NCG030329_Tier III Relief Letter_20231117

ROY COOPER �►`"L `N,TY 1Q.13
Governor
ELISABETH BISER
Secretary
WILLIAM E.TOBY VINSON,JR.
Interim Director NORTH CAROLINA
Environmental Quality
November 17, 2023
LETTER OF APPROVAL
Honda Power Equipment MFG
Attention: Kevin Barrett, Environmental Leader
3721 NC Hwy 119 South
Swepsonville,NC 27258
Subj ect: Request for Regulatory Relief from Monthly Monitoring
Honda Power Equipment MFG
NPDES Stormwater General Permit NCG030000, Certificate of Coverage NCG030329
Alamance County
Dear Mr. Barrett,
On August 7, 2023,the Winston Salem Regional Office of the Division of Energy, Mineral, and Land Resources
(DEMLR) received a letter requesting regulatory relief from monthly monitoring die to consecutive exceedances
of the benchmark value for copper at outfall 1. 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.
Documentation provided by your company states that all other parameters have been meeting the benchmarks
and summarizes monitoring date for copper at outfall 1 from the third quarter of 2021 through the third quarter
of 2023. More specifically, exceedances of the benchmark value for copper in the third quarter of 2021 and the
second quarter of 2022 (no exceedances reported for the fourth quarter of 2021)triggered the Tier Two monthly
monitoring conditions of the NCG030000 permit. The documentation 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 copper levels. In prior discussions with facility personnel, it was relayed that material containing copper
used in the manufacturing of power equipment at the subject facility is not stored outside in any capacity.
Additionally, facility personnel attributed the copper levels to brake dust from vehicular traffic.
Based on the historical monitoring data and information summarized above, we are granting regulatory relief in
the form of a collapsed Tier2 — Tier 3 response. Upon receipt of this letter, Honda Power Equipment MFG may
resume the permit specified quarterly analytical monitoring at the Alamance County facility for the remainder of
the current permit term. Your permit is set to expire on July 1, 2026. This decision applies only to the copper
benchmark. A benchmark exceedance of any other parameter listed in your permit will trigger the tiered
response actions as described in the general permit.
North Carolina Department of Environmental Quality I Division of Energy,Mineral,and Land Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road,Suite 300 1 Winston-Salem,North Carolina 27105
336-776-9800

Regulatory Relief from Monthly Monitoring
Honda Power Equipment MFG
November 17, 2023
Page 2 of 2
You must notify this office, in writing, within five business days if you become aware of any significant source
of copper 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 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 retain and append this letter to your Stormwater Pollution Prevention Plan (SWPPP). If you have any
questions or concerns, please contact me at 336-776-9654 or via email at'I'amera.Eplin'),deq.nc.gov.
Sincerely,
.A/
Tamera Epliq, PE
Regional Engineer
Land Quality Section
Enclosures: Inspection Report

Compliance Inspection Report
Permit:NCG030329 Effective: 07/01/21 Expiration: 06/30/26 Owner: American Honda Motor Co Inc
SOC: Effective: Expiration: Facility: North Carolina Manufacturing
County: Alamance NC Hwy 119 Honda Dr
Region: Winston-Salem
Swepsonville NC 27359
Contact Person:Stephen Fogle Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 11/01/2023 Entry Time 11:OOAM Exit Time: 01:OOPM
Primary Inspector:Kimberly Turney Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG030329 Owner-Facility:American Honda Motor Co Inc
Inspection Date: 11/01/2023 Inspection Type:Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
This facility was inspected per request to determine eligibilty for Tier III Relief. All monitoring data and maps were made
avaiable, and the permittee was able to provide investigative history and source monitoring materials. Copper exceedances
can be contributed to air conditioning condensate; the sporadicity correlates to monthly precipitation in amounts significant
enough to reach outfall 1. Monitoring data from condensate pipes and roof drains confirm the source.A thourough inspection
of the facility, including all outfalls,was conducted; the facility was observed to be in compliance. Relief from monthly
monitoring is appropriate.
Page 2 of 3

Permit: NCG030329 Owner-Facility:American Honda Motor Co Inc
Inspection Date: 11/01/2023 Inspection Type :Compliance Evaluation Reason for Visit: Follow-up
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ ❑
# Does the facility provide all necessary secondary containment? ❑ ❑ ❑ ❑
# Does the Plan include a BMP summary? ❑ ❑ ❑ ❑
# 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? ❑ ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ ❑
# Is the Plan reviewed and updated annually? ❑ ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ ❑ ❑ ❑
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? ❑ ❑ ❑ ❑
#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? ❑ ❑ ❑ ❑
Comment:
Page 3 of 3

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