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HomeMy WebLinkAboutNCS000591_Permit Application_20160223Performance F.I it September 26, 2013 Mr. Charles Weaver NC DENR / DWQ / Point Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 RECEIVEDINCDEWWR Subject: Performance Fibers Operations, Inc. FEB 2 3 2016 Salisbury Permit Renewal NPDES Permit # NC0004944 Water Quality Rowan County Permitting Section Performance Fibers Operations, Inc. owns and operates a polyester manufacturing facility in Salisbury, North Carolina. Process wastewater and stormwater is discharged to North Second Creek in accordance with National Pollutant Discharge Elimination System (NPDES) Permit Number NC0004944, which expires March 31, 2014. Three copies of this letter and the attached permit application are being submitted for renewal of the NPDES Permit. This letter provides an overview of the Performance Fibers Operations, Inc. Salisbury facility, and Attachment A includes the permit renewal application. I. Facility Location The Performance Fibers Operations, Inc. facility is located on the south side of U.S. Highway 70 approximately 4 miles west of Salisbury, North Carolina, near the intersection of Highway 70 and State Highway 801. The facility's location is presented on Figure 1 in Attachment A, which also shows nearby transportation routes and surface waters. II. Plant Overview Performance Fibers Operations, Inc. manufactures polyester in the form of chip and fiber at its Salisbury, North Carolina, facility. Primary raw materials in these manufacturing processes include terephthalic acid, ethylene glycol, and fiber finish lubricants (see Figure 2 in Attachment A). Process wastewater, groundwater, sanitary wastewater, cooling tower blowdown, and water treatment plant blowdown are treated onsite before being discharged to North Second Creek. 7401 STATESVILLE BLVD I SALISBURY, NC 28147 1 TEL 704-636-6000 www.performancefibers.com Performance :'-'; � , Wastewater treatment consists of coarse solids removal (bar screen), equalization, biological treatment (activated sludge), and clarification, followed by a series of polishing ponds, as presented on Figure 3 in Attachment A. Waste biological sludge is aerobically digested and dewatered. Dewatered solids are disposed of off-site by Waste Management, Inc, at the local Rowan County Landfill. The ground water remediation program at the site has been shutdown during a trial period with EPA approval. Future operation of the pump -and -treat remediation is unlikely but the final decision as to whether or not to operate the pump -and -treat system has not been made. When this remediation system is operating the water is treated in the waste treatment plant. Recovered groundwater from the interior system contains primarily ethylene glycol and is anaerobically pretreated before being discharged to the equalization tank for treatment in the W WTP. Recovered groundwater from the perimeter system contains 1,4 -dioxane as the major pollutant and is discharged through the polishing ponds to Outfall 001 to North Second Creek. The plant discharges storm water associated with industrial activity through five stormwater outfalls (A,B,C,D and 5) as presented on Figure 1 in Attachment A. Stormwater Outfall #5 collects stormwater from the main manufacturing areas of the site, where spills are more likely or chemicals are stored. Outfall #5 collects stormwater from a system of diverter weirs that route dry weather spills and the first flush of storm water runoff to either the W WTP headworks or Number 2 Polishing Pond. As the storm water volume increases in the diverter system, flow continues to be discharged to either the W WTP or Number 2 polishing pond with the excess water that overflows the diverter weirs being discharged directly to North Second Creek. All five storm water outfalls are monitored according to the NPDES permit and the Stormwater Pollution Prevention Plan. Information on the storm water outfalls is provided on the EPA Form 2F. III. Historical Data Review Outfall 001 Historical daily data from the Discharge Monitoring Reports (DMRs) were reviewed for the past four and half years (January 1, 2009 through June 30, 2013). Annual DMR data for the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) priority pollutants for the past 5 years (2009 through 2013) were reviewed. The review indicated that no OCPSF chemicals were detected and the daily discharge limits were well within permit limits. 7401 STATESVILLE BLVD I SALISBURY, NC 28147 1 TEL 704-636-6000 www. p erformancefibers. eom Performance r*i�; Storm Water (Outfalls A, B, C, D, and 5) Over the course of the period of 2009 -2013, Performance Fibers has collected storm water samples both annually for analysis of conventional parameters and total toxic organics (TTO) and semi-annually for conventional parameters. For the TTO analysis, the only test result that was above detection limits was methylene chloride (75-09-2) in Outfall 5 in 2010. The result was 3.6 ug/1. Every other annual sample analyzed or Methylene Chloride was under the detection limit. We do not believe this result indicates the presence of this substance in the outfall 5. For the conventional parameters, a 2009 stormwater sample at outfall C was 576 mg/L, which exceeded our benchmark of 100 mg/L. The next sample in 2010 was back below benchmark at 39 mg/L. At outfall A, we had two consecutive samples for phosphorus that exceeded the benchmark of 2.0 mg/L (2.4 (2"d half of 2012) and 3.1 (15t half of 2013)). We instituted Tier H response for this exceedance and implemented monthly sampling as required by our permit until we obtained 3 consecutive samples results below benchmarks (0.55, 0.55 and '<0.05 mg/L). At outfall B, we had one sample for phosphorus that exceeded the benchmark of 2.0 mg/L (2.9 (It half of 2013)). At outfall C, we had one sample for phosphorus that exceeded the benchmark of 2.0 mg/L (2.5 (1' half of 2013)). We also had three consecutive samples for pH that was out of benchmark range (6-9 units) (1st and 2"d halves of 2012 and 1st half of 2013). We instituted Tier II response for this exceedance and implemented monthly sampling as required by our permit until we obtained 3 consecutive samples results within benchmarks (6.1, 6.1 & 6.4 units). At outfall D, we had two consecutive samples for phosphorus that exceeded the benchmark of 2.0 mg/L (2.6 (2"d half of 2012) and 2.5 (191 half of 2013)). We instituted a Tier II response for this exceedance and implemented monthly sampling as required by our permit until we obtained 3 consecutive samples results below benchmarks (0.5775, 0.78 and < 0.05 mg/L). At outfall 5, we had one sample for phosphorus that exceeded the benchmark of 2.0 mg/L (2.1 (1 st half of 2013)). Flow The average effluent (Outfall 001) flow has decreased from the 2008 permit renewal period. The decrease has been caused by a reduction in production levels. The average 7401 STATES M LLE BLVD SA LiSBURY, NC 28147 TBL 704-636-6000 www. performancefibers. com Performance, :e** V' i i1,: ,l daily effluent flow for the past 4.5 years is 0.392 MGD (million gallons per day) compared to a permit limit of 2.305 MGD. Chronic Toxicity The site is required to test the effluent (Outfall 00 1) for chronic toxicity 4 times per year using ceriodaphnia dubia as the test organism. The permit requires no observable inhibition of reproduction or significant mortality at an effluent concentration of 34 percent. There was one failure during the past 5 year cycle, in August 2009, followed by 17 consecutive passing tests. IV. pH Adjustment The effluent (Outfall 00 1) pH is adjusted during periods of high algae bloom in the polishing ponds using sulfuric acid. V. Copper Sulfate Addition Copper sulfate is added to polishing ponds # 3 and #4 to control algae growth during the warm summer months. This is shown on Figure 3. VI. Yadldn/Pee Dee River Basin Association The Salisbury site has been a member in good standing of the Yadkin Pee Dee River Basin Association for the past 15+ years. The Salisbury site has agreed to membership for the next 5 year NPDES cycle for the river basin. The DWQ memo verifying the site's membership and waving the in -stream sampling requirements is attached in Attachment B. VII. Sludge Management Plan Performance Fibers does not have a Sludge Management Plan. Waste biological sludge is aerobically digested and dewatered. Dewatered solids are disposed of off site by Waste Management in the local Rowan County Landfill. VIII. Stormwater Outfall Sampling The state has always allowed the site to collect Stormwater samples using grab sampling techniques instead of composite samplers. The outfalls are located remote from the 7401 STATESVILLE BLVD I SALISBURY, NC 26147 1 TEL 704-636-6000 www.performancefi'bers.com Performance Y' i ir,, manufacturing area where electrical power is not available. The Salisbury plant would like to continue sampling the stormwater outfalls using grab samples. IX. Additional Data The Salisbury site will collect additional wastewater samples for Priority Pollutant Analysis (PPA), to include with this application. When these additional samples have been analyzed, we will submit a revision to EPA FORM 2C (Effluent Data) in Attachment A. X. Contact If you have any questions or require additional information or additional analytical data, Please contact Marty Stewart at (704) 642-2197 or marts.stewartClperformancetibers com. Sincerely, Richard L. Moore K 6 20 1 O Plant Manager Enclosures: Attachment A — Permit Application Attachment B — DWQ Memo — Yadkin Pee Dee River Basin Association Attachment C — Analytical Data 7401 STATESVILLE BLVD I SALISBURY, NC 28147 TEL 704-636-6000 www.performancefi'bers.com Attachment A NPDES Permit Renewal Application EPA FORM 1 n 51 EPA FORM 3510.1 (8.90) 3 (' ✓ L / CONTINUED ON REVERSE CONTINUED FROM THE FRONT VII. SIC CODES 4 -di it in order of Dribritt A. FIRST S. SECOND 2821 (spadrY) 7 2824 (specify) PG Polyster Resin Polyester Fiber 16 18 17 18 16 19 C. THIRD D. FOURTH -7 (specify) 17 (specify)16 1a 17 15 18 18. VIII.OPERATOR INFORMATION A. NAME B. Is the name listed in Item e Performance Fibers Operations, Inc VIII -A also the owner? YES [—]NO is 1e 55 C. STATUS OF OPERATOR Enter the appropriate Ietterinto the answer box., If "Other"s D. PHONE. ares code & no. F = FEDERAL M- PUBLIC (other then federal orstate) P (specify) 0 704 838 8000 A 5 = STATE O = OTHER (specify) ie zr u 26 P= PRIVATE 66 15. 18 ie E. STREET OR PO BOX 7401 Statesville Blvd 28 55 F. CITY OR TOWN G. STATE H. zip CODE I IX. INDIAN LAND c Salisbury NC 28147 Is the facility located on Indian lands? B ❑ YES ® NO 18 1 16 40 42 42 47 51 X. EXISTING ENVIRONMENTAL PERMITS A. NPDES Dische es to Surface Wated D. PSD Air Emissions from Proposed Sources 1 NC 0004944 9 P ° 9 N 15 16 1 17 18 30 15 1 16 17 1 18 30 B. UIC (Underground ftechon of Fluids E. OTHER (specify) (Specify) Title V Air Permit 03325-R44 9 u 9 15 16 17 18 30 15 18 17 ie 30 C. RCRA Hazardous Wester E. OTHER s G (Specify) sR ' NCD 041043811 1° 91 - 17 18 30 16 18.. 17 18 30 j18 . MAP Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility, the location of each of its existing and proposed intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs, rivers and other surface water bodies in the map area. See instructions for precise requirements. XII. NATURE OF BUSINESS rovide a brief descri tion Manufacturer of polyester resin and polyester fiber using polymer produced from terephthalic acid and ethylene glycol. XIII. CERTIFICATION see instructions I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, based on my inquiry of those persons immediately responsible for obtaining the Information contained in the application, I believe that the information is true, accurate and complete. I am aware that there are significant penalties for submildrin false information including the ssibilit of fine and imprisonment. A. NAME & OFFICIAL TITLE (type orprint) B. SIGNATURE / C. DATE SIGNED Richard Moore, Plant Manager ry" i%� ,s.•.G — 2� Zo a COMMENTS FOR OFFICIAL USE ONLY 46 16 16 55 EPA FORM 3510-1(8.90) EPA ID Number (copy from Item 1 of Form 1) Please print or type in the unshaded areae only Form Approved. OMB No. 20460066 Approval expires 531-92 FormUnited 2F NPoes tea Ernironmenle Protection Agency SAM EPA wmit ton, Dc sc Application for Permit to Discharge Storm Water Dischar es Associated with Industrial Activity Paperwork Reduction Act Notice Public reporting burden for this application is estimated to average 28.6 hours per application, including time for reviewing Instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate, any other aspect of this collection of information, or suggestions for improving thisform, including sugggestions which may increase or reduce this burden to: ChiefInformation Policy BranchPM-223U.S., y , , Environmental ProtectionAQency, 401 M St. SW, Washington, DC 20460, or Director, Office of information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 1. Outfall Location For each outfall list the latitude and Ion nude of tis location to the nearest 1 seconds and the name of the recelvinn water. A. Ouffall Number D. Receiving Water ist B. Latitude C. Lo nude name 3> I i4 vJ,tkrDw U 3s 34. 1 W.tl- !7 ?) 36 3)- yIl. Il.Improvements A Are you now required by any Federal State, or local authority to most any implementation schedule for the construction, upgrading or operation of wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described In this application? This includes, but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions. 4. Find 1. Identification of Conditions, 2 Affected OutfallsCom Ilance Date Agreements, Etc. number source of discharge 3. Brief Description of Project a. b: ro'. B. You may attach additional sheets describing any additional water pollution (or other environmental projects which may affect your discharges) you now have under way or which you plan. Indicate whether each program Is now under way or planned, and indicate your actual or planned schedules for construction. IIL Site Dralnal3e Ma Attach a site map showing topography (or indicating the outline of drainage areas served by the outfall(s) covered in the applicetion if a topographic map is unavailable) depicting the facility Including: each of its intake and discharge structures; the drainage area of each storm water outfall; paved areas and buildings within the drainage area of each storm water outfall, each known past or present areas used for outdoor storage or disposal of significant materials, each existing structural control measure to reduce pollutants in storm water runoff, materials loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied; each of its hazardous waste treatment, storage or disposal units (including each area not required to have a RCRA permit which is used for accumulating hazardous waste under 40 CFR 252.34); each well where fluids from the facility are injected underground; springs, and other surface water bodies which receive storm water discharges from the facility. EPA Form 3510-2F (Rev. 1-92) Page 1 of 3 Continue on Page 2 A For tach outfall, provide an estimate of the area (Include units) of impervious surfaces (Including paved areae and building roots) drained the outfall, and an estimate of the total surface area drained by the ouffall. ll Area of Impervious Surface famvide Total Area Drained [provide Outfall Numbe Area of Impervious Surface Total Area Drained units) units) iiiMidde units) [provide unjW) rB. Provide a narrative description of significant materials that are currently or In the past three years have been treated, stored or disposed In ■ manner to allow exposure to storm water; method of treatment, storage, or disposal; past and present materials management practices employed to minim zI a contact by these materials with storm water runoff., materials loading and access areas; and the location, manner, and frequency In which pesticides, herbicides, soil conditioners, and fertilizers are applied. C. For each outfall, provide the location and a description of existing structural and nonstructural control measures to reduce storm water runoff; and a description of the treatment the storm ==Including Including the schedule and type of maintenance pollutants in for control outfall Numbs Trefament List Codes from Table 2FA V. N)onstormwater Dischar es A I certify under penalty of law that the outfalls covered by this application have been tested or evaluated for the presence of discharges, and that all nonstomlwater discharges from these outfall(s) are identified in either an accompanying Form application for the outfall. nonstonnwater 2C or Form 2E Name and official This (type orprind Signature Date Signed / B. Provide a description of the methal used, the date of any testing, and the oneite drainage points that were directly observed during a test. VI. Si ri f>cant Leaks or S )IIs Provide existing Information regarding the history of significant leaks or spills of toxic or hazardous pollutants at the facility in the last three years, including the approximate date and location of the spill or leak, and the type and amount of material released. EPA Form 35110-21F (Rev. "2) - Page 2 of 3 Continue on Page 3 EPA ID Number (copy Isom Mm I ofForm 1) Continued from Page 2 ;; � Y 1" 1 I EPA Form 3510.2F (Rev. 1-92) Page 3 of 3 A.B.C.VII. Discharge lnfor�matlan & D: See instructions before proceeding. Complete one set of tables for each outfall. Annotate the outfall number in the space provided. Tables MIA VII -B, and VII -C are included on separate sheets numbered VII -t and VII -2. E: Potential discharges not covered by analysis - is any toxic pollutant listed in table 2F-2, 2F-3 or 2F-4, a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or byproduct? Yes 01st all such pollutants below > No o to section DQ Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years? Yes Pist all such pollutants below) Y. No o to Section DQ p L hfo,LL ivxl �ifq lt-'nflL�'CP Vn WeiCiCweEt<r' dlSl hG.^�C. IX Contract Analysis Informatic Were any of the analysis reported in item VII performed by a contract laboratory or consulting firm? Yea (list the name, .address, and telephone number of, and pollutants ❑ No (go to Section V anahl2ed by, each offirm A. Name B. Address C. Area Code & Phone No. D. Pollutants Analyzed h SiAicS ditA[, N� LS t-1� . . l» ism 1��.�ceY Av: gOiL X. Certificat J certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualNied personnel properly gather and evaluate the Jrfiormation 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 significarn penalties for submitting false information, includJng the posslbility of fine and imprisonment for knowing violations. A. Name & Official Thle (type or print) B. Area Code and Phone No. bSb t C. Signature D. Date Signed EPA Form 3510.2F (Rev. 1-92) Page 3 of 3 EPA ID Number (Dopy Rom Item 1 of Form 1) 4,r:4,/) us/loci' Form Approved. OMB No. 2040-0086 Annrnvnl nvni m G14X VII. Dische s Information om)nued from e 3 of o=2 Part A- You must provide the results of at least one analysis for every pollutant In this table. Complete one table for each outfall. See Instructions for additional details. Pollutant and CAS Number (davailable) Maximum Values (nclude units) Average Values (include units) Number of Bonn Events Sampled SoutaesofPollutants Grab Semple Taken During First 2D Minutes Flow -weighted Composite Grab SamWa Taken During First 20 Minutes Flow -weighted g Composite Oil and Grease r 9 L N/A Biological Oxygen Demand(BODS)*J / t✓ I M ' / L Chemical Oxygen Demand COD Total Suspended Solids SS) !_ tip i r / l.. ,...e 4s w �e Total Nitrogen 1° / L Total Phosphorus H Minimum;. Maximum Minlmum Maximum l Part 8 - fist each pollutard that Is limited In an effluent guideline w ch the facility te subject to or any pollutant listed in the facility's NPDES permit for hs process wastewater (rf the facility is operating under an existing NPDF3 permit). Complete one table for each outfall. See nn for adelitional d Maximum Values Average Values Number Pollutant (include units) (Include units) of and Grab Sample Grab Sam le Storm CAS Number Taken ring Flow -weighted Ta First 2D Flow -weighted Events available) Minutes Composite Minutes Composite Sampled Sources of Pollutants r, _FA 55 U"2F tnwv..-az/ rage V11-1 Continue on Reverse ,v Continued from the Front Part C - Ust each pollutant shown In Tables 2F2, 2F-3, and 2F-4 that you know or have reason to believe is present. See the Instructions for additional details and requirements. Complete one table for each outfall. Maximum Values Average Values Number Pollutant (include unks) (include units) of Grab Sample Storm and GrabSample w-we�. CAS Number Taken Dunng Flow -weighted Taken During v„eighted Events First 2D First 20 Of available) Minutes Composite Minutes Composite Sampled Sources of Pollutants PartD - Provide data for the storm events which resuked in the maximum values for the flow weighted composite sant le. 1. Date of Storm Event 2. Duration of Storm Event nn minutes 3. A Total rainfall Number of hours between during storm event beginning of storm meas- ured and end of previous nn inches measurable rain event 5. McAmum flow rate during rain event (ge=1 1Tinute or units 6. Total flow from rain event allons or ec'units i lull, ll Y 1,3 Il10 .240 L > > iz 00 "`)/�,�� J--'02 M,/,,,,., I,yYL (VI 6 U )6 1) m� 7. Provide a description of the method of flow measurement or estimate. Dr,—j�a,ec- Cs•i rums(- L- K,cu.F X t-tw( runF,l(l (,X",.>) i2 ,n EPA Form 3510-2F (Rev. 1-02) . Page VIF2 EPA ID Number &WIlrorh awn i of Form 1) ,-.110(11i)N3klI Form Approved. OMB No. 2040MW Aeernval avniraa F.A1A9 EPA Form 351u -2F (Rev. i-92) Page VIFt Continue on Reverse VII- Dische a nforrnatlon ntinued from Dage 3 of Fogn 2 Part A- You must provide the results of at beet one analysis for awry pollutant in this table. Complete one table for each outfall. See Instructions for additional details. Pollutant and CAS Number (davailabb) Maximum Values (include units) Average Values (include units) Number of Storm Events Sampled SoumssofFolluterra Grab SampleGrab Taken During First 2D Minutes Flow -weighted Composite Sem Taken During First 20 Minutes Flow -weighted Composite Oil and Grease o• �/� N/A G- 5.0. 5/� a w.,Rr ivcwtineJ Biological Oxygen Demand BODS O / L 3 5 r* 41 L i7 Chemical Oxygen Demand COD Total Suspended Solids SS ;! �- i' -.^ Sink .� o. Total Nitrogen �' 'tyiL f Total Phosphorus .n y I �- ' - JL u PH Minimum Maximum Minimum I , I IMaximurn Y Part B - List each pollutant that Is limitsd In an effluent guideline which the fadlitY is sub to w an po talent listed In the facility's N per for its process wastewater (d the facility is operating under en exlsbng NPDES pertnitj. Complete one table for each outfall. Seo Maximum Values Average Values Number Pollutant (nclude units) (include units) of and Grab Sample Grub Sam�le Storm CAS Number Taken During Flow -weighted Taken Dur ng Flow-waigmed Events First 20 First 2D (if available) Minutes i Composite Minutes Composite Sampled Sources of Pollutants I EPA Form 351u -2F (Rev. i-92) Page VIFt Continue on Reverse f`.nMle„aei Hees rkeFreM 0 U; (V( 13 Part C - Ust each pollutant shown in Tables 2F2, 2F3, and 217.4 that you know or have reason to believe is present. See the InsbugBons for` ' additional details and requirements. Complete one table for each outfall. Maximum Values Pollutant Qncludeunits) andGrab Sample CAS Number Taken Dunng Flow -weighted 20 Minutes Composite Average Values Number (tnctudeunifs) of Grab Sample Storm Taken During Events First 20 Flowwelghted(Navailaw) Mtnutee Composite Sampled Sources of Pollutants PartD - Provide data for the storm avert which resulted in the maximum values for the flow weighted oomposite sample.. 1. Date Of Storm Event 2. Dunadon of Storm Event on minutes) 9. Total rainfall during storm event (in inches 4. Number of hours between beginning of storm meas- ured and and of previous measurable rain event - & Maximum flow rate during rain event (gallons(minute or specify units(gallons S. Total flowfrom rain event arspedly units 4iisl,z R(tX�IL `{`IDII s.y c I K o U�V > f > 7 Z- > p,.>��� I �,r, p -)O✓ n ytna Oy/Mi9 1 0,ono2- v.11 5" +�y U 11 s- v.I o• r'1L J mt 7. Provide a description of the method of flow measurement or estimate. Ix y X\ I2 EPAFWM W64F -(Rev. 1-� . Pagavim Dii7-FAL L t EPAIDNumber lbopyltonrilsnfol Form l) 4l/)U?Z i; Form Approved. OMB No. 204DOM annm�nl ovnmrne tvtm VU. Discharce Infammition nt)nued from Dam 3 of om12✓ Part A- You must provide the results of at lead one analysis for every polluted in this table. Complete one table for each outfall. See Instructions for additional detalte. Pollutant and CAS Number (d available) (if Maximum Values (include units) Average Values (include units) Number of storm Events Sampled Sourgsof Pollutants Grab Sample Taken During Minutes Flow -weighted Composite Grab Sample Taken During First 20 Minutes Flow-wei hied 8 Composite Oil and Grease N/A C 5-O !a5 ` � P"k ., •. Biological Oxygen Demand BOD5 i - • 3 MJ/L, Chemical Oxygen Demand COD Total Suspended Solids SS 5 5_..� Total Nitrogen I I �) -SII i- Total Phosphorus J-) H IMinimum 5• I1 Maximum IMInimunt IMaximum Part B - Ust each pollutant that 181imited in an effluent guideline Which the taoliq is subject to or any pollutant listed in the facility's N ES permit for its process wastewater fd the facility is operating under an existing NPDES permit). Complete one table for each outfall. See Maximum Values Average Values Number Pollutant (Include unite) (include units) of and Grab Sample Grab Sample Storm CAS Number TakF� ring Flow -weighted Taken During Flow -weighted Events 20 (if available) Minutes Composite Minutes Composite Sampled Sources of Pollutants i r CFM Form aaro-zr (Rev. i•yz) Page VII -1 Continue on Reverse .L) drnttmiad ftem lkefreM - Part C - List each pollutant shown in Tables 2F-2, 2F,9, and 2F-4 that you know or have reason to believe is present. See the instructions for ' additional details and requirements. Complete one table for each outfall. Maximum Values Pollutant Onclude units) and Grab Sample CAS Number - Taken Dunng Flow -weighted First 20 (if available) Minutes Composite Average Values Number Qnclude unifs) of Grab Sample Storm Taken During Flow -weighted Events First 20 Minutes Composite Sampled Sources of pollutants Part D - Provide data for the storm events which resutied in the maximum values for the flow weighted composite sem le.. 1. Date of Storm Evert 2. Duration of Storm Event (in OW & Total rainfall during stone event n inches 4. Number of hours between beginning of storm meas- ured and end of previous measurable rain evert - S. Maximum flow rate during rain event (gallons&&nuts or specify unite(gallons 6. Total flow from rain event orepecify units �Ilgay12:y ��LI13 2�r�11 po zc SIJ i 1__ > 7 L > IZ- o. 000> .�,��,� G,Oij P1 0zea "`7 7. Provide a description of the method of flow measurement or estimate. 71 rs I'f c�ett ✓} x dl i per, i�cl ,.,,, IL EPA Form 8510-21F (Ray.14WJ tie vu -2 on nae EPA ID Number (copy from Item I of Form 1) k/ � 00 r/' - Form Approved. OMB No. 2040-006 Approval expires 5.31-92 VII. Discharce Information(Continued Isom pace 3 of Form 2 Part A- You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See Instructions for additional details. Pollutant and CAS Number (d available) Maximum Values (include units) Average Values (include unite) Number of Storm Events Sampled Sources of Pollutants Grab Sample Taken During First 20 Minutes Flow -weighed composite Grab Sampla Taken During First 20 Minutes Flow -weighted Composite Oil and Grease ,4 S /L N/A�i�L Biological Oxygen Demand BO J L4 L 4.2 iw q Chemical Oxygen Demand COD Total Suspended Solids SS Total Nitrogen . to : v�, r ._ I % ra • J L Total Phosphorus ti pH Minimum Maximum I IpAnimum Maximum Part B - List each pollutant that Is imited In an efflusnt gudelins w Idt the fadlhv is subject to or any pollutant listed in a facility's NPD permit for its process wastewater fd the tach is operating under an exist ng NPDES permit). Complete one table for each outfall. See am ments. Maximum Values Average Values Number Pollutant (include units) (include units) of and Grab Sample Grab Sample Storm CAS Number T:en Oaring Flow -weighted Taken During Flow -weighed Events Fir(d available) Minute Composite Minutes Composite Sampled SourceeofPollutants i r EPA Form 9510-2P (Rev. 1-921 aano enu n....x....� Fye on nae JD 1 q Continued from the Front .,i `�r Part C - Ust each pollutant shown in Tables 04, 2M, and 2F-4 that you know or have reason to believe is present. See the Instructions fol' " additional details and requirements. Complete one table for each outfall. Maximum Values Poliutard pncluds units) and Grab Sample CAS Number - : Taken During Flow -weighted Find 20 (if available) Minutes Composite Average Values Number (Include units) of Grab Sample Storm Taken During . Flovwwsighled Events First 20 Minutes Composite Sampled Sources of Pollutants Part D - Provide data for the storm events which resulted in the maximum values for the flow wei Ided composite sem le. 1. Date of Storm Event 2. Duration of Stone Event in minutes & Total rainfall during stone event n inches 4. Number of hours between of storm mea beginning s ured and and of previous measurable rain event - 5. Maximum flow rate during rain event (gallons(minute or units a. Total flow from rain event allons ors unifs L 9lL til _720 - - > 1, > �, iz C),U1)L)Lr .n;� U.JL):,, V ;ic�0i ^�y�+•.. �, �}. �3y •,� y D G3� Ati J 7. Provide a description of the method of flow measurement or estimate. - 4o»-ao'v ,,o✓� �.:.� �ulluvc _ ,m,�l� j.',ll•�s EPA Form 3810-2E (Rev. 1-92) . Poe V11-2 ;FAIL 5 EPA ID Number (oo horn hear 1 of Form 1) I N4!D'IV/0y:3 ii Form Approved. OMB No. 20460086 Approval expires 53162 VII. Dlischarce Information(Continued from page 3'RFonn 219 Part A- You must Provide the results of at least one analysis for every pollutant In this table. Complete one table for each outfall. See Instructions for additional details. Pollutant and CAS Number (if available) Maximum Values (include units) Average Values (include units) Number of Storm Events Sampled Sources of Pollutants Grab Sample Taken During First 20 Minutes Flow-weighted Composite Grab Semple Taken During First2O Minutes Flow-weighted Composite Oil and Grease /L N/A 5EE RTT'/FtHIN EN'r Biological Oxygen Demand BODS I' Chemical Oxygen Demand COD Total Suspended Solids SS 23 O r^' /L +3 { M, l_ 1 Sc E i3c,' Total Nitrogen y Z n`5 L I Total Phosphorus�- pH Minimum L y Maximum Minimum ^ . 4 Maximum ? I Part B - Ust each pol utaM that Imited In an effluent guideline whion the fadlity is sub &W to or any utent fisted in the tealiry's NPD permit for hs process wastewater �'R the factlitX is operating under an existing NPDES permit). Complete one table for each outfall. See instructions for adanignal Maximum Values Average Values Number Pollutant (include units) Oriciude units) of and Grab Sample Grab Sample Steno CAS Number Taken During Flow-weighted Taken Dunng Flow-weighted Events Fret 20 prat 20 (davallabie) Minutes Composite Minutes Composite Sampled Sources of Pollutants EPA Form 3510-2F (Rev-1-921 Continued from theFront Part C - Ust each pollutant shown in Tables 2F-2, 2F-3, and 2F4 that you know or have reason to believe is present. See the InsWctions fo(. ' additional details and requirements. Complete one table for each outfall. Maximum Values Average Values Number Pollutant Qnctudeunits) Qncludeunfta) of and Grab Sample Grab Sample Storm CAS Number Taken Dunng Flow -weighted Taken During Fknv-weighted Events First 20 Fret 20 (fravailable Minutes Composite Minutes Composite Sampled Sources of Pollutants r PertD - Provide date for the stone events which resuhed in the maximum values for the flow w"nelithted composite sant le.. 1. Date of Storm Event 2. Duration of Storm Event (in m 3. 4. Total rainfall Number of hours between during storm event beginning of storm meas and and of previous Pn inches measurable rain event - 5. Maximum flow rate during rain eventured (galtota ns(minuor unitB(gallons 6. Total flow from rain event ors unite �a/,I 5�ibl v> 9�fYjrz 2v.C, � l � �'yv U i ^),r.M. p ovoy �y(fi,n G,�oc;3 n�l,,,,� 0, t .X7 U•93 ,^,,� 0 • Zti �`� 7. Provide a description of the method of flow measurement or estimate. (! 1 IoW •NCG 1...{.'�'1 _ �GG�,, �.�ky�. (.t.`CI_ L15.F�-� !� r;,n G[� EPA Form 381 o -2F (Rev. 1-02) Page'r/li-2 RECEIVEDINCDEQIDWR FEB 2 3 2016 Water Quality Permitting Section Attachment A NPDES Permit Renewal Application Additional Documents for Stormwater Permit Application Section Storm Water Pollution Prevention Plan Salisbury, NC Plant Effective Date: August 2013 Revision: 8 File: Stormwater Pollution Prevention Plan, rev 8 3.0 Certifications: Certifications required by the plant's NPDES permit are presented on the following pages. A responsible corporate officer must certify that, to the best of his knowledge, all parts of this document are true, accurate, and complete, and were prepared properly by appropriate qualified personnel. In addition, this Storm Water Pollution Prevention Plan must include a certification that storm water discharges have been tested or evaluated for the presence of non -storm water discharges. STORM WATER POLLUTION PREVENTION PLAN PROPER PREPARATION CERTIFICATION I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated 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 fines and imprisonment for knowing violations. Revision: Name and Title of Responsible Official: Richard L. Moore — Plant Manager Signature:/ �� Certification Date: `7 Zr4 / CERTIFICATION OF COMPLIANCE WITH SECTION 313 WATER PRIORITY CHEMICALS REQUIREMENT I certify under penalty of law that this document and all attachments were reviewed and the facility examined by me or those under my direction or supervision in accordance with the Section 313 water priority chemicals requirements of the plant's NPDES permit. To the best of my knowledge and belief, this plan was prepared in accordance with good engineering practices. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Revision Number: Name of Registered Professional Engineer: Registered State and Number: NA Signature: Certification Date: Page 5 Storm Water Pollution Prevention Plan Salisbury, NC Plant Effective Date: August 2005 Revision: 7 File: Salisbury Storunvater Certification Certifications required by the plant's NPDES permit are presented on the following pages. A responsible corporate officer must certify that, to the best of his knowledge, all parts of this document are true, accurate, and complete, and were prepared properly by appropriate qualified personnel. In addition, this Storni Water Pollution Prevention Plan must include a certification that storm water discharges have been tested or ovaluated for the presence of non -storm water discharges. STORM WATER POLLUTION PREVENTION PLAN PROPER PREPARATION CERTIFICATION I certify under penalty or law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated 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 fines and imprisonment for knowing violations. Revision: 7 Name and Title of Responsible Official: Richard L. Moore -Plant Manager Signature: Certification Date: 12-12-12 CERTIFICATION OF COMPLIANCE WITH SECTION 313 WATER PRIORITY CHEMICALS REQUIREMENT I certify under penalty of law that this document and all attachments were reviewed and the facility examined by me or those under my direction or supervision in accordance with the Section 313 water priority chemicals requirements of the plant's NPDES permit To the best of my knowledge and belief this plan was prepared in accordance with good engineering practices. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Revision Number: Name of Registered Professional Engineer: Registered State and Number: NA Signature: Certification Date: Storm Water Pollution. Prevention Plan. Salisbury, NC Plant Effective Date: August 2005 Revision: 7 File: Salisbury Stormwater Certification NON -STORM WATER DISCHARGE ASSESSMENT AND CERTIFICATION Outfall Directly Date of Observed Doing Name of Person Test or the Test (identify, Method Used to Test or Evaluate Describe Results from Test for the Identify Potential Who Conducted Evaluation as indicated on the Discharge Presence of Nom-Stomm water Significant Sources the Test or site map) Discharge Evaluation 10.21-10 A Dry Weather Obsenxatian No Mon -Storm Water Found None WWTP ORC 4.25-11 A 15 gpm See SWPPP Inspection 10-24-11 A 42 gpm See S W PPP Inspection 4-23-12 A 112 gpm None 11.142 A 11 11 No Non-Stormwater Found None 10/21/10 B Dry Weather Observation No Non -Storm water Found None WWTP ORC 4-25-11 B No Non -Storm water Found None 10-24-11 B No Non -Storm water Found None 4.23-12 B -` No Nom -Storm water Found None 11-1-12 B No Non-Storawater Found None 10/21/10 C Dry Weather Observation No Non -Storm water Found None WWTP ORC 4-25-11 C No Non -Storm water Found None 10.24-11 C No Non -Storm water Found None 4-23-12 C No Non -Storm water Found None 11-1-12 C No Non -Storm water Found None 0/21/10 D Dry Weather Observation No Non -Storm water Found None IYWTP ORC 4-25-11 D 11No Non -Storm water Found None 10-24-11 D " No Non -Storm water Found None 4.23-12 D -` No Non -Storm water Found None 11-1-12 D No Non-Stormwater Found None 10/21/10 5 Dry Weather Observation No Non -Storm water Found None WRrrP ORC 4.25-11 5 " No Non-Stonnwater Found None 10-24-11 5 " No Non -Storm water Found None 4.23-12 5 No Nun -Storm water Found None 11-1-12 5 11No Non-Storm\Yater Found None CERTIFICATION I certify under penalty of lawthatthe outfall(s) covered by this application have been tested and/or evaluated for the presence ofunpermitted non -stoat water discharges in accordance with Pan I.A.I.a(5) ofthe plants NPDES permit. Based on my inquiry ofthe person or persons who manage the system, or those persons directly responsible for gathering the information, no wmpenmitted non -storm water is discharged to any storm water drainage system or outfali(s). I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for lanowing violations. A Name & Title of Responsible ficial: (type or print) B. Area Code and Telephone No. Richard L. Moore -Plant Manager 704-636-6000 C. Signature D. Certification Date 12-12-12 i( MIA �l/'7/1I A VI SW Outfall C SW Outfall A imam SW Outfall 5 0 SW Outfall D E a NPDES Outfall 001 SW Outfall B A Facility Information Facility -alltudg, 39'42'34 S " ub-Hasim 03-07-06 Location ,mmitude, WS4'31" fr�1b7.�IYT44=0004944 And_A 916NE, Rowan Mills I ±Imiffi Class, C RQcgivingStmain Nords Second Creek F20ftars, . .1.1 1 .1, . one %A�_" r- r- ,W SEC�NR 1 1 \ REC. cwe /IOUSE LAKE 1-1 � �I— ralrsrF Nm P rs-• 1-4 w asuc 11IfYY � , \ R N2 LEGEND --•— FENCE LINE —t—+ RAILROAD C.L. Q ---IPO SCALE IN FEET ® FRE HYDRANTS OHNE PRESSURE I95 PSI OFT UNE PRESSURE 155 PS LAST ANNSER USED eVESSELS FOR I&MRYATION ON VESSELS SEE FRE : TANKS= � OPERATIONS ZONE . STAGING. AREA DUIDHO OR AREA DERMATION A 10C %ft dm ai NO Ogll AAS M VESSEL & TANK IDENTIFICATION IMP j SFE—DO-1231003 (j0 7 I A WAREHOUSE B BUILDING B BUILDING WAREHOUSE ILI BLD CENTRAL CORE WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING SALISBURY PLANT D 0 W H T BUILDING H E R M fl(TuRF 2 SHOPS & STORES T BLDG # 1 F.0 #2 F. 0. #3 F. 0. 6&7 TWRS P BUILDING GLY. REC. TWRS 1-5 D 0 K W BUILDING T H E R M G BUILDING D 0 W H T BUILDING H E R M fl(TuRF 2 SHOPS & STORES T BLDG # 1 F.0 #2 F. 0. #3 F. 0. 6&7 TWRS P BUILDING GLY. REC. TWRS 1-5 1A B BUILDI 8 BUILDING WAREHOUSE ILI BLD CENTRAL CORE WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING #1 OUTFALL SERVES K BUILDING ROOF DRAINS G BUILDING ROOF DRAINS S BUILDING ROOF DRAINS G BUILDING ELEVATOR SHAFT ROADWAY AND TA PAD DRAINS SALISBURY PLANT #1 OUTFALL H BUIL Ff (.u4g 2 #1 OUTFALL TK FARM c _2 T BLDG 4 1 F.0 6&7 TWRS P BUILDING EC TWRS 1-5 ?,oF10 Y A WAREHOUSE WAREHOUSE B BUILDING B BUILDING WAREHOUSE ILI BLD CENTRAL CORE WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING #2 OUTFALL SERVES GLYCOL TANK FARM STORM DRAINS -TANK FARM SALISBURY PLANT #2 OUTFALL H BUIL D 0 W T H E R M SHOPS & STORES BLDG T 0 TWRS W 1-5 T JD H E R M H BUIL D 0 W T H E R M SHOPS & STORES 6&7 TWRS P BUILDING #2 OUTFA GLY. REC. BLDG T TWRS 1-5 # 1 F.0 6&7 TWRS P BUILDING #2 OUTFA GLY. REC. 0 B BUILDING B BUILDING WAREHOUSE WAREHOUSE ILI BLD CENTRAL CORE WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING 43 OUTFALL SERVES RAILROAD TRACK STORM DRAIN SALISBURY PLANT #3 OUTFALL D 0 W H T BUILDING H E R M SHOPS & STORES 6&7 TWRS P 81JILDING TK FARM #3 OUT Ec" TWRS 1-5 '1nF to D 0 K W BUILDING T H E R M G BUILDING D 0 W H T BUILDING H E R M SHOPS & STORES 6&7 TWRS P 81JILDING TK FARM #3 OUT Ec" TWRS 1-5 '1nF to WAREHOUSE B BUILDING 8 BUILDING WAREHOUSE ILI BLD A CENTRAL CORE WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING #4 OUTFALL SERVES GLYCOL RECOVERY UNIT RAILROAD TRACK STORM DRAIN SALISBURY PLANT #4 OUTFALL H BUILDI D 0 W T H E R M 9TWRS SHOPS & STORES TK FARM D 0 K W BUILDING T H E R M G BUILDING H BUILDI D 0 W T H E R M 9TWRS SHOPS & STORES TK FARM 6&7 TWRS P BUILDING Flo'uK6- Z SoFlo TWRS 1,5 �- -#4 OUTFAL # 1 F.0 #2 F.O. #3 F. 0. 6&7 TWRS P BUILDING Flo'uK6- Z SoFlo I A e BUIL e BUILDING WAREHOUSE WAREHOUSE ILS BLD CENTRAL CORE WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING WAREHOUSE I J BUILDING SALISBURY PLANT #5 OUTFALL D 0 W H T BUILDING H E R M SHOPS & STORES T BLDG # 1 F.0 #2 F. 0. #3 F. 0. TK FARfv GLY. REC. TWRS 1-5 #5 OUTFALL 45 OUTFALL SERVES P BUILDING STORM DRAINS AT SOUTH UNLOADING DOCK FI 6-c4K F' Z / nGlo D 0 K W BUILDING T H E R M G BUILDING D 0 W H T BUILDING H E R M SHOPS & STORES T BLDG # 1 F.0 #2 F. 0. #3 F. 0. TK FARfv GLY. REC. TWRS 1-5 #5 OUTFALL 45 OUTFALL SERVES P BUILDING STORM DRAINS AT SOUTH UNLOADING DOCK FI 6-c4K F' Z / nGlo A SALISBURY PLANT #6 OUTFALL #6 OUTFALL SERVES T BUILDING ROOF DRAINS T BUILDING FLOOR DRAINS 11 BUILDING ROOF DRAINS H DOWTHERM AND TA PAD AREA RAILROAD TRACK STORM DRAINS ABILITY TO PUMP OIL BASINS 6&7 TWRS P BUILDING FC B D BUILDING 0 K W SHOPS & WAREHOUSE BUILDING T STORES H B BUILDING E WAREHOUSE R M G WAREHOUSEL BLD BUILDING : i-�-_ ~ CENTRAL CORE }z""--' `� TWRS }•� �N WAREHOUSE J BUILDING .0% --: i PUMPED ONLY) WAREHOUSE J BUILDING WAREHOUSE J BUILDING 8-10 TWRS #6 OUTFALL #6 OUTFALL SERVES T BUILDING ROOF DRAINS T BUILDING FLOOR DRAINS 11 BUILDING ROOF DRAINS H DOWTHERM AND TA PAD AREA RAILROAD TRACK STORM DRAINS ABILITY TO PUMP OIL BASINS 6&7 TWRS P BUILDING FC SALISBURY PLANT 412 OUTFALL D 0 W SHOPS & T STORES H E R M T BLDG D 0 W T # 1 F.0 H E #2 F. 0. R M #3 F. 0. #12 OUTFALL P BUILDING @12 OUTFALL SERVES ROOF DRAINS FILAMENT WAREHOUSE A BUILDING ROOF DRAINS ROOF DRAINS BEAMING AREA FLOOR DRAINS BEAMING AREA L BUILDING ROOF DRAINS FLOOR DRAINS L BUILDING ROOF DRAINS STAPLE WAREHOUSE FLOOR DRAINS STAPLE WAREHOUSE ROOF DRAINS J BUILDING NORTH AND SOUTH PARKING LOT DRAINS TWRS 1-5 ER EC OUTFALLS 8,9,10,11 SERVICE P BUILDING PARKING LOT ROADWAY DRAINS ON SOUTH SIDE OF PLANT F16 -"WC Z In Ac /n 7.0 Storm water Management Plan This portion of the SWPPP describes and identifies materials management practices used to control and minimize exposure of significant materials to storm water. 7.1 Exposed Materials This section addresses the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to storm water. The section summarizes potential pollutant sources by plant activity (e.g., truck loading and unloading) and presents alternatives for reducing exposure to storm water for each activity. In particular, this section discusses the use of covers for material storage and handling areas as a measure of reducing exposure. Specific changes are identified in Section 7.3 'Best Management Practices." Plant engineering will review the changes identified in Section 7.0 and accomplish them in a technically and economically feasible manner. No areas were identified where diversion of storm water would be applicable. 7.1.1 Summary of Potential Pollutant Sources Potential pollutant sources were identified for each of the following activities: Loading and Unloading Operations Outdoor Storage and Process Areas Dust or Particulate Generating Processes On-site Waste Disposal Practices Vehicle Fueling and Maintenance Areas The potential pollutants associated with each of these activities are summarized in Table 7-1. A brief discussion of each of these activities follows. Thirty-six truck loading and unloading areas can be identified at the plant. Raw materials such as ethylene glycol and terephdWic acid are the most significant items that arrive at the facility by rail. Most of the production areas of the facility are located inside. Materials such as chip, staple, and TA are stored in outdoor silos. Various pieces of production equipment are located outside, primarily along the east side of the main production building. This equipment includes boilers, reboilers, pumps and piping. Bulk storage tanks are not included in the summary presented in Table 7-1. Pipes are sand blasted and coated in an area south of the EO facility. Dust and particulate generating processes are generally associated with solid material handling operations such as handling of chip, staple, and TA. The pipe coating area south of the EO facility is also a particulate generating process. Wastes are collected in dumpsters around the plant site for disposal. Ultimately, the wastes are disposed of off-site. Two vehicle -fueling areas are located on-site in addition to the propane fueling areas for vehicles such as forklifts. One area for vehicle maintenance is located in and adjacent to the southwest comer of Building S. Table 7-1 Summary of Potential Pollutant Sources Location Potential Pollutant Truck Loading and Unloading Facilities Warehouse Along West Side of Main Production Building Staple, Filament North Side of Building B Filament Underground Fuel Tank on the Southwest Comer of Main Production Building Gasoline Fuel Tank Northeast of Building S Diesel Fuel Silos North of Main Production Building Chi Silos South of Main Production Building Chi South Side of Building J Chi North, East and South Sides of Building P Chi Areas Near the Cooling Towers Sodium Hypochlorite, Gengard GN8203, Gengard GN8300, Hydrex 2254, Flogard MS6210, Spectrus OX1201, Depositrol PY5200, Betz Inhibitor AZ8104 South Side of Tank 94 Sodium Hydroxide Ethylene Oxide Facility - shutdown 1 '96 N/A GRU Facility Glycol GRUB Unloading Facility Near Southeast Corner of Building H Glycol South End of the Large Recreation Pond Fuel Oil South and East Sides of TA Silos Near the Main Corridor Terephthalic Acid, Adipic Acid North Side of Tanks 29, 30 and 31 O tis erse APO520, Steamate-NA2440 Near Tanks 56, 57 and 58 South of GRU Facility "PE" Water 1 percent Ethylene Glycol) North, West and East Sides of Building S Chemicals Listed in Appendix D North and South Sides of Tanks 18-21 on the East Side of Building G Dowtherm Adjacent to Tanks 22, 105 and 106 at the Northeast Comer of Building K Dowthemr, TEG Near the Chemical Tanks at the Process Water Treatment Plant Sodium Hypochlorite, Sodium Hydroxide Near the Chemical Tanks at the Wastewater Treatment Plant Betz 1192 East Side of the Raw Water Pond Betz 1192 Rail Loading and Unloading Facilities East Side of GRU Facility Ethylene Glycol, Diethlene Glycol TA Unloading Building Near the Southeast Comer of Building S Terephthalic Acid East Side of Building P Chip, Staple, Diethlene Glycol Covered Dock Northeast of Building P Waste Chip, Fiber, Staple, Filament Outdoor Storage and Process Areas Pie Coating Area Sand Blast Material, Epoxy Coatings Equipment Such as Boilers, Reboilers, Pumps and Piping along the East Side of the Main Production Building Dowthemr Drum Stora eon East Side of K-17 Finish Waste Hazardous Waste Drum Storage Paint Waste, OCP Waste, OCC Waste, Kolene Waste, Acid Waste, Alkaline Waste Drum Storage Near Southwest Comer of Building S Perchloroeth lene, Ethyl Alcohol, Solvents Table 7-1 Summary of Potential Pollutant Sources Dram Storage South of Building T PCB (capacitors & ballasts Non -Hazardous Waste Drum Storage Area South of Textile Lubricants, Beaming Finish Waste, Building P Waste Finish, TA, Glycol, Fuel Oil, K-14 and K-15 Paste, B -roll Exhaust Sludge, Beam Cleaning Sludge, Adipic Acid, Cooling Water Sludge, Salt, Perchloroeth lene, Kolene Drum Storage on East Side of Building G Hydrochloric Acid, Tetramethylammonium Hydroxide, Albright TMP, SIPE-40, Ethylene Glycol, Rezol T-279, Oil, Acetic Acid, Oxa- hos hoan1 kolester, Choline Base Silos East of the Main Corridor Terephtlialic Acid, Adipic Acid Silos North and South of the Main Production Building Chi Dust or Particulate Generating Processes Silos North of Main Production Building Chi Silos South of Main Production Buildin Chi Silos East of Main Production Building Near Main Terephthalic Acid, Adipic Acid Corridor Throughout the Area East of the Main Production Facility Chip West of the Railroad Tracks Vehicle Maintenance and Fueling Areas Southwest Comer of Main Production Building Gasoline, Oil and Grease Northeast of Building S Diesel Fuel Southwest Comer of Building S Oil and Grease, Hydraulic Fluid, Antifreeze 7.1.2 Plan to Minimize Exposure of Material to Storm water Potential changes to the methods of operation and storage practices that have could be employed to address each of the potential pollutant sources listed in Table 7-1 are discussed below. Specific BMPs that have been implemented to minimize significant exposure of materials to storm water are discussed in Section 7.3 'Best Management Practices". include: 7.1.2.1 Truck and Rail Loading and Unloadine Alternatives for reducing exposure of loading and unloading activities to storm water * Rolled -curb containment * Grated trench containment * Covering loading and unloading areas * Drip pans at rail tank car loading and unloading facilities * Cleaning up spills and leaks as required * Development and implementation of a SPCC plan * Locating quick -connect fittings within contained areas The plant's SPCC Plan was updated in 2004 and 2009 to meet more stringent oil spill containment regulations. This effort included adding secondary containment around all oil storage tanks. It also provided spill containment in the form of curbing or portable containments to catch hose drips at the oil truck unloading points. Truck connection points were relocated to place the quick -connect fittings inside the containment area whenever possible. Furthermore, these oil truck unloading operations are now attended include: and monitored continuously with portable barricades to prevent accidental drive off while the hose is connected. Procedures, training, and use of designated "trained oil handlers' is being done to minimize the chance of oil spill. See details in the plant's SPCC Plan. Contamination from the warehouse on the west side of the main production building would only result from spilled packaged solid product. Rolled -curbs have been installed at several truck loading and unloading areas, especially those near bulk storage tanks. Many loading docks are covered. Installation of rolled curbing is more practical and economically feasible than construction of covers for many of the liquid loading and unloading area limitations of location and frequency of use are considered. Good housekeeping will protect storm water from solid materials spilled during loading and unloading. Raw materials such as ethylene glycol (liquid) and terephthalic acid (bulk powder) are the most significant items that arrive at the facility by rail. Contamination in those areas can be contained by the plant SIS system and diverted to the Waste Treatment Plant in the event of a spill. 7.1.2.2 Outdoor Storage and Process Areas Alternatives for reducing exposure of outdoor storage and process areas to storm water * Storing materials inside buildings or in covered tanks where possible * Labeling storage tanks and dnnns * Storing materials in designated areas * Periodic inspection and inventory of stored materials * Written standard operating procedures for materials storage and handling * Secondary containment around liquid storage tanks * Curbed containment around pumps, process equipment, and materials storage areas * Covering drum storage areas * Cleaning up spills and leaks as required * Inspection of production areas * Establishment of an Emergency Response Team and maintenance of cleanup materials on-site * Development and implementation of a SPCC plan * Emphasis on housekeeping in employee training * Addition of rolled curb at doorways leading to storage areas within the plant Several drum storage areas are covered but not curbed. Covering some drum storage areas is not feasible due to limitations such as overhead piping. Most drum storage areas are covered. Those requiring additional protection are identified in Section 7.2. All outside drum storage has secondary containment except the empty drum storage area where triple -rinsed clean drums are stored. Most drum storage areas are also covered. 7.1.2.3 Dust or Particulate Generating Processes Alternatives for reducing exposure of dust and particulate generating processes to storm water include: * Storing materials inside buildings or in covered silos where possible * Cleaning up spills as required * Emphasis on housekeeping in employee training * Covering particulate generating processes Emphasis has been placed on housekeeping to prevent and/or reduce contamination of storm water by spilled chip, staple, TA and other particulates. 7.1.2.4 Waste Disposal Practices Alternatives for reducing exposure of disposal activities to storm water include the following: * Collecting waste in designated areas * Cleaning up spills around dumpsters as required * Covering waste containers * Secondary containment where feasible All materials are disposed of off-site. Housekeeping around waste collection containers is being maintained to acceptable levels. Where needed, dumpsters with covers have replaced those dumpsters, which are not under cover. Waste oil is disposed of in full compliance with new SPCC plan oil handling regulations. All oil storage containers have secondary containment and stringent monitoring of waste oil handling operations by trained oil handlers. 7.1.2.5 Vehicle Fueling and Maintenance Areas Alternatives for reducing exposure of vehicle fueling and maintenance areas to storm water include: * Secondary containment around liquid storage tanks * Curbed containment * Rolled -curb containment in doorways * Covering vehicle fueling and maintenance facilities * Cleaning up spills and leaks as required * Development and implementation of a SPCC plan * Emphasis on housekeeping in employee training Vehicle fueling areas are contained by curbing, and have been addressed as noted above to comply with new oil regulations in the plant's SPCC Plan. As noted above, those new measures include secondary containment around all oil bulk storage tanks, curbed containments and monitoring of fueling operations. The plant has a recently -updated SPCC plan in place for reducing the potential of storm water contamination from spills. 7.1.26 Secondary Containment Secondary containment dikes with periodic inspection by trained operators have been installed around all oil tanks and all outdoor chemical bulk storage tanks. All secondary containment connected directly to storm water conveyance systems meets the following criteria as specified in the permit: * Drainage must be controlled by manually operated valves which are secured by a locking mechanism. * Accumulated storm water must be at least visually observed for color, foam, outfall staining, visible sheens and dry weather flow before release. * Accumulated storm water can be released if found to be uncontaminated. * Records documenting the name of the individual making the observation, a description of the accumulated storm water, and the date and time of the release shall be kept for a period of 5 years. Table 7-6 BMP Implementation Schedule Continued Spill Prevention and Maintain the SPCC Plan On-going Response Procedures Provide Employee Training in Spill At Initial Hire and Periodically Prevention and Response (Particularly for Thereafter Those Involved in Manufacturing, Maintenance and Utility Activities Inspections Improve Current Inspection Procedures On-going Related to Storm water Pollution Prevention Conduct Semi -Annual Comprehensive Site Semi -Annually Compliance Evaluations (Including Outfall Visual Inspection) Based on Inspection Results, Modify S WPPP As Needed as Needed General Visual Site Inspection Routine Employee Training Incorporate Storm water Pollution Prevention On-going Awareness and Tools into Current Employee Training Program Record Keeping Maintain Records on Spill Events and On-going Maintenance and Inspection Activities Sediment and Erosion Maintain Sediment and Erosion Control On-going Control Measures Runoff Management Implement Runoff Management Techniques On-going Where Appropriate Activity Specific BMPs See 'Best Management Practices" On-going Site Specific BMPs See 'Best Management Practices" On-going Attachment A NPDES Permit Renewal Application Manufacturing Operation Flow Diagram (Figure 2) y N 7 O C C C ., 7 7 a. c.) a aU C Q c E U 3 o M IL --------------------- - + ------------- a) >,'a a°a Vi C O fV CD CD O. O N d LL N as o D_ w � I L m in N U - C Q N a) .7,8 �v 8 .c LL. J Vi C O fV CD CD O. O N d LL N as o D_ w � I L m in Attachment A NPDES Permit Renewal Application Waste Treatment Plant Diagram (Figure 3)