NCG030308_Regulatory Relief from Monthly Monitoring_20230201

ROY COOPER
Governor
ELIZABETH;S. BISER
Secretary
DOUGLAS R. ANSEL
Interim Director
Godwin Manufacturing Co., Inc.
Attn: Ryan Taylor, CEO
PO Box 1147
Dunn, NC 28335
NORTH CAROLINA
Environmental Quality
February 1, 2023
Subject: Request for Regulatory Relief from Monthly Monitoring
Godwin Manufacturing Co., Inc.
NPDES Stormwater General Permit NCG030000, Certificate of Coverage NCG030308
Harnett County .
Dear Mr. Taylor:
On January 25, 2023, the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources
(DEMLR) received a letter dated January 25, 2023 requesting regulatory relief from monthly monitoring due
to consecutive exceedances of the benchmark value for Zinc at outfall 3. 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.
The letter states that all other parameters have been meeting the benchmarks and summarizes monitoring
data for Zinc at outfall 3 from the first half of 2021 through the end of 2022. More specifically, exceedances of
the benchmark value for Zinc in second quarter 2022 and fourth quarter 2022 (no discharge reported for third
quarter 2022) triggered the Tier Two monthly monitoring conditions of the NCG030000 permit. The letter also
summarizes that a walk around inspection was conducted and there was no evidence of any leaks or spills
that might have contributed to the elevated Zinc levels. Additionally, facility personnel attributed the Zinc
levels to brake dust from vehicular traffic, numerous metal buildings, chain link fencing around the property,
and gutters on all of the buildings.
In prior discussions with Ms. Cathy Jackson, Executive Assistant, it was relayed that the manufacturing of
truck bodies and other equipment at the subject facility does not involve the use of any products or materials
containing Zinc.
Based on the historical monitoring data and information summarized above, we are granting regulatory relief
in the form of a collapsed Tier 2 - Tier 3 response. Upon receipt of this letter, Godwin Manufacturing Co., Inc.
may resume the permit specified quarterly analytical monitoring at the Harnett County facility for the
remainder of the current permit term. Your current permit is set to expire on June 30, 2026. This decision
applies only to the Zinc benchmark. A benchmark exceedance of any other parameter listed in your
permit will trigger the tiered response actions as described in the general permit.
You must notify this office, in writing, within five business days if you become aware of any significant source
of Zinc, related to industrial activities 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 the facility. If industrial
practices change such that Zinc 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.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
+ Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
� "�Q2A
!i
NOW—t 4f ERVI—Montal Wallty 910.433.3300

Please retain and append this letter to your Stormwater Pollution Prevention Plan (SPPP). If you have any
questions or concerns, please contact me at [phone] or via email at [e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
ec: Cathy Jackson, Executive Assistant — Godwin Manufacturing Co., Inc.
DEMLR NPDES Stormwater Permit Laserfiche Files
cc: FRO — DEMLR, Stormwater Files