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NCG030009_COMPLETE FILE - HISTORICAL_20140509
PERMIT NO. DOC TYPE DOC DATE STORMWATER DIVISION CODING SHEET NCG PERMITS Nc�o3o 0�9 L��ISTORICAL FILE ❑ MONITORING REPORTS YYYYMMDD Geor oulias, Bethan From: Taylor -Smith, Aana Sent: Friday, May 09, 2014 8:57 AM To: Georgoullas, Bethany Subject: RE: Thomas Built Buses (NCG03 & Tiered Response) Hi Bethany, Thomas Built wanted to sample the City water for zinc because they use it to wash buses. The place where they do bus washing is enclosed, but they just wanted to check. Finished, washed buses are stored outdoors. I haven't gotten their results from the drinking water sampling, but they said they'd send it to me by the end of the week and I can let you know how that goes if you like. The upstream sampling was done at points where contaminants by off -site industry/railroads/etc, could be introduced on both Thomas Built sites. The data shows that copper and zinc are present in several locations. Levels fluctuated, but they were often higher than the benchmark, and sometimes higher than the results from their outfalls, especially for zinc. I didn't find the Uwharrie River or Payne Creek on the 303(d) list or on the website as having a TMDL. Thanks, and hope you have a great Friday! -Aana From: Georgoulias, Bethany Sent: Thursday, May 08, 2014 2:09 PM To: Taylor -Smith, Aana; Pickle, Ken Subject: RE: Thomas Built Buses (NCG03 & Tiered Response) Hi Aana, This is great. Thanks again for sharing it with us. It's been so helpful to accumulate some examples from all the regions on these scenarios. I do have a couple questions. Did they say why they were testing the drinking water? That wouldn't be something they'd be discharging through their stormwater outfalls (under our permit anyway). Or were they just testing it for reference? We've had people bring up levels in drinking water before, but it's not always clear what that has to do with any.discharge through their SDOs. Sometimes I think it's a perception that drinking water is "clean" (which is true, but clean for people to drink... sometimes folksJust miss how that doesn't necessarily mean the same thing for bugs or fish living in the stream). Not a big deal or anything — I'm always just curious to explore why permittees test their drinking water for comparison. Railroads are certainly a potential interference, and riot one I'm sure I've thought about before. I'm curious about their upstream results. Did they sample upstream from both sites, how far upstream, and what were their results? Were they streams that were already impaired for copper or zinc? Thanks, Bg Bell any Georgold ias, Environmenial Engineer NCDENR / Division of Energy, Mineral, and Land Resources Stormwater Permitting Proorarn 1612 Mail Service Center, Raleigh, NC 27699-1612 512 H. Salisbury Street, Raleigh, NC 27604 919 / 807-6372 (phone); 919 / 807-6494 (fax) W ebsitc: i ll onto .ncdenr.org/web/ I r/stnn eater 1:-rrw(l eormspundence fu rriraf lrum this athfrass Nall, he sua j a to A, Norrb (:a►ollnu l'tablic ►Zecardti fair- and my &, diselosed to fhird parriex From: Taylor -Smith, Aana Sient6 Monday, May 05, 2014 1:112 PM Tv: Pickle, Ken Cc: Georgoulias, Bethany Subject: Thomas Built Buses (NCG03 & Tiered Response) Hi Ken, As we'discussed, here's the letter I sent to Thomas Built Buses after our meeting on Friday. During the meeting, it was very evident that the facilities have both put significant effort and money into finding potential Sources for zinc or copper. A major problem at both sites is the potential for off -site sources of zinc and copper. Both sites have railroads going around -and through the site and neighboring industries whose facilities drains to the outfalls. In the scientific literature, railroads have been shown to be significant contributors of heavy metals (including Cu and Zn). Additionally, the Fairfield site already has existing BMPs In place at each outfall- The two Thomas Built Buses facilities are ISO 14001 certified and zero waste to landfill. TBB has a pretty rigorous environmental program and they constantly update/review practices to be environmentally friendly. They have addressed some containers on site through the tiered response, including open dumpsters that they have sealed. They've also been doing upstream sampling and testing of the drinking water in High point, which showed some levels of zinc higher than the benchmark. With all of that in mind, I thought it would be best to release them from the tiered response monthly sampling requirements and Matt agreed. They'll be doing one additional sampling event at all outfalls this month. TBB did say that they would keep investigating and improving, which is consistent with their environmental policy. They've contracted with Blue Ridge Geological for all this work. Anyway, if you have any questions just let me know! Thanks, Aana Taylor -.Smith i_and Quallty Section Division of Energy, Mineral, and Land Resources NG IJENR Winston-Salem Regional ©ffIce Phone: (336) )71,�5034 Pax (336) M-4631 E-motl correspondence to and from this address may be subject to the North Carolina Public Records Low and may be disclosed to third parties, A o'iK;'Av NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor 5 May 2014 Thomas Built Buses, Inc. Attn: Alice Wesselman, Environmental Manager P.O. Box 2450 High Point, NC 27261 Subject: Technical Assistance Inspection & Tiered Response Requirements NPDES General Stormwater Permit NCG030000 Certificates of Coverage NCG030009 & NCG030010 Thomas Built Buses, Inc. Guilford County Dear Ms. Wesselman: 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 2 May 2014. Your assistance and cooperation were greatly appreciated. Two Thomas Built Buses facilities were under review during this meeting. The facility covered by NCG030009 is located at 715 West Fairfield in High Point, Guilford County, North Carolina. Stormwater related to industrial activity is discharged from that site to an unnamed tributary to the Llwharrie River, this segment of which is currently classified as Class WS-III Waters in the Yadkin -Pee Dee River Basin. The second facility, covered by NCG030010, is located at 1408 Courtesy Road in High Point, Guilford County, North Carolina, and discharges stormwater to Payne Creek, Class C Waters in the Yadkin -Pee Dee River Basin. Documentation & Monitoring Review This meeting was held to assess compliance with NPDES General Stormwater Permit NCG030000 and to evaluate drainage to the facilities' Stormwater Discharge Outfalls (SDOs). Monthly monitoring has been triggered by consecutive exceedances of the copper and zinc benchmarks at all 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. Thomas Built Buses has been following the tiered response actions at both facilities and is therefore in compliance with the permit. Both qualitative and analytical monitoring have been completed as required. Site Review The facilities are clean and well maintained. Secondary containment is implemented as required. Both sites have the potential for stormwater to become contaminated at the outfalls due to off -site in including railroads and neighboring industries. The Fairfield Road site has existing dry pond BMPs at each of the two outfalls to mitigate Stormwater contamination. SDOs may be relocated at the Courtesy Road site to attempt to avoid off -site contamination and collect more representative samples. Please update the stormwater pollution prevention plan (SPPP) when relocation of outfalls has been completed. Division of Energy, Mineral, and Land Resources Land Quality Section - Winston-Salem Regional Office 585 Waughtown Street, Winston-Salem, NC 27107 • Phone: 336-771-50001 FAX: 336-771-4631 Thomas Built Buses 05/05/2014 Page 2 of 2 Tiered Response 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. Thomas Built Buses has completed monthly monitoring for all outfalls as well as taking extensive actions to identify and eliminate potential sources of pollution at both sites. Upstream sampling and monitoring have been undertaken and housekeeping and site maintenance practices have been reviewed and improved. Dumpsters located near outfalls have been sealed and other storage containers have been reviewed to assess and improve their structural integrity where possible. Metals levels in the City's drinking water have also been assessed to determine whether that could be a contributor. Blue Ridge Geological Services has been contracted to assist with the tiered response investigation. Thomas Built Buses has achieved ISO 14001 certification for environmental management and has taken steps to achieve Zero Waste status. Both facilities are very well maintained. Thomas Built Buses 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 both sites 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 the SDOs for either site. 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 facilities 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 both Thomas Built Buses facilities. 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 SPPPs to document that your facilities have 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 (336) 771-5000. Sincerely, Matthew E. Gantt, PE Regional Engineer Land Quality Section cc: Ken Pickle, SPU Central Files WSRO/LQ Permit: NCG030009 SOC: County: Guilford Region: Winston-Salem Compliance Inspection Report Effective: 11/01/12 Expiration: 10/31/17 Owner: Thomas Built Buses Inc Effective: Expiration: Facility: Thomas Built Buses Inc - High Point 715 W Fairfield Rd Contact Person: Jeff Allen Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Title: Inspection Date: 05/02/2014 Entry Time: 09:30 AM Primary Inspector: Aana Taylor -Smith Secondary Inspector(s): High Point NC 27263 Phone: 919-889A871 Certification: Exit Time: 10:30 AM Phone: Phone: 336-771-5000 Reason for Inspection: Routine Inspection Type: Technical Assistance Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ■ Compliant Q Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NCG030009 Owner- Facility: Thomas Built Buses Inc Inspection Date: 05/02/2014 Inspection Type: Technical Assistance Reason for Visit: Routine Inspection Summary: Please refer to attached inspection letter. 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: Inspection was conducted to assess compliance with tiered response and options for reducing sampling frequency. Facility is compliant with all tiered response requirements and has taken significant steps to identify potential sources and mitigate benchmark exceedances. Facility can return to semi-annual sampling for copper and zinc. 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 ■nnn Yes No NA NE ■nnn nn■n Yes No NA NE Page: 2 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P. E. Governor Director December 4, 2012 Thomas Built Buses Inc PO Box 2450 High Point, NC 27261 Dee Freeman Secretary Subject: NPDES Stormwater Permit Coverage Renewal Thomas Built Buses Inc - Nigh Point CDC Number NCG030009 Guilford County Dear Permittee: In response to your renewal application for continued coverage under stormwater General Permit NCG030000 the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit.. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as subsequently amended). The following information is included with your permit package: • A new Certificate of Coverage (CDC) • A copy of General Permit NCG030000 • A copy of the Technical Bulletin for the General Permit • Two copies of the Discharge Monitoring Report (DMR) Form • Two copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the permit to update your current SPPP to reflect all new permit requirements. The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable, report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this permit and do not count prior exceedances. The more significant changes in the General Permit since your last CDC was issued are noted either in the Draft Permit Fact Sheet that accompanied the public notice (http:Zlportal.ncdenr.orp,/web/wq/ws/su/current- notice ), or in the Response to Comments / Summary of Chonges and Technical Bulletin documents that are posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit http://portal.ncdenr.org/web/wq/ws/suZnpdessw (click on 'General Permits' tab) to review that information for your specific General Permit carefully. 1617 Mail Service Center, Raleigh, Notth Carolina 27699-1617 Location: 512 N, Salisbury St. Raleigh, North Carolina 27604 Phone: 91M07-63001 FAX- 919-807-6492 Internet: www.ncwaterguality.oW An Equal Opportunity [ Affirmative Action Employer One NorthCarolina Natura!!il December 4, 2012 Page 2 of 2 Some of the changes include: Part II: • Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated to the most current language of our permits. Additional conditions for specific industry sectors have been added to the SPPP requirements in some cases. • Sections B, C: Failure to perform analytical Stormwater monitoring may result in the Division requiring that the permittee begin a monthly sampling scheme. • Sections B, C: A lower TSS benchmark of 50 mg/I for HOW, ORW, PNA and Tr Waters applies to these more sensitive waters. • Sections B, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other analytical monitoring requirements. • Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined in the "Definitions" section of the permit. • Sections B, C. The term "Representative Storm Event" has been replaced by "Measurable Storm Event." A measurable storm event is defined in the permit. • Section D. If the permittee fails to respond effectively to problems identified by qualitative monitoring, DWQ may require the permittee to perform corrective action. Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit, including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than 30 days from the date the facility receives the sampling results from the laboratory. Also note that existing permittees do not need to submit a renewal request prior to expiration unless directed by the Division. Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package, please contact the Division's Stormwater Permitting Unit at (919) 807-6300. Sincerely, for Charles Wakild, P.E. cc: DWQ Central Files Stormwater Permitting Unit Files Winston-Salem Regional Office STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030006 CERTIFICATE OF COVERAGE No. NCG030009 STORMWATER NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Thomas Built Buses Inc is hereby authorized to discharge stormwater from a facility located at: Thomas Built Buses Inc - high Point 715 W Fairfield Rd High Point Guilford County to receiving waters designated as Uwharrie River, a class WS-I11 waterbody in the Yadkin River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, 11, 111, and IV of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective December 4, 2012. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this 41�l day of December, 2012. for Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission r •.FUMNAMM. dlih � N®ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleerl H. SuRins Governor Director 11 August 2010 Mr. Dwight Bradshaw, Environmental Manager Thomas Built. Buses 1408 Courtesy Road High Point, North Carolina 27260 SUBJECT: Compliance Evaluation Inspection Thomas Built Buses NPDES Permit Ir 01STCG030009j& NCG030010 Guilford County Dear Mr. Bradshaw: Dee Freeman Secretary A Compliance Evaluation Inspection was performed on the Thomas Built Buses stormwater facilities on August 10, 2010 by Corey Basinger of the Winston-Salem Regional Office. The inspection consisted of two parts: an on -site inspection of the stormwater facilities and an in -office file review. The following are the findings from the subject inspection. 1. Permit The NPDES permits for Thomas Built Buses became effective on November 1, 2007and expire on October 31, 2012. ll. Records/Re .ports A review of the laboratory reports and Discharge Monitoring Reports (DMRs) revealed no discrepancy between the generated data and the data subtnitted to. D�4rQ. A copy of the laboraton data is kept on file. All applicable data is collected as per the NPDES permit requirements. Ili. Facility Site Review All outfalls noted in the Stormwater Plan were inspected and found to be satisfactory. W. Effluent & Receiving Waters Thomas Built Buses discharges storinwater to the following water bodies: (1) an unnamed tributary to Richland Creek (NCG030010 east drainage); (2) an unnamed tributary to Payne Creek (NCG030010 west drainage); and (3) an unnamed tributary to the Uwharrie River (NCG030009). Due to sunny weather conditions on the date of inspection, no stormwater discharge Naas observed. V. Self -Monitoring Program A review of the discharge monitoring reports (DN4Rs) showed that Thomas Built Buses was in compliance with the self - monitoring requirements contained in both NPDES General Permits. Qualitative and quantitative monitoring data was reviewed and demonstrated compliance with permit requirements. Overall, the facilities were deemed to be in compliance with NCGO30009 and NCG030010. If y_ ou should have any . questions or concerns regarding this report, please contact this Office at (336) 771-5000. Sincerely, r Steve W. Tedder " Water Quality Supervisor Cc: NPDES Stormwater Unit Central Files WSRO North Carolina Division of waier Quality, winston-Salem Ree Tonal Oltice t-o:ation: 585 Waughlown St. \Ninston-Salem, Norttr Carolina 27107 nllE Phone: 338-771-50001 F-X 336j71-48301 Customer Service: 1-877-623-5743 1\1 OI th Carolina liter-let:wVrA"ncwaterquali:y.wg ,Yattaw `y An Equal OppwLnity %Afor,natke Aclion cmptoyer Form Approved OMB No_2040-4o57 i -�° Approval Expires United States Environmental Protection A_encv, Washington, D.C., 20460 Section A: National Data System Coding Transaction Code NPDES No. Yr/Mo/Day Inspection Type Inspector FacilityType N 5 NCG030010 10-08-10 C S 2 Facility Evaluation Rating BI QA ..........Reserved........... 4 N N Section B: Facility Data Name and Location of Facility Inspected: Entry Time: Permit Effective Thomas Built Buses. 0945 hrs. Date: Nov 1, 2007 Located at 1408 Courtesy Road, High Point, NC. Exit Time: Permit Expiration 1115 hrs. Date: Oct 31, 2012 Name(s) of On -Site Representative(s): Title(s): Phone No(s): Mr. Dwight Bradshaw Environmental Manager 336-881-6507 Name, Address of Responsible Official: Tide: 'VP of Operations Mr, Jeff Allen Phone No. Contacted? No Thomas Built Buses. PO Box 2450 336-881-7298 High Point, NC 27261 Section C: Areas Evaluated During Inspection (check only those areas evaluated) X Permit NA Flow Measurement X Operations/Maintenance X Records/Reports X Self Monitoring Program NA Sludge Handling/Disposal X Facility Site Review NA Compliance Schedules NA Effluent/Receiving Waters X Stormwater Section D: Summary of Findings/Comments See attached letter for further details regarding the subject inspection. Name(s) and Signature(s) of Inspectors: Agency/Office/Telephone: Date: ' DWQ / WSRO/ (336)771-5000 4utrw47—Z"l° Signature of Reviewer: Agency/Office: Date: ? 6CY C7nc 12D ff DWQ / WSRO / (336)771-5000 F/1-1/k� ..1 Fonn Approved OMB h'o.2040.0057 i Approval Expires 8-31-98 United States Environmental Protection Agency. Washington, D.C., 20460 Section A. National Data lystem Coding TransactionCode NPDES No. Yr/Mo/Day Inspection Type Inspector FacilityType N 5 NCG030009 10-08-10 C S 2 Facility Evaluation Rating BI QA ..........Reserved........... 4 N N_ Section B: Facility Data Name and Location of Facility Inspected: Entry Time: Permit Effective Thomas Built Buses. 0945 hrs. Date: Nov 1, 2007 Located at 1408 Courtesy Road, High Point, NC, Exit Time: Permit Expiration 1 115 hrs. Date: Oct 31, 2012 Name(s) of On -Site Representative(s): Title(s): Phone No(s): Mr. Dwight Bradshaw Environmental Manager 336-881-6507 Name, Address of Responsible Official: Title: VP of Operations Mr. Jeff Allen Phone No. Contacted? No Thomas Built Buses PO Box 2450 336-881-7298 High Point, NC 27261 Section C: Areas Evaluated During Inspection (check only those areas evaluated) X Permit NA Flow Measurement X Operations/Maintenance X Records/Reports X Self -Monitoring Program NA Sludge Handling/Disposal X Facility Site Review NA Compliance Schedules NA Effluent/Receiving Waters X Stormy+ater Section D: Summary of Findings/Comments See attached letter for further details regarding the subject inspection. Name(s) and Signature(s) of Inspectors: Agency/Office/Telephone: Date: DWQ 1 WSRO I (336)771-5000 j�� I� Signature of Reviewer: Agency/Office: Date: DWQ / WSRO 1(336)771-5000 S'A y- L. Permit: NCG030010 Owner - Facility: Thomas Built Buses Inc Inspection bate: 0811012010 Inspection Type: Compliance Evaluation Reason for Visit: Routine a Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention flan? n n n # Does the Plan include a General Location (USGS) map? # n ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ® n ❑ n # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ n Cl # Does the Plan include a list of significant spills occurring during the past 3 years? lz ❑ n n # Has the facility evaluated feasible alternatives to current practices? 19 0 ❑ ❑ # Does the facility provide all necessary secondary containment? is n n # Does the Plan include a BMP summary? all D ❑ Q # hoes the Plan include a Spill Prevention and Response Plan (SPRP)? ® Q Q ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? a Cl 0 # Does the facility provide and document Employee Training? I9 n n C # Does the Plan include a list of Responsible Party(s)? ® Q 0 ❑ # is the Plan reviewed and updated annually? ® n n n # Does the Plan include a Stormwater Facility Inspection Program? ® n n n Has the Stormwater Pollution Prevention Plan been implemented? ®❑ fn n Comment; Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ® 0 n D Comment Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? C1 ❑ ❑ Cl # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ® n ❑ n Comment; Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? p n n n # Were all outfalls observed during the inspection? E;R n n n # If the facility has representative outfall status, is it properly documented by the Division? (3 Q p 0 # Has the facility evaluated all Wicit (non stormwaler) discharges? 0 n n n Comment, Page: 3 J._ Permit: NCGO30009 Owner - Facility: Thomas Built Buses Inc Inspection Date: 08/10/2010 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? M ❑ n ❑ # Does the Plan include a "Narrative Description of Practices"? ®n n n # Does the Plan include a detailed site map including outfali locations and drainage areas? E3 ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ® ❑ n Cl # Has the facility evaluated feasible alternatives to current practices? ® n n n # Does the facility provide all necessary secondary containment? p ❑ ❑ n # Does the Plan include a BMP summary? ®❑ n n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? o n n ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® ❑ ❑ ❑ # Does the facility provide and document Empioyee Training? ®❑ n n # Does the Plan include a list of Responsible Party(s)? ® n n Cl # Is the Plan reviewed and updated annuatly? ®❑ n n # Does the Plan include a Stormwater Facility Inspection Program? is ❑ n Has the Stormwater Pollution Prevention Plan been implemented? ® n n n Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? M n n n Comment: Analytical Monitorin.9 Yes No NA NE Has the facility conducted its Analytical monitoring? M ❑ 0 ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ® n n n Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ® n n ❑ # Were all outfalls observed during the inspection? ® n ❑ ❑ # If the facility has representative outfall status, is it property documented by the Division? ❑ n ® ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ® n ❑ n Comment: Page 3 a R SuC.sdleryor FREIGHTL fx£R uC July 7, 2010 Corey Basinger NCDENR Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Subject: Broken Sewer Line Dear Mr. Basinger: Thomas Guilt Buses, Inc. PO Box 2450 (27281) 1408 Courtesy Road High Point, NO 27260 (336) B&9-4871 Pthong (336) 669.2580 Pax This letter is in reference to the broken sewer line behind Thomas Built Buses' Plant # 1 located at 1408 Courtesy Road, High Point NC. I was notified of the situation at 9:30am on July 1", 2010. The leak entered into a dry weather storm drainage ditch that runs parallel to Plant # 1. The Division of Water Quality was contacted by phone as soon as 1 was informed of the leak as required by our Storm Water General Permit, Section EX — Twenty-four hour reporting. The leak occurred as a result of a cracked terra cotta sewer line. There is one restrooin located upstream of the leak that utilizes this line. This restroom was immediately shutdown and closed to stop the flow of wastewater through the damaged pipe. The duration of the leak is assumed to be one full day. The closed restroom typically serves approximately 2S employees who work in its vicinity. Therefore, using minimum design flow criteria for sewer lines, it is estimated that approximately 625 gallons of wastewater drained into the dry weather storm drainage ditch, You visited the site to inspect the repair and potential downstream impacts on July 2, 2010. It was discovered that the dry weather ditch drains into an Relghlllner LLC Is a DasmEsrChrysler Company unnamed tributary to Payne Creek and that downstream issues were minimal. The sewer Iine was repaired on July 1, 2010 by Smith & Jennings Grading and Utility Contractor. Additionally, a sewer line specialist was brought to the site on July 6`h to estimate a full clean out of this line. Thomas Bus's plan is to clean the line and evaluate options for replacement of the entire line of pipe. In the interim, TBB personnel will monitor the line more frequently than the current monthly BMP visual inspection to ensure the leak has been stopped. If you have any questions, please call me at 336-881-6507. Sincerely, THOMAS BUILT BUSES Dwight Bradshaw Environmental Manager i Fw: Nver Line Leak Subject: Fw: Sewer Line Leak From: "D.Bradshaw" <dbradshaw89@carolina.rr.com> Date: Fri, 20 Mar 2009 23:45:47 -0500 To: <corey.basinger@ncmail.net> ---- Original Message From: D.Bradshaw To: corey.basinger ncmail.net Sent: Friday, March 20, 2009 10:30 PM Subject: Fw: Sewer Line Leak ----- Original Message ----- From: dwi ht.bradshaw daimler.com To. dbradshaw89jcarol_ina.rr.com Sent: Friday, March 20, 2009 9:30 PM Subject: Sewer Line Leak Corey, Per our conversation, I am summarizing the issue discovered on Thursday during our monthly inspections. A sewer line located behind Plant 1 was discovered to have a leak in the rubber coupling at an old in -line flume_ This flume was used years ago for sampling and monitoring of an old pretreatment line that used to be located at the Prospect Street end of Plant 1. 'Currently, there is one bathroom being serviced by this sewer line. Upon discovery, I contacted Frank Skee at the City of High Point Wastewater Treatment plant to inform him of the situation. At that time, it was unknown who's sewer line this belonged to due to it being on railroad property. I sent a picture of the problem to Frank so he could forward it to the correct individual at the City of High Point. I received a call from the City on Friday morning and met two technicians at the site to look at the problem. They also took pictures and sent them to their supervisor. The City researched this sewer line and found that it was indeed a private line. I notified our Facilities and Maintenance Departments of this and they immediately scheduled Saturday work to replace the rubber coupling or remove the old metal box and flume completely and replace with new piping. I have attached the picture I sent to the City of High Point. Also, I inspected the hole this morning and there was nothing coming out of the pipe even though there was some flow. Once the leak has been repaired, I will send you the fixed pictures for your files. If you have any questions give me a call. Thanks for your guidance and help, Dwight t of 2 3/23/2009 7:43 AM .,,'a o�OF' A.' �" o Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources JACK SCHAFER THOMAS BUILT BUSES INCORPORATED PO BOX 2450 HIGH POINT. NC 27261 Dear Permittee: Alan W, Klimek, P.E., Director Division of Water Quality August 23. 2002 Subject: NPDES Stormwater Permit Renewal THOMAS BUILT BUSES INCORPORATED COC Number NCG030009 Guilford County In response to your renewal application for continued coverage under general permit NCG030000, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215-1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983. The following information is included with your permit package: * A new Certificate of Coverage * A copy of General Stormwater Permit NCO030000 * A copy of the Analytical Monitoring Form (DMR) * A copy of a Technical Bulletin for the general permit Your coverage tinder this general permit is not transferable except after notice to DWQ, The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for c6mpliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 548 Sincerely, Bradley Bennett. Supervisor Stormwater and General Permits Unit cc: Central Files Stormwater & General Permits Unit Files Winston-Salem Regional Office NCDENR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1- 800-623-7748 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030009 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended. THOMAS BUILT BUSES INC is hereby authorized to discharge stormwater from a facility located at THOMAS BUILT BUSES INCORPORATED 715 W FAIRFIELD RD HIGH POINT GUILFORD COUNTY to receiving waters designated as a U'r to the Uwharrie River, a class WS-11I stream, in the Yadkin - Pee Dee River Basin in accordance with the effluent limitations. monitoring requirements, and other conditions set forth in Parts I. II, I11, IV, V. and VI of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective September 1, 2002. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day August 23.2002. for Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Gregory J. Thorpe, Ph.D. Acting Director Division of Water Quality December 27, 2001 DOUG HARRISON THOMAS BUILT BUSES INCORPORATED PO BOX 2450 HIGH POINT, NC 27261 Subject: NPDES Stormwater Permit Renewal THOMAS BUILT BUSES INCORPORATED COC Number NCG030009 Guilford Countv Dear Permitice: Your facility is currently covered for stormwater discharge under General Permit NCG030000. This permit expires on August 3 I, 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for continued coverage under the reissued permit. In order to assure your continued coverage under the general permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed you will find a General Permit Coverage Renewal. Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued coverage under the general permit. Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in'assessments of civil penalties of up to $10,000 per day. Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial facilities in any of the 1 I categories of "storm water discharges associated with industrial activity," (except construction activi(ies). If you feet your facility can certify a condition of "no exposure", i.e. the facilly industrial materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General Permits Unit Web Site at 11ttp:ll112o.err.state.nc.us/su/stormwater.hllm] ]I* the subject stormwater discharge to waters of the stale has been terminated, please complete the enclosed Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the rescission process ltas been completed. if you have any questions regarding the permit renewal procedures please contact Corey Basinger of the Winston-Salem Regional Office at 336-771-4600 or Bill Mills of the Central Office Stormwater Unit at (919) 733-5083, ext. 548 Sincerely, Bradley Bennett. Supervisor Stormwater and General Permits Unit cc: Central Files Winston-Salem Regional Office e�� RUMNR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1-800-623-7748 State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality • James B. Hunt, Jr., Governor As Wayne McDevitt, Secretary p E H N A. Preston Howard, Jr., P.E., Director September 25, 1997 DOUG HARRISON THOMAS BUILT BUSES INC PO BOX 2450 HIGH POINT, NC 27261 Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG030009 Guilford County Dear Permittee: In response to your renewal application for continued coverage under the subject permit, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. The following information is included with your permit package: ■ A copy of the stormwater general permit. ■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your permit. This form must be completed and returned to the Division within 30 days of receipt of this letter. DO NOT send the SPPP with the signed form. N Five copies of Analytical Monitoring forms. ■ Five copies of Qualitative Monitoring forms. ■ A copy of a Technical Bulletin on the stormwater program with outlines program components and addresses frequently asked questions. ■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal Form returned to the Division. Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area Management Act or any other Federal or Local governmental permits that may be required. If you have any questions concerning this permit or other attached documents, please contact the Stormwater Group at telephone number (919) 733-5083 Sincerely, for . Preston Howard, Jr., P. E. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper State of North Carolina Department of Environment, Health and Natural Resources 74• Division of Environmental Management �I James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director May 14, 1993 Terry Dawson Thomas Built Buses, Inc. P O Box 2450 High Point, NC 27261 Subject: General Permit No. NCG030000 Thomas Built Buses, Inc. COC NCG030009 Guilford County Dear Mr. Dawson: In accordance with your application for discharge permit received on September 9, 1992, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. - If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Environmental Management. The Division of Environmental Management may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Mr. Bill Mills at telephone number 919/733- 5083. cc: Sincerely, Original Signed By Qoieen H. Sullins A. Preston Howard, Jr., P. E. Winston-Salem Regional Office Pollution Prevention Pays P.D. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer STATE OF NORTH CAROLINA . DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DMSION OF ENVIRONMENTAL MANAGEMENT _►�':_ '_ .� �. ►1 ► I fill Lei • 1 _::_ _ ►1 ► I III STORMWATER DISCHARGES In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Thomas Built Buses, Inc. is hereby authorized to discharge stonnwater from a facility located at Thomas Built Buses, Inc. Plant 2 715 W. Fairfield Rd. High Point Guilford County to receiving waters designated as an unnamed tributary to the Uwharrie River in the Yadkin -Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of General Permit No. NCGO30000 as attached. This certificate of coverage shall become effective May 14, 1993. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day May 14, 1993. Original �` nal Signed B Coleen H. Sullin, A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission 0ass . MAIO, -W W:11; v 6nh jU r tu —pact-. jq 3979 Bch I 4 4 A 3A A Z:� Ln kn 261 is —4 r Al 4n W % mL -J, ',55' i974 jq 3979 Bch I 4 4 A 3A A Z:� Ln kn 261 is —4 r Al 4n W % mL -J, ',55' i974 FACILITY COUNTY Gu�l��a •r: NPDES hr'�G o 30009,'�'' MAP # DSN FLOW NIA SUB BASIN r3 LATTITUDE .' LONGITUDE $o av RECEslV[NC STREAM S T R"kiE CLASS M,IF DISCHARGE CLASS EXPIRATION DATE 0-3/-17 !/15* -/ . 4c, //4-Ae vI ailAGtfi-e I�,'vof N C.vtlbSmDei ` IFA4 rM.A L Bt=NCHMARK -/ OATS IUI- Pnhtnp . 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HP-11 ti r I Gs� a VM6 1�t� ENWOM PSI Amu Bus Lot v-----------I-------��---HP 1191 �DO 02 OF-21 St. Qutfall4and Coo rdj In ka OF-1 Latitude - 35 deg 54 min 58 sec North Longitude - 79 deg 59 min 51 sec West OF-2 Latitude - 35 deg 55 min 3 see North Longitude - 79 deg 59 min 32 see West ,15 Ref: SWPPP & SPCC Site Map last revised 2010, modified by Blue Ridge Geological Services SDO#01 STo�w*ArsRdsamcrom,Au.auftm pow �� EG¢awarsrAwcruriEs p MAMSEmmGATGNBASAY ' M� STPRY SEii'ER YAN MhE " _ _ RROAERTYlINF3 - - F&"LWE -•- - ---• SMRMWATERORAWAGE'IWATERwAY �.n. r.s��E4FYA FiCYYCONrOiA4 LWE MVEI RWz PAVE ENr a0iECTAYOFZ7CVtWWATERF1XW [ � BUS PARKWO/STORAar AREA EifCAGf.A'GYL!'14lVTSrSIN4'l.lEa LOCATIONS OF OIL SOURCES A CHEMAL STORAGE • [ Y • USTEQ A.S A.N SPCC SOURCE + ® A9r0GAA•RE390R4M&MEMATF NALIWOUS WASTL STOWAGE SURDINO • 0 AWN7ENANCf P••'4'fJ.rrtalsdl�Ar SlQ.yJ x ® WASTEI3UM SMfIC &PAC" ty IOTL-GRUM.PA VORICFA jYlON1¢NII Palm A611MHR IHiU•NWWV fflOLpiJ mrr6RCC7F-&"5TQPAGC TANK 0 MGM40M*Lx-PAAvrDAVTAW RMW 0 NATWAM&4rT&nFAcGUWLAT0NARFA DLAGMAR PAWTLINE • JR) HYORAULCBCi1a 1PCRC(N0~3' EU6 WATCR LCM TESTMG Mr • 1& WA$TEORCOI.Irr.TVN EiECTwCTRANSFOWMER • rNEntFNnrerNERAroR 1?)MPS oAvmciy lh VIAU -low TSS . 6)C65i+c 1 nvt�e - RV, ►rkduSt-� . _ r Site Drainage Map Thomas Built Buses 715 West Fairfield Road High Point, North Carolina xil 2014 1 Figure 3 4 I I n pe%4 UP) IPPM 2: 14 Googie 6m HISTORY Thomas Built Buses was founded in 1916 as Perley A. Thomas Car Works in High Point, North Carolina, USA. The company began with the manufacturing of streetcars and trolley buses before transitioning to the production of school buses in 1936. Commercial buses and specialty vehicles were added shortly thereafter. The name was changed to Thomas Built Buses, Inc. in 1972 to emphasize our core business. Today, Thomas Built Buses is North America's leading bus manufacturer, offering a full line of school, commercial and specialty buses to safety, value -minded buyers. More than one- third of the school buses on the road today are Thomas Built Buses. From its manufacturing facilities in High Point, North Carolina, Thomas produces more than 15,000 buses per year. Thomas Built Buses is a member of Daimler Trucks North America LLC, the largest heavy- duty truck manufacturer in North America. Daimler Trucks North America LLC is a Daimler company. SMOKING To promote the safety and health of everyone at TBB, smoking is prohibited in all buildings and vehicles. Smoking is permitted in designated areas outside the main entrances to the plants. SECURITY • Security personnel are on duty 24-hours, 7- days a week. If there is an emergency, dial "0" to be connected for assistance. ■ Visitors must sign the Visitor Log when they first enter the building. This ensures your safety and well-being in case of an emergency. • Visitors need appropriate identification badges to enter the buildings; these may be obtained at the receptionist's station and must be wom at all times. M!� B�.U I L T B U Thomas Built Buses 1408 Courtesy Road High Point, NC 27260 (336) 889-4871 www.thomasbus.com Environmental, Health and Safety Guidelines High Point, North Carolina, USA Revision: 04.22.08 ==A F; -_ TOS -- Truck Operating System HEALTH AND SAFETY PROGRAMS Thomas Built Buses maintains environmental, safety and health programs as part of its social and environmental goals. These programs include the prevention of injuries and illnesses to employees; the protection of property and the environment from damage and waste; and the safety of the public in connection with company operations. HEALTH AND SAFETY INFORMATION Thomas Built Buses places a high priority on the safety and health of its visitors and contractors as well as its employees. To help prevent accidents, please follow the following rules in all areas of our plants. ■ Wear clear, non -mirrored, Z137 certified safety glasses. Wrap -around safety glasses are available for those that wear prescription glasses. Prescription safety glasses require side shields. ■ Wear hearing protection. ■ Wear safety shoes. Closed toe shoes may be worn only in the main aisle ways between the yellow lines. Open toe shoes are not permitted except in office areas. ■ Eating or drinking is not permitted on the shop floor. ■ Using cell phones, cameras, and video equipment in production areas is prohibited. ■ Watch for moving buses and other industrial vehicles. ■ Stay with your guide at all times. Evacuations ■ In the event of a plant emergency, the evacuation horns will sound. ■ Emergency Coordinators will direct the evacuation. ■ Please remain calm and exit the plant at the nearest exit. Here is an example of an emergency exit sign: EXIT • Once you have exited, please proceed to the assembly area with your host. ENVIRONMENTAL INFORMATION Environmental Policy Thomas Built Buses is committed to manufacturing our vehicles in an environmentally responsible manner. We will do this through: "THOMAS" • Total compliance with all environmental laws; • Heightened understanding of the views and needs of our internal and external stakeholders; • Optimized focus on environmentally advanced product and process design; • Maintain continuous improvement of environmental performance; • Achieve reducing our impacts on the environment through pollution prevention; • Setting and achieving environmental goals New Chemicals All chemicals must be approved before being brought into the facility. To receive authorization, provide TBB a detailed MSDS that includes names, CAS numbers and quantities of components. This information will be reviewed by the Health and Safety and Environmental Departments. MSDS Sheets Material Safety Data Sheets are kept electronically for all chemicals used on site. Container Labeling All containers (primary and secondary) must be properly labeled. The following is an example of such a label. HEALTH N FLAMBILITY "ACTIM PERSONAL PROTECTION 0 v' ,v �a lit,t^G(� J ISLt�` stD"C4, KC L-A-k� "DLu�-,. C�I�ve.cC�-ate 5I2I��+ 'zl-Z 0.0a�; LT- 0- SDbt:-_Z-�_21.,_Cu. _iD o�.1 , Zhu �0.��i1_��3.�3.,_Cu�p..0.►z, zn�d 3�5 � CU_� I� ��SD_C�05 d- 5 DOOcn i.l�, �xcJlh -� Lpl•_�pl. �c�'Yr� � 1.yt�i �5 ls�....��,u ra. v+ Ai -All -PAS • e