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NCS000136_Renewal Application_20160603
NPDES STORMWATER PERMIT COVERAGE RENEWAL APPLICATION PERMIT NO. NCS000136 June 2016 Mallinckrodt LLC 8801 Capital Boulevard Raleigh, North Carolina 27616 Mallinckrodt 10 Mallinckrodt Pharmaceuticals June 2, 2016 Bradley Bennett, Manager Stormwater Permitting Program Division of Energy, Minerals, and Land Resources North Carolina Department of Environmental Quality 512 N. Salisbury Street Raleigh, NC 27604 Re: NPDES Stormwater Permit Coverage Renewal Application Mallinckrodt LLC, 8801 Capital Boulevard, Raleigh, Wake County, NC 27616 NPDES Individual Stormwater Permit No. NCS000136 Dear Mr. Bennett: Mallinckrodt LLC (Mallinckrodt) is submitting two (2) copies of the attached NPDES Stormwater Permit Coverage Renewal Application for the above -referenced site for your review and approval. Mallinckrodt is currently permitted to discharge stormwater consistent with NPDES Permit No. NCS000136, effective December 1, 2011, and expiring November 30, 2016 and we currently monitor three (3) stormwater discharge outfalls following the requirements of the Permit. If you have any questions or require additional information, please contact me at 919-878-2895. Sincerely, Mallinckrodt LLC Tim Roberts Environmental Manager Attachments (2) Submitted via Federal Express Tracking # 776419549199 cc: Julie Summers- Mallinckrodt, w/o Attachments 8801 Capital Boulevard • Raleigh, NC 27616 • 919.878.2800 T • 919.878.2823 F • w .mallinckrodt.com A Permit Coverage ©ria Renewal Application Form NCDENl2 National Pollutant Discharge Elimination System NPDES Permit Number Stormwater Individual Permit NCS000136 se provide your permit number in box in the upper right hand corner, complete the information in the space provided I G� w and return the completed renewal form along with the required supplemental information to the address indicated. Owner Information * Address to which permit correspondence will be mailed Owner / Organization Name: Mallinckrodt LLC Owner Contact: Timothy M. Goodman Mailing Address: 8801 Capital Boulevard Phone Number: 919-878-2822 Fax Number: 919-878-2823 E-mail address: tim.goodman@mallinckrodt.com CF��/fin Facilitv Information Facility Name: Facility Physical Address: Facility Contact: Mailing Address: Phone Number: Fax Number: E-mail address: Permit Information Permit Contact: Mailing Address 00*Ne Number: ,Dumber. E-mail address: Discharae Information Receiving Stream: Stream Class: Basin: Sub -Basin: Number of Outfalls Raleigh, NC 27616 Tim Roberts tim.roberts@mallinckrodt.com 8801 Capital Boulevard Raleiah, NC 27616 OVE-IE:IZk}� 919-878-2823 tim.roberts@mallinckrodt.com 031016 ID QUAD TY PERMIT NG Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a separate sheet if necessary. See Section V of Attachments. CERTIFICATION I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is tr , co lete and accurate. Signature Date 0G I A)2 Tlmnthy M r'nndman gitP hlrPrtnr Print or type name of person signing above Title completed application form SW Individual Permit Coverage Renewal Please return this com p PP Stormwater Permitting Program and requested supplemental information to: 1612 Mail Service Center Raleigh, North Carolina 27699-1612 s^ 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: (Do not submit the site Stormwater Pollution Prevention Plan) Initials 7 �vn 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. 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. 4. 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. M 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. 4 Kl 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) /4m*,N TABLE OF ATTACHMENTS, I. SITE MAPS FROM SWPPP II. SUMMARY OF ANALYTICAL MONITORING DATA III. SUMMARY OF VISUAL MONITORING DATA IV. SUMMARY OF BMP'S FROM SWPPP V. NARRATIVE OF SIGNIFICANT CHANGES VI. SWPPP CERTIFICATION u U%i 1 i ��/-=� �`` �� SITE � �'% •'_ )`� �:� -� � \^ J� E IV ^ n I Vw .I-, -11!1 L-�- GRAPHIC SCALE TOPO SOUR NCGS DRG C C SOURCE: WAKE FOREST, DATED 2002 loco o CONTOUR INTERVAL 10 FEET soo moo 2000 THIS DRAWING IS THE PROPERTY OF MALUNCKRODT LLC OR AN AFFILIATE ('MALLI NCKRODT•) AND IS NOT TO BE REPRODUCED, COPIED OR USED IN FEET ( FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRITING BY MALUNCKRODT. MYG,AImO4 Te'AI't+an„matugtl,a WfrckuA P„am,xeuNakbp„me tra„cne„o We Nebndvoolcmpe/ry, Om11MN4,6mtl1 «Mallinckrodt VICINITY FIG,1 Pharmaceuticals RALEIGH PHARMACEUTICAL PLANT BBDI Capital Blvd. Raleigh, NC 27616 SITE RALEIGH PLANT BLDG. SCALE AS NOTED DATE 5 31 16 FLOOR 510 0 - 210 - 0 8 3 I0 DR. BY: ENGR. CHK'D DRAWING PROJECT NO. REVISION NO. DATE ENGR. 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I- _ O o o m p� D D C D D v m 0�ZJ� zm mc)m _ _ _ .J O CT�A W 0011 .A (!0 N ZO W om v Q m Dz0zOm cf) m G) 0 0 0 �W �- r=���oc)000000p� � C Z D D D m c D c_ c c_ c C� mn X �� m z Z p �0CD U) C N c''rcD/��ODnZ��0 �r��U) OZ �� �� > o N� Once cN�n o=--I �������c�n�S 200p--00 �o Dn z> mm U) o� n m z m��r�rrn�mmp �n m� �� O� m ,Zc7 mN�n Do�vzD�=naozO���Z�D Dr z n DO m DDv �c�m-O� z m C)mn O O OTmo 0 D z mm -ni pcDnz nm-1 �z� n z� z D U)> m� 0G) = D COD ,,mOOQ m z �m Z �� uDm O c� n � i oo c0 0O Opp z asp m z �D GDi -cni o;0��77 m F: n -n O Z� C) D z � o m O D T m U)oOz z = C- m rm- 0 U O O r] cn oN D O .n N Z o W mD Cn CD m w a Summary of Analytical Stormwater Monitoring Results Mallinckrodt LLC Raleigh Pharmaceutical Plant March 2012 - Present Outfall 001 Total Rainfall (inches) Parameter (Units) Total Suspended Solids (mg/L) pH (S.U.) Conductivity (uSlcm) Chemical Oxygen Demand (mg/L) Total Nitrogen (mg/L) Nitrate- Nitrite (mg/L) Ammonia Nitrogen (mglL) Sulfate (mg/L) Ammonium Sulfate - Calculated (mg/L) Benchmark N/A 100 6-9 N/A 120 30 10 7.2 500 19 Date 5/9/12 0.45 2.8 7.67 0 16 1.1 0.32 0.14 <5.0 <0.1 9/18/12 3.66 7.1 7.0 28 38 1.0 0.14 <0.10 <5.0 <0.1 4/19/13 0.57 4.8 6.12 180 35 1.8 0.59 0.52 <5.0 <0.1 11/1/13 1.23 3.5 6.1 24 17 1.3 0.31 0.27 <5.0 <0.1 4/25/14 0.47 80 6.3 57 90 2.6 0.68 0.62 <5.0 <0.1 9/24/14 0.57 37 8.7 31 21 0.6 0.05 <0.25 <5.0 <0.1 5/21/15 0.24 26 6.4 77 35 3.1 1.1 0.58 <5.0 <5.0 10/27/15 0.11 53.5 7.2 101 61.5 1.97 1.03 0.334 5.66 0.58 3/4/16 0.11 35.8 4.0 107 19.1 1.4 0.826 0.141 5.57 0.67 Notes: Benchmark Exceedances noted in Bold font. Summary of Analytical Stormwater Monitoring Results Mallinckrodt LLC Raleigh Pharmaceutical Plant March 2012 - Present Outfall 002 Total Rainfall inches Parameter (Units Total Suspended Solids (mg/L) pH (S.U.) Conductivity (US/Cm) Chemical Oxygen Demand (mglL) Total Nitrogen (mg/L) Nitrate- Nitrite (m /L) Ammonia Nitrogen (mg/L) Sulfate (m IL) Ammonium Sulfate - Calculated (m IL) Benchmark N/A 100 6-9 N/A 120 30 10 7.2 500 19 Date 5/9/12 0.45 15 6.85 0.01 5 1.2 0.35 0.41 <5.0 <0.1 9/18/12 3.66 54 6.8 30 23 1.1 0.32 0.4 <5.0 <0.1 4/19/13 0.57 64 6.14 220 370 18 0.69 2.1 7.8 9.91 11/1/13 1.23 85 6.0 61 56 4.1 0.9 1.1 6.8 5.19 4/25/14 0.47 7.7 6.7 48 100 3.3 1.5 0.42 <5.0 <0.1 9/24/14 0.57 29 7.1 99 26 1.3 2.3 0.42 5 1.98 5/21/15 0.24 46 6.5 198 53 5.8 1.7 2 13 9.43 10/27/15 0.11 15.1 6.6 191 26.6 3.99 1.86 1.36 22.9 6.42 3/4/16 0.11 12.0 4.0 54 17.0 1.12 0.657 0.120 5.86 0.57 Notes: Benchmark Exceedances noted in Bold font. Summary of Analytical Stormwater Monitoring Results Mallinckrodt LLC Raleigh Pharmaceutical Plant March 2012 - Present Outfall 003B Total Rainfall inches Parameter Units Total Suspended Solids (mglL) pH (S.U.) Conductivity (US/cm) Chemical Oxygen Demand (mg/L) Total Nitrogen (m /L) Nitrate- Nitrite m /L) Ammonia Nitrogen (m /L) Sulfate (m /L) Ammonium Sulfate - Calculated (m /L) Benchmark N/A 100 6-9 N/A 120 30 10 7.2 500 19 Date 5/9/12 0.45 10 7.78 0.39 56 1.9 <0.10 0.12 38 0.566 9/18/12 3.66 5.2 7.6 304 59 1.5 <0.10 0.14 28 0.66038 4/19/13 0.57 2.6 8.3 503 46 1.0 <0.10 0.54 72 2.55 11/1/13 1.23 13 6.82 377 48 2.5 0.16 0.6 69 2.83 4/25/14 0.47 4.1 8.6 346 25 1.6 0.3 <0.25 74 <0.1 9/24/14 0.57 9.3 6.9 330 40 1.4 <0.10 <0.25 29 <0.1 5/21/15 0.24 29 7.9 448 30 2.4 <0.10 <0.25 64 <2.5 10/27/15 0.11 4.4 6.8 1175 29.2 6.3 <0.10 5.09 469 24.01 3/4/16 0.11 3.20 6.4 317 30.1 2.82 1.90 0.097 115 6.46 Notes: Benchmark Exceedances noted in Bold font. Summary of Visual Stormwater Monitoring Results Mallinckrodt LLC Raleigh Pharmaceutical Plant March 2012 - Present Outfall 001 Other Obvious Floating Suspended Indications of Characteristic Color Odor Clarity Solids Solids Foam Oil Sheen Pollution Date 5/9/12 Clear None 1-Clear 1-None 2-Slight No No None Very Light 9/18/12 Brown None 1-Clear I 1-None 2-Slight No No None 4/19/13 Clear None 1-Clear 1-None 1-None No No None 2-Slight (Grass/ 11/1/13 Light Brown None 1-Clear Leaves) 1-None No No None 2-Slightly 4/25/14 Light Brown None Turbid 1-None 1-None No No None 2-Slightly 9/24/14 Light Clear Tan None Turbid 1-None 2-Slight No No None Very Light 5/21/16 Brown -Gray None 2 2 1-None No No None 10/27/15 Light Tan None 2 2 1-None No No None Light Brown- 2-Slightly 2-Slight 3/4/16 Mostly Clear None Turbid (Leaves) 2-Slight Soil No No None Summary of Visual Stormwater Monitoring Results Mallinckrodt LLC Raleigh Pharmaceutical Plant March 2012 - Present Outfall 002 Other Obvious Floating Suspended Indications of Characteristic Color Odor Clarity Solids Solids Foam Oil Sheen Pollution Date 2-Slightly 5/9/12 Light Tan None Turbid 1-None 2-SlightNo No None 9/18/12 Grayish Brown None 4-Cloud 2-Slight 3-Some No No None 2-Slightly 2-Slight 4/19/13 Light Brown None Turbid (Pollen) 2-Sli ht No No None 2-Slightly 3-Some 11/1/13 Li ht Brown None Turbid (Organics) 1-None No No None Very Light 2-Slightly 4/25/14 Brown None Turbid 2-Slight 1-None No No None 9/24/14 Clear Medium Tan -Gray Unknown' 3-Turbid 3-Some (Grass) 3-Some Yes2 No None Very Light Brown to 2-Slightly 5/21/15 Mediun Brown None Turbid 3-Some 2-Slight No No None Meduium 3-Some 10/27/15 Brown None 3-Turbid (Grass) 2-Sli ht No No None Light Brown- 2-Slightly 2-Slight 3/4116 Mostly Clear None Turbid (Leaves) 2-Slight Soil No No None Footnotes: 1- Could not smell sample due to background odors at the site. 2 - Not much foam but some due to high flow through headwall valve in ditch. Summary of Visual Stormwater Monitoring Results Mallinckrodt LLC Raleigh Pharmaceutical Plant March 2012 - Present Outfal 1003B Other Obvious Floating Suspended Oil Indications of Characteristic Color Odor Clarity Solids Solids Foam Sheen Pollution Date Light Brown, 5/10/12 Tonic Color None 1-Clear 1-None 1-None Yes' No None 9/18/12 Light Brown None 3-Turbid 3-Some 2-Light No No None Light Brown/ 2-Slightly 4/22/13 Bie a None Turbid 1-None 1-None No No None 2-Slightly 11/4113 Light Tan None Turbid 2-Sli ht 2-Light No No None Dark, Clear 4/28/14 Brown None 1-Clear 3-Some 2-Light No No None Clear Dark 2-Slightly 9/24/14 Tan None Turbid 3-Some 2-Li ht No No None 2-Slightly 4-Mostly 5/21/15 Light Brown None Turbid Covered 3-Some No No None 10/27/15 Light Tan None 3-Turbid 2-Slight 2-Light No No None Light Brown, 1-Mostly 3l4/16 Mostly Clear None Clear 1-None 1-None No No None Footnotes: 1 - Foam caused by high flow rate/agitation; observations made during pumping within 30 minutes of starting pump. rd"bN Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into cfi'ect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "" near the Structural BMW. Location: South of the building 5 1 A warehouse in Drainage Zones 1 and 2 Materials: Granular APAP (in cardboard drums), APAP powder (in cardboard drums and boxes), dust control material, Building 51 Warehouse ice melt, lime, cleaning solution, paint, paint thinner, self -shrinking bottle closures, cardboard packaging, glass jars, and wooden pallets. Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: North of the building 51 warehouse and south of building 100 in Drainage Zone 2 Building 5 1 A Warehouse Materials: This storage area APAP which is stored in cardboard drums and supersacks. (S-2)* Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: Southwest of building 901 (boiler house) in Drainage Zone 3B Materials: #2 fuel oil (50,000 gallon tank) Structural BMPs *: This aboveground storage tank is located within a concrete secondary containment dike (80 x 60 x 5') that can contain the contents of the tank plus accumulated No. 2 Fuel Oil Storage Tank rainwater from a 25-year 24 hour storm event. (S-3) Procedural BMPs: Stormwater that collects in the bermed area is inspected by the Mallinckrodt Utilities Department. If the stormwater is found to be clean, it is pumped out from the sump located in the corner of the dike to the stormwater ditch located north of the dike. A lock has been placed on the sump pumpin this area. Location: Northwest of building 901 in Drainage Zone 3B Materials: K083 aniline tar Structural BMPs *: This aboveground storage tank is built with secondary containment in the form of a concrete dike equipped with a sump. The containment structure (34.5 `x 14.5' x 3') will hold the 10,000-gallon capacity of the tank and approximately 3.5" of accumulation of rainfall. This tank is covered by a canopy which diverts rainwater K083 Aniline Tar Feed Tank at Boiler House Procedural BMPs: from accumulating in the containment area. The tank area is inspected daily and the concrete dike (S-5) and sump in this storage area are inspected after each shift for stormwater accumulation. Stormwater accumulation in the sump or diked area is manually pumped out to the hazardous wastewater tanker. Filling the tank is limited to 8,400 gallons or less to allow for the containment of the contents of the tank plus allow for freeboard (see Table 1, S-19, Table 2, and Table 5, W-17). Page 1 of 12 /dmbN Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BUFs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "s" near the Structural BMP. Location: West of building 101 in Drainage Zone 3B Materials: The following materials are stored on the east side of the building: compressed gas cylinders; surplus motors and metal parts; wooden pallets; piping; and the piping rack storage within a metal fence. The following materials are stored on the north side of the building: miscellaneous equipment and parts from the production Maintenance Building (Building 903) lines; APAP hoppers; and empty synthetic lubricant (S-6)* drums. The following materials are stored on the west side of the building; a parts washing system; wooden boxes; and miscellaneous equipment and parts from the production lines. The following materials are stored on the south side of the building: miscellaneous equipment and parts from the production lines; cardboard boxes; and scrap metal. Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: Northwest of Building 903, north of Building 903, and west of Building 201 near power transmission line Used Equipment Storage Areas (south of Hill Tank Farm) in Drainage Zone 3B (S-7) Materials: New and used surplus equipment Structural BMPs: None related to stormwater Procedural BMPs: All equipment, parts and scrap material must not contain, or must be cleaned to remove, significant material residues, including draining of oils or hydraulic fluids, prior to being stored in this area. Insulation must be removed prior to being stored in this area. Location: Northwest of building 903 in Drainage Zone 3B Materials: Four hydrogen tanks: two containing gaseous hydrogen and two containing liquid hydrogen Hydrogen Fram, Structural BMPs: None related to stormwater (S-g)* Procedural BMPs: None related to stormwater, as this area is not a stormwater concern due to the fact that at normal vapor pressure hydrogen is in the gas phase. Location: North of building 903 in Drainage Zone 3B Materials: Empty totes and empty drums which once contained raw materials Structural BMPs: None relating to stormwater Procedural BMPs: Returnable totes are not rinsed prior to returning to the vendor but valves are shut prior to placing in the storage area. Most empty used drums are rinsed and/or drained and crushed prior to placing in dumpsters for off -site Empty Container Storage Area recycled or disposal and generally are not stored or staged in this area. However, prior to being placed in (S-9) this storage area, non -returnable and general returnable drums must be thoroughly rinsed prior to being returned. Returnable totes in good condition including hydrogen peroxide, ethomeen, and aqua ammonia are not rinsed but are stored here and returned to the vendor for reuse. There is also an Empty Container Standard Operating Procedure that personnel follow for the handling of empty containers. Page 2 of 12 E0116N, (AoftN Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "*" near the Structural BMP. Location: Southwest of the ammonia tanks and northwest of the empty drum storage area in Drainage Zone 3B Materials: Acetic acid 20%, nitrobenzene, hydrogen peroxide, acetic anhydride, and aniline. Structural BMPs *: This storage area has a divided concrete dike which allows for segregation of incompatible materials should a spill occur. There is a sump located in each of the diked areas. The tanks in this area are also equipped with overflow detection devices. The containment dike for tank T-8 and the containment dike for Tanks T-1, 2, Hill Tank Farm 6 and 7 have a notch in the top of the containment wall (S-10) dividing them so the dikes act as one larger containment area for all 5 tanks. The containment area for Tanks 1, 2, 6 and 7 is 124.5' x 49' x 3.6. The containment area for T-8 is 34' x 50.5' x 3'. This containment area can hold the volume of the largest tank (135,0000 gallons) and rainwater accumulation. Procedural BMPs: Stormwater is allowed to accumulate in the locked sumps and inspected for visual signs of impact. Stormwater is typically pumped to the process sewer (WWTP). Excessive rainfall may require discharge onto the ground; however, the stormwater is sampled prior to ground discharge. Location: Southwest of buildings 201-205, northeast of the tank farm on the hill in Drainage Zone 3B Materials: Anhydrous ammonia (gaseous) Structural BMPs: The tanks are surrounded by an earthen berm. Ammonia Tanks Procedural BMPs: Stormwater that collects in the earthen berm is (S-12) inspected by the Mallinckrodt PAP Department. If the stormwater is found to be clean, it is pumped out from the corner drain and is discharged into the stormwater ditch system. A lock has been placed on the sump pump in this area. Location: Northeast of building 5 1 A and southwest of building 101 in Drainage Zone 3B Materials: APAP (granular and powder), PAP, bottles with caps, Building 100 cardboard packaging, filter paper, filter cloth, safety (S-13)* absorbent, dense soda ash, 20 gal drums citric acid, rock salt, cleaner, and urea. Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: On the southwestern side of building 101 in Drainage Zone 3B Materials: Potassium hydroxide, second crop mother liquors, APAP mother liquors and crude mother liquors. Largest tank in this area is approximately 11,000 Tank Farm West of Building 101 gallons) (S-14) Structural BMPs *: The tanks in this area are contained by a dike. The dike drains into a sump that drains to the process sewer system. The dike is approximately 49.5' x 20.5' x 2'. A locked sump is located in the diked area and can release accumulated materials to the process sewer. Procedural BMPs: None related to storm water Page 3 of 12 /4"'N '0 Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "*" near the Structural BMP. Location: North of building 101 and south of building 201 in Drainage Zone 3B Materials: Acetic acid (Largest tank is 29,000 gallons), APAP process wastewaters with acetic acid (Largest tank is 8,500 gallons). Structural BMPs *: This storage area contains two concrete diked areas Acetic Acid Tanks - North of Building 101 separating four acetic acid tanks (65' x 33' x 2.5') and two process tanks (33' x 33' x 2.5'). Each diked area (S-15) has a drainage trench equipped with a sump. This dike provides sufficient containment for the volume of the largest tank in the dike and rainwater accumulation from a 25 year-24 hour storm event. Procedural BMPs: The Sump in the diked area is operated in the locked closed position. Stormwater is pumped to the process sewers stem. Location: Northeast of building 101 and east of Tank Farm (S-15) in Drainage Zone 3B Materials: Dried PAP in tote bins and bulk bags, along with miscellaneous equipment PAP Storage Structural BMPs: Curbed areas divert rainwater to the site process sewer (S-16) Procedural BMPs: system. The valves on the bottoms of the tote bins are closed and the bins are rinsed with water to remove excess PAP from the outside of the bins before placing the bins outside. Location: North of building 201 in Drainage Zone 3B Materials: Raw materials including: cardboard, catalyst, empty 55- gal metal drums, PAP in supersacks and drums, sodium Building 200/204 PAP Warehouse hydrosulfite drums, sodium metabisulfite drums, (S-18)* ethomeen, and defoaming agent. Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: On the northeastern corner of building 205 in Drainage Zone 3B Materials: K083 aniline still bottoms Structural BMPs *: The tanks (T-384 and T-385) in this storage area are covered by a canopy and built with secondary containment in the form of a concrete dike (45' x 20.5' K083 Aniline Tar Storage Tanks at 205 x 2') that provides sufficient containment for the largest (S-19) tank and the minimal amount of rainwater that could be accumulated. Additional needed secondary containment is provided by the process sewer in this area. Procedural BMPs: Filling Tanks 384 and 385 is controlled by a level gauge. Any accumulated stormwater is pumped to the hazardous wastewater tanker (Table 6, W-17). Page 4 of 12 /A�6\ Table 2 Materials Storage Practices — BAD Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "*" near the Structural BMP. Location: East of building 205 in Drainage Zone 3B Materials: Hazardous waste, solid wastes, empty drums, boxes of methanol, plastic totes of aqua ammonia, fuel, and plastic totes of hydrogen peroxide Structural BMPs: The hazardous waste storage pad has a full roof and walls on the north, east, and south sides. There are 4 separate bays segregated by a short knee wall. This area also has a concrete pad that has epoxy coating and is sealed with "Waterstop". The base is sloped to 4 separate collection trenches in the rear of the storage area. There is also a speed bump on the western side that is open for roadway access and prevents rainwater from running onto the pad. Hazardous Waste Storage Pad Procedural BMPs: Incompatible wastes/materials are segregated and not (S-20) placed within the same storage bay. Hazardous and solid wastes materials are generally stored in appropriate new containers depending on the nature of the hazardous waste or hazardous material to ensure no incompatible materials stored in the same bay. When using 55-gallon drums, the drums that are sealed are then placed four to a pallet (maximum) with all drums touching to prevent tipping. Provisions are made to stack drums at safe heights and adequate aisle space is maintained between the pallets. Stormwater accumulation in the drainage trenches at the base of the pad is typically evaporates. Should excess stormwater accumulate in this trench, a vac truck collects the stormwater and transports to the WWTP for disposal. Location: Southeast of the WWTP in Drainage Zone 3B Materials: Urea 46% N, hydrated lime, PAP, APAP, pumps and Building 10 Warehouse miscellaneous equipment. (S-22)* Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: Northeast of the WWTP in Drainage Zone 3B Materials: Acetic acid, phosphoric acid, and a mixture of calcium and magnesium hydroxide. Structural BMPs *: The three storage tanks are located in a segregated concrete dike. The Magnesium hydroxide tank (10,000 gallons) is located in an area 23.5' 27.5' x 3.5'. The acetic acid (6,000 gallon) and the phosphoric acid Tank Farm at WWTP (5,000 gallon) tanks are located in an adjacent (S-23) containment dike measuring 22.25' x 27.5' x 3.5'. Each diked area has a drainage valve that is maintained in the locked closed position. There is sufficient containment for the volume of the largest tank and rainwater accumulation in each of the dikes. Procedural BMPs: The stormwater that collects in the diked area is checked visually for signs of contamination and for odor prior to being manually pumped back to the WWTP Page 5 of 12 '0 Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "•" near the Structural BMP. Location: Southwest corner of building 201 in Drainage Zone 3B Materials: Spent catalyst, defoaming agent, miscellaneous equipment (Less than 660 gallons located here) Structural BMPs: This recessed area has a roof, brick floor, walls on the west and south sides, the raised -slab floor of building Washing Area/Catalyst Storage Area 201 on the north side, and a concrete pad on the east (S-24) side. A sump and pump are also located in the northwest corner. Curbs have been added along with a sump. Accumulated water is discharged to the process sewer. Procedural BMPs: None related to stormwater Location: Northwest of the PAP Plant in Drainage Zone 3B Materials: Ammonium sulfate. (Largest tank volume of five tanks in this area is 4 million gallons.) Structural BMPs *: The MASL tanks are field -erected tanks equipped with MASL Aboveground Storage Tanks synthetic liners and leak detection systems. In addition, (S-25)* secondary containment for the MASL storage tank area is provided by the onsite retention pond which has a containment volume of approximately 15 million gallons). Procedural BMPs: None related to stormwater Location: Northeast of building 101 in Drainage Zone 313 Materials: PAP (in drums, super sacks and bins) and lime. Warehouse in Building 105 Structural BMPs : None related to storm water. (S-26)* Procedural BMPs: None related to stormwater. Location: Southeast of the boiler house (Building 901) and west of the building 51 warehouse in Drainage Zone 2 Materials: Fuel (unleaded gasoline and diesel). Total volume is 1,280 gallons) Structural BMPs: The above ground storage tanks are housed in a recessed concrete containment area. A 14' x 29' x 6" high, sloped concrete berm for truck unloading was added to an existing 10'x 29' x 14" area (8" of this area being recesses) where the tanks are located. This Vehicle Fuel Storage Area containment provides sufficient containment for the (S-27) tanks and rainwater accumulation. Procedural BMPs: There are no drains from this area. Stormwater that accumulates in the dike and in the berthed pad is visually inspected by the Mallinckrodt Warehouse Department for signs of contamination and odor. If no impacts are identified, the water is manually pumped to the stormwater ditch located east of the fuel storage area. A lock has been placed on the sump pump in this area. Location: 4n the northeastern comer of building 201 in Drainage Zone 3B Materials: Aniline (Largest tank is 8,500 gallons). Structural BMPs *: These storage tanks are located in a concrete dike (35'x Aniline Storage Tanks 18' x 4.5') that has a drainage valve leading to the (S-30) process sewer. Sufficient containment for the largest tank and rainwater accumulation is provided in this concrete dike. Procedural BMPs: Stormwater that accumulates in the diked area is manually released to the process sewer. Page 6 of 12 ?4mb" Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "*" near the Structural BMP. Location: Southeast end of Building 901 (boiler house) in Drainage Zone 2 Rock Salt Storage Materials: Plastic bags of rock salt (S-31) Structural BMPs: None related to stormwater Procedural BMPs: Provisions are made to store materials in original containers and stack containers on wooden pallets. Location: North of building 2 adjacent to the drainage ditch in Drainage Zone 3B Propane Aboveground Storage Tank Materials: Propane (S-35)* Structural BMPs: None related to stormwater Procedural BMPs: None related to stormwater. Location: North of fuel storage area in Drainage Zone 2 Propane Aboveground Storage Tank Materials: Propane (S-38)* Structural BMPs: None related to stormwater Procedural BMPs: None related to stormwater. Location: Building 901 (Boiler House) in Drainage Zone 2 Materials: Corrosion inhibitor, potassium hydroxide, sodium bisulitte, sodium hydroxide, sodium tripolyphosphate, Building 901, Boiler Treatment Chemicals and Distilled resin cleaner, fuel oil additive, synthetic compressor Water Chemical Storage Area lubricant, rock salt, and boiler treatment chemicals. (S-39)* Structural BMPs: This storage area is inside of a fully enclosed building with concrete flooring and no floor drains. Procedural BMPs: Provisions are made to stack drums at safe heights and lace drums on pallets. Location: Notch of Building 903 (Maintenance Building) in Drainage Zone 3B Materials: Three electrical infrastructure transformers are located in this area. The volume of transformer oil in each one is 487, 392, and 478 gallons. Structural BMPs: A 2-inch high, crush -and -run gravel dike surrounds this transformer station that is owned, operated and Progress Energy (P-E) Substation maintained by P-E. Accumulated rainwater percolates through gravel or evaporates. Should a spill leave this (S-41) area, a series of storm water conveyances with control valves throughout the site would contain the release. Procedural BMPs: The substation is periodically inspected by Mallinckrodt personnel for indicators of contamination (color, foam, sheens, stains and odor). P-E will be contacted immediately if physical indicators of contamination arc observed. Location: North of Building 2 (Administration Building) in Drainage Zone 3B Materials: Approximately 134 gallons of transformer oils are contained in electrical equipment at this substation. Structural BMPs: A concrete dike equipped with a valve is sufficient to contain the oil in the transformer is located around this Transformer Substation No. 1, Near Building 2 substation if found to be leaking. Any materials leaving the dike area will be collected in a series of stormwater (S-42) conveyances with control valves located throughout the site. The dike is located within a locked fenced area. Procedural BMPs: Applicable personnel are trained to close the dike valve if oil leaks are observed. The substation is also inspected semi-annually as a part of the stormwater inspection program. Page 7 of 12 /'0'1 Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "0" near the Structural BMP. Location: North of Building 903 (Maintenance Building) in Drainage Zone 3B Materials: Approximately 131 gallons of transformer oils are contained in electrical equipment at this substation. Structural BMPs: A concrete dike equipped with a valve is sufficient to contain the oil in the transformer is located around this Transformer Substation No. 2, Near Building 903 substation. Any materials leaving the dike area will be (5-43) collected in a series of storm water conveyances with control valves located throughout the site. The dike is located within a locked fenced area. Procedural B14IPs: Applicable personnel are trained to close the dike valve if oil leaks are observed. The substation is also inspected semi-annually as a part of the stormwater inspection program. Location: West of building 101 in Drainage Zone 3B Materials: Approximately 254 gallons of transformer oils are contained in electrical equipment at this substation Structural BIVIPs: A concrete dike equipped with a valve is sufficient to contain the oil in the transformer is located around this substation. Any materials leaving the dike area will be Transformer Substation No. 4, Near Building 101 collected in a series of storm water conveyances with (5-45) control valves located throughout the site. The transformer and dike is located within a locked fenced area. Procedural BMPs: Applicable personnel are trained to close the dike valve if oil leaks are observed. The substation is also inspected semi-annually as a part of the stormwater inspection program. Location: East of building 200 in Drainage Zone 3B Materials: Approximately 168 gallons of transformer oils are contained in electrical equipment at this substation. Structural BMPs: A concrete dike equipped with a valve is sufficient to contain the oil in the transformer is located around this Transformer Substation No. 5B, Near Building 200 substation. Any materials leaving the dike area will be collected in a series of storm water conveyances with (S 46) control valves located throughout the site. The dike is located within a locked fenced area. Procedural BMPs: Applicable personnel are trained to close the dike valve if oil leaks are observed. The substation is also inspected semi-annually as a part of the stormwater inspection program. Location: East of Big Mac (raw waste surge tank) in Drainage Zone 3B Materials: Approximately 300 gallons of transformer mineral oil is contained in electrical equipment. Structural BMPs: Transformer is contained in weatherproof enclosure on concrete pad. Any materials leaving the transformer P-E Transformer Substation No. 1, Near Big Mac area will be collected in a series of stormwater (S 47) conveyances with control valves located throughout the site. Procedural BMPs: The substation is also inspected semi-annually as a part of the stormwater inspection program. Progress Energy will be contacted immediately if physical indicators of contamination are observed. Page 8of12 /00MI\ Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "*" near the Structural BMP. Location: West of Building 10 in Drainage Zone 3B Materials: Approximately 145 gallons of transformer mineral oil is contained in electrical equipment. Structural BMPs: Transformer is contained in weatherproof enclosure on concrete pad. Any materials leaving the dike area will be collected in a series of storm water conveyances with control valves located throughout the site. The dike is located within a locked fenced area. P-E Transformer Substation No.2, West of Building 10 Procedural BMPs: The substation is inspected after rain events by (S-48) Mallinckrodt personnel for indicators of contamination (color, foam, sheens, stains and odor) prior to discharge. Contaminated stormwater would be pumped out and disposed of properly. The substation is also inspected semi-annually as a part of the stormwater inspection program. Progress Energy will be contacted immediately if physical indicators of contamination are observed. Location: North of the Wastewater Treatment Plant in Drainage Zone 3B Materials: Approximately 380 gallons of transformer mineral oil is contained in electrical equipment Structural BMPs: Transformer is contained in weatherproof enclosure on P-E Transformer Substation No.3, Near Wastewater concrete pad. Any materials leaving the dike area will Treatment Plant be collected in a series of storm water conveyances with (S-49) control valves located throughout the site. Procedural BMPs: The substation is periodically inspected by Mallinckrodt personnel for indicators of contamination or release. Progress Energy will be contacted immediately if physical indicators of contamination are observed. Location: Building 907 in Drainage Zone 3B Materials: Lubricant and waste oil drums and a 500-gallon waste oil tank. Structural BMPs: Tanks and drums are housed in a 46' by 51'6" fully - enclosed building with a concrete floor and no floor drains. A 1,100 gallon containment pan is provided for the 500 gallon used oil tank. Any materials leaving Building 907 Oil Storage the building will be collected in a series of storm water (S-50)* conveyances with control valves located throughout the site. Procedural BMPs: Provisions are made to place drums and materials on pallets and stack pallets at safe heights. Spill control materials are readily available. Location: West of the fire training area in Drainage Zone 2 Materials: Paint, fuel, piping, compressed gas. Structural BMPs: Trailers prevent contact with stormwater for most Contractor Trailer Area chemicals. (S-51) Procedural BMPs: Most chemicals are not stored outside the trailers. Portable containment usually provided for chemicals stored outside or at least chemicals stored n pallets so not standing in water. Location: West of Building 201 near catalyst wash area in Drainage Zone 3B Ethomeen Building Materials: 3 totes containing Ethomeen C-12 and 1 tote of (S-52)* defoaming agent. Structural BMPs: Building prevents contact with stormwater. Procedural BMPs: Chemicals are not stored outside the building. Page 9of12 /aF*1N /aft"\ Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BNIPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency Of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "•" near the Structural BMP. Location: Off south end of Building 901 (Boiler House) in Drainage Zone 3B Materials: Approximately 421 gallons of silicone -based dielectric fluid are contained in electrical equipment at this substation. Structural BMPs: A concrete dike equipped with a valve is sufficient to Transformer Substation No. 8, Near Building 901 contain the oil in the transformer is located around this substation. Any materials leaving the dike area will be (S-53) collected in a series of storm water conveyances with control valves located throughout the site. The dike is located within a locked fenced area. Procedural BMPs: Applicable personnel are trained to close the dike valve if oil leaks are observed. The substation is also inspected semi-annually as a part of the stormwater inspection program. Location: Notch of building 205 in Drainage Zone 3B Materials: Dried PAP in bulk bags, off -spec process liquors, miscellaneous equipment PAP Rework and Temporary Chemical Storage Structural BMPs: Area is covered by a canopy to minimize contact with (S-54) (formerly L-5) rain, plus area is curbed with a sump so accumulated rainwater can be sent to the site process sewer system. Procedural BMPs: The materials are stored on pallets or in tote bins. Location: North end of building 101 in Drainage Zone 3B Materials: Northwester Dike -Recovered Acetic Acid and Hydrogen Peroxide (Largest Tank is 1,500 gallons); Northcentral Dike- Process Liquors containing Acetic Acid (Largest Tank is 2,000 gallons); Northeastern Dikes A/B-Process Liquors containing Acetic Acid (Dike A: Largest tank is <3,000 gallons; Dike B: Largest tank is 6,000 gallons) Tank Farm North of 101 (S-55) Structural BMPs: The tanks in this area are contained by four separate dikes. Each dike drains into a sump that pumps into the process sewer system. Northeastern Dike A is approximately 37' x 13' x 2, Northeaster Dike B is approximately 36' x 21' x 3', Northcentral Dike is approximately 19' x 13' x 2', and Northwester Dike is approximately 36' x 18' x 2'. A sump is located in each diked area and can release accumulated stormwater to the process sewer. Procedural BMPs: Stormwater is not discharged to the ground in this area. Location: Southwest of the ammonia tanks and northwest of the empty drum storage area in Drainage Zone 3B Materials: Sulfuric acid. (Largest Tank is 28,000 gallons) Structural BMPs *: This storage area has a concrete dike (27' x 73' x 3.5'). There is a sump located in the diked area. The Sulfuric Acid Tank Farm (5-56) containment area (capacity of 42,000 gallons) is sufficient for the volume of the largest tank and rainwater accumulation. The tanks in this area are also equipped with overflow detection devices. Procedural BMPs: Stormwater is allowed to accumulate in the sump and inspected for visual signs of impact. Stormwater is typically pumped to the process sewer (WWTP). Page 10 of 12 f"a, /afth\ Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2016 Note: The BMPs for material storage areas were chosen based on their level of potential impact to stormwater, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Location and Implemented Best Management Practices (BMPs) NOTE: Associated Required Secondary Containment is described under structural Storage Area BMPs. All containment calculations take into effect the displacement of the tanks located in the containment area. Areas requiring containment is noted with an "'" near the Structural BMP. Location: Wastewater Treatment Plant Area in Drainage Zone 3B Materials: Approximately 82 gallons of diesel is contained is contained in generator. Structural BMPs: The generator is located in a roofed area with a WWTP Back-up Diesel Generator (S-57) secondary containment area capable of containing a release of the oil in the generator and any rainwater that may be accumulated in the dike under the canopy. Procedural BMPs: The generator is periodically inspected by Mallinckrodt personnel for indicators of contamination or release. Location: Wastewater Treatment Plant Area in Drainage Zone 3B Materials: Anti -Foam Agent in two totes. Anti -Foam Dike area in WWTP (S-58) Structural BMPs: This area is contained in concrete curbed shed south of the tank farm at WWTP. Procedural BMPs: The area is periodically inspected by Mallinckrodt personnel for indicators of contamination or release. Location: South of building 903 in Drainage Zone 3B Materials: Structural BMPs: The Boiler and ancillary piping are located in a concrete dike that has a drainage trench equipped with a sump. Boiler No. 7 (S-59) This equipment is located in the same dike as the Cloud [Co -located with Scrubber System (P-5)] Chamber Scrubber (see Table 4, P-5). Procedural BMPs: Stormwater is allowed to accumulate in the sump and inspected by the Mallinckrodt Utilities Department for visual signs of impact. Based on prior approval by the City of Raleigh POTW, stormwater is pumped to the condensate sewers stem. Location: East of Building 200 Materials: Compressor Oil PAP Plant Compressor (S-60) Structural BMPs: Sloped areas divert rainwater to the site process sewer system. Procedural BMPs: None related to stormwater. Notes: • (S-4) Former No. 6 Fuel Oil Tank has been completely removed from the site. • (S-11) Former Bulk Acetic Acid Bladder Tank has been completely removed from the site (in 1996). • (S-17) Former Spent Catalyst Storage Area is not in use; moved to Hazardous Waste Pad (S-20) in 2016. • (S-21) Former Storage Area West of Shot Pond has been completely removed from the site. • (S-28) Former Flammable Liquids Storage Area has been completely removed from the site. • (S-29) Former Storage Pad northwest of Environmental Lab (WWTP area) • (S-32) Former Waste Toluene Storage Tank Area has been completely removed from the site (in 2000). • (S-33) Former Day Tanks at Building 201 have been completely removed from the site (in 1996). • (S-34) Former Day Tanks at Building 205 have been completely removed from the site (in 1996). • (S-36) Former Corrective Action Roll -off Storage is a practice no longer utilized at the site. • (S-37) Wastewater Filter Solids Accumulation Area is no longer utilized at the site. • (S40) Hydrogen Peroxide Tote location moved to the Hill Tank Farm (S-10) in 2009. • (S44) Former Transformer Substation No. 3 has been completely removed from the site (in 2015). Page 11 of 12 Table 2 Materials Storage Practices — BMP Summary Mallinckrodt LLC Raleigh AN Plant Revised: May 2016 Denotes areas not inspected because no significant exposure to stormwater Page 12 of 12 f0"%N Table 3 Loading/Unloading Activities — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised May 2014 Note: The BMPs for loading/unloading activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Loading/Unloading Area Location and Implemented Best Management Practices (BMPs) Location: On the east and south sides of the building 51 warehouse, in Building 51 Warehouse Loading/Unloading Drainage Zones 1 and 2 Materials: APAP (granular and powder) (L-1)* Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: On the eastern and western sides of the building 5 1 A warehouse in Drainage Zones 2 and 3B Building 5 1 A Warehouse Loading/Unloading Materials: Raw materials (see Table 1, S-2) (L-2)* Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: North of building 101 and south of building 201, in Drainage Zone 3B Materials: Acetic acid. Structural BMPs: A trench drain leading to a manually controlled sump that discharges into the process sewer system collects nun -off from this material transfer area. An asphalt berm diverts run-off in Acetic Acid Loading Stations this area to the process sewer. North of Building 101 Procedural BMPs: Before loading/unloading procedures begin, operators make (L-3) sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable or combustible material), and that the hoses, pumps, and lines do not have leaks. Operators are also present during loading and unloading operations, and monitor the levels of materials in the tanks to prevent overflow ands ill, and to observe for leaks. Location: West of buildings 101 and 205 in Drainage Zone 3B Materials: Nitrobenzene, sulfuric acid, and acetic anhydride are received in this area; aniline, ammonium sulfate, and acetic acid are shipped from this area. Structural BMPs: The nitrobenzene railcar transfer areas are equipped with collection pans that drain to a 1,000-gallon sump. The aniline rail car transfer area is equipped with a collection pan that drains to a 500-gallon sump. The sump is equipped with a pump so that the contents can be collected and used or discharged to the site process sewer system. Sulfuric acid Railcar Area Loading/Unloading railcar transfer areas consist of lime to neutralize any spilled (L-4) material. Additional secondary containment would be provided by the series of valve -controlled ditches located onsite. Procedural BMPs: Before loading/unloading procedures begin, operators make sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable or combustible material), and that the hoses, pumps, and lines do not have leaks. Operators also present during unloading and monitor the levels of materials in the tanks to prevent overflow and spill and to observe for leaks. Page 1 of 6 /,.w` /AIMN Table 3 Loading/Unloading Activities — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised May 2014 Note: The BMPs for loading/unloading activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Loading/Unloading Area Location and Implemented Best Management Practices (BMPs) Location: North of the WWTP and east of the flushwater pond in Drainage Zone 3B Materials: Acetic acid, phosphoric acid, and liquid magnesium hydroxide Structural BMPs: Wastewater treatment chemical loadinglunloading occurs on a concrete pad with a 5" sloped concrete berm. The sloped berm allows vehicle access, but provides containment. The pad is approximately 47' by 14' and is constructed in a roadway, and is sloped toward a sump. The capacity of the loading area is approximately 1,900 gallons. The sump has a level switch and accumulated water in the loading area is pumped into the dike around the liquid magnesium hydroxide tank, which has a Tank Farm at WWTP Unloading capacity of approximately 13,000 gallons. A lock has been (L-6) placed on the sump pump in this area. Procedural BMPs: Before loading/unloading procedures begin, operators make sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable or combustible material), and that the hoses, pumps, and lines do not have leaks. Operators also monitor the levels of materials in the tanks and the transfer operations to prevent overflow and minimize the impact of any spill. Water accumulated in the dike is checked visually by the Mallinckrodt Utilities Department for signs of contamination and odor prior to being manually pumped to the WWTP (see Table 2, 5-23). Location: Southeast of the WWTP in Drainage Zone 3B Materials: APAP and PAP Structural BMPs: This loading/unloading area has two loading docks with bumper pads which provide a tight seal between the building and trucks, a canopy and a driveway which is sloped towards the building. The area is paved and contains a catch basin at each loading Building 10 Warehouse Loading/Unloading dock that drains to the storm water system. The majority of the (L-7) materials handling operations are contained inside the trailer and warehouse. Secondary containment for this area would be provided by the onsite retention pond. Procedural BMPs: Provisions are made to place materials on pallets and stack pallets at safe heights. Absorbent materials are also readily available in this area. The catch basins are cleared of leaves and debris as needed. Location: On the western side of building 100 in Drainage Zone 3B Materials: Caustic (Sodium hydroxide or Potassium hydroxide). Structural BMPs: This loadinglunloading area has a concrete containment berm with a capacity of 6,000 gallons. The loading/unloading area contains a sump that allows accumulated liquids to be pumped to the site process sewer system. Loading/Unloading Area Behind Building 100 Procedural BMPs: Before loading/unloading procedures begin, operators make (L-8) sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable or combustible material), and that the hoses, pumps, and lines do not have leaks. Operators also monitor the levels of materials in the tanks to prevent overflow ands ill. Page 2 of 6 Table 3 Loading/Unloading Activities — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised May 2014 Note: The BMPs for loading/unloading activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Loading/Unloading Area Location and Implemented Best Management Practices (BMPs) Location: On the north side of the #2 fuel oil aboveground storage tank (S-3) in Drainage Zone 3B Materials: No. #2 fuel oil Structural BMPs: Top loading/unloading operations are conducted at this truck loading/unloading station. The station, consisting of concrete dike walls on the east and west sides, concrete ramps on the north and south sides (68' x 13 % and a trench drain and sump at the low point has sufficient capacity to contain the volume of one compartment of a 7,500 gallon tanker truck plus freeboard for rain accumulation. An operator is present at all times during No. 2 Fuel Oil/Caustic Unloading Area unloading operations and any leaks or failures in the hoses, etc. (L-9) would be corrected immediately. Procedural BMPs: Before unloading procedures begin, Utility operators make sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), and that the hoses, pumps, and lines do not have leaks in accordance with area -specific fuel unloading procedure in the site's Oil SPCC Plan (see Table 1, S-3). Operators also monitor the levels of materials in the tanks to prevent overflow and spill. The sump is pumped to the stormwater ditch located west across the roadway. A lock has been placed on the sump pumpin this area. Location: On the eastern side of building 100 in Drainage Zone 3B Loading/Unloading Dock at Building 100 Materials: New, empty fiber pack drums and chemicals in drums and bags. (L-10)* Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Location: South of the MASL Storage Tanks in Drainage Zone 3B Materials: Ammonium sulfate (MASL) Structural BMPs: Each of the two-loading/unloading areas has a sloped concrete pad, berms around the concrete pad, and a sump with a total capacity of approximately 3,500 gal. The sumps have pumps with float switches that pump collected materials to MASL Tank # 1. This provides enough containment for the volume of one compartment of a tanker truck plus rainwater accumulation. Procedural BMPs: Truck drivers are responsible for implementing procedures to minimize the likelihood of a release from the truck loading MASL Loading operation. Before loading/unloading procedures begin, drivers (L-11) make sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable or combustible material), and that the hoses, pumps, and lines do not have leaks. A metered loading system automates the loading process and minimizes the possibility of overfill. Drivers are responsible for checking the track valve to ensure it is secure before leaving the site. Failure to comply will ban the driver from receiving any future loads of MASL. Accumulated water is generally pumped to MASL Tank # 1. Page 3 of 6 /406b�l /00ft1 Table 3 Loading/Unloading Activities — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised May 2014 Note: The BMPs for loading/unloading activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and tvne of materials. Loading/Unloading Area Location and Implemented Best Management Practices (BMPs) Location: Southeast of the boiler house (Building 901) and west of the building 51 warehouse in Drainage Zone 2 Materials: Gasoline and diesel fuel Structural BMPs: An additional, bermed 14 feet was added to the length and another 6" added to the height of the existing recessed 10'x 29'x14" fuel tank containment area. The sloped berm allows vehicle access, but provides containment (see Table 1, 5-27). Sufficient containment is provided for a 2,500 gallon tanker truck and 1,400 gallons of rainwater accumulation from a 25 year-24 hour storm event. Containment for the additional 1,300 gallons of possible accumulated rainwater would be provided by the adjacent valve -control storm water ditch. An operator is Vehicle Fuel Loading/Unloading present during all unloading operations and a failure or rupture (L-12) would be addressed immediately. Procedural BMPs: Before unloading procedures begin, Utility operators make sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable material), and that the hoses, pumps, and lines do not have leaks in accordance with specific fuel unloading procedures in the site's Oil SPCC Plan. Operators also monitor the levels of materials in the tanks to prevent overflow and spill. There are no drains from this area. Stormwater that accumulates in the dike and in the bermed pad is manually pumped to the stormwater ditch just east of this area. A lock has been placed on the sump pumpin this area. Location: Northeastern comer of building 201, in Drainage Zone 3B Materials: Aniline, ammonium bisulfate Structural BMPs: This loading/unloading area has a sloped concrete pad, a sump and dike along the western end of the pad, dikes on the northern and southern sides of the pad, and a berm on the eastern end of the pad (this berm was moved approximately 20 ft. to the west in 2004 to facilitate drainage). Stormwater accumulated in the sump is pumped to the process sewer system. Drainage will Aniline Truck Loading/Ammonium Bisulfite allow all stormwater to flow by gravity to the process sewer. Truck Unloading The existing loading/unloading area has a capacity of (L-13) approximately 2,000 gallons. Procedural BMPs: Before loading/unloading procedures begin, operators make sure that wheels are chocked, that the vessel is in good condition, the vessel is vented (if it is pressurized), the vessel is grounded (if it contains flammable or combustible material), and that the hoses, pumps, and lines do not have leaks. Operators also monitor the levels of materials in the tanks as well as the transfer operations to prevent overflow ands ill. Location: West Side of Building 200 in Drainage Zone 3B Materials: PAP Structural BMPs: This loading/unloading area has a driveway that slopes south to three catch basins that drain to the condensate sewer system via West Side PAP Loading/Unloading industrial discharge agreement. There is also roof over the (L-14) loading and unloading platform. Procedural BMPs: Provisions are made to place materials on pallets and stack pallets at safe heights. Absorbent materials are also readily available in this area. Materials are moved inside as soon as possible and not stored on the loading platform. Page 4 of 6 /*M%N r&oft\ Table 3 Loading/Unloading Activities — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised May 2014 Note: The BMPs for loadingfunloading activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Loading/Unloading Area Location and Implemented Best Management Practices (BMPs) Location: Northeast of building 903 in Drainage Zone 3B Materials: Anhydrous ammonia Structural BMPs: This concrete diked loading/unloading area slopes and drains to a sump. Rainwater collected in the sump is manually pumped by the Mallinckrodt Warehouse Department to the stormwater Anhydrous Ammonia Unloading Area conveyance ditch. A lock has been placed on the sump pump in this area. (L-17) Procedural BMPs: Before loadinglunloading procedures begin, operators make sure that wheels are chocked, that the vessel is in good condition, and that the hoses, pumps, and lines do not have leaks. Operators also monitor the levels of materials in the tanks to prevent overflow and spill. Location: Northeast of building 903 in Drainage Zone 3B Materials: Sulfuric acid Structural B1VIPs: This concrete diked unloading area slopes and drains to a sump. Material collected in the sump is manually pumped to the process sewer system. Operators are present during the Sulfuric Acid Unloading Area unloading operations and can manually discharge to process (L-18) sewer. Procedural BMPs: Before unloading procedures begin, operators make sure that wheels are chocked, that the vessel is in good condition, and that the hoses, pumps, and lines do not have leaks. Operators also monitor the levels of materials in the tanks to prevent overflow ands ill. Location: Northeast of building 903 in Drainage Zone 3B Materials: Nitrobenzene Structural BMPs: This concrete diked unloading area slopes and drains to a sump. Materials collected in the sump is manually pumped to the Nitrobenzene Unloading Area process sewer system. Procedural BMPs: Before unloading procedures begin, operators make sure that (L-19) wheels are chocked, that the vessel is in good condition, and that the hoses, pumps, and lines do not have leaks. Operators also monitor the levels of materials in the tanks to prevent overflow ands ill. Location: Adjacent to Building 907 in Drainage Zone 3B Materials: Used Oil Structural BMPs: This concrete loading area slopes to a stormwater conveyance ditch that contains a gate valve that is operated in the locked position. This storm water conveyance provides secondary containment for this area. Procedural BMPs: Only Environmental Staff are able to oversee the loading of used oil and signing of the manifest. Before unloading Used Oil Loading Area (L-20) procedures begin, Environmental personnel make sure that wheels are chocked, that the vessel is in good condition, and that the hoses, pumps, and lines do not have leaks plus verifies that the valve in the stormwater drainage ditch located north of the Hydrogen Plant is locked in accordance with area -specific fuel loading procedure in the site's Oil SPCC Plan. The person also monitors the levels of materials in the tanks to prevent overflow and spill. Spill response materials are located at this area and are placed around the loading operation area and a spill boom is placed between the loading operations and the ditch. Page 5 of 6 /0"*N, Table 3 LoadinglUnloading Activities — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised May 2014 Note: The BMPs for loading/unloading activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Loading/Unloading Area Location and Implemented Best Management Practices (BMPs) Location: In WWTP Area on the east side and adjacent to the diesel emergency backup generator in Drainage Zone 3B Materials: Diesel Structural BMPs: This unloading area slopes to a stormwater conveyance ditch that drains to the onsite retention pond, which provides secondary containment. WWTP Emergency Generator (L-21) Procedural BMPs: Before unloading procedures begin, Utility operators make sure that wheels are chocked, that there is sufficient room in the fuel tank, and that the hoses and pumps do not have leaks in accordance with area -specific fuel unloading procedure in the site's Oil SPCC Plan. Operators also monitor the level of material in the generator to prevent overflow and spill. Spill equipment is available in this area and spill booms are placed around the loadin operations. Notes: • (L-5) Former K083 Tar Loading and Unloading area is no longer in use. Also see Table 6, W-17. • (L-15) Former Waste Toluene Loading area is no longer in use; toluene is no longer used in plant processes. • (L-16) Former Thionyl Chloride and DMF Unloading area is no longer in use; these chemicals are no longer used in plant processes. Denotes areas not inspected because no significant exposure to stormwater Page 6 of 6 rO'b, /4"�N Table 4 Outdoor Process Areas — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2014 Note: The BMPs for outdoor process activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Outdoor Process Area Location and Implemented Best Management Practices (BMPs) Location: West of the building 51 warehouse and southwest of the Fire Training Area gasoline storage and loading/unloading area in Drainage (P-1) Zone 2 Materials: #2 fuel oil, gasoline, various hazardous materials or hazardous/solid wastes Structural BMPs: The fire training area is located on a concrete diked pad approximately 40' x 20' x 1.5' that slopes to a sump on the southern end of the pad. The sump is operated in a locked and closed position. Procedural BMPs: Fire training is conducted annually, typically in October of each year. Upon completion of fire training, an environmental contractor manually pumps liquids in the sump into a vacuum truck for disposal. Residual liquids contained in the sump are typically a mixture of rainwater, #2 fuel oil, and firefighting foam. The sump is then power -washed and emptied into the vacuum truck. During the rest of the year, when no potential contamination sources are present in the sump, collected rainwater in the sump is inspected by the Mallinckrodt Utilities Department and then manually pumped to the stormwater conveyance ditch located east of the training area. A lock has been placed on the sump pump in this area. Mallinckrodt personnel inspect the containment system at least once each six months. When hazardous wastes are temporarily stored in this area (<90-day storage), a minimum of weekly inspections are performed. The Environmental Department ensures that only compatible materials are stored in this area. Location: On the southeastern end of the maintenance building Maintenance Wash Pit (building 903) in Drainage Zone 2 (P-2)* Materials: Infrequent use for rinsing maintenance equipment/ tools. Structural BMPs: The concrete wash pit is sloped towards a sanitary sewer drain located on the northern end of the pit. There are berms located on the southern, eastern, and western sides of the pit. Procedural BMPs: None related to stormwater. Not identified as a significant source of stormwater contamination. Location: North of the PAP process area in Drainage Zone 3B Wastewater Treatment Plant Materials: Process wastewater (P-4)* Structural BMPs: The tanks in the WWTP are equipped with high level alarms, flow controls, and liners with the steel tanks themselves as secondary containment. The 4,000,000- gallon capacity wastewater holding tank is equipped with a water leachate system under the tank that collects and redirects minor spills to the WWTP. Procedural BMPs: None related to stormwater. Page 1 of 2 Aloft\ f'""\ Table 4 Outdoor Process Areas — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: May 2014 Note: The BMPs for outdoor process activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Outdoor Process Area Location and Implemented Best Management Practices (BMPs) Location: South of Building 910 and west of Building 912 in Scrubber System Drainage Zone 3B (P-5) Materials: 25% Sodium hydroxide [Co -located with Boiler No. 7 (S-59)] Structural BMPs: The scrubber system and associated tanks are contained by a dike. This equipment is located in the same dike as Boiler No. 7 (see Table 2, S-59).This dike provides sufficient containment for the volume of the largest tank in the dike and rainwater accumulation from a 25 year- 24 hour storm event. The dike drains into a trench and sump. Procedural BMPs: Stormwater is allowed to accumulate in the sump and inspected by the Mallinckrodt Utilities Department for visual signs of impact. Based on prior approval by the City of Raleigh POTW, stormwater is pumped to the condensate sewer system.. Denotes areas not inspected because no significant exposure to stormwater Page 2 of 2 f'°"N 'A� Table 5 — BMP Summary Dust/Particulate Generating/Control Areas Mallinckrodt LLC Raleigh API Plant Revised: May 2014 Note: The BMPs for dust/particulate generating/control activities were chosen based on their level of potential impact to storm water, including frequency of movement of materials, volume of materials, location at facility, and type of materials. Dust/Particulate Generating/Control Areas Location and Implemented Best Management Practices (BMPs) Location: In Buildings 201 and 205 in Drainage Zone 313 PAP Bag Filters for Vacuum Dryers and Product Bin Materials: PAP (powder) Packaging Structural BMPs: The bag filters are equipped with a control device to (D-I)* prevent emissions of particulates. The roof drains in this area are directed to the WWTP. Procedural BMPs: None related to stormwater. Not identified as a significant source of storm water contamination. Location: In Buildings 101, 102, 103, and 104 in Drainage Zones 2 APAP Bag Filters on Drop Hoppers, Sizing Operating and 3B Equipment, and Multi -level Clean Room Operations Materials: APAP (powder, granular) (D-2)* Structural BMPs: The bag filters are equipped with a control device to prevent emissions of particulates and the roof drains in this area are directed to the WWTP. Procedural BMPs: None related to stormwater. Not identified as a significant source of stormwater contamination. Location: South of Building 102 in Drainage Zone 2 APAP Drying Tower Courtyard Materials: APAP from bag filter transportation (D-3) Structural BMPs: Drainage from the courtyard area, through which bag filters are cleaned and transported, was redirected to the process sewer system in 2004. Procedural BMPs: None related to stormwater. Not identified as a significant source of stormwater contamination. Incidental releases of APAP dust is swept up on a regular basis. Location: West of Building 5 1 A in Drainage Zones 2 and 3B Boiler House Materials: Particulates from the burning of fuels in site boilers (D4)* Structural BMPs: None related to stormwater. Procedural BMPs: None related to stormwater. Not identified as a significant source of stormwater contamination. Denotes areas not inspected because no significant exposure to stormwater Page 1 of 1 Table 6 Waste Disposal Areas — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: July 2015 Note: The BMPs for waste disposal activities were chosen based on their level of potential impact to storm water, including volume of materials, location at facility, and type of materials. Waste Disposal Area Location and Implemented Best Management Practices (BMPs) Location: NW Corner of Building 101 in Drainage Zone 3 Dumpster and Trash Compactor Northwest of Building Materials: Crushed empty fiber drums and trash from Building 101 101 and administrative offices and carbon. (W-2)* Structural BMPs: The trash compactor is self -enclosed and is contained by walls on the south and east sides, and a berm on the west side. The dumpster is contained by walls on the south and east sides, and a berm on the west side. Run off from this area flows to an asphalt diversion berm, then drains to a sump leading to the site process sewer system. Procedural BMPs: Employees are trained about appropriate placement of waste in dumpsters. Location: SE and SW of Building 201 in Drainage Zone 3 Materials: Trash from building 200 and 201, packaging for raw Dumpster Southeast of Building 201 materials, drums/totes of potassium hydroxide, and non - Waste Pallet Dumpster East of the Maintenance Shop recyclable pallets. (W-3)* Structural BMPs: Trash dumpster is self -enclosed. These dumpsters are not covered or within a dike due to low risk of exposure to Stormwater. Procedural BMPs: Employees are trained about appropriate placement of wastes and pallets in dumpsters. Location: NW of Building 10 in Drainage Zone 3 Dumpster Northwest of Building 10 Materials: Trash from Building 10 and WWTP Dumpster near Building 10 Loading Docks Structural BMPs: The common trash dumpster is self -enclosed and the (W-4)* cardboard dumpster is open -topped. Procedural BMPs: Employees are trained about placement of waste in dumpsters. Location: NW of Building 101 in Drainage Zone 3 Cardboard Recycling Container Materials: Cardboard (W-7)* Structural BMPs: None related to stormwater Procedural BMPs: Employees are trained about placement of cardboard for recycling in dumpsters. Location: North of Building 205 in former K083 Tar load/unload Dumpster North of Building 205 area (L-5) in Drainage Zone 3 (W-9)' Materials: Trash from buildings 204 and 205 and packaging for raw materials. Structural BMPs: The dumpster is self -enclosed and is located on concrete pad, surrounded by a berm, sloped toward a sump located inside the loading area. Procedural BMPs: Accumulated storm water is inspected and, if clean, is manually pumped to the process sewer. Employees are trained about placement of waste in dumpsters. Location: NW of the Maintenance Building in Drainage Zone 3 Recycling Bins Northwest of Maintenance Materials: Segregated metal equipment, parts, and miscellaneous (W-10)* construction debris. Structural BMPs: None related to stormwater Procedural BMPs: Employees are trained about placement of recyclables in bins/dumpsters. All oils are drained and piping is wiped down prior to placement in metal recycling bins. Misc. Trash Cans Location: Throughout plant site (W-13)* Materials: Misc. garbage (e.g., paper, beverage containers, etc.) Structural BMPs: The common trash can with lid or open top trash hopper Procedural BMPs: Employees are trained about placement of waste in dumpsters. Hazardous Waste Storage Area (W-14) See Table 1, S-20 Page 1 of 2 /'"4N, ,r°"°\ Table 6 Waste Disposal Areas — BMP Summary Mallinckrodt LLC Raleigh API Plant Revised: July 2015 Note: The BMPs for waste disposal activities were chosen based on their level of potential impact to storm water, including volume of materials, location at facility, and type of materials. Waste Disposal Area Location and Implemented Best Management Practices (BMPs) Location: East of Building 100A in Drainage Zone 3 Trash Compactor East of Building 100A Materials: Crushed empty fiber drums and trash from building 100, (W-16)* 100A and warehouse Structural BMPs: The trash compactor is covered by a roof. Procedural BMPs: Employees are trained about placement of waste in dun stern. Location: Northwest of building 901 in Drainage Zone 3 K083 Rainwater Storage — west of Building 905 Materials: Rainwater/precipitation that has been in contact with (W-17) K083 aniline tar tanks and/or the secondary containment for those tanks. Structural BMPs: Rainwater is pumped or manually transferred to totes from the dikes containment areas of S-5 and 5-19. These totes are stored in this diked concrete secondary containment located adjacent to the Aniline Tar Tank containment area (S-5). This area is 45' x 13' x 0.5' at the ends and is sloped towards the middle where the depth is 0.7'. Procedural BMPs: Stotmwater accumulation from the sumps or diked areas of S-5 and S-19 is manually pumped out directly into totes (or other containers). These totes are stored temporarily in this diked area until being transferred to the Hazardous Waste Storage Building (5-20), at intervals of less than 90 days for each tote. Filling the tote is limited to a few inches below the top of the tote to allow for freeboard. The totes are stored at the Hazardous Waste Storage Pad prior to ultimately being sent off -site for disposal as a hazardous waste. Accumulated water in this area is inspected prior to discharge. Notes: • (W-1) Carbon dumpster now part of W-2. • (W-5, W-6, and W-11) All trash cans and open top hoppers identified as W-13. • (W-8) Dumpsters at Driveway Tank Farm are no longer used. • (W-12) Former Open Top Roll -off Storage (same as S-36) is a practice that is no longer used at this facility. * Denotes areas not inspected because no significant exposure to stormwater Page 2 of 2 /O�N Summary of Significant Changes in Industrial Activities eo'* N Mallinckrodt LLC, Raleigh Pharmaceuticals Plant 2011 to Present Year Description 2011 • Upgraded existing Bulk Acetic Acid/APAP Wastewater Tank Farm including better materials of construction for the acetic acid tanks and an improved containment design (S-15), • Moved storage of 2 raw materials stored in totes, hydrogen peroxide and aqua ammonia, from an uncovered area (S-17) to the covered/diked Hazardous Waste Storage Pad (S-20) • Added new Utilities Building transformer, Substation #8 (S-53) • Converted former Tar Loading/Unloading Truck Station (S-40) to PAP Rework/temporary storage (S-54) • Switched management of K083-contaminated rainwater from a tanker trailer to totes (L-5) • Began using Fire Training Area (P-1) for storing non -routine wastes and high -strength wastewater in tankers and/or totes • Added cartridge filters on exhausts of dust collectors to ensure broken bags do not emit particulate onto the roofs (D-2) 2012 • Added new tank farm/containment system for several replacement vessels used in the production of APAP including an improved containment design (S-55) • Added new replacement sulfuric acid tank farm including better materials of construction for the tanks and an improved containment design (S-56) 2013 • Added new K083 waste -combusting boiler in diked area (S-59) • Added new stormwater trench drain between Buildings 910 and 903 • Added new procedures for collection of HVAC and chiller cleaning water 2014 • Updated protocol for addressing potential stormwater contamination for dumpsters and open -topped buckets 2015 • Modified protocol for valves in oil -filled transformer containment areas to have valves remain open due to safety concerns with ponding water under energized equipment and closing valves upon discovery of oil leaks • Installed additional vessels for the APAP production process, including new containment systems including an improved containment design (S-55) 2016 • Moved spent catalyst residues (S-17) from outdoors to the covered/diked Hazardous Waste Storage Pad (S-20) STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Permitting Facility Name: Permit Number: Location Address: Mallinckrodt LLC NCS000136 8801 Capital Boulevard North Carolina 27616 County: USA 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 Aoft\ 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 14M\ Print or type name of person signing above Date O 6 /0 L/�� Title SPPP Certification 10/13