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Home My WebLink AboutNCG030211_(Signed) NOV & Insp Rpt_20240318 "%STATE ROY COOPER ; Governor �5 ELIZABETH S.BISER � _ ; ' secrelarr WILLIAM E.TOBY VINSON,JR NORTH ::AROLINA Interim Director Environmental Quality March 18, 2024 CERTIFIED MAIL: 7017 0190 0000 9562 8401 RETURN RECEIPT REQUESTED Caterpillar Inc Attn: Trina Briggs 954 NC 42 East Clayton, NC 27527 Subject: NOTICE OF VIOLATION# NOV-2024-PC-0198 Caterpillar Inc Clayton Facility, Certificate of Coverage-NCG030211 NPDES Stormwater General Permit-NCG030000 Ms. Briggs: The Raleigh Regional Office of the Division of Energy, Mineral and Land Resources, has reviewed the sample data entered into our eDMR database for the Caterpillar Inc facility located at 954 NC 42 East, Clayton in Johnston County, North Carolina and found that none of the required sample data has been submitted since January 28, 2020.The database was reviewed after Trina Briggs (HSE Manager)with Caterpillar called with inquiries about past sample data submissions. Ms. Briggs indicated that she could not find past sample data from their facility prior to her employment and that she was aware that no samples were taken for a full year between August 2022 and November 2023 because the EHS Manager was on medical leave. Your Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Neuse River, a Class WS-IV;NSW waterbody in the Neuse River Basin. The file review revealed that the subject facility is covered by NPDES Stormwater General Permit- NCG030000, Certificate of Coverage-NCG030211. As a result of the review, the following permit conditions violations are noted: 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan(SPPP) has not been developed, recorded, or properly implemented. Samples have not been collected and sample data has not been kept at the facility for 5 years as required by the permit. 2) Qualitative Monitoring Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. Samples have not been collected as required and the data has not been recorded and kept or submitted as required by the permit. Nnrth Carolina Department of Environmental Quality I Division of Energy,Mineral and land Resources D E Raleigh Regional Office 1 I628 Mail Service Center 13600 Barrett Drive I Raleigh.North Carolina 27604 ��=re^ a^•^��+"�`\y`�� 919.i111.4200 3)Analytical Monitoring Analytical monitoring has not been conducted and recorded in accordance with permit requirements. Samples have not been collected as required and the data has not been recorded and kept or submitted as required by the permit. Other Observations: Stormwater discharge sampling is a requirement of the permit. If for any reason, it's known the person who takes the samples will not be available, there should be an alternative in place to take samples. Stormwater sampling is not optional or dependent on availability of personnel. Requested Resoonse: 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. 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 Thad Valentine or myself at(919)791-4200 Sincerely, William H. Denton, IV, PE Regional Engineer- RRQ Division of Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality WHDITWV Enclosure cc: Brittany Cook-General Permit Coordinator Mike Lawyer, Supervisor—Stormwater Permitting Program RRQ—Land Quality Section, Stormwater Files-NCG140000 D Q .�� North Carolina Department of Environmental Quality I Division of Energy.Mineral and Land Resources /�,/•�/�t Raleigh Regional Office 1628 Mail Service Center 3800 Barrett Drive ; Raleigh.North Carolina 27609 -•'rat�aa� Y w.yq 949.793.4200 Compliance Inspection Report Permit:NCG030211 Effective: 07/01/21 Expiration: 061X'26 Owner: Caterpillar Inc SOC: Effective: Expiration: Facility: Caterpillar Incorporated County: Johnston 954 NC 42 E Region: Raleigh Clayton NC 27520 Contact Person:Trina Briggs Title; Phone:984-278-0181 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 03/18/2024 Entry Time 09:OOAM Exit Time: 12:OOPM Primary Inspector:Thaddeus W Valentine Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ❑ Compliant 0 Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 permit: NCG030211 Owner-Facility:Caterpillar Inc Inspection Date: 03/18/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: After several email correspondance with Trina Briggs EHS Manager with Caterppillar Inc and after a review of the file data it was discovered that Caterpillar has not in the past collected samples or maintained and submitted sample data as required. Sample collection and submission is required to take place quarterly at the facility and has not been in the past. Samples were not taken or submitted for an extended period of time between 2022 &2023 when the person who collects samples was on medical leave. Samples are required to be taken regardless of whether the primary sample person is available or not and and plan for secondary options for sampling should be built in as required by the permit. Sample collect and submission is not optional depending on staff availabiility Page 2 of 3 Permit: NCG030211 Owner-Facility:Caterpillar Inc Inspection Date: 03/18/2024 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? . #Does the Plan include a General Location(USGS)map? No #Does the Plan include a"Narrative Description of Practices"? 0 ❑ #Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ 0 0 ❑ #Does the Plan include a list of significant spills occurring during the past 3 years? 0 0 a ❑ #Has the facility evaluated feasible alternatives to current practices? ❑ 0 0 0 #Does the facility provide all necessary secondary containment? ❑ N ❑ #Does the Plan include a BMP summary? 0 0 0 ❑ #Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 0 ❑ #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ 0 D #Does the facility provide and document Employee Training? 0 ❑ M 0 #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? 0 El M El Has the Stormwater Pollution Prevention Plan been implemented? Comment: Sample records review Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? . Comment: data review and conversations with the EHS Mana er with Catwer illar has brought to light that samples are not beinq collected and submitted as required 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: Review of the files and correspondance with EHS Manager Trina Briggs revealed that samples were not being collected and submitted as required Permit and Outfalls Yes No NA NE #Is a copy of the Permit and the Certificate of Coverage available at the site? 0 0 #Were all outfalls observed during the inspection? ❑ 0 #If the facility has representative outfall status, is it properly documented by the Division? OOMn #Has the facility evaluated all illicit(non stormwater)discharges? 0 D NO Comment: NA Page 3 of 3