NCG090020_Tier III Notification_20230526

NC Department of
Richard Rejdovjan Environmental Quality
Plant Manager Received '
Wood Coatings Group MAY 2 6 2023 AA
Axalta Coating Systems 0 336 802-4035 AXALTA
1717 English Road M 678 314-5714 Winston-Salem
High Point,NC 27262 [e-mail]
www.axalta.com Regional Office
CERTIFIED MAIL 7020 316o 000i 3410 3498
May 24, 2023 \JC O ? OO O
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Winston-Salem Regional Office
Regional Engineer
Attn: Ms. Tamera Eplin
45o West Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105
RE: Axalta Coating Systems — 1717 W. English Road, High Point, North Carolina
General Permit No. NCGo90000/Benchmark Sampling&Corrective
Actions
Dear Ms. Eplin,
We are writing in connection with the Axalta Coating Systems (Axalta) facility in High Point,
North Carolina and benchmark sampling conducted there in accordance with North Carolina
DEQ DEMLR General Stormwater Permit No. NCGog000.
Axalta's High Point facility has conducted benchmark monitoring as required by the permit.
Since March 16, 2022,the facility exceeded benchmark values for total suspended solids(TSS)
at one outfall on five(5) occasions(see Table below). Due to an administrative oversight,the
facility inadvertently failed to timely notify DEMLR of the TSS benchmark exceedances as
required by the permit.
Outfall Sample TSS Result Comments
Date (mg/L)
SDO-oo5 3/16/22 103
SDO-oo5 9/10/22 112
SDO-005 11/27/22 154
Sample location changed from drain located in
SDO-005 1/25/23 55o street to outfall located on property-
immediately adjacent to West English Road
SDO-oo5 3/17/23 586 Sample collected from same location as 1/25/23
SDO-0o5 4/22/23 474 Sample collected from same location as 1/25/23
&3/17/23
Axalta Coating Systems,LLC
Sensitivity:Business Internal

Despite DEMLR not having been notified,Axalta has taken several corrective actions that we
believe will ultimately address the exceedances. Corrective actions implemented to date
include:
- Adding new gravel to the trailer staging yard to address possible erosion of the
original base layer of gravel. The addition of gravel did not reduce TSS numbers.
- Relocating the benchmark sampling point in an effort to eliminate background
interference from possible cross-contamination from offsite street run-off.
Counterintuitively,the change in sampling point resulted in increased(not
decreased)TSS numbers.
- Pressure washing and vacuuming-out the stormwater pipe leading to the
stormwater outfall where the exceedances had been observed. Our contractors
observed that one catch basin was covered with approximately one(1)foot of soil.
The basin chamber was blocked with sediment. The basin and the entire
stormwater pipe were both thoroughly cleaned, and all sediment was removed.
- Purchasing and installing custom-manufactured industrial storm drain filter
inserts. These inserts arrived at the facility only recently and were just installed.
With respect to the last two(2) corrective actions,both have been completed as of this
submittal. In the intervening weeks,the High Point facility has not experienced a qualifying
storm event that would result in sufficient stormwater flow for confirmatory sampling to be
completed. Our sampling team is currently on standby, and we will conduct sampling as soon as
possible in order to assess the effectiveness of all of the corrective actions cumulatively. Once
these results are received,we will update you with our findings.
Please do not hesitate to contact me if you have any questions.
Sincerely,
_ c C
Richard Rejdovja
Plant Manager
Sensitivity:Business Internal