 0.294 0.222 1/22/2018 0.171 0.11 2/7/2018 0.0468 0.253 3/24/2018 0.14 0.0615 4/1/2018 5/10/2-M 0.0851 0.0774 6/21/2018 <2.8 71 <,005 <.005 0.0561 <5 <4.5 7.1 <.005 <.005 0.0557 <5.0 13.4 6.4 0.0067 0.0122 0.118 <5.0 7/24/201.8 0.0087 0.0135 8/1/2018 9/15/2018 0,0171 0.0375 Baldar Electric Stormwater Sumrr OUTFALL H Parking Lot 1 Benchmarks 50 6-9 1 0.307 1 0.03 0.067 is s0 6-9 0.007 0.03 0.067 is Sampie Date TSS pH Cu Pb in O&G TSS pH Pb �;Zif" 1 O&G 1/13/2016 2/15/2016 3/12/2D16 4/12/2016 <2.9 6.2 <.005 <.005 0.353 <S.0 4/22/2016 0.228 5/5/2016 Jun-16 7/5/2016 Aug-16 9/27/2016 10/7/2016 11/29/2016 <2.7 6.6 <.005 <,005 0.149 5 12/12/2016 0.152 1/23/2017 2/7/2017 3/1/2017 4/1/2017 5/1/2017 6/8/2017 3.7 6.5 <,005 <,005 0.763 <5.0 7/15/2017 8/4/2017 9/1/2017 10/23/2017 11/7/2017 12/5/2017 1/22/2018 2/7/2018 3/24/2018 4/1/2018 5/10/2018 Sampled parking lot because of casting storage In area, 6/21/2018 <2.8 6.3 <.005 <.005 .120 <5 <2.6 6.3 <.005 <M5 0,226 <5.0 7/24/2018 8/1/2018 9/15/2018 ]SAT-MOR A MEMBER OF THE ABB GROUP Asheville Plant 70 Reems Creek Rd Weaverville, NC 28787 828-645-4235 January 24, 2014 North Carolina Department of Environment and Natural Resources Division of Land Resources 2090 U.S. Highway 70 Swannanoa, NC 28778 Attn: Ms. Laura Herbert, Regional Supervisor Re: Baldor Electric Company, Inc. General Permit No. NCGO030070 Dear Ms. Herbert: Baldor Electric Company, Inc (Baldor) has a current stormwater discharge permit with the Division of Land Resources. Over the past two semi-annual reporting periods (i.e., 2013) Baldor has four Discharge Points that have exceeded copper and/or zinc benchmark limits. All other stormwater parameters have been in compliance. At the Baldor site only Discharge Points E and F directly discharge stormwater to Outfalls. The other five Discharge Points — B, C, D, G, and I — discharge to fields, vegetated areas, or ditches that eventually flow to an Outfall. After the first semi-annual report of 2013 Baldor conducted a Tier I evaluation of potential metals discharges. Based on that evaluation, Baldor instituted the following actions to limit metals releases. 1. Instituted daily wet floor sweeping in Babbitt Room work areas. 2. Instituted dry HEPA vacuuming in Babbitt Room work areas three times per week. 3. Conduct rotary brush vacuuming of forklift paths three times per week on paved outside raw material storage area and casting building. 4. Instituted daily wet sweeping in manufacturing area aisles seven times per week. 5. Installed filter inserts into stormwater drop inlets in outside paved area. After these activities we collected periodic stormwater Discharge Point samples as listed in Table 1. These values demonstrate that our efforts are having little to no effect on copper and zinc stormwater discharges. We have several observations about Table 1: 1. Four Discharge Points exhibit a consistent pattern of metal discharges above respective Benchmark limits. 2. Two Discharge Points exhibit a consistent pattern of metal discharges of one above and the rest below respective Benchmark limits. 3. Four Discharge Points exhibit an inconsistent pattern of metal discharges. Exception is sources E and F, whose compliance is undetermined because of a lack of sampling data. 4. Discharge Points D, E, and F are exclusively roof discharges (i.e., no manufacturing floor or paved area drainage) and none of our Tier 1 activities had any impact on their metal discharges. After the second 2013 semi-annual testing on November 17, Baldor entered the Tier II response category for Discharge Points B, C, D, and 1. The circled values in Table 1 represent two consecutive reporting periods of metals concentrations above Benchmark Limits. We recently had our environmental contractor re -review our entire MSDS collection. This review focused on materials that contain copper or zinc as a minor constituent or as a chemical additive or stabilizer. This review"] dentified 21 materials that contain copper and/or zinc. Table 3 lists these materials and identifies whether their individual physical properties, use locations, or use practices promotes them being spread inside the plant or tracked outside. Of all the copper and/or zinc -containing materials only one is a candidate source of metals to stormwater; other materials either contain only minute amounts of either metal or the material is used in very small quantities or it used in only one area from which it is not available to spread. We believe the Rockwell Zinc -Ammonia Chloride solution used in the Babbitt Room is likely a source of zinc discharges to the roof via the room ventilator. This area drains to conveyance point D. Consequently, we have added a Babbitt Room air pollution control device to the 2014 capital improvement list. Copper is less common in our raw materials or infrastructure. It is in many if not all electrical connections but the nature of this activity is such that copper does not come into contact with stormwater. Copper is- also in certain water and lubricant piping; which rarely comes into contact with stormwater. None of the materials listed in table 3 are likely to contribute copper to stormwater. Zinc is present in two materials that routinely come into contact with stormwater: 1. Roofing materials. 2. Stormwater discharge pipes. Ultimately, we must conclude that most zinc found in our stormwater Discharge Point samples arises from infrastructure sources, A stormwater sample collected from the roof of the casting building on August 7, 2013, had a zinc level of 0.31 milligrams per liter (mg/L). This roof area drains to conveyance points B and C. We have not yet evaluated the stormwater discharge pipes themselves for zinc. We believe that the copper discharges are also from infrastructure sources but we cannot identify sources. Ultimately, this opinion comes from the lack of copper containing -materials available to become part of a stormwater discharge. In light of our efforts to determine copper and zinc sources in our stormwater, we request that the Division of Land Resources relieve Baldor of the Tier II monthly sampling requirement for Discharge Points B, C, D, and I for copper or zinc. Please contact me at 828-645-1718 or at Gary. Massey@Baldor.ABB.corn if you have questions or comments. Sincerely, Baldor Electric Company, Inc Gary Massey EHS CC: Daniel J March, Pisgah Environmental Services SAT-I)OR A MEFBER cr rHE ABB GROUP Table 1. Baldor Stormwater Metals Concentrations in 2013 upper' � Lead'-' Zinel,2 Source Jan 303 Feb 7 Apr 4 N1ay IS Aug 7 Nov 173 Nov 26 Jan 303 Feb 7 Apr 4 May 18 Aug 7 Nov 173 Nov 26 Jan 303 Feb 7 Apr May 1 Aug 7 Nov 1.73 Nov 26 B 0:0181 0 NIS�05D.005 0.00S D.D5980:OD5 <0;045 NIS 0.0059 0.05 3 1_370.226 NIS0 0. 5 0.278 1 0.269 C O.UIx i^ �0.0474 0.0210 0,0097 0.028 0.0071 0.006 trft?J$ - ff-W !{ '�1 669ii D 9 iJ�n03 D.0725 0. �29 0.037 -0 0.04 9 0.0767 D <0.005 NIS <0.005 NIS <0.005 <0.005 <0.045 0.0398 0.0096 0.0309 O.D527 0.100 0,0085 0.0065 0.D898 0.109 4.155 0.214 0.560 [1.154 0P E <0.005 NIS NIS N15 NIS <0.005 NIS <0.005 N15 NIS NIS NIS <0,005 N/5 0: 13 NIS NIS NIS. , NIS 0. 2 F <0.005 NIS NIS NIS NIS <0,005 <0.005 <0.005 NIS NIS NIS NIS <0.005 <0.005 0.0256 NIS NIS NIS NIS D,0815 0 G 0.0087 0.0111 i-0.005 <0.005 0.0069 <0.005 NIS WW' 4 I~'�'M 0:0245 t):0,1".4, U;UIi6 i3: i 131a NIS 6Off1?1 lf: i0lgij N7 `�??3i1 O'.D'4!1`7 I <0.005 N/S NIS I NIS <0.005 <0.005 <0.005 <0.005 NIS NIS NIS <0.01 <0.005 1 <0.005 0.0747 0.220 NIS 0.141 1 0.500 0.179 0.094, Bench mark 0.007 0.030 0.067 ' Bolded values exceed Benchmark Limit. Z Color groupings: Yellow highlighted values have consistent pattern of metal discharges above respective Benchmark Limits. B6l e;FiiF! iijht d values have consistent pattern of metal discharges of one above and the rest below respective Benchmark Limits. Gieyhighlig6ted values have inconsistent pattern of metal discharges. Exceptions are sources E and F, whose pattern is undetermined because of a lack of sampling data. Unhighlighted values have consistent pattern of no metal discharges. 3 Semi-annual sample. Table 2. Discharge Point Sources Source Metal Drainage F3 Zinc Paved raw material storage area driveway above truck unloading dock for Castro Building. C Cu, Pb, Zn Roof of Casting Building and paved raw material storage area includina north forklift ramp. D Pb, Zn Main buildipp, roof including Babbitt Room roof with ventilator and ba house discharges. E Zn Main buildin roof west and near Babbitt Room roof. F Zn Main building roof northwest and near Babbitt Room roof. G Pb. Zn Paved raw material storage area including south forklift ramp. 1 Zn Main building roof south of Babbitt Room. Table 3. Materials Containing Copper and/or Zinc Material Copper Content ei ht % Zinc Content ei ht % Area Used Susceptible to -Spreading? Amabrasive <0.20 --' Flexid ne Shot Material not used, bottled and shipped with product. Bronze Alloys 55-99 045 Tool Room Low volume contained to specific area. Not used in production areas. Alkaline Batteries -- 11-16 Primarily Maint. Material not crushed or otherwise available to spread. ALL RTW Carbide Grade' 1-50 1-25 Tool Room Solid material, not ground or modified, not used in production areas. Carbon &Alloy Steels 03-1.9 2 oz/fl Tool Room Material used in small quantities, not used inroduction areas. Copper -Zinc Alloys N/L2 NIL Powder metal area In solid forth, used as an additive for heat treat process. Diamond or Cubic Bordon GrindingWheels 1-10 -- Tool Room Tool room onl , not used in production areas. Tin Flux and Solder N/L N/L Work -up Area Small quantities, only used in this area. Gray Iron 0.01-1.00 -- Production Ubiquitous, but very low Cu content and no Zn content. Daily aisle cleaning with wet sweeper. No small chips or grindings. High Seed Babbitt 3-8 -- Not Used High Speed Babbitt 3-8 -- Not Used High Test Top !Flux -- ZnCI Work -up Area Used in small quantities in one area lnfiltratin Powder (BSMn-il) 92-97 1-7 PM Area No longer used Johnson's Solderin Fluid -- 39 Work-u Area Used in small guantities in one area Mobil Grease HP222 -- 1-5 Maintenance Shop Minimal use for maintenance purposes Mobil grease XHP(97E898) -- <2.5 Maintenance Shop Minimal use for maintenance purposes l4tobilux EP 0(641290-06) -- <2.5 Maintenance Sb op Minimal use for maintenance purposes Rel-I I AB Powder Metal 2.0 -- Production Used in the press area of the plant only. We perform dail aisle cleaning with wet sweeper in this area. Rockwell Zn-Am Chloride Solution -- 37-40 Babbitt Room Room is ventilated to the roof. This area discharges to conveyance point D. Likely source of Zinc. Static Intercept <10 -- Packaging Area Desiccant packs. Material not crushed, released, or otherwise available to s read. Sunnen floning Stones 5 -- Tool Room Used occasionally for special boring applications in Toolroom. Not in production areas. Sunnen Metalbond Honing Stone 85 12 Tool Room Used occasionally for special boring applications in Toolroom. Not in production areas. Presumed zero (0). 2 Quantity Not Listed. Presumed to be less than 1 perecnt; which is the MSDS minimum reportable quantity. Baldor Electric Company 70 Reems Creek Weaverville, NC 28787 March 3, 2014 c Discharge Point Activity Area .(ft2)(ft2) Impervious Area ' ` Rainfall (ft ' Rainfail Volume (ft3) Rainfall Volume (gal) Rainfall Volume (MG) PH A 10,716 6,750 0.011667 79 589 0.0006 N/S B 10,135 8,460 0.01 1667 99 738 0.0007 7.0 C 32,774 23,695 0.011667 276 2,068 0.0021 6.5 D 9,500 9,500 0.0 11667 I H 829 0.0008 7.4 1 49,644 49,644 0.011667 579 4,332 0.0043 N/S 1�- 75,369 75,369 0.011667 879 6,577 0.0066 N/S C 37,032 37,032 0,011667 432 3,232 0.0032 N/S 1-1 1 12,000 1 12,000 0,011667 1 140 1,047 0.0010 N/S 9,000 1 9,000 0.011667 1 105 785 0.0008 1 6.9 Baldor Electric Company — Stormwater 4 �l r�W c _ � Disc►+ ¢ � ry e ROOF d I FLOW I 10 1 { ROOF 1 FLO I FEW ROOOF FF I� N Rtl0 I FLOW © / FL❑ � CZ)) EGEND rn[ rs�.. to j7f ROOF ROOF I FLOW ^ "` 0 ROOF Q 1! FLOW I `J FLOW 1 .. w r Ogle 4 ® 4 Q St01`n wilier, flow © _ R► W4 .%"". zwa IRi3flF FLO a s Yr V—v OF FOLOW � G hs ✓� f/ 2 Figure 1. 13aldor Electric Company Stornmater Plow to Discharge Points A — I and Outfalls I — 3. = 5ealc; I inch1621'ces Baldor Electric Company — Storniwater 3 = A.LX)0=� A MEMBER OF THE ASS GROU; January 24, 2014 North Carolina Department of Environment and Natural Resources Division of Land Resources 2090 U.S. Highway 70 Swannanoa, NC 28778 Attn: Ms. Laura Herbert, Regional Supervisor Re: Baldor Electric Company, Inc. General Permit No. NCG0030070 Dear Ms. Herbert_ Asheville Plant 70 Reems Creek Rd WeaverviIIe, NC 28787 828-645-4235 Z/L/ _WV, Baldor Electric Company, Inc (Baldor) has a current stormwater discharge permit with the Division of Land Resources. Over the past two semi-annual reporting periods (i.e., 2013) Baldor has four Discharge Points that have exceeded copper and/or zinc benchmark limits. All other stormwater parameters have been in compliance. At the Baldor site only Discharge Points E and F directly discharge stormwater to Outfalls. The other five Discharge Points — B. C. D, G, and I — discharge to fields, vegetated areas, or ditches that eventually flow to an Outfall. After the first semi-annual report of 2013 Baldor conducted a Tier I evaluation of potential metals discharges. Based on that evaluation Baldor instituted the following actions to limit metals releases. 1. Instituted daily wet floor sweeping in Babbitt Room work areas. 2. Instituted dry HEPA vacuuminb in Babbitt Room work areas three times per week. 3. Conduct rotary brush vacuuming of forklift paths three times per week on paved outside raw material storage area and casting building. 4. Instituted daily wet sweeping in manufacturing area aisles seven times per week. 5. Installed filter inserts into stormwater drop inlets in outside paved area. After these activities we collected periodic stormwater Discharge Point samples as listed in Table 1. These values demonstrate that our efforts are having little to no effect on copper and zinc stormwater discharges. We have several observations about Table 1: 1. Four Discharge Points exhibit a consistent pattern of metal discharges above ;�w .:_.:•_, r. respective Benchmark limits. ` F E B 6 2014 I. ward Qva11ty Sectlon !'rhiville 2. Two Discharge Points exhibit a consistent pattern of metal discharges of one above and the rest below respective Benchmark limits. 3. Four Discharge Points exhibit an inconsistent pattern of metal discharges. Exception is sources E and F. whose compliance is undetermined because of a lack of sampling data. 4. Discharge Points D. E, and F are exclusively roof discharges (i.e., no manufacturing floor or paved area drainage) and none of our Tier l activities had any impact on their metal discharges. After the second 2013 semi-annual testing on November 17, Baldor entered the Tier II response category for Discharge Points B. C, D, and 1. The circled values in Table 1 represent two consecutive reporting periods of metals concentrations above Benchmark Limits. We recently had our environmental contractor re -review our entire MSDS collection. This review focused on materials that contain copper or zinc as a minor constituent or as a chemical additive or stabilizer. This review identified 21 materials that contain copper and/or zinc. Table 3 lists these materials and identifies whether their individual physical properties, use locations; or use practices promotes them being spread inside the plant or tracked outside. Of all the copper and/or zinc -containing materials only one is a candidate source of metals to stormwater; other materials either contain only minute amounts of either metal or the material is used in very small quantities or it used in only one area from which it is not available to spread. We believe the Rockwell Zinc -Ammonia Chloride solution used in the Babbitt Room is likely a source of zinc discharges to the roof via the room ventilator. This area drains to conveyance point D. Consequently_ we have added a Babbitt Room air pollution control device to the 2014 capital improvement list. Copper is less common in our raw materials or infrastructure. It is in many if not all electrical connections but the nature of this activity is such that copper does not come into contact with stormwater. Copper is also in certain water and lubricant piping; which rarely comes into contact with stormwater. None of the materials listed in table 3 are likely to contribute copper to stormwater. Zinc is present in two materials that routinely come into contact with stormwater: 1. Roofing materials. 2. Stormwater discharge pipes. Ultimately, we must conclude that most zinc found in our stormwater Discharge Point samples arises from infrastructure sources. A stormwater sample collected from the roof of the casting building on August 7, 2013, had a zinc level of0.31 milligrams per liter (mg/L). This roof area drains to conveyance points B and C. We have not yet evaluated the stormwater discharge pipes themselves for zinc. We believe that the copper discharges are also from infrastructure sources but we cannot identify sources. Ultimately, this opinion comes from the lack of copper containing -materials available to become part of a stormwater discharge. In light of our efforts to determine copper and zinc sources in our storMwater, we request that the Division of Land Resources relieve Baldor of the Tier II monthly sampling requirement for Discharge Points B. C. D, and I for copper or zinc. Please contact me at 828-645-1718 or at Gary,Massey@Baidor.ABB.com if you have questions or comments. Sincerely, Baldor Electric Company, Inc Gary Massey EHS CC: Daniel J March, Pisgah Environmental Services BALI]OR A MEMBER OF THE ABB GROUP "liable 1. Baldor Stormwater Metals Concentrations in 2013 Copper"' Lead'''' Zinc1.2 Source Jan 303 Feb 7 Apr 4 Nlay 18 Aug 7 Nov 173 Nov 26 Jan 303 Feb 7 Apr 4 Nlay 18 Aug 7 Nov 173 Nov 26 Jan 303 Feb 7 Apr 4- May l Aug 7 Nov 173 Nov 26 13 0.0181 0 <(}.00$ NIS 1. <O:OUS <OA05 O.d598 �0.005, �0.005 N/S 0.0059. <0,005, �O.005 d.348 .137 0.226 NIS 0 0 f1.278 0,269 C f1.f1184 0.0474 0.0216 0.0097 0.028 fl d071 0.006 .0? U83 .009 t) 00 1.003 0.0725 0. .129 0.03 73 fi0 60 889 0.0767 1) <0.005 NIS <0.005 NIS <0.005 <0.005 <0.005 0.0398. 0.0096 0.0309 0.0527 6.100 0,0085 0.0085 0.0898 0.109 0.155 0.214 O.S60 0,154 (11.1110 H <0.005 NIS NIS NIS NIS <0.005 NIS <0.005 NIS NIS NIS NIS <0.005 NIS 0.03I3 NIS NIS NIS NIS (}.0)32 NIS I- <0.005 NIS NIS NIS NIS <0.005 <0.005 <0.005 NIS NIS NIS NIS <0.005 <0.005 0.025E NIS NIS NIS NIS 0.0815 0.0390 Ci 0.0087 0.011-f �0,'005 <0.005 0.0069 �-0.005 NIS .(144 l 021- ). 114 U? .01 I I NIS O60I .,S. UA8 I. i : NIS 1 N1SNIS <0.005 <0.005NISNIS NI <0.01<0.005 <0.0U5 f ( .141<0.005 F0 0.500 I1.179 0.0944 Bench mark 0.007 0.030 0.067 ' Bolded values exceed Benchmark Limit. '• Color groupings: Ycllow hi ghli ghted values have consistent pattern of metal discharges above respective Benchmark Limits. flue hi hli life values have consistent pattern ofmctal discharges of one above and the rest below respective Benchmark Limits. Grey highlighted values have inconsistent pattern ofmctal discharges. Exceptions are sources I: and F. whose pattern is undetermined hecause of a lack of sampling data. ljnhighlightcd values have consistent pattern of no metal discharges. 3 Semi-annual sample. Table 2. Discharge Point Sources Source Metal Drainage 13 Zinc Paved raw material storage area driveway above truck unloading dock for Casting Building. C Cu, Pb, Zn Roof of Casting BUildin } and paved raw material storage area including north forklift ramp. D Pb, Zn Main building roof including Babbitt Room roof with ventilator and ba house discharges. E In Main building roof west and near Babbitt Room roof. F Zn Main building roof northwest and near Babbitt Room roof. G 13b, Zn Paved raw material storage area including south forklift ramp. [ Zn Main building roofsottth of Babbitt Room. Table 3. Materials Containing Copper and/or Zinc Copper Zinc Content Content Material Wei ht % (Weight % Area Used Susceptible to Spreading? Amabrasive <0.20 -- Flcxid yne Shot Material not used, bottled and shipped with product. Bronze Alloys 55-99 0-45 Tool Room LOW volume contained to specific area. Not used in areas. Alkaline Batteries -- 1 1-16 Primarily Maint. _production Material not crushed or otherwise available to spread. ALL RTW Carbide Grade 1-50 1-25 Tool Room Solid material, not ground or modified, not used in areas. Carbon & Alloy Steels .03-1.9 2 ozlft2 Tool Room _production Material used in small quantities, not used in areas. Copper -Zinc Alloys N/L' NIL Powder metal area _production In solid form, used as an additive for heat treat process. Diamond or Cubic Bordon Grinding Wheels 1-10 -- Tool Room Tool room only, not used in production areas. Tin Flux and Solder N/i, NIL Work -Up Area Small quantities, only used in this area. Ubiquitous, but very low Cu content and no Zn Gray Iron 0.01-1.00 -- Production content. Daily aisle cleaning with wet sweeper. No small chips or grindings. High Speed Babbitt 3-8 -- Not Used High Speed Babbitt 3-8 -- Not Used High Test Top Fhtx -- ZrtCl Work-u j Area Used in small quantities in one area Infiltratin Powder 135Mn-il 92-97 1-7 PM Area No longer used Johnson's Soldering Fluid -- 39 Work -Lip Area Used in small quantities in one area Mobil Grease I-IP222 -- 1-5 Maintenance Shop Minimal use for maintenance purposes Mobil grease XHP(97E898) -- <2.5 Maintenance Shop Minimal use for maintenance purposes Mobilux El' 0 641290-06 -- <2.5 Maintenance Shop Minimal use for maintenance purposes Rcl- I 1 All Powder Metal 2.0 -- Production Used in the press area of the plant only. We perform daily aisle cleaning with wet sweeper in this area. Rockwell Zn-Am Chloride Solution -- 37-40 Babbitt Room Room is ventilated to the roof. This area discharges to conveyance point D. Likely source of Zinc. Static Intercept <10 -- Packaging Area Desiccant packs. Material not crushed, released, or otherwise available to spread. Sunnen Honing Stones 5 -- Too] Room Used occasionally for special boring applications in Toolroom. Not in production areas. Sunnen Metalbond Honing Stone 85 l2 Too] Room Used occasionally for special boring applications in Poolroom. Not in production areas. ' Presumed zero (0). Quantity Not Listed. Presumed to be less Ilian 1 percent; which is the NISDS minimum reportable quantity. Stepp, Jonathan From: Sent: To: Cc: Subject: Hi Bethany and Ken, Stepp, Jonathan Wednesday, January 15, 2014 9:27 AM Georgoulias, Bethany; Pickle, Ken Herbert, Laura C FW: Baldor Weaverville I received this e-mail yesterday from a consultant, Dan March (former DENR Air Quality employee). I just wanted to give you another example of the correspondence we are getting related to the copper and zinc benchmarks in the NCG03 permit. I have advised Mr_ March to pursue the collapsed tiered response. Additionally, I encouraged him to get Baldor personnel more involved with the permit and hand over the qualitative monitoring to them. In my experience, this will force them to have a better understanding of stormwater at their site and lead to better outcomes from an environmental and compliance standpoint, Thanks, Jonathan Jonathan Stepp—Jonathan.Stepp@ncden,r.gov North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Energy, Mineral, and Land Resources - Land Quality Section 2090 U.S. 70 Highway Swannanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7043 Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third parties. From: Daniel March [mailto: is ah-air vt.edu] Sent: Tuesday, January 14, 2014 10:45 AM To: Stepp, Jonathan Subject: Baldor Weaverville ,Jonathan, Happy Ne-vv Year. We need clarification for the requirements of Tier II sampling for my client Baldor Electric Company (Buncombe County) in Weaver%ille, NC (NCG030000). The general permit issued October 25, 2012, describes actMties stemming from benchmark exceedances (Part II Page 7 of 10) in two consecutive monitoring periods as: The perm ittee shall: 1. Repeat all the required actions outlined above in Tier One. 2. Immediately institute monthly monitoring for all parameters. Conduct monthly monitoring at every outfall where a sampling result exceeded the benchmark value for two consecutive samples. Monthly (analytical and qualitative) nror7itoring shall continue until three consecutive sample results are below the benchmark values or within benchmark range. 3. Submit a monthly monitoring report indicating "No Flow" if no discharge occurs during the sampling period. 4. Benchmark exceedances for a different parameter separately trigger a tiered response. $. Maintain a record of the Tier Two response and monitoring results in the SPPP. The above sampling requirements call for analysis of "all parameters". This includes all analytical and all qualitative parameters. Baldor has never had a measurable stormwater Oil and Grease discharge in the past several }rears my company has collected samples and reported results. Considering that the analyses are conducted on Discharge Points rather than actual Outfalls, we assume that surface waters are well protected from potential Oil and Grease releases from the Baldor facility. Does DLR have a application and approval mechanism to waive Oil and Grease sampling, analysis, and reporting requirements during the Tier I1 process? These analyses cost about $bo each plus the cost of collecting and reporting. So, the cost savings are not insignificant. The same situation applies to the qualitative monitoring requirement except that there are no analytical costs. What information would DLR need to process such a request for respite from Tier 11 permit requirements for Oil and Grease and Qualitative monitoring? Call me �N ith questions, Dan March Pisgah Environmental Services, LLC 9 Woodvale Avenue Asheville. NC 28804 www.pisgah-air.com 828-768-3335 - Cell 828-255-1092 -Fax MALDOI - A MEMBER OF THE ABB GROUP AshevilIePlant 70 Reems Creek Rd Weaverville, NC 28787 828-645-4235 January 24, 2014 North Carolina Department of Envirorinicnl and natural Resources Division of Land Resources 2090 U.S. Highway 70 Swannanoa, NC 28778 Attn: Ms. Laura Herbert, Regional Supervisor Re: Baldor Electric Company, Inc. General Permit No. NCGO030070 Dear Ms. Herbert: Baldor Electric Company. Inc (Baldor) has a current stormwater discharge permit with the Division of Land Resources. Over.the_past two semi-annual reporting.periods-(i.e.,.201'3)] Baldor has four Discharge Points that have exceeded copper and/or zinc benchmark limits. All other stormwater parameters have been in compliance. At the Baldor site only Discharge Points E and F directly discharge stormwater to Outfalls. The other five Discharge Points — B. C, D, G, and I — discharge to fields, vegetated areas, or ditches that eventually -flow to_an_O.utfall_ After the first semi-annual report of 2013 Baldor conducted a Tier I evaluation of potential metals discharges. Based on that evaluation Baldor instituted the following actions to limit metals releases. 1. Instituted daily wet floor sweeping in Babbitt Room work areas. 2. Instituted dry HEPA yacuuming'in Babbitt -Roam pork -areas three times per week 3. Conduct rotary brush vacuuming of forklift paths three times per week on paved outside raw material storage area and casting building. 4. Instituted daily-wet-sweeping•in-manufacturing area aisles°seven'tiM per week._.l 5. Installed filter inserts into stormwater drop inlets in outside pavearea. After these activities we collected periodic stormwater Discharge Point samples as listed in Table 1. These values demonstrate that our efforts are having little -to -no -effect on-copper-andl ,zinc-stormwafer discharges. We have several observations about Table-1: 1. Four Discharge Points exhibit a consistent pattern ofimetal`diseh_ armies above respective BURchmark_limits.' JAN 27 2014 1..;,nd Quality Sectlan 11 r1 oet-out h 1 v.bvj� A 'Ix J� 2. Two Discharge Points exhibit a consistent pattern of metal discharges of one above and the rest below respective Benchmark limits. I. Four Discharge Points exhibit an inconsistent pattern of metal discharges. Exception is sources E and F. whose compliance is undetermined because of a lack of sampling data. 4. Discharge-Points.D,,E,_and. F are exclusively roof discharges.(i.e.,.no.manufacturing Moor or paved area drainage) and none of our Tier 1 activities had any impact on their metal discharges. After the second 2013 semi-annual testing on November 17, Baldor entered the Tier II response category for Discharge Points B, C, D, and 1. The circled values in Table I represent two consecutive reporting periods of metals concentrations above Benchmark Limits. We recently had our environmental contractor re -review our entire MSDS collection. This review focused on materials that contain copper or zinc as a minor constituent or as_a� chemical.additive-or-stabilizer. Tfiis review identified 21 materials that contffm copper and/or zinc. Table 3 lists these materials and identifies whether their individual physical properties, use locations, or use practices promotes them being spread inside the plant or tracked outside. Of all the copper and/or zinc -containing materials only one is a candidate source of metals to ,,stormwater;; other materials either contain only minute amounts of either metal or the material is used in very small quantities or it used in only one area from which it is not available to spread. tWe-belieN e he Rockwel]-Zinc-Ammonia Chloride solution used-iti the B5bI5itt Room is likely a source of zinc discharges'to the roof `via the room ventilator.71s area drains to !. Cn conveyance point D:�Consequently,, we have added a Babbitt-Room-air-pollution-contrnl device to`the 2014 capital-imooveinent-list: Copper is less common in our raw materials or infrastructure. It-is_in_many_if not all electrical lco a tions bet the nature`of this activity is such that_copper_does-not-come-into.contact_with� stormwater. Copper is.al_so i� n_ certa wni titer -and'lubricant piping; which.razely_comes.into� contact with.stormwat_ None of the materials listed in table 3 are likely to contribute copper to stormwater. Zinc is present in two materials that routinely come into contact with stormwater: 1. Roofing materials./ 2. Stormwater discharge pipes. Ultimately, we must conclude that most zinc found in our stormwater Discharge Point samples arises from infrastructure sources. A stormwater sample collected from the roof of the casting building on August 7, 2013, had a zinc level of 0.31 milligrams per liter (mg/L). This roof area drains to conveyance points B and C. We have not yet evaluated the stormwater discharge pipes themselves for zinc. JAN 2 7 2014 I -and Quality Section We believe that the copper discharges are also from infrastructure sources but we cannot identify sources. Ultimately, this opinion comes from the lack of copper containing -materials available to become part of a stormwater discharge. In light of our efforts to determine copper and zinc sources in our stormwater, we request that the Division of Land Resources relieve Baldor of the Tier II monthly sampling requirement for Discharge Points B. C, D,.and"I'for copper or zinc. Please contact me at 828-645-1718 or at Gary.Massey@Baidor.ABB.com if you have questions or comments. Sincerely, Baldor Elec is Company, Inc ary Massey EHS CC: Daniel J March, Pisgah Environmental Services 1- , I-tcj Quality Section Asheville BALDOR A MEMBER OF THE ABS GROUP Table 1. Baldor Stormwater Metals Concentrations in 2013 Copper`.2 Lead''' Zinc"' ` Source Jan 303 Feb 7 Apr 4 May 18 Aug 7 Nov 17' Nov 26 Jan 303 Feb 7 Apr 4 May 18 Aug 7 Nov 173 Nov 26 Jan 30' Feb 7 Apr 4- May Aug 7 Nov 173 Nov 26 13 0.0181' 0. 0 <05.0.0 NIS k0.005 <0.005. 0.0598 ',<0.005 <0.005 NIS 0.0059 <0.005 ';<0.0050.348 .137 0.226 NIS 0.05 0.278 0.269 C 0.0184 0.0474 0.0210 0.0097 0.028 0.0071 0.006 - 02� 1: 083 .009 .0 .009 .003 0.0725 0. 129 03 0.73 !(} 0.0489 0.0767 1) <0.005 NIS <0.005 NIS <0.005 <0.005 <0.005 0.0398 0.0096 0.0309 0.0527 0.100 0.0085 0.0085 0.0898 0.109 0.155 0.214 0.560 0.154 0.110 I- <0.005 NIS NIS NIS NIS <0.005 NIS <0.005 NIS NIS NIS NIS <0.005 NIS 0.0313 NIS NIS 'NIS NIS 0.0632 NIS F 0.005 NIS WS NIS NIS <0.005 <0.005 <0.005 NIS NIS NIS I NIS <0.005 <0.005 0.0256 1 NIS NIS NIS NIS 0.0815 0.0380 G U.[}087, 0.011 l' ;<O.OUS. -01005 0.0069. <0.005 NIS 044 1 0?4 114* .02 1.01E 1 NIS ).0 0 i}K0 }.048 1; i ; 1.04 I N/5 1 <0.005 NIS NIS NIS <0.005 <0.005 <0.005 <0.005 NIS NIS NIS I <0.01 <0.005 <0.005 0.0747 0.220 NIS 0.141 0.500 0.179 0.0' Bench mark 0.007 iao.j 0.030 p�5'� 0.067 r ' Bolded values exceed E3enchmark Limit. 2 Color groupings: Yellow highlighted Vi►IUCS have consistent pattern of metal discharges above respective Benchmark Limits. UjMQjlQTQcl values have consistent pallern of metal discharges of one above and the rest below respective Benchmark Limits. Gre), highlighted values have inconsistent pattern of metal discharges. lsceptions are sources I: and 17, whose pattern is undetermined because of a lack of sampling data. Unhighlighted values have consistent pattern of no metal discharges. 3 Scmi-annual sample. Table 2. Discharge Point Sources Source Metal Drainage B Zinc Paved raw material storage area driveway above truck unloading dock for Casting Building. C Cu, Pb, Zn Roof of Casting Bifilding and paved raw material storage area including north forklift ramp. D 11b, Zn Main building roof including Babbitt Room roof with ventilator and ba ghouse discharges. E Zn Main building roof west and near Babbitt Room roof. F Zn Main building roof northwest and near Babbitt Room roof. G i3b, Zn Paved raw material storage area including south forklift ram . 1 Zn Main building roof south of Babbitt Rootn. JAN 2 7 2014 i_.alld Quality Section .Asheville Table 3. Materials Containing Copper and/or Zinc Material Copper Content (Weight % Zinc Content (Weight % Area Used Susceptible to Spreading? Amabrasive <0.20 --Ihlexid nc Shot Material not used, bottled and shipped with pnodUCt. Bronze Alloys 55-99 0-45 Tool Low volume contained to specific area. Not used in roduction areas. Alkaline Batteries -- l 1-16 Primaril %.Maiiit Material not crushed or otherwise available to spread. ALL RTW Carbide Grade 1-50 1-25 Too] Room Solid material, not ground or modified, not used in production areas. Carbon & Alloy Steels .03-1.9 2 oz/ft2 Tool Room Material used in small quantities, not used in production areas. Copper -Zinc Alloys N/L2 NIL Powder metal area In solid form, used as an additive for heat treat process. Diamond or Cubic Bordon Grinding Wheels I-l0 -- Tool Room Tool room only, not used in production areas. "I'in Flux and Solder N/L NIL Work -up Area Small quantities, only used in this area. Gray Iron 0.01-1.00 -- Production Ubiquitous, but very low Cu content and no Zn content. Daily aisle cleaning with wet sweeper. No small chips or grindings. Hi h S eed Babbitt 3-8 -- Not Used High Speed Babbitt 3-8 -- Not -Used High Test Top Flux -- ZnCI 1 Work-u Area Used in small quantities in one area Infiltrating Powder B5Mn-il 92-97 1-7 '-M Area, ' No longer used Johnson's Soldering Fluid -- 9Work-up Area Used in small quantities in one area Mobil Grease HP222 -- 1-5 Maintenance Shop Minimal use for maintenance pUrposes Mobil &rease XHI' 97C898 -- <2.5 Maintenance Shop Minimal use for maintenance purposes Mobilux EP 0 641290-06 -- <2.5 Maintenance Shop Minimal use for maintenance eureoses Rel-I I Ala Powder Metal 2.Q -- Production Used in the press area of the plant only. We perform daily aisle cleaning with wet sweeper in this area. Rockwell Zn-Ant Chloride Solution -- = 4-- Babbitt Room Room is-ventildted-to the roof-Tliis area dis`char s•to eanveyance�oint D. Likely source of Zinc r Static Intercept <10 -- Packaging Area Desiccant packs. Material not crushed, released, or otherwise available to spread. Sunnen Honing Stones 5 -- Tool Room Used occasionally for special boring applications in Toolroom. Not in production areas. Sunnen Metalbond Honing Stone 85 12 Tool Room Used occasionally for special boring applications in 'Poolroom. Not in production areas. Presumed zero (0). 2 Quantity Not Listed, Presumed to be less than I percent; which is the MSI)S minimum reportable quantity. dAN 2 7 2014 Land Ouality Section Herbert, Laura C From: Georgoulias, Bethany Sent: Wednesday, January 15, 2014 10:24 AM To: Stepp, Jonathan; Pickle, Ken Cc: Herbert, Laura C Subject: RE: Baldor Weaverville Hi Jonathan, Thanks for sending this. I'm still looking for some example letters with relief to monitoring. If you all are allowing them to collapse the tiers based on circumstances, you can craft options (like discontinuing O&G from monthly samples, even if they continue to sample for the metals) if that makes sense. Our default is to have them sample everything so they don't miss what's going on with the whole picture, but sometimes it's not going to make a difference to the problem they are pursuing. We just can't predict every case. The RO has the flexibility to direct them in a specified monitoring plan as it sees fit. I would encourage trying to dispel Mr. March's notion that just because his sample point isn't where the outfall is, the stream is "well protected." I see what he's getting at, but without specific information, it's not a blanket assumption in every case. And, it's important to remember sampling is not just for protecting water quality, but also a tool for assessing BMP effectiveness. Bg Bethany Georgoulias, Environmental Engineer NCDENR / Division of Energy, Mineral, and Land Resources Storrnwater Permitting Program 1612 Mail Service Center, Raleigh, NC 27699-1612 512 N. Salisbury Street, Raleigh, NC 27604 919 / 807-6372 (phone); 919 / 807-6494 (fax) Website: hit :1/ ortal.ncdenr.or webflr/stormwater F.-matt correspondence to and from this address may be subject io the North Carobita Public Records 1mv and nary be disclosed to third parries. From: Stepp, Jonathan Sent: Wednesday, January 15, 2014 9:27 AM To: Georgoulias, Bethany; Pickle, Ken Cc: Herbert, Laura C Subject: FW: Baldor Weaverville Hi Bethany and Ken, I received this e-mail yesterday from a consultant, Dan March (former DENR Air Quality employee). I just wanted to give you another example of the correspondence we are getting related to the copper and zinc benchmarks in the NCG03 permit. I have advised Mr. March to pursue the collapsed tiered response. Additionally, I encouraged him to get Baldor personnel more involved with the permit and hand over the qualitative monitoring to them. In my experience, this will force them to have a better understanding of stormwater at their site and lead to better outcomes from an environmental and compliance standpoint. Thanks, Jonathan Jonathan Stepp—Jonathan.SteppCc@ncdenr.gov North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Energy, Mineral, and Land Resources - Land Quality Section 2090 U.S. 70 Highway Swannanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7043 Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third parties. From: Daniel March [mailto: i ah-air vt.edu] Sent: Tuesday, January 14, 2014 10:45 AM To: Stepp, Jonathan Subject: Baldor Weaverville Jonathan, Happy New Year. We need clarification for the requirements of Tier II sampling for my client Baldor Electric Company (Buncombe County) in Weaverville, NC (NCG030000). The general permit issued October 25, 2012, describes activities stemming from benchmark exceedances (Part II Page 7 of 10) in two consecutive monitoring periods as: The perm ittee shall: 1. Repeat all the required actions outlined above in Tier One. 2. Immediately institute monthly monitoring for all parameters. Conduct monthly monitoring at every outfall where a sampling result exceeded the benchmark value for two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until three consecutive sample results are below the benchmark values or within benchmark range. 3. Submit a monthly monitoring report indicating "No Flow" if no discharge occurs during the sampling period. 4. Benchmark exceedances for a different parameter separately trigger a tiered response. 5. Maintain a record of the Tier Two response and monitoring results in the SPPP. The above sampling requirements call for analysis of "all parameters". This includes all analytical and all qualitative parameters. Baldor has never had a measurable stormwater Oil and Grease discharge in the past several years my company has collected samples and reported results. Considering that the analyses are conducted on Discharge Points rather than actual Outfalls, we assume that surface waters are well protected from potential Oil and Grease releases from the Baldor facility. \ y ROE FLE ROOF FL13V ROOFROOF FLOW FLOW ROOF' ROOF FLOW FLOROOF t+J Ow ROOF FL3W � \Pv A � ( LEGEND ACUVE MWA& CkTm NAM MWALL 0 nzw C:fD A"M P-IA E-040 F-7 C-e 14*9 gno W7 me 3t, Scorn water flow Aria �..� NCDENR North Carolina Department of Environment and Natura Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder Governor Director August 22, 2013 Gary Massey Baldor Electric Company 70 Reems Creek Rd Weaverville, NC 28787 SUBJECT: NPDES Stormwater Permit Compliance Inspection Baldor Electric Company Permit No: NCG030070 Buncombe County Dear Mr. Massey: Resources John P. Skvarla, III Secretary This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on June 12, 2013. The facility was found to be in compliance with permit NCG030070. Enclosed is a -copy of the Compliance Inspection Report, which contains additional observations and comments for your reference. Please contact me at (828) 296-4664 or Tim.Foxnamcdenr.gov, if I can be of any further assistance. Sincerely, v Tim Fox Environmental Specialist Surface Water Protection Enclosure cc: Central Files Asheville Files G:IWQISWPOuncombe\StormwalerlNCCr03 Metal Fabrication\Ba1dor\CE1 Baldor08-19-13.doc Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 Phone: 828-296-45001 FAX: 828-299-7043 Intemet: www.ncwaterqualiZy.org NorthCarolina Naturally An Equal Opportunity 1Afirmative.Ac6on Employer Permit: NCG030070 SOC: County: Buncombe Region: Asheville Compliance Inspection Report Effective: 11/01/12 Expiration: 10131/17 Effective: Expiration: Contact Person: John Reno Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s)- Related Permits: Title: Inspection Date: 06/12/2013 Entry Time: 02:00 PM Primary Inspector: Timothy R Fox Secondary Inspector(s): Certification: Owner: Baldor Electric Company Facility: Baldor Electric Company 70 Reems Creek Rd Weaverville NC 28787 Phone: 828-645-4235 Exit Time: 03:45 PM Phone: Phone: 828-296-4500 ,Jonathan Stepp Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ■ Compliant [I Not Compliant Question Areas: E Storm Water (See attachment summary) Page: 1 Permit: NCG030070 Owner -Facility: Baldor Electric Company Inspection Date: 06/12/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Tim Fox and Jonathan Stepp with the Division of Water Quality met with Gary Massey (Safety and Environmental Coordinator with Baldor Electric Company) and Dan March (Pisgah Environmental Services). During the visit the SWPPP was reviewed. All record keeping was in order. Operational activities and stormwater exposures were discussed as well as new permit limits for zinc and copper. A tour of the facility was conducted that included observation of all outfalls, stormwater conveyances and site conditions. Housekeeping, maintenance, and record keeping were all in order. Baldor Electric has made significant efforts to identify any possible sources of exposure and to meet permit requirements. All stormwater outfalls were observed. We discussed some of the potential industrial sources of materials at the site which included: Metal roofing, fork lift traffic, HVAC units, cast iron boxes with galvanized coated wire, and gutters. Currently the parking area was being swept three times a week and the sweeper was planned to be kept for three months. Exceedances with outfalls C and G are mostly likely parking lot issues and outfall D is most likely a roof issue (roof ventilator in the babbit room). Analytical monitoring for copper and zinc has been added to allow more facilities to qualify for coverage under this general permit. However, Baldor Electric has been pro -active and diligent in evaluating possible causes for their benchmark exceedences. No significant issues were observed during the site inspection. At this time DWQ recommends continued efforts to evaluate and gather and provide additional data. Asheville regional office has started discussions with our central office regarding facilities that have provided sound data concerning benchmark exceedances due to the new zinc and copper limits and have had a site visit by the regional office. At this time DWQ recommends to continue efforts as per the permit requirements and to evaluate and gather appropriate data. Asheville Regional Office will continue to provide guidance in the future. Page: 2 Permit: NCG030070 Owner -Facility: Baldor Electric Company Inspection date: 06112/2013 Inspection Type: Compliance Evaluation Beason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ Q n n # Does the Plan include a General Location (USGS) map? ® n n n # Does the Plan include a "Narrative Description of Practices"? ■ n n n # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ fI Q # Has the facility evaluated feasible alternatives to current practices? ■ n ❑ # Does the facility provide all necessary secondary containment? ■ n n n # Does the Plan include a BMP summary? ■ n n n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ rl n n # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? o n n n # Does the facility provide and document Employee Training? ■ n n n # Does the Plan include a list of Responsible Party(s)? ■ [l Q 0 # Is the Plan reviewed and updated annually? ■ n n n # Does the Plan include a Stormwater Facility Inspection Program? e n n n Has the Stormwater Pollution Prevention Plan been implemented? ■ n n n Comment: Record Keeping was in good order. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ n n n Comment: Qualitative monitoring had been implemented. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: Permit and Qutfalls # 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? # Has the facility evaluated all illicit (non Stormwater) discharges? Comment: Yes No NA NE ■000 D 0 m 0 Yes No NA NE Page: 3 `{ F, -3-3 3-- C Le-lr= LA-O'j _a �� -Tee. ��►�� Tim (-.PAS t J7 'ems �- .� I •1 `d }^ / �•'�..." w ± 1 � .ilk � �.-' 1 . 1 1 i.F C ♦ ` J f r, e % S"L_'� 1 -r 1.-t �� T' : � ��" .Ei .{_.:py �• ` ` 1 � vY 4•T- •�frr �j , � �3i. r r 1 1 � - rlL - �'•4•�-�. ' � �J ..�i41•iC+. ••L w 4ti 1 .r. ' ', • � jj •�' w , � • E . w � 1 sAP.)'A'J. • f f 4` r.h ' 1 'F�-+`l 'r � � ~ice fl • �-- �v-.:s` � �,y �x , F , l ' ��`yy � r �•' • 1 ll+� t��.� �av,3F.ir�}� �'t.. ;�� �T:_�t•,�, � I�h - T �,, � • '•�.i t A, jFA AS;= NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Dale Spivey Baldor Electric Company 70 Reems Creek Rd Weaverville, NC 28787 Dear Permittee: Division of Water Quality Charles Wakild, P. E. Director December 4, 2012 Dee Freeman Secretary Subject: NPDES Stormwater Permit Coverage Renewal Baldor Electric Company COC Number NCG030070 Buncombe County In response to your renewal application for continued coverage under stormwater General Permit NCG030000 the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as subsequently amended). The following information is included with your permit package: • A new Certificate of Coverage (COC) • A copy of General Permit NCG030000 • A copy of the Technical Bulletin for the General Permit • Two copies of the Discharge Monitoring Report (DMR) Form • Two copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the permit to update your current SPPP to reflect all new permit requirements. The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable, report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this permit and do not count prior exceedances. The more significant changes in the General Permit since your last COC was issued are noted either in the Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current- notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit httC,1/portal.ncdenr.otg/web/wq/ws/su/nodessw (click on 'General Permits' tab) to review that information for your specific General Permit carefully. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location, 512 N. Salisbury St Raleigh, North Carolina 27604 Phone: 91 H07-63001 FAX: 919-807-6492 Internet: www rimaterguality.org An Equal OpportunitylAffirnaiiveAction Employer One NorthCarolina Naturally Dale Spivey December 4, 2012 Page 2 of 2 Some of the changes include: Part II: • Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated to the most current language of our permits. Additional conditions for specific industry sectors have been added to the SPPP requirements in some cases. • Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring that the permittee begin a monthly sampling scheme. • Sections B, C: A lower TSS benchmark of 50 mg/I for HQW, ORW, PNA and Tr Waters applies to these more sensitive waters. • Sections B, C. The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other analytical monitoring requirements. • Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined in the "Definitions" section of the permit. • Sections B, C: The term "Representative Storm Event" has been replaced by "Measurable Storm Event." A measurable storm event is defined in the permit. • Section D: If the permittee fails to respond effectively to problems identified by qualitative monitoring, DWQ may require the permittee to perform corrective action. Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit, including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than 30 days from the date the facility receives the sampling results from the laboratory. Also note that existing permittees do not need to submit a renewal request prior to expiration unless directed by the Division. Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package, please contact the Division's Stormwater Permitting Unit at (919) 807-6300. Sincerely, /I for Charles Wakild, P.E. cc: DWQ Central Files Stormwater Permitting Unit Files Asheville Regional Office STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030070 STORMWATER NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of'North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Baldor Electric Company is hereby authorized to discharge stormwater from a facility located at: Baldor Electric Company 70 Reems Creek Rd Weaverville Buncombe County to receiving waters designated as Reems Creek, a class C;Tr waterbody in the French Broad River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 11, II1, and IV of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective December 4, 2012. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this 41h day of December, 2012. for Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakifd, P.F. Governor Director Gary Massey Baldor Electric Company 70 Reems Creek Road Weaverville, NC 28787 April 3, 2012 bog0 Subject: Permit Application Return Permit NCG030000 Buncombe County Your request for a General Permit renewal received on February 27, 2012 is being returned due to: ❑ Check for $100.00 made payable to NCDENR is missing. ❑ Application is incomplete. ❑ Application package is missing the supporting documents. ❑ Missing copy of county map or USGS quad sheet with facility clearly marked. Dee Freeman Secretary 0- Other Your facility has submitted a renewal a2plication for your current permit. This application and fee are not needed for your renewal. We are returning the application and fee. Please reLttrn the complete package of information so we can continue processing your request. if you have any additional questions, please contact Bradley Bennett at 919-807-6378. cc Wetlands and Stormwater Branch 1617 Mail Service Center, Raleigh, North Caratina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 91"07-6300 y FAX: 919-807-64941 Customer Service: 1.877-623-6748 Intemet: www.ncwaterauality.org An Equal Opportunity 1 Affirmative Action Employer One NorthCarohna ,'zatvmllty Table 2 Activity Areas Activity Area Activity Surface 1 Raw Casting Delivery, Raw Material Storage Concrete 2 Shipping Receiving, Raw Material Storage Concrete Material Handling; Sitting of Trash and Corrugated Packaging West Compactors; 3 Sitting of Spare Machining Fluid Reservoir; Concrete Load Waste Oil, Waste Machining Fluid and Waste Pretreatment Concentrate; Raw Material Storage 4 Store and Load Waste Machining Fluid and Grass Waste Pretreatment Concentrate Shipping 1 Receiving: 5 Material Handling: Storage of Raw Materials Concrete and New Pallets 6 Roof - Storage Area Metal 7 Roof Membrane 8 Roof Membrane 9 Storage of Ammonia, Propane, and Nitrogen Gravel, Grass, and Concrete 10 Roof Membrane 11 Roof Membrane 12 Roof Metal WEnviromentakStormwater Discharge\Miscellaneous\Table 2 Activity Areas.xls Table 3 Stormwater Conveyance and Discharge Points Conveyance and Discharge Point Activity Area Droned Total Activity Area Drained (sq. ft.) Impervious Activity Area Drained % Impervious A 1, 2 ,4 10,716 6,750 63% B 1,2 10,135 8,460 83% C 2, 3, 4, 6, 9 32,744 23,695 72% D 10 8,400 8,400 100% E 8, 10 49,644 49,644 100% F 7 75,369 75,369 100% G 5, 11 37,032 37,032 100% H 7 12,000 12,000 100% 1 12 9,000 9,000 100% HAEnviromentaRStormwater Discharge\SWPP Plan\Table 3 Conveyance Points.xls GRASS GRASS D�r�H ROOF FLOW 10 R I ROOF I ROOF 1 Q FLAW 8 FLOW FL❑OOF la Q ROOF � ROOF FLOW ROOF Q FLOW 11 FLOW GRASS Q- ,���5 Figure 2 `�. Iv (s030017-0 J April 7, 2011 North Carolina Department of (Environment and Natural Resources Division of Water Quality Surface Water Protection 2040 US Highway 70 Swannanoa, NC 28778 Attn: Chuck Cranford, Environmental Specialist Re: Baldor Electric Company Stormwater Sampling Strategy Certificate of Coverage No. NCG030070 Dear Mr, Cranford: Thank you for your guidance and advice concerning our stormwater issues and sampling locations during your January 24, 2011 inspection. We have considered all your suggestions and have modified our stormwater sampling strategy accordingly. The modified stormwater sampling strategy is described below. ISSUES/BACKGROUND Several Stormwater Discharges have exceeded benchmark value(s) in the past year. Tier I and Tier 11 evaluations are almost complete. We have installed new air pollution control equipment and made significant changes to our Work Practice Standards in two work areas. Compliant Tier II sampling is required for April 2011 and the Tier [/Tier 11 program will be complete. Based upon our conversation on January 24, we understand that two of the existing Stormwater Discharges (A and H, see Figure 1) are for parking lot or driveway areas and are not subject to DENR/DWQ stormwater standards. Five other Stormwater Discharges (B, C, D, G, and I) discharge to Baldor property, not to adjacent property(s) or to surface waters, and are also not subject to stormwater standards. In total, seven of Baldor's nine Stormwater Discharges are not subject to stormwater standards. Only Stormwater Discharges E and F truly discharge to surface waters (i.e... un-named tributary to Reems Creek). Sampling at the junction of Reems Creek Road and Reems Creek - the point identified as Outfall 3 during our January 24 meeting - is going to be problematic. Stormwater sheet flow from the two automotive maintenance facilities upgradient from the sampling point and the influence of Reems Creek Road itself introduce many pollutants to the r- storinwater stream over which Baldor has no control. For example, on February 28, a stormwater sample collected from the ditch beside Reems Creek road exceeded the total suspended solid benchmark value by over 200 percent. The lead value is 8 1.5 percent of its benchmark value. Table 2 lists the analytical results of that testing campaign. Table 1. Baldor Existing Stormwater Discharges Discharge_ Point Drainage Area Stormwater 0utfall A Paved driveway 2 B Paved storage/work area 2 C Paved storage/work area 3 D Roof 3 E Roof 1 F Roof 1 G Paved storage/work area 3 H Parking lot 1 l Roof 3 Table 2. Stormwater Sampling Results — Reems Creek Road Ditch — Feb 28, 2011 Analytical, Parameter Analytical Value m IL Benchmark Value m /L Benchmark . Compliance H 6.7 65x59 Yes TSS 215 100 No Lead 0.0269 0.033 Yes Oil and Grease <5 30 Yes PROPOSED STORMWATER SAMPLING STRATEGY Stormwater Discharges B, C, D, G, and I provide information about production releases to the building roofs and to paved outside areas. The production releases include air exhausts from roof vents to the roofs. The paved area releases include trackout from specific production areas. Baldor proposes to continue sampling the Stormwater Discharges listed in Table 3 as part of its semi-annual monitoring/reporting requirements. In this strategy, we eliminated the driveway and parking lot discharge points - A and H respectively. This strategy will continue for some indeterminate time; until we are satisfied that the existing pollutant sources have been adequately addressed and no new issues have arisen. We will keep DENR/DWQ updated on our progress and will not make any changes to this strategy without further input from DWQ. Baldor Electric Company Stormwater Sampling Strategy The number of Discharge Points to be monitored after we are satisfied the existing pollutant sources are indeed controlled is not yet known. That number and exact locations will be discussed with DENR/DWQ in the future. Table 3, Baldor Proposed Stormwater Discharges Discharge Point _ Drainage Area Stormwater Outfall B Paved storage/work area 2 C Paved stora c/work area 3 D Roof 3 E Roof 1 F Roof 1 G Paved stora e/work area 3 I Roof 3 CONCLUSIONS Please provide comments or suggestions of the proposed stormwater monitoring strategy described above. We are asking for your approval of this strategy and are very appreciative of any suggestions that you may have. You may contact me with questions or comments concerning the stormwater monitoring/reporting strategy at Baldor Electric Company. I can be reached at 828-645-1817 or at gbmassey@baldor.com. Sincerely, Baldor Electric Company Gary Massey Safety & Environmental Coordinator Baldor Electric Company 70 Reems Creek Rd. Weaverville, NC 28787 CC: Daniel J. March — Pisgah Environmental Services Baldor Electric Company Stormwater Sampling Strategy PuW I 1 F�aj FWF t LOV kMFisiO o Fu ' FI.OROO .. k I IQ I V .� T1prn�6tlr f!O• L� rRI I Qa . E NM Figure 1. Baldor Electric Company Stormwater Flow and Sampling Diagram February 10, 2011 VIA CERTIFIED MAIL RETURN RECEIPT North Carolina Dept. of Environment and Natural Resources Division of Water Quality, Wetlands and Stormwater Branch 512 N. Salisbury St. Raleigh, NC 27604 Baldor Electric Company 5711 R.S. Boreham Jr. Street Fort Smith, Arkansas 72901 Phone (479) 646-4711 Fax (479) 648-5841 www.baidorcom F FF 4 2011 Re: LADES General Permit No. NCG030000; . w� WAI Ty I Certificate of Coverage No. NCG030070 LL, �& � aer j 70 Reems Creek Rd., Weaverville,.NC 28787 Baldor Electric Company; Courtesy Notice of Change in Stock Ownersh11) To Whom It May Concerti: On .lanUary 27, 2011 Brock Acquisition Corporation, a subsidiary of ABB Ltd, acquired the outstanding stock of Baldor.Electric Company. Baldor Electric Company operates a facility located at 70 Reems Creek Rd., Weaverville, NC 28787, which holds the permit referenced above. The acquisition will not result in a change in the oiviiei orioperator{of the facility;'tN6'day=``y bperat'ioii's-of the'facilityror the t aiI1e of Baldor Electric Company. Baldor Electric Company will continue to operate under the terms of the aforementioned permit. U is our understanding that, under these circumstances, no transfer or reissuance of the pennit is required. We are providing this notice of the acquisition to your agency as a courtesy, however. If there is any additional action or notice that is iegiiired, please let me know. My phone number is 828-645-1723, my FAX number is 828-645-521 1, and my address is: Baldor Electric Company, 70 Reems Creek Rd., Weaverville, NC 28787. Thank. yO r. Sincerely, V t- n u�5 Vance Litz Environmental Manaver Copy: 'lvlaine'Wammi`& Di'rector:ofl'Envi'r(minen'tal Eri&ihee ingand)Siistainab ility' ABB Cnc._ i,1t.' �S �.,f ���, :'�.5, i.. •.SG �-'i ..! .Fc .. ,,L ��. •=S�'��.• :.. .. ,.1_ _ !�l lr � .)1 .1 �' is . Cy• ...�.- . 33AI:.=03R • REL►ANCEP MASKA "To be the best as determined by our customers" QQF W A T9QG Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Q Coleen H. Sullins, Director Division of Water Quality November 7, 2008 Mr. Chris M. Hoyle Baldor Electric Company 70 Reams Creek Road Weaverville, NC 28787 Subject. NPDES General Permit NCG030000 Certificate of Coverage NCG030070 Baldor Electric Company Formerly Reliance Electric Company Buncombe County Dear Mr. Hoyle: On August H, 2008, Division personnel received your request to revise your stormwater permit Certificate of Coverage to accurately include you new company name. Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency. If you have any questions, please contact the Stormwater Permitting Unit at (919) 807-6303,. Sincerely, 3RIGINAL SIGNED , — KEN . KEN PICKLE. Coleen H. Sullins cc: DWQ Central Files Asheville Regional Office Stormwater Permitting Unit No ` Carolina Ntura!!y North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 807-6300 Customer Service Internet: h2o.emstate.mus 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 807-6494 1-877-623-6748 An Equal Opportunily/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030070 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, BALDOR ELECTRIC COMPANY is hereby authorized to discharge stormwater from a facility located at BALDOR ELECTRIC COMPANY 70 REAMS CREEK ROAD WEAVERVILLE . BUNCOMBE COUNTY to receiving waters designated as Reams Creek, a class C stream, in the French Broad River Basin, in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 11, III, and IV, V and VI of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective November 7, 2008. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day November 7, 2008. C'RIGINALSIGNED ''KEN 1°ICKLE for Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Atan W, Klimek, P.E., Director Division of Water Quality August 23.2002 JOHN RENO DODGE ROCKWELL AUTOMATION 70 REEMS CREEK ROAD WEAVERVILLE, NC 28787 Subject: NPDES Stormwater Permit Renewal DODGE ROCKWELL AUTOMATION COC Number NCG030070 Buncombe County Dear Permittee: In response to your renewal application for continued coverage under general permit NCG030000, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of [North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1981 The following information is included with your permit package: * A new Certificate of Coverage * A copy of General Stormwater Permit NCG030000 * A copy of the Analytical Monitoring Form (DMR) * A copy of a Technical Bulletin for the general permit Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater and General Permits Unit at (919) 733-5083. ext. 548 Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Stormwater & General Permits Unit Files Asheville Regional Office N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 ern NCDERR Customer Service 1- 800-623-7748 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCC030000 CERTIFICATE OF COVERAGE No. NCG030070 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, DODGE ROCKWELL AUTOMATION is hereby authorized to discharge storrawater from a facility located at DODGE ROCKWELL AUTOMATION 70 REEMS CREEK ROAD WEAVERVfLLE BUNCOMBE COUNTY to receiving waters designated as Reems Creek, a class C stream, in the French Broad River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set Forth in Parts 1, 11, Ill. IV, V, and VI of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective September 1, 2002. This Certificate of Coverage shal I remain in effect for the duration of the General Permit. Signed this day August 23.2002. for Alan W. Klimek, P.E., Director Division of Wetter Quality By Authority of the Environmental Management Commission Mlchael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Gregory,!. Thorpe, Ph.D- Acting Director Division of Water Quality December 27, 2001 TERRY ALLEN RELIANCE ELECTRIC CO-WEAVERVIL 70 REEMS CREEK RD WEAVERVILLE, NC 28787 Subject: NPDES Stormwater Permit Renewal RELIANCE ELECTRIC CO-WEAVERVIL COC Number NCG030070 Buncombe County Dear I ermitice: Your facility is currently covered for stormwater discharge under General Permit NCG030000. This permit expires on August 31, 2002- The Division staff is currently in the process of rewriting this permit and is scheduled to have the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for continued coverage under the reissued permit. In order to assure your continued cove€age under the general permit, you crust apply to the Division of Water Quality (DWQ) for renewal of your permit coverage. To mine this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed you will find a General Permit Coverage Renewal Application Norm. The application must be completed and returned by March 4, 2002 in order to assure continued coverage under the general permit. Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge ol'stormwater from your facility without coverage under a valid Stormwater NPDES permit would constitute a violation of NCGS 143-215. l and could result in assessments ol'civil penalties of up to $10.000 per day - Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial facilities in any of the I 1 categories of "storm water discharges associated with industrial activity," (except construction activities). If you feel your facility can certify a condition of "no exposure", i.e. the facilty industrial materials and operations are not exposed to stormwater, you Can apply for the no exposure exclusion. For additional information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General Permits Unit Web Site at htip://h2o.enr.st<ite.ne.us/su/stormwater.hinii If the subject storrnwater discharge to waters of the state has been terminated, please complete the enclosed Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the rescission process has been completed. II' you have any questions regarding the permit renewal procedures please contact Jim Reid of the Asheville Regional Office at 828-251-6208 or Bill Mills of the Central Office Stormwater Unit at (919) 733-5083, ext. 548 Sincerely. Ley 45e-I- > Bradley Bennett, Supervisor Stormwater and General Permits Unit cc; Central Files Asheville Regional Office. ��� NCDENR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1- 800-623-7748 ,.� 'State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director October 1, 1997 VANCE LITZ RELIANCE ELECTRIC CO-NNTAVERVIL PO BOX 24820 6065 PARKLAND BLV CLEVELAND, OH 44124 LTI.Ky"WA EDEHNR Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG030070 Buncombe County Dear Permittee: In response to your renewal application for continued coverage under the subject permit, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. The following information is included with your permit package: ■ A copy of the stormwater general permit. e A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your permit. This form must be completed and returned to the Division within 30 days of receipt of this letter. DO NOT send the SPPP with the signed form. E Five copies of Analytical Monitoring farms. N Five copies of Qualitative Monitoring forms. ■ A copy of a Technical Bulletin on the stormwater program with outlines program components and addresses frequently asked questions. ■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal Form returned to the Division. Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area Management Act or any other Federal or Local governmental permits that may be required. If you have any questions concerning this permit or other attached documents, please contact the Stormwater Group at telephone number (919) 733-5083 Sincerely, for A. Preston Howard, Jr., P. E. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5033 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 5090 recycled/ 10% post -consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE NO. NCG030070 STORMWATER DISCHARGES In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, RELIANCE ELECTRIC CO-WEAVERVIL is herby authorized to discharge stormwater from a facility located at: 70 REEMS CREEK ROAD WEAVERVILLE, NC BUNCOMBE COUNTY to receiving waters designated as Reems Creek in the FRENCH BROAD River Basin in accordance with the effluent limitations, monitoring requirements and other conditions set forth in Parts I, II. III and IV of General Permit No. NCG030000 as attached. This Certificate of Coverage shall become effective September 15, 1997 This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day October 1, I997 for A. Preston Howard, Jr., P.E., Director Division of Water Quality By Authorization of the Environmental Management Commission State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director May 15, 1996 Mr. Vance Litz Dodge, Rockwell Automation P. Q. Box 24820 Cleveland, OH 44124 Dear Mr. Litz: 1•s rrCC F1 Subject: NPDES Stormwater Permits Name Change Forms Permit No.: NCGO30O70 The NPDES Stormwater Group has completed a preliminary review of your analytical monitoring report (DMR) for your NPDES stormwater permit compliance. The information we have received revealed a change in the name of your facility. Please complete the enclosed permit name change forms and return them to our office. If you have any questions with regards to this request, please feel free to contact me at 919/ 733- 5083, extension 545. Sincerely, Steve Ulmer NPDES Stormwater Group enclosure cc: file, NCG030070 P.O. Box 29535, Raleigh, North Carolina 27525-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper ,r State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director June 4, 1993 Vance Litz Reliance Electric Company P O Box 24820 Cleveland, OH 44124 � E Subject: General Permit No. NCG030000 Reliance Electric, Mechanical Drives Plant COC NCG030070 Buncombe County Dear Mr. Litz: In accordance with your application for discharge permit received on September 28, 1992, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Environmental Management. The Division of Environmental Management may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Mr. Bill Mills at telephone number 919/733- 5083. cc: Sincerely, Original Signed By Coleen H. Sullins A. Preston Howard, Jr., P. E. Asheville Regional Office P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT u..H12111110► 1XIII11111 i 1XVTT•. a1 I 1111111 STORMWATER DISCHARGES WAKIK"JIM01.11 R111111 KUM 0 1JR1r.:.: u 1 1trj'vf► _u In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Reliance Electric Company is hereby authorized to discharge stormwater from a facility located at Reliance Electric, Mechanical Drives Plant 70 Reems Creek Road (SR 1003) Weaverville Buncombe County to receiving waters designated as Reems Creek in the French Broad River Basin in accordance with the effluent limitations, monitoring requirements, and other,conditions set forth in Parts I, II, III and IV of General Permit No. NCG030000 as attached. This Certificate of Coverage shall become effective June 4, 1993. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day June 4, 1993. Original Signed BY Coleen H. Sullins A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission "51 _e7 ;F bcl PLA4 r FACILITY FZ C COUNTY -cl 0 s NPDES MAP DSN FLOW NIA SUB GASrN 0+— C)� c> ti LATTiTUDE 411 06 i L 0 G, 54C DISCHARGE CLASS EXPIRATION DATE e- 0 EFILE COPY NCDEiNR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Govemor January 28, 2011 Gary Massey Baldor Electric Company 70 Recros Creek Rd Weaverville NC 28787 Division of Water Quality Coleen H. Sullins Director SUBJECT: NPDES Stormwater Permit Compliance Inspection Baldor Electric Company Permit No: NCG030070 Buncombe County Dear Mr. Massey: Dee Freeman Secretary This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on January 25, 201 L The facility was found to be in compliance with permit NCG030070. Enclosed is a copy of the Compliance inspection Report, which contains additional observations and comments for your reference. Please contact me at (828) 296-4664 or chuck.cranford2nedenngov and we can discuss an approach to addressing the benchmark exceedances you have been attempting to remedy. I look forward to working with you on the hatter. Sincerely, Chuck C Sanford Environmental Specialist Surface Water Protection Enclosure cc: Central Files Asheville Files S:\S\VP\BuncombeAStonnwata-XNCGO3 Metal Fabricationl13aldoACE1.01.27_ 11_doc Location, 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 Phone: 828-29645001 FAX 828-299-70431 Customer Service:1-877-623-6748 intemet: www,ncwate;quality.org One NorthCarolina �aurally Ah Equal Opportunity 1 Affirnialive Action Employer Compliance inspection Report Permit: NCG030070 Effective: 11/01/07 Expiration: 10/31/12 Owner: Baldor Electric Company SOC: Effective: Expiration: Facility: Baldor Electric Company County: Buncombe 70 Reems Creek Rd Region: Asheville Weaverville NC 28787 Contact Person: John Reno 'Title: Phone: 828-645-4235 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): Qn=Site Representative(s): Related Permits: Inspection Date: 01125/2011 Entry Time: 10:00 AM Exit Time: 11:00 AM Primary Inspector: Chuck Cranford Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluafion Permit Inspection Type: Metal Fabrication Stvrmwater Discharge COC Facility Status: ■ Compliant ❑ Not Compliant Question Areas: N Storm Water (See attachment summary) Page: 1 Permit: NCO030D70 Owner - Facility: Baldor Electric Company inspection Date: 01/25/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary. DWQ staff was met on site by Gary Massey and Dan March (Pisgah Environmental). A tour was conducted of the exterior of the facility, observing the stormwater conveyances and outfalls and site conditions. During the visit, the SPPP manual was reviewed, operational activities and existing stormwater exposures were discussed. At the time of the inspection the site was found to be in compliance with the permit. The inspector noted that the facility appeared to maintain good housekeeping practices and records were found to be in good order. The permittee is currently in Tier II for lead benchmark exceedances. Baldor has made significant efforts to comply with permit requirements and reduce the lead stormwater exposures. A review of the outfalls of the facility was conducted and the inspector identified that a reduction in sampling points was appropriate. Baldor should modify their site plan to reflect the changes discussed during the visit. Further sampling and analysis should be conducted to better quantify the measurements of lead in the stormwater discharges. The inspector will assist with the sampling protocol. Page: 2 Permit: NCG030070 owner - Facility: Bald or Electric Company Inspection Date: 01/25/2011 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? ■ ❑ ❑ El # Does the Plan include a General Location (USGS) map? ■ # Does the Plan include a "Narrative Description of Practices'? ■ ❑ 0 Q # Does the Plan include a detailed site map -including outfall locations and drainage areas? ■ n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ Q Cl Q # Has the facility evaluated feasible alternatives to current practices? ■ 0 ❑ 0 # Does the facility provide all necessary secondary containment? ® n n n # Does the Plan include a BMP summary? ■ C3 0 El # Does the Plan include a Spill Prevention and Response Plan (SPRP)? O # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ Q ❑ ❑ # Does the facility provide and document Employee Training? ■ n Cl n # Does the Plan include a list of Responsible Party(s)? ■ Cl 0 ❑ # Is the Plan.reviewed and updated annually? ■ Q 0 # Does the Plan include a Stormwater Facility Inspection Program? ■ n n n Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ fl Q Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ Q ❑ 0 Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ■ ❑ 0 # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ■ 0 ❑ Q Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ D [1 ❑ # Were all outfalls observed during the inspection? ■ 0 0 D # If the facility has representative outfali status, is it properly documented by the Division? ■ ❑ Q Q # Has the facility evaluated all illicit (non stormwater) discharges? e Comment: Page: 3 P'�T July 28, 2010 Department of Environment and Natural Resources Division of Water Quality Central Files 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Baldor Electric Company 70 Reems Creek Road Weaverville, NC 28787 General Permit No. NCGO030070 Dear Sirs: Oft — 7 2010 ' ► Y 4tG r••J Attached is the first semiannual 20I0 stormwater discharge monitoring report for Baldor Electric Company. During the second semiannual 2009 stormwater monitoring event, two Discharge Points exceeded lead permit limits and a Tier I evaluation was instituted. This report describes the outcome of our Tier I evaluation and presents the most recent stormwater monitoring results. Tier I Evaluation During the summer of 2009, Baldor installed a new process line in the Babbitt Room of the facility. Discharge Points C, D, and G primarily drain stormwater from this roof area. The new process line uses molten lead and three process steps were ventilated uncontrolled through four roof exhausts. Our Tier I investigations conclude that these exhausts conveyed lead to the roof. We also believe that sorne construction materials from the new process line may have contributed to the elevated stormwater lead levels from roof water flowing over paved areas before passing through the Discharge Points. The new process line exhaust vents were evaluated to determine whether one or all were releasing lead to the roof. Operations of the new process line were evaluated to determine whether changes to certain production steps could influence lead releases. Our investigations determined that all four exhausts should be captured by close pickups and controlled by a single baghouse filtration system. Vendor evaluations of the exhaust system and calculations of baghouse filtration requirements occupied several weeks and in early May a system was proposed. Installation of the capture and control system began in mid -June and the roof was cleaned to remove deposited lead. During the initial start-up evaluation period the internal fire -suppression system failed and ruined the filters. The filters were removed and the system was restarted to ventilate the 01 k " `�1 ` process line work area. A new tire -suppression system design is under review by the local Fire Department and approval is imminent. We anticipate that the baghouse filtration system will be fully operational ,by late August. After a short evaluation period the roof will be cleaned again and non -complying roof Discharge Points will be sampled to determine compliance with the lead permit limit. Since the controls identified in our Tier I evaluation are not yet fully operational, we are still in a Tier I evaluation period. However, in order to comply with the semiannual requirement of our NPDES permit, Baldor collected and analyzed and report in this letter the results of our compliance requirement. These results demonstrate that lead is still being emitted from the roof drain system. The first semiannual 2010 sampling was conducted before the controls (i.e., baghouse filtration system) were fully operational. The second semiannual 2010 sampling will proceed as normally scheduled. Engineering samples were collected from Discharge Points C, D. and G on June 10 during a non -representative storm event to determine whether operational changes in the Babbitt Room had influenced lead emissions. This thunderstorm lasted about 30 minutes. Only lead and pH were measured; oil and grease and total suspended solids were not measured. The rainfall volume was not measured. We believe these results are not part of the reportable compliance sampling and analysis activities covered under our NPDES discharge permit. However; the results are included here in the interest of full disclosure and to demonstrate our on -going Tier I activities to mitigate stormwater lead releases. A copy of the June 10 stormwater report is attached. First Semiannual 2010 Stormwater Results Storrnwater sampling was planned for the late -May to mid -June timeframe to allow for the Tier I controls to be installed and evaluated. Unfortunately, this period was exceedingly dry and no `Representative Storm Events' presented an opportunity to collect samples. Consequently, samples were collected on July 12, 2010; during a 'Representative Storm Event' from the nine Discharge Points that constitute the three facility Outfalls. Samples were collected using good sampling practice into precleaned - and in some cases preserved - containers supplied by Pace Analytical Laboratories. Pisgah Environmental Services measured the pH of each outfall within 15 minutes of collection as required by DENR. The pH meter was calibrated before testing with two buffer solutions that bracketed the expected pH range. Calculations of maximum total flow through each Discharge Point are attached. The total precipitation over a 3-hour period before sampling was 0.45 inches. Precipitation amounts are based on an on -site rain gauge. Baldor Electric Company - Stormwater Qualitative observations of three stormwater outfalls are included in the three attached checklists. No deficiencies were observed; all three systems were operating as designed and were in good order with no evidence of pollutant discharges. Three Discharge Points — C, D. and G — have lead discharge concentrations above the benchmark concentration of 0.033 milligrams per liter. The three elevated lead concentrations were 0.196, 0.203, and 0.064 milligrams per liter respectively. Please note that a ninth Discharge Point —1— was added to our sampling matrix in early 2010. This Discharge Point drains the roof of a new building expansion on the east side of the main production building. Baldor Stormwater Samaline Strate Stormwater at Baldor is released from multiple `Discharge Points' through three `Outfalls' to Reems Creek as presented in Figure 2. Each 'Discharge Point' is sampled during a representative storm event and each `Outfall' is examined qualitatively; the semiannual Stormwater report includes both evaluation results. Outfall 1 is a combination of Discharge Points E, F, and H; which all discharge to an un- named wet -weather tributary to Reems Creek along the western property boundary. Discharge Points A. B, C, D, G, and I drain to Outfall 2 on the eastern property boundary over a cattle pasture. No Discharge Points drain to Outfall 3; it is generated from run-off water from a wooded portion of the property along the northern property boundary. Discharge Points A. B, C, D, G, and I are individual pipe drains that discharge into a cattle pasture and move as sheet flow to a ditch at the bottom of the hill along Reems Creek Road. The ditch discharges to Reems Creek and is designated Outfall 2. Baldor samples individual piped Discharge Points that discharge to the pasture rather than combined now at Outfall 2 after it has passed over the pasture. Conclusions Based on the 2009 second semi-annual stormwater results of non-compliance with the lead discharge standard and the inability of the facility to demonstrate compliance with subsequent samplings, we conclude that a Tier 11 evaluation is necessary. Despite not having completed the Tier I evaluation, Baldor will collect monthly stormwater samples from the two Discharge Points (i.e., C and D) that have had elevated lead levels in the past two sampling events. Please contact me with operational or compliance issues. Otherwise, contact Dan March of Pisgah Environmental Services at 828-768-3335 or via e-mail at Pisgah-air@,vt.edu if you have questions or comments concerning technical aspects of this report. Baldor Electric Company - Stormwater n 0 Sincerely, Baldor Electric Company Y _L GarMasse Y Y Safety & Environmental Coordinator 828-645-1718 Attachments: Discharge Monitoring Report Qualitative Monitoring Report (3) Stormwater Flow Calculations Analytical Report Sampling Chain -of -Custody Engineering Stormwater Report — June 10, 2010 Baldor Electric Company - Stormwater STORMWATER DISCHARGE OUTFALL (SDO) MONITORING REPORT GENFRAL PERMIT NO. NCG030000 SAMPLES COLLECTED DURING CALENDAR YEAR: 2010 _ CERTIFICATE OF COVERAGE NO. NCG03 - 0070 (This monitoring report is due at the Division no later than 30 days from the date the facility receives the sampling results from the laboratory.) FACILITY NAME - Baldor Electric Company COUNTY - Buncombe PERSON COLLECTING SAMPLES - Dan March - PES PHONE NO. (828)645-4235 CERTIFIED LABORATORY - Pace Analytical Labs Lab # 40 Lab # PLEASE SIGN ON THE REVERSE', 4 Part A: Specific Monitoring Re uirements Outfall No. Date Sample Collected, mo/dd/yr 00530 00400 01051 00556 78141 Total Suspended Solids, m /L pH, Standard units Lead, m /L Oil and Grease, m /L Total Toxic Organics', m /L Benchmark - 100 Within 6.0 - 9.0 0.033 30 1 A 07/12/10 7.6 7.8 <0.005 <5.0 NIA B 07/12/10 43.0 7.8 0.0222 <5.0 NIA C 07/12/10 45.3 8.2 0.196 <5.0 N/A D 07/12/10 13.0 8.0 0.203 <5.0 N/A E 07/12/10 <3.6 8.0 <0.005 <5.0 N/A F 07/12/10 4.3 8.2 <0.005 <5.0 NIA G 07/12/10 26.5 8.2 0.0645 <5.0 N/A H 07/12/10 17.9 7.5 0.0175 <5.0 N/A 1 07/12/10 4.6 8.2 <0.005 <5.0 N/A Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier I or Tier 2 responses. See General Permit text. Did this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_ yes _X_no Part B: Vehicle Maintenance Activity onitoring Requirements Ou t fa I I No. Date Sample Collected, mo/dd/vr 00556 00530 00400 Oil and Grease, m /L Total Suspended Solids, m /L pH, Standard units New Motor Oil Usage, Annual average al/mo Benchmark - 30 100 6.0 - 9.0 - Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier 1 or Tier 2 responses. See General Permit text. STORM EVENT CHARACTERISTICS: Date: 7/12/2010 (first event sampled) Total Event Precipitation (inches): _0.45 Mail Original and one copy to: Division of Water Quality Attn: DWQ Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 SWU-245-031308 Page] of 2 Date: (list each additional event sampled this reporting period, and rainfall amount) Total Event Precipitation (inches): I Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.1 1; for semiconductor manufacture use the definition as found in 40 CFR 469.12; for electronic crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in 40 CFR 469.31). Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement for TTO monitoring may be waived. The solvent management plan shall include a list of the total toxic organic compounds used and the other elements listed in the General Permit. For those facilities electing to employ the TTO monitoring waiver, the discharger shall sign the following certification statement: "Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for total toxic organics (TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are exposed to rainfall or stormwater runoff has occurred since filing the last discharge monitoring report. I further certify that this facility is implementing the all the provisions of the solvent management plan included in the Stormwater Pollution Prevention Plan." Gary Massey Name (Print name) Safe & Environmental Coordinator Title (Print title) (Signature) (Date) "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 gather and evaluate 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 pos ibility of toes and imprisonment for knowing violations." (Signature of Permittee) (Date) S W U-245-0313 08 Page 2 of 2 Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report For guidance on filling out this form. Tease visit. htt ://h2o.enr.state.nc.uslsu/Forms Documents.htm#miscibrmti Permit No.: NICI Facility Name: County: • Inspector: Date of Inspection: Time of Inspection: Total Event Precipitation (inches): 0.41a �^ of Coverage No.: NICIGI O/ 4) I Q / Was this a Representative Storm Event? (See information below) x Yes ❑ No Please check your permit to verify if Qualitative Monitoring must be performed during a representative storm event (requirements vary). A "Representative Storm Event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no precipitation, this report is accurate and complete to the best of my knowledge: (Signature of Pernlittee or Designee) 1. Outfall Description: autfalI No. i Receiving Stream: F3 ,U Structure (pipe.Cc te.) Describe the 4ustrial activities that occur within the outfall drainage area: 2. Color: Describe the color of the (light, medium, dark) as descriptors: using basic colors (red, brown, blue, etc.) and tint 3. Odor: Descri trif, y distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.): Page I of 2 S W U-242-t t 2608 4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is clear and 5 is very cloudy. , 2 3 4 5 5. Floating Solids: Choose the number which best describes the amount of floating solids in the stormwater discharge, where l is no solids and 5 is the surface covered with floating solids: a 2 3 4 5 6. Suspended Solids. Choose the number which best describes the amount of suspended solids in the stormwater discharge, where l is no solids and 5 is extremely muddy: 2 3 4 5 7. Is there any foam in the stortnwater discharge? Yes No 8. Is there an oil sheen in the stormwater discharge? Yes No 9. Is there evidence of erosion) or deposition at the outfall? Yes No 10. Other Obvious Indicators of Stormwater Pollution: List and describe - I c/l `'� n2 Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition maybe indicative of pollutant exposure- These conditions warrant further investigation, . Page 2 of 2 SWU-242-1 12W8 K �a� 1_0 Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report For guidance onfzUing out this form, please visit: hfitp://l��c�.enr.st.iE�.i�c.0 /su/F�rms- Dmunicnlshtin#inisclornzs Permit No.: NICI or Certificate of Coverage No.. NIC1Gl 012101 C! i l�l Facility Name: L M k LC I r T,F_ t � 7� +.i-, P Au - CountY: Phone No. S7 Inspector. _ At- i � Date of inspection: t - 3 C3 Time of Inspection: _ _ it L o Total Event Precipitation (inches): _ Was this a Representative Storm Event? (See information below) x Yes ❑ No Please check your permit to verify if Qualitative Monitoring must be performed during a representative storm event (requirements vary). A "Representative Storm Event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no precipitation. jsignature,1, f_4tify that his report is accurate and complete to the best of my knowledge: (Signature of Permince or Designee) 1. Outfall Description: Outfall No. Structure (pipe, ditch, etc.) _s 4A,,"\ , Receiving Stream: Describe e ind Mal activ es that occur within the outfall drainage area: 2. Color: Describe the color of (light, medium, dark) as descriptors: _ 3. Odor: Des chlorine odor, etc.): 5 WU-242-! 12609 using basic colors (red, brown, blue, etc.) and tint y distinct odors that the discharge may have (i.e., smells strongly of oil, weak 2 "i- Page i of 2 4. Clarity: Choose the number which best describes the clarity of the discharge, where I is clear and 5 is very cloudy- O 2 3 4 5 S. Floating Solids: Choose the number which best describes the amount of floating solids in the stormwater discharge, where l is no solids and 5 is the surface covered with floating solids: i� 2 3 4 5 6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater discharge, where I is no solids and 5 is extremely muddy: 2 3 4 5 7. Is there any foam in the stormwater discharge?- Yes No 8. Is there an oil sheen in the stormwater discharge? Yes No 9. Is there evidence of erosion or deposition at the outfall? Yes oNq 10. Other List and descrit Note: Low diarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition may be indicative of pollutant exposure. These conditions warrant further investigation. Page 2of2 S WU-242-1 12608 Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report For guidance onfrllingout thisform,please visit. hit1211h2o.enr.si,tle_nc_tis/s�i/Pn�ms DOct1mEFits. fit m#l1nisctornis Permit No.: N/C1 Facility Name: County: Y` Inspector. Date of Inspection: Time of Inspection: '(�/.3/0/vlo/col or Total Event Precipitation (inches): 0 ._ `l*- of Coverage No.: N/GGI Q/ ' IL l CJI 71(31 No. ?>-Z' 7 (b K _ 7� �Z -- -s-- k Was this a Representative Storrn Event? (See information below) K Yes ❑ No Please check your permit to verify if Qualitative Monitoring must be performed during a representative storm event (requirements vary). A "Representative Storm Event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours Q clays) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to I0 consecutive hours of no precipitation. I cerfi fy that thi� report is accurate and complete to the best of my knowledge: L _ (Signature of Permittee or Designee) 1. Outfall Description: Outfall No. Structure (pipe, 4 tch, etc.) Receiving Stream: t Describe a ind serial activ ties that occur within the outfall drainage area, 2. Color: Describe the color of charge using basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors: tic- A c 3. Odor: Desct7l. ny distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorins odor, etc.): L Page 1 of 2 SWU 242-112608 -7. Clarity: Choose the number which best describes the clarity of the discharge, where I is clear and 5 is very_ cloud'; - 2 3 4 5 5_ Floating Solids: Choose the number which best describes the amount of floating solids in the stormwater discharge, where I is no solids and 5 is the surface covered with floating solids: (10 2 3 4 5 6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the storrnwater discharge, where 1 is no solids and 5 is extremely muddy 2 3 4 5 7. Is there any foam in the stormwalter discharge?- Yes 8. Is there an oil sheen in the starmwater discharge? Yes 9. Is there evidence of erosion or deposition at the outfall? Yes No ltf_ Other List and descril Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition may be indicative of pollutant exposure. These conditions warrant further investigation. Page 2 of 2 S VVU-242-112608 Baldor Electric Company 70 .Reems Creek Road Weaverville, NC 28787 :I a ly 12 2010 Discharge Point Attivit Y Area (ft') Impervious Area ;(ft') Rainfall ; (ft) ; Rainfall Volume (ft3) Raiiifa!! Y olume s (gal) Rainfall V olurne (1 .1. P A 10,716 61750 0.0375 253 .1,893 0.00.19 7.8 B 10,135 8,460 0.0375 317 2,373 0.0024 7.8 C 325774 23,695 0.0375 889 6,646 0.0066 8.2 D 95-500 9,500 0.0375 356 2,665 0.0027 8.0 E 49,644 491644 0.0375 1,862 13,925 0.0139 8.0 F 75,369 75,369 0.0375 21826 21,141 0.0211 8.2 G 37,032 37,032 0.0375 1,389 10,387 0.0104 8.2 H 12,000 12,000 0.03754 450 3,366 0.0034 7.5 1 9,000 9,000 0.0375 338 2,525 0.0025 8.2 CAPES Projects1807089 Baldor 5toi-mwater\Reports\Rainfa.11 Flow Volume 031409.xis 7/28/2010 • acmnalytical wwwpamlahs-C= July 22, 2010 Mr. Dan March Pisgah Environmental Services J Woodvale Asheville, NC 28804 RE: Project: Baldor 07112 Pace Project No.: 9273187 Pace Analytical an, Inc. 2225 Riverside Or Asheville, NC 28804 (828)254-7176 Pace Analytical Services, Inc. 980014JnceyAve. Suite 100 Huntersville. NC 28078 Dear Mr. March: Enclosed are the analytical results for sample(s) received by the laboratory on July 12, 2010. The results relate only to the samples included in this report. Results reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of the report_ Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All Microbiological analyses were performed at the laboratory where the samples were received. If you have any questions concerning this report, please feel free to contact me. Sincerely, Tom Williams tom.williams@pacelabs.com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in tail, without the wrilten consent at Pace Analytical Services, Inc.. (704)875-9092 Page 1 of 17 aceAnalytleal s wvrwp3o81abx am Pace Analyticai ices, Inc. 2225 Riverside Cr. Asheville, NC 28804 (826)254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 Kncey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Project: Safdor 07112 Pace Project No.: 9273187 Sample: SALDOR A Lab ID: 9273187001 Collected: 07/12/10 11:50 Received: 07/12/10 12:25 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Analytical Method: EPA 1664A Oil and Grease ND mg/L 5.0 1 07/13/10 09:00 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Lead ND ug1L 5.0 1 07/13/10 11:40 07/14/10 21:44 7439-92-1 25400 Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids 7.6 mg/L 3.6 1 07115/10 20704 Date: 07/22/2010 02:23 PM REPORT OF LABORATORY ANALYSIS This report shall not he reproduced, except in full, without the written oonsent of Pace Analytical Services, Inc.. «o, to ' Page 4 of 17 aceAnalytical Www.pacafab&=n ® Pace Anatyticaloices, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Pace Anatytcal Services, Inc. 9800 Kincay Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Project: Baldor 07112 Pace Project No.: 9273187 Sample: BALDOR B Lab ID: 9273187002 Collected: 07/12110 11:05 Received: 07/12110 12:25 Matrix: Water Parameters Results Units Report Limit DI= Prepared Analyzed CAS No. Qual HEM, Oil and Grease Oil and Grease 200.7 MET ICP Lead 2540D Total Suspended Solids Total Suspended Solids Date: 07/22/2010 02:23 PM Analytical Method: EPA 1664A ND mg1L 5.0 1 07/13/10 09:00 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 22.2 ug1L 5.0 1 07/13/10 11:40 07/15/10 01:08 7439-92-1 Analytical Method: SM 2540D 43.0 mg1L 4.2 1 07/15/10 20:04 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. �t�dCz; Page 5 of 17 s aceAnalylfical www.pacelabs.=v Pace Analyticai ices, Inc. 2225 Rrverside pr. Asheville, NC 28804 (826)254-7176 ANALYTICAL RESULTS Pace Analy0cal Services, Inc. 9800 Kinsey Ave. Suite 100 Huntersvilie. NC 28076 (704)875-9092 Project: Baldor 07112 Pace Project No : 9273187 Sample: BALDOR C Lab ID: 9273187003 Collected: 07/12/10 11:05 Received: 07112110 12:25 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Quai HEM, Oil and Grease Oil and Crease 200.7 MET ICP Lead 25400 Total Suspended Solids Total Suspended Solids Date. 07122/2010 0213 PM Analytical Method: EPA 1664A ND mg11- 5.0 1 07/13/10 09:00 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 196 uglL 5.0 1 07/13/10 11:40 07/15/10 01:18 7439-92-1 Analytical Method: SM 25400 45.3 mglL 8.3 1 07/15/10 20:04 REPORT OF LABORATORY ANALYSIS This report shall not be reproduoed, except in full, vANAA the written consent of Pace Analytical Services, Inc.. Page 6 of 17 aceAnalytical �wwpecdabicam Project- Raldnr 07112 Pace Project No-- 9273187 Sample: BALDOR D Pace Analytical &&$, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254.7176 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 KlrxxyAve_ Suite 700 HuntersWiie, NC 28078 (704)875-9092 Lab ID: 9273187004 Collected: 07/12/10 11:00 Received- 07112110 12:25 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. HEM, Oil and Grease Analytical Method: EPA 1664A Oil and Grease ND mg1L 5.0 1 07/13/10 09:00 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 2007 Lead 203 ug/L 5.0 1 07113/10 1111:40 07/15/10 01:24 7439-92-1 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids 13.0 mg/L 2.9 1 07/15/10 20:04 Date: 07/22MI0 02:23 PM REPORT OF LABORATORY ANALYSIS This report shall not he reproduced, except in full, without the mitten consent of Pace Analytical Services, Inc.. Qual Page 7 of 17 aceAnalytical wtrw.paaefabs.mn Pace Analytical Ices, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7178 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Project: Saldor 07112 Pace Project No.: 9273187 Sample: BALDOR E tab ID: 9273187005 Collected: 07/12/10 11:35 Received: 07/12/10 12:25 Matrix: Water Parameters Results Units Report Limit OF Prepared Analyzed CAS No. quaff HEM, Oil and Grease Oil and Grease 200.7 MET ICP Lead 25401) Total Suspended Solids Total Suspended Solids Date: 0712212010 02:23 PM Analytical Method: EPA 1664A ND mg/L 5.0 1 07/13/10 09:00 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 ND ug1L 5.0 1 07/13/10 11:40 07/15110 01:36 7439-92-1 Analytical Method: SM 2540D NO mg1L 3 6 1 07/15/10 20:05 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written oonsent of Pace Analytical Services, Inc.. o. Win lacy, Page 8 of 17 aceAnalytical www.Pecelar &WR Project: Baldor 07/12 Pace Project No.: 9273187 Pace Analytical doe, lnc. 2225 Riverside Dr. Asheville, NC 20804 f828j254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 Nncey Ave. Suite 100 Huntersvilie, NC 28078 (704)875-9092 Sample: SALOOR F Lab ID: 9273187006 Collected: 07/12/10 11:25 Received: 07112F10 12:25 Matrix: Water Parameters Results Units Report limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Analytical Method: EPA 1664A Oil and Grease ND mg1L 5.0 1 07/13/10 09:00 200.7 MET 1CP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Lead ND ug/L 5.0 1 07113/10 11:40 07/15110 01:39 7439-92-1 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids 4.3 mg1L 2.6 1 07/15/10 20:05 Date: 0712212010 02:23 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the mitten consent of Pace Analytical Services, Inc.. Page 9 of 17 Pace Analytical Am, Inc. Pace Analytical Services, Inc. eAnalvficalac2225 Riverside Dr. 9800 KnM Ave. Suite 100 / WwWPacetabsmm Asheville, NC 28804 Hunlersviile, NC 28078 I(/ (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Project: Baldor 07112 Pace Project No.: 9273187 Sample: BALDOR G Lab ID: 9273187007 Collected: 07/12/10 11:10 Received: 07/12/10 12:25 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qua[ HEM, Oil and Grease Analytical Method: EPA 1664A Oil and Grease NO mglL 5.0 1 07113/10 09:00 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Lead 64.5 uglL 5.0 1 07/13/10 11:40 07/15/10 01:42 7439-92-1 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids 26.5 mg/L 4.2 1 07/15/10 20:05 Date: 07/22/2010 02:23 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 10 of 17 Pace Analytical ..es, Inc. aceMalytical 2225 Riverside Dr. w»w.pacelebscmr Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Project: Baldor 07112 Pace Project No.: 9273187 Pace Analytical Services, Inc. 9800 Kncey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: BALDOR H Lab ID: 9273187008 Collected: 07/12/10 11:25 Received: 07/12/10 12:25 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qua[ HEM, Oil and Grease Oil and Grease 200.7 MET ICP Lead 2540D Total Suspended Solids Total Suspended Solids Date: 07/22/2010 02:23 PM Analytical Method: EPA 1664A ND mglL 5.0 1 07/13/10 09:00 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 17.5 ug1L 5.0 1 07/13/10 11:40 07/15/10 01:46 7439-92-1 Analytical Method: SM 2540D 17.9 mg1L 2.6 1 07/15/10 20:05 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. �ii'leidC�= Page 11 of 17 aceAnalytical www.pacefehs.c= Pace Analytical :,es, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875.9092 Project: Saldor 07/12 Pace Project No.: 9273187 Sample: BALDOR I Lab ID: 9273187009 Collected: 07/12/10 11:10 Received: 07/12/10 12:25 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed GAS No. Qual HEM, Oil and Grease Oil and Grease 200.7 MET ICP Lead 2540D Total Suspended Solids Total Suspended Solids Date: 07/22/2010 02:23 PM Analytical Method: EPA 1664A ND mg1L 5.0 1 07/13/10 09:00 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 ND ug1L 5.0 1 07/13/10 11:40 07/15/10 01:49 7439-92-1 Analytical Method: SM 2540D 4.6 mg1L 2.6 1 07/15/10 20:06 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. ��l Ic1CiC.= Page 12 of 17 .. 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ENVIRONMENT6L SERVICU, LLC, 9 Woodva I e Avenue § Asheville,NC 28804 § Phone 828-768-3335 § Fax 828-255-1092 § Email Pisgah air@vt.edu June 18, 2010 Baldor Dodge Reliance 70 Reems Creek Road Weaverville, NC 28787 Attn: Mr. Gary Massey Safety & Environmental Coordinator Re: DENR Stormwater Permit —Tier ITesting Dear Mr. Massey: Enclosed are the results of a Stormwater Sampling/Testing event for Discharge Points C, D, F, and I. This sampling event was conducted as part of a Tier 1 evaluation of the facility necessitated by lead discharge concentrations above pen -nit limits during the previous semiannual testing. Discharge Point I is the roof drain for the new building addition. PES collected samples on June 10, 2010, after a `non -Representative Storm Event' (a thunderstorm). The four discharge points drain parts of the roof and the eastern side of the building. This sampling event was conducted after the new construction project in eastern sections of the plant were complete but before control devices have been installed in the Babbitt Area. Note that the Discharge Point D concentration is almost 5 times the allowable limit of 0.033 milligrams per liter (mglL). Both Discharge Points C and D are within the area influenced by the Babbitt Area molten lead pot emission point. Table 1. Discharge Point Stormwater Results Discharge",.. Point - P Lead Concentration - m Stormwater Permit " Compliance C NIA 0.0209 Y D NIA 0.152 N F 7.5 <0.005 Y 1 8.3 <0.005 Y Not Analyzed = NIA Sincerely, Pisgah Environmental Services, LLC Daniel J. March Principal �OF W A TF9Q O L O 'C Mr. Chris M. Hoyle Baldor Electric Company 70 Reams Creek Road Weaverville, NC 28787 Dear Mr. Hoyle: C� Michael F. Easley, Governor William G. Ross 1r., Secretary North Carolina Department of Environment and Natural Resources Colcen H. Sullins, Director Division of Water Quality November 7, 2008 Subject: NPDES General Permit NCG030000 Certificate of Coverage NCG030070 Baldor Electric Company Formerly Reliance Electric Company Buncombe County On August 11, 2008, Division personnel received your request to revise your stormwater permit Certificate of Coverage to accurately include you new company name. Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency. If you have any questions, please contact the Stormwater Permitting Unit at (919) 807-6303, cc: DWQ Central Files Asheville Regional Office Stormwater Permitting Unit Sincerely, CRIGINAL SIGNED 61 KEN PICKLE Coleen H. Sullins D� War ID NOV 12 2008 j WATER QUALITY SECTION . ASHEVILLE REGIONAL OFFICE One _ Nor Carolina A(rallj North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 807-6300 Customer Service Intemet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 807-6494 1-977-623-6748 An Equal opportunilylAffimtative Actiwt Employer — 50% Recycledi10% Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030070 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, BALDOR ELECTRIC COMPANY is. hereby authorized to discharge stormwater from a facility located at BALDOR ELECTRIC COMPANY 70 REAMS CREEK ROAD WEAVERVILLE . BUNCOMBE COUNTY to receiving waters designated as Reams Creek, a class C stream, in the French Broad River Basin, in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 11, 1II, and IV, V and VI of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective November 7, 2008. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day November 7, 2008. GRiGiNAL SIGNED EW KEN PICKLE for Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission F WATF j� Michael F. Easley, Governor `OTC 9QG William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources y Alan W. Klimek, P.E. Director Division of Water Quality Asheville Regional Office SURFACE WATER PROTECTION January 29, 2007 Mr. John Reno Dodge Rockwell Automation 70 Reems Creek Road Weaverville, NC 28787 SUBJECT: Compliance Evaluation Inspection Dodge Rockwell Automation Permit Number NCG030070 Buncombe County Dear Mr. Reno: Enclosed please find a copy of the Compliance Evaluation Inspection report from the inspection conducted on January 24, 2007. The facility at 70 Reems Creek Road is Compliant with all terms and conditions of its general stormwater permit NCG030070. I appreciate your time and assistance during the site inspection and file review. It is a pleasure to see such environmental integrity incorporated into everyday business practice at Dodge Rockwell Automation. If you should have any questions regarding your permit or compliance with its requirements, please feel free to contact me at 8281296-4664. Enclosure cc: Danny Smith — NIPS ACO Unit c ARO Files Central Files Sincerely, cLkoM. J, Laurie L. Moorhead Environmental Specialist One NorthCarohna Naturally 2090 US Hwy 70, Swannanoa, NC 28778 828-296-4500 Fax 828-299-7043 Customer Service 877-623-6748 Permit: NCG030070 SOC: County: Buncombe Region: Asheville Compliance Inspection Report Effective: 09/01/02 Expiration: 08/31/07 Owner: Dodge Rockwell Automation Effective: Expiration: Facility: Dodge Rockwell Automation 70 Reems Creek Rd Contact Person: John Reno Directions to Facility: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Weaverville NC 28787 Phone: 828-645-4235 Certification: Phone: Inspection Date: 0112412007 Entry Time: 10:06 AM Exit Time: 11:15 AM Primary Inspector: Laurie L Moorhead- 1� Phone: 828-296-4500 CULL `` ! i. Ext.4664 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Stormwater Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ■ Compliant l=1 Not Compliant Question Areas: 0 Storm Water (See attachment summary) Page: i Permit: NCG030070 Owner - Facility: Dodge Rockwell Automation Inspection Date: 01/24/2007 Inspection Type: &tormwater Reason for Visit: Routine Inspection Summary: The inspector met John Reno, Plant Engineer, for a site inspection and document review. The site has a thorough and complete stormwater management plan that is updated annually, with all documentation. Furthermore the plan is being implemented, All visual and analytical monitoring has been conducted. A site inspection noted no issues for cause of concern. Note that visual monitoring may be conducted during any size rainfall event during the spring and fall of each year; but that analytical monitoring is to be conducted during a representative rainfall event only. Page; 2 Permit: NCG030070 Owner - Facility: Dodge Rockwell Automation Inspection Date: O1/24/2007 inspection Type: Stormwater Reason for Visit: Routine Stormwater Pollution Prevention Pull Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ n n [i # Does the Plan include a General Locabon (USGS) map? ■ n n n # Does the Plan include a "Narrative Description of Practices"? ■ n n n # Does the Plan include a detailed site map including outfall locations and drainage areas? >v n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ Q ❑ n # Has the facility evaluated feasible alternatives to current practices? ■ n n # Does the facility provide all necessary secondary containment? ® n ❑ Q # Does the Plan include a t3MP summary? ■ n n n # Does the Plan include a Spill Prevention and Response Plan ($PRP)? ■ n n Q # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ ❑ ❑ n # Does the facility provide and document Employee Training? ■ n n n # Does the Plan include a list of Responsible Party(s)? ■ fl # Is the Plan reviewed and updated annually? ■ 0 n n # Does the Plan include a Stormwater Facility Inspection Program? ■ n n n Has the Stormwater Pollution Prevention Plan been implemented? ■ n n - Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ n U 01 Comment: Note that visual monitoring may be conducted during any size rainfall event, not necessarily a representative rainfall event as defined in the permit. Analytical Monitoring Yes No NA NE _..... ......... ._._... Has the facility conducted its Analytical monitoring? ■ D 0 ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n ❑ ■ 0 Comment: No vehicle maintenance is conducted on -site. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ® n 0 n # Were all outfalls observed during the inspection? ■ n n n # If the facility has representative outfall status, is it properly documented by the Division? n 11 ® n # Has the facility evaluated all illicit (non Stormwater) discharges? ■ n ❑ Page: 3 Permit: NCG030070 Owner • Facility: Dodge Rockwell Automation Inspection Date: 01/24/2007 Inspection Type: Stormwater Reason for Visit: Routine Comment: All floor drains are captured for pre-treatment prior to connecting to the Metropolitan Sewerage District's system. Page: 4 Michael F. Easley, Governor William (3. Ross Jr., Secretary North Carolina Department of> nvironment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Qualily March 31, 2006 Dodge Rockwell Automation 70 Reems Creek Rd Weaverville, NC 28787- Subject: General Stormwater Permit Inspections Dodge Rockwell Automation Permit No. NCG030070 Buncombe County Dear Sir or Madam: Your facility holds a general permit from the North Carolina Division of Water Quality to discharge stormwater associated with industrial activities performed at your facility. Please be advised that the Asheville Regional Office will be performing NPDES stormwater inspections sometime in the near future. If this office has not previously inspected your facility, you should be prepared to demonstrate compliance with all terms and conditions included in the permit. Specifically, we will be evaluating the following: your stormwater pollution prevention plan, stormwater outfall locations, qualitative and analytical monitoring data and any other activities required by your permit. Please note that any data reported to the State must be analyzed by a facility that has a North Carolina laboratory certification, either as a full laboratory or as a facility certified to perform on -site field testing. If you have any questions regarding the generation of your facility's data, please feel free to call Gary Francies at (828) 296-4677. Copies of the general permits and accompanying documents can be accessed from the following webpage: http://ivu>>v.ncls)atergr.tality.oi�g/su/Forms_DocunTents.htnai#stormwaterGP. If you have any questions, please contact me in the Asheville Regional Office at (828) 296-4500. cc: NPS Compliance & Assistance Oversight Unit SWP-Central Files ARP Files Sincerely, Rszl� I Q�_�� Roy Davis Environmental Engineer Noy"hCarolina J1 rrtrrrallil North Carolina Division of Water Quality 2090 U.S. If ivy 70 Internet: hfp:llwww.ncwaterquaEty.org/ An Equal OpportunitylAHirmaVve Action Employer Swannanoa. NC 28778 Phone (828) 2964500 Fax (828) 299-7043