NCS000329_EPA Inspection Report_20190603

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION 4
ATLANTA FEDERAL CENTER
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61 FORSYTH STREET
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ATLANTA, GEORGIA 30303-8960
MAY 2 8 2019
CERTIFIED MAIL 7017 1450 0000 7973 2823
RETURNED RECEIPT REQUESTED
Mr. Ryan Scott
Environmental Manager RE C FVF- D
ATI Allvac — Bakers Plant JUN 0 3 2019
P.O. Box 5030
Monroe, North Carolina 28111-5030 DENR-LAND QUALITY
STORMWATER PEWii i fING
Re: Compliance Evaluation Inspections
ATI Allvac — Bakers Plant, Monroe, North Carolina
NPDES Permit No. NCS000329
Dear Mr. Scott:
On March 20, 2019, the U.S. Environmental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the ATI Allvac — Bakers Plant located at 6400 and 3570 Alloy Way in Monroe, NC. The purpose of
the CEI was to evaluate ATI Allvac — Bakers Plant's compliance with the requirements of Sections 301
and 402(p) of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and 1342(p); the regulations promulgated
thereunder at 40 C.F.R. § 122.26; and, the State of North Carolina's NPDES Stormwater Permit
NCS000329.
The EPA and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to Lauren. ag rciagncdenr. gov.
There is no need to respond directly to the EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Ahmad Dromgoole at the above address, by email at
[e-mail], or at [phone].
Enclosures
cc: Ms. Annette Lucas
10411101�
Sincerely,
=Q—
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
Intemet Address (URL) • http://www.epa.gov
Recycled/Recyclable . Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer)

1"'� U.S. Environmental Protection Agency, Region 4
61 Forsyth Street SW, Atlanta, GA 30303
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Water Compliance Inspection Report
FACILITY DATA
NPDES ID: NCS000329 Effective Date: 03/01/2010 Expiration Date: 02/28/2015
Facility Name: ATI Allvac — Bakers Site ISIC Code: 3356, 3341
Address: 1700 Teledyne Road, Monroe, NC 28110
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Ryan Scott David Pope
Environmental Manager Plant Manager
P.O. Box 5030 P.O. Box 5030
Monroe, NC 28111-5030 Monroe, NC 28111-5030
INSPECTION DATES/TIMES
Entry Date/Time: 03/20/2019, 2:10 pm Exit Date/Time: 03/20/2019, 7:00 pm
NAMESOF EPA AND STATE INSPECTORS
EPA Inspectors: Ahmad Dromgoole and Kenneth Kwan
NCDENR Inspectors: Holliday Keen, Seth Titley, Brandon Finch, and James Moore
AREAS EVALUATED DURING
X Permit Self -Compliance Program Pretreatment
X Records
Compliance Schedule
Pollution Prevention
X Facility Site Review
Laboratory
X Storm Water
X Effluent / Receiving Waters
X
Operations & Maintenance
Combined Sewer Overflow
Flow Measurement Sludge Handling/ Disposal Sanitary Sewer Overflow
INSPECTION 1
The inspection team, consisting of EPA inspectors and state inspectors from various regional offices, arrived at the facility on March
20, 2019 to perform an unannounced Compliance Evaluation Inspection (CEI). This CEI, which focused on the facility's NPDES
Industrial Stormwater permit, was performed as both a joint inspection with the state and a training opportunity for state inspectors.
Upon arrival at the facility, EPA inspectors checked in at the guard station and waited for the appropriate facility personnel to arrive.
Upon their arrival, the inspectors presented credentials and facilitated an opening conference. The CEI included both a records
review portion and a facility walk through. Due to time restraints, the inspection team executed a brief exit conference with facility
personal in which they were informed of EPA's preliminary findings from the walk around. Initial findings from the records review
were not provided due to additional documents needing to be provided to EPA at a later date. At the end, facility personnel were
informed that an inspection report will be sent to the facility by EPA.
P♦
REPRESENTATIVES
Inspector Signature/Name
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9212
Ahmad Drom oole, Environmental Engineer
USEPA Region 4/WPD-CWEB-SRES
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signature/Name
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9434
Daniel J. O'Lone, Chief
Stormwater and Residuals Enforcement Section
Page 1 of 6

GPS
Coordinates
1. FACILITY LOCATION IN1' 1
Latitude 3501'6.26"N Longitude
80036'39.81"W
Receiving
Site
Weather
Water(s) or
Bearskin Creek
Acreage
82 acres
Condition
Cloudy skies
MS4
Does the site
Date of
SIC
3356.
Discharge to
discharge pollutants
Permit
09/03/2014
Code(s)
3341
303(d) listed or
No
contributing to the
N/A
Application
TMDL waters
receiving stream
impairment.
2. BASIC 1 POLLUTION PREVENT PLAN (S"'
SPPP TOPICS (Part II)
YES
NO
N/E
SPPP on -site (obtain a copy of the plan) Section A
X
A copy of the SPPP was provided during the inspection. The SPPP is kept electronically and did not
have dated signatures for updates. According to facility personnel, the last save date of the document
provided was 02//24/18.
Site Description Section A(I)(b)
X
A site description was provided in the SPPP.
Identify potential Pollutant Sources and Particular Pollutants Section A(I)(b)
X
The site description in the plan included information about most of the potential pollutant sources and
control measures in place at each of the outfalls. The plan did not identify the locations of the various
dust/particulate control processes, specifically, the locations of the various ba houses.
Site Maps (general location map and site specific map) Sections A(I)(a & c)
X
A site map specific to the SPPP was not provided during the inspection. Instead what was provided
was the site map from the facility's SPCC plan. These maps, though they did include some
information on outfalls and flow patterns, did not include information on the various pollutant sources
(i.e. dust generation sources, outdoor storage, and outdoorprocesses).
Spill History (3 year history or spills and corrective actions) Section A(I)(d)
X
A statement was provided in the SPPP stating that there had been no reportable spills in the past
three years. The statement did not include a date (identifying what the three year window is) nor
was there a date on the SPPP (which could be used as in indication of when the portions of the
SPPP was evaluated).
SPPP Certification Section A(I)(e)
X
(Annual recertification of no evidence of non-stormwater discharging)
The SPPP did not include annual certifications or information pertaining to annual plan updates.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
X
(Analysis of control options like eliminating exposure or controlling runoff)
The SPPP provides a description of when and how feasibility studies would be performed at the site.
Neither the plan nor facility personnel were able to confirm the existence and resulting actions of any
feasibility studies.
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
X
The SPPP included a section discussing the secondary containment requirements. The section states
that there is a table of secondary containment structures, but it was not included in the copy of the
SPPP provided. A copy of the SPCC plan was provided which did include a table of the above ground
tanks and their secondary containment volume.
Page 2 of 6

2. BASIC STORMWATER POLLUTION PREVENT INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
Stormwater BMP Summary Section A(2)(c)
X
Section 8 of the SPPP provided a description of the various BMPs implemented at the site. This
included both structural and non-structural BMPs.
Spill Prevention & Response Procedures (SPRP) Section A(3)
X
The provided SPPP included a section referring to the SPCC for spill procedures. This section
included information on the various responsible officials and their contact information.
Preventative Maintenance and Good Housekeeping Program Section A(4)
X
Sections 8 and 9 of the SPPP provided descriptions of the routine preventative maintenance and
housekeeping measures to be implemented at the site. Additionally, these measures were included in
the inspection checklist used at the facility. Although the descriptions of measures were included, the
SPPP did not establish schedules.
Employee Training Section A(5)
X
Per the SPPP, monthly general awareness training is provided in which spill prevention and
environmental housekeeping topics are discussed.
Identify the Responsible Party Section (A)(6)
X
According to the SPPP, the EHS Manger is responsible for the overall coordination, development,
and implementation of SPPP plan.
SPPP Modified or Update to Current Conditions Section (A)(7)
X
The SPPP provided during the inspection included neither a signed signature nor dates in the annual
updates sections. Specifically, benchmark data since 2017 has shown frequent exceedances of
benchmark limits for copper, zinc, and chlorine. The SPPP provided during the inspection included
no mention of additional measures to be implemented by the facility to address these benchmark
exceedances.
Schedule and Procedures for Routine Inspections Section A(8)
X
According to the SPPP, routine inspections are to be performed monthly. This was inconsistent with
the provided inspection documents which done monthly.
ATI Allvac operates multiple metal alloy facilities in Monroe, NC. The Bakers North and Bakers South facilities operated
under the same NPDES permits. Operations at Bakers North and South complex began in the 1960s. In 2017, ATI began
operations at a third facility, the Bakers Powder facility. A separate permit application has been submitted for this facility.
At the Bakers North and South facilities, a variety of titanium alloys are formed and nickel ingots from the Monroe facility
are reformed and finished. The raw materials for these plants include titanium revert and nickel ingots. The products from
the processes are metal ingots used as a raw material for other forming processes.
The Bakers North and South facilities both operate under the one NPDES permit: NCS000329. This permit provides
coverage for both industrial stormwater and wastewater from non -contact cooling water. The facility operated three external
outfalls discharging to the stream (SW Outfall 91, Outfall 42, and Outfall 93). Of those outfalls, only Outfall 91 was
commingled with process wastewater from the cooling processes. In addition to the external outfalls, there are a number of
internal outfalls throughout the site that discharge to the primary pond associated with SW Outfall # 1. Many of these internal
outfalls are associated with various water quality and retention ponds.
Page 3 of 6

4. RECORD REVIEW
Record Review
YES
NO
N/E
Records of the Implementation of the SPPP Part II Section A(9), Part III Section D(6)
X
Samples of records from 2017 and 2018 were available and reviewed.
Records of Maintenance and Housekeeping Programs Part II, Section A(9)
X
Samples of the maintenance and housekeeping records were requested for 2017-2019. These records,
which are kept electronically, were provided and appeared to show the facility performing periodic
maintenance of its stormwater BMPs.
Records of Routine Inspections Part II, Section A(9)
X
A sample of the monthly inspection records were provided by the company. These records were
reviewed, identified the various areas inspected, and included descriptions of the concerned found.
Records of Employee Training Part II, Section A(9)
X
Records of employee training were provided for 2018.
Records for the Approval of Representative Outfalls Part III Section D(5)
X
The facility had not requested the use of representative outfalls.
Records of Benchmark Monitoring Part II, Section B & D, Part III Sections D, & E(I)
X
Records of benchmark monitoring were reviewed back through 2017. The review of these records
appeared to show the required preservatives and holding times being met for the samples. Sampling
records were reviewed for the three outfalls. From this review, consistent copper exceedances were
observed at all three outfalls. Additionally, consistent total chlorine exceedances were reported for
Outfall 1 (the commingled outfall).
Records of Qualitative Monitoring Part II Section C, Part III Section D
X
Qualitative monitoring was performed with periodic benchmark monitoring. Qualitative monitoring
records were reviewed back through 2017. A review of these records appeared show the required
observations being made.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
X
From the review of benchmark data since 2017, it was determined that the facility has had consistent
benchmark exceedances for copper at all of the outfalls and chlorine at Outfall 1. Additionally, Outfall
2 had two back to back occurances of benchmark exceedances for zinc. The most recent Tiered
response (a Tier I response), was provided by the facility and dated 07/30/18. The copper and chlorine
exceedances have continued since this last Tiered evaluation but there have been no additional
measures implemented nor was monthly monitoring being performed.
Records of Bypasses Part III Sections E(7)
According to facility personnel, there have been no instances during 2017 and 2018 meeting this
X
requirement.
Records of 24 hr Reporting Part III Sections E(8 &9)
According to facility personnel, there have been no instances during 2017 and 2018 meeting this
X
requirement.
Pollutant Sources Note location, quantitative description, design issue, O&M deficiencies (including the
nature and extent), and pollutants off -site
The Bakers South facility receives metal ingots from the Monroe facility which it further
processes. Outside storage of these unfinished ingots was observed at the site and seen in photos
DSCN1913 and DSCN1917-DSCNI918. In addition to some of the raw ingots, there was also
Material Storage Areas the storage of cut and finished ingots awaiting shipping. These can be seen in photos DSCN1920
and DSCN1922. At the Bakers North facility, an overflow material storage area was observed
along its west side (seen in photos DSCN1927-fDSCNI928). This area was observed as
miscellaneous storage for waste and product samples.
Page 4 of 6

Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the
nature and extent), and pollutants off -site
Process Operations -
Furnace, Rolling,
ATI operated several baghouses at the Bakers facilities for air pollution control. These units
forming (including air
were typically located outdoors with silt sacks or barrel in place for the collecting of particulate
pollution control
materials. One of these baghouse areas can be see in photo DSCN1914.
equipment areas)
Storm drains throughout the site are used to collect stormwater and direct it to the primary
cooling water pond (often by way of a retention or water quality pond). At the Bakers North
Storm drains
facility, Storm drain inlets were observed along the south side of one of the process buildings.
Some of these inlets, seen in photos DSCN1933-DSCNI934, were observed unprotected and
with exposure to furnace dust and other particulates.
Some potential housekeeping concerns were observed throughout the site. In the waste bin
Housekeeping
staging area near the southwest corner of the Bakers South facility, the waste bins used for the
storage of SWARF material were observed with seepage discharging to the storm drain system
(seen in photos DSCN1924-DSCNI925).
Outdoor storage of fluid material was observed in various area throughout to the site. Per the
Fluid
facility's SPPP, any bulk storage of liquid materials of 55-gals or greater require secondary
Storage/Secondary
containment. Photograph DSCN1926 shows a hazardous waste storage area at the Bakers South
Containment
facility. Although the drums were observed on pallets off the ground, no secondary containment
was observed in this area.
The stormwater runoff throughout the site can be directed to either one of the three outfalls to
the stream or to one of the internal water quality ponds at the site. At the Bakers North facility,
stormwater runoff can be directed either directly to a stormwater only outfall (Outfalls 92 and
Best Management
#3) or to the commingled outfall (Outfall #1) by way of the primary cooling water pond. At the
Practices (BMPs)
Bakers South facility, there are internal use ponds in place to collect stormwater runoff for reuse
at the facility or to direct water to the primary cooling water pond. These internal ponds include
Water Quality Pond 2 (photo DSCN1912), Water Quality Pond 1 (photo DSCN1915),
Detention Pond 1 (photo DSCN1916), and Detention Pond 2 (photo DSCN1921).
Various waste storage areas were observed throughout the site. In the areas near the process
buildings, roll off bins (seen in photos DSCN1923-DSCNI925) and process waste including
spend furnace rods (seen in photo DSCN1919) were observed. Additionally, a haz waste storage
Disposal/Waste
area was observed near the southwest corner of the Bakers South facility (seen in photo
Handling Areas
DSCN1926). In this area, waste was stored in a sealed bin and in 55 gal drums. Some of the
drums in this area were located on pallets off the ground and underneath shed cover. Other
drums, some containing metal shavings, though also raised off of the ground were not staged
underneath the covered area.
Vehicle and Equipment
Between the two processes buildings at the Bakers North facility, there was an equipment
Maintenance Areas
storage and maintenance area (seen in photos DSCN1931-DSCN1932).
Page 5 of 6

6. OUTFALL, STORMWATEROBSERVATIONS
Outfall, Stormwater
Discharge & Receiving YES NO
Water
Describe: According to the facility's SPPP, there were three NPDES outfalls
Number & location of
discharging to the stream. Two of these outfalls (Outfall 93 seen in photos
stormwater
DSCN1929-DSCN1930 and
discharge(s)/outfall(s)
X
Outfall 92 seen in photos DSCN1935) are stormwater only outfalls and discharge
consistent with the
directly to the tributary. The third outfall, Outfall Al seen in photo DSCN1936, is
SPPP
a commingled stormwater and process cooling water outfall. This outfall
discharges from the primary cooling water pond to Dry Folk.
Evidence of off -site
accumulation of
Describe: Although the tributary was not observed during the inspection,
pollutants observed in
X
observation was made of the various outfall which did not show evidence of
discharged pollutants.
receivingwater
Other potential
discharges off -site
X
Describe: No exterier outfalls aside from those identified in the SPPP were
(through outfalls not
observed during the inspection.
included in the SPPP)
Non-stormwater
X
Describe: During the inspection, the inspection team did not observe any
discharge observed
unauthorized non-stormwater discharges.
Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the facility area
as necessary:
At the end of the site visit, an exit conference was held with facility personnel were the following observations provided:
• SPPP Observations
o No date was not provided on the SPPP documenting the most recent revision
o All of the stormwater pollutant sources were not provided in the plan. Specifically, the site plan did not
identify all of the material storage areas, baghouse areas, or the SWARF waste bins.
o The site plan did not include of the stormwater management features like the storm drain inlets
• Records Observations
o Due to time restraints and the availability of records during the inspection, an initial assessment of the
facility records was not proved during the closing. This analysis would be performed upon recent of the
requested documents.
Site Observations
o Some housekeeping concerns were observed at the site including sediment trails from baghouse areas, roll
off dumpsters, and storm drain inlets with significant pollutant exposure.
Page 6 of 6

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DSCN1912.JPG
Attributes
File Name
DSCN1912.JPG
Description
Photograph of Water Quality Pond 2. The outfall for this pond is an internal outfall leading to the
facility's primary pond and outfall.
Latitude
N 35° 01' 09.10"
Longitude
W 80' 36' 50.77"
SW-NCS000329-032019 Page 2 of 26

DSCN1913.JPG
F
L-V
Attributes
File Name
DSCN1913.JPG
Description
Photograph of an outdoor storage area near Water Quality Pond 2.
Latitude
N 35° 01' 07.72"
Longitude
W 80' 36' 52.85"
SW-NCS000329-032019 Page 3 of 26

DSCN1914.JPG
Attributes
File Name
DSCN1914.JPG
Description
Photograph of one of the baghouses at the Bakers South facility. Some sediment trailing was
observed from this area leading to one of the storm drain inlets
Latitude
N 35° 01' 06.70"
Longitude
W 80' 36' 44.15"
SW-NCS000329-032019 Page 4 of 26

DSCN1915.JPG
CEO
Attributes
File Name
DSCN1915.JPG
Description
Photograph of Water Quality Pond 1.
Latitude
N 35° 01' 07.43"
Longitude
W 80' 36' 43.39"
SW-NCS000329-032019 Page 5 of 26

DSCN1916.JPG
--
Attributes
File Name
DSCN1916.JPG
Description
Photograph of Detention Pond 1.
Latitude
N 35° 01' 05.77"
Longitude
W 80' 36' 39.14"
SW-NCS000329-032019 Page 6 of 26

DSCN1917.JPG
Attributes
File Name
DSCN1917.JPG
Description
Photograph of the outdoor storage area at the Bakers South facility which discharges to Detention
Pond 1.
Latitude
N 35° 01' 05.54"
Longitude
W 80' 36' 39.32"
SW-NCS000329-032019 Page 7 of 26

DSCN1918.JPG
5. v O M1 Survey, USDA Farm Service Agency
Attributes
File Name
DSCN1918.JPG
Description
Photograph of the outdoor storage area at the Bakers South facility which discharges to Detention
Pond 1
Latitude
N 35° 01' 05.58"
Longitude
W 80' 36' 39.57"
SW-NCS000329-032019 Page 8 of 26

DSCN1919.JPG
Attributes
File Name
DSCN1919.JPG
Description
Photograph of an outdoor storage area at the Bakers South facility for spend furnace rods.
Latitude
N 35° 01' 02.75"
Longitude
W 80' 36' 47.06"
SW-NCS000329-032019 Page 9 of 26

DSCN 1920.J PG
Attributes
File Name
DSCN1920.JPG
Description
Photograph of an outdoor product storage area at the Bakers South facility.
Latitude
N 35° 01' 02.93"
Longitude
W 80' 36' 47.11"
SW-NCS000329-032019 Page 10 of 26

DSCN 1921.J PG
Attributes
File Name
DSCN1921.JPG
Description
Photograph of Detention Pond 2. Rip Rap structures observed in the pond and at the inlets were
not identified in the site plan.
Latitude
N 35° 01' 02.99"
Longitude
W 80' 36' 53.56"
SW-NCS000329-032019 Page 11 of 26

DSCN1922.JPG
Attributes
File Name
DSCN1922.JPG
Description
Photograph of the outdoor storage area along the west side of the Bakers South facility.
Latitude
N 35° 01' 03.23"
Longitude
W 80' 36' 53.48"
SW-NCS000329-032019 Page 12 of 26

DSCN 1923.J PG
Attributes
File Name
DSCN1923.JPG
Description
Photograph of the roll of dumpsters for swarf at the Bakers South facility.
Latitude
N 35' 01' 03.52"
Longitude
W 80' 36' 53.33"
SW-NCS000329-032019 Page 13 of 26

DSCN1924.JPG
0
Attributes
File Name
DSCN1924.JPG
Description
Photograph of the area around the two swarf roll off dumpsters. Although the dumpsters were
covered, they were not water tight and were observed with leakage. The leakage from the
dumpster, which was observed with metal shavings and sediment, appear to drain towards
nearby storm drain inlet.
Latitude
N 35' 01' 04.75"
Longitude
W 80' 36' 52.87"
SW-NCS000329-032019 Page 14 of 26

DSCN1925.JPG
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Attributes
File Name
DSCN1925.JPG
Description
Photograph of the area around the two swarf roll off dumpsters. Although the dumpsters were
covered, they were not water tight and were observed with leakage. The leakage from the
dumpster, which was observed with metal shavings and sediment, appear to drain towards
nearby storm drain inlet.
Latitude
N 35' 01' 04.69"
Longitude
W 80' 36' 52.86"
SW-NCS000329-032019 Page 15 of 26

DSCN1926.JPG
Attributes
File Name
DSCN1926.JPG
Description
Photograph of a waste storage area at the Bakers South facility. The waste drums (blue drums)
were located under shed cover with all but one observed with covers on. The gray drums, which
were for metal shavings and other facility waste, were not located under the shed cover. Some of
these drums were observed with an unknown fluid in them.
Latitude
N 35' 01' 04.80"
Longitude
W 80' 36' 53.33"
SW-NCS000329-032019 Page 16 of 26

DSCN1927.JPG
Attributes
File Name
DSCN1927.JPG
Description
Overflow storage area in the southwest corner of the Bakers North facility.
Latitude
N 35° 01' 10.70"
Longitude
W 80' 36' 56.41"
SW-NCS000329-032019 Page 17 of 26

DSCN1928.JPG
Attributes
File Name
DSCN1928.JPG
Description
Photograph of the material storage area along the southwest side of the Bakers North facility.
Latitude
N 35' 01' 10.87"
Longitude
W 80' 36' 56.63"
SW-NCS000329-032019 Page 18 of 26

DSCN 1929.J PG
cM
Attributes
File Name
DSCN1929.JPG
Description
Photograph of Outfall 3.
Latitude
N 35' 01' 22.46"
Longitude
W 80' 36' 42.11"
SW-NCS000329-032019 Page 19 of 26

DSCN 1930.J PG
Attributes
File Name
DSCN1930.JPG
Description
Photograph of the stormdrain outlet leading to Outfall 3.
Latitude
N 35° 01' 22.48"
Longitude
W 80' 36' 42.10"
SW-NCS000329-032019 Page 20 of 26

DSCN 1931.J PG
01
Attributes
File Name
DSCN1931.JPG
Description
Photograph of the outdoor storage area at Baker Plant North near Outfall 2.
Latitude
N 35° 01' 17.50"
Longitude
W 80' 36' 43.52"
SW-NCS000329-032019 Page 21 of 26

DSCN1932.JPG
Attributes
File Name
DSCN1932.JPG
Description
Photograph of the outdoor storage area at Bakers Plant North near Outfall 2.
Latitude
N 35' 01' 17.78"
Longitude
W 80' 36' 43.99"
SW-NCS000329-032019 Page 22 of 26

DSCN1933.JPG
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Attributes
File Name
DSCN1933.JPG
Description
Photograph of a stormdrain inlet at the Bakers North facility near the Helium tanks. The inlet was
located in a gravel area and was unprotected from potential sand and gravel runoff. Additionally,
some staining was observed in this area from the process.
Latitude
N 35° 01' 19.29"
Longitude
W 80' 36' 46.08"
SW-NCS000329-032019 Page 23 of 26

DSCN 1934.J PG
- 7
Attributes
File Name
DSCN1934.JPG
Description
Photograph of a gravel area at the Bakers North facility near the main pond. Some staining from
furnace dust was observed in this area.
Latitude
N 35° 01' 17.21"
Longitude
W 80' 36' 44.68"
SW-NCS000329-032019 Page 24 of 26

DSCN 1935.J PG
Attributes
File Name
DSCN1935.JPG
Description
Photograph of Outfall 2.
Latitude
N 35° 01' 16.74"
Longitude
W 80' 36' 41.99"
SW-NCS000329-032019 Page 25 of 26

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