NCG030085_COD Action Plan_20221229

DAIMLER TRUCK
North America
December 20, 2022
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 20115
[e-mail]
Subject: Tier Three Action Plan, Fourth Quarter 2022
Daimler Trucks North America, LLC- Mount Holly Truck Plant
Certificate of Coverage NCG030085
Dear Mr. Khan,
Daimler Trucks North America, LLC - Mount Holly Truck Plant is submitting the attached Tier Three Action for your approval in
accordance with NPDES Industrial Stormwater Permit NCG030000, Part E for Fourth Quarter, 2022. 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 me at [e-mail].
Sin�cere�ly�,
Michael K enburg
Environmental Engineer
Daimler Trucks North America LLC
1800 North Main Street
Mount Holly, NC 28120
704.822.7413 Phone
Michael. [e-mail]
cc: Lily Kay, NCDEQ Mooresville
Enclosures
Tier Three Action Plan, Fourth Quarter 2022
DAIMLER TRUCK NORTH AMERICA 1 1800 N MAIN STREET, MOUNT HOLLY, NC 28120 1 706.822.7000 I MMAWDAIMLERTRUCKNORTHAMERICA.COM

DAIMLER
DAIMLER TRUCKS NORTH AMERICA
Mount Holly Truck Plant
1800 North Main Street
Mount Holly, North Carolina
Certificate of Coverage NCG030085
Tier Three Action Plan, Fourth Quarter 2022
In compliance with General SW Permit NCG030000, Part E-7
Prepared by:
OSHIELD
ENGINEERING
4301 Taggart Creek Road
Charlotte, NC 28208
Shield Project No. R990150187
December 12, 2022
I certify by my signature below, underpenaltyoflaw, that this document and all attachments were
prepared under my direction orsupervision in accordance with a system designed to assure that
qualified personnel pmpady gather and evaluate the infomation 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
(�informal' n,includin a Iblityoffines and imprisonment for knowing violations.
Joanna Cooper u Date
DTNA —Mount Holly

Daimler Trucks North America, LLC -Mount Holly Page 1
Tier Three Response Action Plan December 12, 2022
Facility
Daimler Trucks — Mount Holly NGG030085
SDO
1 001
Parameters
COD
Date Prepared
1 12/1212022
INTRODUCTION
This Action Plan has been prepared in accordance with Part E-7(b) of General Permit for
benchmark exceedances which have triggered a 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 Benchmark Exceedances
The table below documents the benchmark exceedances for COD at Outfall 001 for Daimler
Trucks — Mount Holly during 2021 and 2022. While preparing this Action Plan, the laboratory
results from the November 15, 2022 sampling event were received, and since COD was exceeded
during this sampling event, the analytical result is included in the table:
COD benchmark=120 mg/I
Outfall
Month
Sep-21
Nov-21
Sep-22
Oct-22
Nov-22
001
1 230
220
350
290
484
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 area of Outfalls 001. Typical industrial activities that occur in each of these drainage
areas is described below.
Drainage Area 001: Includes heavy vehicle movement and storage, Tank Farm, Tire Shop, CRC,
Dyno 2, Dead Trucks Area, Pool 1 Pad.
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 areas.
!it. 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.

Daimler Trucks North America, LLC -Mount Holly Page 2
Tier Three Response Acton Plan December 12 2022
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 COD concentrations in
stormwater discharged from Ouffall 001 and contribute to benchmark exceedances:
Potential Cause of
Benchmark Exceedanee
Location(s)
Potential
Pollutant
Outfall(s)
Affected
Motor Oil and Hydraulic
Loading Areas and
COD
001
Fluid
Outdoor Asphalt
Pavement and
Drains
Cumulative Effect from
Loading Areas and
COD
001
Dust and Debris
Outdoor Asphalt
Pavement and Drains
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.
Complete clean out and vacuum of oil/water separator
Both actions were completed
ahead of normal PM.
on 12/8/2022 by the Facility —
2.
Clean out and vacuum the corrugated plastic pipe that
soon after the completion of
drains from the oil -water separator.
the facility inspection on
12/1/2022 and ahead of the
normal PM schedule.
3.
Replace the drain insert on Drain 2 on a monthly
Drain to will be replaced hn
basis, rather than an as -needed basis, and evaluate
January 2023. Monthly
progress after one quarter of implementation.
progress will be evaluated
after Q12023.
4.
Add sediment removal from the Drain 2 vicinity to the
January 2023
tasks completed during the monthly preventative
maintenance.
5.
Review housekeeping practices with team
January 2023
leadstsupervisors in the area, track progress through
internals stems.
' The dates provided are target dates and may change due to reasons beyond Dalmlels 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 SOO 001 at least monthly until three
consecutive samples for COD are below the benchmark value. In the event a sample cannot be
collected during a month, the Facility will document 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.

Daimler Trucks North America, LLC -Mount Holly Page 3
Tier Three Response Acton Plan December 12, 2022
ATTACHMENTS:
Stormwater Management Inspection (COD, Outfall 001)
Site Map

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