NCG03 Comments from Daimler Trucks North America

Morman, Alaina
Subject: RE: [External] Comment on NCG03 Stormwater General Permit DRAFT
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Sent: Monday,June 14, 2021 2:14 PM
To: Clark, Paul <[e-mail]>
Subject: [External] Comment on NCG03 Stormwater General Permit DRAFT
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Good afternoon.
Daimler Trucks North America would like to provide a public comment regarding draft NPDES Stormwater General
Permit No. NCG030000 for Metal Fabrication.
Pertaining to Part B-12 for the draft permit, we propose that the language be updated to clearly allow training to be
tracked through electronic systems.The draft permit states, "The training shall be documented by the date, signature,
and printed or typed name of each employee trained."The requirement for signature may imply that a hand written
signature is required. We maintain records for many regulatory and skills based training requirements for each of our
thousands of employees.We have found that the most accurate and efficient way to manage these records is through
electronic databases.The quality of the training itself is not effected by the records tracking system.
We would like to offer the proposed edit for the permit language for Part B-12.
"The training shall be documented by the date, signature or digital certification, and printed or typed name of
each employee trained."
We believe that this change will allow industries to utilize the most current, accurate, and efficient systems for managing
training of their employees.
Please let me know if there is any additional information that I can provide.
Best,
Lindsey Speed Nichols, P.E.
Corporate Environmental Engineer
Cell: 704-775-6875
DAIMLER
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We thank you for your support.

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