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HomeMy WebLinkAboutNCG180085_Compliance Evaluation_20211228E F VANGUARD F U R N I T U R E December 23, 2021 Mr. James Moore, Assistant Regional Engineer NCDEQ Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC 28115 RE: Compliance Evaluation Inspection Report Vanguard Furniture Company, Inc. NCG180012 NCG180023 NCG180085 Dear Mr. Moore, RECEIVED DEC 2 8 2021 DENR-DEMLR Land Quality Section Mooresville Regional Office Vanguard Furniture Company, Inc. received the compliance evaluation inspection report in reference to the inspection performed on September 22, 2021. We have done the following to correct the deficiencies: 1. Reviewed and updated all the Stormwater programs. 2. Monitored each outfall. 3. Reviewed site map. 4. Conducted annual Stormwater training If you have any questions, please feel free to contact me at 828-328-5601 or at wstan¢e(dvanguardfurniture.com Sincerely, i Will Stange, Safety Manager. Mailing: post QJJice Boz218y, Hickory, NC 286o3 I ph) sical: jog Simpson Street, Conover, NC 28613 1 phone 828.326.563t I Jaz 828.328.9816 W WO/.VANGUARDFUANITDRE AOM RECEIVED DEC 2 8 2021 JENR-DEMLR Land Quality Section STORMWATER POLLUTION :Mooresville Regional Office PREVENTION PLAN VANGUARD FURNITURE CO., INC. VGM, VGF, and CGF Permit NCG180012 Origin Date: November 1999 Revision Date: December 2021 Prepared for: Vanguard Furniture Co., Inc. Site Address: 109 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 (919)836-8688 go Vanguard Furniture SPPP December 2021 Page 2 DISCLAIMER This Stormwater 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 Furniture 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 ani Signature Date Signed o�c , dUa. I Area Code and Telephone No. (828) 328-5631 H Vanguard Furniture SPPP December 2021 Page 4 TABLE OF CONTENTS SECTION P_ I. POLLUTION PREVENTION TEAM 6 II. FACILITY MAPS 8 III. SITE ASSESSMENT 13 1. Chemical Inventory 13 2. Potential Pollutant Evaluation 13 3. Existing Management Practices 19 4. Existing Monitoring Data 20 5. Spill Incidents 20 6. Non-Stormwater Discharge Certification 22 IV. BEST MANAGEMENT PRACTICES 23 V. PERSONNEL AWARENESS AND TRAINING 31 1. Introduction 31 2. Spill Prevention Measures 31 3. Housekeeping 32 4. Preventative Maintenance 32 5. Specific Personnel Duties 33 6. Outside Contractors 34 7. Facility Inspections 34 8 Stormwater Sampling/Monitoring 35 VI. STORMWATER POLLUTION PREVENTION PLAN EVALUATION 38 1. Semi -Annual Site Compliance Evaluation 38 2. SPPP Revisions 38 3. Record Keeping and Internal Reporting 39 4. EPCRA, Section 313 Chemicals 39 (Continued next page) a 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 Furniture SPPP December 2021 Page 5 10 17 18 21 27 29 30 37 Figure 1 Pollution Prevention Team Organization Chart 7 Figure 2 Pre-BMP Site Map 9 Figure 3 Facility Location Map 12 Figure 4 Example Stormwater Systems Evaluation Form 36 Vanguard Furniture 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 Vanguard Furniture 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 Furniture SPPP December 2021 Page S 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 before 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 Furniture SPPP December 2021 Page 9 Figure 2 Pre-BMP Site Map (See Map Pocket) Vanguard Furniture SPPP December 2021 Page 10 Table 1 Significant Material Areas* Area 1 (South Side of VGM Building) Receiving and Shipping area Area 2 (East Side of VGM Building) Compactor waste bin Receiving area Waste bin Wooden pallet storage area Hazardous waste drum storage area Area 3 (West Side of VGM Building) Shipping area Area 4 (South Side of VGF Building) Receiving and Storage area for finishing materials (paints, lacquers, stains, etc.) Shipping area Area 5 (East Side of VGF Building) Miscellaneous debris pile Waste bin Receiving area Area 6 (North Side of VGF Building) Sawdust collection area with bagfilter Wood scrap waste bin Empty glue drums Cardboard waste bin Area 7 (South Side of CGF Building) Hazardous waste drum storage area Vanguard Furniture SPPP December 2021 Page 11 Table 1 Significant Material Areas (continued) Area 8 (East Side of CGF Building) Shipping and Receiving area Waste bin Area 9 (North Side of CGF Building) Receiving area Area 10 (West Side of CGF Building) Closed waste bin The significant material areas listed are located on the pre-BMP site map. 0 n Facility Location Map �- m 9L . 4C q.MdNtlit Www HICKORY, NC 31051SW-024 1993 stledddrees: i�t IO'1 'a 9L1+'Xt CAx+�, NMhCarNvu 2f+iL'a SLI IIUTTaN 51REkkT, SUITE L 0T RAIEWK.NC 'MU (919) 634-Bf86 Azv&wal.0 - SUh,I& ILaccov� WA q-. ANVT fc-w--IAg AIIPLTFD+,•,11PER TECHNOLOGY Vanguard Furniture SPPP December 2021 Page 12 .wC � /rt� +,LgI01 1\li,'� `ON, MC 35mi-FMFO24 L334 SG -C ]24= e fna ® 3]Ol mm s)p rta .E vANcuARD rmirrum, cowANY 1N4" FIGWE 3 FAMrLY IA AIIIih"13.('W Swan. ]'01999 III. SITE ASSESSMENT 1. Chemical Inventory Vanguard Furniture SPPP December 2021 Page 13 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 facility. A visual inspection of the facility revealed the following potential pollutant areas: Area 1 Trucks are parked in the receiving areas while being unloaded of boxing materials, frames, upholstery materials, and fabrics. This area is also used to loaded finished product. There is the potential for oil and grease buildup on the pavement or minor petroleum spills from trucks with leaks. Two of the four unloading and loading areas are covered which minimizes or eliminates the potential for stormwater contact with products being transported to Vanguard Main building at these areas. There are accumulated piles of miscellaneous debris such as wooden pallets located in this area. There is the potential that stormwater could contact any residues on the pallets. Runoff from Area 1 flows east into grated storm drain inlets on the east side of Vanguard Main building and flows east into Cline Creek which is located on the east side of the property line. Area 2 An enclosed waste compactor bin and two open waste bins are located in this area. Upholstery waste from Vanguard Main building is collected in these bins and the waste is hauled off periodically for disposal in a landfill. The waste bin for metal is recycled. Vanguard Furniture SPPP December 2021 Page 14 There are also piles of wooden pallets located in this area. This is the primary location for pallets to be kept until they are hauled away to be recycled. Approximately 10-12 55- gallon drums of hazardous waste are also located in Area 2, in a storage area with an overhead cover surrounded by a berm. There is the potential for stormwater to contact any residues on the drums or pallets. There are two receiving bays in this area and both are covered. One bay is located under a shelter used to cover raw wood storage. This bay receives upholstery supplies. The other receiving bay located farthest north receives polyurethane foams, cushions, and frames. There is the potential for oil and grease buildup from trucks with leaks to accumulate on the pavement in this area. Runoff from Area 2 flows east collecting in grated storm drains on east side of Vanguard Main building which discharge into Cline Creek which is located on the east side of the property line. Area 3 Trucks are parked in the Supply Cage area while being unloaded with upholstery supplies, cushions, and frames. There is the potential for oil and grease buildup from trucks with leaks to accumulate on the pavement. Runoff from Area 3 flows north east collecting in grated storm drain inlets on the east side of Vanguard Main building which discharge into Cline Creek on the east side of the property line. Area 4 Trucks park in this area while unloading finishing material such as lacquers, stains, paints, etc. and load frames for delivery to other plants. The finishing materials are located in a covered storage area, which reduces or eliminates the potential for stormwater contact with these products. However, some empty containers are located outside the building to be picked up for disposal. There is potential for oil and grease buildup on the ground from trucks with leaks. Vanguard Furniture SPPP December 2021 Page 15 Runoff from Area 4 flows east and collects in grated storm drain inlets on the east side of Vanguard Frame building which discharges into Cline Creek on the east side of the property line. Area 5 Miscellaneous debris such as empty drums and scrap metal is located in this area, along with one open bin for waste. There is the potential for stormwater contact with any residues on the materials in this area. Lumber is stored and lumber is received under a covered structure in this area, minimizing the potential for stormwater contact. However, there is the potential for oil and grease buildup on the ground in this area when trucks deliver the wood and from forklifts in the area. A sawdust collection system equipped with bagfilters and an enclosed trailer used for dust collection also are located in this area. Runoff from Area 5 flows east into grated storm drain inlets and discharges into Cline Creek on the east side of the property line. Area 6 A sawdust collection system equipped with a bagfilter and a scrap wood collection bin are located in this area. There is potential for stormwater contact with the materials in the bin. Wooden pallets are located in this area, along with stored plywood under a covered shed. There is the potential for stormwater contact with any residues on pallets, or plywood. Runoff from Area 6 flows east into grated storm drains along the north side of Vanguard Frame building and discharges into Cline Creek which flows along the eastern property line. Area 7 Approximately 10-12 55-gallon drums of hazardous waste are located in Area 7, in a hazardous storage area with an overhead cover surrounded by a berm. Empty drums are on the side of the building. There is the potential for stormwater to contact any residues on the drums Vanguard Furniture SPPP December 2021 Page 16 Runoff from Area 7 flows south east into storm drains located on the eastern side of Vanguard Frame building and discharges into Cline Creek which is located on the east side of the eastern property line. Area 8 Trucks are parked at the shipping and receiving bays in this area while delivering supplies and white wood product or picking up finished product for distribution center. An uncovered waste bin for trash is also located in this area. There is the potential for oil and grease buildup on the pavement from trucks with leaks. Runoff from Area 8 flows east into Cline Creek, which is located on the east side of the eastern property line. Area 9 Trucks are parked at Bay 53 while unloading paint, filters, and rags. There is the potential for oil and grease buildup on the pavement from trucks with leaks. Runoff from Area 9 flows north until it collects in a grated storm drain inlet along Farrington Street and discharges into Cline Creek. Area 10 No delivers are made in this area but there is a closed waste bin. There is the potential for stormwater contact with the materials in this area if the bin is open or material left on dock. Runoff from Area 10 flows north into a grated storm drain inlet along Farrington Street and discharges into Cline Creek. Vanguard Furniture SPPP December 2021 Page 17 Table 2 Chemical and Material Inventory Material Purpose/ Use Quantity Purchased/Stored Gallons Contact with Stormwater Glaze Manufacturing 330 No Lacquers Manufacturing 660 No Stains Manufacturing 330 No Glue Manufacturing 230 No No. 2 fuel oil Back up fuel source 7,500 No Hazardous waste Waste 1,100 Yes Vanguard Furniture SPPP December 2021 Page 18 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 site tank) pile covered, drum Material Exposure (Units) map) sealed) Hazardous * 11,100 Area 2, 7 drum Overhead shed with waste gallons berm surroundin it Upholstery * ------- Area 2 bin None waste bin Miscellaneous * ------- Area 2,4,5,6,8,10 bin None waste bin Wooden * ------- Area 1,23476 pile None pallets Miscellaneous * ------- Area 1,5,6 pile None debris Sawdust * ------- Area 5,6 bin Bagfilter collection bin Empty drums I* ------- Area 4 5 7 drum Drums sealed * Facility has been operating for approximately 5 years. These types of materials have been stored or located in the areas indicated for that period. Wooden pallets, empty drums, and hazardous waste drums are periodically hauled off for disposal when enough materials have accumulated. The waste bins are emptied periodically and the waste material hauled off for disposal. 13 Vanguard Furniture SPPP December 2021 Page 19 3. Existing Management Practices Numerous areas at the facility already employ measures to reduce stormwater contact with significant materials and activities. These areas are as follows: Area 1 Two of the four receiving areas are covered thereby reducing the potential for stormwater with the materials being unloaded. Area 2 The upholstery waste bin compactor is enclosed, thereby eliminating the potential for stormwater contact with the contents of the waste bin. The receiving bay for frames and upholstery supplies is located under the covered structure reduces the potential for stormwater contact with materials being unloaded. This covered area also reduces the potential for stormwater to contact the wood stored under the cover. Overhead shelter with surrounding berm for hazardous waste storage. Area 3 One of the bays for Supply Cage area is covered, thereby reducing the potential for stormwater contact with the materials being unloaded. Area 4 The finishing materials are kept inside an enclosed covered storage area, thereby eliminating the potential for stormwater contact with the materials. Area 5 The receiving bay and storage area for lumber are located under a covered structure, which reduces the potential for stormwater contact with lumber. Area 6 A bagfilter is being used to collect airborne particles (sawdust) generated from material handling operations. Area 7 Overhead shelter with surrounding berm for hazardous waste storage. 7 r Vanguard Furniture SPPP December 2021 Page 20 4. Existing Monitoring Data Prior to 1999, there was no existing stormwater monitoring data available. This facility is not required to perform analytical monitoring under their general stormwater permit, NCG 1800012. All stormwater visual monitoring data will be collected 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 stormwater permit as defined in Table 4. Vanguard Furniture SPPP December 2021 Page 21 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. Vanguard Furniture SPPP December 2021 Page 22 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((ice 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 Presi Date Signed 6Zj Area Code and Telephone No. (828) 328-5631 Vanguard Furniture SPPP December 2021 Page 23 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 stormwater pollution. Recommended BMPs for the previously identified areas are as follows: Area 1 Trucks park in the receiving area while unloading materials. Two of the four receiving bays are covered. It is recommended that the other receiving bays be covered and/or avoid performing unloading activities in the rain. Absorbent material should be readily available. Area 2 Drums of hazardous waste are being stored in this area until hauled off for disposal. It is recommended that these drums continue to be stored in the designated hazardous waste area that has an overhead shelter and surrounding berm. This area is also the main storage location for wooden pallets. The pallets should be covered and runoff should be diverted around the storage area to minimize stormwater contact. Absorbent material should be readily available. Area 3 Absorbent material should be readily available. Area 4 Finishing materials are received in this area. It is recommended that any empty drums of finishing material be kept inside or cover provided and runoff diverted around the drums to reduce the potential for stormwater contact with any residues on the drums. It is recommended that the receiving bays be covered and/or avoid performing unloading activities in the rain. Some wooden pallets were located in this area. It is recommended that these pallets be moved to the designated wooden pallet storage area and covered until moved to reduce the potential for stormwater contact. Absorbent material should be readily available. T Vanguard Furniture SPPP December 2021 Page 24 Area 5 It is recommended that the miscellaneous debris in this area be cleaned up and disposed of properly including placing empty glue drums in designated covered area. A bin for miscellaneous waste is located in this area. This bin should be covered to eliminate the potential for stormwater contact with any materials inside the bin. Absorbent material should be readily available. Area 6 Wooden pallets located in this area should be moved to a designated wooden pallet storage area. Until moved these pallets should be covered to reduce the potential for stormwater contact. The sawdust collection bin is also located in this area. This area should be swept on a regular basis and sawdust placed in an appropriate waste bin for disposal. Absorbent material should be readily available. Area 7 It is recommended that the receiving bay for chemicals be covered and/or avoid bringing in/out chemicals in the rain. Drums of hazardous waste are also being stored in this area until hauled off for disposal. It is recommended that these drums continue to be stored in the designated hazardous waste area that has an overhead shelter and surrounding berm. Absorbent material should be readily available. A metal waste bin is located in this area. This bin should be covered to eliminate the potential for stormwater contact with the waste materials inside. Area 8 Trucks park in the shipping and receiving areas while loading and unloading materials. It is recommended that these bays be covered and/or avoid performing unloading activities in the rain. Absorbent material should be readily available. A waste bin for miscellaneous debris is located in this area. This waste bin should be covered to eliminate the potential for stormwater contact with the waste inside. Area 9 Trucks park in the receiving area while unloading materials. It is recommended that the shipping bay be covered and/or avoid performing unloading activities in the rain. Absorbent material should be readily available. Vanguard Furniture SPPP December 2021 Page 25 Area 10 There is a closed waste bin for Finish located in this area. It is recommended that the waste bin be kept closed and no material left on the dock. Absorbent material should be readily available. General Best Management Practices for the site in general will include regular comprehensive facility inspections, maintaining an updated material inventory, and ensuring that current SDSs 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 before 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. Y - � Vanguard Furniture SPPP December 2021 Page 26 • 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. • 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. Vanguard Furniture SPPP December 2021 Page 27 Table 5 Pollutant Source Summary Stormwater Pollutant Sources Existing Management Description of New BMP Options Practices Area 1 • Two of the receiving • Cover other bays. • Receiving area for bays are covered. • Keep absorbent materials readily packaging, frames, and available. upholstery supplies. • Periodically clean up Shipping area for finished miscellaneous debris and dispose product. of in appropriate waste container. Area 2 • Enclosed upholstery • Cover and divert runoff around • Receiving area for waste compactor. wooden pallet storage area. upholstery supplies and • Covered storage area • Keep absorbent materials readily frames. for wood. available. • Wooden pallet storage area. • Receiving bays are • Hazardous waste storage located under a covered area. structure. • Enclosed upholstery waste • Overhead shelter with compactor. surrounding berm for • Upholstery waste bin and hazardous waste storage miscellaneous waste bin. Area 3 • One bay is covered. • Keep absorbent materials readily • Receiving area for available. upholstery supplies, cushions and frames. Area 4 • Finishing materials are • Move empty drums and wooden • Finishing material storage kept in an enclosed pallets to designated covered area. covered storage area. area. • Shipping area for frames. • Cover shipping bay. • Empty drums. • Keep absorbent materials readily available. Area 5 • Receiving bay is located • Clean up debris and move to • Miscellaneous debris pile. under covered structure. either designated storage area or • Waste bin. dispose of properly. • Receiving bay for lumber. • Cover waste bin. • Sawdust collection system • Keep absorbent materials readily available. Vanguard Furniture SPPP December 2021 Page 28 Table 5 Pollutant Source Summary (continued) Stormwater Pollutant Sources Existing Management Description of New BMP Options Practices Area 6 • Bagfilter used to collect • Move empty drums and wooden • Sawdust collection system. sawdust particulates. pallets to designated covered • Scrap wood waste bin. area. • Empty glue drums. • Cover cardboard waste bin. • Wooden pallet piles. • Periodically sweep and dispose of material in waste bin. • Keep absorbent materials readily available. Area 7 • Overhead shelter with • Keep absorbent materials • Hazardous waste storage surrounding berm for readily available. area. hazardous waste storage Area 8 • None • Cover waste bin. • Shipping and receiving bays • Cover shipping and receiving for supplies, white wood bays. product, and finished • Keep absorbent materials product. readily available. • Waste bin. Area 9 • None • Cover receiving bay. • Receiving area for paint, • Keep absorbent materials filters, and rags. readily available. Area 10 • None • Waste bin should be kept closed • Closed waste bin. and no material left on the dock. • Keep absorbent materials readily available Vanguard Furniture SPPP December 2021 Page 29 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. • Regular 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 Provide berms & ditches to divert runoff from areas. (Areas 2 and 7). Additional BMP's (Activity and • Provide berms & ditches to divert runoff from areas. (Areas Site Specific) 2 and 7) • Cover waste bins. (Areas 2,4,5,6, and 8) • Provide covering for barrels outside (Area 2, 6 and 7) Y � r Vanguard Furniture SPPP December 2021 Page 30 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 equipment 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 Provide berms & ditches to divert runoff from Runoff areas. Areas 2 6, and 7). Additional • Provide berms & ditches to divert runoff BMP's (Activity from areas.(Areas 1, 2, and 4) and Site Specific) • Cover waste bins.(Areas 2,4,5,6,7, and 8) • Provide covering for barrels outside (Area 2 and 7) Vanguard Furniture SPPP December 2421 Page 31 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. Safety Data Sheets, b. 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. ' ► r Vanguard Furniture SPPP December 2021 Page 32 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 Furniture SPPP December 2021 Page 33 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 Manager 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. 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. DEQ STAT Environmental Services 6. Outside Contractors Vanguard Furniture SPPP December 2021 Page 34 911 911 (800) 662-7956 (24 hours) (919) 733-5083 (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, 1 � � Vanguard Furniture SPPP December 2021 Page 35 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 stormwater permit, NCG 180012. All stormwater visual monitoring data will be collected and kept on -site as directed under the requirements of the general stormwater permit. f A ♦ 1' Vanguard Furniture SPPP December 2021 Page 36 Figure 4 Example Stormwater Systems Evaluation Form Date: Inspectors Name and Title: Inspectors Signature: Check One: Routine Evaluation Non -Routine Evaluation (Reason: ) 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 Furniture SPPP December 2021 Page 37 Table 8 Employee Training Training Schedule for Topics Description of Training Training 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 ollutant 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 Vanguard Furniture SPPP December 2021 Page 38 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. e t { w Vanguard Furniture SPPP December 2021 Page 39 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, b. 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 Furniture SPPP December 2021 Page 40 Annual Review Date I Name 12/18/2021 Will Stange Change name of certification and names/responsibilities of pollution prevention team. Added new areas of potential pollutant: dust collection system (VGF), plywood storage area (VGF), and hazardous waste area (CGF). Also updated assessment of those areas. Vanguard Furniture SPPP December 2021 Page 41 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 Nos ills occurred.