NCG030487_Inspection_20090127

�QF Beverly Eaves Perdue,Governor
0 G Dee Freeman,Secretary
rNorth Carolina Department of Environment and Natural Resources
'I
Coleen Sullins,Director
Division of Water Quality
January 27, 2009 •
Ms. Jennifer Holliday
Daimler Buses of North America
6012-B High Point Road
Greensboro, North Carolina 27407
Subject: General Stormwater Permit Inspection
NPDES General Permit No. NCG030487 — Daimler Buses of North America
Guilford County
On January 22, 2009, Jenny Graznak of this office performed a Stormwater Permit
Inspection at Daimler Buses of North America located at 6012-B High Point Road in
Greensboro, North Carolina. This facility holds General Stormwater Permit No. NCG030487
under the National Pollutant Discharge Elimination System (NPDES) to discharge Stormwater
associated with activities classified as Metal Fabrication. In addition to you, James Husted
(Environmental Consultant, Husted & Associates, Inc.) was present for the inspection. This type
of inspection consists of two basic parts: a review of facility files and self-monitoring data and an
inspection of the facility's discharge points. .This particular inspection evaluated five (5) areas,
and observations from each area are addressed below:
1. Permit
The permit became effective November 1, 2007 and expires October 31, 2012. A copy of the
permit was available during the inspection.
2. Records/Reports
As required by the Permit, the facility has a complete Stormwater Pollution Prevention Plan
(SPPP) that was available for review during the inspection. The SPPP, which is updated on an
annual basis, appeared to be thorough and complete, including a location map of the outfalls
and a site plan listing potential stormwater pollutants and best management practices used at
the site. Employee Training of the SPPP occurs on an annual basis.
3. Facility Site Review
Damiler only uses one-third of the building and outdoors space at this site. The other two-thirds
of the site belong to Legacy Paddlesports, which has a separate Stormwater permit and outfalls.
Daimler assembles and up fits buses, but they do not actually manufacture them. The facility
houses bulk oil storage on site that requires a Spill Prevention, Control and Countermeasure
Plan. However, these tanks are located inside the building. There are two covered dumpsters
on the Daimler property. Vehicle maintenance occurs inside the maintenance buildings. A bus-
wash bay has an oil/water separator, which is serviced by an oil-recycling vendor and the
wastewater is routed to sewer. There is also a chemical storage area, which is covered and
protected from rain with no outlet.
It was determined during the visual inspection of the property that a condition of No Exposure
exists at this facility. All chemicals and materials at the facility are covered by a storm resistant
shelter to prevent exposure to rain, snow, snowmelt, and runoff. Therefore, as long as all of the
North Carolina Division of Water Quality 585 Waughtown Street Winston Salem,NC 27107 Phone[phone] Customer Service
Internet: h2o.enr.state.nc.us FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer-50%Recycled/10%Post Consumer Paper
No`hCarolina
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Ms. Holliday, Daimler Buses
Page 2
January 27, 2009
conditions described above remain in effect at this location, it is recommended that you apply
for a No Exposure Certification for Exclusion from NPDES Stormwater Permitting. A No
Exposure application is attached to this letter should you choose to proceed in that direction. If
you wish, please complete and send the application to:
The Stormater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. Effluent/Receiving Waters
Stormwater from the property discharges to an unnamed tributary to the Bull Run Creek (Class
WS-IV) in the Cape Fear River Basin.
5. Self-Monitoring Program
The stormwater permit requires semi-annual qualitative and quantitative monitoring of
stormwater discharge outfalls and effluent. An on-site review of the monitoring data during the
inspection showed that all parameters were evaluated per the specifications of the permit. R&A
Laboratories analyzes all samples. All qualitative monitoring is also performed as required by
the permit. You also perform the annual analytical monitoring requirements of the permit that
are associated with the on-site vehicle maintenance activities, which use more than 55 gallons
of new motor oil per month when averaged over the calendar year.
This office appreciates your efforts to comply with the Stormwater permit requirements.
If you have any questions concerning this letter or the attached inspection report, please contact
Ms. Graznak or me at [phone].
Sincerely,
Steve W. Tedder
Regional Supervisor,
Surface Water Protection Section
cc: NPS Assistance & Compliance Oversight Unit
SWP— Central Files
SWP—WSRO

Compliance Inspection Report
Permit: NCG030487 Effective: 09/01/02 Expiration: 08/31/07 Owner: DaimlerChrysler Commercial Buses NA
SOC: Effective: Expiration: Facility: Daimler Chrysler Commercial Buses NA
County: Guilford 6012 High Point Rd
Region: Winston-Salem
Greensboro NC 27407
Contact Person: Clarice Garrett Title: Environmental Engineer Phone:[phone]
Directions to Facility:
•
•
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
On-site representative James Husted Phone: [phone]
Related Permits:
Inspection Date: 01/22/2009 Entry Time: 01:00 PM Exit Time: 02:30 PM
Primary Inspector: Jennifer F Graznak Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Stormwater
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG030487 Owner-Facility: DaimlerChrysler Commercial Buses NA
Inspection Date: 01/22/2009 Inspection Type: Stormwater Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ■ n n n
#Does the Plan include a General Location(USGS) map'? ■ n n n
#Does the Plan include a"Narrative Description of Practices"? ■ n n n
#Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ n n
#Does the Plan include a list of significant spills occurring during the past 3 years? ■ ❑ n n
#Has the facility evaluated feasible alternatives to current practices? ■ n n n
#Does the facility provide all necessary secondary containment? ■ n n ❑
#Does the Plan include a BMP summary? ■ ❑ n n
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ n n n
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ n n n
#Does the facility provide and document Employee Training? ■ n n ❑
#Does the Plan include a list of Responsible Party(s)? ■ n n n
#Is the Plan reviewed and updated annually? ■ n n n
#Does the Plan include a Stormwater Facility Inspection Program? ■ n ❑ n
Has the Stormwater Pollution Prevention Plan been implemented? ■ n n
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ n n n
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ n n n
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ■ n n n
Comment:
Permit and Outfalls Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? ■ n n n
#Were all outfalls observed during the inspection? ■ n n n
#If the facility has representative outfall status, is it properly documented by the Division? ■ n n n
#Has the facility evaluated all illicit(non stormwater)discharges? ■ ❑ n ❑
Comment:
Page: 3