NCG030547_COMPLETE FILE - HISTORICAL_20140515

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• - - STORMWATER DIVISION CODING SHEET
RESCISSIONS .
PERMIT NO..
DOC TYPE
L9'COMPLETE FILE -HISTORICAL
DATE OF
.RESCISSION
YYYYMMDD

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Pickle, Ken
From:
Taylor -Smith, Aana
Sent:
Thursday, May 15, 2014 1:57 PM
To:
Pickle, Ken; Georgoulias, Bethany
Subject:
NCG03.tiered response inspection
Attachments:
TE Connectivity 05-15-14.pdf
Hi there,
1 just wanted to send this along for your records. I went to TE Connectivity (formerly Tyco Electronics) today to discuss
tiered response actions for copper and zinc at that facility. This is another company that has been very diligent in trying
to find potential sources of copper and zinc. They have spent tens of thousands of dollars and many work hours
conducting weekly facility inspections, sampling various points from the roof and other areas of the building, having the
roof completely cleaned, etc. The facility also has no outdoor industrial activity or storage at all. They are going to apply
for no exposure, which I suppose solves their tiered response problem.
They did mention that when the HVAC system was last serviced, a Rust-Oleum product containing zinc (something like
this: htto://www.rustoleum.com/product-cataloe/industrial-brands/hieh-oerformance/hiah-heat-coatines/4200-system-
high-heat-grav-zinc-sele/) was used to control corrosion. This product is very common in many industries and
commercial facilities, which raises concern for me because it is not directly involved with industrial activity. Any building
with HVAC could use it — including schools, office buildings, hospitals, etc. It would be hard for us to regulate the use of
this kind of product in industries when we can't restrict its use throughout the state. Just a thought...
Please feel free to contact me with any questions or concerns!
Thanks,
Aana Taylor -Smith
Land Quality Section
Division of Energy, Mineral, and Land Resources
NC DEN Winston-Salem Regional Office
Phone: [phone]
Fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

FMA
KNEW
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
15 May 2014
TE Connectivity
Attn: Delores Green
719 Pegg Road
Greensboro, NC 27409-9672
Subject: Technical Assistance Inspection & Tiered Response Requirements
NPDES General Stormwater Permit NCG030000
Certificate of Coverage NCG030547
TE Connectivity
Guilford County
Dear Ms. Green:
John E. Skvarla, III
Secretary
Aana Taylor -Smith of the Winston-Salem Regional Office of the NC Division of Energy, Mineral, and Land
Resources (DEMLR) met with you to discuss tiered response requirements for the NCG030000 permit for metal
fabricators at the subject facility on 15 May 2014. Your assistance and cooperation were greatly appreciated.
This facility is located at 719 Pegg Road in Greensboro, Guilford County, North Carolina. Stormwater related to
industrial activity is discharged from the site to the East Fork Deep River, which is currently classified as Class WS-
IV Waters, in the Cape Fear River Basin.
Documentation & Monitoring Review
This meeting was held to assess compliance with NPDES General Stormwater Permit NCG030000 and evaluate
drainage to the facility's two Stormwater Discharge Outfalls (SDOs). Monthly monitoring has been triggered by
consecutive exceedances of the copper and zinc benchmarks at both outfalls. Please keep in mind that benchmark
exceedances are not limit violations or violations of permit conditions; however you are obligated to follow the
tiered response actions outlined in your permit. TE Connectivity has been following the tiered response actions
and is therefore in compliance with the permit. Both qualitative and analytical monitoring have been completed
as required.
Site Review
The facility is very clean and well maintained. Secondary containment is implemented as required. No vehicle
maintenance takes place on site. It was noted during the inspection that this facility qualifies for No Exposure
Certification. No industrial activity takes place outside and storage of all materials and wastes is either indoors or
under secure cover. It is highly recommended that TE Connectivity apply for No Exposure Certification, which
would eliminate the need for the NCG030000 permit as long as the facility abides by No Exposure requirements.
More information, along with the application form, can be found at the following website:
http-Lportal.ncdenr.org/web/lrinpdes-stormwater#tab-5
Division of Energy, Mineral, and Land Resources
Land Quality Section - Winston-Salem Regional Office
5135 Waughtown Street, Winston-Salem, NC 27107 - Phone: [phone] / FAX: [phone]

TE Connectivity
05/15/2014
Page 2 of 2
Tiered Reseonse Requirements
Currently, monthly monitoring is required in response to two consecutive exceedances of the benchmark values
or range for any specific parameter at a specific SDO. TE Connectivity has completed monthly monitoring for both
outfalls as well as taking actions to identify and eliminate potential sources of pollution. Facility inspections are
now conducted weekly. The roof was thoroughly cleaned and inspected for potential sources of contaminants.
Additional sampling has been undertaken at various points on the roof to determine potential contribution from
HVAC units and coatings such as Rust-O-Leum. Zinc levels detected in those sample results indicated that zinc may
reach the outfalls from structural components not related to industrial activity. Housekeeping and site
maintenance practices have been reviewed and improved.
TE Connectivity has achieved ISO 14001 certification for environmental management and zero discharge status.
The facility also has applied for the NC DEN Environmental Stewardship Initiative program and is taking steps to
achieve zero waste to landfill status. TE Connectivity continually takes measures to reduce the potential for
stormwater contamination on site and has a very rigorous environmental program.
At this time, the Division concurs that more frequent monitoring at this site would be ineffective. The Division
relieves you of the additional monitoring frequencies required in the Tiered Response section of this permit for
copper and zinc. You must continue to monitor semi-annually as required by the permit, but you will not be
required to institute monthly monitoring for any future exceedances of the copper and zinc parameters at SDO #1
or SDO #2. Tiered response requirements still apply for all other parameters.
You must notify this office in writing within five business days if you become aware of any significant source of
copper or 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 and housekeeping actions at this facility. If industrial practices
change and copper and/or zinc become a significant stormwater exposure risk, this office reserves the right to
withdraw this decision and reinstate the permit -specified tiered response or other actions that may be warranted.
We appreciate your efforts to comply with the stormwater permit and the proactive steps taken to identify and
eliminate potential sources of pollution. No additional response to this letter is required, but please append this
letter to your SPPP to document that your facility has been relieved of monthly monitoring requirements for the
specified parameters. Should you have any questions regarding the NCG030000 permit or this letter, please do
not hesitate to contact Ms. Taylor -Smith or me at [phone].
Sincerely,
Matthew E. Gantt, PE
Regional Engineer
Land Quality Section
Attachments: BIMS Inspection Checklist
cc: Ken Pickle, SPU
Debbie Shoff ner (City of Greensboro stormwater Management Division, via email: [e-mail])
Central Files
WSRO/LQ

Compliance Inspection Report
Permit: NCG030547 Effective: 11/01/12 Expiration: 10/31/17 Owner: T E Connectivity
SOC: Effective: Expiration: Facility: T E Connectivity
County: Guilford 719 Pegg Rd
Region: Winston-Salem
Greensboro NC 27409
Contact Person: Darren Kemp Title: Phone: 33"65-4472
Directions to Facility:
Hwy 68 S. from 1-40 to Throndike Road, Right on Thorndike, L onto Pegg Road, App. 1/2 mile on left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 0511512014 Entry Time: 09:00 AM Exit Time: 10:00 AM
Primary Inspector: Aana Taylor -Smith Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Technical Assistance
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG030547 Owner • Faculty: T E Connectivity
Inspection hate: 05/15/2014 Inspection Type: Technical Assistance Reason forVisit: Routine
Inspection Summary:
Please refer to inspection letter.
Pag e: 2

Permit: NCGO30547 Owner - Facility: T E Connectivity
Inspection Date: 05/1512014 Inspection Type: Technical Assistance
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a Gereral 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?
Reason for Visit: Routine
Comment: SPPP is complete, thorough, and up to date. No spills have occurred in
past 3 years.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: Facility has stepped up qualitative monitoring as a part of the tiered
response.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Analytical monitoring is performed monthly as a result of tiered response
for copper and zinc at both outfalls. Analytical monitoring has also been performed on
samples taken from various points on the roof, at the front of the building, and upstream
of the outfalls as a part of the tiered response.
Permit and Outfalls
# is a copy of the Permit and the Certificate of Coverage avaliable at the site?
# Were all outfalls observed during the inspection?
Yes No NA NE
■ ❑ ❑ ❑
Yes No NA NE
■ ❑ Q ❑
❑ ❑ ■ ❑
Yes No NA NE
■ ❑ ❑ ❑
Page: 3

Permit. NCG030541 Owner - Facility: T E connectivity
Inspection Date: 0511512014 Inspection Type. Technical Assistance Reason for Vlslt: Routine
# If the facility has representative outfall status, is it properly documented by the Divislon? ■ 13 ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑
Comment: ROS was granted in 2012 and is properly documented. Outfall #2 is
representative of #3. The facility is very clean and well maintained and qualifies for No
Exposure Certification.
Page: 4