NCG030478_Notice of Violation Response_20240102

CA
INTELLIGENT MOTION
Columbus McKinnon Corporation 1 13320 Ballantyne Corporate Place Suite D,Charlotte,NC 28277 1 `3 716.689,5400 1 716.689.5644 1 www.cmco.coni
Timothy LaBounty
Regional Engineer RECEIVED
North Carolina Department of Environmental Quality
Division of Energy, Mineral and Land Resources JAN 0 Z 2024
December 14, 2023 oZ=cq
DEQ-FAYETTEVILLE REGIONAL OFFICE
Dear Mr. LaBounty,
Please allow this to serve as the required response to NOV-2023-PC-0570 issued by your department on November
28tn 2023 and received by the site on December 4tn, 2023.
In regards to the two permit condition violations cited, the site has since been able to locate and file all of the
Qualitative and Analytical Monitoring requested during the site inspection with the exception of the second half of 2021.
During this time the site was without an EHS Manager and it is believed that this requirement was overlooked.
To help prevent any deviations from the permit, all requirements, including the Qualitative and Analytical Monitoring
and subsequent eDMR submittal, have been added to the company's electronic compliance system. This was done
prior to receipt of this NOV, but was not in place in Q3 and Q4 of 2021. This system allows you to reassign these tasks
in the event of personnel change and is overseen by members of the Corporate EHS Team for added visibility. This
system was briefly reviewed with Ms. Joyner and Ms. Jonas during the site inspection.
In addition to the use of the compliance system, in Q1 of 2022, the site contracted a 3rd party to begin taking these
samples. The 3rd party conducts both the Analytical and Qualitative Monitoring and provides the results and
documentation to the site. Although the ultimate responsibility for compliance lies with the site, the 3rd party
involvement is another level of protection to ensure no future samples are overlooked.
To ensure these records are available on site or electronically as required, the expectation is for them to be printed and
filed, as well as stored electronically. The records are attached to the compliance task upon completion so that anyone
can readily find and access them.
Recently the site worked with Trinity Consultants to fully review and update the site SWPPP. The completed SWPPP
was received just prior to the inspection and was in the process of being fully implemented. The site will review the
SWPPP on an annual basis as required and if major changes are needed we will reach out to Trinity or a similar party
for help or clarification. The site is fully committed to meeting the permit requirements and environmental stewardship,
and we believe we have a good system in place moving forward.
Should you have any questions or need further information please contact me, or Worley Johnson at 859-893-3306 or
[e-mail]
Sincerely,
/ames Clar c
Plant Manager
Columbus McKinnon—Wadesboro Operations