NCG030075_2022 DMR_20220622 (2)

Ala
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 22, 2015
BorgWarner Turbo Systems
ATTN: Mr. Jack Martindale
PO Box 15075
Asheville, North Carolina 28813
Donald R. van der Vaart
Secretary
SUBJECT: NPDES Stormwater Permit: Request for Regulatory Relief and
Representative Outfall Status
BorgWarner Turbo Systems
General Permit No: NCG030000; COC No: NCG030076
Buncombe County
Dear Mr. Martindale:
In response to your request for regulatory relief, NCDENR-Land Quality Section staff
conducted a site inspection on February 25, 2015. The primary goal of this inspection
was to evaluate compliance with the conditions of the NCG030000 General Permit, to
discuss any actions that have been or could be taken to identify and limit potential
sources of zinc and copper related to process operations, and to discuss potential for
representative outfall status on one or more. outfalls. At the time of this inspection the
facility was found to be in compliance with permit NCG030075 and no illicit discharges
were discovered.
Monthly monitoring was triggered by exceedances of the zinc and copper benchmarks
in Storm Drain Outfalls OF-1, OF-2, OF-3, OF-4 and OF-7 at your facility. Please keep
in mind that benchmark exceedances are NOT limit violations or violations of permit
conditions; however, you are obligated to follow the tiered response actions outlined in
your permit. BorgWarner Turbo Systems has been following the tiered response
actions and therefore is in compliance with the permit.
As part of tiered response, BorgWarner Turbo Systems initiated housekeeping actions
to reduce the zinc and copper levels, as documented in the `Evaluation of Stormwater
Activities Related to Tiered Response' dated March 26, 2015. Based on these actions
and no finding of significant sources of zinc or copper, we are granting regulatory relief
in the form of a collapsed Tier 2 — Tier 3 response. Upon receipt of this letter,
BorgWarner Turbo Systems may resume the permit specified semi-annual analytical
monitoring for the remainder of the current permit term. Your current permit is set to
expire on October 31, 2017. This decision only applies to the zinc and copper
Division of Energy, Mineral, and Land Resources — Land Quality Section
Asheville Regional Office, 2090 US Highway 70, Swannanoa, North Carolina, 28778-8211
Telephone [phone] Fax [phone] One
http://portal.ncdenr.org/web/Ir/land-quality NofthCarolina
An Equal Opportunity / Affirmative Action Employer Natura!!r,

Mr. Jack Martindale
April 22, 2015
Page 2 of 2
benchmarks. A benchmark exceedance of any other parameter listed in your
permit will trigger tiered response actions as described in the general permit.
In response to your request for Representative Outfall Status, we agree that OF-3 is
representative of OF-2 and OF-3. We also note that OF-4, OF-5, OF-6 and OF-7
should be documented as outfalls in your SPPP, but you are granted relief from
analytical monitoring of these outfalls because they are not related to any process
areas. Therefore, analytical monitoring will only be required per your permit conditions
on OF-1 and OF-3.
You must notify this office in writing, within five business days, if you become aware of
any significant source of zinc or copper at your facility that has the potential to be
exposed to stormwater. The relief granted in this letter is contingent upon the current
industrial practices at BorgWarner Turbo Systems. If industrial practices change and
zinc or copper does become a significant stormwater exposure risk then this office
reserves the right to withdraw this decision and reinstate the permit specified tiered
response or other actions that may be warranted by the new set of circumstances.
Please refer to the enclosed Compliance Inspection Report for additional comments,
observations, and recommendations made during the inspection.
Please retain and append this letter to your Stormwater Pollution Prevention Plan
(SPPP) or permit. If you have any questions or comments concerning this letter, please
contact Darlene Kucken or me at [phone].
Sincerely,
Laura Herbert, PE
Regional Engineer
Enclosure
ec: Bethany Georgoulias, RCO
Matthew E. Wallace, P.E., Amec Foster Wheeler Environment and Infrastructure,
Inc. (matthew.wallace(D-amecfw.com )

Compliance Inspection Report
Permit: NCG030075 Effective: 11/01/12 Expiration: 10/31/17 Owner: Borg Warner Turbo System
SOC: Effective: Expiration: Facility: Borgwarner
County: Buncombe 1849 Brevard Rd
Region: Asheville
Arden NC 28704
Contact Person: Mike Doughtery Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/25/2015 Entry Time: 02:OOPM
Primary Inspector: Darlene J Kucken,
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 04:OOPM
Phone:
Melissa King Phone :
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

permit: NCGO30075 owner - Facility: Borg Warner Turbo System
Inspection Date: 02/25/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection was conducted as a compliance inspection, an assessment of Representative Outfall Status and an
assessment of potential regulatory relief from tiered sampling. The site was found to be in very clean condition both inside
and outside. A field assesment of potential impacts to each outfall was conducted. Based on the reference analytical work
conducted, best management practices installed, and the site conditions, the following communication was provided by
email on 3/16/2015 from Darlene Kucken to Jack Martindale and Matthew Wallace:
1. Outfalls #4, 5, 6 and 7 should be documented in your SWPPP and you should conduct visual inspections per your
permit, but you are granted relief from analytical monitoring of these outfalls because they are related to parking lots and
grassed areas and not to process areas. Please understand that these four outfalls are unregulated, which is different from
Representative Outfall Status.
2. As for your request for Representative Outfall Status: We are prepared to agree to continued sampling of outfall #1
and outfall #3 (as representative of outfalls #2 and #3). Therefore, only outfalls #1 and #3 will require analytical monitoring.
This should be documented in your SWPPP.
3. Please submit a written engineering argument for the relief from monthly Tiered sampling. This argument should
address what you have already done in response to the exceedances, such as wet mopping, magnet sweeping, pre -vent
filters, etc., etc. Within the engineered argument, please provide your data on the rainfall sampling you conducted. The
intent of this argument is to provide documentation, which we do not currently have from you, to the file. Until we receive
this engineered argument, you should continue your Tiered sampling.
4. After this office receives your engineered argument, you will receive an official letter providing your status as it relates
to Representative outfall Status and to Tiered Sampling.
An Update to Representative Outfall Staus was provided to this office on March 13, 2015. A request was made to Jack
Martindale on March 23 to revise and sign the request form.
Page: 2

Permit: NCG030075 Owner - Facility: Borg Warner Turbo System
Inspection Date: 02/25/2015 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?
N ❑ ❑ ❑
# Does the Plan include a General Location (LISGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N ❑ ❑ ❑
# 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?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
E ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
N ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
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? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
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? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ 0 ❑
Comment:
Page: 3