NCS000155_NOV_20191019

ROY COOPER
Govcrr:or
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Ditwor
NORTH CAROLINA
Environmental Quality
October 19, 2019
CERTIFIED MAIL 7016 3560 0000 4428 6154
RETURN RECEIPT REQUESTED
GKN Driveline
Attn. Charles Corwin, Site Director
4901 Womack Road
Sanford, NC 27330
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0706)
GKN Driveline - Sanford Precision Facility
NPDES Individual Industrial Stormwater Permit No. NCS000155
Lee County
Dear Mr. Corwin,
The subject facility is covered by NPDES Individual Industrial Stormwater Permit
NCS000155. Permit coverage authorizes the discharge of stormwater from the facility to
receiving waters designated as Little Buffalo Creek, a class C stream in the Cape Fear River
Basin.
On April 27, 2019, Lauren Garcia from the Raleigh Central Office of the Division of Energy,
Mineral, and Land Resources (DEMLR), conducted a compliance inspection for the GKN
Driveline facility located at 4901 Womack Road, in Lee County, North Carolina. For your
reference, a copy of the Inspection Report issued by DEQ is enclosed with this notice. This
report lists and describes the violations of the facility's permit conditions, which
constitutes a violation of the Clean Water Act and is grounds for enforcement action. The
inspection was conducted to ensure stormwater best management practices are being
followed, and to help fulfill NCDEQ's goal of inspecting all permitted facilities during each
permit period. A copy of the Compliance Inspection Report is enclosed for your review.
As a result of the compliance inspection, the following permit condition violations were
noted:
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1) Part 11. Sectionm Il i n Prevention Plan
The facility is required to review and update the SWPPP on an annual basis.
Implementation of the SWPPP includes the documentation of all monitoring 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. 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.
Employee Training and Responsible Parties are required sections of the SWPPP. 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.
2) Part Ill. tin E:-Reporting Requirements
The facility is required to submit duplicate signed copies of all Discharge Monitoring
Reports (DMRs) to the Division no later than 30 days from the date the facility receives the
sampling results from the laboratory.
Rye uired ResponsC_
You are directed to respond to this office, in writing, within 30 calendar days from the
receipt of this notice. Your response shall include, at minimum:
1) A reasonable explanation as to why the aforementioned violations occurred,
includLog but not limited to:
a. An explanation as to why DMRs were not available upon request at the Facility.
b. An explanation For why DMRs have not consistently been submitted to the Division
in the manner outlined in the permit.
2) AA SWPPP updated to the specifications of the rmi
3) A reasonable timetable -for completion of all actions to be taken in response to the
aforementioned violations. including the corrective actions outlined in the InspCction
Report,

Thank you for your attention to this matter. Your above -mentioned response to this
correspondence will be considered in any enforcement proceedings. This office requires
that the violations, as detailed above, be properly resolved. These violations and any
future violations are subject to a civil penalty assessment of up to $25,000 per day
for each violation. Should you have any questions regarding these matters, please contact
Thad Valentine at [phone] or thad.valentinePncdenr.gov.
Sincerely,
W 9
William Denton, PE
Regional Engineering Supervisor
Land Quality Section
Division of Energy, Mineral, and Land Resources
North Carolina Dept. of Environmental Quality