NCS000107_Renewal Application_20220317

SW Individual Permit Coverage Renewal
Stormwater Planning Program
1612 Mail Service Center
Raleigh, NC 27699-1612
LANXESS
Energizing Chemistry
RECEIVED
MAR 17 2927_
DENR•LANO QUALITY
3TORMWATER PERMITTING
Subject: Lanxess Corporation NPDES Stormwater Permit Renewal
Application
Permit Number NCS000107
Dear Brianna ,
Please find enclosed the application for renewal of NPDES Stormwater Permit
NCS000107 for its stormwater discharge. The permit expires July 31, 2022.
Attached are one copiy of the NPDES Stormwater Permit renewal application and
supplemental information.
We appreciate the opportunity to submit this renewal application and hope that it
meets your approval. We are available to meet with you at your convenience to
provide clarification on the renewal application.
Please contact me at 336-378-0965 extension 115 or 336-709-0046 if you have
any questions or need additional information.
Yours.sincerely,
4 LaSon 00_ Mc7 Millian ,
Plant Manager
March 11, 2022
LANXESS Corporation
LaBAROn O. McMillian
520 Broome Road
Greensboro, NC 27406
Phone [phone]
Fax [phone]
[e-mail]
w .us.lanxessxom
INTERNAL

RECEIVED
EPA Identification Number
NPDES Permit Number
Facility ame5/19
MAft0%7 20409�004
NCDO61795696
NCS000107
Lanxese Corporation
.......
Form
U.S. Environmental Protection Agency TnRAAWATER
1
:.EPA
Application for NPDES Permit to Discharge Was Atg3ttrt
NPDES
GENERAL INFORMATION
SECTION•
• r
1.1
Applicants Not Required to Submit Form 1
1.1.1
Is the facility a new or existing publicly owned
1.1.2
Is the facility a new or existing treatment works
treatment works?
treating domestic sewage?
If yes, STOP. Do NOT complete Ej No
If yes, STOP. Do NOT No
Farm 1. Complete Farm 2A.
complete Form 1. Complete
Farm 2S.
1.2
Applicants Required to Submit Form 1
1.2.1
Is the facility a concentrated animal feeding
1.2.2
Is the facility an existing manufacturing,
€
operation or a concentrated aquatic animal
commercial, mining, or silvicultural facility that is
rl
production facility?
currently discharging process wastewater?
oYes
4 Complete Farm 1 ❑✓ No
Yes 4 Complete Form 0 No
z
and Form 2B.
1 and Form 2C,
1.2.3
Is the facility a new manufacturing, commercial,
1.2.4
Is the facility a new or existing manufacturing,
m
mining, or silvicultural facility that has not yet
commercial, mining, or silvicultural facility that
commenced to discharge?
discharges only nonprocess wastewater?
Yes 4 Complete Form 1 ❑� No
❑ Yes 4 Complete Form 0 No
N
and Form 2D.
1 and Form 2E.
1.2.5
Is the facility a new or existing facility whose
2
discharge is composed entirely of stormwater
a
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
Yes 4 Complete Form 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x) or
SECTION
ADDRESS, AND LOCATIONr
2.1
Facility Name
Lanxess Corporation
`0
2.2
EPA Identification Number
u
0
NCD061795696
a
2.3
Facility Contact
N
v
Name (first and last)
Title
Phone number
La Barron O. McMillian
Plant Manager
[phone]
a
Email address
[e-mail]
2.4
Facility Mailing Address
E
Street or P.O. box
z
520 Broome Road
City or town
State
ZIP code
Greensboro
North Carolina
27406
EPA Form 3510-1 (revised 3-19) Page 1

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCD061795696
NCS000107
Lanxess Corporation
OMB No. 2040-0004
2.5
FacilEty Location
Street, route number, or other specific identifier
-
o =
20 Broome Road
y c o
County name
County code (if known)
z
Guilford,
a a4 Y K
City or town State ZIP code
='
Z. .;
Greensboro North Carolina 27406
SECTION•D
40 CFR
-�
3.1
'S C�Gode(s� � I�esc�ip�tcn�iL
v
3.2
NAiCS Cade(s)
Desc#ption'(ophoal)
`
325199
All other basic organic manufacturing
' " 1
325998
All other miscellanous chemical product and preparation manufacturing
4.1
,Name oQ a afor~ A377
Lanxess Corporation
o
4.2
Is the name you listed in Item 4.1 also the owner?
o
✓❑ Yes ❑ No
.'.
4.3
0 erator;$tatus
❑Public —federal Elublic—state ❑ Other public (specify)
O
❑✓ Private ❑ Other (specify)
4.4
_ .PhoeeNiumbe�:of Operator
[phone]
4.5
0 rator.:Address .
Street or P.O. Box
520 Broome Road
c .0
_
City or town
State
ZIP code
o 'o
Greensboro
North Carolina
27406
Email address of operator
[e-mail]
SECTION
=a
5.1
Is the facility located on Indian Land?
A c,
c
❑ Yes ❑✓ No
EPA Form 3510-1(revised 3-19) Page 2

EPA
Idenfificagon Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCD061795696 NCS000107 Lanxess Corporation OMB No. 2040-0004
SECTION-s
,i CFR •
r
6.1
`xistilii "Eit�n" eriaPelrlmiscie " i-: - -
g. ... c a�fh'aPPY and pIn:arYl�e :die crrsponngermt nuea
® NPDES (discharges to surface
m RCRA (hazardous wastes)
❑ UIC (underground injection of
a
I
water)
fluids)
-2
NCS000107
NCD061795696
"W i
❑ PSD (air emissions)
❑ Nonattainment program (CAA)
❑ NESHAPs (CAA)
'Ss3 r
❑ Ocean dumping (MPRSA) ❑ Dredge or fill (CWA Section 404) ❑ Other (specify)
k
SECTION
A•
40
7.1
Have you attached a topographic map containing all required information to this application? (See instructions for
specific requirements.)
✓❑ Yes ❑ No ❑ CAFO—Not Applicable (See requirements in Form 2B.)
SECTIONOF
4t CFR s
8.1
Describe the nature of your business.
The Greensboro, North Carolina location operates as a production site for the Polymer Additives Business Unit.
"
Lanxess Corporation site is dedicated to producing Flame Retardants, phthalate -free plasticizers for polymer
processing and other specialty products
SECTION•
COOLING WATER INTAKE STRUCTURES (40 CFR •
9.1
Does your facility use cooling water?
❑ Yes ❑ No + SKIP to Item 10.1.
3
9.2
Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at
o,
40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your
-$x-
NPDES permitting authority to determine what specific information needs to be submitted and when.
p 9 tY p )
The source of the cooling water from the City of Greensboro
SECTION
10. VARIANCE
10.1
REQUESTS (40 CFR 122.21(f)(10))
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)? (Check all that
T
apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
❑ Fundamentally different factors (CWA ❑ Water quality related effluent limitations (CWA Section
Section 301(n)) 302(b)(2))
❑ Non -conventional pollutants (CWA ❑ Thermal discharges (CWA Section 316(a))
Section 301(c) and (g))
Not applicable
EPA Form 3510-1(revised 3-19) Page 3

STORMWATER SAMPLE ANALYTICAL RESULTS
Sampling Date
2/1/2017
Location
Out Flow 1
•
(reported
5.9
•
(Calculated
value)
0.0059
• , •
35
7
2
2/1/2017
Out Flow 2
2.5
0.0025
20
7
2
9/12/2017
Out Flow 1
6.8
0.0068
28
7
3
9/12/2017
Out Flow 2
1.9
0.0019
25
7.5
3
5/1/2018
Out Flow 1
3.9
0.0039
35
6.5
3
5/1/2018
Out Flow 2
21.9
0.0219
33
6.9
3
12/14/2018
Out Flow 1
4.6
0.0046
143
6.7
3
12/14/2018
Out Flow 2
70.5
0.0705
182
6.6
3
3/25/2019
Out Flow 1
8.1
0.0081
28.9
6.4
2
3/25/2019
Out Flow 2
27.8
0.0278
113
6.5
2
10/20/2019
Out Flow 1
17.7
0.0177
62.5
6.2
2
10/20/2019
Out Flow 2
8
0.008
ND
6.5
2
1/24/2020
Out Flow 1
6.6
0.0066
56
6.3
0.25
1/24/2020
Out Flow 2
3.8
0.0038
ND
6
0.25
10/28/2020
Out Flow 1
6.3
0.0063
58.5
6.3
2
10/28/2020
Out Flow 2
1.9
0.0019
201
6.4
2
3/19/2021
Out Flow 1
6.2
0.0062
58.6
6.4
1
3/19/2021
Out Flow 2
1.9
0.0019
30.6
6.8
1
12/18/2021
Out Flow 1
15.1
0.0151
49.3
7
1.5
F- 12/18/2021
Out Flow 2
6.3
0.0063
35
7
1.5
[P►��X.1IT,14

EPA Identification Number NPDES Permit Number
Facility Name Form Approved 03/05/19
NCD061795696 NCS000107
Lanxess Corporation OMB No. 2040-0004
SECTION
11. CHECKLIST
e CERTIFICATION STATEMENT. I • •
11.1
In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application.
For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note
that not all applicants are required to provide attachments.
[� Section 1: Activities Requiring an NPDES Permit
❑ wl attachments
Section 2: Name, Mailing Address, and Location
❑ w/ attachments
[� Section 3: SIC Codes
❑ wl attachments
[� Section 4: Operator Information
❑ w/ attachments
Section 5: Indian Land
❑ w/ attachments
[� Section 6: Existing Environmental Permits
❑ w/ attachments
E
:
Section 7: Map
w/ topographic
pograp ❑ wl additional attachments
❑
ma
Section 8: Nature of Business
Elwl attachments
0
0
Aa
Pr Section 9: Cooling Water Intake Structures
❑ wl attachments
[� Section 10: Variance Requests
❑ w/ attachments
c
Section 11: Checklist and Certification Statement
❑ wl attachments
of
11.2
Certification Statement
I 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. l am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
LaBarron O. McMillian
Plant Manager
Signature
Date signed
PFA
EPA Form 3510-1 (revised 3-19) Page 4

STORMWATER DISCHARGE OUTFALL MONITORING REPORTS
Date of Inspection
Location
Color
Odor
Clarity
Floating
Solids
Suspended
Solids
Foam
Oil Sheen
Erosion
9/12/2017
Out Flow 1
Clear
None
1
2
2
No
No
No
9/12/2017
Out Flow 2
Clear
None
1
1
2
No
No
No
5/1/2018
Out Flow 1
Clear
None
1
1
3
No
No
No
5/1/2018
Out Flow 2
Clear
None
1
1
2
No
No
No
12/14/2018
Out Flow 1
Clear
None
1
1
2
No
No
No
12/14/2018
Out Flow 2
Clear
None
1
1
2
No
No
No
3/25/2019
Out Flow 1
Clear
None
1
1
3
No
No
No
3/25/2019
Out Flow 2
Clear
None
1
1
2
No
No
No
10/20/2019
Out Flow 1
Clear
None
1
1
1
No
No
No
10/20/2019
Out Flow 2
Clear
None
1
1
1
No
No
No
1/24/2020
Out Flow 1
Clear
None
1
1
1
No
No
No
1/24/2020
Out Flow 2
Clear
None
1
1
1
No
No
No
10/28/2020
Out Flow 1
Clear
None
1
2
2
No
No
No
10/28/2020
Out Flow 2
Clear
None
1
2
3
No
No
No
3/19/2021
Out Flow 1
Clear
None
1
1
1
No
No
No
3/19/2021
Out Flow 2
Clear
None
1
1
1
No
No
No
12/18/2021
Out Flow 1
Clear
None
1
1
1
No
No
No
12/18/2021
Out Flow 2
Clear
None
1
1
1
No
No
No
INTERNAL

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Program
Facility Name:
LANXESS CORPORATION
Permit Number:
NCS000107
Location Address:
520 BROOME ROAD
GREENSBORO, NC 27406
County:
GUILFORD COUNTY
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
LABARRON O. MCMILLIAN
Date Z d Z t-
PLANT MANAGER
Print or type name of person signing above Title
SPPP Certification 10/13

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
Nz
(Do not submit the site Stormwater Pollution Prevention Plan)
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3.
k 4.
A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

T1' r z ,
q ' ,
Outfalls from the facility flow generally to the east and discharge through wooded property South Buffalo Creek (Stream
Index 16-11-14-2a), part of the Cape Fear River drainage basin. South Buffalo Creek is considered impaired (according to the
NC 303(d) list of impaired waters) for which a Total Maximum Daily Loads (TMDLs) have been established for Cyanide,
Fluoride and Selenium (approved 09/16/97).
FIGURE F-2
SITE MAP
MAP SCALE: 1 INCH = 200 FEET (approximate)
LANXESS Corporation
MAP SOURCE: Greensboro, North Carolina
Guilford County GIS: http://gis.guilfordcountync.aoy/guilfordis/
April 2020

SECTION NO.4
SUPPLEMENTAL INFORMATION
BEST MANAGEMENT
PRACTICES
LANXESS Corporation is committed to preventing pollution at the source, and as such, has implemented
numerous best management practices (BMPs) and at -source storm -water pollution prevention controls to reduce
the quantity of pollutants in the Storm -water runoff. The structural controls (e.g., containment, dike, curb, and/
or roof) and management practices employed at the individual significant materials at LANXESS are, listed in
Table 2 in the Supplemental Information Section No. 1. The site -wide BMPs that are, utilized by LANXESS
are; described in this section and include:
➢ Good Housekeeping,
➢ Inspections/Preventative Maintenance Programs,
➢ Outside Material Storage/Tanks/Secondary Containment,
➢ Material Handling,
➢ Spill Prevention and Response,
➢ Sewer and Outfall Identification, and
➢ Employee Training.
Good Housekeeping
LANXESS Corporation maintains a clean and orderly facility through implementation of a variety of programs,
practices and procedures, including:
• Regular pickup and disposal of garbage and debris
• Routine inspection for leaks
Proper material container storage practices
• Identification and labeling of all chemical substances
• Disposal of old equipment and used chemicals
These housekeeping practices help to reduce waste and pollutant generation as well as the potential for spills
and leaks.
Inspection/Preventative Maintenance Program
The preventive maintenance program at LANXESS ensures that the Storm -water control facilities are clean and
operating effectively. The program consists of visual inspection, cleaning, and repair activities. Inspections
are, conducted at the Storm -water controls and the significant materials identified on the Site Map and Table 2
in the Supplemental Information Section No.1. At a minimum, these inspections are, conducted semi-annually.
Upon completion of the inspection, any cleaning and repair activities, if needed are, documented. Completion
of the inspections, cleaning, and repairs are tracked electronically.
LANXESS Corporation-MES Storm -water
INTERNAL

4 '.__�t
Specific inspection areas include:
■ Material handling and storage areas
■ Secondary containment areas
■ Storm -water outfalls
■ Catch basins and trench drains
■ Roofs and covers
■ Potential spills and areas of possible contamination
Outside Material Storaae/Tanks/Secondary Containment
LANXESS Corporation practices and activities related to outside material storage areas and aboveground tanks
are in place to prevent or minimize contact of significant materials with storm -water. Many material storage
areas are covered and /or have containment curbing or grading. Aboveground tanks; are in compliance with
federal and state laws for containment, integrity testing, overflow protection, and protective guards. Storm -
water retained by the curbing or dikes is, visually inspected for contaminants prior to release.
BMPs currently in use:
■ Provide secondary containment for liquid storage
■ Provide containment curbing, dikes, and /or grading
■ Cover materials to eliminate exposure to Storm -water
■ Store materials on pallets or racks
■ Visually inspect Storm -water retained by curbing/dikes/containment prior to release
■ Move storage areas inside if possible
Material Handling
Material loading and unloading is, typically conducted in areas designed to reduce potential contact with Storm -
water. Loading areas for bulk chemical transfers are either: (1) contained to allow visual inspection of Storm -
water prior to release, or (2) are, graded to direct Storm -water to the process drain system for treatment prior to
discharge. The Storm -water is contained during transfer operations by secondary containment, curbing,
grading, trays, and /or drain covers. Further, manual valves in the closed position have, been installed in
selected storm drains.
Direct pipeline transfers are in place for several materials and waste streams. This method of material transfer
greatly reduces the potential of Storm -water contamination.
There are detailed written guidelines on loading and unloading procedures in the Spill Prevention Control and
Countermeasures Plan.
Spill Prevention and Response
LANXESS Corporation has written procedures on spill prevention and response. These procedures describe the
protocol of responding to a spill and the individuals at the site that are to be, contacted. The procedures are
included in the facility Spill Prevention Control and Countermeasures Plan and in the Radiological Contingency
and Emergency Plan. Site staff are; trained on spill prevention and response.
LANXESS Corporation-NMES Storm -water
INTERNAL

EmAloyee Training
The Employee Education and Training Program is, designed to familiarize key employees with the intent and
components of the Storm -water Pollution Prevention Plan. Training is, provided for employees involved in
operations with the potential to affect Storm -water.
Topics included in the training session include:
■ General Storm -water awareness
■ How to use the Storm -water Pollution Prevention Plan
■ Chemical spill response procedures
■ Preventative maintenance
■ Inspection Procedures
■ Materials management practices
■ Good housekeeping measures
Sewer and Outfall Identification
There are three separate drainage collection systems at the facility: process wastewater, sanitary wastewater,
and Storm -water. Sewer manhole covers and catch basins have been color -coded to distinguish between these
systems.
In addition, as described previously, placards are, posted at all storm -water outfalls. This ensures consistent
location evaluation during visual monitoring, outfall inspections, and non -storm -water discharge assessments.
(Specialist, 2018)
LANXESS Corporation-MMES Storm -water
INTERNAL

LaNXESS
Energizing Chemistry
SITE MAP for Storm Water Prevention Plan
Permit NCS000107 Expires 6/31/2022
Lanxess Corporation
520 Broome Road
Greensboro, NC 27406
Attached is a site map of the Lanxess Corporation showing the following:
1. Industrial Buildings
2. Drainage Areas for each outfall
3. Activities occurring for each outfall
4. Concrete Impervious Areas.
5. Storm water outfall #1 near the shipping dock
6. Storm water outfall #2 gate valves between E & C tank farms.
Raw materials used in manufacturing include various alchols, organic anhydrides, sulfonyl
chlorides, inorganic alkaline material, and organic solvents.
Finished products include esters, sulfonamides, polymers, and other specialty chemical
compounds.
During the past five years time frame, there have been no significant spills or leaks of pollutants
that have come in contact with the storm water discharges.
INTERNAL

Lanxess Corporation
520 Broome Road
Greensboro, NC 27406
LANXESS
Energizing Chemistry
Best Management Practices for
Storm Water Prevention Plan
Permit NCS000107 Expires 6/31/2022
Stormwater Management Overview
At the Lanxess Greensboro facility, all loadinglunloading areas are covered. The areas behind
inside production area LP-2 are primarily for drum and tote filling on both liquid and molten
materials. Filled drums are stored in warehouse by shipping dock. Cast molten material is
stored on racks and shelves prior to being ground to meet customer specifications. Cast material
solidifies quickly while filling and casting in LP1 or LP2 diked production areas, to prevent
spilling to environment.
Drum recycling takes place on contained concrete pad behind LP2. Drum recycling consists of
weak caustic rinse of emptied drums on concrete pad by automated filling equipment. Caustic is
pumped into and out of drum. Concrete pad contains all spill to the sump, for collection to C6
pretreatment. C6 pretreatment is discharged to City of Greensboro POTW.
All outside tanks are diked, in the event of a spill or leak. Storm water from these dikes is
pumped to collection in C6, prior to discharge to City of Greensboro POTW. Facility has
equipment for recovery in the event of a spill or leak. No spills from the diked tank farms should
ever be released to stormwater drainage system.
Additionally the manufacturing areas designated on the map (UP-1, UP-2, LP-1, and LP-2,
Flammable Storage Warehouse, Finished Product Storage, Centrifuge Building, hot room
storage, and Pilot Plot) are all designed to contain accidental spills or leaks to roadways and
storm water discharge.
Spill Prevention and Response Management Overview
The identified potential pollutant sources at Lanxess Greensboro are:
1. Failed or broken valves, transfer lines, or hoses used during loading and
INTERNAL

LANXESS
Energizing Chemistry
unloading operations.
2. Accidental release of materials, from the reactors, such as rupture discs,
pressure relief valves activation, or in the event of attached broken valves or lines.
3. Accidental spills of materials while transporting containers between production
and warehouse areas, including flammable storage building, and the hot room
storage buildings.
Daily management walk-arounds are conducted to assess status of tanks and production
equipment. Work orders for needed improvements are recorded in computer system to be
repaired.
Employee Training
The Employee Education and Training Program is, designed to familiarize key employees with
the intent and components of the Storm -water Pollution Prevention Plan. Training is, provided
for employees involved in operations with the potential to affect Storm -water.
Topics included in the training session include:
■ General Storm -water awareness
• How to use the Storm -water Pollution Prevention Plan
■ Chemical spill response procedures
■ Preventative maintenance
■ Inspection Procedures
■ Materials management practices
■ Good housekeeping measures
INTERNAL