NCG030085_Tier 3 Action Plan_20211027

SHIELD
ENGINEERING
October 25, 2021
Zahid Khan
Regional Engineer, Land Quality Section
Energy, Mineral, and Land Resources G�
North Carolina Department of Environmental Quality o
Mooresville Regional Office
610 East Center Avenue, Suite 301 0
Mooresville, North Carolina 28115
[e-mail]
Subject: Tier Three Action Plan, Third Quarter 2021
Daimler Trucks North America, LLC — Mount Holly Truck Plant
Certificate of Coverage NCG030085
Dear Mr. Khan,
On behalf of Daimler Trucks North America, LLC (DTNA) — Mount Holly 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-Mount Holly's
responsible official. If you have any questions regarding this Action Plan, please contact us at
[phone] or Sean Quarry with DTNA-Mount Holly at [e-mail].
Sincerely,
SHIELD ENGINEERING, INC.
Y
nd l�i. Greene
or Engineer
f^ '
Magdaline M. Tzannis
Senior Project Manager
ATTACHMENTS
cc: Sean Quarry, DTNA-Mount Holly
James Moore, NCDEQ Mooresville
President/CEO
1/1
4301 Taggart Creek Road www.shieldengineering.com Telephone [phone]
Charlotte, NC 28208 License No. F-0856

DAI M L E R
DAI MLER TRUCKS NORTH AMERICA
Mount Holly Truck Plant
•ao
1800 North Main Street
Mount Holly, North Carolina
n
Certificate of Coverage NCG030085
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
October 25, 2021
I certify by my signature below, under penally 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. 1 am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Craig Redshaw Date
DTNA — Mount Holly

Daimler Trucks North America, LLC - Mount Holly Page 1
Tier Three Response Action Plan October 25, 2021
V
Facility
Daimler Trucks — Mount Holly NCG030085
SDO
001,002
Parameters
Zinc, Copper
Date Prepared
10/19/2021
1
r�
Ns s P
07 N/'P
INTRODUCTION
C
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 and Zinc at Outfall 001 have carried over from the previous
General Permit. Daimler Trucks — Mount Holly has made progress towards meeting the
benchmark for Copper and achieved results below the benchmark values during the September
2021 sampling event. While this Action Plan was developed primarily to address Zinc Tier 3
Response, this Action Plan has the potential to have an impact on Copper concentrations at
Outfall 002 and therefore addresses both Copper and Zinc Tier Three Response.
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 benchmark exceedances for Zinc and Copper at Outfalls 001 and
002 for Daimler Trucks — Mount Holly during 2021.
Zinc benchmark = 0.126 mg/I
Outfall
Month
Jan-
21
Feb-
21
May-
21
Sep -
21
001
10.150
10.180
10.200
0.240
Zinc benchmark = 0.126 mg/I
Outfall
Month
Oct-
20
Feb-
21
May-
21
Sep -
21
002
10.170
0.260
0.270
0.140
Copper benchmark = 0.010 mg/I
Outfall
Month
Apr-19
Apr-20
Feb-21
May-21
002
0.024
0.012
0.0130
0.0150

Daimler Trucks North America, LLC - Mount Holly Page 2
Tier Three Response Action Plan October 25, 2021
ii. 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 Outfalls 001 and 002. Typical industrial activities that occur in each of
these drainage areas is described below.
Drainage Area 001: Includes heavy vehicle movement and storage, parts storage, bulk chemical
storage, Dyno 2, and partial building roof.
Drainage Area 002: Includes heavy vehicle movement and storage, Offline Paint, Dyno 1,
Chemical Pad, parts loading and unloading, cooling towers, bulk used oil tanks, Central
Accumulation Area (hazardous waste), recycling, leak testing, majority of main building roof and
receiving docks.
The inspection reports note areas of concern observed as having the potential to contribute to
benchmark exceedances. A site map is attached for reference of the drainage areas.
iii. An evaluation of standard operating procedures and good housekeeping procedures
Daimler Mount Holly 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 001. 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 - Mount Holly 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 Outfalls 001 and 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
001,002
Fluid throughout the Facility
Outdoor Asphalt
Pavement
Cumulative Effect from Tire
Loading Areas and
Zinc
001,002
Dust and Debris
Outdoor Asphalt
Pavement
Cumulative Effect from
Outdoor Asphalt
Copper
001,002
Vehicle Brake Pad
Pavement
Deposits

Daimler Trucks North America, LLC - Mount Holly Page 3
Tier Three Response Action Plan October 25, 2021
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. Engage contractor to clean out high risk drains.
This will be completed as part
of framed drain insert install —
see below.
2. Install framed drain insert at high risk drain locations
The contractor has provided
and continue to inspect monthly; place on
the costs and the frame
replacement PM as needed.
drains will be installed before
11 /15/21; The monthly
cadence will commence in
November with materials
being installed by 12/1 /21,
however the supply chain
delays may push that date to
12/15/21-12/31 /21.
3. Replace sock boom at drain inlet between Tire Shop
New socks have been
and CRC (OM separator) and increase replacement
ordered and placement is
frequency.
I anticipated by 10/30/2021.
' The dates provided are target dates and may change due to reasons beyond Daimler's control such as supply chain or delivery
issues.
vi. A monitoring plan to verify that the Action Plan has addressed the source(s).
Daimler Trucks - Mount Holly will attempt to sample SDO 001 at least monthly until three
consecutive samples for Zinc 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 — Mount Holly 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 (Zinc, Outfall 001)
Stormwater Management Inspection (Zinc, Outfall 002)
Site Map

Stormwater Management Inspection Report (Tier Response)
Facility
DAIMLER
TRUCKS — MOUNT HOLLY
Parameter Exceedance
Zinc
SDO
001
Date of Sample
9/8/2021
Date Received from Lab
9/27/2021
Date NC DEQ Notified
10/12/2021
Notification Method
Email & Hardcopy/Priority Mail
Benchmark
0.126 m /I
Lab Result
0.240 m /I
Date/Time of SW Inspection
10/4/2021 1:00pm — 2:20 m
Weather during Inspection
I Clear, 800
Inspector(s)
M Greene and M Tzannis (Shield); S Qua Daimler
MTH
Areas Inspected
Drainage Area for SDO where industrial activit occurs: Tank Farm, Tire Shop, CRC, D no 2
Areas of Concern
POTENTIAL SOURCE
POTENTIAL IMPROVEMENTS*
INLET DRAINS:
These drains have been identified as high
1. Remove sediment and vegetation from
Near Tank Farm (#1)
impact drains. While the drains do house
drains.
Between Tire Shop and
mesh inserts, the frameless inserts have
2. Add catch basin filtration insert system
CRC (#2)
fallen and/or need more frequent
(frame with replaceable bag) to each
Near Dyno & CRC (#3)
replacement. Some drains contain excessive
high impact drain.
trash, sediment and vegetative growth. The
3. Evaluate replacement frequency of
(number corresponds to
absorbent sock around the drain inlet along
each drain insert on an individual basis.
location on attached site
the curb between Tire Shop and CRC (at
4. Replace sock boom at drain inlet
map)
O/W separator) appears to be beyond its
between Tire Shop and CRC (O/W
useful life. Tire and brake dust from
separator) and increase replacement
movement of vehicles is likely to contribute
frequency.
to high metals concentrations in this
drainage area.
Areas of Concern
POTENTIAL SOURCE
POTENTIAL IMPROVEMENTS
GENERAL HOUSEKEEPING
There is an excessive amount of trash and
1. Re-emphasize proper use of in-house
debris in the drainage area. Trucks still in
sweepers and spot cleaning.
production (waiting on parts) are parked
2. Encourage good housekeeping as a
across the drainage area making routine
part of a daily and/or weekly routine.
sweeping difficult. A small spill was observed
southwest of CRC; loose absorbent had
been placed on the spill, but the absorbent
material had not been disposed of.
*Source controls, operational controls or physical improvements

Facility
DAIMLER
TRUCKS — MOUNT HOLLY
Parameter Exceedance
Zinc
SDO
002
Date of Sample
9/8/2021
Date Received from Lab
9/27/2021
Date NC DEQ Notified
10/12/2021
Notification Method
Email & HardcopytPriority Mail
Benchmark
0.126 m /I
Lab Result
0.140 mg/1
Date/Time of SW Inspection
10/4/2021 1:00 m — 2:20pm
Weather during Inspection
Clear, 80"
Inspector(s)
M Greene and M Tzannis (Shield); S Qua Daimler MTH
Area(s) Inspected
Drainage Area for SDO where industrial activity occurs: Offline Paint, CAA, Chem Pad, Central
Stores Canopy, Material Storage, D no 1
Areas of Concern
POTENTIAL SOURCE
POTENTIAL IMPROVEMENTS*
INLET DRAINS:
These drains have been identified as high
1. Remove sediment and vegetation from
Near East Security Gate
impact drains. While the drains do house
drains.
& Scale (#4)
mesh inserts, the frameless inserts have
2. Add catch basin filtration insert system
Behind Offline Paint (#5)
fallen and/or need more frequent
(frame with replaceable bag) to each
Near Dyno & Offline Paint
replacement. Some drains contain excessive
high impact drain.
(#6)
trash, sediment and vegetative growth. Tire
3. Evaluate replacement frequency of
Material Storage (#7)
and brake dust from movement of vehicles is
each drain insert on an individual basis.
(number corresponds to
likely to contribute to high metals
location on attached site
concentrations in this drainage area.
map)
Areas of Concern
POTENTIAL SOURCE
POTENTIAL IMPROVEMENTS
GENERAL HOUSEKEEPING
There is an excessive amount of trash and
1. Re-emphasize proper use of in-house
debris in the drainage area. Trucks still in
sweepers and spot cleaning.
production (waiting on parts) are parked
2. Encourage good housekeeping as a
across the drainage area making routine
part of a daily and/or weekly routine.
sweeping difficult.
*Source controls, operational controls or physical improvements

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