NCG060229_Assessment of Best Management Practices_20131027

,m
Procter & Gamble Pet Care
The lams Company
845 Commerce Drive
Henderson, N.C. 27537
October 28, 2013
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Assessment of Best Management Practices
Dear Ms or Sir:
In response to the requirement in Part II Section E of Stormwater General Permit
NCG060000, Certificate of Coverage NCG060229, we are providing this assessment of
Best Management Practices of Procter & Gamble's Henderson, N.C. facility.
ray v ti � �
7 2C U

NCDENR
November 2212013
Page 2
Assessment of Best Management Practices (BMPs)
The assessment was conducted by P&G Henderson staff during September/October 2013
and consisted of field observations of all outside industrial activities, walkthroughs of all
storm water conveyance systems and walks of all property areas and boundaries. The
assessment is presented below using the sequence suggested by Part II, Section E of the
General storm water permit.
1) Narrative Description of all Material Handling Activities:
The majority of industrial activities that occur at the P&G Henderson facility are
conducted inside the main plant buildings or under permanent covers to prevent
storm water exposures. Outside industrial activities at the P&G Henderson site
are limited to material receiving/unloading/storage, craft contractor material
storage areas, wastewater treatment plant components, and parking areas for
empty and loaded raw material and finished product trucks.
All materials are received/unloaded within structures that prevent exposure to
storm water. Liquid raw materials such as, but not limited to, animal fats,
liquefied meats, choline chloride, and Naturox are unloaded within covered and
spill protected structures. Dry grains and AnPro meal materials are unloaded
from trucks and/or rail cars within enclosed unloading bays.
A majority of the storage tanks utilized by P&G Henderson are located within the
main plant buildings. For example, animal fat, digest, and Naturox are stored in
tanks located within the main building and are not exposed to storm water. The
tanks are also provided secondary containment and do not represent exposure of
significant material to storm water.
The animal protein meal operation, AnPro, is housed within an on -site building
that is adjacent but separate from the main pet food manufacturing building.
Unloading of unprocessed protein meal and load -out of processed protein meals
occurs within enclosed bays. AnPro has also covered the north side area of their
building to prevent storm water exposure of equipment such as air compressors,
roll -off waste box and 500 gallon diesel fuel tank for refueling of AnPro material
handling equipment.
A 10,000-gallon storage tank containing choline chloride (aqueous solution) is
located under roof on the east side of the main plant building. Partial secondary
containment for this tank is shared with the fat and oil unloading area, which is
also under roof. The risk of impact to stormwater from small spills and leaks is
very low.

NCDENR
November 22, 2013
Page 3
The grain storage silos and unloading area are located at the northeast corner of
the main building. The area contains four grain silos and a grain storage elevator
with a grain auger bridge between the elevator and the main building. A
receiving hopper for grain fines is also located in this area on the ground. Fines
are conveyed pneumatically via a tube into the hopper. The system is designed to
be totally enclosed. The risk of impact to storm water from this area is low.
The grain receiving areas are covered under shelters, and the grain transfer
operations are not directly exposed to storm water. Raw materials are also
unloaded at the Protein Building. Personnel are present during unloading
operations, and the unloading area is also covered to prevent exposure to storm
water.
The fire pump fuel tank is also located on the east side of the building. Tanker
trucks periodically unload diesel fuel into the fire pump fuel tank located inside
the fire pump house. Tanker trucks also unload diesel fuel into a covered 500-
gallon diesel fuel tank located north of the Protein Building. Refrigerated meat
product is also loaded/unloaded on the east side of the building. These materials
are loaded/unloaded from enclosed tractor -trailers abutting up to enclosed loading
bays. The concrete in this area is also sloped so that any potential spills are
collected and discharged to the facility's wastewater treatment plant.
The chemical room and use area is located within the eastern portion of the main
building. The drums are located inside and are not exposed to precipitation. New
drums are periodically brought on site, unloaded from trucks, and transferred to
these areas. The drums are closed during all transfer operations.
The finished product loading docks for the facility are located on the west side of
the main building. Most materials are loaded into enclosed tractor trailers
abutting up to enclosed loading bays.
Waste finished product is stored in the warehouse on the west side of the facility
and is periodically loaded into enclosed tractor trailers abutting up to enclosed
loading bays for delivery to the local landfill, contracted composting facility.
General refuse and recycling material is stored in three enclosed compactors
located on the east side of the main building and is periodically picked up by
contracted Waste Management industry.
Loading/unloading operations may also occur at the wastewater treatment facility.
For example, totes of sodium hydroxide are periodically unloaded adjacent to the
wastewater treatment facility building located east of the main building. The totes
are immediately transferred inside the building and are not exposed to
precipitation. In addition centrifuge solids are collected in a covered roll -off box
which is periodically picked up by a contracted service for composting.

NCDENR
November 22, 2013
Page 4
The primary wastewater treatment plant components are located in a separate
enclosed structure east of the main building. The treatment system consists of
waste pits, treatment ponds, with clarifier, and dissolved air flotation units.
A sand pile is also located adjacent to the wastewater treatment facility. The sand
is used throughout the site in the event of a spill.
2) Feasibility evaluation of reduced exposure potential.
Fats, oils, meat -products and animal protein materials used in the manufacturing
processes are received, unloaded and utilized within enclosed or covered
structures that prevent exposure to storm water.
Grain material storage silos are located outside the main plant building. Grains
are conveyed from the silos into the main plant building via enclosed conveyance
systems that prevent exposure to storm water.
Trucks delivering grains and dry protein materials to the Henderson site can
release incidental amounts of materials that have accumulated or adhered to the
truck and/or trailer's structural components. As trucks transit the property
materials can be deposited on the paved areas of the site including truck
parking/drop lot areas and perimeter road.
Good housekeeping BMPs utilized by P&G Henderson include the following:
• Periodic street sweeping of all paved areas to remove raw materials that
may have been deposited by transiting truck/trailer rigs.
• Doors to unloading bays are maintained in their closed positions except
when delivery trucks or railcars are entering/exiting the structures.
• Periodic inspections of all outside areas of the plant are conducted by the
Site Environmental Leader. Any observed accumulation of materials that
could migrate into storm water conveyance systems are immediately
addressed.
Potential enhancements to current practices in order to minimize exposure:
• Historically periodic street sweeping activities have been conducted on a
once per calendar month frequency. These activities could be increased to
an every two -week frequency during spring & summer months. This
potential enhancement to current management practices is quite feasible.

NCDENR
November 22, 2013
Page 5
3) Presence of animal wildlife.
The P&G Henderson facility is located outside of the City limits in a sparsely
populated area of Vance County. The property is bounded on the east
predominantly by agricultural fields, to the south by Peter Gill Road and a small
farmstead and mulch operation, to the west by Commerce Drive and two light
industrial manufacturing operations, and to the north by undeveloped wooded
acreage. During site property inspections by P&G personnel evidence (ex: animal
tracks on the property, visual sittings) of the following animal wildlife have been
observed:
• Deer
Possums
• Skunks
• Groundhogs
• Squirrels
• Chipmunks
• Rodents
• Rabbits
• Beavers
• Feral cats
• Feral dogs
• Owls
• Pigeons
• Crows/Ravens
• Hawks
• Vultures
• Various song birds
• Seagulls
Many observations of the above wildlife have been within the storm water
conveyance systems and areas of our property that drain into the conveyance
systems. As a result, it is our belief that feces from wildlife contribute to the
presence of fecal coliform in our site's storm water conveyance systems.
4) Corrective action plan review and proposal.
The P&G Henderson plant has historically implemented or enhanced several BMPs at
the site to help ensure storm water discharges meet permit expectations. The
following is a current list of the site's BMPs:
• Environmental awareness training for all employees — (Annual)
• Good housekeeping and equipment maintenance.
• Off -site maintenance of Company -owned over -the -road vehicles.

NCDENR
November 22, 2013
Page 6
• Development and enhancement of grassed areas across various portions of the
property for improved erosion prevention.
• Secondary containment of above -ground liquid material storage tanks.
• Emission control devices to minimize release of airborne contaminants.
• Change management process includes reviews by site HS&E leaders.
• Storm water conveyance systems.
• Spill retention areas serving areas of liquid material unloading operations.
• Enhanced drainage areas at outfalls 1 & 4 by replacing quarry rock with
concrete drain pads. This allows for better drainage and drying of the
immediate area and easier access for periodic cleaning of debris from the
drainage to the actual outfall. Completed 2012-2013.
• Rail car receiving/unloading enclosure has been extended to allow better
control of fugitive dust during unloading process. Completed 2013.
• Automated doors at protein unloading structure to ensure timely closure when
trucks are staged for loading/unloading. Completed 2013.
• Re-routing of condensate discharge from our plant dehumidifying equipment
away from conveyance system for outfall #4 and into our waste water
treatment facility. We believe this small but fairly constant flow of clean
water potentially contributes to creating an environment conducive to growth
of bacteria and algae.
o Completed November 2013.
The following is a list of additional actions planned to further ensure storm water
discharges from the P&G Henderson site meet permit expectations:
• Flow improvements for portions of outfalls 1, 2 and 4:
o Conducting grading work to eliminate potential for standing water
within the conveyance system swales/ditches.
o Replacing sections of quarry rock with crushed gravel to allow better
drainage and drying of conveyance system between storm events.
o Above items targeted for completion during JFM 2014.
Should you have questions or concerns please contact our site environmental leader, John
Romero, at 252-204-1167 or via email at [e-mail]
Sincerely,
Kathy Brown
Henderson Site Leader