NCS000155_GKN Driveline Updated Compliance Inspection20190703

ROY COOPER
Governor
MICHAEL S. REGAN
Sea clue y
S. DANIEL SMITH
Interim Director
NORTH CAROLINA
Environmental Quality
July 3, 2019
GKN Driveline
Attn. Charles Corwin, Site Director
4901 Womack Road
Sanford, NC 27330
Subject: Compliance Inspection
Permit No. NCS000155
GKN Driveline - Sanford Precision Facility
Lee County
Dear Mr. Corwin:
On April 27, 2019, Lauren Garcia with the North Carolina Department of
Environmental Quality (NCDEQ) - Division of Energy, Mineral and Land Resources
(DEMLR), met with James McBride, Safety and Quality Risk Manager, at the facility located
at 4901 Womack Road, Sanford, Lee County, to conduct a compliance inspection. The
inspection consisted of reviewing: the Stormwater Pollution Prevention Plan (SWPPP) and
each of its components, the facility's outfalls, and the overall site conditions. The inspection
was conducted to ensure stormwater best management practices are being followed, to
help fulfill NCDEQ's goal of inspecting all permitted facilities during each permit period,
and to confirm the permit adequately reflects the needs of the facility now that the permit
is in the process of renewal.
It should be noted the facility's EHS Specialist and original point of contact, Christopher
Blaine, was suddenly made unavailable to the facility, closely following the beginning of the
renewal process in April 2019. Due to a serious illness, Christopher Blaine was forced to
take multiple months of medical leave. During this time, the Division was not notified of the
temporary change in personnel and continued with renewal processes and compliance
inspection.
Permit:
This facility has Individual Stormwater Permit NCS000155 to discharge stormwater from
the industrial activity of manufacturing motor vehicle parts and accessories [SIC 3714]
under the National Pollutant Discharge Elimination System (NPDES). The current permit
was issued on September 8, 2008.
North Carolina Department of Environmoital Quality 1 Division of Energy, Mineral and land Resources
r.-D-E% 512 North Salisbury Street i 1612 Mail Service Center ( Raleigh, North Carolina 27699-1612
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Records/Reports:
The facility is required to keep a copy of the permit and certificate of coverage available at
the site.
• A copy of the permit and certificate of coverage was not available onsite.
The facility is required to develop and maintain a SWPPP in accordance with Part II, Section
A of the permit. All qualitative and analytical monitoring records are required to be
maintained with the SWPPP for a minimum of five years. Implementation of the SWPPP
includes the documentation of all monitoring, measurements, inspections, maintenance
activities, and training provided to employees, including the log of the sampling data and of
actions taken to impletnettt BMPs associated with the industrial activities, including vehicle
maintenance activities. Such documentation shall be kept on -site for a period of five years
and made available to the Director or the Director's authorized representative immediately
upon request, in accordance with Part II, Section A, Item 9 of the permit.
• Monitoring data was not available upon request at the site, except for approximately
three lab analytical reports, dated 2017, 2018, and 2019. The site contact was
unable to provide any Discharge Monitoring Reports (DMRs) for the current permit
term (2008-2019).
The facility is required to review and update the SWPPP on an annual basis in accordance
with Part II, Section A, Item 7 of the permit.
• The SWPPP has not been updated since 2017.
Employee Training and Responsible Parties are required sections of the SWPPP, in
accordance with Part II, Section A, Items 5 and 6 of the permit. Training programs shall be
developed for facility personnel with responsibilities for: spill response and cleanup,
preventative maintenance activities and for any of the facility's operations that have the
potential to contaminate stormwater runoff. Facility personnel (or team) responsible for
implementing the training shall be identified, and their annual training shall be
documented by the signature of each employee trained. The Stormwater Pollution
Prevention Plan shall identify a specific position(s) responsible for the overall
coordination, development, implementation, and revision to the Plan. Responsibilities for
all components of the Plan shall be documented and position assignments provided.
• Responsible Parties and Employee training records were present in the SWPPP, accurate
through 2017; however, as stated above, requested documents could not be provided.
This was observed to be because remaining personnel were unaware of the document
locations. The exact location of Outfall 001 was also left undetermined. Several possible
Outfall 001 s were observed during the site visit.
Note: These sections of the SWPPP are intended to address situations similar to that
discussed above, where unexpected circumstances have led to a temporary change in
personnel. It is the responsibility of the facility to implement the conditions of the
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permit in its entirety, whether or not standard personnel are present at the site. This
includes the availability of the above referenced paperwork.
The facility is required to submit duplicate signed copies of all DMRs to the Division no
later than 30 days from the date the facility receives the sampling results from the
laboratory, in accordance with Part III, Section E, Items 1 and 2 of the permit.
• The Division is in receipt of only three DMRs: two from 2015 and one from 2016.
• The facility was asked to provide all DMRs and monitoring data from the current
permit term during the site visit. As stated above, monitoring data was not available
upon request at the site, except for approximately three lab analytical reports.
• When prompted, the site contact stated the facility was under the impression Pace
Analytical, the lab handling the facility's analytical testing, was sending the Division
the required DMRs.
• The Division has no records of receiving DMRs from Pace Analytical, or any other
lab, associated with the facility.
Facility Site Review:
The facility manufactures motor vehicle parts and accessories. The facility consists of two
main buildings.
• All materials, machinery, and tanks were stored/located within proper secondary
containment and/or storm -resistant shelters.
• The site appeared to be clean and well maintained.
There are three sampled outfalls present at the facility.
• The outfalls appeared to be clear of debris and were well maintained.
Receiving Waters:
Stormwater at the site discharges to Little Buffalo Creek, a class C stream in the Cape Fear
River Basin. Little Buffalo Creek is an impaired waters experiencing problems with benthos
and fish tissue mercury.
Self -Monitoring Program:
The facility is required to provide qualitative and analytical monitoring data twice annually
in accordance with the monitoring schedule detailed in Part II, Section B, page 6 of 10 of the
permit.
• As stated above, monitoring data and/or DMRs were not provided.
Corrective Actions:
• The SWPPP shall be updated annually and to the specifications outlined in the
permit;
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• A copy of the permit and certificate of coverage shall be available immediately upon
request during all future inspections;
Documentation of all monitoring (qualitative and analytical) data, measurements,
inspections, maintenance activities, and training provided to employees, including the log
of the sampling data and of actions taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities shall be available
immediately upon request during all future inspections in accordance with permit
requirements;
• Employee training programs and responsible parties shall be updated and implemented in
accordance with permit requirements; and,
• DMRs shall be submitted to the Division in accordance with permit requirements.
The determination from the inspection is the facility is not in compliance with the
conditions of their permit in its entirety. If you have any questions or need additional
information, please contact Lauren Garcia at [phone] or [e-mail].
Sincerely,
Laur n Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental
Quality
Enclosures: Inspection Report
cc: Charles Corwin, GKN Driveline - Sanford Precision Forming
ec: James McBride, GKN Driveline - Sanford Precision Forming, [e-mail]
Thad Valentine, DEMLR Raleigh Regional Office, [e-mail]
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512 North Wsbury Street i 1612 Mal Service Center ( Rai 49K North C uc na 270-44-16, 2
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