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NCG030533_Meritor Heavy Vehicle Systems NOD_20240425
NI ETBISER t-: (4:1_'''.°4' .,,, Secretary 1,i1, WILLIAM E.TOBY VINSON,JR NORTH CAROLINA Interim Director Environmental Quality May 23, 2024 CERTIFIED MAIL: 9589 0710 5270 0597 7462 96 RETURN RECEIPT REQUESTED Mentor Heavy Vehicle Systems LLC Attn: Chris Drose 22021 Skyway Church Road Maxton, NC 28364 Subject: NOTICE OF DEFICIENCY(case#NOD-2024-PC-0093) NPDES Stormwater General Permit NCG030000 Mentor Heavy Vehicle Systems LLC Mentor Heavy Vehicle Systems LLC, Certificate of Coverage NCG030533 Scotland County Dear Mr. Drose: On April 25, 2024, Kelly Jonas and Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Mentor Heavy Vehicle Systems facility located at 22021 Skyway Church Road, Maxton, Scotland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Stephanie Kane, EHS Supervisor, was present during the inspection and her 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 NCG030533. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Lumber River,class WS-IV, B; SW, HQW waters in the Lumber River Basin. As a result of the site inspection, the following deficiencies are noted: • The Stormwater Pollution Prevention Plan has not been fully implemented per the conditions of the NPDES General Permit NCG030000. 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 deficiency has occurred as well as a Plan of Action with reasonable timeframe to address this deficiency. Q North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources 5Fayetteville Regional Office I225 Green Street.Suite 714{ Fayetteville.North Carolina 28301 .r:�.1-,C.l2ill , DeM, ntoi Emitonmenm Nal I joe6.4 910.4333300 Action Items 1. Update the detailed map to include contours, stormwater control measures (SCMs), and best management practice (BMP) measures. 2. Conduct and document quarterly Good Housekeeping inspections that include the outfall, SCMs, and BMP measures. 3. Complete the list of responsible parties for the Spill Prevention and Response Plan (SPRP)with all required names, roles, signatures, and dated. 4. Conduct annual illicit discharge evaluation. 5. Document annual SWPPP review. 6. Register for eDMR (online portal for submitting Analytical Monitoring reports). 7. Provide a locking mechanism for the diesel aboveground storage tank(AST). Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and detailed in the enclosed inspection report, be properly resolved. Failure to address the deficiencies could result in the issuance of a Notice of Violation,which is subject to a civil penalty assessment of up to $25,000 per day for each violation. Should you have any questions or concerns, please contact Kelly Jonas or myself at(910)433-3300. Sincerely, imothy L. LaBo ty, PE Regional Engineer DEMLR TL/kbj Enclosure: Compliance Inspection Report ec: Stephanie Kane, EHS Supervisor— Meritor Heavy Vehicle Systems 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 cc: FRO— DEMLR, Stormwater Files Compliance Inspection Report Permit:NCG030533 Effective: 07/01/21 Expiration: 06/30/26 Owner: Meritor Heavy Vehicle Systems LLC SOC: Effective: Expiration: Facility: Meritor Heavy Vehicle Systems LLC County: Scotland 22021 Skyway Church Rd Region: Fayetteville Maxton NC 28364 Contact Person:Stephanie Kane Title: EHS Supervisor Phone:910-844-8360 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 04/25/2024 Entry Time 09:20AM Exit Time: 10:55AM Primary Inspector:Kelly Jonas Phone: 910-433-3300 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: 0 Compliant ElNot Compliant Question Areas: III Storm Water (See attachment summary) Page 1 of 3 Permit: NCG030533 Owner-Facility:Mentor Heavy Vehicle Systems LLC Inspection Date: 04/25/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: Kelly Jonas and Melissa Joyner met with Stephanie Kane, HSE Lead, to conduct an industrial stormwater inspection of the Meritor-Cummins facility in Maxton, NC. The Stormwater Pollution Plan (SWPPP)was reviewed per the conditions of the National Pollutant Discharge Elimination System (NPDES)General Permit NCG030000. The current plan was reviewed and appeared fairly complete, but has not been fully implemented. The detailed map needs to include contours, stormwater control measures (SCMs)and best management practice (BMP) measures. Good Housekeeping inspections are conducted regularly but have not been documented.The annual SWPPP review has been conducted but not documented. The list of responsible parties in the Spill Prevention and Response Plan (SPRP)needs to include the maintenance team, as well as be signed and dated.The annual evaluation for illicit(non-stormwater)discharges has not been conducted. Qualitative and Analytical Monitoring has been conducted per the conditions of the General Stormwater Permit NCG030000. The facility is not registered on the eDMR(electronic discharge monitoring report)system. The facility grounds were inspected, including one 1,204-gallon diesel aboveground storage tank(AST)and one outfall. The facility grounds could use maintenance, but at the time of the inspection was not impacting the outfall or SCMs. The diesel AST needs to be secured with a locking mechanism. The following corrective actions are required: 1. Update the detailed map to include contours,SCMs and BMP measures.; 2. Conduct and document quarterly Good Housekeeping inspections that include the outfall,SCMs and BMP measures.; 3. Complete the list of responsible parties for the SPRP with all required names, roles, signatures and dated.;4. Conduct annual illicit discharge evaluation.; 5. Document annual SWPPP review.; 5. Register for eDMR.; 6. Provide a locking mechanism for the diesel AST. Page 2 of 3 Permit: NCG030533 Owner-Facility:Mentor Heavy Vehicle Systems LLC Inspection Date: 04/25/2024 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? • 0 0 0 #Does the Plan include a General Location(USGS)map? • 0 0 0 #Does the Plan include a"Narrative Description of Practices"? • ❑ 0 0 #Does the Plan include a detailed site map including outfall locations and drainage areas? • 0 ❑ ❑ #Does the Plan include a list of significant spills occurring during the past 3 years? • 0 0 ❑ #Has the facility evaluated feasible alternatives to current practices? • 0 0 0 #Does the facility provide all necessary secondary containment? • ❑ ❑ 0 #Does the Plan include a BMP summary? • ❑ ❑ ❑ #Does the Plan include a Spill Prevention and Response Plan(SPRP)? • ❑ ❑ 0 #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? El • ❑ 0 #Does the facility provide and document Employee Training? • ❑ ❑ 0 #Does the Plan include a list of Responsible Party(s)? ❑ • ❑ ❑ #Is the Plan reviewed and updated annually? 0 • 0 0 #Does the Plan include a Stormwater Facility Inspection Program? • 0 ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 II ❑ ❑ Comment: The Stormwater Pollution Prevention Plan has not been fully implemented per the conditions of the NPDES General Permit NCG030000. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? • ❑ El 0 Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? • El ❑ ❑ #Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ • ❑ Comment: Permit and Outfalls Yes No NA NE #Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ 1E ❑ ❑ #Were all outfalls observed during the inspection? • ❑ 0 ❑ #If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ • ❑ #Has the facility evaluated all illicit(non stormwater)discharges? 0 • El ❑ Comment: Page 3 of 3 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF ENERGY, MINERAL,AND LAND RESOURCES GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030533 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Meritor Heavy Vehicle Systems LLC is hereby authorized to discharge stormwater from a facility located at: Meritor Heavy Vehicle Systems LLC 22021 Skyway Church Rd Maxton Scotland County to receiving waters designated as LUMBER RIVER, class WS-IV,B;Sw,HQW waters in the Lumber River Basin(s), in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in General Permit No. NCG030000 which can be downloaded by entering"deq.nc.gov/SW-industrial" in the browser window and navigating to the "NPDES Stormwater General Permits" web page. This certificate of coverage shall become effective July 1, 2021. This Certificate of Coverage shall remain in effect for the duration of the General Permit. for Brian Wrenn Director, Division of Energy, Mineral and Land Resources By the Authority of the Environmental Management Commission I U.S. Postal Service`" r e...... -nu- CERTIFIED MAIL® RECEIPT © Domestic Mail Only J For delivery Information,visit our website at www.usps.com`'' 0 z . o o ` r. r- Certified Mail Fee it u rr cr $ t.rl o oI . 1-1-1 inExtra Services&Fees(check box,add fee as appropriate) D w Q D In Return Receipt(hardcopy) $ w LLo ❑Return Receipt(electronic) $ Postmark a W CIO ['Certified Mall Restricted Delivery $ Here rU 2E ri �r ❑Adult Signature Required $ a ui F¢ Lim Lai to ❑Adult Signature Restricted Delivery$ e t Postage CI Yw ~ CI o $ r UQ re- N= Ima. ,-a Total Postage and Fees o <LL W o a $ a (1.1) ° IIIIINMENNIMI Sent To U— era a- a- t:0 111.11111.111.1111Mc13 LID Street and Apt.No.,or P6 Box No. ou Ln ��� Ii to Er I Q' City,State,Z1P+4a PS Form 3800 Janua 2023 PSN 7530-02•000-9047 See Reverse for Instructions