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Home My WebLink AboutNCG030039_Monitoring Report_20211105SHIELD ENGINEERING November 2, 2021 Zahid Khan Regional Engineer, Land Quality Section Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, North Carolina 28115 Zahid.Khan@ncdenr.gov Subject: Tier Three Action Plan, Third Quarter 2021 Daimler Trucks North America, LLC — Cleveland Truck Plant Certificate of Coverage NCG030039 Dear Mr. Khan, On behalf of Daimler Trucks North America, LLC (DTNA) — Cleveland Truck Plant, Shield Engineering, Inc. has prepared and is submitting the attached Tier Three Action for your approval in accordance with NPDES Industrial Stormwater Permit NCG030000, Part E for Third Quarter, 2021. The cover page of the report contains the required certification by DTNA-Cleveland's responsible official. If you have any questions regarding this Action Plan, please contact us at (704) 394-6913 or Colin Buchanan with DTNA-Cleveland at colin.buchanan@daimler.com. Sincerely, SHIELD ENGINEERING, INC. Melinda ndreene Senior Engineer Magdaline M. Tzannis Senior Project Manager ATTACHMENTS cc: Colin Buchanan, DTNA-Cleveland James Moore, NCDEQ Mooresville Robert L. G PE • • 4301 Taggart Creek Road www.shieldeneineering.com Telephone 704.394.6913 Charlotte, NC 28208 License No. F-0856 DAIMLER DAIMLER TRUCKS NORTH AMERICA Cleveland Truck Plant 11550 Statesville Boulevard Cleveland, North Carolina Certificate of Coverage NCG030039 Tier Three Action Plan, Third Quarter 2021 In compliance with General SW Permit NCG030000, Part E-7 Prepared by: SHIELD ENGINEERING 4301 Taggart Creek Road Charlotte, NC 28208 Shield Project No. 1140109-08 November 2, 2021 l certify by my signature below, 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. Erik Johnson Date DTNA — Cleveland Daimler Trucks North America, LLC - Cleveland Page 1 Tier Three Response Action Plan November 2, 2021 Facility Daimler Trucks — Cleveland NCG030039 SDO 002 Parameters Copper, Zinc Date Prepared 11/02/2021 This Action Plan has been prepared in accordance with Part E-7(b) of General Permit for benchmark exceedances which have triggered Tier Three Response. Tier Three status for Copper and Zinc at Ouffall 002 have carried over from the previous General Permit. This Action Plan was developed to address Copper and Zinc Tier 3 Response at Outfall 002. ACTION PLAN ELEMENTS The General Permit, Part E-7(b), requires specific elements be addressed. Each of these elements are being addressed as follows: i. Documentation of the Four Benchmark Exceedances The tables below document the last four benchmark exceedances for Zinc and Copper at Outfall 002 for Daimler Trucks — Cleveland. Copper benchmark = 0.010 mg/I Outfall Month 9/2021 5/2021 1/2021 9/2020 002 0.015 0.011 0.014 0.017 Zinc benchmark = 0.126 mg/I Outfall Month 9/2021 5/2021 3/2021 2/2021 002 0.200 0.180 0.130 0.190 H. An Inspection report that covers the industrial activities within the drainage area of the outfall with the exceedances (including the date of the inspection and the personnel conducting the inspection) See attached inspection report. The inspection covered all areas of industrial activity in the drainage areas that drain Outfall 002. Typical industrial activities that occur in this drainage area include heavy vehicle movement, storage and parking, partial main building roof, 400 Paint building & Off Line building roofs, bulk chemical storage, Offline Paint, Dyno, leak testing, receiving docks, fire pump house, used oil tanks, Central Accumulation Area (hazardous waste), parts loading and unloading. The inspection report notes areas of concern observed as having the potential to contribute to benchmark exceedances. A site map is attached for reference of the drainage area. Daimler Trucks North America, LLC - Cleveland Page 2 Tier Three Response Action Plan November 2, 2021 iii. An evaluation of standard operating procedures and good housekeeping procedures Daimler Cleveland has evaluated its standard operating procedures applicable to the potential for pollutants to reach stormwater as well as its good housekeeping procedures related to industrial activities in the drainage area for SDO 002. Any recommendations for improvements in these activities are described in the attached inspection report or in (v) below. iv. Identification of the source(s) of exceedances Daimler Trucks - Cleveland has identified sources it believes may be contributing to the exceedances. The following causes have a high potential to effect Zinc and Copper concentrations in stormwater discharged from Outfall 002 and contribute to benchmark exceedances: Potential Cause of Location(s) Potential Outfall(s) Benchmark Exceedance Pollutant Affected Motor Oil and Hydraulic Loading Areas and Zinc 002 Fluid throughout the Facility Outdoor Asphalt Pavement Cumulative Effect from Tire Loading Areas and Zinc 002 Dust and Debris Outdoor Asphalt Pavement Cumulative Effect from Outdoor Asphalt Copper 002 Vehicle Brake Pad Pavement Deposits v. Specific actions that will be taken to remedy the identified source(s) with a schedule for completing those actions ACTIONS SELECTED FOR IMPLEMENTATION BY SITE SCHEDULE FOR COMPLETION 1. Review Preventive Maintenance procedure for This will be completed inspecting and cleaning stormwater drains. internally, by 11 /19/2021. 2. Create, if needed, a visual guidance for rating high Inspection reports for drains risk stormwater drain filters/cartridges to assist with will be reviewed to determine determination of appropriate replacement frequency appropriate replacement of the high -risk stormwater drain filters/cartridges. frequency of the high -risk stormwater drain filters/cartridges. 3. Engage contractor to sweep site (in-house sweeper is A contractor will be contacted in need of repair and replacement part is on back by 11/30/2021 to provide order). costs and availability for 4. Implement routine sweeping. sweeping SDO 002, every 2 weeks. Sweeping will commence late November or early December 2021.' 1 The dates provided are target dates and may change due to reasons beyond Daimler's control such as contractor's availability (sweeper). Daimler Trucks North America, LLC - Cleveland Page 3 Tier Three Response Action Plan November 2, 2021 iii. An evaluation of standard operating procedures and good housekeeping procedures Daimler Cleveland has evaluated its standard operating procedures applicable to the potential for pollutants to reach stormwater as well as its good housekeeping procedures related to industrial activities in the drainage area for SDO 002. Any recommendations for improvements in these activities are described in the attached inspection report or in (v) below. iv. Identification of the source(s) of exceedances Daimler Trucks - Cleveland has identified sources it believes may be contributing to the exceedances. The following causes have a high potential to effect Zinc and Copper concentrations in stormwater discharged from Outfall 002 and contribute to benchmark exceedances: Potential Cause of Location(s) Potential Outfall(s) Benchmark Exceedance Pollutant Affected Motor Oil and Hydraulic Loading Areas and Zinc 002 Fluid throughout the Facility Outdoor Asphalt Pavement Cumulative Effect from Tire Loading Areas and Zinc 002 Dust and Debris Outdoor Asphalt Pavement Cumulative Effect from Outdoor Asphalt Copper 002 Vehicle Brake Pad Pavement Deposits v. Specific actions that will be taken to remedy the identified source(s) with a schedule for completing those actions ACTIONS SELECTED FOR IMPLEMENTATION BY SITE SCHEDULE FOR COMPLETION 1. Review Preventive Maintenance procedure for This will be completed inspecting and cleaning stormwater drains. internally, by 11/19/2021. 2. Create, if needed, a visual guidance for rating high Inspection reports for drains risk stormwater drain filters/cartridges to assist with will be reviewed to determine determination of appropriate replacement frequency appropriate replacement of the high -risk stormwater drain filters/cartridges. frequency of the high -risk stormwater drain filters/cartridges. 3. Engage contractor to sweep site (in-house sweeper is A contractor will be contacted in need of repair and replacement part is on back by 11 /30/2021 to provide order). costs and availability for 4. Implement routine sweeping. sweeping SDO 002, every 2 weeks. Sweeping will commence late November or early December 2021.' 1 The dates provided are target dates and may change due to reasons beyond Daimler's control such as contractor's availability (sweeper). Daimler Trucks North America, LLC - Cleveland Page 4 Tier Three Response Action Plan November 2, 2021 vi. A monitoring plan to verify that the Action Plan has addressed the source(s). Daimler Trucks - Cleveland will attempt to sample SDO 002 at least monthly until three consecutive samples for Zinc and Copper are below the benchmark value. In the event a sample cannot be collected during a month, record documentation as to why a sample could not be collected. Daimler Trucks — Cleveland will continue routine facility inspections to ensure the effectiveness of the implemented actions and identify any new potential causes or contributors to the benchmark exceedances. ATTACHMENTS: Stormwater Management Inspection (Copper and Zinc, Outfall 002) Site Map Stormwater Management Inspection Report (Tier Response) Facility DAIMLER TRUCKS — CLEVELAND Parameter Exceedance Copper SDO 002 Date of Sample 9/16/2021 Date Received from Lab 9/30/2021 Date NC DEQ Notified 10/19/2021 Notification Method Email Benchmark 0.010 m /I Lab Result 0.015 m /I Date/Time of SW Inspection 10/11/2021 Weather during Inspection Clear, 65" 11:52am —1:00 m Inspector(s) C Buchanan Daimler CLE Areas Inspected Drainage Area for SDO where industrial activity occurs: See attached map. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS* High Risk INLET DRAINS These drains have been identified as high 1. Review PM for inspecting stormwater impact drains. While the drains currently house drains and ensure rating system has (see attached site map) framed cartridge inserts, the cartridges may metrics for cartridge replacement. need more frequent replacement. Tire and brake 2. Evaluate replacement frequency of dust from movement of vehicles is likely to each drain insert on an individual basis. contribute to high metals concentrations in this 3. Replace cartridges as needed. drainage area. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS GENERAL HOUSEKEEPING Asphalt areas need sweeping. In-house 1. Engage contract sweeper and schedule sweeper needs repair and replacement part is routine sweeping until in-house on backorder. sweeper is repaired. 2. Encourage good housekeeping as a part of a daily and/or weekly routine. *Source controls, operational controls or physical improvements Facility DAIMLER TRUCKS — CLEVELAND Parameter Exceedance Zinc SDO 002 Date of Sample 9/16/2021 Date Received from Lab 9/30/2021 Date NC DEQ Notified 10/19/2021 Notification Method Email Benchmark 0.126 m /I Lab Result 0.200 m /I Date/Time of SW Inspection 10/11/2021 Weather during Inspection Clear, 65° 11:52am —1:00 m Inspector(s) C Buchanan Daimler CLE Areas Inspected Drainage Area for SDO where industrial activity occurs: See attached map. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS* High Risk INLET DRAINS These drains have been identified as high 1. Review PM for inspecting stormwater impact drains. While the drains currently drains and ensure rating system has (see attached site map) house framed cartridge inserts, the metrics for cartridge replacement. cartridges may need more frequent 2. Evaluate replacement frequency of replacement. Tire and brake dust from each drain insert on an individual basis. movement of vehicles is likely to contribute 3. Replace cartridges as needed. to high metals concentrations in this drainage area. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS GENERAL HOUSEKEEPING Asphalt areas need sweeping. In-house 1. Engage contract sweeper and schedule sweeper needs repair and replacement part routine sweeping until in-house is on backorder. sweeper is repaired. 2. Encourage good housekeeping as a part of a daily and/or weekly routine. *Source controls, operational controls or physical improvements b '00£=a l (1333 NO Leis rl-rls. 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The cover page of the report contains the required certification by DTNA-Cleveland's responsible official. If you have any questions regarding this Action Plan, please contact us at (704) 394-6913 or Colin Buchanan with DTNA-Cleveland at colin.buchanan@daimler.com. Sincerely, SHIELD ENGINEERING, INC. Melinda nreene Senior Engineer Magdaline M. Tzannis Senior Project Manager ATTACHMENTS cc: Colin Buchanan, DTNA-Cleveland James Moore, NCDEQ Mooresville Robert L+GnPE President/CEO 4301 Taggart Creek Road www.shieldengineering.com Telephone 704.394.6913 Charlotte, NC 28208 License No. F-0856 DAIMLER DAIMLER TRUCKS NORTH AMERICA Cleveland Truck Plant 11550 Statesville Boulevard Cleveland, North Carolina Certificate of Coverage NCG030039 Tier Three Action Plan, Third Quarter 2021 In compliance with General SW Permit NCG030000, Part E-7 Prepared by: SHIELD ENGINEERING 4301 Taggart Creek Road Charlotte, NC 28208 Shield Project No. 1140109-08 November 2, 2021 I certify by my signature below, 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. Erik Johnson Date DTNA — Cleveland Daimler Trucks North America, LLC - Cleveland Page 1 Tier Three Response Action Plan November 2. 2021 Facility Daimler Trucks —Cleveland NCG030039 SDO 002 Parameters Copper Zinc Date Prepared 11/02/2021 INTRODUCTION This Action Plan has been prepared in accordance with Part E-7(b) of General Permit for benchmark exceedances which have triggered Tier Three Response. Tier Three status for Copper and Zinc at Outfall 002 have carried over from the previous General Permit. This Action Plan was developed to address Copper and Zinc Tier 3 Response at Outfall 002. ACTION PLAN ELEMENTS The General Permit, Part E-7(b), requires specific elements be addressed. Each of these elements are being addressed as follows: i. Documentation of the Four Benchmark Exceedances The tables below document the last four benchmark exceedances for Zinc and Copper at Outfall 002 for Daimler Trucks — Cleveland. Copper benchmark = 0.010 mg/I Outfall Month 1 9/2021 5/2021 1/2021 9/2020 002 0.015 0.011 0.014 0.017 Zinc benchmark = 0.126 mg/I Outfall Month 9/2021 5/2021 3/2021 2/2021 002 1 0.200 0.180 0.130 0.190 H. An Inspection report that covers the industrial activities within the drainage area of the outfall with the exceedances (including the date of the inspection and the personnel conducting the inspection) See attached inspection report. The inspection covered all areas of industrial activity in the drainage areas that drain Outfall 002. Typical industrial activities that occur in this drainage area include heavy vehicle movement, storage and parking, partial main building roof, 400 Paint building & Off Line building roofs, bulk chemical storage, Offline Paint, Dyno, leak testing, receiving docks, fire pump house, used oil tanks, Central Accumulation Area (hazardous waste), parts loading and unloading. The inspection report notes areas of concern observed as having the potential to contribute to benchmark exceedances. A site map is attached for reference of the drainage area. Daimler Trucks North America, LLC - Cleveland Page 2 Tier Three Response Action Plan November 2.2021 iii. An evaluation of standard operating procedures and good housekeeping procedures Daimler Cleveland has evaluated its standard operating procedures applicable to the potential for pollutants to reach stormwater as well as its good housekeeping procedures related to industrial activities in the drainage area for SDO 002. Any recommendations for improvements in these activities are described in the attached inspection report or in (v) below. iv. Identification of the source(s) of exceedances Daimler Trucks - Cleveland has identified sources it believes may be contributing to the exceedances. The following causes have a high potential to effect Zinc and Copper concentrations in stormwater discharged from Outfall 002 and contribute to benchmark exceedances: Potential Cause of Location(s) Potential Outfall(s) Benchmark Exceedance Pollutant Affected Motor Oil and Hydraulic Loading Areas and Zinc 002 Fluid throughout the Facility Outdoor Asphalt Pavement Cumulative Effect from Tire Loading Areas and Zinc 002 Dust and Debris Outdoor Asphalt Pavement Cumulative Effect from Outdoor Asphalt Copper 002 Vehicle Brake Pad Pavement Deposits v. Specific actions that will be taken to remedy the identified source(s) with a schedule for completing those actions ACTIONS SELECTED FOR IMPLEMENTATION BY SITE SCHEDULE FOR COMPLETION 1. Review Preventive Maintenance procedure for This will be completed inspecting and cleaning stormwater drains. internally, by 11/19/2021. 2. Create, if needed, a visual guidance for rating high Inspection reports for drains risk stormwater drain filters/cartridges to assist with will be reviewed to determine determination of appropriate replacement frequency appropriate replacement of the high -risk stormwater drain filters/cartridges. frequency of the high -risk stormwater drain filters/cartridges. 3. Engage contractor to sweep site (in-house sweeper is A contractor will be contacted in need of repair and replacement part is on back by 11 /30/2021 to provide order). costs and availability for 4. Implement routine sweeping. sweeping SDO 002, every 2 weeks. Sweeping will commence late November or early December 2021.' r _ J- — .:J nl,e.n- e/..n fn rnacnna hnunnrt n2imlaec rnntml curt, aS rnntmenes availability (sweeper). Daimler Trucks North America, LLC - Cleveland Page 3 Tier Three Response Action Plan November 2.2021 iii. An evaluation of standard operating procedures and good housekeeping procedures Daimler Cleveland has evaluated its standard operating procedures applicable to the potential for pollutants to reach stormwater as well as its good housekeeping procedures related to industrial activities in the drainage area for SDO 002. Any recommendations for improvements in these activities are described in the attached inspection report or in (v) below. iv. Identification of the source(s) of exceedances Daimler Trucks - Cleveland has identified sources it believes may be contributing to the exceedances. The following causes have a high potential to effect Zinc and Copper concentrations in stormwater discharged from Outfall 002 and contribute to benchmark exceedances: Potential Cause of Location(s) Potential Outfall(s) Benchmark Exceedance Pollutant Affected Motor Oil and Hydraulic Loading Areas and Zinc 002 Fluid throughout the Facility Outdoor Asphalt Pavement Cumulative Effect from Tire Loading Areas and Zinc 002 Dust and Debris Outdoor Asphalt Pavement Cumulative Effect from Outdoor Asphalt Copper 002 Vehicle Brake Pad Pavement Deposits v. Specific actions that will be taken to remedy the identified source(s) with a schedule for completing those actions ACTIONS SELECTED FOR IMPLEMENTATION BY SITE SCHEDULE FOR COMPLETION 1. Review Preventive Maintenance procedure for This will be completed inspecting and cleaning stormwater drains. internally, by 11/19/2021. 2. Create, if needed, a visual guidance for rating high Inspection reports for drains risk stormwater drain filters/cartridges to assist with will be reviewed to determine determination of appropriate replacement frequency appropriate replacement of the high -risk stormwater drain filters/cartridges. frequency of the high -risk stormwater drain filters/cartridges. 3. Engage contractor to sweep site (in-house sweeper is A contractor will be contacted in need of repair and replacement part is on back by 11 /30/2021 to provide order). costs and availability for 4. Implement routine sweeping. sweeping SDO 002, every 2 weeks. Sweeping will commence late November or early December 2021.1 The dates provided are target dates and may change due to reasons beyond Daimler's control sucn as contractors avanaoany (sweeper). Daimler Trucks North America, LLC - Cleveland Page 4 Tier Three Response Action Plan November 2, 2021 vi. A monitoring plan to verify that the Action Plan has addressed the source(s). Daimler Trucks - Cleveland will attempt to sample SDO 002 at least monthly until three consecutive samples for Zinc and Copper are below the benchmark value. In the event a sample cannot be collected during a month, record documentation as to why a sample could not be collected. Daimler Trucks — Cleveland will continue routine facility inspections to ensure the effectiveness of the implemented actions and identify any new potential causes or contributors to the benchmark exceedances. ATTACHMENTS: Stormwater Management Inspection (Copper and Zinc, Outfall 002) Site Map Stormwater Management Inspection Report (Tier Response) Facility DAIMLER TRUCKS — CLEVELAND Parameter Exceedance Copper SDO 002 Date of Sample 9/16/2021 Date Received from Lab 9/30/2021 Date NC DEQ Notified 10/19/2021 Notification Method Email Benchmark 0.010 m /I Lab Result 0.015 mg/1 Date/Time of SW Inspection 10/11/2021 Weather during Inspection Clear, 650 11:52am —1:00 m Inspector(s) C Buchanan Daimler CLE Areas Inspected Drainage Area for SDO where industrial activity occurs: See attached map. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS* High Risk INLET DRAINS These drains have been identified as high 1. Review PM for inspecting stormwater impact drains. While the drains currently house drains and ensure rating system has (see attached site map) framed cartridge inserts, the cartridges may metrics for cartridge replacement. need more frequent replacement. Tire and brake 2. Evaluate replacement frequency of dust from movement of vehicles is likely to each drain insert on an individual basis. contribute to high metals concentrations in this 3. Replace cartridges as needed. drainage area. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS GENERAL HOUSEKEEPING Asphalt areas need sweeping. In-house 1. Engage contract sweeper and schedule sweeper needs repair and replacement part is routine sweeping until in-house on backorder. sweeper is repaired. 2. Encourage good housekeeping as a part of a daily and/or weekly routine. "Source controls, operational controls or physical improvements Facility DAIMLER TRUCKS — CLEVELAND Parameter Exceedance Zinc SDO 002 Date of Sample 9/16/2021 Date Received from Lab 9/30/2021 Date NC DEQ Notified 10/19/2021 Notification Method Email Benchmark 0.126 m /I Lab Result 0.200 m /I Date/Time of SW Inspection 10/11 /2021 Weather during Inspection Clear, 650 11:52am —1:00 m Inspector(s) C Buchanan Daimler CLE Areas Inspected Drainage Area for SDO where industrial activity occurs: See attached map. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS* High Risk INLET DRAINS These drains have been identified as high 1. Review PM for inspecting stormwater impact drains. While the drains currently drains and ensure rating system has (see attached site map) house framed cartridge inserts, the metrics for cartridge replacement. cartridges may need more frequent 2. Evaluate replacement frequency of replacement. Tire and brake dust from each drain insert on an individual basis. movement of vehicles is likely to contribute 3. Replace cartridges as needed. to high metals concentrations in this drainage area. Areas of Concern POTENTIAL SOURCE POTENTIAL IMPROVEMENTS GENERAL HOUSEKEEPING Asphalt areas need sweeping. In-house 1. Engage contract sweeper and schedule sweeper needs repair and replacement part routine sweeping until in-house is on backorder. sweeper is repaired. 2. Encourage good housekeeping as a part of a daily and/or weekly routine. *Source controls, operational controls or physical improvements l Q iT E � t 's E E �q / z 8 e gig¢ Ogg ;5 m=�' m9ao ,( ��2 9 A CZ_ O CI� 2 g7m o B ?¢ o m F £ IP: 0 IR � � fi $ c �eli��ffi1�'rf8 saliSlSB!ffi� £ s gCFeGCCFSi �'�'[ - a Sasa�vaYae Y'�m c� O a c a S i sffi am.e eki g1glO 1ffi@Bsx^ffi A�@ $`yffiffiBffi�ffiffiggffi��@&@ �ffi$$@ $�'3��' D ¢d ®Bee¢980942 Fs° snin N "Im j, oaa'Mxc M/.,E m:o wrt oo�PcWNEeo Pfl OJECi NAME. BiMYYAvo, WtroX PNEVEN,pNP4N ^sw'ngc.mre�m+, Nry rwr rq n.e myrmn° � mO >mM O � LtJEM XAYE .G IAIRS!'MMMMNY[Att',. LLl' ,�r,�owr ,q vW ua,w-tea me _ OSHIELD ENOINEERIN6 „`�,� 9CNE t�]oT`o