NCS000330_INSPECTION REPORT_20190603

--..:,- -
NORTH CAROLI NA
Department of Environmental Qual

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO,
CS OC�C� 2j�
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
❑ APPLICATION
COMPLIANCE
❑ OTHER
DOC DATE
❑ Z.O�q D(o U 3
YYYYM M DD

J��SO SrO
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
?" REGION 4
�r ATLANTA FEDERAL CENTER
�F nor 61 FORSYTH STREET
�TA4 P110l ATLANTA, GEORGIA 30303-8960
MAY 2 8 zDi9
CERTIFIED MAIL 7017 1450 0000 7973 2762
RETURNED RECEIPT REQUESTED
Mr. Joe Hinkle REcj7I:r
E14S Manager JUN 0 3 2019
ATI Allvac — Monroe Plant
2020 Ashcraft Road OEW-LANE) Q11ALIrr
Monroe, North Carolina 29110 STOR%VATl R PERiV.,ffJ-1NG
Re: Compliance Evaluation Inspections
ATI Allvac -- Monroe Plant, Monroe, North Carolina
NPDES Permit No. NCS000330 -
Dear Mr. Hinkle:
On March 21, 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 — Monroe Plant located at 2020 Ashcraft Road in Monroe, NC. The purpose of the
CEI was to evaluate ATI Allvac — Monroe 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
NCS000330.
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 feceiving this letter by calling [phone] or by sending an
email to lauren. Larcia( ncdenr. 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].
Sincerely,
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
Enclosures
cc: Ms. Annette Lucas
NCDEQ
Intemet Address (URL) • http:1/www,epa,gov
Recycled/Recyclable . Printed wdh Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

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Industrial.Stormt*eF permit jwas performed as both a joibVihspection wlth,the state andia.tralning opportumtyrfor state;lnspectors
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Page 1 of 7

*11' FORM
O
,Ptu
34°59'2.78"NLongitude
80030'5$.57"W
�G!
;coordinates ti,K r�:4
7E
'Recetv�ng
, •
{
Water(sj:or ;
Richardson Creek
Site
65 Acres
Wea#b'er�,�',
>t .
Partly Cloudy,
•MS4'.
Acreage
+.�
+ Con„dition
Does t_he s�tecdischarge ,
Permit
" +Discharge
;' SIC
3356,
to
d x « _,
�pol[utantszcontnliuhng�;
,Applicati©n•
02/24/ 14
�y x� �°
�:Code(s),
3341
Jb (d)�I�4 or
k
No
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Ito the+receiving stream
a
NIA
- .
- r p
��
TIVIDL�waters
16 a • .k : s n
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! t FORMATION
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a•rn. , ...
" Ni
SPPP on -site (obtain a copy of the plan) .Section A
Copies of the SPPP and SPCC Plans were provided during the inspection in an email response after
X
the inspection.
Site Description Section A(1)(b)
X
A site description. was provided in the provided plan.
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
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
X
dust/particulate control erocesses, s ecifical I , the locations of the various baghouses.
Site Maps (general location map and site specific map) Sections A(1)(a & e)
X.
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
In the plan provided in the subsequent email to the inspection, a completed form with the spill
X
history was provided. This spill history extended back to 10/2009.
SPPP Certification Section A(1)(e)
In the plan provided in the subsequent email to the inspection, a completed form summarizing the
X
annual u dates to the plan was provided. The most recent update to the plan was 08/2017.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
The provided site plan provided information on when feasibility studies were to be performed. In this
X
section of the plan, a description of the resulting actions from the feasibili study was provided.
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
The site's SPCC plan included tables of the various above ground tanks, the available secondary
X
containment, and the inspection and testina re uirements.
Stormwater BMP Summary Section A(2)(c)
In the plan provided in the subsequent email to the inspection, in addition to the specific section for
13MPs there was information in the section pertaining to the outfalls about the measures in place at
X
the outfalls. During the inspection, additional areas of rip rap were observed in the conveyances
leading to outfall 5 which was not included in the plan.
Spill Prevention & Response Procedures (SPRP) Section A(3)
In the SPCC plan provided during the inspection, spill response procedures were included for above
X
round tanks. • .
Page 2 of 7

POLLUTION,. „P e.
b
SPPP TUPICS(Part Il)':�*
Preventative Maintenance and Good Housekeeping Program Section A(4)
In the plan provided in the subsequent email to the inspection, there was a section outlining the
housekeeping and maintenance program implemented at the site. Additionally, these measures were
included in the inspection checklist used at the facility. Neither the plan nor checklist included all of
X
the observed BMPs at the site. Specifically, the rip rap drainage features and check dams were not
identified on the checklist. Additionally, the plan did not establish schedules for the required
measures.
Employee Training Section A(5)
The site plan requires annual training for facility personnel responsible for oil -handling operations.
X
Identify the Responsible Party Section (A)(6)
X
SPPP Modified or Update to Current Conditions Section (A)(7)
In the plan provided in the subsequent email to the inspection, a table of the annual updates was
X
provided. The most recent update of the plan appeared to have been from 08/2017.
Schedule and Procedures for Routine Inspections Section A(8)
The SPCC plan provided during the inspection and the SPPP provided in the subsequent email
included the requirement for quarterly inspections and included the checklist that was to be used. This
monthly inspection form listed the various areas requiring inspections (which included areas like the
X
tanks areas and outfalls). The documents did not include all of the observed BMPs at the site.
Specifically, the rip rap drainage features and check dams were not identified on the checklist.
ATI Allvac operates a meta] alloy facility in Monroe, NC which produces a variety of nickel and titanium allows.'This`
facility operates 24 hours per day, seven days per week and employees approximately 1300 employees. These products are
produced through a variety of processes including melting, casting, forging, rolling, sawing, and grinding. Additionally, -the,
facility performs maintenance operations at this facility. The primary raw material used at the site is raw metal which is'
received by 55 gal drum. Products from the process are ingots of various alloys which can be sent either to customers or to
the Bakers facilities for further processing. In addition to the storage of metal materials at the site, there is also fuel and
chemical storage.
The Monroe facility currently operates with three NPDES permits: an industrial stormwater permit, NCS000330; a
conventional wastewater permit for cooling water, NC0045993; and a pretreatment permit, CM-15. For its industrial
stormwater permit, AT] operates six stormwater outfalls which discharge stormwater from six different drainage areas. The'
facility has a seventh drainage area which discharges to the stream by way of the cooling water ponds and is covered under
the conventional permit. For its six stormwater outfalls, the facility had identified Outfall 42 as the representative outfaliTf r
which benchmark monitoring is performed.
w
RECORD4.
-_7
Record Review, '
)(ES
,
Representative on -site
X
Records of the Implementation of the SPPP Part H Section A(9), Part III Section D(6)
Samples of records from 2017 and 2018 were available and reviewed.
X
Records of Maintenance and Housekeeping Programs Part H, Section A(9)
X
Page 3 of 7

RECORD REVIEW
Record,Revaew. t ,' '`
YES
N6
N/E�'
v
The facility maintained an electronic database for maintenance activities. Samples of maiiiteriance -
.
and housekeeping measures were requested 'and provided. The, provided records showed the facility
performing maintenance on drainage features, outfalls, and performing cleaning and debris removal.
Records of Routine Inspections Part 11, Section A(9)
Inspection records were reviewed back through 2017 and showed the facility performing monthly
X
inspections. With the exception of the records from 05/2017 and 07/20I 7, the inspection records were
available for review.
Records of Employee Training Part 11, Section A(9)
According the facility personnel, employee training is provided to all plant personnel. A database of
X
the employees and their training status was maintained by the facility. These records were requested
for 2018 and appeared to meet the necessa requirements.
Records for the Approval of Representative Outfalls . Part III Section D(5)
During the permit renewal process in 2009, the facility submitted a request to use Outfatl 2 as the
X
representative outfall for the b stormwater outfalls. This approach was approved by the state in the
cover letter for the permit renewal.
Records of Benchmark Monitoring Part 1I, Section B & D, Part III Sections D, & E(1)
Benchmark monitoring data was reviewed for 2017 and 2018. The provided data appears to show
sampling being performed quarterly. According to facility personnel, aside from pH sampling which
is performed by facility personnel, the testing of samples is performed by an outside lab. A review of
X
the monitoring records shows the appropriate holding times and analysis methods were being met.
The monitoring data also shows that since 2017 the facility has experienced regular exceedances of
zinc benchmark.
Records of Qualitative Monitoring Part 111 Section C, Part III Section D
Qualitative monitoring records were included with the periodic benchmark monitoring. Although
benchmark monitoring was only required at Outfall 2 (the representative outfall), quarterly qualitative
X
monitoring was still required for all outfalls. Review of the available monitoring data showed the
facility performing the qualitative monitoring at all of the outfalls at the frequency of the benchmark
monitoring.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
Benchmark data since 2017 shows single exceedances for COD (0712017) and nickel (01/2018). For
zinc, benchmarks have been consistently exceeded since 2017 except for the 05/2018 sampling event.
In response to the COD and nickel exceedances, the facility provided its applicable Tier 1 response.
X
For the zinc exceedances, which have not seen two consecutive events without exceedances, there
was no documented tiered response. Additionally, due to the duration of the zinc exceedances, the
facility should have been performing monthly benchmark monitoring (instead of semiannually).
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.
Page 4 of 7

a
Pollutant Sources.N
Tyr
Note location, quantitative desc1 ion, desiigny slue 0& deficiencies (nC Ll Ing'the4.:nature'
Pay tfr�� -� § ,
',extent},wand+pollutantsroi�f
b
and site
According to facility personnel, the majority of the raw materials received at the facility are received
i
by truck primarily in 55 gal drums. The primary raw material use at the site is raw metal. Once the
material in the drums is used, the drums are retained at the site for use at finished end of the process.
:RaW MIteHil°and;
This includes storage or waste material from the process and the storage of historical process
Prod—t A Storaget
samples.
Areas
The products from the facility are typically shipped as metal ingots. Product storage areas were
observed in various areas throughout the site including along the west side of the site. Photographs
DSCN 1938-DSCN 1940 show the outdoor storage area within the Outfal14 drainage area.
Although the majority of the process operations at the facility are located inside of the various
buildings, there were some process equipment and operations that are performed outdoors.*
-Outdoor Process
Baghouses were used for the control of particulate air emissions. The baghouses were typically
;Operations '
located outside of the buildings and collected particulates in either 55 gal drums or sacks (seen in
photos DSCN 1954-DSCN 1955 and DSCN 1957). A washing station was observed nearthe northwest
corner of the site. This area, seen in photo DSCN 1970, had drain inlets used to collect water and
direct it to the wastewater treatment plant.
Stormwater throughout the site could be collected in storm drains throughout the site (seen in photos
Storm ,drains
DSCN 1950-DSCN 1954, DSCN 1956, and DSCN 1959) and directed to the various drainage features
to the outfalls or the wastewater treatment facility.
According to the facility's site plan, periodic inspections of housekeeping measures are performed.
This includes inspecting for accumulated dust, debris, and metal turnings in storage areas. During
the inspection, areas of debris and dust accumulation were observed in a few of the storage areas on
site. Examples of these include the waste storage areas along the south side of the site (seen in photos
DSCN 1945 and DSCN 1957). In these areas, evidence of dust, metal, and other dumpster material
accumulation was observed accumulated.
Housekeepiagi 3
In addition to the storage areas, some of the stormwater managing features were observed 'm need of
1
some additional housekeeping measures. One of the storm drain. inlets near one of the baghouse
areas, seen in photo DSCN 1954, was observed with accumulated sand, gravel, and white °powder
r;
material. In the stormwater conveyance through the middle of the site, seen in photo DSCN 1968,
significant amounts of sediment/dust debris were observed. The facility was observed as having'
installed check dams in this conveyance near the storm drain inlets to help manage sediment.
y
Sediment around the check dams had accumulated to the height of the check dams resulting in a
reduced effectiveness of the control measure and therefore in need of maintenance.
Several above ground storage tanks were in place at Allvac's Monroe facility. Most of these tanks
were place in areas with secondary containment. One of these areas can be seen in photo DSCN1958.
'
According to facility personnel, the two containment structures in this area are connected and tied to
L quid Storage'
the wastewater treatment facility. Evidence of past spills were evident in this area. Photo DSCN 1969.
Tarihs:
shows a fueling station and the secondary containment around the above ground tank. This
containment structure was observed with a capped drain valve. According to facility personnel,
accumulated liquid in the secondary containment structure can be pumped to either the storm drain
or to the wastewater treatment plant depending on its contents.
Page 5 of 7

.-W .d
1 /
_ •.'rT�i —•y ,r71 •--^ ^�.•'_.', h �•— Y ,'-,r'+r _?T"F---s•-.
Note'location quantitative descripfion;+'deSignu�ss�e; �O&MydeficiEncxes (�ncludlag t11C�natur'e
'Fallntant Sources Y =
e5cteitt pollutan#s{off=site •gig' . �. 3
,=and _
'•^"-' "~'
A variety of BMPs were implemented to help manage sfoi'inwater runoff from the site- Several of
!the
§tormwater conveyances and outfalls throughout the site were observed with rip rap installed to
minimize erosion and sediment entrainment. Examples of this can be seen in photos DSCN1939-
�zt
DSCN 1940, DSCN 1946, DSCN 1961-DSCN 1962, and DSCN 1964. Some stonnwater drainage
BettjManagement'
features were observed without any rip rap and erosion prevention measures (see photo DSCN1960
Practices (BIVIPs}°
of outfall 3). A few of the drainage features appeared to have been subjected to significant sediment
runoff and as a result had multiple rock check dams installed to better manage the runoff. This was
observed in the drainage feature to Outfall 5 (seen in photo DSCNI967) and concrete conveyance
running east/west near the middle of the site (seen in photo DSCN 1068). These additional BMPs
were not identified in the site plan.
Waste material storage was observed in various locations at the site" Along the south side of the site,
""
spent furnace rods were observed in one of these storage areas along the south end or the site (seen
in photo DSCN1941). This'location was near an erosion feature (seen in photo DSCN1942)
5 ..". •.
potentially discharging off site and not addressed in the facility's site plan. Additional waste storage
area can be seen in photos DSCN 1944-DSCM 1945, DSCN 1949, and DSCN 1966.
Some of the waste material at the site was stored in various areas in 55 gal drums. Near the northeast
DispbsalVWasle, .,
corner of the site, the facility has a storage area for empty drums that will be utilized for storage (see
$and6ag A;Uas" 'r
photo DSCN1965). Flux material from the furnaces was observed in various areas of the site being
stored in open top 55 gal drums (see photos DSCN 1955 'and DSCN 1957).
vt:'
Along the south side of one of the furnace buildings, the facility was observed with open top
• .".:- .:.`.: = �d.'
dumpsters in place receiving spent brink from the furnace rebuilds. One of the dumpsters, seen in
photo DSCN1948, was observed with a cloudy white discharge. No best management practices
a2ecared in place which the runoff believed to reach one of the facili 's unmonitored outfalls.
6. OUTFALL, STORMWATEROBSERVATIONS
Outfa11,1'St6rmwater =1
L4 .' �I
Discharge & „�. 1YES hNQ
.. -_. it = t '� - • 1 ,S s 1
Recervin •Water u1 �. '. "
x J
�,- k -',u ;. {� •. _ 7 kiyp �j �fI.�.Afir' y ��' T a�e�'F
, , �� ., ;t, •: ?r FI q
y - 1 - b♦ � +• -. Y # ,r111,,1 >, { F.
�,� � '1• _ :�: ��.:� __��'° �,g � _..r�` �"
-.
Describe: The inspection team observed six external outfalls associated with its
stormwater permit during the inspection. Outfall 1 was located on the east side of
.'x •
the site and can be seen in photo DSCN 1963. Outfall 2, located on the east side of
the property, is the outfall currently designated as the representative outfall for the
'{
site. This outfall can be seen in photos DSCN 1961-DSCN 1962. According to facility
Nymber&:location,
�;
personnel, benchmark samples are pulled towards the end of the rip rap channel.
;-1 -. vg r : •
—.ri — I .
Outfall 3 can be seen in photo DSCN1960. Outfall 4 was observed discharging near
i3ischarge(s)/outfall(s)''.,
X
':'
the southwest corner of the site. This outfal1, seen in photo DSCN 1937, was observed
cons it `
discharging water with a distinct red color during the inspection. This appeared to be
cSPp-pv } '^�
:'•�''
qualitatively unique from the other outfalls. The collection ditches leading to Outfall
4 can be seen in photos DSCNl939-DSCN1940. Outfall 5, which is near the
= _ . - : ;� . •' ; .
northeast corner of the site, can be seen in photo DSCN 1964. Outfal16 was observed
__
�. r •y ; �._ ,; ; :
in photo DSCN 1947 and discharged to the south side of the site. This outfall was fed
• �'
by the drainage ditch seen in photo DSCNN 1946.
Page 6 of 7

1('+
DISCHARGE • OBSERVATIONS-
TER
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_
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- -- - - - - - --- - - --
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vide a ofoff=`site -
§MC Tr TMR i. A. 4 '..
sacumulatton�of
poll�antsol;served::
X
Describe: No evidence of off -site accumulation was observed during the inspection.
, 1rece in g,watOr,
Describe: Additional erosion features were observed near the southwest side of the
pOthIn tenhal.:
site near a waste material storage area. Two erosion feature, seen in photos
_discharges;offa�te
DSCN1942-DSCNI943, were observed leading to the southern property bourder.
;k(through:outfalls_"not
X
,A a,,e �;
The feature in photo DSCN 1942 was observed with rip rap in place signaling that
+included, '�the
the facility was aware of discharging from this point implementing best management
SPPP)Y.=
practices to manage the discharge.
Non=storiiywater.'
Describe: During the inspection, the inspection team did not observe any non-
�discliarge observed
X
stormwater discharges discharging to stormwater outfalls.
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 The site map included in the site plan did not include all of the potential pollutant sources and BMPs
o The plan provided neither signed nor included documentation of it being reviewed and updated annually
• records Observations
o The inspection records provided by the facility did not include evaluations of the storm drain inlets
o Records of stormwater BMP maintenance were not available. Specifically, the facility was unable to
provide records of rip rap repair and storm drain cleaning and maintenance.
• Site Observations
o Some housekeeping concerns were observed at the site including sediment trails to storm drain inlets
o A significant difference in appearance was observed between the selected representative outfall (Outfall
#2) and Outfall #4 suggesting that there could be pollutants unique to Outfall 4 and therefore not .
appropriately represented by Outfal1 #2.
o There was neither labeling nor information in the site plan pertaining to which outfall the various storm
drains throughout the site drain,
Page 7of7

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Attributes
File Name DSCN1937.JPG
Description Photograph of Outfall 4.Outfall is not the determined representative and monitored outfall at
this facility. This outfall, which drains the west side of the facility, was observed with a distinct red
color indicative of entrained iron.
Latitude N 34" 59' 01.06"
Longitude W 80° 31' 08.73"

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Attributes
File Name DSCN1939.JPG
Description Photograph of an outdoor storage area in the drainage area for Outfall 4.
Latitude N 34' S9'01.21"
Longitude W 80* 1' 08.63"

DSCN1940.JPG
Attributes
File Name
D5CN1940.JPG "
Description
Photograph of It
N 34° 59' 01.70"
Latitude
Longitude
W 80' 31' 08.85"
utfall 4.

DSCN1941.JPG
Attributes
File Name I D—SCN1941JPG
Description Photograph of the storage area in the southwest corner of the site. This area was primarily used
for waste and spend furnace rods.
Latitude N 34" 59' 00.54"
Longitude W 80° 31' 02.35"

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DSCN1942.JPG
Attributes
File Name DSCN1942.JPG
-
Description Photograph of an unaccounted for outfall near the southwest carrier of the site near the scrap
! storage area.
Latitude _N 34' 59' 00.07"
Longitudes W 80' 31' 01.70"

Attributes
File Name DSCN1943JPG
Description Photograph of an erosion feature on the southside of the site resulting in an additional potential
outfall.
Latitude I N 34" 58' 59.99"
Longitude _I W 800 31' 01.02"

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DSCN1944.JPG
11&
_ Attributes
File Name DSCN1944.JPG __-- - -- -
Description Paved area on the south in the drainage area to Outfall 6. Some dust and sand ac' mu ation were
observed in this area which is used for waste storage.
Latitude N 34° 59' 00.02"
Longitude W 80° 31' 01.01"

°Tx DSCN1945.JPG

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File Name
DSCN1947.JPG
Description
Photograph of Outfall 6.
Latitude
N 34' 58'59.81"
Longitude
W 80* A 5811'
DSCN1947JPG
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Attributes
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DSCN1948.]PG
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Attributes
File Name DSCN1948.JPG _
Description Photograph of an open dumpster on the southside of the facility. The dumpster was used for
catching spend refractory brick from the furnaces. Some of the refractory material was observed
outside of the dumpster and a liquid stream was observed discharging from the dumpster with
residuals from the spent brick (the white sheen).
Latitude N 34° 58' 59.68"
Longitude___ 80' 30' 57.37"

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D5CN1949.1PjG
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Attributes
File Name DSCN1949.JPG
Description Area along the south side of the site near the underground storage tank. Some spend material
storage was observed in this area including open buckets (seen at the bottom of the photo) with
accumulated stormwater and process material.
Latitude N 34' 58' 59.48"
Lonsitude W 80" 30' 55.18"

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Attributes
File Name i DSCN1951.JPG
,07
Description Photograph of a storm drain along the south side of the site behind the melt building. According
to facility personnel, this storm drain discharged to lower pond which was part of the waste water
treatment system.
Latitude N 34' 58' 59.15"
Longitude I W 80° 30' 52.51"

DSCN1952.JPG
Attributes
File Name DSCN1952.JPG _
Description Photograph of a storm drain along the south side of the site behind the melt building. This drain
appeared to have roof drains and three additional pipes discharging into it. According to facility
personnel, this storm drain discharged to lower pond which was part of the waste water
treatment system.
Latitude N 346 58' 59.11"
Longitude W 80° 30' 52.47"

DSCN1953.JPG
Attributes
File Name I D5CN1953JPG
Description Photograph of a storm drain inlet near the cooling water pumps. According to facility
this storm drain leads to the lower pond and the wastewater treatment system.
Latitude N 34' 58'59,13"
Longitude W 80' 30' 52.12
41P.

DSCN1954.JPG
Attributes
File Name DSCN1954.JPG
Description Photograph of the storm drain inlet on the southside of the building near one of the baghouses_
Sand and white dust accumulation was observed in this area leading to the storm drain which
directs runoff to 4utfall 3.
Latitude N 34° 58' 59.21"
Longitude W 80' 30' 49.27°'

DSCN1955.JPG
0
Attributes
File Name DSCN1955JPG
Description Photographs of open top drums with flux from the process. Accumulated water was observed in
the drums potentially commingling with the flux.
Latitude N 34" 58' 58.86"
Longitude W 80° 30' 49.11"

QSCN1956.1PG

DSCN1957.JPG
Attributes
File Name DSCN1957.JPG _
Description Photograph of an outdoor drum storage area on the south side of the building. Stormwater
accumulation was observed on and in the drums. Some dust/sediment accumulation was
observed in the area around the drums.
Latitude N 340 58' 58.61" _
Longitude W 80' 30' 46.68"

DSCN1958.JPG
Attributes
File Name DSCN1958.lPG
Description Photograph of a storage tank area on the south side of the site. Some oil acc-u-m- 'ulation was
observed along the containment structures in this area. There were two secondary containment
structures in this area around the tanks with one draining to the other which was connected to
the wastewater treatment system.
Latitude N 34° 58' 58.21" - - -
Longitude ; W 80' 3a' 43.94"

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DSCN1959.1PG'
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Attributes
File Name 1 DSCN1959.JPG
0
Description Photograph of a storm drain inlet near the southeast corner of the site. This inlet was located
near one of the facility baghouse behind the GPM process.
Latitude N 34° 58' 58.10"
Longitude I W 80° 30' 36.67"

DSCN1960.JPG
Attributes
File Name I DSCN1960.JPG
Description Photograph of Outfall 3 near the southeast corner of the site. Rip rap and other erosion control
measures were observed in the drainage ditches leading to the outfall but none located in the
area in the photograph below the outfall.
Latitude N 34° 58' S7.47"
Loneitude W 80° 30' 33.37"

DSCN1961.JPG
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Attributes
File Name I DSCN1961.JPG
Description Photograph of Outfali 2 on the east side of the site. This outfall is the representative outfall that
has periodic benchmark monitoring. Benchmark samples are pulled from the area at the end of
the rip rap.
Latitude N 34° 59' 00.23"
Longitude I W 80' 30' 32.96"

DSCN1952.JPG
Longitude W 80' 30' 33.22" - - - - -

File Name
DSCN1963.JPG
Description
Photograph of Outfall 1 al
Latitude
N 34' 59' 02.30"
Longitude
W 80` 30' 36.02"
DSCN1963.JPG
Attributes
the east side of the site.

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- - - Attributes -- � ----- ..
File Name
D5CN1965.JPG
Description
Photograph of outdoor drum storage area near Outfall 5.
Latitude
N 34' 59' 07.09"
Longitude
W 80° 30' 38.0Z"

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DSCN1967.]PG ►Y :`_?�' -- p . re r
Attributes
File Name I DSCN1967.JPG
Description Photograph of rip rap berms leading to Outfall 5. The rip rap observed in the ditch was not
identified in the facility's site plan.
Latitude I N 34° 59' 05.95"
Longitude I W 80° 30' 38.56"

I
I
f
1
JI .�
_ Attributes
File Name DSCNl968.JPG
Description Photograph of a drainage ditch running through the middle of th—J�This e i of the ditch
was near the inlet to the storm drain inlet. Significant sand and dust was observed along the ditch
and around the storm drain inlet.
Latitude N 34' 59' 00.32"
Longitude I W 80' 30' 42.61i1

Attributes
File Name I DSCN1969.JPG
Description Photograph of a fueling area near the middle of the site. A secondary containment structure was
observed around the tank with a capped outlet. Accumulated water in the secondary
containment structure can be either pumped to the storm drain or sent to the wastewater
treatment system depending on test results.
Latitude N 340 59' 01.34"
Longitudes W 80° 30' 50.75"

DSCN1970.)PG