NCG050172_Name-Owner Change Supporting Info_20231130

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CARPENTER
Stormwater Pollution Prevention Plan
Carpenter Co.
1515 Carter Street
P.O. Box 1528
Mount Airy, NC 27030
December 1, 2023
General Permit Number: NCG050000
Certificate of Coverage Number NCG050172 (Effective 6/1/2023-2028)

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Stormwater Pollution Prevention Plan
Travis Gnida
Carpenter Co.
Division Manager

CONTENTS
CONTENTS
EXECUTIVE SUMMARY 4
1. GENERAL FACILITY INFORMATION 6
2. SWPPP OBJECTIVES 6
3. SITE OVERVIEW 8
3.1 Description of Facility 8
3.2 Location Map 8
3.3 Narrative Description 9
3.3.1 Process Description 9
3.3.2 Potential Pollutants 9
3.3.3 Outfall 1 10
3.3.4 Other Areas 10
3.4 List of Significant Spills or Leaks 10
3.5 Non-Storm Water Discharges 10
3.5.1 General 10
3.5.2 Certification 11
4. STORM WATER MANAGEMENT STRATEGY 17
4.1 Feasibility Study 17
4.1.1 Railcar Chemical Unloading Area 17
4.1.2 Truck Chemical Unloading Area 17
4.1.3 Diesel Fueling 17
4.1.4 Product Shipping/Receiving Activities 17
4.1.5 Solid Waste Disposal 17
4.1.6 Temporary Storage of Tractor Trailers 18
4.2 Secondary Containment 18
4.3 BMP Summary 18
4.4 Soil Erosion and Sediment Control 19
5. SPILL PREVENTION AND RESPONSE PROCEDURES 20
5.1 Potential Spill Areas 20
5.1.1 Railcar Chemical Unloading Area 20
5.1.2 Diesel Fueling Area 21
5.2 Spill Response Team and Reporting Procedures 21
6. PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING PROGRAM 22
6.1 Preventative Maintenance 22
6.1.1 Facility Preventative Maintenance Inspections 22
6.1.2 Records on Preventive Maintenance 22
6.2 Good Housekeeping Program 22
7. INSPECTIONS, SAMPLING,AND RECORDKEEPING 24
7.1 Facility Inspections 24
7.2 Storm Water Sampling 24
7.3 Recordkeeping 25
10. Other Obvious Indicators of Stormwater Pollution: 29
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition may be
indicative of pollutant exposure. These conditions warrant further investigation. 29
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CONTENTS
8. EMPLOYEE TRAINING 30
8.1 Spill Prevention and Response 30
8.2 Preventative Maintenance 30
8.3 Good Housekeeping 30
8.4 Training Frequency 31
9. RESPONSIBLE PARTY 32
10. SWPPP AMENDMENT AND ANNUAL UPDATE 35
11. SWPPP IMPLEMENTATION 37
APPENDIX A LIST OF FACILITY STORAGE TANKS
APPENDIX B INSPECTION SUMMARY
List of Tables
Table 3-1 Inventory of Potential Pollutant Sources 15
Table 3-2 Significant Spills or Leaks 16
Table 7-1 Facility Inspection 26
Table 7-2 Qualitative Visual Inspection 28
Table 9-1 Pollution Prevention Team Responsibility 33
Table 9-2 Annual Comprehensive SWPPP Evaluation 34
Table 10-1 SWPPP Amendments 36
..ist of Figures
Figure 3-1 Facility Location 13
Figure 3-2 Site Map 14
Carpenter Co.SWPPP Version:D-11-2023 Page ii

CONTENTS
Acronyms and Abbreviations
Acronym Description
BMP Best Management Practice
COC Certificate of Coverage
DEMLR Division of Energy, Mineral and Land Resources
DEQ Department of Environmental Quality
EPA United States Environmental Protection Agency
ERM ERM NC, Inc.
MDI polymeric diphenylmethane diisocyanate
CARPENTER CO. CARPENTER CO. Polyurethanes - BMC
NPDES National Pollutant Discharge Elimination System
SARA Superfund Amendments and Reauthorization Act
SWPPP Storm Water Pollution Prevention Plan, referred to as SPPP in the NPDES permit
TDI toluene diisocyanate
TMDL Total Maximum Daily Load
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EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
On 1 December 2023, Carpenter Co. purchased the facility, located at 1515 Carter Street, in Surry County,
Mount Airy, North Carolina, and eceived a notification of the availability of a Certificate of Coverage
(COC)#NCG050172.
On 20 September 2018, the NCFI Polyurethanes— BMC facility, located at 1515 Carter Street, in Surry
County, Mount Airy, North Carolina, received a notification of the availability of a Certificate of Coverage
(COC)#NCG050172 from the Division of Energy, Mineral and Land Resources (DEMLR)that reissued
General Industrial Storm Water Permit(General Permit), Permit No. NCG050000. The effective date of
the COC was 1 June 2018. This Storm Water Pollution Prevention Plan (SWPPP) was prepared for the
NCFI Polyurethanes -BMC facility in accordance with the requirements of the General Permit. Carpenter
Co. purchased the facility On 1 December 2023. The NPDES Stormwater Permit Name/Owner Change
Request was filed prior to the purchased date.
This SWPPP identifies potential sources of stormwater pollution at the CARPENTER CO. facility and
recommends appropriate Best Management Practices (BMPs)or control measures to be implemented to
minimize or eliminate the discharge of pollutants in stormwater runoff. The key compliance requirements
of the General Permit and the SWPPP are highlighted below:
• Deadlines:
In accordance with Part III Section A.1, Carpenter Co. will update the existing SWPPP within 6 months
after receiving notification of COC (by 1 June 2023).
• Coverage:
The General Permit does not authorize non-storm water discharges. All such discharges must be
properly permitted or eliminated. Facility inspections are conducted quarterly to identify and correct
non-storm water discharges.
• Availability:
The SWPPP must be retained at the facility at all times. The plan is a public document, and a
copy must be made available to the North Carolina Department of Environmental Quality
(DEQ, Division of Energy, Mineral, and Land Resources (DEMLR), municipality, or public
upon request. CARPENTER CO. , however, may claim portions of this SWPPP as
confidential business information, including any portion describing facility security measures.
This plan and associated reports are also considered legal documents and must be retained
on-site in the facility's files.
• Storm Water Monitoring and Reporting:
Inspections of the facility and all storm water conveyance systems shall occur at a minimum on a
quarterly schedule, once in: Q1 (January-March), Q2 (April-June), Q3 (July-September), and Q4
(October-December). During each inspection, visual monitoring of storm water for color, foam, outfall
staining, visible sheens and dry weather flow, shall be performed at all storm water outfall locations.
In accordance with the requirements of the General Permit, storm water discharges from any vehicle
maintenance activity occurring on-site, which uses more than 55-gallons of new motor oil per month
when averaged over the calendar year, shall be monitored by the facility. The CARPENTER CO.
facility currently does not use more than 55-gallons of new motor oil per month and is not subject to
sampling requirements.
• Recordkeeping and Reporting Requirements:
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EXECUTIVE SUMMARY
Implementation of this plan shall include documentation of all stormwater sampling, visual
inspections, maintenance activities, and employee training. Such documentation shall be retained on-
site for a period of five (5)years and made available to the Director of the DEMLR or his/her
authorized representative upon request.
Carpenter Co.SWPPP Version:D-11-2023 Page 5

GENERAL FACILITY INFORMATION
• SWPPP Updates:
The SWPPP shall be reviewed and updated on an annual basis. The SWPPP shall also be updated
or amended whenever changes at the facility increase or have the potential to increase the exposure
of significant materials to storm water, or when the plan is determined to be ineffective in achieving
the general objectives of controlling pollutants in storm water discharges associated with industrial
activities.
• Authorized Signature:
The SWPPP and all attachments shall be signed by a responsible corporate officer(i.e., president,
secretary, treasurer or vice-president)who is in charge of the Co.'s principal business function.
It is important to recognize that development and implementation of this SWPPP does not ensure
compliance with all terms and conditions of the General Permit. The SWPPP provides reference to some
of the permit conditions; however, not all the regulatory requirements are provided herein. The
CARPENTER CO. facility's Pollution Prevention Team Coordinator is responsible for reviewing the entire
General Permit and ensuring compliance with all terms and conditions.
1. GENERAL FACILITY INFORMATION
Name of Facility: Carpenter Co.
Facility Address 1515 Carter Street
Mount Airy. North Carolina 27030
Facility Contact Title: Environmental Specialist/ EHS Manager
Phone Number: [phone] extension 2403
Standard Industrial Classification (SIC) Code: 3086
General Permit No.: NCG05000
Certificate of Coverage No.: NCG050172
Effective Date of Permit: June 1, 2023
Expiration Date of Permit: May 31, 2028
Number of Storm Water Outfalls: One
2. SWPPP OBJECTIVES
The United States Environmental Protection Agency (EPA) published regulations in November 1990 to
control storm water discharges under the National Pollutant Discharge Elimination System (NPDES)
permit program. The goal of the storm water permit program is to improve water quality by reducing the
amount of pollutants contained in storm water runoff. To accomplish this goal, in part, industrial facilities
requiring a NPDES storm water discharge permit must prepare and implement a Storm Water Pollution
Prevention Plan (SWPPP).
Carpenter Co.SWPPP Version:D-11-2023 Page 6

SWPPP OBJECTIVES
• Section 3 Site Overview(corresponds to Part II, Section A.1 of the permit): provides a
description of the physical facility and the potential pollutant sources that may be expected to
contribute to contamination of storm water.
• Section 4 Storm Water Management Strategy(corresponds to Part II Section A.2 of the
permit): contains a narrative description of the materials management practices employed which
control or minimize the storm water exposure of significant materials, including structural and
nonstructural measures.
• Section 5 Spill Prevention and Response Procedures (corresponds to Part II Section A.3 of
the permit): incorporates an assessment of potential pollutant sources based on a materials
inventory of the facility.
• Section 6 Preventive Maintenance and Good Housekeeping Program (corresponds to Part II
Section A.4 of the permit): provides a discussion of the facility's existing preventive maintenance
program and is supplemented with schedules of inspections and maintenance activities relative to
storm water pollution prevention.
• Section 7 Facility Inspections (corresponds to Part II Section A.5 of the permit): describes the
types and frequency of inspections that will be conducted under the SWPPP.
• Section 8 Employee Training (corresponds to Part II Section A.6 of the permit): provides a
discussion of the components of the CARPENTER CO. training program that address spill
prevention, good housekeeping, material management practices and the basics of water pollution
laws.
• Section 9 Responsible Party(corresponds to Part II Section A.7 of the permit): identifies the
specific positions responsible for the overall coordination, development and implementation and
revisions of the SWPPP.
• Section 10 SWPPP Amendment and Annual Review(corresponds to Part II Section A.8 of the
permit): provides an overview of when the SWPPP will be amended and discusses the annual
review of the SWPPP.
• Section 11 SWPPP Implementation (corresponds to Part II Section A.9 of the permit)-
Monitoring, Documenting and Reporting: discusses how CARPENTER CO. will implement the
SWPPP and appropriate BMPs to prevent contaminants from entering surface waters via storm
water.
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SITE OVERVIEW
3. SITE OVERVIEW
3.1 Description of Facility
The CARPENTER CO. facility is involved in the manufacturing and fabricating of flexible polyurethane
foam for use in the furniture manufacturing industry as well as the production of carpet cushions. The
CARPENTER CO. facility also has a specialty product manufacturing division where a two-part foam
solution is sold to contractors. The CARPENTER CO. facility is classified under Standard Industrial
Classification (SIC) code 3086, Plastic and Foam Products. As with facilities within this SIC Group 30, the
CARPENTER CO. facility is within the scope of 40 CFR§ 122.26 (b)(14)(xi) and constitute what are
commonly referred to as "Category 11" or"light-industry"facilities.
The primary CARPENTER CO. manufacturing facility is located on a 34-acre parcel at 1515 Carter Street
in Mount Airy, North Carolina. The primary facility is bounded to the north by Carter Street, to the east by
the Southern Railway and Woltz Street, to the south by Woltz Street, and to the west by an adjacent
industrial facility. The CARPENTER CO. site is located within a semi-rural area that is comprised of
mostly light industries and commercial property. The primary manufacturing facility's main entrance is
located on Carter Street and consists of two attached buildings, Building A and Building B. Building A
includes office space, bun storage, and flexible polyurethane foam fabrication. Building B, which is
located on the western portion of the parcel contains specialty product manufacturing where a two-part
foam solution is manufactured. South of the primary manufacturing facility is Building C, where foam
products are cut and shipped. Southwest of the primary manufacturing facility is the Tech Center at 1552
Woltz Street. Half of the floor space in the Tech Center is office space, while Research and Development
tests products for different customer needs in the other half of the space. Conveyances for storm water
from Buildings A, B, C, and the Tech Center are directed to Outfall 1.
The majority of the chemical bulk storage tanks at the facility are located outdoors (Appendix A presents
a list of the tank capacities and contents). The bulk chemical tanks are dedicated to handle the chemical
properly. The CARPENTER CO. facility also has a diesel underground storage tank which is used for on-
site fueling of trucks.
CARPENTER CO. occupies additional facilities adjacent or within close proximity to the primary
manufacturing facility. Manufacturing activities do not occur at these additional facilities, and they are
considered off-site facilities. These include:
• Building D at 199 Woltz Street
• Building E at 1550 Carter Street
• Tech Center and Building C at 220 Woltz Street ends at the same outflow
3.2 Location Map
Figure 3-1 presents the general location of the facility on the Mount Airy South Quadrangle (7.5-minute
series), showing the facility's location in relation to transportation routes and surface waters. The Ararat
River, a Class C water in the Yadkin-Pee Dee River Basin, is the receiving waters for the outfall from the
CARPENTER CO. facility. Figure 3-2 is a site map that shows the stormwater flow, the outfall, the
location of various buildings, storage tanks and other items of interest. The outfall for the CARPENTER
CO. facility is described in Section 3.3 of this document and are as follows:
Outfall 1 —Latitude-80.6074, Longitude 36.4739
The receiving waters (the Ararat River, from Seed Creek to Rutledge Creek)are impaired (as listed in
303(d). A TMDL has been established for turbidity in the watershed. In addition, a mercury TMDL has
been established for all waters statewide.
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SITE OVERVIEW
3.3 Narrative Description
CARPENTER CO. manufactures flexible polyurethane foams and various blends of foam generating
materials. The following sections provide more details of the operations.
3.3.1 Process Description
3.3.1.1 Consumer Products - Flexible Polyurethane Foam Manufacturing
CARPENTER CO. 's flexible polyurethane foam production is conducted indoors, normally not in contact
with storm water. Industrial activities with potential exposure to storm water include material handling
activities including storage, loading and unloading, transportation, or conveyance of any raw material,
intermediate product, final product, by-product or waste product. Manufacturing and processing activities
are conducted indoors and based on a review of air emissions in the air permit, storm water is not
expected to be materially affected through vent stacks to roof drains.
The chemicals (raw materials) used to manufacture flexible polyurethane foam are shipped to the
CARPENTER CO. facility by railroad tanker cars. The raw materials, polyols and TDI, are received in
railroad tanker cars and the chemicals are transferred to large above-ground storage tanks, which are
located outdoors. Combustion modifying additives and auxiliary blowing agents (carbon dioxide) are
received and stored in a comparable manner. Other basic chemicals that are commonly used in smaller
quantities are stored in 55-gallon drums within the plant. These include tertiary aliphatic amine and tin
catalysts, silicone surfactants, combustion modifying additives (alkyl phosphate compounds and/or
chlorinated phosphate ester), auxiliary blowing agents (carbon dioxide) and other miscellaneous
components (crosslinkers, dyes, fillers, melamine).
CARPENTER CO. also blends a pentane blowing agent(s) into the resin component of some of the
polyurethane chemical systems. This process takes place in a dedicated structure built for this process.
One Pentane storage tank and one pentane blowing agent tank is located outside the Tech Center inside
secondary containment.
3.3.1.2 Specialty Products - Spray Foam Insulation Process
CARPENTER CO. 's Specialty Products Division manufactures spray foam products for use in homes,
office buildings, institutions and agricultural facilities. Chemicals used in the process include MDI, polyols,
blowing agents, catalyst, dyes, flame retardants, surfactants and other chemicals. MDI, polyols, flame
retardants, surfactants, blowing agents are stored in tanks outdoors within a concrete containment berm.
Other material is stored in totes and drums inside the facility, within secondary containment. Spray foam
manufacturing is conducted indoors. Based on a review of the air permit, dust or particle-generating vent
stack emissions are not expected to materially impact stormwater.
3.3.2 Potential Pollutants
This section provides a narrative description of the one outfall at the CARPENTER CO. facility and the
activities and significant materials within the drainage area which may be potential sources of pollutants.
Table 3-1 presents a summary of the significant exposed potential pollution sources or activities identified
at the CARPENTER CO. facility. A turbidity TMDL for the watershed and a state-wide mercury TMDL
state-wide is in place. Mercury is not an expected potential pollutant for the site, based on facility
operations and chemical inventory. The CARPENTER CO. facility periodically monitors for Total
Suspended Solids, a marker for turbidity, identifies and corrects non-stormwater discharges, and
periodically qualitatively assesses its stormwater discharges for clarity. For each source or activity, a
description of existing practices to minimize contact and the corresponding potential stormwater pollutant
are also provided in Table 3-1.
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SITE OVERVIEW
3.3.3 Outfall 1
Storm Water Outfall 1 (OF-1) is a 30-inch diameter corrugated metal pipe located approximately 180-feet
east of the main manufacturing building (building A) and parking lot at the eastern property boundary. OF-
1 receives surface water runoff from the entire facility through a system of vegetated drainage swales.
OF-1 also receives run-on from adjacent industrial facilities to the north and to the west. There are
numerous above-ground storage tanks at the facility which are used for storage of chemicals associated
with manufacturing flexible polyurethane foam. There are two (2) 250,000-gallon water above-ground
storage tanks located within the drainage area that are intended to be used for fire-fighting activities. The
drainage area of OF-1 is approximately 50% impervious.
The CARPENTER CO. facility currently provides spill containment for the outdoor above-ground storage
tanks by utilizing a spill containment drain "plug" and "gate"to prevent the discharge of chemical products
into receiving waters.
The significant materials or activities within the drainage area include the railcar chemical unloading of
polyols, TDI, polymeric diphenylmethane (MDI), and the truck unloading of miscellaneous chemicals
including resins, solvents and glue. Other significant materials within the drainage area include truck
fueling activities, shipping and receiving activities associated with intermediate and final products, solid
waste disposal, and the temporary storage of tractor trailers.
3.3.4 Other Areas
There are several other areas at the facility where surface water does not contribute to the discharge at
OF-1 and are referred to as depressional storage areas. There are no significant materials or activities
within the depressional storage areas.
3.4 List of Significant Spills or Leaks
The General Permit requires a description of significant spills or leaks of toxic or hazardous pollutants that
have occurred at areas that are exposed to storm water or that otherwise drain to a storm water
conveyance at the facility after the date of three years prior to the effective date of the General Permit.
"Significant spills or leaks" are defined by the regulations as a release to the environment within a 24-hour
period of a hazardous substance or oil in an amount equal to or in excess of a reportable quantity listed in
40 CFR Part 117 and 40 CFR Part 302.
No spills or leaks of toxic or hazardous pollutants have occurred since the date of three years prior to the
effective date of the General Permit within the OF-1 drainage area.
Table 3-2 is provided for the recording of significant spills or leaks which may occur in the future.
3.5 Non-Storm Water Discharges
3.5.1 General
The General Permit prohibits unauthorized non-storm water discharges to the storm drainage system
unless specifically covered by a NPDES permit. Furthermore, the General Permit requires that the facility
operator certify that all storm water outfalls have been evaluated for the presence of non-storm
discharges. The certification shall include the identification of potential significant sources of non-storm
water at the facility, a description of the results of any test and/or evaluation for the presence of non-storm
discharges, the evaluation criteria or testing method used, the date of any testing and/or evaluation, and
the on-site drainage points that were directly observed during the test.
Carpenter Co.SWPPP Version:D-11-2023 Page 10

SITE OVERVIEW
As per the General Permit and the Federal Storm Water Regulations, unauthorized non-storm water
discharges must be eliminated, or covered by a different NPDES permit.
The General Permit considers the following to be unauthorized non-storm water discharges:
■ Floor drains, sinks, and other waste discharges to the ground surface;
■ Boiler blow down or cooling water;
■ Vehicle and equipment wash water;
■ Steam cleaning wastes; and
■ Process water.
The General Permit considers the following non-storm water discharges to be generally authorized:
■ Discharges from fire-fighting activities;
■ Flushing of fire hydrants;
■ Potable water sources;
■ Irrigation drainage;
■ Lawn watering;
■ Uncontaminated groundwater;
■ Uncontaminated foundation or footing drains;
■ Discharges from springs;
■ Routine exterior building wash-down without detergents;
■ Pavement wash waters where spills or leaks of toxic or hazardous materials have not occurred and
where detergents are not used and
■ Air conditioning condensate.
3.5.2 Certification
The following page provides the necessary certification of elimination of non-storm water discharges in
accordance with the General Permit. This will be re-certified on an annual basis and a copy will be
retained at the site.
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SITE OVERVIEW
CERTIFICATION OF ELIMINATION OF NON-STORM WATER DISCHARGES
I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to ensure 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.
The undersigned, or persons who manage the system, has visually inspected the CARPENTER CO.
facility located at 1515 Carter Street, Mount Airy, North Carolina, and certifies that no unauthorized non-
storm water discharges are present at the facility.
North Carolina Foam Industries, Inc.
(Printed Name)
(Signature)
President
(Title)
(Date)
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SITE OVERVIEW
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Drawn by CHS Scale:As Shown Project No 0474506
Coordinate System:NAD83 UTM 17N Checked by:KME Date:29 NOV 2018
Carpenter Co.SWPPP Version:D-11-2023 Page 13

SITE OVERVIEW
Figure 3-2 Site Map
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Carpenter Co.SWPPP Version:D-11-2023 Page 14

SITE OVERVIEW
Table 3-1 Inventory of Potential Pollutant Sources
CARPENTER CO. Polyurethanes
Exposed Industrial Exposed Material Existing Practices to Potential Storm
Activity or Area Minimize Contact Water Pollutants
with Storm Water
Railcar Chemical Spills or leaks from Facility Standard Organic chemicals,
Unloading chemical transfer Operating Procedures chemical oxygen
procedures, solvents, (SOP). Chemical bulk demand, suspended
polyol, TDI, MDI storage is located with particulates.
secondary
containment area.
Trach Scrap foam and Covered trach Flexible polyurethane
Compactor/Dumpster miscellaneous trash compactor and foam and total
dumpsters suspended
particulates
Temporary Storage of Tractor Trailers None Oil and grease and
Tractor trailers components of diesel
fuel
Diesel Fueling Activities Diesel Fuels Automatic shut-off Components of diesel
valve on pump hose, fuel
area is covered.
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SITE OVERVIEW
Table 3-2 Significant Spills or Leaks
Facility: _CARPENTER CO. Polyurethanes Person Completing Form: Date:
Date Location Material Released Approximate Quantity Action Taken in
Released Response to Spill
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STORM WATER MANAGEMENT STRATEGY
4. STORM WATER MANAGEMENT STRATEGY
The Storm Water Management Strategy contains a narrative description of the materials management
practices employed which control or minimize the exposure of significant materials to storm water,
including structural and non-structural control measures. A technical and economic evaluation of
changing facility practices is initially presented followed by a description of appropriate storm water
management control measures, also referred to as best management practices (BMPs).
4.1 Feasibility Study
A discussion of the technical and economic feasibility of changing methods of operations and/or storage
practices to eliminate or reduce exposure of the potential pollutant sources identified in Section 3.0 is
provided.
4.1.1 Railcar Chemical Unloading Area
The railcar chemical unloading area is partially covered, and it may be feasible to construct a roof over
the entire area. However, based on economics and the fact that area is within secondary containment,
constructing a roof over the entire area is not considered practical. The secondary containment in the
railcar chemical unloading area provides secondary containment for the volume of one railcar. The focus
will be on other practices including preventive maintenance and spill prevention, response and cleanup
measures to prevent spills during railcar chemical unloading activities.
4.1.2 Truck Chemical Unloading Area
The truck chemical unloading/loading bays are covered and have rubber door skirts that allow the trailer
end of the truck to back up flush with the building. Chemical drums and totes are stored indoors where
the building provides secondary containment. No other changes in methods of operations are necessary.
The facility will implement a good housekeeping program for this area.
4.1.3 Diesel Fueling
There is no specific source area that is associated with diesel fueling, other than spills of diesel fuel. The
fueling station is covered with a roof structure which may not, however, provide adequate cover for the
area during heavy storm events. Therefore, the facility maintains adequate spill clean-up materials and
trains staff on spill prevention, response and cleanup measures at the diesel fueling area.
4.1.4 Product Shipping/Receiving Activities
The shipping/receiving activities associated with intermediate and final products that occur at the truck
bays that are covered and have rubber door skirts that allow the trailer end of the truck to back up flush
with the building. No other changes in methods of operations are necessary, with the exception of
implementing a good housekeeping program for these areas.
4.1.5 Solid Waste Disposal
Most of the solid waste generated at the facility is placed in a trash compactor south of Building A that
empties into a dumpster which is regularly emptied by a licensed waste hauler for transport and disposal
to an approved landfill. Though the dumpster is enclosed, the trash compactor is uncovered.
Housekeeping is required to run the trash compactor with every load of waste inserted into the trash
compactor to ensure storm water is not exposed to the trash. Additionally, the facility will consider the
technical and economic feasibility of covering the compactor.
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STORM WATER MANAGEMENT STRATEGY
A small open dumpster was utilized on the north side of the facility. The facility will consider the technical
and economic feasibility of covering the dumpster or replacing it with an enclosed dumpster. An obsolete
air compressor was stored at the Building E parking lot. Personnel will confirm oils were drained and
ensure obsolete equipment containing chemicals or oils are drained, tagged and disposed of, as feasible.
4.1.6 Temporary Storage of Tractor Trailers
Tractor trailers are temporarily stored on-site on both paved and unpaved areas until ready to be used for
deliveries. It is not considered to be economically or practically feasible to construct a building structure to
cover the on-site storage of tractor trailers. However, implementing spill prevention methods within the
storage areas will reduce the potential for pollutants (i.e., diesel fuel, oil, antifreeze, or grease)from
entering storm water runoff.
4.2 Secondary Containment
In accordance with the General Permit, a schedule to provide secondary containment for bulk storage of
liquid materials, storage of Section 313 of Title III of the Superfund Amendments and Reauthorization Act
(SARA)water priority chemicals, or hazardous materials to prevent leaks and spills from contaminating
storm water runoff is required.
The CARPENTER CO. facility considers that all above-ground storage tanks located outdoors are
provided with secondary containment by the use of culvert drain plugs and a sliding culvert gate which is
located at the facility's storm water outfall location (OF-1). The containment devices are maintained in an
open position to allow for the normal discharge of storm water from the facility property. In the event of a
large spill, the facility has specific spill containment procedures for using the culvert drain plugs and
sliding culvert gate to prevent the spill from entering surface waters of the state. The CARPENTER CO.
facility has erected dikes as additional secondary containment for outdoor above ground bulk storage
tanks.
4.3 BMP Summary
Appropriate storm water management controls, or best management practices (BMPs)to be implemented
by the CARPENTER CO. facility are described herein. As described in Section 4.1, certain practices are
considered technically and economically feasible to eliminate or reduce exposure of the potential pollutant
sources identified in Section 3.0. The following BMPs are recommended changes in methods of
operations and/or storage practices:
■ If trucks are temporarily stored outdoors without connections to trailers, the "fifth wheel" of the trucks
shall be covered where practical with plastic or a tarpaulin and secured appropriately to prevent
exposure of oil and grease to storm water; and
■ Chemical transfer hoses and hydraulic oil hoses for the squeezer trailer shall be drained of all
products prior to completing unloading procedures to prevent contact with storm water.
■ For the dikes that provide secondary containment, the facility shall keep the secondary containment
valves closed and locked. Any storm water that accumulates in the containment area shall be at a
minimum visually observed for color, foam, outfall staining, visible sheens and dry weather flow, prior
to release of the accumulated storm water. Accumulated storm water shall be released if found to be
uncontaminated. CARPENTER CO. will keep records documenting the individual making the
observation, the description of the accumulated storm water, and the date and time of the release for
a period of five (5) years.
1 The fifth-wheel coupling provides the link between a semi-trailer and the towing truck.
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STORM WATER MANAGEMENT STRATEGY
BMPs related to spill prevention, spill response, preventive maintenance, good housekeeping and
employee training are presented in Sections 5.0, 6.0, and 7.0 of this SWPPP.
4.4 Soil Erosion and Sediment Control
Storm water outfalls and conveyance systems at the CARPENTER CO. facility should be inspected for
erosion at a minimum of twice-per-year in conjunction with the Visual Inspections (Section 8.0) or
following heavy storm events. In particular, areas to inspect should include areas downstream of pipe
outlets, areas of high truck activity that are not paved, and other un-vegetated areas around the facility.
The following measures will be implemented by CARPENTER CO. to prevent soil erosion and control
sediment movement:
■ Provide erosion protection at pipe outlets: Localized areas of high-water velocity such as at pipe
outlets or steep sections of ditches are subject to erosion. These areas should be protected from
erosion resistant material such as gravel, stone, asphalt or concrete. Erosion protection should be
used where there is erosion at a downspout from a roof. Areas of high-water velocity should be
periodically inspected for signs or erosion or scouring.
■ Maintain gravel covering on access roadways: Gravel access roadways that are used primarily by
trucks are susceptible to wear and erosion. Gravel shall be maintained on all gravel access roadways
that are used by trucks. The gravel access roadways are periodically inspected by facility
maintenance staff for signs of erosion and bare ground.
■ South of Building A and adjacent to the main dumpster, a sawdust pile is maintained for spill cleanup.
The facility is considering the technical and economic feasibility of eliminating possible migration of
sawdust to storm water.
Page 19

SPILL PREVENTION AND RESPONSE PROCEDURES
5. SPILL PREVENTION AND RESPONSE PROCEDURES
The Spill Prevention and Response Procedures incorporates a risk assessment of potential pollutant
sources based on the materials inventory of the facility. Establishing standard operating procedures such
as safety and spill prevention procedures, along with employee training can reduce accidental releases.
Avoiding spills and leaks is preferable to cleaning spills or leaks from both an environmental and
economic standpoint, because spills and leaks can cause increased operating costs and lower
productivity.
5.1 Potential Spill Areas
The areas where spills or leaks are likely to occur at the CARPENTER CO. , based on the type and
volume of materials handled and stored, include the following two areas:
• Railcar chemical unloading area.
• Diesel fueling area.
5.1.1 Railcar Chemical Unloading Area
There is the potential for spills at the railcar chemical unloading area during (and after) unloading
activities. Significant materials unloaded in this area include TDI, polyols, and MDI. Due to the potential
for a spill to occur in this area, the following unloading (handling) procedures are followed by
CARPENTER CO. employees responsible for the delivery during railcar chemical unloading operations:
• Inspect bill of lading to insure contents are as ordered;
• Inspect tank into which contents are to be transferred to ensure adequate volume is available to
transfer the entire load;
• Block wheels of railcar;
• Visually inspect all hoses, fittings and gaskets before making connections;
• Trace piping to insure proper valves are open or closed, as appropriate;
• Place drip pan under hose connection at the railcar and tank the material is being pumped to;
• Maintain inspection of connections during transfer;
• After contents are transferred, allow air pressure to completely empty all hoses and piping into
receiving tanks; and
• After all contents are transferred, confirm the volume transferred coincides with the volume delivered.
In the event of a spill or leak during railcar chemical unloading, the following safety and response
procedures shall be implemented:
• Evacuate the immediate area, if required.
• Prevent further escape of the chemical as outlined in Section 4.2.
Additional safety and response BMPs that are appropriate for the CARPENTER CO. facility, include the
following:
• Conduct Refresher Courses in Operating and Safety Procedures: Personnel that work in the
chemical unloading areas are required to have training and refresher courses in operating and safety
procedures. This helps to reduce spills and accidents caused by negligence, which may result in
storm water contamination. Training and refresher courses are provided periodically, as needed.
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SPILL PREVENTION AND RESPONSE PROCEDURES
■ Contain Leaks: Visible leaks from hoses or valves during chemical transfers shall be immediately
contained (i.e., drip pan).
■ Control Spills: To reduce the potential for spills, safety data sheets (SDSs)are followed for handling,
storage, and cleanup of minor spills. Any spill, small or large, shall be controlled immediately to
prevent pollutants from being transported to storm water outfalls. Appropriate spill control materials
are kept on site. Smaller spills shall be contained using absorbent materials such as saw dust.
Instructional signs are posted to describe where spill control materials are maintained. Spent
absorbent materials (saw dust) shall be managed appropriately and disposed of in accordance with
applicable regulations.
■ Larger spills shall be controlled only by designated facility personnel and cleanup arrangements shall
be made with a licensed clean-up contractor to immediately supply appropriate equipment.
5.1.2 Diesel Fueling Area
The pump at the diesel fueling area has an automatic shutoff valve which reduces the potential for a large
spill. In the event of a spill or leak during diesel fueling activities, the following safety and response
procedure shall be implemented:
■ Personnel shall immediately clean up a spill or leak using the absorbent material supplied at the
diesel fuel pump. The spent absorbent shall be cleaned up immediately following spill response
procedures and disposed of properly.
An additional safety and response BMP that is considered appropriate for the CARPENTER CO. facility,
includes the following:
■ A sign is posted at the fueling pump area instructing personnel not to overfill tanks, to use the
supplied absorbent materials to clean up spills, and to report spills. The sign includes a telephone
number and contact person that is to be notified in the event of a spill.
5.2 Spill Response Team and Reporting Procedures
All affected employees are informed of proper cleanup procedures and their responsibilities. Spill
response procedures are prominently posted at appropriate locations throughout the facility. The facility's
existing spill response procedures are presented below:
"Small Spills &Leaks:For small spills and leaks a decontaminate material is
available for TD1 and is stored in the Pour Line Department. Absorption material
(saw dust) is stored in a pile[outside]near the boiler building behind the main
plant and is available for all other liquid[spills]. It is to be used and disposed in
the prescribed manner of the material absorbed. Report all spills and leaks to
your supervisor immediately."
Large Spills:For large spills all workers in the affected area are to notify their
supervisor immediately and leave the area until further directed to return. Any
large spill is to be diked and spill containment for culvert drain plug and gate is
to be implemented. See SPILL CONTAINMENT PROCEDURES FOR
CULVERT DRAIN PLUG AND GATE. There may be other measures specific to
the raw material which is spilled. Refer to supervision and other sections of[the]
manual for material specific information for large spills."
All significant spills and leaks should be reported to the Storm Water Pollution Prevention Coordinator, or
designated alternate. Depending on the type and amount of material spilled, state and/or federal agencies
may also need to be notified.
Page 21

PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING
PROGRAM
6. PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING PROGRAM
Storm water pollution prevention is required by the General Permit to be incorporated into the
preventative maintenance and good housekeeping program.
6.1 Preventative Maintenance
The focus of the preventative maintenance program at the CARPENTER CO. facility is to expand the
existing program to provide more emphasis of storm water pollution prevention within the permitted
drainage area.
6.1.1 Facility Preventative Maintenance Inspections
Preventative maintenance involves the regular inspection and testing of plant equipment and operational
systems. These inspections should uncover conditions, such as cracks or slow leaks which could cause
breakdowns or failures that result in discharges of chemicals to surface waters. Employees look or are
aware of areas showing signs of corrosion, support or foundation failure, spots or puddles of chemicals,
smoke, fumes, or other signs of leaks.
Qualified personnel inspect the designated equipment and plant areas for problems and the potential for
storm water pollution on a semi-annual basis. The following is a partial list of equipment to be inspected
and/or tested:
■ outdoor piping that contains chemical products, e.g., hydraulic oil lines for trash compactor;
■ valves (on tanker trucks, and on transfer hoses); and
■ secondary containment devices.
6.1.2 Records on Preventive Maintenance
An inspection form has been developed by CARPENTER CO. . The form shall be filled out each time an
inspection is conducted. The form documents the following information:
■ Date of inspection.
■ Name of inspector.
■ Equipment or areas inspected.
■ Potential problems (i.e., leaks, debris build up, and other signs of potential pollution).
■ Corrective actions necessary.
■ Was corrective action implemented?
Defective equipment found during employee inspections and testing should be promptly repaired or
replaced. Spare parts for equipment that needs frequent repair are kept on-site.
All inspection forms are retained with this SWPPP for five years.
6.2 Good Housekeeping Program
Good housekeeping practices are intended to maintain areas in a clean and orderly manner. These
practices are generally low cost, easy to implement, and can be quite effective.
Appropriate good housekeeping BMPs for the CARPENTER CO. facility are specified below:
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PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING
PROGRAM
■ Maintain clean, paved areas by using brooms, shovels, or contracted sweeping machines.
■ Collect and properly dispose floor scrubber water to sanitary discharge or waste hauler, depending
on hazardous material testing and regulatory review.
■ Regularly pickup and dispose of garbage and other debris collected around the facility.
■ Routinely inspect for contact of storm water with raw materials, waste materials, or final products.
■ Label all containers to show the name of the substance, stock number, expiration date, health
hazardous, suggestions for handling, and first aid information. This information is usually provided on
the SDS for each chemical material that is purchased. Unlabeled chemicals with deteriorated labels
may be improperly handled or disposed of.
■ Ensure that all outdoor storage areas of hazardous materials are designed to contain spills.
■ Incorporate information sessions on good housekeeping practices into the facility's existing employee
training program.
■ Discuss good housekeeping practices at employee meetings.
■ Publicize pollution prevention concepts around the facility through the use of posters.
■ Post bulletin boards with updated good housekeeping procedures, tips, and reminders.
The facility has developed an employee training program. At a minimum, the training is conducted on an
annual basis, addressing proper spill prevention, and preventative maintenance activities for all personnel
involved in any of the facility's operations that have the potential to contaminate storm water runoff. The
SWPPP information is also reviewed with all new and existing employees. The following subjects are
addressed in the training program:
■ Basic concepts of water pollution and pollution prevention.
■ Spill Prevention and Response Procedures
■ Preventive Maintenance
■ Good Housekeeping Practices
Employee training is essential to effectively implement the SWPPP. The purpose of the training program
is to educate personnel at all levels of responsibility the components and goals of this SWPPP. When
properly trained, personnel will be more capable of preventing spills, responding safely and effectively to
an accident, and recognizing situations that could contribute to storm water contamination.
The CARPENTER CO. Pollution Prevention Coordinator shall evaluate the effectiveness of the training
program and make improvements as necessary to promote employee awareness and accountability.
Page 23

INSPECTIONS,SAMPLING,AND RECORDKEEPING
7. INSPECTIONS, SAMPLING, AND RECORDKEEPING
7.1 Facility Inspections
The Pollution Prevention Team Coordinator(or designee)conducts visual inspections of the facility for
evidence of or the potential for pollutants entering the storm water conveyance system. The purpose of
the visual inspection is to confirm that potential pollutant sources (identified in Section 3.0)are properly
controlled.
Areas inspected, at a minimum, include:
■ The potential pollutant source areas identified in Section 3.0,
■ Areas where spills or leaks are likely to occur(or have in the past), and
■ Storm water outfalls for signs of erosion and buildup of debris
Inspections of the facility and all storm water conveyance systems occur at a minimum on a quarterly
quarterlyquarterlyschedule, with a minimum of 60 days separating inspections. The inspections and any
corrective actions performed are documented, recording data and time of inspection, individual(s) making
the inspection.
A blank facility inspection form is provided in Table 7-1. All facility inspection forms are be retained with
this SWPPP for a period of five years.
7.2 Storm Water Sampling
In terms of the requirements of the Permit, storm water discharges from any vehicle maintenance activity
occurring on-site, which uses more than 55-gallons of new motor/hydraulic oil per month when averaged
over the calendar year, shall be monitored by the facility. The CARPENTER CO. facility currently does
not use more than 55-gallons of new oil per month and would not be subject to the sampling requirements
for vehicle maintenance activities.
Qualitative monitoring is required for storm water outfalls associated with industrial activity (not just
vehicle maintenance activities). Qualitative storm water monitoring for color, foam, outfall staining, visible
sheens, etc. shall be performed at OF-1 during a measurable storm event, as described in Table 7-2.
Qualitative monitoring is performed quarterly, unless the DEMLR requires more frequent monitoring. If
CARPENTER CO. repeatedly fails to respond effectively to correct problems identified by qualitative
monitoring, or a discharge causes or contributes to a water quality standard violation, CARPENTER CO.
may be required by the DEMLR to revise monitoring, install controls, or implement measures. Unless
adverse weather conditions prevent sample collection, a minimum of 60 days must separate the
quarterlymonitoring, unless the CARPENTER CO. has instituted monthly sampling.
Adverse weather conditions are those that are dangerous or create inaccessibility for personnel, such as
local flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period, the
permittee must take a substitute sample or perform a visual assessment during the next qualifying storm
event. Documentation of an adverse event(with date, time and written narrative) and the rationale must
be included with the SPPP records. Adverse weather does not exempt the CARPENTER CO. from
having to file a monitoring report in accordance with the sampling schedule.
For each sampled measurable storm event the total precipitation must be recorded. An on-site rain gauge
is required. A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours prior. The
72-hour storm interval does not apply if the facility is able to document that a shorter interval is
Page 24

INSPECTIONS,SAMPLING,AND RECORDKEEPING
representative for local storm events during the sampling period, and the permittee obtains approval from
the local DEMLR Regional Office.
A blank qualitative visual inspection form is provided in Table 7-2. In the event an atypical condition is
noted at the storm water outfall, the facility shall document the suspected cause of the condition and
corrective actions taken. All qualitative visual inspection forms shall be retained with this SWPPP for a
period of five years.
7.3 Recordkeeping
Implementation of this plan shall include documentation of all inspections and maintenance activities, and
training provided to employees, including records of on-site vehicle maintenance activities. Such
documentation shall be retained on-site for a period of five (5)years and made available to the Director of
the Division of Environmental Management or his/her authorized representative upon request.
Page 25

INSPECTIONS,SAMPLING,AND RECORDKEEPING
Table 7-1 Facility Inspection
Facility: CARPENTER CO. Polyurethanes Person Completing Form: Date:
Location Potential Qualitative Description of Action Description of Action Date
Pollutant Runoff Needed Action
_ Source (Yes/No)? Taken
1. Pourline Day Use
Pit 1 —Day tanks and mix tanks
2. Pourline Day Use
Pit 2— Day tanks
3. Polyol Tank Farm
4. Iso and Poly tank farm
5. TDI containment ZE
underground
6. Unloading ramp
7. #2 Fuel Oil
8. Diesel pump house
9. Old tank farm
10. Culvert 1
11. Culvert 2
12. Culvert 3
13. Slide gate
14. New tank farm containment
15. New tank farm containment
Ipit
16. Gate 1
Page 26

INSPECTIONS,SAMPLING,AND RECORDKEEPING
Location Potential Qualitative Description of Action Description of Action Date
Pollutant Runoff Needed Action
Source (Yes/No)? Taken
17. Gate 2
18. Rigid containment area
19. Containment pit at blend
tanks
20. Pentane containment
21. Pentane on hill
22.
23.
24.
25.
26.
Page 27

INSPECTIONS,SAMPLING,AND RECORDKEEPING
Table 7-2 Qualitative Visual Inspection
Environmental
Quality
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form,please visit
https://deq.nc.gov/about/divisions/energy-mineral-land-resources/npdes-stormwater-gps
Permit No.: N/C// / / / / / / or Certificate of Coverage No.: N/C/G/ / / / / / /
Facility Name:
County: Phone No.
Inspector:
Date of Inspection:
Time of Inspection:
Total Event Precipitation (inches):
All permits require qualitative monitoring to be performed during a"measurable storm event."
A"measurable storm event"is a storm event that results in an actual discharge from the permitted site
outfall. The previous measurable storm event must have been at least 72 hours prior. The 72-hour storm
interval does not apply if the permittee is able to document that a shorter interval is representative for
local storm events during the sampling period,and the permittee obtains approval from the local DEMLR
Regional Office.
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permittee or Designee)
1. Outfall Description:
Outfall No. Structure (pipe, ditch, etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
Page 28

INSPECTIONS,SAMPLING,AND RECORDKEEPING
2. Color: Describe the color of the discharge using basic colors(red,brown,blue, etc.) and tint
(light,medium, dark) as descriptors:
3. Odor: Describe any distinct odors that the discharge may have(i.e., smells strongly of oil,
weak chlorine odor,etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge,where 1 is
clear and 5 is very cloudy:
1 2 3 4 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge,where 1 is no solids and 5 is the surface covered with floating solids:
1 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids
in the stormwater discharge,where 1 is no solids and 5 is extremely muddy:
1 2 3 4 5
7. Is there any foam in the stormwater discharge? OYes C. No.
8. Is there an oil sheen in the stormwater discharge?0 Yes ® No.
9. Is there evidence of erosion or deposition at the outfall? 0 Yes 0 No.
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/
deposition may be indicative of pollutant exposure. These conditions warrant further
investigation.
Page 29

EMPLOYEE TRAINING
8. EMPLOYEE TRAINING
8.1 Spill Prevention and Response
Spill prevention and response procedures are described in detail under Section 5.0 of this SWPPP. The
training procedures directed towards spill prevention and response are to ensure that facility personnel
are aware of necessary actions in the event of a spill. Specifically, employees involved in industrial
activities at the CARPENTER CO. facility are trained in the following measures:
• Potential spill areas and drainage routes (where a spill would discharge from the facility), including
information on past spills (if applicable).
• Proper notification in the event of a spill.
• Specific handling procedures and storage practices (particularly in outdoor areas).
• Implementation of spill response procedures.
Outside contractors or vendors operating at the facility are informed of the plant operations and design
features to help prevent accidental discharges or spills from occurring at the facility.
Facility personnel are educated on how to handle and store materials in a safe manner to avoid the
potential for spills and accidentally contaminate storm water runoff. The following material management
practice training items shall be discussed in employee training sessions:
• Hazardous materials present at the facility (i.e., TDI), and the proper methods of handling and
storage.
• Storage of certain materials at the facility to minimize exposure to storm water.
8.2 Preventative Maintenance
Facility personnel are educated on conducting inspections and testing of plant equipment to identify
conditions that may result in breakdowns or failures which would contribute to releases of pollutants to
storm water discharges. Section 6.1 specifically addresses the procedures to be implemented in the
facility Preventive Maintenance Program. The following preventive maintenance training items shall be
discussed in employee training sessions:
• The importance of promptly repairing or replacing defective equipment found during inspections and
testing.
• Areas and equipment which shall be inspected.
• The frequency of inspections.
• Information to be included on the inspection form.
8.3 Good Housekeeping
Facility personnel shall be educated on how to maintain a clean and orderly facility environment. Section
6.2 specifically addresses the procedures to be implemented in the facility Good Housekeeping Program.
The following good housekeeping training items shall be discussed in employee training sessions:
• The importance of regular cleaning of outdoor areas that appear to accumulate trash and debris on a
regular basis (i.e., near the trash compactor/dumpster and loading/unloading docks).
Page 30

EMPLOYEE TRAINING
■ Ensuring the trash compactor is run every time trash is inserted such that the trash is deposited into
the closed top dumpster.
■ The location of good housekeeping equipment(i.e., brooms, shovels, vacuums, etc.).
■ The effectiveness of a good housekeeping program.
8.4 Training Frequency
The Storm Water Pollution Prevention Coordinator at CARPENTER CO. determines a schedule for
periodic training activities that will occur at a minimum of once per year. The Permit requires that the
effectiveness of the SWPPP and training efforts are to be regularly evaluated and documented. In most
cases, communicating with employees and conducting regular inspections will provide the necessary
procedures for measuring the effectiveness of the overall program. The site maintains a training log to
document SWPPP training.
Page 31

RESPONSIBLE PARTY
9. RESPONSIBLE PARTY
In accordance with the requirements of the Permit, Table 9-1 identifies CARPENTER CO. personnel who
constitute the Pollution Prevention Team that are responsible for developing, implementing, maintaining
and revising the SWPPP:
• Environmental Specialist
• President/Plant Manager/Responsible Corporate Officer
The responsibilities of each team member are presented in Table 9-1 at the end of this section.
The Environmental Specialist responsibilities will include:
• Employee Training: preparing training documents and materials, scheduling, coordination, and
conducting training sessions.
• Site Inspections: conducting quarterly facility inspections, quarterly qualitative visual monitoring, and
preparing site inspection documentation.
• Comprehensive Site Compliance: The SWPPP annual reviews are documented with the Annual
Comprehensive Site Compliance Inspection as shown in Table 9-2. The annual inspection verifies:
- that the SWPPP remains current;
- potential pollutions sources at the facility are identified;
- the facility site map and drainage map remain accurate; and
- BMPs prescribed by the SWPPP are being implemented, properly operated and adequately
maintained.
The inspections start with a review of the written SWPPP. The SWPPP is amended (see Section 10)
if through the inspection it is found that SWPPP is ineffective in controlling contaminated storm water
from being discharged from the facility.
• Recordkeeping: maintaining records associated with the SWPPP including inspection reports, a
current site map, maintenance records, spill reports and monitoring records.
Page 32

RESPONSIBLE PARTY
Table 9-1 Pollution Prevention Team Responsibility
Responsibility
Routine Revise
Title Team Signatory Record Employee Submit Implement Comprehensive
Visual Review
Coordinator Authority Keeping Training Reports BMPs Inspection Site Evaluation SWPPP
Environmental
S ecialist
rest en -\l
Page 33

RESPONSIBLE PARTY
Table 9-2 Annual Comprehensive SWPPP Evaluation
Facility CARPENTER CO. Polyurethanes Inspection Date: Inspector's Name:
Review Yes/No/NA
Has the SWPPP been updated to include the current non-storm water discharge
evaluation results?
Has your SWPPP been amended for any new construction that would affect the site
map or drainage conditions at the site?
Has your SWPPP been amended for any changes in facility operations that could
be identified as new source areas for contamination of storm water?
Are there any materials at the facility that are handled, stored or disposed in a
manner to allow exposure to storm water that are not currently addressed in you
SWPPP?
Are there any maintenance or material handling activities conducted outdoors that
have not been addressed in you SWPPP?
Are outside areas kept in a neat and orderly condition?
Are regular housekeeping inspections made at the facility?
Do you see spots, polls, puddles, or other traces of oils, grease, or other chemicals
on the ground?
Are particulates on the ground from industrial operations or processes being
controlled?
Do you see leaking equipment, pipes or containers?
Do drips, spills, or leaks occur when materials are being transferred from one
source to another?
Are drips or leaks from equipment or machinery being controlled?
Are clean-up procedures used for spilled solids?
Are absorbent materials (floor dry, kitty litter, etc.) regularly used in certain areas to
absorb spills?
Can you find discoloration, residue or corrosion on the roof or around vents or
persist that ventilate or drain work areas?
Are BMPs implemented to reduce or eliminate contamination of storm water from
source areas at the facility?
Are there significant changes to the SWPPP needed to correct plan inadequacies to
effectively control a discharge of contaminated storm water from your facility? 01
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SWPPP AMENDMENT AND ANNUAL UPDATE
10. SWPPP AMENDMENT AND ANNUAL UPDATE
CARPENTER CO. will amend the SWPPP whenever there is a change in design, construction,
operation, site drainage, maintenance, or configuration of the physical features which may have a
significant effect on the potential for the discharge of pollutants to surface waters. All aspects of the
SWPPP will be reviewed and updated on an annual basis. The annual update will include:
■ an updated list of significant spills or leaks of pollutants for the previous three (3)years, or the
notation that no spills have occurred (element of the Site Overview),
■ a written recertification that the storm water outfalls have been evaluated for the presence of non-
storm water discharges (see Section 3.3),
■ a documented re-evaluation of the effectiveness of the on-site storm water BMPs (BMP Summary
element of the Storm Water Management Strategy), and
■ a review of qualitative visual monitoring data over the past year, including a discussion about Tiered
Response status.
If the DEMLR notifies CARPENTER CO. that the SWPPP does not meet one or more of the minimum
requirements of the permit. Within 30 days of such notice, CARPENTER CO. will submit a time schedule
to the DEMLR for modifying the SWPPP to meet minimum requirements. CARPENTER CO. will provide
certification in writing to the DEMLR that the changes have been made.
The SWPPP will be amended whenever there is a change in design, construction, operation, or
maintenance that has a significant effect on the potential for the discharge of pollutants, or if the SWPPP
proves ineffective in achieving the general objective of controlling storm water discharges. The SWPPP
will also be amended if the USEPA or state agency reviews the SWPPP and finds itdeficient. Table 10-1
provides the amendment documentation.
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SWPPP AMENDMENT AND ANNUAL UPDATE
Table 10-1 SWPPP Amendments
Date Updated by Page(s) Reason(s)for Amendment(s)
Affected
Dec. 2018 - ERM, Katie Bowman ALL Overhaul of SWPPP, compliance with new permit.
Draft
Feb. 2019 - ERM, Katie Bowman ALL Overhaul of SWPPP, compliance with new permit.
Final
July 2023 Danny Lineberry All Annual review with date change
October 2023 Danny Lineberry Cover and All Removed ERM identification content, Permit dates updated, added
quarterly inspections due to new DEQ Storm Water Monitoring and
Reporting and sampling requirements
-U
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SWPPP IMPLEMENTATION
11. SWPPP IMPLEMENTATION
CARPENTER CO. has implemented the SWPPP and the appropriate BMPs to prevent contaminants
from entering surface waters via storm water. Implementation of the SWPPP includes documentation of
the monitoring, measurements, inspections, maintenance activities, and training provided to employees,
including the log of the sampling data and of actions taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities. Such documentation is kept on-site for a
period of five (5)years and made available to the DEMLR inspector or representative immediately upon
request.
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SWPPP IMPLEMENTATION
APPENDIX A LIST OF FACILITY STORAGE TANKS

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