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HomeMy WebLinkAboutNCG030055_Tier Relief Letter_20170905Energy, Mineral and Land Resources ENVIRONMENTAL QUALITY September 5, 2017 Meritor Heavy Vehicle Systems LLC Attn: Hank Laughter 1000 Rockwell. Drive Fletcher, NC 28732 Subject: Relief from Monthly Stormwater Sampling Stormwater Permit # NCG030055 Meritor Heavy Vehicle Systems Henderson County Dear Mr. Laughter: .ROY COOPER Governor MICHAEL S. REGAN Secretary TRACY DAVIS Director The Division has reviewed your request for regulatory relief from monthly stormwater sampling. The facility was inspected on March 28, 2017, and was found to be in compliance.with the tiered response actions and other conditions of the NCG030000 General Permit. As noted in the follow-up email received on March 30, 2017, from Hank Laughter, Meritor Heavy Vehicle Systems LLC has performed inspections, modified and implemented additional stormwater pollution prevention measures and procedures. Also, the facility has installed sheds for storing dunnage; reviewed SDS database for material used onsite in production with zinc and copper content; installed a new sluice valve; store decommissioned equipment under roof or under cover when awaiting transfer offsite, eta As observed during the inspection and due to facility actions taken regarding investigating and correcting exceedances, the Division is granting the facility regulatory relief from the tier responses for copper and zinc. Upon receipt of this letter, the subject facility may resume the permit specified semi-annual analytical monitoring for the remainder of the current permit term which ends on October 31, 2017. This decision applies only to copper and zinc benchmarks and is valid until October 31, 2018. A benchmark exceedance of any other parameter listed in your permit will trigger the tiered response actions as described in the general permit., You must notify this office, in writing, within five business days if you become aware of any significant source of copper and zinc at your facility that has the potential to be exposed to stormwater. The relief granted in this letter is contingent upon the current industrial practices at Meritor Heavy Vehicle Systems LLC. If industrial practices change and copper or zinc does become a significant stormwater exposure risk or significant copper or zinc values have been recorded during a regular sampling event, then this office reserves the right to withdraw this decision and reinstate the permit specified tiered response or other actions that may be warranted by the new set of circumstances. State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources 2090 US 70 Highway I Swannanoa, NC 28778-8211 828 296 4500 T Monthly Monitoring Meritor Heavy Vehicle Systems September 5, 2017 Page 2 of 2 . Please retain and append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit. If you have any questions or need further information, please contact Shawna Riddle at (828) 296- 4500. Sincerely, Stanley E. Aiken, Regional Engineer Land Quality Section Enclosure: Inspection Report ec: Bethany Georgoulias, Environmental Engineer, (bethany.georgoulias@ncdenr.gov) State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources 2090 US 70 Highway I Swannanoa, NC 28778-8211 828 296 4500 T Compliance Inspection Report Permit: NCG030055 Effective: 11/01/12 Expiration: 10/31/17 Owner Meritor Heavy Vehicle Systems SOC: Effective: Expiration: Facility: Meritor Heavy Vehicle Systems County: Henderson 1000 Rockwell Dr Region: Asheville Fletcher NC 287329494 Contact Person: Mary Bowen Title: Phone: 828-687-2145 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): On-site representative Related Permits: Inspection Date: 03/28/2017 Primary Inspector: Shawna Riddle Secondary Inspector(s): Certification: Phone: Hank Laughter Entry Time: 10:OOAM 828-687-2215 Exit Time: 11:30AM Phone: 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) r Page: 1 Permit: NCG030055 Owner - Facility: Meritor Heavy Vehicle Systems Inspection Date: -.03/28/2017- Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Facility is in compliance with the SPPP. Facility had requested regulatory relief from monthly sampling for copper and zinc. Met with Hank Laughter for a tour of the facility and following inspection. The facility has taken multiple measures of correction/investigating after their first exceedance. Some of the measures are: removing saplings and underbrush from outfall #1, flume pond reduced to prevent copper and zinc from leaching into runoff, aged crossover pipes replaces and banks seeded to restore drainage and correct erosion, installed sheds for storing dunnage, replaced rusted culvert at fire pond, reviewed SDS database for material used onsite in production with copper/zinc content - verified no path existed to stormwater as a potential runoff contaminant, installed new sluice valve at water diverter pit, moved waste hoppers away from diverter pit eliminating potential contaminants of runoff, decommissioned equipment is now stored under roof or under cover when awaiting transfer offsite, installed curbing in overhead door threshold of compressor room and service team areas, etc. The request for regulatory relief from monthly sampling has been granted and the facility can return to the permit specified semi-annual monitoring. Page: 2 Permit: NCG030055 Owner - Facility: Meritor Heavy Vehicle Systems Inspection Date: 03/28/2017 Inspection Type : Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? # Does the Plan include a General Location (USES) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfall locations and drainage areas? # Does the Plan include a list of significant spills occurring during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? # Does the Plan include a BMP summary? # Does the Plan include a Spill Prevention and Response Plan (SPRP)? # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? # Does the facility provide and document Employee Training? # 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? Has the Stormwater Pollution Prevention Plan been implemented? Comment: Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: Yes No NA NE ® ❑ ❑ ❑ Yes No NA NE ■❑❑❑ ® 111:1 ❑ Yes No NA NE ® ❑ 1:11:1 ®❑ ❑ ❑ ❑❑®❑ ■❑❑❑ Page: 3