NCG030308_CEI_20201030

ROY COOPER
Governor
MICHAEL S. REGAN`
Secretary
BRIAN WRENN
Director
NORTH CAROLINA
Environmental Quality
October 30, 2020
Godwin Manufacturing Co., Inc.
Attn: Ryan Taylor, CEO
PO Box 1147
Dunn, NC 28335
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG030000
Godwin Mfg Co, Certificate of Coverage NCG030308
Harnett County
Dear Mr. Taylor:
On October 29, 2020, Michael Lawyer, Environmental Program Consultant, and Penny Markle, Environmental Specialist,
with the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DENMLR) conducted a site
inspection for the Godwin Mfg Co facility located at 17666 US Highway 421 South, Dunn, Harnett County, North Carolina.
A copy of the Compliance Inspection Report is enclosed for your review. Ms. Cathy Jackson, Executive Assistant, was also
present during the inspection and her time and assistance is greatly appreciated. The site visit and file review revealed that
the subject facility is covered by NPDES Stormwater General Permit NCG030000 under Certificate of Coverage
NCG030308. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as
Mingo Swamp, class C;Sw waters in the Cape Fear River Basin.
As a result of the inspection, the facility was found to be compliant with the conditions of the NCG030000 permit. Please
refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or via e-mail at
mike. [e-mail].
Sincerely,
.�T
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure: Compliance Inspection Report
ec: Cathy Jackson, Executive Assistant — Godwin Manufacturing Co., Inc.
Chris Ward, Plant Manager — Godwin Manufacturing Co., Inc.
cc: FRO — DEMLR, Stormwater Files
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Q E Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
Q;-I/
NOFrr.i r..aa �Nn
oaaemacmrmaoMrem�uuni� ,'r""� 910.433.3300

Compliance Inspection Report
Permit: NCG030308 Effective: 11/01/18 Expiration: 05/31/21 Owner: Godwin Mfg Co
SOC: Effective: Expiration: Facility: Godwin Mfg Co
County: Harnett 17666 US Hwy 421 S
Region: Fayetteville
Dunn NC 28334
Contact Person: Chris Ward Title: Plant Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Cathy Jackson 910-591-5202
Related Permits:
Inspection Date: 10/29/2020 Entry Time 10:05AM Exit Time: 01:15PM
Primary Inspector: Mike Lawyer Phone: [phone]
Secondary Inspector(s):
Penny Markle?A/\
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: E Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG030308 Owner- Facility: Godwin Mfg Co
Inspection Date: 10/29/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Reviewed the facility's Stormwater Pollution Prevention Plan (SPPP), which appeared to contain all necessary components
and associated documentation pertaining to the annual review and update requirements. A written Solvent Management Plan
could be incorporated into the SPPP to waive the TTO monitoring requirement Monitoring records from 2017 through 2020
for two stormwater discharge outfalls that had been identified by the facility were reviewed. There have been occasional,
non-consecutive exceedances of the benchmark values for Copper and Zinc and one exceedance of the benchmark value foi
TSS. During site observations, three additional stormwater discharge outfalls were identified. The additional outfalls and
direction of flow need be added to the site map and the outfalls need to be monitored per the conditions of the permit. It was
relayed by the inspectors that two of the additional outfalls, which are located near outfall #1 could potentially be covered
under Representative Outfall Status (ROS) being granted for outfall #1. A copy of the ROS Request Form will be included
with the inspection report. Secondary containment is provided for ASTs, however it appeared that the drain valve for one of
the containment structures did not have a locking mechanism. At the time of inspection, facility grounds appeared to be well
maintained.
Page 2of3

Permit: NCG030308 Owner- Facility: Godwin Mfg Co
Inspection Date: 10/29/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
E ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0 ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
N ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
E ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
N ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
N ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? N ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑'E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? KEI ❑ ❑
Comment:
Page 3 of 3