NCG080583_NOV Response_20210309

SCHNEIDER
March 5, 2021
Via Federal Express and E-mail
[phone]
Zahid.khan(@ncdenr.gov
Mr. Zahld S. Khan
Regional Engineer, Land Quality Section
North Carolina Department of Environmental Quality
Division of Energy, Mineral and Land Resources
610 E. Center Avenue, Suite 301
Mooresville, North Carolina 28115
Ike. Notice of Violation (NO V-2021-PG0147)
Schneider National Carriers
Certificate of Coverage., NCGO80583
Mecklenburg County
Dear Mr. Khan:
By way of introduction, I am the Environmental Administrator for Schneider National Carriers, Inc., and its related
companies. We received, on February 26, 2021, your Notice of Violation letter (NOV Letter) dated as of February 23, 2021.
As a point of reference, your NOV Letter notes that the following permit condition was violated:
"l) Analytical Monitoring
The pemnittee failed to conduct monthly analytical monitoring of stormwater
discharges as required in the Tier Two response actions. [Part II, Section B]"
Please allow this letter to serve as Schneider's formal response to the NOV Letter. In your NOV letter, you identify
two items for response by Schneider, which I address below.
1) Written Explanation as to Why the Violation Occurred
Our understanding of the permit in question was that, if possible, stormwater monitoring was to be collected within
30 minutes after the onset of the commencement of the rainstorm. We were operating under a reasonable, but incorrect,
interpretation of the permit that, if we were unable to collect the sample(s) within 30 minutes (e.g., if it rained when we did not
have a trained sample collector on site), that the sample(s) should not be collected. As an additional matter, this location has
six outfalls from which stormwater would need to be collected. Given the size of the property, and the location of the outfalls,
collecting from all six outfalls within the 30 minute period posed not only timing concerns (due to distance between outfalls),
but potential safety concerns as well due to the potential of a rushed collection process. We certainly had no intention to
affirmatively violate our permit but, rather, were operating under a misinterpretation of the requirements.
On January 14, 2021, Mr. Richard Farmer, the Mecklenburg County Storm Water Inspector, arrived at our site. Due
to the importance of this matter to Schneider, I flew from Green Bay, WI to the property in order to personally meet with Mr.
Farmer. During this inspection, I, along with our maintenance coordinator, Mr. Gary Lord, spent approximately 6 hours
speaking with Mr. Farmer, discussing our stormwater sampling and our outfalls, and generally gathering best practice advice.
Additionally, during this inspection, we were able to get our prior permit misinformation corrected (e.g., around the proper
timeline of when to collect samples during storm events and how much time between storm events must elapse), and Mr.
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SCHNEIDER
Farmer indicated that we should strive to collect within the first 30 minutes but, if that is not possible, then we should collect
the samples as soon as possible thereafter. Mr. Farmer was also able to help us address some of our safety concerns with
outfall locations and sampling of those outfalls by identifying alternative options for sampling locations that would still get a
representative sample. As a result of our conversations with Mr. Farmer, we have already made — and will continue to make, as
necessary - changes to our processes to ensure safe, reliable, and timely sampling of the applicable outfalls. Moreover, in order
to ensure all of our associates who may perform the sampling have consistent information on these processes and procedures,
we intend to implement additional training (on a regular basis) and provide "Q&A" sessions for our facility coordinators
across the United States in order to help clarify, and ensure understanding of, the requirements under our stormwater permits.
2) Begin Monitoring Immediately
As indicated above, our failure to monitor stemmed from a reasonable, but incorrect, interpretation of the stormwater
permit in question. As a result of our conversation with Mr. Farmer, we can confirm that we have adjusted our processes to
monitor, and collect, samples on a monthly basis going forward in accordance with the guidance shared by Mr. Farmer. In
fact, there was a qualifying storm event in February, and subsequently, we were able to collect samples for the month of
February. As an aside, however, we would like to note that, subsequent to our meeting with Mr. Farmer, these were no
additional qualifying storm events in January. As a result, we were necessarily unable to collect any samples for the month of
January.
In conclusion, our time spent with Mr. Farmer proved invaluable, and we are certainly grateful for the information
and perspective he shared, and for the time he spent with our organization. We now have a better understanding of the
requirements of the permit and have implemented (and will continue to implement) process changes to improve and enhance
future compliance. At your convenience, Schneider would certainly welcome an opportunity to discuss this matter further with
you, and to provide any other information which you might deem relevant. To that end, please feel free to contact me at (920)
592-3928, or via email at towensendd(2schneider.com if you have any questions, concerns that I can address, or would like to
set up some time to discuss further.
On behalf of Schneider, I thank you for your time.
Best Re
eos: Derek
Environmental Administrator
4e2-8004 srzoie