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HomeMy WebLinkAboutNCG030478_Notice of Violation Sent and Received_20231128 i �Yw:3 ROY COOPER a Governor 1 ELIZABETH S.BISER ^� � QUAM'N Secretary WILLIAM E.TOBY VINSON,JR NORTH CAROLINA Interim Director Environmental Quality November 28, 2023 CERTIFIED MAIL: 7020 3160 0000 3835 2306 RETURN RECEIPT REQUESTED Columbus McKinnon—Wadesboro Operations Attn: James Clark 2020 Country Club Road Wadesboro, NC 28170 Subject: NOTICE OF VIOLATION (Case#NOV-2023-PC-0570)and NPDES Stormwater General Permit NCG030000 Columbus McKinnon—Wadesboro Operations Columbus McKinnon—Wadesboro Operations, Certificate of Coverage NCG030478 Anson County Dear Mr. Clark: On inspection date, Ms. Melissa Joyner and Ms. Kelly Jonas from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Columbus McKinnon — Wadesboro Operations facility located at 2020 Country Club Road, Anson County, North Carolina.A copy of the Compliance Inspection Report is enclosed for your review. Ms. Lily Hans(Corporate EHS Manager)and Mr. Worley Johnson (EHS Plant Manager)were also present during the inspection and their time and assistance is greatly appreciated.The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG030000 under Certificate of Coverage NCG030478. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Lampley Branch, class C waters in the Yadkin River Basin. As a result of the site inspection, the following permit conditions violation(s) are noted: 1) Qualitative Monitoring Per Part D, Section D-1...Qualitative monitoring has not been conducted and/or recorded in accordance with permit requirements. 3)Analytical Monitoring Per Part E, Section E-1 -E-4...Analytical monitoring has not been conducted and/or recorded in accordance with permit requirements. Other Observations Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Requested Response You are asked to respond to this office, in writing,within 30 calendar days from receipt of this notice. Your written response should include a reasonable explanation as to why the aforementioned violations have occurred as well as a Plan of Action to prevent these violations from recurring. �.-.--- CJ�` ��E��� North Carolina Department of Environmental Quality I Division of Energy.Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301 ow�.recm eoh WftWil, 910.433.3300 Action Items Conduct quarterly Qualitative Monitoring and Analytical Monitoring per the conditions of the General Permit NCG030000. Thank you for your attention to this matter. This office requires that the violations, as detailed above, be properly resolved. These violations and any future violations are subject to a civil penalty assessment of up to$25,000 per day for each violation. Should you have any questions regarding these matters, please contact Ms. Joyner or myself at(910)433-3300. Sincerely, Timothy L. LaB n , PE Regional Engineer DEMLR TL/maj Enclosure: Compliance Inspection Report ec: James Clark, Plant Manager Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations— DEMLR Brad Cole, PE, Chief of Regional Operations—DEMLR Michael Lawyer, CPSWQ—Stormwater Program Supervisor— DEMLR Kieu Tran, Environmental Specialist, Stormwater Program—DEMLR DEMLR NPDES Stormwater Permit Laserfiche File M. FRO— DEMLR i Compliance Inspection Report Permit:NCG030478 Effective: 07/01/21 Expiration: 06/30/26 Owner: Columbus McKinnon-Wadesboro Oprs SOC: Effective: Expiration: Facility: Columbus McKinnon-Wadesboro Oprs. County:Anson 2020 Country Club Rd Region: Fayetteville Wadesboro NC 28170 Contact Person:Worley Johnson Title: Phone:859-893-3306 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 11/02/2023 Entry Time 10:30AM Exit Time: 12:30PM Primary Inspector:Melissa A Joyner Phone: Secondary Inspector(s): Kelly Jonas 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 of 3 Permit: NCG030478 Owner-Facility:Columbus McKinnon-Wadesboro Oprs Inspection Date: 11/02/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: Melissa Joyner and Kelly Jonas met with Lily Hans (Corporate EHS Manager),Worley Johnson (EHS Plant Manager) and James Clark (Plant Manager),to conduct an industrial stormwater inspection of the Columbus McKinnon-Wadesboro Operations facility. The Stormwater Pollution Prevention Plan (SWPPP) was reviewed per the conditions of the National Pollutant Discharge Elimination System (NPDES) General Permit NCG030000. The current plan was dated October 2023, and appeared fairly complete. The facility had recently received it from their engineering consultant, and was still in the process of reviewing and completing the certifications. The detailed site map needs to be updated to include topographic lines and percent of impervious area in the drainage area. The annual employee training had not been conducted as of the date of the inspection, but was being scheduled. Qualitative and Analytical Monitoring has not been conducted per the conditions of the General Stormwater Permit NCG030000. Quarterly good housekeeping inspections have not been documented. Annual evaluation of the presence of non-stormwater(illicit)discharges in the stormwater outlets has not been completed and documented. The facility grounds were inspected, including the outfalls, including Outfalls 02 and 04. Outfalls 01, 02 and 03 flow into Outfall 04. Therefore,the facility only needs to conduct quarterly Qualitative and Analytical Monitoring of Outfall 04. The facility grounds appeared to be well-maintained. The following actions are recommended: 1. Complete implementing the updated SWPPP, including certifications and employee training.; 2. Update the Site Map to include the topographic lines and percentage impervious.; 3. Conduct quarterly Qualitative and Analytical Monitoring per the conditions of the General Permit NCG03000O.; 4. Document inspections of the quarterly good housekeeping inspections.; 5. Conduct the annual evaluation of the presence of non-stormwater(illicit)discharges in the stormwater outlets.; 6. Moving forward, conduct annual review and certification of the SWPPP.; 7. Maintain a rain gauge at the facility. Page 2of3 i Permit: NCG030478 Owner-Facility:Columbus McKinnon-Wadesboro Oprs Inspection Date: 11/02/2023 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? 0 ❑ ❑ ❑ #Does the Plan include a General Location(USGS)map? N ❑ ❑ ❑ #Does the Plan include a"Narrative Description of Practices"? 0 ❑ ❑ ❑ #Does the Plan include a detailed site map including outfall locations and drainage areas? E ❑ ❑ ❑ #Does the Plan include a list of significant spills occurring during the past 3 years? E ❑ ❑ ❑ #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? E ❑ ❑ ❑ #Does the Plan include a Spill Prevention and Response Plan(SPRP)? N ❑ ❑ ❑ #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑ #Does the facility provide and document Employee Training? ❑ E ❑ ❑ #Does the Plan include a list of Responsible Party(s)? E ❑ ❑ ❑ #Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑ #Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ ❑ Comment: Qualitative Monitorinq Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ N ❑ ❑ Comment: Qualitative Monitoring has not been conducted per the conditions of General Permit NCG030000. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ E ❑ ❑ #Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑ Comment: Analytical Monitoring has not been conducted per the conditions of General Permit NCG030000. 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? 0 ❑ ❑ ❑ #If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ E #Has the facility evaluated all illicit(non stormwater)discharges? ❑ E ❑ ❑ Comment: Page 3of3 i SECTIONSENDER:COMPLETE THIS SECTION COMPLETE THIS . . ■ Complete items 1,2,and 3. A. Signature ■ Print your name and address on the reverse X ❑Agent so that we can return the card to you. ❑Addressee ■ Attach this card to the back of the mailpiece, B. Feived by(Printed Name) C, Date of Delivery or on the front if space permits.. 1. Article Addressed to: D. Is delivery address different from item 1? ❑Yes COLUMBUS MCKINNON-WADESB R(Y OPA er d�ljygfy_address below: p No ATTN:JAMES CLARK l 1111V J 2020 COUNTRY CLUB ROAD WADESBORO,NC 28170 3. 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