HomeMy WebLinkAboutNCG030085_DMR_20200102 Nc600o��
DAIMLER
Sean Quarry
Sr.Environmental Engineer
Daimler Trucks
1800 North Main Street
Mount Holly,NC 28120
704.822.7034 Phone
January 17, 2020
NCDEQ- Division of Water Quality RECEIVED
Attn: Central Files FEB 0 4 202p
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 DENR-LAND QUALITY
STORMWATER PERMITTING
To whom it may concern:
Please find the enclosed January 2020 Stormwater Discharge Outfall (SDO) #001 and #002
analytical results for the Daimler Trucks NA, LLC - Mount Holly Truck Manufacturing Plant (TMP)
(NPDES General Permit No. NCG030000). The stormwater samples were collected on January 2,
2019. Results from this sampling event show no exceedances of the corresponding benchmarks.
Daimler remains in Tier 3 at SDO #001 and SDO #002 for Zinc and Copper. Shield will continue
to perform monthly sampling per Tier 2 requirements until instructed to decrease sampling
frequency by Daimler.
Should you have any questions, please contact me at 704-822-7034 or
sean.quarry@daimler.com.
Sincerely,
Daimler Trucks NA, LLC
4— ' 2'if
Sean Quarry
Sr. Environmental Engineer
Enclosures—Shield Engineering, Inc. Cover Letter and DTNA signed DMR forms
‘,„5„SHIELD
ENGINEERING, INC.
January 13,2020
Mr. Sean Quarry
Daimler Trucks North America,LLC
1800 North Main Street
Mount Holly,NC 28120
Subject: Monthly Stormwater Sampling—January 2020
NPDES General Permit No.NCG030000
Daimler Trucks of North America LLC-Mount Holly,North Carolina
Shield Project No. 1140109-06
Dear Mr. Quarry:
Shield Engineering, Inc. (Shield) successfully collected monthly stormwater samples for Stormwater Discharge
Outfalls (SDO) #001 and #002 at the Mount Holly facility for the month of January 2020. During the January
2"d sampling event, Shield's field measurements of pH were 7.01 and 6.90,respectively,at SDO#001 and SDO
#002. In addition to collection of samples, Shield performed Qualitative Monitoring at SDO#001 and #002. A
partially completed discharge monitoring report (DMR) is attached, as well as the analytical results and
Qualitative Monitoring Report forms. The person designated to act as the permittee by Daimler Trucks—Mount
Holly facility should sign all "Red" sections of the DMR. The signed DMR form should then be mailed to the
regulatory agency Central Files. Results from the January 2nd sampling event show no exceedances.
Daimler remains in Tier 3 at SDO #001 and SDO #002 for Zinc and Copper. Shield will continue to perform
monthly sampling per Tier 2 requirements until instructed to decrease sampling frequency by Daimler. Shield
greatly appreciates the opportunity to provide environmental services to Daimler Trucks,North America. If you
have any questions in reference to this document or require further information, please feel free to contact either
of the undersigned at(704)394-6913.
Respectfully,
SHIEL ENGINEERING,INC.
Magdaline Tzannis Robert L.Griffin, . .
Senior Project Manager President/CEO
elind . Greene, EIT
Senior Engineer
ATTACHMENTS
Stormwater DMR,Qualitative Monitoring Report,Analytical Results
4301 Taggart Creek Road Telephone 704.394.6913
Charlotte.NC 28208 Www.shieldengineering.com Fax 704.394.6968
Stormwater Discharge Monitoring Report
for North Carolina Division of Energy, Mineral and Land Resources General Permit No. NCG030000
Date submitted 1/13/2020
CERTIFICATE OF COVERAGE NO. NCGO3 0 0 8 5 SAMPLE COLLECTION YEAR 2020_______..__._.__
FACILITY NAME Daimler Trucks-Mount Holly SAMPLE PERIOD ❑Jan-June ❑July-Dec
COUNTY Gaston or Q Monthly' January (month)
PERSON COLLECTING SAMPLES TJ Gladden/Shield Engineering Inc DISCHARGING TO CLASS ORW I IHQW nTrout PNA
LABORATORY Shealy Env Services Inc Lab Cert.# 329 _Zero-flow 'Water Supply LSA
Comments on sample collection or analysis: *Other
There are no exceedances
PLEASE REMEMBER TO SIGN ON PAGES 2 AND/OR 3 -)
Part A: Stormwater Benchmarks and Monitoring Results
No discharge this period?2
Non-Polar O&G/
Date Sample 24-hour rainfall pH, Total Toxic
Outfall No. i Total Suspended Solids Total Copper Total Lead Total Zinc Total Petroleum
Collected amount, Standard units Organics'
(mo/dd/yr) Inches; Hydrocarbons
Benchmarks - - 100 mg/L or 50 mg/14 6.0—9.0 0.010 mg/L 0.075 mg/L 0.126 mg/L 15 mg/L 1 mg/L
Parameter Code - 46529 C0530 00400 01119 01051 01094 00552 78141
1
SDO#001 1/2/2020 0.38 2.3 7.01 0.0030 <0.0010 0.045 <5.0 N/A
SDO#002 1/2/2020 0.38 6.1 6.90 0.0021 <0.0010 0.052 <5.0 N/A
1 Monthly sampling(instead of semi-annual) must begin with the second consecutive benchmark exceedance for the same parameter at the same outfall.
2 For sampling periods with no discharge at any single outfall,you must still submit this discharge monitoring report with a checkmark here.
'The total precipitation must be recorded using data from an on-site rain gauge. Unattended sites may be eligible for a waiver of the rain gauge requirement.
'See General Permit, Section B,Table 1 to identify the especially sensitive receiving water classifications where the more protective benchmark applies.
5 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 433.11;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).
Permit Date: 11/1/2018 05/31/2021 SWU-245, last revised 11/1/2018
Page 1 of 3
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."
—3----exn—e.._ 2aS4%S-e n
Name(Print name)
in
e..r... l .M c, tia a —/
Title(Print t. ) V
l, /%')), i (02,1 2 c2 2....)Signatur Date
Note: Results must be reported in numerical format. Do not report Below Detection Limit, BDL,<PQL, Non-detect, ND,or other similar non-numerical
format. When results are below the applicable limits,they must be reported in the format,"<XX mg/I.",where XX is the numerical value of the detection
limit, reporting limit, etc. in mg/L.
Note: If you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2,or Tier 3 responses. See General Permit text.
Part B: Vehicle Maintenance Area Monitoring Results: only for facilities averaging> 55 gal of new oil per month.
— No discharge this period?2
Outfall No. Date Sample Collected.' 24-hour rainfall amount, New Motor Oil or Non-Polar O&G/Total Total Suspended
(mo/dd/yr) Inches3 Hydraulic Oil Usage Petroleum Hydrocarbons Solids
Benchmarks - - - 15 mg/L 100 mg/L or 50 mg/L4
Parameter Code - 46529 NCOIL 00552 C0530
Footnotes from Part A also apply to Part B
Note: if you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2,or Tier 3 responses. See General Permit text.
Permit Date:11/1/2018-05/31/2021 SWU-245,last revised 11/1/2018
Page 2 of 3
FOR PART A AND PART B MONITORING RESULTS:
• A BENCHMARK EXCEEDANCE TRIGGERS TIER 1 REQUIREMENTS. SEE PERMIT PART II SECTION B.
• 2 EXCEEDANCES IN A ROW FOR THE SAME PARAMETER AT THE SAME OUTFALL TRIGGER TIER 2 REQUIREMENTS. SEE PERMIT PART II SECTION B.
• TIER 3: HAS YOUR FACILITY HAD 4 OR MORE BENCHMARK EXCEEDENCES FOR THE SAME PARAMETER AT ANY ONE OUTFALL? YES ❑NO 12
IF YES,HAVE YOU CONTACTED THE DEMLR REGIONAL OFFICE? YES❑ NO❑
REGIONAL OFFICE CONTACT NAME:
Mail an original copy of this DMR,including all"No Discharge"reports, within 30 days of receipt of the lab results(or at end of monitoring period in the
case of"No Discharge"reports)to:
Division of Water Quality
Attn:DWQ Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
YOU MUST SIGN THIS CERTIFICATION FOR ANY INFORMATION REPORTED:
"1 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 signifi t penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
2\
.. /�0 //.?16/ZfJ ZJ
Signature of Permittee V Date
Permit Date:11/1/2018-05/31/2021 SWU-245,last revised 11/1/2018
Page 3 of 3
4131.,- SHIELD
ENGINEERING, INC.
January 22,2020
Mr. Sean Quarry
Daimler Trucks North America, LLC
1800 North Main Street
Mount Holly,NC 28120
Subject: Annual Update Summary-2019
NPDES General Permit No.NCG030000
Daimler Trucks of North America LLC-Mount Holly,North Carolina
Shield Project No. 1140130-02
Dear Mr. Quarry:
Shield Engineering, Inc. (Shield) has conducted an Annual Update Summary for 2019 for the
Stormwater Pollution Prevention Plan (SPPP) at the request of Daimler Trucks North America LLC for
its facility located at 1800 North Main Street, Mount Holly, North Carolina. The Annual Update
Summary for 2019 is attached to this cover letter and should be maintained at the facility, as part of the
SPPP, Appendix G.
If you have any questions regarding this report, please contact us at(704) 394-6913.
Respectfully,
SHIELD ENGINEERING,INC.
Magdaline Tzannis Robert L. Griffin, P. •.
Senior Project Manager President/CEO
Melind M. reene, EIT
Senior neer
ATTACHMENTS
Annual Update Summary,Non-Stormwater Discharge Assessment and Certification, Annual Summary
Data Monitoring Report, Compliance Tracking Worksheet
4301 Taggart Creek Road Telephone 704.394.6913
Charlotte,NC 28208 www.shieldengineering.com Fax 704.394.6968
March 18 26 I9 Stormwater Pollution Prevention Plan
Daimler Trucks North America,LLC-Mt.Holly Truck Manufacturing Plant
Paye , 1800 North Main Street,Mt.Holly,North Carolina
Annual Update Summary—2019
Prepared by Shield Engineering, Inc.
It will be the responsibility of Daimler Trucks North America, LLC to amend the Stormwater
Pollution Prevention Plan (SPPP) whenever there is a change in design, construction, operation,
site drainage, maintenance, or configuration of the physical features which may have a
significant effect on potential for the discharge of pollutants to surface waters. All aspects of
the SPPP shall be reviewed and updated as needed on an annual basis.
The current SPPP was reviewed and referenced in the preparation of this SPPP update. The
following reviews were made to this SPPP for Daimler Trucks North America, LLC—Mt. Holly
Truck Plant:
• The Site Map has been updated to reflect current operations without affecting the
narrative description of the SPPP.
• The NCDEQ Integrated Reports (2018) have been reviewed for changes to
impairment listing for the Catawba River. No new TMDLs have been developed.
• Daimler has updated the list of spills and leaks(for the previous 3 years).
• Shield along with Daimler evaluated the stormwater outfalls and a re-certification
for the presence of non-stormwater discharges is attached.
• The effectiveness of on-site stormwater best management practices was evaluated
during a site visit.
• Employee Training records were reviewed and indicate annual training
requirements were met.
• An updated compliance tracking worksheet has been attached, along with the
Annual Summary Data Monitoring Report Form for 2019.
Non-Storm Water Discharge Assessment and Certification
Daimler Trucks NA—Mt. Holly Truck Manufacturing Plant
Mt. Holly, NC
Date of Test or Outfall Directly Observed Method Used to Test or Describe Results from Test for Identify Potential Name of Person Who
Evaluation During the Test(identify as Evaluate Discharge the Presence of Non-Storm Significant Conducted Test or
indicated on the site map) Water Discharge Sources Evaluation
1/20/2020 001 Visual Observation None observed(discharge NA Shield Engineering
from Halo Wash (M. Tzannis) and
authorized by State). DTNA(Sean
002 Visual Observation None observed NA Quarry)
Certification
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, thb information
submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for knowing violations.
A. Name(Type or Print) Magdaline Tzannis B. Title Senior Project Manager
C. Signature D. Date Signed 1/20/2020
s
STORMWATER DISCHARGE OUTFALL (SDO)
ANNUAL SUMMARY DATA MONITORING REPORT (DMR) I SPPP Annual Update DATA REVIEW FORM
Calendar Year 2019
Individual NPDES Permit No. NCS_ or
Certificate of Coverage (COC) No. NCG 030085
This monitoring report summary of the calendar year should be kept on file on-site with the facility SPPP.
Facility Name: Daimler Trucks of North America LLC — Mount Holly Facility
County: Gaston
Phone Number: ( ) Total no. of SDOs monitored 2
Outfall No. 01
Is this outfall currently in Tier 2 (monitored monthly)? Yes ❑x No ❑
Was this outfall ever in Tier 2 (monitored monthly) during the past year? Yes El No ❑
If this outfall was in Tier 2 last year, why was monthly monitoring discontinued?
Enough consecutive samples below benchmarks to decrease frequency I
Received approval from DWQ to reduce monitoring frequency ❑
Other ❑
Was this SDO monitored because of vehicle maintenance activities? Yes ❑ No 0
Parameter, (units)
Total i Non-Polar
pH TSS Copper Lead Zinc TTO
Rainfall, 08.GffPH
inches (S.U.) (mg/I) (mg/I) (mg/I) (mg/I) (mg/I) (mg/I)
Benchmark N/A 6.0-9.0 100 15 0.010 0.075 0.126 1
Date Sample
Collected,
mm/dd/yy
01/23/19 0.1 8.35 81 14 0.010 0.028 0.230 N/A
02/27/19 0.1 8.35 26 4.8 1 0.0065 0.0013 0.140 N/A
03/08/19 0.5 8.47 71 7.6 0.011 0.0025 0.330 N/A
04/12/19 1.0 7.2 38 5.9 0- .0083 0.002 0.180 N/A
06/12/19 1.26 8.2 19 3.9 0- .0058 0.0011 f 0.230 N/A
07/23/19 0.25 7.5 6.7 2.0 0- .0061 0.00030 0.092 N/A
SWU-264 -Generic Annual DMR
SDO 001 continued
Parameter, (units)
Total Non-Polar
Rainfall, pH TSS Copper Lead Zinc TTO
(S.U.) (mg/I) 0 H (mg/l) (mg/I) (mg/I) (mg/I)
inches (mg/I)mg/I)
Benchmark N/A 6.0-9.0 100 15 0.007 0.030 0.067 1.0 _
Date Sample
Collected,
mm/dd/yy
08/27/19 0.05 8.0 13 3.6 0.0029 0.00026 0.093 N/A
11/12/19 0.54 7.76 24 2.1 0.005 0.0012 0.160 N/A
12/17/19 0.28 6.00 11 1.7 0.0028 0.00044 0.068 N/A
I
COMMENTS:
No flow and/or no qualifying storm event during the months of May, September and October.
SWU-264 - Generic Annual DMR
Additional Outfall Attachment
Outfall No. 292
Is this outfall currently in Tier 2 (monitored monthly)? Yes E No E
Was this outfall ever in Tier 2 (monitored monthly) during the past year? Yes x❑ No ❑
If this outfall was in Tier 2 last year, why was monthly monitoring discontinued?
Enough consecutive samples below benchmarks to decrease frequency [l
Received approval from DWQ to reduce monitoring frequency LI
Other ❑
Was this SDO monitored because of vehicle maintenance activities? Yes ❑ No ❑x
Parameter, (units)
Total Non-Polar
Rainfall, pH TSS Copper Lead Zinc TTO
inches (S.U.) (mg/I)inches )H (mg/I) (mg/I) (mg/I) (mg/I)
Benchmark N/A 6.0-9.0 100 15 0.010 0.075 0.126 1
Date Sample
Collected,
mm/dd/yy
01/23/19 0.1 7.93 120 <4.4 0.013 0.032 0.170 N/A
02/27/19 0.1 8.16 39 <5.0 0.0065 0.0023 0.100 N/A
03/08/19 0.5 8.45 41 2.8 0.013 0.0027 0.160 N/A
04/12/19 1.0 7.6 140 4.5 0.024 0.006 0.220 N/A
06/12/19 1.26 7.8 46 3.9 0.0083 0.0026 0.180 N/A
07/23/19 0.25 7.6 40 15 0.0076 0.0017 0.074 N/A
08/27/19 0.05 8.5 12 <5.1 0.0024 0.00035 0.028 N/A
11/12/19 0.54 8.01 21 2.0 0.0058 0.0012 0.120 N/A
12/17/19 0.28 6.20 21 16 0.0057 0.0011 0.099 N/A
COMMENTS:
No flow and/or no qualifying storm event during the months of May, September and October.
SWU-264 -Generic Annual DMR
"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 possibility of fines and imprisonment for knowing violations."
Signature
Date
For questions, contact your local Regional Office:
DWQ Regional Office Contact Information:
. 4i "
•
• 'elite Sit )
N'. •Ia.
•
ASHEVILLE REGIONAL OFFICE FAYETTEVILLE REGIONAL OFFICE MOORESVILLE REGIONAL OFFICE
2090 US Highway 70 225 Green Street 610 East Center Avenue/Suite 301
Swannanoa,NC 28778 Systel Building Suite 714 Mooresville,NC 28115
(828)296-4500 Fayetteville,NC 28301-5043 (704)663-1699
(910)433-3300
RALEIGH REGIONAL OFFICE WASHINGTON REGIONAL OFFICE WILMINGTON REGIONAL OFFICE
3800 Barrett Drive 943 Washington Square Mall 127 Cardinal Drive Extension
Raleigh,NC 27609 Washington,NC 27889 Wilmington,NC 28405-2845
(919)791-4200 (252) 946-6481 (910) 796-7215
WINSTON-SALEM REGIONAL OFFICE CENTRAL OFFICE
585 Waughtown Street 1617 Mail Service Center ,�� "To preserve,protect
Winston-Salem,NC 27107 Raleigh,NC 27699-1617 '1!!I,.(M and enhance
(336) 771-5000 (919) 807-6300 North Carolina's water-.•
SWU-264-Generic Annual DMR
Dbdsage Characteristics to be Tested Discharge Characteristics to be Tested
Non polar Oil& Non-polar 00&
MOUNT HOLLY FACILITY Total Grease/TPH Copper,Total Lead,Total Zinc,Total Total Toxic Total Grease/TPH Copper,Total Lead,Total Zinc,Total Total Toxic
PH Suspended EPA Method Recoverable Recoverable Recoverable Organics(TTO) pH Suspended EPA Method Recoverable Recoverable Recoverable Organics(TTO)
Solids(mg/t) 1664(SGT-HEM) (mg/L) (mg/L) (mg/L) (mg/L) Solids(mg/L) 1664(SIT-HEM) (mg/L) (melt) (mg/L) OVA)
(mg/t) (mg/Ll
Sample Date Outten LIMIT 6-9 100 15 0.007 0-030 0.067 1 Semple Date Oil UMIT 6-9 /00 15 0.007 0.030 0.067 1
Monthly SDO Monthly SDO
(January �) 8 15 81(71) 14 0 010 0 028 0 23 NA' (January 2019) 7 93 120 <4 4 0 013 0 032 0 17 NA•
Monthly SDO Manthry SDO
(February 2019) 001 8 35 26 4 8 0 0065 0 0013 0 14 hA' (February 2019) 002 816 39 45.0 0 0065 0 0023 0 100 NA'
Monthly SDO Monttdy SDO
(March 2019) 001 847 71 7.6 0.011 0 0025 033 NA. ( itch2019) 002 8.45 41 28 0013 00027 0160 N6•
Monthly
SDO
SDO
(April 2019) 0017.2 38 5 9 0.001 0 18 NA' (April20 7.6 140 4 5 0.024 0 006 0 220 NA'
Monthly SDO No Quail Monthly Sao
(May 2019) 001 fying Event No Qualifying Event
(May 2019) 002
Monthly SDO 001 SDO
8.2 19 3 9 0 0058 0 0011 0 23 NA• (1M ) 7 8 46 3 9 0 0083 0 0026 0 18 6A•
(lune 2019)w 002
ay Monthly9) SDO
7 5 6 7 2 0 0.0061 0 00030 0.D92 NA• 'Monthly hay ) 7 6 40 1 5 0 0076 0 D017 0.074 NA.
002
(Au 20h19) SDO
8 00 13 3 6 0 0029 0 00026 0 091 NA• (Aug Monthly SDO ust9) 8 5 12 <5 1 0 0024 0 00035 0 028 NA.
gust 002
Monthly SDO Monthly SDO
(Sept 2019) 001 (Sept 2019) 002
---- No Qualifying Event No Qualifying l vent
Monthly SDO Monthly SDO
(Oct 2019) 001 (Oct2019) 002
(NovemberMonth��) �O 7 76 24 2 1 0 005 0.0012 0 160 NA' (Novetmber 2019)onthly �2 8 01 21 2.0 0 0058 0 0612 0.120 NA"
SDO
SDO
(11echlmberg2019) 0016 11 1 7 0 0028 0 00044 0.068 NA. (p�Mm 2019) 6.2 21 1 6 0 0057 0 0011 0 099 NA'
Discharge Charectertuiu to be Test. Discharge Characteristics to be Tested
Sao*le Date Oudall Ulan 6-9 100 15 0.010 0.075 0.126 1 Sample Dena Outfit! UNIT 6-9 100 15 0.010 0.075 0.126 1
Non-polar C.I& Non-polar C:I&
Total Grease/TPH Copper,Total Lead,Total Zinc,Tota'i Iota Toxic Benchmarks changed Total Grease/TPH Copper,local Lead,Total Zinc,Total Total Toxic
PH Suspended EPA Method Recoverable Recoverable Recoverable Organics(TTC) 11/2018 pH Suspended EPA Method Recoverable Recoverable Recoverable Organics(TTO)
Solids(rng/l) 1664(SGT-HEM) Ime/L) (rrre/L) Img/LI (rnJJLl Solids(me/LI 1664(SOT-HEM) (me/ll Img/t) (mg/LI (m6/t)
(me.) (mg/L)
•Not applicable due to the presence of solvent management plan
Tiers: Tier 1-1 exceedanre
Tier 2•2 consecutive exceedances;monthly monitoring all parameters until 3 consecutive samples below benchmark
Tier 3-1 exceedances over permit lifetime