NCS000233_COMPLIANCE_20131216

-- -—STORIVIVUATER-DIVISION-CODING-SHEET-- --
PERMIT NO.
NC ODD 2 3�
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
''* COMPLIANCE
❑ OTHER
DOC DATE
� 2013 12 I (o
YYYYMMDD

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NCDENR
North Carolina Department of Environment and Natural Resources
Tracy E. Davis, PE, CPM Division of Energy, Mineral, and Land Resources
Director Land Quality Section
December 16, 2013
Trinity Manufacturing Company, Inc.
Attn: Victor J. Perreault
11 E.V. Hogan Drive
Hamlet, NC 28345
Subject: COMPLIANCE EVALUATION INSPECTION
Trinity Manufacturing Company, Inc.
NPDES Stormwater Individual Permit- N C S000233
Richmond County
Dear Mr. Perreault:
Pat McCrory, Governor
John E. Skvarla, III, Secretary
On December 11, 2013, a site inspection was conducted for the Trinity Manufacturing Company, Inc. facility located at
11 E.V. Hogan Drive in Richmond County, North Carolina. A copy of the Compliance Inspection Report is enclosed for
your review. Ms. Karen Messana, EHS & Regulatory Compliance Manager, Mr. Todd Barnes, Manufacturing Operations
Manager, and Ms. Belinda Furby, Plant Safety Coordinator were also present during the inspection and their time and
assistance is greatly appreciated. Permit coverage authorizes the discharge of stormwater from the.facility to receiving
waters designated as a UT to Falling Creek, a Class WS-I11 stream in the Yadkin River Basin. The site visit and file
review revealed that the subject facility is covered by NPDES Stormwater Individual Permit-NCS000233.
As a result of the inspection, the facility was found to be in compliance with the conditions of the NCS000233 permit.
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Please be advised that violations of the NPDES Stormwater Individual Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff has any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or by a -mail at
m ike.lawyer @ ncde n r. gov.
Sincerely,
Michael Lawyer, CPSWQ
Environmental Specialist
Enclosure(s)
cc: FRO — Land Quality Section, Stormwater Files-NCS000233
Fayetteville Regional Office 225 Green Street — Suite 714, Fayetteville, North Carolina 28301
Phone: [phone]/FAX: [phone]-internet: http://portal.ncdenr.org/web/ir/iand-quality
An Equal Opportunity / Affirmative Action Employer

�Y
Compliance Inspection Report
Permit: NGS000233 • Effective: 03/01/12 Expiration: 02/28/17 Owner: Trinity Manufacturing Co Inc
SOC: Effective: Expiration: Facility: Trinity Manufacturing Co Inc
County: Richmond 11 Ev Hagan Dr
Region: Fayetteville
Contact Person: Victor J Perreauli
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
On -site representative
On -site representative
Related Permits:
Hamlet NC 28345
Title: Phone: [phone]
Certification: Phone:
Karen Messana Phone: 910-41"566
Belinda Furby Phone:
Todd Barnes Phone: [phone]
Inspection Date: 12/1112013 Entry Time: 09:30 AM
Primary Inspector: Mike Lawyer�jtjj
Secondary Inspector(s):
Sally Y Castle
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Exit Time: 11:50 AM
Phone: [phone]
Ext.729
Phone:
Inspection Type: Compliance Evaluation
E
Page: 1

Permit: NCS000283 Owner - Facility: Trinity Manufacturing Co Inc
Inspection Date: 12/11/2013 Inspection type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted in conjunction with the inspection of two sediment and erosion control plans (sedimentation
inspection reports enclosed with stormwater inspection report letter). Met with Mr. Todd Barnes, Manufacturing
Operations Manager, Ms. Karen Messana, EHS & Regulatory Compliance Manager, and Ms. Belinda Furby, responsible
for employee training.
Reviewed the facility's Stormwater Pollution Prevention Plan (SWPPP) and documentation of semi-annual Qualitative
Monitoring and Analytical Monitoring. Qualitative and Analytical Monitoring is conducted and recorded per the conditions
of the permit for the facifity's single outfall. The SWPPP was well written, appeared to be kept up to date with changes,
and contained all permit requirements with the exception of employee training. Employee training records are kept in a
separate notebook. Employee training was well -documented.
Stormwater is directed into a single outfall via vegetated ditches and a detention pond. This outfall is easily accessed.
Secondary containment for the chemical storage areas was observed but was not the focus of the inspection. The facility
has the capability of discharging releases from the secondary containment into a pretreatment system that drains to the
City of Rockingham POTW. The facility appeared to be well -maintained and implementing a pro -active approach to
stormwater management.
Page: 2

Permit: NCS000233 Owner - Facility: Trinity Manufacturing Co Inc
Inspection Date: 12/11/2013 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? ■ ❑ ❑ Cl
# Does the Plan include a General Location (USGS) 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?
■
Cl
❑
❑
# 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?
■
Cl
❑
❑
# 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?
■
f7
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment:
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
D
Comment:
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:
Permit and Outfalls
Yes
No
NA
NE
# 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? ❑ Cl ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑
Comment:
Page: 3

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
October 31, 2011
Trinity Manufacturing Company, Inc.
Attn: Victor J. Perreault
PO Box 1519
Hamlet, NC 28345
Subject: COMPLIANCE EVALUATION INSPECTION
Trinity Manufacturing Company, Inc.
NPDES Stormwater Individual Permit-NCS000233
Richmond County
Dear Mr. Perreault:
Dee Freeman
Secretary
On October 25, 2011,1, Michael Lawyer from the Fayetteville Regional Office of the Division of Water
Quality, conducted a site inspection for the Trinity Manufacturing Company, Inc. facility located at
11 E. V. Hogan Drive, Hamlet, Richmond County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Mr. David Rose, Plant Manager, Ms. Karen Messana,
EHS & Regulatory Compliance Manager, and Mr. Todd Barnes, Manufacturing Operations Manager,
were also present during the inspection and their time and assistance is greatly appreciated. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as
South Prong Falling Creek, a Class C stream in the Yadkin River Basin; however this should be revised
upon permit renewal to Falling Creek, a Class WS-111 stream in the Yadkin -Pee Dee River Basin. The
site visit and file review revealed that the subject facility is covered by NPDES Stormwater Individual
Permit-NCS000233.
Accordingly, the following observations were noted during the Division of Water Quality inspection:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented.
es■ No❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
es■ No❑
Location: 225 Green Street, Suite 714, Fayetteville, North Caroiina 28301
Phone: [phone] FAX: [phone] t Customer Service:1-877-623-6748
Internet: h1p:/Jportal.ncdenrorg1weblwq
An Equal Opportunity', AfElrmalive Action Employer
One
NorthCarolina
Nah rally

Other Observations: ♦' "'
Please refer to the enclosed Compliance Inspection Report for any additional comments and
observations made during the inspection.
Requested Response:
A response is not requested at this time.
Please be advised that violations of the NPDES Stormwater Individual Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff has any questions,
comments, or needs assistance with understanding any aspect of your permit, please contact me at (910)
433-3329, or by e-mail at [e-mail].
Sincerely, ;
Michael Lawyer, CPSWQ
Environmental Specialist
Enclosure
cc: FRO -Surface Water Protection '
Niki Maher-WBS Compliance & Permits Unit
DWQ Central Files

Compliance Inspection Report
Permit: NCS000233 Effective: 03/02/07 Expiration: 03/01/12 Owner: Trinity Manufacturing Co Inc
SOC: Effective: Expiration: Facility: Trinity Manufacturing Co Inc
County: Richmond 11 Ev Hogan Dr
Region: Fayetteville
Hamlet NC 28345
Contact Person: Victor J Perreault Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
On -site representative
On -site representative
Related Permits:
David Rose
Todd Barnes
Karen Messana
Certification:
Inspection. Date: 10/25/2011 Entry Time: 01:40 P Exit Time: 04:00 PM
Phone:
Phone: [phone]
Phone: [phone]
Phone: [phone]
Primary Inspector: Mike Lawyer Phone: [phone]
Secondary Inspector(s): , �, Ex�S
�^ /lj_ J 33zl
Belinda S Henson c t�( Phone: [phone] Ext.726
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCS000233 Owner - Facility: Trinity Manufacturing Co Inc
Inspection Date: 10/25/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted in conjunction with site visit for permit renewal. Met with Mr. David Rose, Plant Manager, Ms. Karen
Messana, EHS & Regulatory Compliance Manager, and Mr. Todd Barnes, Manufacturing Operations Manager. Reviewed
facility's Stormwater Pollution Prevention Plan (SWPPP) and documentation of semi-annual Qualitative Monitoring. The
SWPPP was well written and contained all permit -required components. Qualitative Monitoring is conducted and recorded
per the conditions of the permit for the facility's single outfall. Discussed potential revisions to the facility's individual
stormwater permit upon renewal, including the proposed addition of semi-annual Analytical Monitoring. Made
observations of site conditions focusing on the chemical storage areas with secondary containment and routing of
accumulated stormwater in these areas to the facility's pretreatment system that drains to the City of Rockingham POTW.
Also observed areas with stormwater drainage to vegetated ditch and retention pond leading to single outfall. Facility
appeared to be very well maintained with proactive approach to stormwater management.
Page: 2

Permit: NC$000233 Owner - Facility: Trinity Manufacturing Co Inc
Inspection Date: 10/25/2011 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?
# 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
❑ ❑ ■ ❑
❑❑■❑
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
Page: 3