Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
NCG030260_COMPLETE FILE - HISTORICAL_20100521 (FIX)
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. I /V C(0 3 o a�a b DOC TYPE DOC DATE HISTORICAL FILE ❑ MONITORING REPORTS u 'D t5 a J YYYYMMDD NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H, Sullins Governor Director May 21, 2010 CERTIFIED MAIL 7009 0080 0000 9764 8662 RETURN RECEIPT RE VESTED Siemens Energy, Inc. Mrs. Amy Gray 5101 Westinghouse Blvd, Charlotte, NC 28273 Subject: Application for No Exposure Certification For Siemens Energy, Inc. manufacturing plant 7000 Siemens Rd. Wendell, NC 27591 Wake County Dear Mrs. Gray: Dee Freeman Secretary On May 11, 2010 Mr. Myrl Nisely of the Raleigh Regional Office made an inspection with your help to evaluate whether the above facility qualifies for a No Exposure Certification and subsequent rescission of General Stormwater Permit NCG030260. Mr. Nisely appreciated that you delayed a meeting in order to carry out this site review while you were visiting the plant that day. It was noted during this visit that no person working daily at this facility is assigned responsibility for environmental oversight. This was also the status encountered when an inspection was attempted in January, 2010 for permit NCG030260. The requirements of that permit were foreign to personnel at the plant. None of the components of an active program called for in a Stormwater Pollution Prevention Plan (SPPP) were in evidence, such as employee training, documented observations of the stormwater outfalls, analytical sampling or other elements of the program. Your response to the January Notice of Violation letter was the application for No Exposure status and a March update of the SPPP. You and Mr. Nisely did not take time to review that program any further on May 1 I because of your need to participate in a meeting. The hazardous waste storage building has a roof and security fencing, but the four sides are open to the elements. Rain can blow into the area, contact the containers and any spilled material if a spill ever occurred, and then run out onto the concrete and away from the location because there is no containment device. Before the certification can be offered, this storage will need to be improved so that rain cannot enter. There will also need to be at least a minimal containment placed around it to hold any spills. Following this inspection a discussion with the January inspector, Vicki Webb, revealed that a walled building had been used in the past for haz waste. If so, that arrangement would be much preferred. One NorthCarolina Naturally North Carolina Division of Water Quatity Raleigh Regional Office Surface Water Protection Phone (919) 7914200 Customer Service Internot: www.ncwaterqualityorg 1628 Mail Service Center Raleigh. NC 27699-1628 FAX (919) 788-7159 877.623-6748 An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper Siemens Energy No Exposure inspection May 2010 Page 2 of 2 1- There was exposed storage of discarded large electrical parts such as transformers (that you stated contained no PCB or mineral oil), cabinets, and numerous storage bins and shelves containing items ranging from electrical tape to electrical parts to an open container of grease. These constitute a potential threat to stormwater quality, and must be removed before the requested No Exposure can be granted. Based upon the observed site conditions May 11, a file review of past permit history, and the fact that a local delegation of day-to-day environmental oversight appears to be absent, the application for No Exposure is being denied at this time. You may reapply when you feel these issues have been addressed. Until that time, the facility remains responsible for compliance with permit NCG030260. Violations of that permit can be subject to civil penalties of up to $$25,000 per day, If you have questions or comments on this inspection, please contact Myrl at 919-791-4200, or at m) rl.niselyCc�ncdenr.com. ince ely, t Danny S/]ityv Water Qegional Supervisor Raleigh Regional Office cc: RRO SWP files Central Office files Jovonah Weeden, Stormwater Permitting Unit Permit: NCGNE0689 SOC: County: Wake Region: Raleigh Compliance Inspection Report Effective: Expiration: Owner: Siemens Power Generation Inc Effective: Expiration: Facility: Siemens Energy, Inc 7000 Siemens Rd Contact Person: Amy Gray Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 05/11/2010 Primary Inspector: Myrl Nisely Secondary Inspector(s): Title: Entry Time: 02:25 PM Wendell NC 27591 Phone: 704-551-5339 Certification: Exit Time: 03:35 PM Phone: Phone: 919-791-4200 Reason for Inspection: Routine Inspection Type: Reconnaissance Permit Inspection Type: Stormwater Discharge, No Exposure Certificate Facility Status: ❑ Compliant ❑ Not Compliant Question Areas: ■ Miscellaneous Questions (See attachment summary) Page: 1 Permit: NCGNE0889 Owner - Facility: Siemens Power Generation Inc Inspection Date: 05/11/2010 Inspection Type: Reconnaissance Reason for Visit: Routine Inspection Summary: This inspection was a site review to determine if a No Exposure Certification is warranted. This facility has permit NCG030260, under which very little has been done to impiiment permit requirements. NOV-2010-PC-0020 was issued in January accordingly. There is no one at the facility designated as responsible for environmental compliance. Rather, Amy Gray from Charlotte oversees permit issues. She visits several times a year, and perhaps at least once every month, although this was not fully determined. It was observed that most of the outside areas of the site were free of pollutants except for a dicarded equipment area containing electrical equipment, shelves and bins, Some of the bins contained items. Amy agreed that this location must be cleared before no exposure could be granted. In addition, a haz waste storage area outdoors has a roof but no sides to keep rain from blowing onto stored materials, so this must be modified to preclude rain. There needs to be a containment of some kind erected, too, to keep any spill from leaving the storage room. Page: 2 SIEMENS OIOZ g - ddb April 5. 2010 Vicki Webb North Carolina Department of Environment and Natural Resources Division of Water Quality Surface Water Protection Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 Re: Siemens Energy, Inc. Wendell, NC Facility Request for Rescission of NPDES Permit No. NCG030260 CERTIFIED MAIL: 7004 2890 0001 5483 1066 Dear Ms. Webb: This letter follows up on our meeting at the Siemens Energy, Inc. facility in Wendell. NC on February 17, 2010. As we discussed at that meeting, the operations at the Wendell facility have changed significantly since this stormwater permit was issued. Previously, the operations at the Wendell facility included sheet metal fabrication and powder coating of sheet metal parts and assemblies. As of July 25, 2008, these operations were transferred to a Siemens facility in Mexico. At this time, the facility does light machining of metals (drilling, milling, turning), clectro-mechanical assembly and testing of low and medium voltage circuit breakers, assembly and testing of medium voltage reclosers, and assembly and testing of relay control panels. These current operations and the materials used in these operations are not exposed to precipitation or runoff: In addition, following up on the discussion at our site meeting, the uncovered pallets have been removed from the facility and any pallets that remain on the property are located inside or under cover, protected from precipitation or runoff. In short, there are no manufacturing, processing or raw material storage areas exposed to stormwater at the Wendell facility. Since sheet metal fabrication and finishing activities have ceased, it may well be the case that the facility is no longer subject to the regulations governing stormwater associated with industrial activity even though the SIC code is still 3613. However, in the event that the regulations still apply, we are submitting with this letter a completed No Exposure Certification for exclusion from the permitting requirements. We also formally request that our current NPDES Permit No. NCG060260 be rescinded. SIEMENS Also following up on our meeting at the site, I wanted to let you know that the facility's Integrated Storm Water Pollution Prevention and Spill Prevention, Control and Countermeasure Plan has been updated to reflect current activities at the facility. A copy of this updated plan has been included with this letter. Our Maintenance department is conducting regular inspections of our bulk storage liquid containers along with our hazardous material storage building and waste storage area based on the Spill Prevention Control and Countermeasure requirements. Finally, I recently received an annual permit fee invoice for our current permit, NCG030260. Unless I hear from you otherwise, we will hold this invoice for payment until final action is taken on our No Exposure Certification request. If you need any additional information regarding our request for rescission of permit no NCG030260 or anything else addressed in this letter, please give me a call at 704-551-5339. Thank you for your attention to these matters. I look lorward to hearing from you. Sincerely, Amy . Gray Enclosures Integrated Storm water Pollution Prevention Plan and Spill Prevention, Control & Countermeasure Siemens Energy, Inc. 7000 Wendell Road Wendell, NC 27591 Updated by: A. Gray SELF CERTIFICATION of SPCC PLAN The Wendell facility has reviewed the requirements provided in 40 CFR Part 112, and management attests that this Plan has been prepared in accordance with good engineering practices, including consideration of acceptable industry standards, and with the requirements of 40 CFR 1 12, and that the procedures for required inspections and testing have been established, and that the SPCC Plan is adequate for the facility. Name Date Confidential - 3/24/2010 — Rev. 2 NON-STORMWATER DISCHARGE CERTIFICATION (This section may be rcmoved if we qualify for a no -exposure) 1 certify that stormwater outfalls have been inspected for the presence of non-stormwater discharges and that no such discharges are present at the facility. certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with the systems designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiries of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted, is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for known violations. This Plan is fully supported by the management of Siemens. By signing below, the designated company official has authority to commit the necessary resources to perform the provisions described in this Plan. Name: Signature: Title: Date: Confidential - 3/24/2010 — Rev. 2 SUBSTANTIAL HARM CRITERIA CERTIFICATION Facility Name: Siemens Energy, Inc. Wendell Facility Address: 7000 Siemens Road, Wendell, NC 27591 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage greater than or equal to 42,000 gallons? Yes No_X_ 2. Does the facility have a total oil storage capacity greater than or equal to l million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest above ground oil storage tank plus sufficient freeboard to allow for precipitation within any above ground oil storage tank area? Yes No_X_ 3. Does the facility have a total oil storage capacity greater than or equal to I million gallons and does the facility located at a distance such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? Yes No_X_ 4. Does the facility have a total oil storage capacity greater than or equal to I million gallons and does the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake? Yes No—X- 5. Does the facility have a total oil storage capacity greater than or equal to I million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes No—X— Certification: i certify under penalty of law that l have personally examined and am familiar with the information submitted in this document, and based on my inquiry of those individuals responsible for obtaining this information, 1 believe that the submitted information is true, accurate, and complete. Signature: Name: Title: Confidential - 3/24/2010 — Rev. 2 TABLE OF CONTENTS SELF CERTIFICATION of SPCC PLAN............................................................................................... i NON-STORMWATER DISCHARGE CERTIFICATION.......................................................................... ii SUBSTANTIAL HARM CRITERIA CERTIFICATION "' 1.0 INTRODUCTION...................................................................................................................................... 1 1.1 Background and General Requirements......................................................................................... l 1.2 Site and Operation Description...................................................................................................... 1 1.3 Facility Operator and Contact........................................................................................................ 2 1.4 Spill History of Significant Spills or Leaks.................................................................................... 2 2.0 SPILL RESPONSE PLAN........................................................................................................................ 2 11 Spill Alert Procedures..................................................................................................................... 2 2.2 Regulatory Spill Notification......................................................................................................... 3 2.3 Spill Documentation and Follow-up.............................................................................................. 4 2.4 Tank Inspections and Integrity Testing.......................................................................................... 4 3.0 SPILL POTENTIAL AND STORMWATER EXPOSURE.................................................................... 4 3.1 Storage Practices............................................................................................................................ 4 3.2 Potential Spill Events..................................................................................................................... 5 3.2.1 Worst Case Storage Tank Spill Scenario........................................................................ 5 3.2.2 Worst Case Loading/Unloading Spill Scenario.............................................................. 5 4.0 EXISTING PROCESS AND MATERAL HANDLING PRACTICES ................................................. 6 4.1 Loading and Unloading Practices................................................................................................... 6 4.2 Process Areas............................................................................... ............... 6 ................................... 4.3 Waste Disposal Practices............................................................................................................... 6 5.0 POTENTIAL STORMWATER POLLUTANT SOURCES................................................................... 7 5.1 Potential Stormwater Pollutant Sources in Outfall 001 Drainage Area ........................................... 7 5.2 Potential Stormwater Pollutant Sources in Outfall 002 Drainage Area ........................................... 7 5.3 Non -Storm water Discharge Certification ..... ......... ............... ...... ............. .... .... I.............................. 8 6.0 MATERIAL MANAGEMENT PLAN..............................................................................................I......1 8 6.1 Feasibility Study............................................................................................... 6.2 Best Management Practices............................................................................................................ 8 6.3 Requirements for Inspections of Stormwater System and Plant Facilities and Documentation................................................................................................................................ 10 7.0 EMPLOYEE TRAINING.......................................................................................................................... 10 7.1 Spill Prevention and Response........................................................................................................ 11 7.2 Preventive Maintenance and Good Housekeeping.......................................................................... 11 7.3 Material Management Practices.................................................................................................... 11 7.4 Storm water NPDES Permit Requirements..................................................................................... 11 7.5 Schedule for Training .......................................... ..... .................. 12 ....................... .............................. Confidential - 3/24/2010 — Rev. 2 iv TABLE OF CONTENTS (Continued) 8.0 MONITORING AND REPORTING REQUIREMENTS...................................................................... 12 9.0 RESPONSIBILITY FOR STORMWATER POLLUTION PREVENTION PLAN, PLAN AMENDMENTS, AND DOCUMENTATION................................................................................................................................ 12 9.1 Personnel Responsible for Stormwater Pollution Prevention Plan ........................................ 12 9.2 Storm water Pollution Prevention Plan Review and Amendments ......................................... 13 9.3 Documentation........................................................................................................................ 13 LIST OF FIGURES Figure 1 -Site Location Map... .................................................................. 14 Figure2 -Site Map........................................................................................... 16 LIST OF APPENDICES Appendix A Spill Incident Reports........................................................................ 18 Appendix B Inspection Forms.............................................................................. 19 Appendix C SPCC Plan Requirements Reference....................................................... 21 Appendix D SWPPP and SPCC Plan Revisions......................................................... 22 Appendix E NPDES Permit No. NCG030260............................................................ 23 Confidential - 3/24/2010 — Rev. 2 v 1.0 INTRODUCTION 1.1 Background and, General Reguirements Current Federal, State of North Carolina, and local regulations require the Siemens facility to maintain a Storm Water Pollution Prevention Plan (SWPPP), and Spill Prevention, Control and Countermeasure (SPCC) Plan. An SPCC Plan Cross Reference Matrix is included as Appendix F of this Plan. Since the requirements of these plans overlap, a more usable working document can be generated by integrating the plans. This Integrated Spill and Storm water Pollution Prevention Plan meets the requirements of the individual plans, so that all spill response and prevention plan requirements and chemical handling procedures can be addressed with one document. The plan is designed to achieve two main objectives: Identify the actions to be taken in case of an accidental release or spill. Evaluate the potential pollution sources to select and implement appropriate methods to prevent or control the discharge of pollutants in storm water runoff to surface waters or discharge to the city treatment works. The plan does not need to be submitted to the North Carolina Division of Water Quality (DWQ) or the EPA, unless requested, but it must be available for review by DWQ upon request. If the plan is found to be deficient, the permittee must present to DWQ, within 30 days, a time schedule for amending the plan to correct the deficiencies. The plan must be amended whenever there is an expansion or a change in design, construction, operation, or maintenance, which has a significant effect on the potential for the discharge of pollutants to surface waters or the municipal wastewater system. In addition, the plan must be reviewed and updated annually. The Annual Review is maintained as Appendix E of this Plan. 1.2 Site and Operation Description The Siemens facility is located in Wendell, North Carolina just south of Highway 64. Storm water from the site flows north and outfalls into an unnamed tributary that flows west to Buffalo Creek. Buffalo Creek flows south and eventually discharges into the Neuse River. A topographic Site Location Map for the facility is shown in Figure 1. The Wendell facility is a manufacturing plant for electrical switchgear. Siemens operations include packaging, materials storage, product assembly, shipping and receiving, machine shops, and an electrical equipment -testing lab. The entire area of the property is approximately 39 acres. Normal plant operation is 8 hours a day, five days per week. Security is on site 24 hours per day. Confidential - 3/24/2010 — Rev. 2 l .3 Facility Operator and Contact Siemens Energy, Inc. 7000 Siemens Road Wendell, NC 27591 Wake County Contacts: Frank Cinnirella Facilities Manager CB Richard Ellis 919-434-4827 Amy Gray Sr. Facilities HSE Engineer Siemens Energy, Inc. 704-551-5339 1.4 Spill History of Significant Spills or Leaks The EPA has defined "significant spills" to include releases of hazardous substances in excess of reportable quantities designated under Section 311 of the Clean Water Act and Section 102 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Reportable quantities are set amounts of substances as listed at 40 CPR Part 117 and 40 CFR Part 302. Siemens personnel have attested that; based on the definition above, there have been no spills or leaks of toxic or hazardous pollutants at the facility in the past three years. 2.0 SPILL RESPONSE PLAN 2.1 Spill Alert Procedures All spill/ releases of chemicals, paints, diesel fuel, and maintenance oil/lubricants, must be reported immediately, In case of a spill of any amount outside of its storage tank, piping, drum, or beyond its normal use and containment: (A) Stop and Contain the Spill • Stop the source of the spill and contain the spill (socks, pads, pillows or granular absorbent can be used). + Assure that no nammable liquids are near an ignition source. Secure the area. Confidential - 3/24/2010 — Rev, 2 (B) Initial Spill Notification • Immediately report the spill to the key Siemens emergency coordination personnel listed below, in order, at the earliest opportunity after containment procedures have been implemented. Name Office Number Home Number Cell Number Security 919-302-7454 Frank Cinnirella 919-468-7470 919-434-4827 Amy Gray 704-551-5339 407-808-5185 (C) Spill Cleanup • Implement the following spill cleanup procedures: • Collect minor spills occurring within the facility property with absorbent material from a spill kit. • Spilled material contained by absorbent should be collected using absorbent booms or by pumping. • Collected material should be transferred to appropriate containers or vehicles and labeled for disposal. Disposal will be in accordance with federal, state, and local requirements. 2.2 Re ug latory Spill Notification Spills that leave the property will be reported to the following regulatory agencies: Agency Phone Number Wake County Emergency Management 919-856-6480 North Carolina Division of Emergency Management 919-733-3825 National Response Center / U.S. Coast Guard National Response Center (CERCLA Chemical Spillsaransportation Emergency 800-424-8802 U.S. Environmental Protection Agency, Region IV — Southeast — for North Carolina 404-562-8700 NC Division of Water Quality (for oil and hazardous substance spills) http://porial.nodenr.org/web/wq/home 919-807-6300 NC Dept. of Environment and Natural Resources - Raleigh Regional Office 919-571-4700 Confidential - 3/24/2010 — Rev. 2 3 CHEMTREC (24 Hour Chemical Emergency Information Services) 800-424-9300 2.3 Spill Documentation and Follow -Up The HSE Officer will fill out a spill report detailing the cause and size of the spill as well as the actions taken. This information will be kept with the spill plan in Appendix A. 2.4 Tank Inspections & Integrity Testing In addition to monthly visual inspections, Siemens will arrange to have integrity tests performed on any part of the system on which material repairs or modifications have been performed. The testing results will be maintained with this Plan in Appendix B. Samples of monthly visual inspections are located in Appendix B. 3.0 SPILL POTENTIAL AND STORM WATER EXPOSURE The principal process materials include: Steel, copper, aluminum, paints, oils, diesel fuel, and maintenance chemicals. The tanks and buildings referenced in the following sections can be located in Figure 2 of the plan. 3.1 Storar?e Practices All chemicals, with the exception of diesel fuel, are stored inside buildings. All ASTs are constructed of steel, compatible with their contents, and inspected regularly. Unused fill ports and piping are capped when not in use. Wood pallets are stored under cover outside or inside the building. CHEMICALS STORED ON -SITE Material Location Volume Containment Hydraulic and Outdoor Hazardous Covered area, waste oils Waste Storage Area 55 gallon drums containment berm, spill kit Hazardous Material Hydraulic oil 55 gallon drums Stored indoors, spill kit Storage Building Confidential - 3/24/2010 — Rev. 2 4 Material Location Volume Containment Hazardous Material Paints Storage Building, I gallon and 5 gallon Stored indoors, spill kits Maintenance, containers throughout building Scrap Metal Stored inside in the Pit Open top container Stored indoors area Scrap Wire Stored outside Open top container Uncovered Pump House Pump House 250 gallons Stored indoors, spill kit Diesel Tank Generator Diesel Outdoors Near Tank has secondary Fuel Emergency Generator 2,500 gallons containment 3.2 Potential Spill Events 3.2.1 Worst Case Storage Tank Spill Scenario (A) A major spill event will occur by over -filling of the diesel fuel tank at the emergency generator or by the failure of the tank itself, a tank drain valve failure, human error, or a combination of these reasons. The most serious tank failure would be the 2,500-gallon tank, since this is the maximum single volume of oil or chemical stored on -site. (B) The tank is a double walled tank; therefore a rupture of the interior tank would be contained. If both walls of the tank were ruptured, and the spill was subsequently uncontamed, oil will flow generally west into the storm water drainage ditch, then toward Outfall 002. (See Figure 2). Prompt response could contain the spill on the pavement area between the tank and the storm water ditch and/or the storm water ditch could be manually blocked, limiting the impact of the spill. Management will be notified using the Spill Alert Procedures. (C) Clean up will be started. If a spill is significant, the proper authorities will be notified and a qualified hazardous chemical clean-up company will be employed to clean up the spill if it cannot be handled by designated, trained plant personnel. 3.2.2 Worst Case Loading/Unloading Spill Scenario (A) The most serious spill potential event would result from a 5,000-gallon tank truck failure during fuel delivery, since no permanent containment area is provided for tank truck unloading. However, such an event is unlikely, because the fuel is for emergency generator use only, and fuel deliveries are very infrequent, approximately once or twice a year. Spills Confidential - 3/24/2010 — Rev. 2 5 resulting from a tank truck incident or before chemical containers are unladed from a trailer truck must be treated on a case -by -case basis by the truck owner. Siemens/ CBRE personnel will help to contain the spill but are not expected to clean up a tanker spill of 5,000 gallons or a Full chemical container spill. Uncontained loading and unloading spills will flow by storm water drains and ditches to Outfall 001 or 002 (See Figure 2) unless prompt action is taken to block or divert the spill. (B) When an unloading tank truck experiences a major spill event, pumps will be stopped, valves closed and the cleanup procedure initiated. (C) Management will be notified using the spill Alert Procedures. (D) After cleanup, the spill will be analyzed and a method to prevent repetition of the spill will be devised and procedures initiated. 4.0 EXISTING PROCESS AND MATERAL HANDLING PRACTICES 4.1 Loading and Unloading Practices The following list describes the loading and unloading practices for process materials. (A) Diesel fuel is unloaded with supervision present during the unloading. An unloading containment area does not exist, but a spill kit is available to address a spill. (B) All chemicals are received at the loading dock, which is located on the west side of the plant. All materials are transported to their respective storage and use areas immediately. A containment basin, which discharges to the storm water ditch on the west side of the site, lies below the off-load area (at Shipping and Receiving) in case of a release. 4.2 Assembly Areas All assembly areas are indoors and not exposed to storm water. 4.3 Waste Disposal Practices (A) Liquid Wastes All liquid wastes are contained in DOT approved containers and disposed of in accordance with state and federal laws. (B) Solid Wastes Process solid wastes include: • Scrap metal is stored inside. • Pallets that are stored outside are under cover. Confidential - 3/24/2010 — Rev. 2 e Scrap wire is stored outside in an open container on a paved surface. Solid wastes from the offices and throughout the plant are placed in a compactor dumpster and have minimal exposure to storm water. Cardboard is placed in a compactor dumpster and has minimal exposure to storm water. 5.0 POTENTIAL STORMWATER POLLUTANT SOURCES Figure 2 shows the location of structures and storage areas relative to the site drainage pathways and storm water OutfalI locations. An outfall is defined as the point where storm water enters a natural waterway or a separate storm sewer system. 5.1 Potential Storm water Pollutant Sources in Outfall 001 Drainage Area The potential storm water contamination is limited to the storage and transportation of chemicals. An example of a monthly inspection log for this area is maintained in Appendix B. Completed forms are kept in a total site inspection binder. (A) Paints and Oils Paints and oils being delivered to the Hazardous Material Storage Building could be punctured or spilled while being moved. All employees transporting chemicals have been trained in the proper use of the forklifts and on how to respond to a spill if one occurs. (B) Scrap Metal Scrap metal is stored inside on the west side of the building. Scrap wire is stored outside uncovered. (C) Hazardous Waste Storage Area A secondary containment berm is built around the outdoors Hazardous Waste Storage Area to contain spills. This area has limited access and is inspected regularly. Completed forms are kept in a total site inspection binder. 5.2 Potential Storm water_ Pollutant Sources in Outfall 002 Drainage Area The potential storm water contamination is limited to the storage and transportation of diesel fuel, An example of the monthly inspection log for this area is in Appendix B. A spill during the unloading of diesel fuel at the emergency generator fuel tank or the fuel tank in the fire pump house could result in the contamination of storm water. All unloading of fuel is done in the presence of supervision to assure that no leaks or spills occur. A spill kit is available Confidential - 3/24/2010 -- Rev. 2 to immediately respond to any release. Off-loading of diesel will be rare since the fuel is only used for an emergency generator and water pump engines. 5.3 Non -Storm Water Discharge Certification Non -storm water discharges are not covered under the NPDES Permits for Storm water Discharges. Non -storm water discharges must be covered by a separate storm water permit or a wastewater NPDES permit, depending on the discharge. Non -storm water discharges are illegal unless covered by a separate permit. As part of the requirements for an SPPP plan, a certification statement that the discharge from the facility has been tested for the presence of non-stormwater discharges must be included in this plan. The purpose of the test is to make certain that the origin and content of flows that discharge from the stormwater outfalls are known. The certification must contain at least the following information: • Date of testing • On -site drainage points observed during the test • Method of testing used • Description of the test results • Statement regarding the presence of non -storm water in the observed discharge 6.0 MATERIAL MANAGEMENT PLAN The material management plan for the Siemens facility addresses materials management practices to control or minimize the exposure of materials to storm water or process drains. These management practices include both structural and non-structural measures, and applicable Best Management Practices. 6.1 Feasibility Study The current storage and containment areas minimize the chance for storm water contamination. The facility drainage ditch also contains vegetation that acts as a natural filter for storm water before it leaves the site. Though pallets stored outside are covered, inside storage should be considered. 6.2 Best Management Practices Best Management Practices (BMPs) are measures used to prevent or mitigate pollution that can result from many types of industrial activities. BMPs cover a wide range of activities that include Confidential - 3/24/2010 — Rev. 2 processes, procedures, schedules of activities, prohibitions on practices, and other management practices to prevent or reduce storm water pollution. BMPs are aimed at preventing environmental incidents by stressing the importance of employee awareness of potential spill situations. BMPs generally include practices for: prevention, containment, mitigation, and disposal. Prevention includes monitoring, covering, and clean up prior to exposure to storm water. Containment includes spill containment, flow diversion, and dust control. Mitigation includes clean up of leaks and spills, and the separation of contaminated and uncontaminated materials. Disposal includes hauling to off -site disposal facilities and discharges to sanitary sewers or storm water systems. This section briefly describes BMPs that are in place at the Siemens facility (A) Preventive Maintenance The Siemens preventive maintenance program includes the timely inspection and maintenance of storm water management devices, inspection and testing of plant equipment to prevent conditions that could cause breakdowns or failures and result in storm water pollution or discharges to the sewer, and proper maintenance of plant equipment and systems. Visual inspections are completed weekly and monthly. Examples of the forms and procedures used at this facility for inspections and record keeping are included in the Appendices of the plan. The preventive maintenance and inspection practices are reviewed regularly to determine if personnel are performing the tasks properly and in a timely manner, or if more effective methods should be implemented. (B) Good Housekeeping Good housekeeping practices are designed to maintain a clean and orderly work environment. These practices are often the most effective first step in preventing pollution. Spills around process equipment are cleaned up as soon as possible. Solid waste materials are regularly picked up and properly disposed. Training occurs to ensure that spill cleanup procedures are understood by employees. (C) Material Storage and Inventory Practices Drums and other containers of material should be stored away from direct traffic routes to prevent accidental spills. Drums and containers should be stacked according to manufacturers' instructions to avoid damaging the containers. All containers should be labeled with name of material and health hazards. Maintain an up-to-date inventory of all materials present on the site and a current Material Safety Data Sheet for each. Confidential - 3/24/2010 — Rev. 2 (D) Sediment and Erosion Control 'There is little opportunity for erosion associated with the storm water collection and conveyance system because the open ditches or swales that could be subject to erosion are well established with vegetation and are not traveled across. 6.3 Requirements for Inspections of Storm Water System and Plant Facilities and Documentation Weekly inspections of the hazardous waste storage areas and monthly inspections of all other chemical and oil storage locations will be completed. The purpose of this inspection is to look for cracks, deterioration, accumulations of solids, and other factors that could impact the effectiveness of the system. These inspections are currently documented. Examples of these forms are included in Appendix B. In addition, it is required that each of the storm water outfalls be visually inspected at a minimum of two times per year, once in the fall (September through November) and once in the spring (April through June). The forms for documenting the results of these visual inspections are included as Appendix C. 7.0 EMPLOYEE TRAINING Employee training is essential to the effective implementation of the Integrated Spill and Stormwater Plan. The purpose of an employee training program is to inform personnel at all levels of responsibility of the goals and components of the plan. When properly trained, personnel are more capable of preventing spills, recognizing situations that could lead to storm water contamination or sewer slug discharges, and responding safely and effectively to an accident when one occurs. Training should address each component of the Integrated Spill and Stormwater Plan, including how and why tasks are to be implemented. Training should address four major areas: • Spill Prevention and Response • Preventive Maintenance and Good Housekeeping • Material Management Practices • Basics of Stormwater NPDES Permit Requirements • A brief description of each topic that should be covered as part of the training program is outlined below. Confidential - 3/24/2010 — Rev. 2 10 71 Spill Prevention and Response • Show employees the potential spill sources and locations, and drainage routes at the facility. • Instruct employees on how to report spills and the appropriate individuals to contact. • Instruct employees on how to quickly and safely implement the facilities spill response procedures. • Show employees the spill response equipment and spill kits and where.they are located. • Instruct on -site contractors, temporary personnel.. and fuel delivery personnel about plant operations and procedures in order to help prevent spills from occurring. 7.2 Preventative Maintenance and Good Housekee in • Instruct employees to promptly clean up spilled materials to prevent storm water from becoming contaminated. • Show employees the locations of housekeeping equipment such as brooms, absorbents, etc. • Discuss updated procedures and report on the progress and success of good housekeeping. 7.3 Material Management Practices • Discuss material handling procedures and storage requirements. • Instruct employees on the proper methods to secure drums and other containers for transport by forklift or hand truck and for storage. • Instruct employees to routinely check the drums and containers for leaks. • Instruct employees to maintain stored materials in a neatly organized manner. • Discuss need to clearly mark toxic and hazardous substances. • Describe proper and safe handling procedures for toxic and hazardous substances. • Describe use of Material Safety Data Sheets and where they are available. 7.4 Storm water NPDES Permit Requirements Stormwater now requires a State permit to be discharged off a site due to concerns about the amount of pollution that is contributed by storm water runoff from industrial sites. Confidential - 3/24/2010 — Rev. 2 11 Goal of the permitting procedure is to reduce the pollutants that wash off of the plant site. Pollutants can be reduced by successful implementation of spill prevention, preventive maintenance, good housekeeping, improved materials management, etc. A requirement of the permit is the development and implementation of a Stormwater Pollution Prevention Plan. This plan is an integration of these requirements with other spill and emergency response requirements. Penn it requires storm water monitoring. The frequency of monitoring and pollutants to be monitored for are listed in the permit. 7.5 Schedule for Training • 'Training should be completed annually. New employees are initially trained as part of their orientation and then participate in the annual training. • Training documentation is located with the FISE Officer, 8.0 MONITORING AND REPORTING REQUIREMENTS The General permit issued to the Siemens facility contains monitoring and reporting requirements. A copy of National Pollutant Discharge Elimination Systems (NPDES) Permit No NCG030260 is included as Appendix E. 9.0 RESPONSIBILITY FOR STORMWATER POLLUTION PREVENTION PLAN, PLAN AMENDMENTS, AND DOCUMENTATION 9.1 Personnel Responsible for Storm water Pollution Prevention Plan The plan must identify a specific position that is responsible for the overall coordination, development, implementation, and revision of the plan. If designated by the person with overall responsibility, the responsibility for individual components of the plan may be delegated and must be so documented. The person with overall responsibility for the SWPPP/SPCC plan at the Siemens facility is: Name: Amy Gray Title: Sr. Facilities HSE Engineer Phone: 704-551-5339 Confidential - 3/24/2010 -- Rev. 2 12 9.2 Storm water Pollution Prevention Plan Review and Amendments The permittee must review this plan as necessary or at least annually. In addition to the annual update, the permittee must amend the plan whenever there is an expansion or a change in design, construction, operation, or maintenance that has a significant effect on the potential for the discharge of pollutants to surface waters. 9.3 Documentation Implementation of the plan includes the documentation of: • Inspection and maintenance activities • Training provided to employees • Stormwater sampling measurements and data The documentation must be kept on -site for a period of five (5) years and must be made available to the Division of Environmental Management immediately upon request. Confidential - 3/24/2010 — Rev. 2 13 /O L3 VVV W Wl.aJ04 /O C V I AV b a 7r tr it m 70°23.000' W WG5D4 78"22.000' W 0 S 1Nlf �CM FEET Limm M,p F .d mtL Toole OW" N,w d G..MLe (wwvmtiom�egi peKmaRopo7 DATE: APR11,2005 DRAWN: TRP TRiGON_E RING CONSULTANTS INC- �� 7DO 8E 71Rart FEiape SCALE: q5 NOTED CHECKED; TEiP Caf " 21oi R+.ktr. liaih CuaEn� 27608 7I9IiaC 3IV -----_..--._ Fry m:IVtfl]`- 1 FNCMR) 7-111 APPROVED: TIiP QUADRANGLE LOCATION RFFFRENF_E; U.S GEOLOGICAL SURIIFY- MONCURE AND MERRY OAKS QUADRANGLES NORTH CAROLINA 7.5 MINUTE SENES SITE LOCATION MAP SIEMENS WENDELL, NORTH CAROLINA FIGL 1 LEGEND --'-----' Property Line Stcrmwater Flaw Direction I Earthen Berm WOODS--"(Stormwater Ditch ; I -- Stormwater Outfall OUTFALL 002 I % OFFICE i Pavement BUILDING OUTFALL 001 r r Road I _ , ! SIEMENS RD. PRODUCTION BUILDING ; y- I �. EMERGENCY ` E� GENERATOR i LOADING DOCK 1 i , ® I I I ! 30,000-GALLON I ! FIRE WATER RESERVOIR PAINT I AND PUMPHOUSE HOUSE HAZARDOUS WASTE STORAGE AREA I I � I waoos ' HAZARDOUS MATERIAL �— ! r STORAGE BUILDING SCALEI I ' a' 500' mime scnuu vaovFxn ur+E �Nos,wv>soweµt>•:'Lv rsv solrnp I DATE: APRIL2005 PRAWN'. TRP SITE MAP FIGURE ��� TR1G0.N ENGZ,,,hF NGCONSVLTANTS INC. 7�o e1n HN" CI stem tot SCALE; q5 NOTED CHECKED: TRP 2 naylpn,Nonnc.,dm. neoa SIEMENS y TFi900N pltae.,a,n7� 11 Fe ro,a,7So-W. APPROVED: TRP WENDI=LL, NORTH CAROLINA APPENDIX A Spill Incident Reports (example) Spill Event Form Date: Person Reporting the Spill: Description of Spill (source. material. amount spilled). Facility Personnel Response Time: Emergency Personnel Response Time: Notes. Changes 10 be Implemented: Time Table for Implementation: Confidential - 3/24/2010 — Rev. 2 APPENDIX B Inspection forms Monthly inspections Wendell faulty, 7000 Siemens Road, Wendell, NC Legend: Y - Yes, N - No YFAR Generator Diesel Tank 1. Is the edenor mating In good condiWO— ����1♦������� 0. Are in -line equipment operating 7. Is the Interstitial monitodngde0ce, working properly? ������'1♦���� ected by jEnWlnfflais) r s.•. Inspected Comments: 1, Is the eidedor mating of the tank in good condnion? 7. Are contain men( areas showirg sigrrs of era eking? Comments: Mnnlh hazilrftus Material Storage BulidirV on©u©ann©m©n Comments, Confidential - 3/24/2010 —Rev. 2 Accumulated Stormwatef Inspection Form This form is to be completed if Stormwater is found in any secondary containment areas rvTnl� 1. Stormwater has collected in a secondary containment area. 2. Are the secondary containment devices connected directly to the stormwater system? (if yes, see 92, if no. see #3 3. if yes, the ccnnecticn shall be controlled by manually activated valves or other similar devices secured closed with a)ocking mechanism The stormwater shall be released if found to be uncontaminated by the material stored within the containment area. 4. The stormwater has been visually_observed for color pnor to release? 5. The stonnwaler has been visually observed for foam prior to release? 6, The stormwater has been visually observed for outfall stainin prior to release? 7. The stormwater has been visually observed for a visible sheen prbr to release? the observations? and Time of release of the accumulated stormwater: Confidential - 3/24/2010 — Rev. 2 APPENDIX C SPCC Plan Requirements Reference The purpose of this cross-reference matrix is to ensure that all the regulatory requirements of the SPCC Plan have been met. Each regulatory citation is addressed in the corresponding page listed below. 40 CFR 112 Requirement Section of this Plan § 112.7 (a)(l) Discussion Of the facility's conformance 1.1 Background and General Requirements with the requirements listed in §l 12.7 § 112.7 (ax3) & (ax3)(i) Physical layout of the facility List Appendices including a facility diagram, which includes location, contents, and size of each container §112,7 (a)(3)(ii) Discharge prevention measures and 4,0 Existing Process and Material Handling procedures for routine handling Practices § 112.7 (a)(3)(iii) Discharge] drainage controls i.e. 20 Spill Response Plan; 3.0 Spill Potential and secondary containment Stonn Water Exposure §112.7 (a)(3)(iv) Countermeasures for discharge, 2D Spill Response Plan discovery, response and cleanup §112.7 (a)(3)(v) Methods ol'dispoml of recovered 2,0 Spill Response Plan materials §112.7 (a)(3)(vi) 1 nrergency contacts (National 2.2 Regulatory Spill Notification Response Center, Cleanup contractors with whom you have agreements, and Federal, State, and local agencies that must be contacted in case of a discharge) §112.7 (vi)(4) Exact reporting infonnation 2.2 Regulalory Spill Notificalion §112,7 (vi)(5)(b) Prediction of direction of drainage 5.0 Potential Stormwate, Pollutant Sources and flow Appendix (list) Confidential - 3/24/2010 — Rev. 2 APPENDIX D SWPPP and SPCC Plan Revisions A review and evaluation of the SWPPP is required to be conducted annually, and the SPCC Plan is required to be reviewed at least once every live years. As a result of this review and evaluation, Wendell Siemens Energy, Inc. will make modifications to the plan, if required. This Plan will also be amended within six months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility's potential for the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines. Revision Date 2010/2C22 Revision I Updated Integrated SWPPP and SPCC Plan, with changes to processes and contact information. 2010/03/24 Revision 2 Made minor changes to plan: Self Certification of SPCC Plan section, formatting, table of contents Confidential - 3/24/2010 — Rev. 2 a i y STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES S DIVISION OF WATER QUALITY �a GENERAL PERMIT NO. NCG030000 ; a' CERTIFICATE OF COVERAGE No. NCG030260` 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, SIEMENS POWER TRANSMISSION DC is hereby authorized to discharge stormwater from a facility located at SIEMENS POWER TRANSMISSION DC 7000 SIEMENS RD WENDELL WAKE COUNTY to receiving waters designate . s a UT to Buffalo Creek, a class B NSW stream, in the Neuse RivcBasin in accordance witli the effluent l itations, monitoring requirements, and other conditions set forth in P% I, IT, III, 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 shall 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 Water Quality By Authority of the Environmental Management Commission APPENDIX E National Pollutant Discharge L-limination System (NPllLS) Permit No NCG030260 Confidential - 3/24/2010-- Rev. 2 23 SIEMENS Vicki Webb North Carolina Department of Environment and Natural Resources Division of Water Quality Surface Water Protection Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 Re: Siemens Energy, Inc. Wendell, NC Facility Notice of Violation (NOV) NOV-2010-PC-0020 CERTIFIED MAIh: 7004 2890 0001 5483 1035 Dear Ms, Webb: This letter is in response to the January 1], 2010 NOV and also follows up on our telephone conversation on January 13, 2010. This response is being submitted by February 5, 2010 as requested in the NOV. Since receipt of the NOV, we have been conducting a thorough audit to not only respond to the items in the NOV but also to accurately assess the Wendell's plant compliance status with the general stormwater permit, identity what actions may need to be taken as to any potential compliance deficiencies, and, if any, determine why those deficiencies occurred and take steps to ensure as much as possible that those do not occur again in the future. This audit is still continuing but we want to report to you on what we have done thus far. We will provide further information when our investigation is completed, which will probably be some time in the next two to three weeks. In addition to the potential issues identified in your letter, our inquiry has identified some other potential issues related to the stormwater permit, some of which we are continuing to assess. We have already begun taking some actions. We are in the process of updating the facility's stormwater pollution prevention plan. With regard to inspections, the facility's engineer has historically conducted regular inspections of the plant all of which appear to have shown the plant to be in compliance with the qualitative monitoring requirements. No stormwater problems or concerns were reported to plant management. However, we have not yet located any written documentation of these inspections. In advance of completing our review on that, we are currently developing a form document for these inspections to be used in the future and will be conducting within the next few days an inspection which uses this form. With regard to analytical monitoring, we have scheduled a sampling event for this weekend (as a high chance of SIEMENS rain is predicted) and will provide those results to you as soon as we receive them. To date, we have not found records of any sampling. We are also trying to determine whether the Wendell facility has been required to be covered by this general permit and if it needs to continue to be covered going forward. Historically, the operations at the Wendell facility included sheet metal fabrication and powder coating of sheet metal parts and assemblies. As of July 25, 2008, these operations were transferred to a Siemens facility in Mexico. As a result, all sheet metal fabricating and finishing activities at the Wendell facility have ceased which may mean that coverage under the general permit is no longer required. Finally, to the extent that the general permit ever did apply, we will thoroughly investigate why any identified compliance issues arose. As noted above, there have been business changes and management reorganizations at the Wendell facility culminating with the relocation of operations to Mexico, and we understand that this kind of situation could have ultimately contributed to that. There also appears to be some uncertainty as to whether or not the plant ever received notice that the general permit had been reissued and that it continued to apply to the plant. We offer this only by way of background. Siemens fully understands that it is our responsibility to comply with any applicable permit requirements regardless of these kinds of events. We anticipate being able to provide the documented inspection report and the sampling results in the next two to three weeks. If that schedule changes, we will let you know right away. You had also asked for an opportunity to come out and look at the facility's operations. Once we submit this additional information, perhaps we could then schedule a meeting at the plant to discuss all of these issues further and afford you that opportunity. Thank you for your attention to these matters. If there is anything you would like to discuss, please give me a call at 704-551-5339. We will be in touch soon. Sincere[ , Amy . Gray NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary January 11, 2010 CERTIFIED MAIL 7006 2150 0000 3312 8543 RETURN RECEIPT REQUESTED Mr. Julius Parker 7000 Siemens Rd. Wendell, NC 27591 Subject: Notice of Violation (NOV) NOV-2010-PC-0020 Stormwater Compliance Evaluation Inspection NPDES Permit No. NCG030260 Siemens Power Transmission DC Wake County Dear Mr. Parker: On January 4, 2010, Vicki Webb of the Raleigh Regional Office conducted a stormwater compliance evaluation inspection of the subject facility. The following observations were made: 1. The Siemens Power Transmission DC is located at 7000 Siemens Rd., Wendell, NC. The facility discharges into the receiving waters designated as an unnamed tributary to Buffalo Creek in the Neuse River basin. 2. This facility is in violation of all aspects of your permit. The main violations occur in Part II: Monitoring, Controls, and Limitations for Permitted Discharges, Section A: Stormwater pollution Prevention Plan, Section B: AnalyticaI Monitoring Requirements, and Section C: Qualitative Monitoring Requirements. 3. You can visit the Stormwater Unit web site under NCG030000 Metal Fabrication to attain a copy of your general permit, http:Hh2o.enr.state.ne.us/su/Forms Documents.htm. PIease respond to this NOV by February 05, 2010, addressing how you plan to bring this facility in to compliance. Also include in your response all documentation you have pertaining to item #2 listed above. Permit condition violations are subject to civil penalty assessment of up to $25,000.00 per day per violation. The Raleigh Regional Office is considering recommending to the Director that further enforcement actions be taken, including penalty assessments. Aturally onehCarolina North Carolina Division of Water Qua0ty Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet. www.newaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 788.7159 877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer paper F1 4 Siemens Power 'rransm is si on DC Notice of Violation (NOV) NOV-20 I O-PC-0020 NPDES Permit No. NCG030260 Wake County Thank you for your attention to these matters. If you have any questions regarding the attached report or any of the findings, please contact Vicki Webb at (919) 791-4256 or email: vicki.webbnncdenr.gov. Sincerely, S. Daniel Smith Water Quality Regional Supervisor Regional Office cc: Central Files �RRO A Permit: NCG030260 SOC: County: Wake Region: Raleigh Compliance Inspection Report Effective: 09/01/02 Expiration: 08/31/07 Owner: Siemens Power Transmission Dc Effective: Expiration: Facility: Siemens Power Transmission Dc 7000 Siemens Rd Contact Person: Andres Guzman Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 01/04/2010 Primary Inspector: Vicki Webb Secondary Inspector(s): Title: Facility Manager Certification: Wendell NC 27591 Phone: 919-365-2087 Phone: Entry Time: 11:30 PM Exit Time: 12.15 PM o 0 --5"� za � o 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: NCG030260 Owner - Facility: Siemens Power Transmission Dc Inspection Date: 01/04/2010 inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Page: 2 Permit: NCG030260 Owner - Facility: Siemens Power Transmission De Inspection Date: 01/04/2010 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? ❑ ■ ❑ Cl # Does the facility provide all necessary secondary containment? Cl ■ ❑ ❑ # 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: NOV Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑ Comment: NOV 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: NOV Permit and Outfalis 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? ❑ ■ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ ■ ❑ ❑ Comment: NOV Page: 3 Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality August 23, 2002 ANDRES GUZMAN SIEMENS POWER TRANSMISSION DC PO BOX 29503 RALEIGH, NC 27626 Subject: NPDES Stormwater Permit Renewal SIEMENS POWER TRANSMISSION DC COC Number NCG030260 Wake 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, 1983. 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 Mack Wiggins of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 542 Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Stormwater & General Permits Unit Files Raleigh Regional Office N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 ®pO NCDENR Customer Service 1-800-623-7748 State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, P.E. Director 06/06/2002 CERTIFIED MAIL RETURN RECEIPT REQUESTED ATTN: JOHN W KERN JR. "SIEMENS ENERGY AND AUTOMATION, INC." PO BOX 29503 RALEIGH, NC 27626 Dear Permittee: NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: NOTICE. OF VIOLATION FAILURE TO SUBMIT RENEWAL APPLICATION "SIEMENS ENERGY AND AUTOMATION, INC." NCG030000 COC NUMBER NCG030260 WAKE COUNTY This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a renewal request for the subject permit certificate of coverage. This is a violation of NCGS §143.215.1 (c)(1) which states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be". Any permittee that has not requested renewal at least 180 days prior to expiration or permittee that does not have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures as provided in NCGS § 143-215.6 and 33 USC 1251 et. seq. In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). If the subject discharge 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. Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please contact Mack Wiggins of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 542. Sincerely, for Alan W. Klimek, P.E. Director, Division of Water Quality cc: Stormwater and General Permits Unit Files Central Files Raleigh Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources •�oF ,�cA ricRQ �O v 6 JOHN W KERN JR. SIEMENS POWER TRANSMISSION DC PO BOX 29503 RALEIGH, NC 27626 Dear Permittee: Gregory J. Thorpe, Ph.D. Acting Director Division -of Water Quality December 27, 2001 Subject: NPDES Stormwater Permit Renewal SIEMENS POWER 'TRANSMISSION DC COC Number NCG030260 Wake County 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 laic 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 coverage under the general permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in advance that your permit will he expiring. Enclosed you will find a General Permit Coverage Renewal Application )Norm. The application must he 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 of stormwater f'ronl your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in assessments of 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 I 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 iacilly industrial materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional information contact the Central Off -ice Stormwater Staff member listed below or check the Stormwater & General Permits Unit Web Site at hitp://li2o.eiii-,st,,ite.nc.us/,;tj/st(.)rniwitei-.Iittiil If the subjecl stormwater discharge to waters of the state has been terrninaled, please complete the enclosed Rescission Request Form. Mailing instructions are listed on the bottom of'thc form. You will be notified when the rescission process has been completed: If you have any questions regarding the permit renewal procedures please contact Joe Alhiston of the Ralcigh Regional Office at 919-571-4700 or Bill Mills of the Central Office Stormwater Unit at (919) 733-5093, ext. 548 Sincerely, Bradluy 13cnnett, Supervisor Stormwater and General Permits Unit cc: Central Files Raleigh Regional Office N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 N"A NCDENR Customer Service 1- 800-623-7748 State of North Carolina Department'of Environment LT ah and Natural Resources • Division cf \^!oter Quality Michael F. Easley, Governor William G. Ross Jr., Secretary NCDENR Kerr T. Stevens, Director NORTH CAROUNA-DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 5/30/2001 CERTIFIED MAIL - RETURN RECEIPT REQUESTED JOHN W. KERN, JR. SIEMENS POWER TRANSMISSION DC PO BOX 29503 RALEIGH NC 27626 SUBJECT: NOTICE OF VIOLATION AND REVOCATION FOR NON PAYMENT PERMIT NUMBER NCG030260 1 SIEMENS POWER TRANSMISSION DC� WAKE COUNTY Dear Permittee: Payment of the required annual administering and compliance monitoring fee of $80,00 for this year has not been received for the subject permit. This fee is required by Title 15 North Carolina Administrative Code 2H.0105, under the authority of North Carolina General Statutes 143-215.3(a)(1), (1a) and (1b). Because this fee was not fully paid within 30 days after being billed, this letter initiates action to revoke the subject permit, pursuant to 15 ncac 2H.0105(b) (2) (k) (4), and G.S. 143-215.1 (b) (3). Effective 60 days from receipt of this notice, subject permit is hereby revoked unless the required Annual Administering and Compliance Monitoring Fee is received within that time. Discharges without a permit are subject to the enforcement authority of the Division of Water Quality. Your payment should be sent to: N.C. Department of Environment and Natural Resources Division of Water Quality Budget Office 1617 Mail Service Center Raleigh, NC 27699-1617 . If you are dissatisfied with this decision, you have the right to request an administrative hearing within Thirty (30) days following recipt of this notice, identifying the specific issues to be contended. This request must be in the form of a written petition conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina, 27611-7447. Unless such request for hearing is made or payments received, revocation shall be.final and binding. If you have any questions, please contact: Mr. Ken Schuster, Raleigh Water Quality Regional Supervisor, (919) 571-4700. Sincerely, Kerr T, Stevens cc: Supevisor, Water Quality Permits and Engineering Unit Raleigh Regional Office County Health Department 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 1 10% post -consumer paper . k'ta►e of North Carolina Department of Environment, Healthiand Natural Resources. Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director Mr. Richard Brindza Siemens Energy and Automation, Inc. P.O. Box 29503 Raleigh, N.C. 27626 Dear Mr. Brindza: October 22, 1993(t`y 4. `k 'PO Subject: General Permit No. NCG030000 Siemens Energy and Automation, Inc. COC NCG030260 Wake County 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 MilIs at telephone number 9191733- 5083. Sincerely, Original Signed 8y CG:een H. Sullins A. Preston Howard,.Jr., P. E. cc: (Raleigh Regional Office Wake County Health Department P.O. Box 29535, Raleigh, Forth Carolina 27626-0535 Telephone 919-733.5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper 1,. STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE NO. NCG030260 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, Siemens Energy & Automation, Inc. is hereby authorized to discharge stormwater from a facility located at Siemens Energy & Automation, Inc. Siemens Road Wendell Wake County to receiving waters designated as an unnamed tributary to Buffalo Creek in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11, III and IV of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective October 22, 1993. This Certificate of Coverage shall remain -in effect for the duration of the General Permit. Signed this day October 22, 1993. CziN �'a4 S..rned By LK jUiilils A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission Cerise i/ l• .�—� Ll �� Q yI'�\ �� I .. � . fir• � �' yn , � � �� C ' , %`J��, ✓/r J ^ /-� 1^,�//� r \ \ - 3969 60 POO pa,�: �' � _ 3�: —• r-� 3 5 ,'\ \ 'i, ••'Z325 ,� c cp 2325 \\ ,;. _— �/ ,� II � •ti II_``\ !`� � ,tip-�•� Z ^_' `� `�� 1 `✓ , '� T ���� l_/ � k�c7 �JI i j �I 1� 1 ��QV � ; �/ 1 : -0350 •:I za d Lick' m �� — —:�-'�� 1 �'—��i � �� � � —�•' � zoos �' •`'�i. — �y�• I �LAhi v �))! li V�ghSch� •'j•� I � -i � � �`1�`/. 'S� ;�I'~.� J � ;357 AW 300 IA /r I n 1 f l`1-� II• _ '�_-~ .�-'-�.1� `� .\' ,$ephz�ba�� r, _ _ _ +` *ram �- / am\. �,__ _ jj \ `'3965 r✓; . i J /--- I ii�--��.7.-•;ter'; i, �j� �.. `����'� 'il` � QRFQ�x�—vim. ; 3 �emri I � � r �-•'/ _'� � !1�' �I �- �.,` �,-y�' .` \� '. �Y. — ��--���-� �` • �`.�i�. �\ � � 4��.� � t`� '. rifiP I �2��_, 326 3964 125p11 ;� 3zz u.tagle OCKLS— _,-_ �' �. - 47'30,. ate. /�J \�E. �'• �' •!! L. ,_ _3!°�^ �/, _ SO-Ce '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 Mr. Joseph E. Spahn Sr. Mfg. Eng. Siemens Energy and Automation, Inc. P. O. Box 29503 Raleigh, NC 27626-0503 Dear Mr. Spahn: ID FE F 1 January 24, 1994 RECE1 JJAI 1 0E1*VR'RgL Subject: Waiver of First Sampling General Permit C of C NCG030260 Siemens Wendell, Wake County Zei This letter is in response to your letter of November 2, 1993, to Mr. Preston Howard wherein you request that the first sampling event as specified in General Permit NCG030000 be waived for your facility. The sampling activity which you undertook in order to prepare the individual NPDES stormwater permit application is sufficient to give an adequate characterization of stormwater from you facility prior to implementation of the Stormwater Pollution Prevention Plan, which is the intent of the first sampling required by NCG030000. Therefore, your first sampling requirement under the provisions of NCG030000 is hereby waived. If you have any questions concerning these requirements or we may_,be of further service concerning the stormwater program, please contact me at 733-5083, ext. 548, i cc: t4eigh Regional Office P.O. Box 29535, Raleigh, North Carolina 27626-0535 An'Equal Opportunity Affirmative Action Employer Sincerely, "Lr�� William C. Mills, PE Stormwater Group, Permits and Engineering Telephone 919-733-7015 FAX 919-733-9919 50% recycled/ 10% post -consumer paper .- State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality • • James B. Hunt, Jr., Governor Wayne McDevitt, Secretary [D C I'A F1 A. Preston Howard, Jr., P.E., Director September 24, 1997 JOHN W. KERN, JR. SIEMENS POWER TRANSMISSION DC PO BOX 29503 RALEIGH, NC 27626 Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG030260 Wake 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: z A copy of the stormwater general permit. ■ 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. ■ Five copies of Analytical Monitoring forms. ■ 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, forA. Preston Howard, Jr., P. E. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper State of North Carolina Department of Environment, Health and Natural Resources i3ivision of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director Mr. Richard Brindza Siemens Energy and Automation, Inc. P.O. Box 29503 Raleigh, N.C. 27626 Dear Mr. Brindza: October 22, 1993 Subject: General Permit No. NCG030000 Siemens Energy and Automation, Inc. COC NCG030260 Wake County 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. Sincerely, pzigielal Signed By coir,en li. Sullins A. Preston Howard, Jr., P. E. cc: Raleigh Regional Office Wake County Health Department 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 r' STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE NO. NCG030260 STORMWATER DISCHARGES NATIONAL MLLUTANTDISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawfiil standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Siemens Energy & Automation, Inc. is hereby authorized to discharge stormwater from a facility located at Siemens Energy & Automation, Inc. Siemens Road Wendell Wake County to receiving waters designated as an unnamed tributary to Buffalo Creek in the Neuse 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 October 22, 1993. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day October 22, 1993. [c3it=C� IA. Sullins A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission 0 50' 2325 Jff I 350 C U ! 100 (^�`.0 362 �/ ll'4jj`�� �- 3 r'� 2325 r l 7-� \\`�. ll ��✓ 'y - c_- /I �.'� \o Jab 00 3so L i ✓% j �� a 1, ll^ +.I : - . .La d Lick w 8h-Srh /� �y' �- I -� 3 iV � �35• • •/ � z W A34 ED Lu C 1 r �� ✓ -Len r Cem'`-' JJJJ ' ; J _. Tr@rler L% 3ao nrJ E� ��G!`•� :' �•� Paikl� �- i� / J !'1, 63a6 :,:�---` �_r.. Hep k�ah�� '• 'i\ �,+a �f� { �`� �_ `ram - \} I .� 300 /f =\1• � � � �, � �irl � �i7 3965 � � �Ii ! )vim � l` 2329 �. ,r e'r\r{%i;/:� V / /,i 116 1 V' I II_l�/�; C `� i ; f \ ( ,r `f' i•'-� �/�/o � r i _'.,�/.�•f�-�1 I / � ���� fl�(�� �\ ,I �{�J '\ .fir: �.�'_� op FOt I~ ' 9� ' Gem \ \�I r �'/� ' . • �' II \\ /'`/ i / 1 \J l ' /` a '3.3< •� •I /-J� Cam" . 1��'//�. ✓ , BAR\Jab 3964 ,+1 2501 �:: - �.: "iJ19r_' �, \ \r� � ��,� �4�t<DOP-^-� -_-R�✓ �` � � � 3az "J �, '�,�_• eag00 le 47'30" VA / L" .� .lye �/ �� •1L= -- 325r!•• ` ./ � ram,\ l � '�.1 3/ �� , \�• U ��! �1 i�C J) /I�,` • • -` r o/ I , (� --`�SOUTHER •`}1 l r \` — �J,�r 1 e 1 ! Ce }�, _ r/ f✓�-r, \L• TL� �' % - II L� I ! �` �, ��° �rhendell. l ,1� \ '•ram �. _ �',_, _ 0 �r (} r_ _=\� �� �� %'3�t.- �! :�i :i: 3963 ''' \ • tll• �_% :�`'1 �' ,�_ '_ l --�� / J1, _ ° !t%1 "'.1� '.. .., i:`1....I FAC111-14 Y ryl e Inc C, C- U N' T If LAJ AU — MA A D Go L C, 2S 30 1, YV�lo ((eC_ .e �f\ Y, E, v i llll� G S-o - r� CLAISS DISCeHe".RGE CLASS DATE j