NCG180023_Vanguard Furniture SWPPP Update_20220107

STORMWATER POLLUTION
PREVENTION PLAN
VANGUARD FRAME #2
(Use to be CRAFTWORK GUILD FRAME PLANT)
Permit NCG180085
Origin Date: November 1999
Revision Date: December 2021
Prepared for:
Vanguard Furniture Co., Inc.
Site Address:
440 Simpson Street
Conover, North Carolina 28613
Mailing_ Address:
Post Office Box 2178
Hickory, North Carolina 28603
First Created and Prepared by:
Applied Water Technology
621 Hutton Street, Suite 107
Raleigh, North Carolina 27606
[phone]

Vanguard Frame #2 SPPP
December 2021
Page 2
DISCLAIMER
This Storm Water Pollution Prevention Plan was developed for
Vanguard Furniture Co., Inc. to use at their Hickory, North Carolina
facility. Modifications to the plan, other than those to accommodate
changes in normal plant operations required by the execution of this
SPPP, or reuse for other facilities or operations for which this
document was not originally intended are not recommended. Any
such modification or reuse without written verification or adaptation
by AWT, as appropriate, for the specific purpose intended will be at
Vanguard Furniture's sole risk and without liability or legal exposure
to AWT from all claims, damages, losses, and expenses including
attorneys' fees arising out of or resulting therefrom. Any such
verification or adaptation will entitle AWT to further compensation
at rates to be agreed upon by Vanguard Furniture Co., Inc. and
AWT.

Vanguard Frame #2 SPPP
December 2021
Page 3
Certification
I, Tammy Smith (Vice President of Human Resources), certify under penalty of law that
this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who
manage the system or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name and Official Title
Signature
f Human
Date Signed 1- � - 2 9 • ;U Area Code and Telephone No. [phone]

Vanguard Frame #2 SPPP
December 2021
Page 4
TABLE OF CONTENTS
SECTION
PAGE_.
I.
POLLUTION PREVENTION TEAM
6
II.
FACILITY MAPS
8
III.
SITE ASSESSMENT
12
1. Chemical Inventory
12
2. Potential Pollutant Evaluation
12
3. Existing Management Practices
16
4. Existing Monitoring Data
17
5. Spill Incidents
17
6. Non-Stormwater Discharge Certification
19
IV.
BEST MANAGEMENT PRACTICES
20
V.
PERSONNEL AWARENESS AND TRAINING
26
1. Introduction
26
2. Spill Prevention Measures
26
3. Housekeeping
27
4. Preventative Maintenance
27
5. Specific Personnel Duties
28
6. Outside Contractors
29
7. Facility Inspections
29
8 Storm water Sampling/Monitoring
30
VI.
STORMWATER POLLUTION PREVENTION PLAN EVALUATION
33
1. Semi -Annual Site Compliance Evaluation
33
2. SPPP Revisions
33
3. Record Keeping and Internal Reporting
34
4. EPCRA, Section 313 Chemicals
34
(Continued next page)

TABLE OF CONTENTS
(Continued)
TABLES
Table 1
Significant Material Areas
Table 2
Chemical and Material Inventory
Table 3
Exposed Significant Materials
Table 4
Significant Spills and Leaks
Table 5
Pollutant Source Summary
Table 6
Best Management Practice Summary
Table 7
Best Management Practice Implementation
Table 8
Employee Training
FIGURES
Vanguard Frame #2 SPPP
December 2021
Page 5
10
14
15
18
23
24
25
32
Figure 1 Pollution Prevention Team Organization Chart 7
Figure 2 Pre-BMP Site Map 9
Figure 3 Facility Location Map 11
Figure 4 Example Stormwater Systems Evaluation Form 31

Vanguard Frame #2 SPPP
December 2021
Page 6
I. POLLUTION PREVENTION TEAM
Leader
Tammy Smith, Vice President of Human Resources
Signatory authority
Emergency response director
Members
Will Stange, Safety Manager
Hazard Communication Training
Coordinate SPPP & BMP implementation
Coordinate employee training
Oversee and performs facility inspections
Responsible for spill prevention training
Retain all records
Coordinate and submit documentation of required stormwater sampling
Safety/spill response coordinator
Responsible for annual site compliance evaluation & SPPP revisions
Shift Workers
Responsible for general good housekeeping and clean-up of routine spills
Group Activities
Targeting stormwater management options

Vanguard Frame #2 SPPP
December 2021
Page 7
Figure 1
Pollution Prevention Team
Organization Chart
Vice President of Human Resources
Tammy Smith
Safety Manager
Will Stange
Shift Workers

Vanguard Frame #2 SPPP
December 2021
Page 8
II. FACILITY MAPS
The pre-BMP site map located in the map pocket identifies the representative stormwater
outfall, drainage areas, and locations of significant materials at the facility prior to
implementation of any Best Management Practices (BMPs). The significant material
areas indicated on the pre-BMP site map are listed in Table 1. The facility pre-BMP site
map presented in Figure 2 shows the site location for all stormwater discharges.
The significant material areas listed are located on the pre-BMP site map in Figure 2.

Vanguard Frame #2 SPPP
December 2021
Page 9
Figure 2
Pre-BMP Site Map
(See Map Pocket)

Vanguard Frame #2 SPPP
December 2021
Page 10
Table 1
Significant Material Areas*
Area 1 (North Side of Building)
Shipping/receiving area
Area 2 (West Side of Building)
Scrap wood waste bin
Waste bin
Sawdust collection bin with bagfilter
Area 3 (South Side of Building)
Receiving area for plywood
Area 4 (East Side of Building)
Employee parking
The significant material areas listed are located on the pre-BMP site map.

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III. SITE ASSESSMENT
1. Chemical Inventory
Vanguard Frame #2 SPPP
December 2021
Page 12
A review and inventory of the facility raw material information, supplied by Vanguard
Furniture, was performed and is summarized in Table 2. The table outlines the
purpose/use, quantity used and stored on -site, and the likelihood of stormwater contact
for each material.
Chemical Inventory materials that are exposed to stormwater contact are further
described in Table 3.
2. Potential Pollutant Evaluation
The potential for stormwater contact with pollutants exists at locations around the
J
facility. A visual inspection of the facility revealed the following potential pollutant
areas:
Area 1
Trucks are parked in the shipping and receiving areas while loading and unloading
frames. There is the potential for oil and grease buildup on the ground or minor
petroleum spills from trucks with leaks.
Runoff from Area 1 flows northwest into a ditch on the north side of property and
ultimately discharges into Cline Creek.
Area 2
There is a lumber -receiving bay in this area. There is the potential for oil and grease
buildup from forklift trucks with leaks to accumulate on the pavement in this area. A
scrap wood waste bin and sawdust collection bin are located in this area. The sawdust
collection bin is equipped with a bagfilter to control particulate material emissions.
Runoff from Area 2 flows west off the property line and ultimately discharges into Cline
Creek.

Vanguard Frame #2 SPPP
December 2021
Page 13
Area 3
Trucks are parked in the receiving area while unloading plywood. There is the potential
for oil and grease buildup from trucks with leaks to accumulate on the ground.
Runoff from Area 3 flows southwest off the property and ultimately discharges into Cline
Creek.
Area 4
Employee parking occurs in this area. There is potential for oil and grease buildup on the
ground from vehicles with leaks.
Runoff from Area 4 flows northwest into a ditch along the north property line and
ultimately discharges into Cline Creek.

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December 2021
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Table 2
Chemical and Material Inventory
Chemical and Material Inventory
Material
Purpose/
Use
Quantity
Purchased/Stored
Gallons
Contact with
Stormwater
Glue
Frame Assembly
110
None

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December 2021
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Table 3
Exposed Significant Materials
Method of
Existing Practice of
Description of
Storage (e.g.
Material
Exposed
Quantity
Location (as
pile, drum,
Management (e.g.
Significant
Period of
Exposed
indicated on
tank)
pile covered, drum
Material
Exposure
(Units)
site map)
sealed)
Upholstery
-------
Area 1
bin
None
waste bin
Scrap wood
-------
Area 2
bin
None
waste bin
Sawdust
-------
Area 2
bin
I
Bagfilter to control
collection bin
particulate emissions

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December 2021
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3. Existing Management Practices
There is one area at the facility that already employs measures that reduce stormwater
contact with significant materials and activities. These areas are as follows:
Area 2
A bagfilter is being used to collect airborne particles (sawdust) generated from of
material handling operations.

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December 2021
Page 17
4. Existing Monitoring Data
There is no existing stormwater monitoring data available prior to 1999. This facility is
not required to perform analytical monitoring under their general storm water permit,
NCG 1800085. All storm water visual monitoring data will be collected in the future and
kept on -site as directed under the requirements of the general stormwater permit.
5. Spill Incidents
As required by regulation, an audit of all spills and leaks was completed for the past 3
years. No spills have occurred at this facility in the three years prior to issuance of
Vanguard Furniture's general storm water permit as defined in Table 4.

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December 2021
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Table 4
Significant Spills and Leaks
Date
Name
Details
2017
Mick James
Nos ills occurred.
2018
Mick James
Nos ills occurred.
2019
Will Stange
Nos ills occurred.
2020
Will Stange
Nos ills occurred.
2021
Will Stange
Nos ills occurred.

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December 2021
Page 19
6. Non-Stormwater Discharge Certification
Vanguard Furniture, Inc. personnel have inspected the facility floor drain piping and
confirmed that all non-stormwater discharges are routed to the Conover WWTP.
Certification
I, Tammy Smith (Vice President of Human Resources), certify under penalty of law that this
document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the
system or those persons directly responsible for gathering the information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations.
Name and Official Title Tammy Smith (Vice President of
Date Signed W . 964 Area Code and Telephone No. [phone]

Vanguard Frame #2 SPPP
December 2021
Page 20
IV. BEST MANAGEMENT PRACTICES
Best Management Practices (BMPs) address potential pollutant areas that were identified
during the facility site assessment. The BMPs are designed to help reduce the potential
for stonnwater pollution. Recommended BMPs for the previously identified areas are as
follows:
Area 1
Trucks are parked in the shipping and receiving area while loading and unloading frames.
It is recommended that the shipping/receiving bays be covered and/or avoid performing
loading/unloading activities in the rain.
Area 2
Trucks are parked in this area while unloading lumber. It is recommended that the
receiving bay be covered and/or avoid performing unloading activities in the rain.
Absorbent material should be readily available. An uncovered scrap wood waste bin is
located in this area and should be covered to reduce the potential for storm water contact
with the wood waste materials inside. A sawdust collection bin equipped with a bagfilter
for particulate emissions control is also located in this area. The area surrounding the
sawdust collection bin should be swept regularly and the sawdust material disposed of
appropriately.
Area 3
Trucks are parked in this area while unloading materials. It is recommended that the
receiving bays be covered and/or avoid performing unloading activities in the rain.
Absorbent material should be readily available.
Area 4
Vehicles are parked in this area during operating hours. Absorbent material should be
readily available.

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December 2021
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General
Best Management Practices for the site in general will include regular comprehensive
facility inspections, maintaining an updated material inventory, and ensuring that current
MSDSs are readily available. All employees shall be trained in spill response and good
housekeeping practices. Adequate supplies of materials for dry clean up of spills and
leaks should be kept readily available to all areas.
Additional BMP's
These additional BMPs could be implemented to further reduce or eliminate the potential
for stormwater contact. Some of these additional BMPs were recommended for site -
specific pollutant areas; however, utilization of these BMPs facility wide could further
reduce the potential for stormwater contact.
Outdoor unloading and loading
• Confine loading/unloading activities to a designated area.
• Perform all loading/unloading activities in a covered or enclosed area.
• Close storm drains during loading/unloading activities in surrounding areas.
• Avoid loading/unloading materials in the rain.
• Inspect all containers prior to loading/unloading of any raw or spent materials.
• Berm, curb or dike loading/unloading areas.
• Use dry clean-up methods instead of washing the areas down.
• Train employees on proper loading/unloading techniques.
Outdoor material storage including waste and particulate emission management)
• Train employees on proper waste control and disposal.
• Berm, curb or dike any areas around tanks.
• Ensure that all containers are properly sealed and valves closed.
• Inventory all raw and spent materials.
• Inspect air emission control systems regularly, and repair or replace when necessary.
• Store wastes in covered, leakproof containers (e.g., dumpsters, drums).
• Store wastes in enclosed and/or covered areas.

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December 2021
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• Ensure hazardous and solid waste disposal practices are performed in accordance
with applicable Federal, State, and local requirements.
• Ship all wastes to offsite landfills or treatment facilities.
Erosion and sediment control:
• Trap sediment at downgradient locations and outlets serving unstabilized areas. This
may include filter fabric fences, gravel outlet protection, sediment traps, vegetated or
riprap swales, vegetated strips, diversion structures, catch -basin filters,
retention/detention basins or equivalent.
• Runoff containing oil and grease may include the use of absorbent booms or sand
filters in front of outlet structures or other equivalent measures.

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December 2021
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Table 5
Pollutant Source Summary
Stormwater Pollutant Sources
Existing Management
Description of New BMP Options
Practices
Area 1
• None.
• Cover bays and waste bin.
• Shipping/receiving area for
• Keep absorbent materials readily
frames.
available.
Area 2
• Bagfilter controls
• Cover bays and waste bins.
• Receiving area for lumber.
particulate emissions
. Keep absorbent materials readily
• Scrap wood waste bin.
from sawdust collection
available.
• Sawdust collection bin and
bin.
• Sweep area regularly and
bagfilter.
dispose of collected material
• Open waste bin
properly.
Area 3
• None.
• Cover bays.
• Receiving area for plywood.
• Keep absorbent materials readily
available.
Area 4
• None.
Keep absorbent materials readily
• Employee parking.
available.

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December 2021
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Table 6
Best Management Practice Summary
BMP's
Brief Description of Activities
Good Housekeeping
•
Sweep area regularly
•
Pick up all trash and dispose of in proper container
•
Designate material storage location
Preventive Maintenance
•
Comprehensive semi-annual facility inspections.
•
Re lar equipment maintenance.
Inspections
•
Comprehensive monthly facility inspections.
•
Semiannual stormwater system inspections
Spill Prevention Response
•
Keep absorbent materials on hand.
Sediment and Erosion Control
•
Provide maintenance to preserve vegetative cover on
unpaved areas.
Management of Runoff
Additional BMP's (Activity
and
.
Cover waste bins.(Areas 2, 3)
Site Specific)
•
Cover bays Area 1 2 and 3

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December 2021
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Table 7
Best Management Practice Implementation
Scheduled
Person
BMP's
Description of Action(s) Required for
Completion
Responsible
Implementation
Dates
for Action
Good
1. Sweep regularly.
Housekeeping
2. Pickup trash and dispose of properly.
3. Designate material storage area.
Preventive
1. Comprehensive monthly facility inspections.
Maintenance
2. Regular equip ment maintenance.
Inspections
1. Comprehensive semi-annual facility
inspections.
2. Regular equipment maintenance.
Spill Prevention
1. Keep absorbent materials on hand.
and Response
Sediment and
1. Provide maintenance to preserve vegetative
Erosion Control
cover on unpaved areas.
Management of
Runoff
Additional
• Cover waste bins.(Areas 2 and 3)
BMP's (Activity
and Site
. Cover bays (Areas 1,2 and 3)
Specific)

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December 2021
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V. PERSONNEL AWARENESS AND TRAINING
1. Introduction
If any pollution prevention program is to succeed, all of the people involved must be
properly oriented, trained, and motivated. Personnel working in potential spill areas shall
be acquainted with the following basic issues:
1. Proper precautions to prevent spills,
2. Good housekeeping,
3. Preventative maintenance,
4. Specific duties of designated personnel,
5. Material Safety Data Sheets,
6. Emergency response procedures, and
7. Facility inspection procedures.
2. Spill Prevention Measures
A. The facility shall schedule and conduct stormwater pollution prevention briefings
for their operating personnel to assure adequate understanding of pollution
prevention for the entire facility. Such briefings will highlight and describe
known spill events or failures, malfunctioning components, and recently
developed precautionary measures.
B. Facility personnel shall be trained in initial emergency response for chemical and
petroleum spills. The training shall familiarize personnel with emergency
procedures, emergency equipment, and emergency systems. Personnel shall be
sufficiently well trained and informed about procedures and equipment to make
immediate decisions.

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December 2021
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C. The facility shall always have designated personnel available who are accountable
for spill prevention and response.
D. Operators of powered industrial equipment such as forklift trucks and other such
equipment shall be trained in their proper operation.
E. Warehousing rules will be comprehensive and will follow good practices. Care
shall be taken to assure that materials and chemicals are stored properly. Reactive
chemicals shall not be stored in the same area with combustible materials.
F. Contractors or other temporary personnel using the facilities shall be informed
about the facility's provisions for stormwater pollution prevention and directed to
dispose of hazardous materials and other chemicals and wastes properly.
G. All personnel training shall be documented and records retained in the personnel
files.
3. Housekeeping
Good housekeeping principles should be practiced throughout the facility. All employees
should be trained on the location and use of housekeeping materials, spill response
materials, and personal protective equipment. Keeping the facility clean and orderly will
help facilitate identification of spills, leaks, and general maintenance problems.
Therefore, a "clean as you go" attitude should be encouraged. All employees should be
on the lookout for potential spills and conditions that could lead to direct contact of
stormwater with significant materials.
4. Preventative Maintenance
A preventative maintenance program used in conjunction with facility inspections is the
heart of any pollution prevention plan. Equipment repairs shall be initiated when defects
and flaws are revealed during an inspection and before failure occurs. Additionally,

Vanguard Frame #2 SPPP
December 2021
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normal equipment maintenance schedules will be implemented according to equipment
manufacturer's recommendations. With proper scheduling, preventative maintenance
operations can be carried out without disrupting facility operations.
Maintenance items such as repairs to leaking valves and cleaning and painting of rusting
piping or vessels shall be regularly performed. A vessel of proper size shall be provided
to catch and contain any such material that could spill on the floor or ground. The
contained material shall be properly disposed in accordance with normal and approved
facility disposal procedures for the material in question. These requirements and
procedures shall also apply to outside contractors working on -site.
5. Specific Personnel Duties
Specific personnel shall be responsible for emergency response procedures. All
personnel are responsible for the following duties:
1. Identifying spills, leaks, or potential problem areas,
2. First response and initial containment of spills, if possible, and
3. Reporting all problems to the shift supervisor.
The Shift Supervisors are responsible for the following duties:
1. Notifying the Safety Coordinator of all incidents,
2. Ensuring that all personnel are properly trained in emergency response, and
3. Ensuring that all spills are adequately cleaned up.
The Safety Manager shall be responsible for the following duties:
1. Ensuring that all Shift Supervisors are adequately trained to supervise
emergency response,
2. Reporting all significant incidents to the Emergency Response Director,
3. Verifying that any spills have been adequately cleaned up, and
The Emergency Response Director shall be responsible for the following duties:
1. Reporting significant spills to regulatory authorities, and
2. Maintaining incident reports.

Emergency phone numbers are as follows:
Police Department
Fire Department
N.C. DENR
STAT Environmental Services
6. Outside Contractors
Vanguard Frame #2 SPPP
December 2021
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911
911
[phone] (24 hours)
[phone] (days)
1-800-627-1451
Contractors or other temporary personnel using the facilities shall be informed about the
facility's provisions for stormwater pollution prevention and directed to dispose of
significant materials and other chemicals and wastes properly. Handling and hazardous
awareness training must be provided to outside contractors and all training must be
documented.
7. Facility Inspections
Facility personnel shall perform regular inspections of the facility. The inspections shall
cover the following areas:
1. Storage areas,
2. Waste accumulation,
3. Log entries, and
4. Security.
Stormwater system inspections shall be performed semiannually in April and September
and any time a stormwater problem is identified. An example stormwater systems
evaluation form is provided in Figure 4. All stormwater inspections shall include:
1. Potential spill areas,
2. Existing spills and leaks,
3. Potential new stormwater pollution contact sources,
4. Inspection of containers, tanks, and drums for signs of deterioration,

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December 2021
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5. Inspection of existing BMPs,
6. Recommendation of new BMPs,
7. Identification of sediment and erosion problem areas,
8. Visual monitoring for color, foam, outfall staining, visible sheens and dry
weather flow, and
9. A summary and narrative description of findings.
All inspection records shall be maintained in the facility files with the SPPP.
8. Stormwater Sampling/Monitoring
Vanguard Furniture, Inc. is not required to perform analytical sampling. However, visual
monitoring is required under the Vanguard Furniture's general storm water permit, NCG
180085. All storm water visual monitoring data will be collected and kept on -site as
directed under the requirements of the general storm water permit.

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December 2021
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Figure 4
Example Stormwater Systems Evaluation Form
Date:
Inspectors Name and Title:
Inspectors Signature:
Check One:
Routine Evaluation
Non -Routine Evaluation (Reason: i
Describe the Following:
1. Potential spill areas
2. Existing spills and leaks
3. Potential new stormwater pollution contact sources
4. Identification of sediment and erosion problem areas
5. Recommendation of new BMPs
6. Visual monitoring for color, foam, outfall staining, visible sheens and dry weather
flow
Condition and Practice Satisfactory? YES NO
1. Signs of deterioration of containers, tanks, and drums
2. Existing BMPs
Comments or Recommendations:
This evaluation form must be accompanied by a narrative summary including
description of findings and recommendations.

Vanguard Frame #2 SPPP
December 2021
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Table 8
Employee Training
Employee Training
Training
Schedule for
Topics
Description of Training
Trainin
Attendees
Spill Prevention
Specific duties of personnel,
Annual
Maintenance
and Response
emergency response procedures and
and Hazardous
equipment, emergency notification
Waste Personnel
protocol, contingency lannin
Good
Location and use of materials and
Annual
All employees
Housekeeping
equipment, importance of clean and
orderly facility, reporting potential
pollutant sources
Material
General management practices
Annual
All employees
Management
(BMP's), pollution potential
Practices
awareness
Hazard
Labeling, MSDSs
Annual
All employees
Communication
Preventative
Spill prevention, preventative
Annual
All shifts
Maintenance
maintenance in conjunction with
monthly inspections
Inspections
Purpose and content of regular facility
Annual
Facility
inspections, stormwater systems
inspectors
evaluations, required forms and
reporting
Outside
Stormwater pollution prevention,
As needed
Outside
Contractors
proper disposal of significant
contractors
materials, handling and hazard
awareness
Stormwater
Awareness reminder program
Annual
All employees
Pollution
Prevention
Awareness

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December 2021
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VI. STORMWATER POLLUTION PREVENTION PLAN EVALUATION
1. Semi -Annual Site Compliance Evaluation
The facility site assessment and best management practices must be regularly updated
through semi-annual site compliance evaluations. Semi-annual evaluations should be
documented and a copy of the report placed in the facility files with the SPPP. Semi-
annual site compliance evaluations shall include the following:
• Inspect stormwater drainage areas for evidence of pollutants entering the drainage
system.
• Evaluate the effectiveness of Best Management Practices (BMPs).
• Observe any structural measures, sediment controls, or other stormwater BMPs to
ensure proper operation.
• Prepare a summary report of inspection results, including the date and inspector's
name, signature, and recommended follow-up actions.
2. SPPP Revisions
This Stormwater Pollution Prevention Plan shall be reviewed and/or amended
within two weeks of:
•Revision of applicable regulations.
-Changes in facility design, construction, operations, or maintenance which
materially affect the potential for stormwater contact of significant materials.
•Identification of an SPPP deficiency or recommendation of follow-up measures
during annual site compliance evaluation inspections.
-Notification from the State that the plan does not meet a minimum requirement
of the permit.
The plan shall be reviewed at least once every year and shall be amended if such review
indicates that the plan does not reflect current operations or physical facility features or is
deficient in any way.

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December 2021
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3. Record Keeping and Internal Reporting
Records of all facility inspections and training should be kept in the facility files with the
SPPP for a period of five years. All documentation should include the name and
signature of the reporter and the date of the incident or inspection. Spill and incident
reports should also include a description of the incident, weather conditions, cause, and
any resulting environmental problems. The following records should be maintained with
the SPPP:
1. Facility inspections,
2. Spill reports,
3. Site evaluations,
4. Employee training,
5. Stormwater sampling,
6. Facility and equipment maintenance,
7. Sampling data, and
8. BMP implementation.
4. EPCRA, Section 313 Chemicals
If the facility is subject to reporting under EPCRA, Section 313 for water priority
chemicals, the SPPP must be reviewed and certified by a Registered Professional
Engineer and recertified every 3 years or after the plan is significantly changed.
This certification that the plan was prepared in accordance with good engineering
practices does not relieve the facility owner or operator of responsibility to prepare and
implement the plan.

Vanguard Frame #2 SPPP
December 2021
Page 35
Annual Review
Date I Name I Chanites
12/21/2021 Will Stange Change name of certification and names/responsibilities of
pollution prevention team. Updated assessment of stormwater
runoff flow areas.

Vanguard Frame #2 SPPP
December 2021
Page 36
Spill List
Date
Name
Details
2017
Mick James
Nos ills occurred.
2018
Mick James
Nos ills occurred.
2019
Will Stange
Nos ills occurred.
2020
Will Stange
Nos ills occurred.
2021
Will Stange
No spills occurred.

Vanguard Furniture
TRAINING
SIGN IN SHEET
TOPIC: Stormwater Management TRAINER: 1J10,1�60) DATE: }II+ I
TOPICS COVERED:
Stormwater Management
Stormwater Outfalls
Potential Contaminants at Vanguard
Spill Prevention and Control
Responding to Spills
Good Housekeeping
Best Management Practices
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AREA COMPUTATION BY COORDINA:
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PROPERTY DOES NOT LIE IN A SP
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