HomeMy WebLinkAboutNCS000096_Renewal Application_20140410CM4►~j 9Ili ]Iw .
April 3, 2014
Stormwater Permitting Program
Individual Permit Renewal
1612 Mail Service Center
Raleigh, NC 27699-1612
RoclMod
Lithium
RIDS
RE: NPDES Individual Stormwater Permit Renewal
Rockwood Lithium Inc. (formerly known as Chemetall Foote Corp)
Kings Mountain, Cleveland County, NC
Permit # NCS000096
Dear Mr. Bennett:
Please find enclosed an original and two copies of the renewal application for the
above -referenced Stormwater Permit. This permit authorizes Rockwood Lithium,
Inc. (formerly known as Chemetall Foote Corp) to discharge stormwater from its
manufacturing facility located in Kings Mountain, North Carolina.
Please note that Chemetall Foote changed its name to Rockwood Lithium, Inc. in
2012. Notice of this change has been previously provided to your office, but I
have attached another Notice for your records. The site has also added
Christian Mueller, Site Director, as an authorized signatory for all site records;
and he has signed this application. This notice has also been previously provided
with recent Annual and Semi -Annual reports.
As you will note within the text of this submittal, the Kings Mountain facility has
worked diligently during the current permit period to make improvements at its
facility that will help ensure the quality of stormwater discharge from the site; and
the company continues with these efforts as we move into the next permit period.
Should you have any questions or need additional information related to this
permit renewal application submittal, please contact me at 704-734-2694.
Regards,
Ken Brown SHE Director, North America
Ken.brown@rockwoodlithium.com
ARoc"oodCompany
NYSE F.c
Rockwood Lithium Inc.
348 Holiday Inn Drive
Kings Mountain, INC 28086
Phone:704-739-2501
www. rockwoodlithiu m.com
wj Permit Coverage
AGRenewal Application Form
WDENR National Pollutant Discharge Elimination System
Stormwater Discharge Permit
Permit Number
NCS000096
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information
*Reissued Permit will be mailed to the owner address
Owner / Organization Name:
9"^4404all d
L�.
Owner Contact:
Ra;o Raw! ��i,
Di{ro.,`�1
Mailing Address:
348 Holiday Inn Dr
Kings Mountain, NC 28086
Phone Number:
_ ►-�o y = 13,A
Fax Number:
E-mail address:
l o y - 13
Ai+4c,t LJ NorciO ���� ,brown) (�
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f`Ock..roori L : I'l,.'�,.,
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Facility/Permit Contact Information
Facility Name:
�
n _ I`D L�_W00r L;+k,., �nL
Facility Physical .Address:
348 Holiday Inn Dr
Kings Mountain, NC 28086
Facility Contact:
Mailing Address:
Ar^E A
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream
Kings Creek
Stream Class:
C
Basin:
Broad River Basin
Sub -Basin:
03-08-05
Number of Outfalls:
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes No ❑ Don't Know
( for information on these waters refer to http://h2o.enr.state.nc.us/su/Impaired Waters TMDL/ J
V CS<< A++x c L.LJ
CERTIFICATION
I certify that I am familiar with the informati contained in the application and that to the best of my knowledge and belief such
information is tru , co plete and accurat
Sig
nature Date
�.�I `i
l,�f`i5fi,an vc.lttr- S'�'C.�irGti�or
Print or type name of person signing above Title
Please return this completed renewal application form Stormwater Permitting ProgramIndividual Permit Renewal
and other required supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Date: June 1, 2012
RE: Request for Name Change on all Environmental Permits/Compliance Documents
Chemetall Foote Corp. to Rockwood Lithium Inc.
To Whom It May Concern,
Effective April 1, 2012, Chemetall Foote Corp's North American Lithium and Special
Metal businesses experienced a change -in -name to Rockwood Lithium Inc. This
change -in -name is for brand awareness and marketing purposes only, and does not
reflect a change in ownership of the company. All details concerning the business have
remained the same as a result of this change, except the noted change -in -name.
As a result of this change, the company will be required to update its environmental
permits and other regulatory documentation. With this letter, I hereby request that such
change be made on behalf of the company.
My thanks for your help in assisting us with this request.
Best Regards,
Ronald A. France, CFO
Rockwood Lithium Inc.
Rockwood Lithium Inc.
348 Holidw, Inn Dri-�e
ARod poodCompany Kings Mountain, NC 28086
■'�`�\'���' 7 Phone: 704-739-2501
NYSE:hOC www.rackwoodlithium.com
STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Permitting
Facility Name: T" ,
Permit Number: NCS000096
Location Address: 348 Holiday Inn Dr
Kings Mountain, NC 28086
County: Cleveland
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and
implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief, true, accurate and
complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at
this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing
violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND
STORMWATER POLLUTION PREVENT19N PLAN WITH THIS CERTIFICATION.
SignatureZ�g -�
Print or type name of pei-on signing above
Date U 3)) 4
Title
SPPP Certification 10/13
SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES
STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application to be
considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Ini `'als
v
1.
A current Site Map from the Stormwater Pollution Prevention Plan. Thelocation of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2.
A summary of Analytical Monitoring results during the term of the existing permit (if your
permit required analytical sampling). Do not submit individual lab reports. The summary
can consist of a table including such items as outfall number, parameters sampled, lab
results, date sampled, and storm event data. H
3.
A summary of the Visual Monitoring results. Do not submit individual monitoring reports.
The summary can consist of a table including such items as outfall number, parameters
surveyed, observations, and date monitoring conducted.
4.
A summary of the Best Management Practices utilized at the permitted facility. Summary
should consist of a short narrative description of each BMP's in place at the facility. If the
implementation of any BMP's is planned, please include information on these BMP's.
5.
A short narrative describing any significant changes in industrial activities at the permitted
facility. Significant changes could include the addition or deletion of work processes,
changes in material handling practices, changes in material storage practices, and/or
/
\/
changes in the raw materials used by the facility.
6.
Certification of the development and implementation of a Stormwater Pollution Prevention Plan
for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed prior
to filing the renewal submittal, then the last years monitoring results should be submitted within 30
days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal waiting on lab results)
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Recderg Stream KingsCredt
a Outfall Latitude Longitude +% Stream Cass, C
004 35'13.147' 81°21.064' \ 1 n' �'�'� (Broad Ricer Basin) c
005A 35*12.847' 81'21.240' ,r -
�, �, > 005E 35' 12.847' 81*21.240'
N
0.5 Mi 2000 Ft
FI GURE
SITE LOCATION MAP
ERM NC, Inc. ROCKWOOD LITHIUM
ERM KI NGS M OUNTAI N, NC
NCDENR - Impaired Waters & TDML Map Page 1 of 1
NC Department of Environment and Natural Resources
Energy Mineral and Land Resources - Impaired Waters a TDML Map
Back to storrmwater Permitting (http://portal.ncdenr.org/web/wq/ws/su/maps)
NC Impaired Waters Ft TMDL Map
Enter Address: 348 holiday inn drive kings mountain Find Address Reset
Latitude (decimal degrees, N): Longitude (decimal degrees, W): Find Location
Need to convert deg.Te ,.minutes, seconds to decimal format? (http://transition.fm.gov/mb/audio/bicker/DDDA A4SS-decimaL.html)
.........................................................................................................................................................
Or, just enter coordinates in the'ADDRESS' field like this: (deg min sec) (-deg min sec), and then click'Find Address.
Need help with this map? Contact Robert Patterson at (919) 807-6375 or robert:patterson@ncdenr.gov
For detailed information about impaired waters, the 303d list, IR Categories, TMDLs, or what parameter(s) a water is impaired for: please visit the Modeling & TMDL. Unit
(http://portal.ncdenr.org/web/wq/ps/mtu/assessment) .
.................................................................................
Click on the map to see waterbody information.
**IMPORTANT** When selecting streams with overlapping layers, only the top layer will be identified. layers can be turned on/off in the legend.
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Note: Modiied(10/05/2012)
N.C. Department of Environment and Natural Resources
1601 MaiL Service Center, Raleigh, NC 27699-1601
Headquarters (Environment and Natural Resources Building): 217 W. Jones St. AM
Archdale Building: 512 N. Salisbury St.
Toll Free: (877) 623-6748
http://portal.ncdenr.org/web/Ir/sw-impaired-waters-map 04/01/2014
2014 AU Number: I AU Name:
AU Description:
11-135a Crowders Creek
From source to SR 1118
CLEVELAND Catawba River Basin
AU Length Area: AU Units: Classification:
1.9 FW Miles C
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Fair (Nar, AL, FW)
2002
1998
5
EC
Fish Community Poor (Nar, AL, FW)
2004
1998
9-53-9 Jakes Branch 5.5 FW Miles C
From source to Buffalo Creek
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Fish Community Fair (Nar, AL, FW)
2012
2014
5
EC
Benthos Fair (Nar, AL, FW)
2012
2014
11-135-2 McGill Creek 3.3 FW Miles C
From source to Crowders Creek
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Fair (Nar, AL, FW)
2011
1998
Cape Fear River Basin COLUMBUS
18-(63)a CAPE FEAR RIVER 3.8 FW Miles C;Sw
From raw water supply intake at Federal Paper Board corporation (Riegelwood) to Bryant Mill Creek
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Fair (Nar, AL, FW)
1998
1998
15-2-6-3 Friar Swamp (Council Millpond) 11.6 FW Miles C;Sw:+
From source to Big Creek
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Severe (Nar, AL, FW)
2011
2014
15-17-1-11 Juniper Swamp 6.7 FW Miles C;Sw
From North Carolina -South Carolina State Line to Grissett Swamp
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Severe (Nar, AL, FW)
2011
2014
14-27b Porter Swamp 15.2 FW Miles C;Sw
From Dunn Swamp to Lumber River
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Severe (Nar, AL, FW)
2006
1998
14-27a Porter Swamp
From source to Dunn Swamp
6.4 FW Miles C;Sw
IRCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Severe (Nar, AL, FW)
2011
1998
Wednesday, January 29, 2014 draft 2014 NC 303(d) List -Category 5 assessments requiring TMDLs Page 61 of 158
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I. I. FACILITY DISCHARGE AND DRAINAGE CONTROLS
Reference maps attached:
Site Location Map (Latitude/Longitude, Receiving Stream Identification)
NC Impaired Waters and TMDL Map
Site Plan and Drainage Patterns (Drain area acreage and impervious, flow direction)
As outlined in the enclosed Site Plan and Drainage Patterns map, stormwater within the
industrial portions of the Kings Mountain facility discharge from one of three (3) dedicated
outfalls - designated as 004, 005A, and 005B. In general, 004 receives water from the
northern portion of the site, 005A receives stormwater from the western portion of the
site, and 005B receives water from the eastern portion of the site. Stormwater in these
areas predominantly flows in a southerly direction, with some localized flow in Drainage
Areas 004 and 005B following an easterly path prior to turning south and joining Kings
Creek pursuant to National Discharge Elimination System (NPDES) permit NCS000096.
Because the industrial portions of the Kings Mountain facility have been constructed on the
remnants of an old mining site, the subsurface land is heavily laden with substantial rock
overburden, concrete slabs, and other tailings materials. While these underground
features have the potential to influence the overall hydrology at the site, the site has limited
its determination of "impervious" to only the visible surface.
DRAINAGE AREA 004
Drainage Area 004 includes run-off from some of the parking and rooftop gutters of the
new Technical Center (Bldg. No. 1),; the Resource/Records Storage Building (Bldg. No. 6);
the Battery facility (Bldg. No. 2) and lithium metal drum storage; Contractor office trailer
(Bldg. No. 20); drum and tank storage for lithium chloride and lithium bromide solutions
(liquors, wastewater, etc.); hydrochloric and hydrobromic acid storage tanks and
unloading areas; liquid argon tank; and miscellaneous dumpsters for recycle metal,
cardboard, and municipal trash. Operations in the area include battery component
manufacturing (lithium foils, alloys, anodes, etc.) and lithium chloride/lithium bromide
(halides) production. From the Resource/Records Storage Building and Contractor trailer
on the northern hillside, stormwater sheet flows in a southerly direction into earthen
ditches that feed a broadened drainage ditch (designated as Low Point P) located on the
northeastern portion of the facility. Storm drains from the production areas also drain into
this broadened ditch, flowing in a northeasterly direction. From Low Point P, the run-off
flows through a pipe under the road, where it discharges into Kings Creek at 004 (35' 13'
6"/81° 21' 5"). The total area within 004 is 10.2 acres, with 4.1 acres being impervious.
11Page
DRAINAGE AREA 005A
Drainage Area OO5A includes run-off from the Halide/Chemical Process facility (Bldg. No.
4), the Shipping Warehouse (Bldg. No. 7), the Organometallic Pilot facility (Bldg. No. 9) and
associated storage bunkers, the Lithium Storage Building (Bldg. No. 10), the Upper Shop
(Bldg. No. 11), the Maintenance complex (shop, stores, and warehouse), and the Lithium
Hydroxide process building (Bldg. No. 15). Operations in the area include shipping, pilot
plant operations and chemical storage, lithium chloride and lithium bromide brines
storage, lithium metal storage, lithium hydroxide production, and calcium carbonate
storage. Stormwater flows in a southerly direction through a series of drains from these
areas and by surface run off to discharge at Point OO5A (35' 12.847'/81°21.240').
Discharge Point 005 discharges into a natural depression referred to as the Sand Trap
(35°12.899' Latitude, 81°21,237' ). The Sand Trap is a densely vegetated, naturally -
occurring detention area within the site's property that serves as a natural buffer prior to
discharge to Kings Creek. Accessibility to this point is very limited, requiring the company
to designate its sampling outfall at OO5A rather than at Kings Creek. The total area within
005A is 22.3 acres, with 8.9 acres of impervious surfaces.
DRAINAGE AREA 005B
Drainage Area OO5B includes run-off from some of the parking and rooftop gutters of the
Technical Center (Bldg. No. 1), the open drive in front of the Halide/Chemical Process
facility (Bldg. No. 4), the Boiler House (Bldg. No. 13), the Lithium Metal Casting Facility
(Bldg. No. 3), the drum washing area at the Casting facility, the Pharmaceutical Unit (Bldg.
No. 12), the liquid Carbon Dioxide tank, and the fuel/used oil storage area. Operations in
the area include casting and hexane -washing of lithium ingots, hexane transfer activities,
drum rinsing station, lithium chloride and lithium bromide brine production, and
pharmaceutical lithium carbonate production. Stormwater sheet flows across the
production area yard in easterly fashion to a swale along the eastern fenceline of the
facility. From the Swale, stormwater flows southerly to discharge Point 005 (B35° 12.847'/
81°21.240'), which is located nearly adjacent to Outfall 005A in the Sand Trap area. Like
OO5A, stormwater discharge from 005B enters the heavily vegetated natural depression of
the Sand Trap prior to entering Kings Creek. The total area in 005B is 4.5 acres, with about
4 acres of impervious surfaces.
2 1 P a g e
1.2. BEST MANAGEMENT PRACTICES GENERAL SUMMARY
The Kings Mountain facility utilizes many Best Management Practices intended to minimize
the potential exposure to stormwater of materials used in its daily operations. The site's
current method of operations and storage practices contribute heavily to this endeavor.
The site maintains environmental management systems that are equivalent to ISO 14001,
heavily driven by written procedures established within each operating unit as well as
within the Safety, Health and Environmental Department. Many of these procedures
outline the safe manner in which to handle, package, and store the site's raw materials and
products. Because the site works with lithium metal and lithium -based materials, which
can be pyrophoric in nature, these procedures are critical to each operating unit. Site
personnel are trained on these procedures on a routine basis,
In addition to the ISO 14001 Management System and its corresponding Standard
Operating Procedures, the site has implemented other Best Management Practices to
protect the quality of its stormwater discharge:
In general, routine processes are performed within buildings or under a shedded
roof with curbed pads.
The site does not store bagged products outdoors, but has designated locations
within the warehouse or inside the respective operational area where it will be
used.
3. Due to the volume of material produced for shipment offsite, Li Cl and Li Br brine
products are stored outdoors. However, these materials are stored in plastic totes
inside a large containment system. Both the containers and the containment are
inspected on a routine basis.
4. When moving raw materials from the warehouse to operational units, forklift
personnel stay on newly -paved surfaces to minimize the potential for an incident.
In addition, raw materials and products for the new LIOH facility are transported
under a shedded cover.
S. The Shipping and Receiving Building does not have any external docks, minimizing
the opportunity for spill or releases outside the warehouse. This building remains
locked and implements sound security measures to prevent unauthorized access.
6. Secondary containment is provided for all bulk storage vessels onsite, with the
exception of the argon and carbon dioxide tanks (these do not require containment
since they are gases). The site requires documented inspection of all containments
prior to discharge, and all containment systems are inspected in accordance with
the site's SWPPP.
7. Operational processes that emit significant dust emissions are equipped with air
pollution control filters or scrubbers that are maintained in accordance with the
site's Air Quality permit.
8. All waste is now stored in a dedicated, newly constructed building that is equipped
with secondary containment. This area is inspected on a weekly basis.
9. The site manages all of its oil raw materials and oil -containing equipment in
accordance with its Spill Prevention Control and Countermeasures Plan. This plan
outlines an inspection program for these materials (including transformers, bulk oil
3 1 P a g e
tanks, and process equipment), as well as the site's general spill response
procedures.
10. Any leaks or spills not covered under the SPCC plan are cleaned up immediately in
accordance with the site's SWPPP and Emergency Control Plan. The site maintains
spill kits in those areas with high levels of material handling or storage.
11. Site maintenance conducts PM inspections on critical vessels, valves,
instrumentation, and safety devices as outlined by the manufacture or industry
standard.
12. The site conducts documented monthly housekeeping inspections within the site.
Action items from this inspection are created and followed up on.
13. The site maintains an internal "mishap" tracking program in which employees
report any safety or environmental issues (including spills, leaks, etc.) observed
onsite. These "mishaps" are investigated and addressed to an appropriate extent.
14. The site is using electronic probes to monitor and properly manage inventory levels
in its HCL tank, some of the Li Cl reactor vessels, and much of the LION process
vessels.
15. The site restricts the unloading of HCL from tanker trucks to its bulk tank to first
shift, Monday - Friday. Unloading of this material requires that a fully -trained
Halides employee be present during the entire offloading. The tank and its
corresponding pumps are located within secondary containment.
16. The site has similar restrictions for the loading of Li Cl brine into tanker trucks. This
is performed within a newly constructed secondary containment and loading rack
system. Railcar loading of brine does not occur often (maybe twice per year), but is
managed closely when required. Drip pans are used to collect material from fittings.
An inspection checklist is completed to ensure that the tanker trucks and railcars
are secured prior to transport.
17. In the drum rinse area, rainwater is collected for re -use in the rinsing process or
within the LION manufacturing process. The LION unit also re -uses rainwater
collected in its tank farm within its raw material liquor feed.
18. The pad used to store roll -offs of calcium carbonate byproduct is equipped with a
valve on the stormwater drain that can be closed in the event of a spill. Rainwater
or rinse waters from this area can also be collected and re -used in the LIOH liquor
feed.
19. The site maintains security at the site to prevent unauthorized entry, including 24-
hr contract guards at the site's main entrance. The guards require all visitors to sign -
in and await escort by an authorized site personnel. The guards perform
documented, standard rounds during off -shifts and weekends. All plant operations
occur within a perimeter fence, and all gates to the fence are monitored by video.
4 1 P a g e
1.3. SIGNIFICANT CHANGES IN INDUSTRIAL ACTIVITIES AT SITE
Since the submittal of the site's last permit application in 2009, the King's Mountain facility
has been diligent in its efforts to make changes intended to improve process efficiency and
overall site appearance. As these changes have been implemented, the site has
intentionally incorporated improvements to its overall stormwater management systems.
Specifically, the site has made the following significant changes:
1. Construction of new LICH manufacturing facility and Technical Center that houses
all administrative personnel as well as all R&D and QC lab functions.
2. As part of the Technical Building construction, the site constructed two (2)
Bioretention Ponds designed to handle all the stormwater from parking lots, roof
gutters, and other impervious surfaces associated with the Tech Building. These
ponds are managed pursuant to permit #SW3110401.
3. Renovation of old R&D and QC labs into a new maintenance complex that will allow
centralized, indoor storage of parts, oils, and other maintenance items.
4. Construction of new, state-of-the-art waste storage facility, with shed and
containment; removal of old bunkers that used to house this waste.
5. Construction of tanker loading station with containment for Li Cl brine transfers.
6. Constructed a large containment system to house large volumes of Li Cl and Li Br
Brine products in totes/drums.
7. Full-scale infrastructure improvements, including the paving of all internal roads to
reduce the risk of incident when forklifts are transporting materials from the
warehouse to operational units. This project also re -graded certain areas and re-
inforced existing stormwater conveyance structures.
8. Re -lined all site containment structures for bulk tank storages
9. Removed numerous misc storage bunkers that allowed for random storage of
materials and centralized or eliminated old inventories.
10. Replaced old Hydrochloric Acid tank (cracked liner) with new tank and added
electronic monitoring of inventory levels; also added a defoamer tote for emergency
response in the event of a release.
11. Added a containment system around the wastewater/stormwater reserve tank
located outside Halides facility.
12. Upgraded the site's hexane transfer process to reduce the frequency of material
transferred on daily basis (conversion from drums to cylinder tanks).
13. Upgraded the containment in the Casting unit's drum wash area, including recycling
of water into new LICH operation.
14. Replaced old, undersized and leaking boiler with new, larger and more efficient
boiler. Also made necessary repairs/upgrades to sump pit and discharge lines that
allowed all Boiler blowdown waters to be sent to City of Kings Mountain Municipal
Wastewater System rather than be discharged under an NPDES Wastewater Permit.
15. Eliminated need for transfer of Li Carbonate bags from warehouse to the old Upper
Shop, which required long, bumpy journey across the site over old mine roads.
5 1 P a g e
16. As part of an overall electrical improvement project, the site replaced or removed at
least eleven (11) older transformers. Each of these was tested and properly
disposed.
List of Significant Spills during the last 5 years:
1. Hydrochloric Acid - On June 4, 2012, the site experienced a release of 36% HCL
due to a crack in the acid storage tank liner. This was a new tank that had only been
in service less than 1 month. Approximately 5,500 gallons of HCL was released from
the storage tank into its surrounding secondary containment. Upon discovery, the
site immediately implemented its emergency response procedures, activating the
foam suppression system to prevent further release. The site was able to recover
the majority of the HCL, but is estimated to have lost 400 lbs to the air and around
50 gallons to the soil outside the secondary containment. This material was fully
contained onsite and was immediately cleaned up with no offsite impact to land or
water. As a result of this incident, a new liner was installed in the HCL tank,
increased internal inspections of the acid tank were established, and the
containment systems for all bulk storage tanks onsite were re -lined.
2. Calcium Carbonate -On July 9, 2013, the site experienced a release of
approximately 2000 lbs of calcium carbonate slurry from one of the roll -off
containers in which it is stored while awaiting pickup for landfill disposal. In this
case, the driver of the waste truck picked up the wrong roll -off and began lifting it,
at which point slurry poured out the back gate and onto the concrete pad dedicated
to these roll -offs. This particular roll -off had been set aside because its contents
were too wet and needed to be solidified prior to hauling offsite. The release was
fully contained onsite and cleaned up immediately. As a result of this incident, the
site improved its sign -in and inspection procedures for picking up roll -offs.
6 1 P a g e
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