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HomeMy WebLinkAboutNCS000041_SPPP_20090130STORMWATER DIVISION CODING SHEET NCS PERMITS PERMIT NO. DOC TYPE ❑ FINAL PERMIT ❑ MONITORING REPORTS ❑ APPLICATION DPP JP COMPLIANCE Sly ❑ OTHER DOC DATE ❑ ZD YYYYM M DD Storinwater Pollution Prevention Plan Stormwater Pollution Prevention Plan Clariant Corporation Mount Holly West Plant January 30, 2009 Revision 5 page 1 of 15 January 30, 2009 Stormwater Pollution Prevention Plan Certification I certify that the stormwater outfalls at the Clariant Corporation Mount Holly West Plant have been evaluated for the presence of non-stormwater discharges. Kenneth L. Golder President, USA Clariant Corporation Revision 5 page 2 of 15 January 30, 2009 Stormwater Pollution Prevention Plan I. SFFE PLAN A. B. General Location Map A general location map of the Mount Holly West (MHW) Plant is shown in Attachment 1. All of the site's stormwater outfalls discharge into the Catawba River. The stormwater outfall locations are as follows: Outfall 001 Outfall 003 Outfall 004 Outfall 005 Outfall 006 Outfall 007 Latitude: 35.17.45 Latitude: 35.17.42 Latitude: 35.17.38 Latitude: 35.17.35 Latitude: 35.17.32 Longitude: 81.00.21 Longitude: 81.00.23 Longitude: 81.00.24 Longitude: 81.00.25 Longitude: 81.00.26 Combines with public stormwater and is discharged through Outfall 006 Narrative Description Storage Practices Materials are stored in bulk storage tanks and in a variety of portable container types. a. Bulk Storage Tanks Product, intermediate, and raw material storage tanks are located in diked tank farms. There are six main tank farm areas: Plant 1, Plant 2, Plant 3, Plant 4, Plant 5, and Area 190. There are also two dedicated tank storage areas: one for ethylene oxide (EO) and one for propylene oxide (PO). Also, there are four petroleum -based fuel storage tanks located throughout the site; these are not in diked areas but they are double -walled tanks. b. Containers Solid and liquid materials are stored in a variety of container types. The most common are 275-gallon totes and 55-gallon drums. There are also other drum sizes as well as several types of bags, supersacks, and buckets. Container storage locations can be virtually anywhere on site, the most common being inside the Warehouse, inside of or outside near any of the production buildings (Plant 1, Plant 3, Plant 4, Plant 5), and outside along the site roadways. Materials in bags or other containers that could be damaged by rain are not stored outside. Hazardous wastes are stored separately in designated areas. Loading and Unloading Activities Materials are loaded into and/or unloaded from rail cars, tank trucks, and trailers. There are four rail car loading/unloading areas: Plant 1, Area 190, Plant 4 CFA/SI, and EO/PO. There are seven tank truck loading areas: Plant 1, Plant 2, Plant 3, Plant 4, Plant 5, Plant 4 IPF, and Area 190. All of these areas utilize loading racks designed for that purpose. Containers are loaded into trailers at Warehouse loading docks and Plant 5 loading docks. 3. Outdoor Process Areas Revision 5 page 3 of 15 January 30, 2009 Stormwater Pollution Prevention Plan Process areas are mostly covered or inside of buildings. There is some process piping outside that is connected to the storage tanks in the diked areas. Also there is some transfer piping outside between different buildings. Some notable examples of outside process piping are wastewater piping and transfer Iines from Plant 1 to Plant 4. Also, the entire wastewater treatment plant (WWTP) is located outside. 4. Dust and Particulate Generating Processes The SCI process in Plant 3 generates a solid flake product. Several processes use powders or solids as raw materials. All solid material handling is done inside the process buildings: Plant 3, Plant 4, and Plant 5. 5. Waste Disposal Practices The MHW Plant has well -established practices that assure the proper handling and disposal of waste. The following is a brief description of how the most common waste types are managed. a. Trash Generic non -hazardous trash is placed trashcans or small dumpsters, which are collected daily. The trash is emptied daily, compacted, and placed into a roll -off container. The roll -off container is removed weekly by a local waste company and taken to a Clariant-approved Subtitle D landfill. This trash category includes empty chemical bags, chemical gloves, non -regulated samples, non -regulated filter pads, foodstuffs, non -recyclable office materials, and miscellaneous household trash. b. Chemicals All chemical wastes are placed in compatible DOT containers. Only personnel with proper training are authorized to handle chemical waste. The person who generates a waste obtains the samples and information necessary to characterize the waste. They then submit the waste, along with a completed Waste Inventory Sheet (WIS), to the Waste Department. The Waste Department stores the waste in a designated storage area. The Waste Department then determines the proper classification and disposal method for the waste. Non -hazardous chemical waste is typically disposed in a Clariant-approved Subtitle D landfill. Hazardous waste, and some non -hazardous waste, is sent to a Clariant-approved permitted TSDF. All chemical waste is tracked by manifest. C. Recyclable Materials Various types of containers are staged throughout the MHW site for the collection of recyclable materials. These materials include paper, cardboard, wood, and scrap metal. Scrap metal is cleaned prior to recycling and evaluated by the Waste Department to ensure that it meets the definition of scrap metal and is managed properly. d. Universal Waste Revision 5 page 4 of 15 January 30, 2009 Stormwater Pollution Prevention Plan Universal wastes such as bulbs, batteries, and mercury -containing devices are collected as they are generated, secured in appropriate containers, and stored in a designated area. Universal wastes are periodically picked up and taken to a Clariant-approved facility. e. Soil The MHW Plant has an excavation permit process that ensures that all excavated soil is properly evaluated, managed, and disposed. The Waste Department determines the classification of the soil and the appropriate disposal options. If necessary, soil samples are sent to a certified lab for analysis. if a designated Solid Waste Management Unit (SWMU) is involved, proper documentation is developed. Any soil that is determined to be hazardous waste is sent to a Clariant-approved Subtitle C landfill or other TSDF, as appropriate. f. Wastewater Residuals Sludge from the WWTP is collected in a sludge storage building. Approximately every two weeks, it is Hauled off and land applied according to the site's Land Application permit. Sometimes if there is no permitted field available the sludge is disposed in a Clariant-approved Subtitle D landfill- C. Site Map Attachment 2 is a map of the industrial areas of the MHW site. All items required to be in the site map are either shown in Attachment 2 or are described below in this section. Storage of Materials Bulk tank storage locations are shown on the site map. Outside areas most commonly used for storage of materials in containers are also shown on the site map. Inside storage areas are not specifically indicated, other than designated hazardous waste storage areas. Inside storage is mainly in the Warehouse. 2. Disposal Areas There are no disposal areas on site. All wastes are accumulated, stored, and sent off site for disposal. 3. Process Areas Process areas are indicated on the site map. The main areas are: Plant 1 (Building 151), Plant 3 (Building 153), Plant 4 (Building 154), Plant 5 (Building 155), Pilot Plant (Building 159), and WWTP (Area 163). 4. Loading and Unloading_ Areas Loading and unloading areas are shown on the site map. Drainage Structures Revision 5 page 5 of 15 January 30, 2009 Stormwater Pollution Prevention Plan The MHW Plant has a network of stormwater sewers and industrial sewers. The sewers are generally separate systems, although there are locations where stormwater can be transferred into the industrial sewers. The stormwater system includes not only sewers but also sumps, curbs, containment walls, a retention pond, and outfall valves. All of these structures are shown on the site map. 6. Draina a Areas for Each Outfall The approximate drainage areas for each outfall are indicated on the site map. Note that Outfall 006 receives a substantial portion of its drainage from public streets and neighborhoods; these off -site sources of drainage are not on the site map. Activities Occurring in Each Drainage Area Activities throughout the M14W Plant have already been described and are indicated on the site map. Buildiniz Locations Building locations are shown on the site map. 9. Existing BMPs Some of the more significant Best Management Practices (BMPs) are as follows: a. Secondary containment is provided for the bulk storage of chemicals. b. Loading and unloading operations are conducted in paved areas that drain into the industrial sewer. C. Secondary containment is provided around the truck scale. d. Process areas utilize written procedures for all chemical -handling tasks. e. Containment curbing is provided for most of the site, to provide additional protection for areas having the greatest risk of loss of containment. £ Outfall valves and containment area valves are normally kept closed. Only authorized employees open them after inspection of the stormwater. g. Outfalls and containment structures are inspected regularly. h. All employees who work in chemical process areas receive training in operating procedures, spill prevention, and spill response. i. The site has an emergency response team (EAT) on site, trained in spill containment and mitigation. j. Major construction contractors are required to have an erosion control plan. k. 5S program has been implemented to clean and organize work areas. 10. Impervious Surfaces Most of the active portion of the site has impervious surfaces. All chemical storage, handling, loading, and unloading activities are in impervious areas, except the following areas are gravel: Area 190, Plant 4 CFA/SI, and EO/PO rail car loading areas; the storage area for roll -off containers of non -hazardous waste drums; and the WWTP. Revision 5 page 6 of 15 January 30, 2009 Stormwater Pollution Prevention Plan 11. 12. Drainage Area Surfaces The percentage of each drainage area that is impervious can be determined from the following estimates: a. Outfall 001 b. Outfall 003 C. Outfall 004 d. Outfall 005 e. Outfall 006 f. Outfall 007 � h1l) Note that (i) the Outfall 006 estimates include only the on -site drainage areas but not the public drainage areas and (ii) the Outfall 007 estimate is based only on the truck dike that drains into it. Potential Pollutants Permeable area: 146,800 ft2 Permeable area: 83,700 ft2 Permeable area: 91,200 ft2 Permeable area: 45,000 ft2 Permeable area: 176,400 ft2 Permeable area: 0 ft2 Impervious area: 177,600 ft Impervious area: 74,300ft2 Impervious area: 43,800ft2 Impervious area: 5,700ft2 Impervious area: 327,700ft2 Impervious area: 1,400ft Normally, no pollutants are discharged through any of the MHW Plant's stormwatcr outfalls. The potential pollutants described in this section could be present only in the event of an unplanned release that enters the stormwater sewer system. a. Outfall 001 Most of the chemical process areas on site are within the stormwater drainage area for this outfall. There are more than 400 chemical raw materials and products on site, and virtually all of them could potentially enter Outfall 001. Some of the major categories include: fuels, heat transfer fluids, fatty alcohols, fatty acids, alkylphenols, EO & PO, caustic, acids, amines, resins, phenols, xylene, formaldehyde, DEET, and biocides. Detailed lists are available in the site's annual Tier 2 report or in the chemical inventories for each building. b. Outfall 003 Drainage to this outfall is mainly from Area 190, Plant 1, and the roads south and east of the Warehouse. There is also the possibility of receiving overflow from the Outfall 001 drainage area or from the industrial sewer system. Because virtually any chemical on site could find its way to Outfall 003 from at least one of these source areas, the list of potential pollutants is the same as for Outfall 001. C. Outfall 004 This outfall receives overflow from the Outfall 003 drainage area, the Outfall 005 drainage area, and some on -site roads. While there are some chemicals unlikely to flow all of the way to Outfall 004 (e.g. EO & PO), the chemical transport vehicle traffic on the on -site roads and the proximity several loading areas makes it possible for the most of the chemicals described for Outfall 001 to be considered potential pollutants at Outfall 004. Also, gravel can potentially wash down from any of several sloped areas into Outfall 004. Revision 5 page 7 of 15 January 30, 2009 Stormwater Pollution Prevention Plan d. Outfall 005 The WWTP is the main activity within the drainage area for this outfall. Potential pollutants from the WWTP include treated wastewater, wastewater residuals (sludge), liquid polymers, defoamers, phosphoric acid, and urea. Occasionally some non -hazardous waste is stored near the trash compactor, which is also located in the Outfall 005 drainage area. Outfall 006 The drainage area for this outfall includes Plant 5 and the road west of the WWTP. There are potentially more than 100 chemical raw materials and products in the Plant 5 area, and virtually all of them could potentially enter Outfall 006. Some of the major categories include: fatty alcohols, fatty acids, alkylphenols, caustic, acids, amines, resins, phenols, xylene, and formaldehyde. Detailed lists will be available in the site's annual Tier 2 report or in the chemical inventory for Plant 5. Wastewater from the WWTP is another possible pollutant. Outfall 006 also receives all stormwater flow from Outfall 007. And also, Outfall 006 receives a large volume a stormwater from the public stormwater system. Clariant has no knowledge of potential pollutants from sources outside of its control. f. Outfall 007 Outfall 007 receives stormwater from the back parking lot, the lawn beside the Administration Building, the roads around the parking lot, and the truck scale. The main potential for pollutants comes from the truck scale. Most chemicals on site are weighed on the scale at some point, so again, with some exceptions, most of the potential Outfall 001 pollutants are also potential Outfall 007 pollutants. D. Sinificant Spills There have been two significant releases to the Catawba River within the past three years. 1. The first occurred on August 21, 2007, when a rupture disk operated in Plant 3, releasing the contents of a reactor. The reactor contained a mixture of raw materials used for manufacturing a soap ingredient, Hostapon SCI 65. Approximately 10,000 lbs were released, with an estimated 500 lbs landing in the river. The raw materials in the reactor were coca hydrogenated fatty acid (550/6), Hostapon SI 57% (450/0), and zinc oxide (0.03%). A film of this material developed on top of the river. The incident was reported to the National Response Center and several local agencies, and the material was cleaned out of the river within 24 hours. Note that this incident did not actually involve the site's stormwater system, although it did cause materials to enter the river. The site's containment systems functioned effectively to prevent any materials landing on the site property from entering the river through stormwater. The incident report can be found in Clariant's Incident Management System (IMS) in the Lotus Notes database, report number 20070045. 2. The second release was discovered on June 3, 2008. A Plant 5 chemical sump pump malfunctioned and overflowed into the storm sewer during a rain event. The storm Revision 5 page 8 of 15 January 30, 2009 Stormwater Pollution Prevention Plan sewer leads to Outfall 006. Residue samples taken from the storm sewers and the outfall showed evidence of sodium hydroxide and n,n-dimethyl alkyl (C12-C1 S) amines. These are both production materials that were used in Plant 5 prior to the _ incident discovery. A working committee was convened and as a result there have d been numerous improvements made to the Plant 5 sewer system. Another incident identical to the one that occurred is no longer a feasible event. The committee remains active, with several more stormwater system improvements planned. Reports of minor spills can also be found in IMS. U. STORMWATER MANAGEMENT PLAN A. Feasibility Study 1. Storage Areas a. Bulk Storage There is no identified need to change methods of operation to reduce exposure of bulls storage tanks to stormwater. Although product and raw material storage tanks are exposed to stormwater, they are all located within secondary containment. Fuel tanks are not located in secondary containment but they are double -walled tanks that are inspected regularly. b. Container Storage Some chemical containers are stored inside the Warehouse where they are not exposed to stormwater. However, many chemical containers are stored outside where they are exposed to stormwater. Except for Plant 5, stormwater runoff from container storage areas is controlled procedurally through the use of the outfall valves. In the event of a release from a container, all applicable outfall valves will be closed and the stormwater will be contained and/or diverted to the industrial sewer. (The stormwater valves are normally kept closed most of the time). Plant 5, instead of relying on outfall valves, is set up so that containers are only stored in locations that drain to the chemical sewer, which does not discharge to any outfall. Sitewide efforts in 2006 and 2007 successfully eliminated several outside container storage areas. Further improvements have been identified to provide covers and/or containment for several remaining outside container storage areas. In particular, a large contained storage area is eventually planned for the former Plant 2 location. 2. Material Handling erations All loading (and unloading) areas are exposed to stormwater. These loading areas have a variety of secondary containment provisions, ranging from some areas that have the capability of containing a full tanker load of material, to other areas that do not have secondary containment at all. Stormwater runoff from loading areas is controlled procedurally through the use of the outfall valves. All loading activities are attended. In the event of a release during loading activities, all applicable outfall valves will be closed and the stormwater will be contained and/or diverted to the industrial sewer. (The stormwater valves are normally kept closed most of the time). The feasibility of Revision 5 page 9 of 15 January 30, 2009 Stormwater Pollution Prevention Plan providing additional protection by constructing full secondary containment for all of the loading areas will continue to be evaluated. One notable improvement planned for 2009 is the installation of an automated pump to pump out the Plant 4 tanker loading sump into the contained Plant 4 tank farm dike area. Manufacturing Operations There is no identified need to change methods of operation to reduce exposure of manufacturing processes to stormwater. Virtually all process operations take place either inside buildings or within contained areas. 4. Fueling Operations The only fueling operations occur at the gasoline tank, where a few gasoline -fueled vehicles are fueled. Fueling occurs relatively infrequently. The fueling area is exposed to stormwater and it does not have secondary containment. Stormwater runoff is controlled procedurally by ensuring that the Outfa11001 valve is closed while fueling. The feasibility of providing additional protection by constructing secondary containment or relocating the gasoline tank is being evaluated. B. Secondary Containment Schedule 1. Bulk Storage of Liquid_ Materials Bulk storage areas already have adequate secondary containment. Containment areas are either pumped to the industrial sewer or drained to the stormwater sewer. Drainage to the stormwater sewer is controlled by manual valves that are normally kept closed. Only W WTP employees are authorized to open these valves and release accumulated stormwater. Before releasing any stormwater, WWTP personnel visually observe the water for color, foam, staining, sheens, and evidence of dry weather flow. Records of each inspection and stormwater release are documented and kept in the WWTP. There is a written WWTP procedure detailing the steps described here. 2. Storage of SARA 313 Water Priority Chemicals The following SARA 313 water priority chemicals are stored on site: benzyl chloride, formaldehyde, hydrochloric acid, maleic anhydride, naphthalene, phosphoric acid, propylene oxide, sulfuric acid, and toluene. Chemicals stored in bulk are within secondary containment areas. Chemicals stored in containers are generally stored in the Warehouse but could be stored in any inside or outside storage area. Inside storage areas, including the Warehouse, have adequate secondary containment. Outside storage areas do not have local secondary containment. Secondary containment is provided by the outfall valves as described earlier, and also by the Plant 5 layout as described earlier. A schedule for providing local secondary containment for additional protection will be developed. 3. Hazardous Substances Bulk storage areas already have secondary containment as described above. Containers of hazardous substances could be stored in any inside or outside storage area. Inside storage areas have adequate secondary containment. Outside storage areas do not have Revision 5 page 10 of 15 January 30, 2009 Stormwater Pollution Prevention Plan local secondary containment. Secondary containment is provided only by the outfall valves as described earlier, and also by the Plant 5 layout as described earlier. A schedule for providing local secondary containment for additional protection will be developed. C. BMP Summary The MHW Plant currently uses numerous BMPs to prevent and/or minimize the potential for pollutants to reach surface waters. These BMPs have been developed and implemented based on many years of experience, and have taken into consideration the types, volumes, and locations of potential pollutant sources. A long history of stormwater monitoring data has affirmed the effectiveness of these BMPs. l . Secondary containment is provided for the bulk storage of chemicals. 2. Loading and unloading operations are conducted in paved areas that drain into the industrial sewer. 3. Secondary containment is provided around the truck scale. 4. Process areas utilize written procedures for all chemical -handling tasks. 5. Containment curbing is provided for most of the site, to provide additional protection for areas having the greatest risk of loss of containment. 6. Outfall valves and containment area valves are normally kept closed. Only authorized employees open them after inspection of the stormwater. 7. Outfalls and containment structures are inspected regularly. 8. All employees who work in chemical process areas receive training in operating procedures, spill prevention, and spill response. 9. The site has an emergency response team (ERT) on site, trained in spill containment and mitigation. 10. Major construction contractors are required to have an erosion control plan. II1. SPILL PREVENTION AND RESPONSE PLAN A. Assessment of Potential Pollution Sources Potential pollution sources are described in detail in the Sections I and II of this Stormwater Pollution Prevention Plan (SPPP)_ All areas of chemical operations, loading, and storage are potential pollution sources. All chemicals handled on site are potential pollutants. In relative terms, the most significant potential sources are those that do not have complete secondary containment in the immediate vicinity. These areas include process sewers, certain loading areas, and certain outside chemical container storage areas. B. Responsible Personnel Spill prevention and response is the responsibility of all employees working inside the plant. Some specific responsibilities are detailed within the following two sections of this SPPP. C. SPW Prevention Spill prevention is accomplished by the use of standard operating procedures. All employees who handle chemicals are responsible for following established procedures. Spill prevention is also effected by properly maintaining equipment in good working condition. Area owning Revision 5 page 11 of 15 January 30, 2009 Stormwater Pollution Prevention Plan departments and Maintenance are jointly responsible for ensuring the mechanical integrity of equipment designed to containment chemicals or prevent spills. D. Spill Control Many spills can be controlled without a major "response" effort if proper procedures are followed to utilize the site's secondary containment facilities_ Employees who handle chemicals are primarily responsible for ensuring proper use of such facilities in the event of a spill. Waste Department personnel also have a role in managing certain spill containment areas. Area supervision is responsible for ensuring the adequacy of the procedures and containment in their areas. D. Spill Response Spill response procedures, equipment, training, and responsibilities are described in detail in the site's Emergency Response Plan (ERP) and Spill Prevention Control and Countermeasures (SPCC) Plan. These plans are not duplicated within this SPPP, but they are incorporated by reference. Both referenced plans describe in detail the responsibilities for initial response, small spill response, and major spill response. IV. PREVENTIVE MAINTENANCE AND GOOD HOUSEKEEPING A. Stormwater System IIISpecWQns System Inspections All stormwater systems are formally inspected twice per year. These inspections are documented using a checklist. These inspections provide a means of systematically assessing the condition of stormwater facilities. Completed checklists are filed in the Waste Department. 2. Daily Inspections WWTP operators visually inspect all stormwater outfalls and stormwater containment areas at least once per shift. These inspections are intended to identify any obvious or critical problems. Correction of Deficiencies If a deficiency is noted during an inspection, the owning department is notified and becomes responsible for ensuring that the necessary repairs are completed. The Environmental Team Leader is responsible for any revisions to this SPPP. Resolution of corrected deficiencies will be noted on a subsequent inspection checklist. B. Process Equipment Inspections Mechanical Integrity Inspections In accordance with the site's preventive maintenance and mechanical integrity programs, each production area works with Maintenance to assure that all critical Revision 5 page 12 of 15 January 30, 2009 Stormwater Pollution Prevention Plan process equipment in their area is inspected at a designated frequency. Inspections are scheduled and documented using the SAP computer database and the equipment files. 2. Daily Inspections Each production area conducts visual inspections of their equipment at least once per shift. These inspections are intended to identify any obvious or critical problems. Correction of Deficiencies Deficiencies identified during inspections are addressed and ultimately corrected. Area supervision is responsible for ensuring that deficiencies in their area are resolved. C. Housekeepin.2 1. Daily Housekeeping All areas of the site maintain housekeeping on an ongoing basis. Areas are kept neat and organized and are washed down as necessary. Some of the daily housekeeping responsibilities of each area include: a. Maintaining clean floor and ground surfaces. b. Regular pickup of trash and waste materials. C. Maintaining clean conditions around trash dumpsters. d. Ensuring that dust and powder levels near building vents are kept to a minimum. e. Proper labeling of all containers. f. Prompt cleanup of spills. g. Maintaining adequate aisle space. h. Storing containers out of the path of common traffic routes. i. 5S program has been implemented to clean and organize work areas. 2. Monthly Inspections Monthly safety and housekeeping inspections are conducted by each department. These inspections are documented on a checklist. Each department is responsible for correcting deficiencies identified by these inspections. V. EMPLOYEE TRAINING A. Training Schedule All employees whose jobs have the potential to affect stormwater are trained at least once per calendar year. B. Training Content Annual training includes: proper spill response and cleanup procedures, housekeeping practices, maintenance and inspection requirements, spill containment facilities and procedures, and a review of the stormwater sewers and stormwater outfalls at the site. Additional topics of emphasis are often added each year. Revision 5 page 13 of 15 January 30, 2009 Stormwater Pollution Prevention Plan C. D. _esignated Person Responsible for Training At the MHW Plant, the person responsible for implementing SPPP training is the Environmental Team Leader. Currently that person is: Gil Insley Telephone 704-822-2218 Cell Phone 704-301-4598 V1. RESPONSIBLE PARTY A. Overall SPPP The Environmental Team Leader is responsible for the overall coordination, development, implementation, and revisions to the SPPP. B. Management Support The Plant Leadership Team (PLT) is responsible for overseeing the implementation and compliance with the SPPP. The PLT also ensures that the necessary financial and technical resources are provided as needed to support the SPPP. C. Engineering & Maintenance The Engineering and Maintenance staff is responsible for implementing the preventive maintenance and mechanical integrity related tasks identified in the SPPP, as well as for implementing any equipment modifications or repairs that may become necessary. D. Operations Operations employees are responsible for completing daily tasks such as equipment visual inspections. They are also responsible for ensuring that their activities are in accordance with the requirements of this SPPP. Operations supervision is responsible for initiating corrective actions related to equipment or procedures in their areas. E. All Employees All employees who work inside the industrial potion of the MHW site are responsible for: Following the requirements of this SPPP. 2. Responding to spills appropriately based on their level of training and their familiarity with the material spilled. Taking all reasonable precautions to prevent the contamination of stormwater. VU. PLAN AMENDMENT This SPPP will be updated as necessary. As a minimum, the SPPP will be updated annually. Additionally, the SPPP will be updated whenever: A. There is a change in design, construction, operation, or maintenance which has a significant effect on the potential to discharge contaminated stormwater to the Catawba River. Revision 5 page 14 of 15 January 30, 2009 Stormwater Pollution Prevention Plan B. There is a release of a reportable quantity of a hazardous substance or oil, if the released material enters the Catawba River. C. A critical need for an immediate improvement is identified. VM. FACILITY INSPECTION PROGRAM Stormwater system inspections are conducted semi-annually as required by the site's permit. Stormwater discharge monitoring is also conducted semi-annually as required. Copies of all inspection records and monitoring results are kept on file in the Waste Department. IX. IMPLEMENTATION All documentation required by the site's permit is kept on file for at least five years. Revision 5 page 15 of 15 January 30, 2009 STORAGE TANKS CLARIANT CORPORATION - MOUNT HOLLY WEST PLANT 7/8/2009 Tank Volume Area Tank 9 (gallons) Current Contents Plant 1 161 12,000 out of service 162 12,000 out of service 163 8,000 empty 171 3,000- empty 172 8,000 empty 173 8,000 empty 174 8,000 empty 177 8,000 out of service Plant 2 261 6,000 OLEIC ACID 262 6,000 empty 263 6,000 OLEIC ACID 264 12,000 TALL OIL FATTY ACID 267 12,000 empty 268 12,000 empty 271 12,000 empty 272 12,000 out of service 273 12,000 RECOVERED OCETYL ALCOHOL 274 10,000 GENAMIN C 050 277 12,000 PROPYLENE GLYCOL 281 12,000 LIAL 111 282 12,000 empty 283 10,000 empty 285 12,000 empty 286 12,000 empty 287 12,000 empty 288 12,000 empty Plant 3 341 12,000 out of service 342 12,000 DIETHYLAMINE (DEA) 343 6,000 DEA, TEA, & WATER 344 4,500 DEET 351 12,000 DEET & IMPURITIES 352 6,000 DEET & NEMTA 353 6,000 WATER, DEET, & IMPURITIES 361 12,000 DEET 362 12,000 out of service 363 6,600 out of service 371 20,000 NIPACIDE BIT 20 DPG 372 15,000 out of service 373 6,000 DIPROPYLENE GLYCOL 381 20,000 out of service 382 15,000 NIPACIDE BIT 20 --- 6,000 NITROGEN (not diked) Page I of) Page 3 B. Any stormwater runoff from the affected areas at the site shall be in accordance with any applicable permit requirements and regulations promulgated by the Environmental Protection Agency and enforced by the N.C. Environmental Management Commission. It shall be the permittee's responsibility to contac the Division of Water Quality to secure any necessary stormwater permits o other approval documents. 2. A. Any mining process producing air contamination emissions shall be s jec# to the permitting requirements and rules promulgated by the N.C. Env onmental Management Commission and enforced by the Division of Air Quality. B. During mining operations, water trucks or other means thaty be necessary shall be utilized to prevent dust from leaving the permitted ea. 3. A. Sufficient buffer (minimum 50 foot undisturbed) shall bey6aintained between any affected land and any adjoining waterway or wetland tcyprevent sedimentation of that waterway or wetland from erosion of the affected and and to preserve the integrity of the natural watercourse or wetland. B. Any mining activity affecting waters of the State/,waters of the U. S., o`r wetlands shall be in accordance with the requirements d regulations promulgated and enforced by the N. C. Environmental Manage ent Commission. 4. A. Adequate mechanical barriers including b not limited to diversions, earthen dikes, check dams, sediment retarding st ctures, rip rap pits, or ditches shall be provided in the initial stages of any land isturbance and maintained to prevent sediment from discharging onto adjacqbt surface areas or into any lake, wetland or natural watercourse in proximity tcythe affected land. B. All drainage from the affected are,A around the mine excavation shall be diverted internal to said excavation or ino the stilling basins. C. Mining activities shall occur s indicated on the Site Plan dated July 30, 2007 and the supplemental inf ation received by the Land Quality Section on September 24, 2/ed October 24, 2007. 5. All affected area bound.74 acres) and mining permit boundaries (18.68 acres) shall be permanently mthe site on 140-foot intervals unless the line of sight allows for larger spacinls. 6. The angle for grad9d slopes and fills shall be no greater than the angle, which can be retained by veg tive cover or other adequate erosion control measure, structure, or device. In an event, exposed slopes or any excavated channels, the erosion of which may caus ff-site damage because of siltation, shall be planted or otherwise provided with gro d cover, devices or structures sufficient to restrain such erosion. STORAGE TANKS CLARIANT CORPORATION - MOUNT HOLLY WEST PLANT 7/8/2009 Tank Volume Area Tank -4 (gallons) Current Contents Plant 4 401 13,000 ETHYLENE OXIDE 402 13,000 ETHYLENE OXIDE 403 13,000 PROPYLENE OXIDE 456 30,000 HOSTAPON IPF 457 30,000 HOSTAPON SI 458 30,000 C-1218 459 5,000 out of service 462 12,000 CORSAMINE PCD 463 12,000 OKERIN 11044 464 12,000 EMERSOL 136 465 8,000 MPG 1820 466 8,000 DECYL ALCOHOL 467 8,000 CAUSTIC SODA 50% 468 8,000 BENZYL ALCOHOL 469 13,000 NITROGEN (not diked) 472 12,000 CO-1214 ALCOHOL 473 12,000 C-3 HEADS - 474 12,000 COCONUT FATTY ACID 475 8,000 SORBITOL 476 8,000 TRIDECYL ALCOHOL 477 8,000 CASTOR OIL 478 8,000 2-ETHYL HEXANOL 479 8,000 POE 20 SORBITAN 482 12,000 C-3 HEADS 483 12,000 HOSTAGLISS EHS 484 12,000 V-1100 485 12,000 2-BUTOXY ETHANOL 486 12,000 PELARGONIC ACID (TEMP-40) 487 12,000 CORSAMINE PCD 488 5,000 RECOVERED PELARGONIC ACID 489 5,000- DIESEL FUEL Plant 5 ST-01 16,000 MONOCHLOROACETIC ACID ST-02 12,000 COCONUT FATTY ACID IV 1 MAX ST-03 16,000 CAUSTIC 50% ST-05 12,000 empty ST-06 12,000 empty ST-07 16,000 SAFEWING MP III ECO ST-08 16,000 empty ST-09 16,000 ISONONANOIC ACID ST-10 16,000 empty ST-11 16,000 ARKOPAL N-090 ST-12 16,000 empty ST-13 16,000 HOSTAGLISS 1603 ST-14 16,000 HOSTAPUR SAS-30 Page 2 of 3 Page 4 7. The affected land shall be graded so as to prevent collection of pools of water that are, or likely to become, noxious or foul. Necessary structures such as drainage ditches or conduits shall be constructed or installed when required to prevent such conditions. 8. Existing vegetation or vegetated earthen berms shall be maintained between the mine and public thoroughfares whenever practical to screen the operation from the public. 9. Sufficient buffer (minimum 50 foot undisturbed except for a section of the haul road shall be maintained between any excavation and any mining permit boundary to pro adjacent property. 7 10. A. No on -site disposal of refuse or other solid waste that is generated out (de of the mining permit area shall be allowed within the boundaries of the mini permit area unless authorization to conduct said disposal has first been ob ined from both the Division of Waste Management and the Land Quality Se on, Department of Environment and Natural Resources. The metho of disposal shall be consistent with the approved reclamation plan. B. Mining refuse as defined by G.S. 74-49 (14) of The Mining ct of 1971 generated on -site and directly associated with the mining ctivity may be disposed of in a designated refuse area. All othe�wast products must be disposed of in a disposal facility approved by the is' n of Waste Management. No petroleum products, acids, solven or their storage containers or any other material that may be considered hazar ous shall be disposed of within the permitted area. C. For the purposes of this permit, the Division of and Resources considers the following materials to be "mining refuse" (in a dition to those specifically listed under G.S. 74-49 (14) of the N.C. Mining A of 1971): 1. on -site generated land clearing d ris 2. conveyor belts 3. wire cables 4. v-belts 5. steel reinforced air hoses 6. drill steel D. If mining refuse is to be per nently disposed within the mining permit boundary, the following inf mation must be provided to and approved by the Division of Land Resour s prior to commencement of such disposal: 1. the approxim a boundaries and size of the refuse disposal area; 2. a list of ref a items to be disposed; 3. verificati that a minimum of 4 feet of cover will be provided over the refus - 4. ve ' cation that the refuse will be disposed at least 4 feet above the - easonally high water table; and, Area Area 190 WWTP Misc STORAGE TANKS CLARIANT CORPORATION -- MOUNT HOLLY WEST PLANT 7/8/2009 Tank Volume Tank 9 (gallons) Current Contents ST-15 16,000 PROPYLENE GLYCOL ST-16 16,000 PROPYLENE GLYCOL ST-17 16,000 SAFEWING MP IV LAUNCH ST-18 16,000 SAFEWING MP IV LAUNCH ST-19 16,000 SAFEWING MP IV LAUNCH ST-20 16,000 SAFEWING MP IV LAUNCH ST-21 16,000 SAFEWING MP IV LAUNCH ST-22 16,000 SAFEWING MP 1V LAUNCH ----- 16,000 out of service ----- 16,000 out of service ----- 16,000 out of service ST-01 35,000 HOSTAPUR SAS 30 LS ST-02 16,000 HOSTAPUR SAS 60 LS ST-03 35,000 empty . ST-04 35,000 out of service ST-05 35,000 HOSTAPUR SAS 30 LS ST-06 35,000 HYDROCHLORIC ACID ST-07 35,000 HYDROCHLORIC ACID ST-08 35,000 out of service TK-03 10,000 WATER TK-04 6,000 WATER ----- 13,000 NITROGEN (not diked) ----- 13,060 NITROGEN (not diked) ST-63-01 6,000 out of service ST-63-02 6,000 out of service ST-64-FUEL-1 500 DIESEL FUEL (emergency generator) ------- 500 DIESEL FUEL (fire water pump) ------- 500 DIESEL FUEL (fire water pump) ST-64-FUEL-4 500 DIESEL FUEL (emergency generator) 1 Page 3 of 3 Page 5 5. verification that a permanent vegetative groundcover will be established. 11. An Annual Reclamation Report shall be submitted on a form supplied by the Department by February 1 of each year until reclamation is completed and a 12. The operator shall notify the Department in writing of the desire to delete, modi or otherwise change any part of the mining, reclamation, or erosion/sediment co roI plan contained in the approved application for a mining permit or any approved re ision to it. Approval to implement such changes must be obtained from the Departure prior to on -site implementation of the revisions. 13. The security, which was posted pursuant to N.C.G.S. 74-54 in the for of a $15,400.00 Irrevocable Standby Letter of Credit, is sufficient to cover the operati as indicated in the approved application. This security must remain in force for thi permit to be valid. The total affected land shall not exceed the bonded acreage. 14. A. Authorized representatives of the Division o/he tl History shall be granted access to the site to determine the significant archaeological resources. B. Pursuant to N. C. G. S. 70 Article 3, "The Unan Burial and Human Skeletal Remains Protection Act," should thr any person in his employ encounter human skeletal remains, otification shall be provided to the county medical examiner anrchaeologist, North Carolina Division of Archives and History.