NCG030229_Tier Three Letter_20190829

Moore, James
From:
Moore, James
Sent:
Thursday, August 29, 2019 9:08 AM
To:
[e-mail]
Cc:
Khan, Zahid
Subject:
Eaton Kings Mountain NCG030229
Attachments:
jm-08292019.pdf
Thank you for your August 20, 2019 Tier Three letter regarding 4 exceedances for copper at one of your outfalls. Please
continue to evaluate possible sources of copper per the letter and please submit a follow up report at the end of 2019
with the monitoring data summarized on an Excel spreadsheet. In the mean time should you have any questions or if
you want to schedule a technical assistance inspection please do not hesitate to contact me.
James Moore
Assistant Regional Engineer
Land Quality Division
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone] x2135
Fax: [phone]
Email: [e-mail]
Mailing Address: 610 E. Center Ave. Suite 301
Mooresville, NC 28115
Jti"Nothing Compares.---,,,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

Es l*N
Powering Business Worldwide
August 20, 2019
Mr. Zahid Khan
NCDENR-DEMLR
Stormwater Section
610 East Center Avenue
Suite 301
Mooresville, NC 28115
RE: Eaton Corporation — Kings Mountain
General Permit No. NCG030000
Certificate of Coverage No. NCG030229
Dear Mr. Khan:
Eaton
Vehicle Group
P.0 Box1728
744 S Battleground Ave.
Kings Mountain, NC 28086
Eaton Corporation operates a facility producing transmissions and components for the commercial
trucking industry in Kings Mountain, North Carolina, which has coverage under the Metal Fabrication
General Stormwater Permit No. NCGO30000 ("Permit").
The facility has had more than four' exceedances of the benchmark values at one of the six outfalls on
site. As required by the Tier Three response actions in the Permit, Eaton is providing notification of
benchmark value exceedances for Copper.
The benchmark value exceedances of Copper occurred at Outfall 002. As a result of the exceedances of
the benchmark values, Eaton initiated the response actions for Tier One and Tier Two as required in the
permit to limit the impact of Copper on the stormwater. These actions include:
• Verified the PM for changing dust collector filters at the shot peen/clean area. Filters have been
changed.
• Verified material composition of amasteel shot
• Peat moss socks have been ordered
• Reviewed outfall area housekeeping expectations
• A sampling of AC condensate water has been ordered for quantitative verification
Eaton has also reviewed the manufacturing activities to identify potential sources of Copper. The
facility operates an enclosed fabrication area where solid carbon steel components are processed
through heat treating, shot blasting/peening and machining processes. Both the carbon steel (i.e.
ETN22 grade) and the steel shot media contain less than 0.25% Copper. Considering the enclosed
manufacturing processes and the BMPs in place, Eaton is still investigation the potential source of
Copper for the benchmark level exceedances. In addition, there have been no changes to the
' One exceedance occurred under the new 2018 benchmark values; however the site was already subject to the Tier
requirements due to previous benchmark value exceedances for outfall 002 under the previous permit.

manufacturing operations that could have increased the potential of this metal to be present in the
stormwater discharge.
While Eaton has promptly responded with follow-up actions, continues to inspect the drainage area and
evaluate the facility for opportunities to reduce impacts to stormwater, Eaton believes that more
investigation on potential sources is needed to further evaluate the actions taken. We propose
collecting of additional representative samples for four months and then submitting an update to this
letter.
Pleased contact me at 704-937-7331 or [e-mail] if you have any questions or need
additional information.
Sincerely,
Katia Almeida
EHS Manager
Eaton — Kings Mountain