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HomeMy WebLinkAboutNCS000373_MONITORING INFO_20040322v'`M/Cfi/ELKNOW /N From: Michelin Aircraft Tire Corporation March 22, 2004 40589 S. Stanly School Rd. Norwood, NC 28128 Stanly County NPDES Permit #ncs000373 To: Individual Permit Renewal 1 Attn: Bill Mills \d\a Stormwater & General Permits Unit D�\� 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: NPDES Permit #ncs000373 Renewal Mr. Mills, Please accept the enclosed permit renewal application for Michelin Aircraft Tire Corporation's NPDES permit 4ncs000373. I believe that all pertinent and supplemental information has been included according to the instruction letter sent out by the Division of Water Quality. MATC has been operating according to its storm water permit throughout its duration. Due to the capricious and arbitrary nature of the weather, however, MATC was not able to perform all of its qualitative sampling during the "windows" specified in our original permit (Apr. -June and Sept. -Nov.). When weather conditions did not permit our sampling within the specified windows, the first storm event occurring afterwards was used. I was pleased to see the elimination of the sampling "windows" and the implementation of sampling anytime during the year as long as it meets the new criteria for a representative storm event. That will make sampling much easier. If you have any questions, comments or suggestions for improving the format of the information supplied, please contact me. If this renewal package is deficient in any way, please contact me IMMEDIATELY so that I may have the opportunity to resubmit within the specified time limit (prior to April 3, 2004). Thank you for your time and consideration. Michelin Aircraft Tire Corporation 40589 South Stanly School Rd. Norwood, North Carolina 28128 Respectfully, aLt Don Matthews Environmental Mgr. 704-474-7726 (office) 704-474-7756(fax) don.matthews@us.michelin.com Tel: 704/474-7634 AI Rim Fax:704/474-7722 AviatorTM AIR XT" AAT® 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) Initials dDA1 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location 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. y/•l 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. * 1211— 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. om4. 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. eZ� 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 ��''1�,��,�( changes in the raw materials used by the facility. l/1 v t G. 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) Representative storm sampling may now be conducted anytime during the year (the April to November window has been eliminated) and the representative rainfall event is now defined as a storm event that measures greater than 0.1 inches and is preceded by at least 72 hours in which no storm event measuring greater than 0.1 inches has occurred. �. W ArFgo o c y PERMIT COVERAGE RENEWAL APPLICATION FORM National Pollutant Discharge Elimination System Stormwater Discharge Permit Permit Number ncs11110373 THIS APPLICATION MUST BE SIGNED AND RETURNED ALONG Wrri TILE REQUESTED SUPPLENIEN'rAl, INFORNIA,r10N TO THE DIV. OF WATER QUALITY IN ORDER FOR YOUR FACILITY TO QUALIFY FOR RENEWAL OF YOUR STORMWATER PERMIT NCS000373 The following is the information currently in our database for your facility. Please review this information carefully and make all corrections as necessary in the space provided to the right of the current information. OWNER INFORMATION Owner/Org. Name: MICHELIN AIRCRAFT TIRE CORP Owner Contact Mailing Address: Phone Number: Fax Number E-mail address: FACILITY INFORMATION Facility Name: MICHELIN AIRCRAFTTIRE CORPORATION Facility Contact: Facility Address: 40589 SOUTH STANLY SCHOOL. NORWOOD, NC 28128 Phone Number: Fax Number E-mail address: PERMIT INFORMATION Permit Contact. DON MATmEws Mailing Address: 40589 SOl1TH STANLY SCHOOL NORWOOD, NC 28128 Phone Number: 7044747726 Fax Number: E-mail address: DISCHARGE INFORMATION Discharge Receiving Water: UTOFCEDARCREEK Stream Class: WS-Iv Basin: Sub -Basin #: Number of outfalls: CERTIFICATION 'Do h 114.-f-tA?", 5 7D H - 4,7H - 772 & 6 r10" mfi f f is a7lIS. mI r rti. evM T���ri-O/r �wn E]tI S/N 1 certify that 1 am familiar with th InJbrmation contained in the application and that to the best of my knowledge and belief such i m s rue, cc. lete and accurate. �j Signature* ignature Date �o — ON" kej l e F�r,lT�Io�rr Print or type na f person signing above Title Please return this completed renewal application form to Individual Permit Renewal Attn: Bill Mills Stormwater and General Permits Unit 1617 Mai Service Center Raleigh, North Carolina 27699-1617 Ilk f Lotus cc:Mail for Matthews, Don Forward Header Subject: Fwd[2]:HELP!!! QUICKLY Author: John-N000295 Duggins Date: 3/16/2004 8:17 AM Grover, We are not'owned' by one individual. We area wholly owned subsidiary of Michelin North America, Inc. As you know, Bill Van Someren and Mike Early are two of our officers which are based here in Greenville. Bill's number is (864) 458-4505; Mike's is (864) 4584819. Our fax is (864) 458-6887. Our mailing address is: One Parkway South, P.O. Box 19001, Greenville, SC 29615. Forward Header Subject: HELP!!! QUICKLY! Author: Don-N513274 Matthews Date: 3/15/2004 1:54 PM Cherif / Grover, I need the following information ASAP as it is required for the renewal of our National Pollution Discharge Elimination System (NPDES) permit (stormwater permit). I must get this fired off to the Division of Water Quality by the end of the week. Please provide the following information as quickly as you possibly can: Owner Information for MATC: Owner is listed as Michelin Aircraft Tire Corp. I need the following: Owner Contact: Mailing address: Phone # Fax number email address Thanks! DON U441fowa EP/AV/MATC Michelin Aircraft Tire Corp. 40589 S. Stanly School Rd. Michelin D3 Restricted Norwood, NC 28128 Cat 201-101 < 90 days Phone- 704-474-7726 N N LEGEND 8 ---- Property Line E g Fence line a Right -Of -Way Line Z OUTFALL2 — — - --------------------- ______ Storm Drain NOREOLK AND SOOIHENN RN(NWD ® • .^A � �Il_ Q_D Railroad ---- ---- --'-- - - -- - ---' -- z.•.T - - - - - - - - Swale I - z�a---.�." r ---- - - - - - I DA3 _ .---�- d I -. _ — — — Drainage Divide ..mrnws= ' P.n �= ' ssc, sm Ymsal^ u , \...�_ DA Drainage Arco (1), or (2) 8 t J DA2 \ \ 6 F oT. DA2 DA1 IOf ! .SRSl1T \ M1�l�lPIA AW Wr Wl P 4 YIHIFACIIIIM4' MnuAYc .. ... . '.\ 5 / r DA2 EL / 1 I ,m I � 1 OAl \ �\ 1 OUTFALLI \ \/ 1 A ;s / 3 -- PYm ewu wi oml �— / POTENTIAL POLLUTANT SOURCES 0 Waste RUbber/Waste Tlssae OA Loading Dock OGreen Tire Paint Station Vents GRAPHIC SCALE �3 New Tire_Residing Vent - O Heptone Unloading Station �• Z QHep Transfer Station © Hazardous Waste/Waste Oil Storage O Fuel Oil Unloading/Transfer Station ® Lubricating Oil Storage ❑g Diesel Fael Unloading Station _ Trash Compactor SfaRM WATER h DRN- -� NORWOOO MANUEMiURIND EADIIDY H GE D c ,.••-.- - n Z+wa i ao" Z --------------------- NMR)Ix NO SOUM W RMAW fr nAp�asc /F wico xc i 0 5 'f� DA2 i DA1 iaz I I y z m®rsamm Z_ Pew dr is vm) POTENTIAL POLLUTANT SOURCES Ej Waste Rubber/Waste Tissue Loading Dock ❑2 Green Tire Point Station Vents � New Tire Residing Vent ® Heptane Unloading Station ❑g Heptane Transfer Station © Hazardous Waste/Waste Oil Storage ❑7 Fuel Oil Unlooding/Transfer Station © Lubricating Oil Storage Qg Diesel Fuel Unloading Station tO Trash Compactor cxnawc sc.we DUTFALL 2 LEGEND ----------------- Property Line Fence line o---�— ---------- Right —Of —Way Line Storm Drain --V----V--II Railroad — Swale — — Drainage Divide DADrainage Area (1), or (2) DA1 Impervious Surface (Total = 166,467 sq. ft.) ® DA2 Impervious Surface \ (Total = 92,817 sq. ft.) \ DA1 �.\ \ \i OUIFALL I --------------------------------- i =f1M I�� SWPPP ANALYTICAL / QUALITATIVE DATA Analytical Requirements Discharge Characteristics Maas. Frequency Sample Location Units Sample Type Total suspended Solids Annually * Storm Discharge Outfall mg/I Grab Chemical Oxygen Demand Annually * Storm Discharge Outfall mg/I Grab pH Annually * Storm Discharge Outfall Standard Grab Total Rainfall Annually * NA Inches NA Event Duration Annually * NA Minutes NA Total Flow Annually * Storm Discharge Outfall MG NA * Unless cutoff levels are not reached. Then data not required until last year of permit. Qualitative Requirements Discharge Characteristics Maas. Frequency Sample Location Color Semi-annual Storm Discharge Outfall Odor Semi-annual Storm Discharge Outfall Clarity Semi-annual Storm Discharge Outfall Floating Solids Semi-annual Storm Discharge Outfall Suspended Solids Semi-annual Storm Discharge Outfall Foam Semi-annual Storm Discharge Outfall Oil Sheen Semi-annual Storm Discharge Outfall Other obvious indicators of Semi-annual Storm Discharge Outfall stormwater pollution Cutoff Concentrations Discharge Characteristics Cut-off Limits Total Suspended Solids 100 Chemical Oxygen Demand 120 pH Within 6.0-9.0 ANALYTICAL MONITORING RESULTS SDO #1 DATE- TOTAL EVENT TOTAL` Ph TOTAL CHEMICAL SAMPLED RAINFALLI DURATION FLOW SUSPENDED ,:OXYGEN BY SOLIDS = DEMAND 04Jan-00 .25 " 1 hr 20 min .0011 MG 6.0 40 mgll Not Detected I Donald Matthews 05Jun-Jun- 40" 1 hr 30 min .0015 MG 6.0 4.4 mg/l Na Detected Donald Matthews W No analytical monitoring available during last of 2003. Stanly Co. down 48" due to no rain. 12-Feb-04 0.59" 1 hr 30 min .0022 MG 7.0 15.0 mg/I Not Detected Donald Matthews arithmetic mean = Lk03> M2.212{m— �Oimgll� �TL J ALSO 6.0-9.0 100 mgll 120 mg/I CUTOFFS Within Compliance? OK OK OK - I I I I I I ANALYTICAL MONITORING RESULTS SDO #2 DATE TOTAL EVENT TOTAL Ph TOTAL RAINFALL DURATION FLOW SUSPENDED SOLIDS CHEMICALSAMPLED OXYGEN` BY DEMAND 04Jan-00 .25 " 1 hr 20 min 0005 MG 6.0 19 mg/l 33 mg/l Donald Matthews 05Jun-Jun .40" 1 hr 30 min .0008 MG 6.0 19 mg/I 56 mg/I Donald Matthews NA No analytical monitoring available during last of 2003. Stanly Co. down 48" due to no rain. 12-Feb-04 0.59" 1 hr 30 min .0011 MG 7.0 4.8 mg/I 120 mg/I Donald Matthews arithmetic mean = t6 rnq�TLOITtALS� 6.0-9.0 1 100 mgll 120 mgll CUTOFFS Within Compliance? OK I OK OK ph rounded to nearest whole number Total flow prepared according to EPA Guidance Manual 50518-91-002 Section 5.5.1 NPDES Permit # NCS000373 Michelin Aircraft Tire Corp. Stanly County, NC OCT. 1999 THROUGH OCT. 2000 QUALITATIVE MONITORING RESULTS EVENT DATE: 4 Jan. 2000 SDO #1 SDO #2 DISCHARGE CHARACTERISTICS OK INOTOK FINDINGS OK NOT OKI FINDINGS Color: X X Odor: X X Clarity: X X Floating Solids: X Leaf Particles X Leaf Particles Suspended Solids: X X Foam: X X Oil Sheen: X X Other obvious indicators of Storm Water Pollution: None None Total Rainfall: 0.25 Total Total Event Duration: 80 min. Flow: .0857 MG Flow: .0439 MG Sampled on Matthews EVENT DATE: 5 June 2000 SDO #1 SDO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK NOT OK FINDINGS Color: X X Odor: X X Clarity: X X Floating Solids: X X Suspended Solids: X X Foam: X X Oil Sheen: X X Other obvious indicators of Storm Water Pollution: None None Total Rainfall: 50" Total Total Event Duration: 2.0 hrs I Flow: .0014 MG/min , I Flow: 1.0007 MG/min Sam a on atthews OCT. 2000 THROUGH OCT. 2001 QUALITATIVE MONITORING RESULTS EVENT DATE: 30 Jan 2001 SDO #1 ■ SDO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK INOTOKI FINDINGS Color: x x X X Odor: X Clarity: X Floating Solids: X X X x x None Suspended Solids: Foam: X X Oil Sheen: X Other obvious Indicators of Storm Water Pollution: NoneJUI— Total Rainfall: NA Total "at Event Duration: NA Flow: NA , Flow: I NA am n Matthem EVENT DATE: 22 Mav 2001 SDO #1 SOO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK X NOT OKI FINDINGS Color: X Odor. x x x x Clarity: Floating Solids: x X Suspended Solids: X x X X None Foam: x Oil Sheen: X Other obvious indicators of Storm Water Pollution: None Total Ralnfall: .80" Total Total Event Duration: 2.0 hrs Flow: .0014 MG/min ' Flow: .0007 MG/min am a on a ewe QUALITATIVE MONITORING RESULTS EVENT DATE: 3 Sept 2001 SDO #1 ■ SOO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK NOT OK FINDINGS Color: X X x x Odor: x Clarity: x Flm"g Solids: Suspended Solids: X X X X X Foam: x Oil Sheen: x X None Other obvious Indicators of Storm Water Pollution: None Total Raln/all: .98" Total Total Event Duration: 45 min Flow: .0027 MG/min Flow: .0014 MGlmin am a on mathews OCT. 2001 THROUGH OCT. 2002 QUALITATIVE MONITORING RESULTS EVENT DATE: 13 Mar 02 SDO #1 01 SDO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK INOTOK FINDINGS Color: X X Odor: X X Clarity: X X Floating Solids: X X Suspended Solids: X X Foam: X X Oil Sheen: X X Other obvious indicators of Storm Water Pollution: None None Total Rainfall: 0.4 Total Total Event Duration: 45 min I Flow: .003 MG/min Flow: .0016 MG/min Sam le on Matthews EVENT DATE: SDO #1 SDO #2 DISCHARGE CHARACTERISTICS OK NOT OKI FINDINGS OK NOT OKI FINDINGS Color: Odor: Clarity: Floating Solids: NO SAMPLING DONE - DROUGHT NO SAMPLING DONE - DROUGHT Suspended Solids: (Sample taken in November 2002) (Sample taken In November 2002) Foam: Oil Sheen: Other obvious indicators of Storm Water Pollution: Total Rainfall: Total Total Event Duration: Flow: 4 ' Flow: 1 Sam a on Matthews OCT. 2002 THROUGH OCT. 2003 QUALITATIVE MONITORING RESULTS EVENT DATE: 5 Nov. 2002 SDO #1 SDO #2 DISCHARGE CHARACTERISTICS OK NOT OKI FINDINGS OK NOT OK FINDINGS Color: X X Odor: X X Clarity: X X Floating Solids: X X Suspended Solids: X X Foam: X X Oil Sheen: X X Other obvious indicators of Storm Water Pollution: None T None Total Rainfall: 0.3 Total 0.3 Total Event Duration: 35 min I Flow: .0029 MG/min ' 35 min Flow: 1 .0015 MG/min Sampled on Matthews EVENT DATE: May 31, 2003 SDO #1 SDO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK NOT OK FINDINGS Color: X X Odor: X X Clarity: X X Floating Solids: X X Suspended Solids: X X Foam: X X Oil Sheen: X X Other obvious indicators of Storm Water Pollution: None None Total Rainfall: 0.4 Total 0.4 Total Event Duration: 25 min Flow: .0055 MG/min ' 25 min Flow: 1.0028 MG/min Sam a on Matthews OCT. 2003 THROUGH OCT. 2004 QUALITATIVE MONITORING RESULTS EVENT DATE:. 12 Feb. 2004 SOO #1 SOO #2 DISCHARGE CHARACTERISTICS OK I NOT OK FINDINGS OK NOT OK FINDINGS Color: X X Odor: X X Clarity: X X Floating Solids: X X Suspended Solids: X X Foam: X X Oil Sheen: X X Other obvious indicators of Storm Water Pollution: I None None Total Rainfall: 0.59 Total Total Event Duration: 90 min Flow: .0022 MG/min Flow: .0011 MG/min Sam a on Mafthews EVENT DATE: SOO #1 SOO #2 DISCHARGE CHARACTERISTICS OK NOT OK FINDINGS OK NOT OKI FINDINGS Color: Odor: Clarity: Sample not due yet. Sam le not due yet. Floating Solids: Suspended Solids: Foam: Oil Sheen: Other obvious indicators of Storm Water Pollution: Total Rainfall: Total Total Event Duration: Flow. ' Flow: Sampled on Matthews SECTION 3 EXISTING MEASURES AND CONTROLS This section describes the existing measures and controls at Michelin's Norwood facility for minimizing the potential of contaminating storm water. Section 3.1 describes general measures and controls at the facility, and Section 3.2 describes the measures and controls for the specific potential pollutant sources identified during the site assessment. 3.1 GENERAL MEASURES AND CONTROLS A review of facility programs that directly or indirectly prevent and/or mitigate releases of contaminants to storm water is presented below. The following measures and controls are discussed: • Good Housekeeping Practices • Standard Operating Procedures • Visual Inspections • Preventive Maintenance • Integrated Spill Prevention, Control & Countermeasure Plan • Spill Prevention/Response Team • Employee Training • Security 3.1.1 Good Housekeeping Practices Good housekeeping practices are a part of Michelin's operation to maintain a clean and orderly environment and thereby reduce the possibility of accidental spills and equipment damage that may result in releases to surface waters. Examples of these practices include the following: • A contract cleaning operation cleans the production areas twice per day with a sweeper. (Inside - keeps loading dock areas clean) • Drip pans with absorbent rags are located under nozzles on the 55-gallon drums at lubricating oil stations. (Eliminates oil escaping through floor drains or cracks in the floor) 3-1 03/17/04 • All areas are cleaned at the end of each shift by the employees. Brooms, dust -pans and trash containers are stored throughout the plant. • Spills of any kind are contained and cleaned up promptly. 3.1.2 Standard Operating Procedures To further enhance a clean, orderly environment, employees are trained in standard operating procedures (SOPs) that have been developed for all work posts. The SOPS specify the safety protection required, the instructions for performing the work task, the cleaning procedures, and the instructions for emergency stops. They are also trained on what to do if a spill occurs on site, and their role in preventing pollution of the environment. SOP's used by facilities personnel during the course of their work include specific procedures on inspection of grounds, equipment maintenance, and environmentally safe methods of loading, unloading, and transfer of oils, hazardous substances, or wastes. 3.1.3 Visual Inspections In addition to the visual inspections of production equipment and production areas that occur on a continuous basis during production, Michelin has two additional formal visual inspection practices. The first is a daily inspection of the facility during all scheduled production days, and the second is an inspection conducted every two hours during scheduled plant shutdowns. Inspection forms used for these procedures are included in Appendix C of the SWPPP. 3.1.4 Preventive Maintenance Michelin has established a preventive maintenance schedule tracked by computer to keep equipment at the facility in good operating condition. The system provides a summary at the beginning of each week of all equipment scheduled for maintenance that week. Regular maintenance is performed on such things as the Rotocyclone and the Green Tire Paint booth; both of which have a potential to send particulate matter out of the plant and into the environment. Examples of the preventive maintenance forms are shown in Appendix C. Maintenance activities performed are recorded in the system. 3.1.5 Integrated Spill Prevention, Control & Countermeasure Plan Michelin has implemented an Integrated Spill Prevention, Control and Countermeasure plan which combines the procedures outlined in 40 CFR.265(c) (Prevention & Preparedness Plan) and 40 CFR.112.7 (Spill Prevention, Control, & Countermeasure plan). It outlines plant operations, oil and hazardous substances used or generated, responsibilities, management practices, equipment, containment 3-2 03/17/04 procedures, and reporting requirements in the event of an unplanned release into the environment. 3.1.6 Spill Prevention/Response Team While only 1 minor spill has occurred at the Michelin facility, response procedures have been established should a spill occur (document EP0013MOO). The emergency coordinator is to be immediately notified in the event of a spill, and he/she will take all necessary steps to contain the spill. Michelin has several employees trained to be members of the Spill Team. Those individuals are trained to utilize containment equipment (absorbents, bags, dams, etc.) to contain spills. All spills are reported using form EP0015MOO. 3.1.7 Employee Training Employees at Michelin receive training as dictated by their job responsibilities. All employees receive an orientation training which includes the following topics: • OSHA Hazard Communication • Emergency Evacuation Procedures • Lock Out/ Tag Out • Plant Safety Policies • Hearing Conservation • Fire Equipment Codes • Fire Extinguisher Training Some employees receive the following training programs: • HAZCOM Training - Facilities group trained to handle hazardous materials • Forklift Training • Stormwater Pollution Prevention Plan / Integrated SPCC & PPP • ISO14001 Environmental Management Management and production employees receive training on the Integrated Spill Prevention Control & Countermeasure plan and the Storm Water Pollution Prevention plan annually. Records are kept by the Training Department. 3-3 03/17/04 3.1.8 Security Unauthorized access is discouraged by means of a fence around the entire facility, video camera surveillence, and several "No Trespassing" signs. Entry is controlled by electronic access cards and a computer system. Public access is only allowed by prearranged visit or presentation of a legitimate business need to office personnel or Shipping & Receiving personnel. Additionally, all visitors must sign in and out and wear visitor passes while at the facility. 3.2 MEASURES AND CONTROLS FOR SPECIFIC POLLUTANT SOURCES Section 2 of the SWPPP plan presented a site assessment of the Michelin facility and identified 11 potential pollutant sources. The existing measures and controls for these source are described in Table 3.1. 34 03/17/04 TABLE 3.1 EXISTING MEASURES AND CONTROLS FOR SPECIFIC POLLUTANT SOURCES Potential Pollutant Source Existing Measures/Controls 1. Waste Rubber/Waste Tissue Loading • Loading dock is covered. 2. Green Tire Paint Station Vents • Exhaust system is thoroughly inspected weekly. 3. New Tire Residing Vent • Dust collection system is inspected regularly. 4. Lacolene Unloading Station The SPCC Plan is the principal control measure used. Key elements of the plan are summarized below: • The storm drain is covered prior to the unloading operation. • Warning signs are posted, and wheel chocks are used to prevent vehicle departure before unloading complete. • Storage tank is equipped with level indicator within view of unloading personnel. • Unloading personnel required to observe entire unloading operation. • Unloading occurs only during daylight hours. • An employee trained in spill containment and reporting procedures is present during unloading. • An unloading station has been constructed with secondary containment & drainage. s-s 03/17/04 5. Lacolene Transfer Station 6. Hazardous Waste/Waste Oil Storage The SPCC Plan is the principal control measure used. Key elements of the plan are summarized below: • There are no long distribution lines. The delivery station is close to the tank itself. • The lacolene transfer pump is surrounded by a small diked area to contain any small spills or leaks. • The transfer pump is activated by a key and only designated personnel have a key. • Boom -type absorbent material is stored near the station in case of a spill. • The storage building in which drums are kept is self-contained. • Drums are taken to the storage area one at a time using a forklift with a drum carrying attachment. • Spills within the storage building are cleaned up with absorbent material stored at the building 7. Fuel Oil Unloading/Transferring I The SPCC Plan is the principal control Station measure used. Key elements of the plan are summarized below: • Warning signs are posted, and wheel chocks are used to prevent vehicle departure before unloading complete. • Unloading / transferring is only performed during daylight hours. • Unloading personnel required to observe entire unloading operation. 3-6 03/17/04 8. Lubricating Oil Storage • Storage tank is equipped with level indicator within view of unloading personnel. • An employee trained in spill containment and reporting procedures is present during unloading. • Storm sewer is covered prior to the unloading / transferring operation. • The 800-gallon tank is equipped with a switch to stop the transfer pump at high level. The SPCC Plan is the principal control measure used. Key elements of the plan are summarized below: • Lubricating oil is stored in drums along the West wall of the tire room. • The batch -house storage area is under roof and is curbed to contain any leaks. • Absorbent material is stored in the lubricating oil storage area for use in the event of a spill 9. Diesel Fuel Unloading Stations The SPCC Plan is the principal control measure used. Key elements of the plan are summarized below: • Prior to unloading, storm drains in the area sealed with an oil resistant barrier. • Warning signs are posted, and wheel chocks are used to prevent vehicle departure before unloading complete. • Unloading is only performed during daylight hours. 3-7 03/17/04 10. Trash Compactor 1 • Each of the 2 diesel fuel storage tanks are dedicated to a single piece of equipment and are hard -piped to them. • Only general trash is discarded in the compactor. Wood pallets, cardboard, metals, rubber compound and textile are recycled. • All empty containers that once contained hazardous materials are collected separately. 3-s 03/17/04 CHANGES TO INDUSTRIAL ACTIVITIES The retread operation was removed from the Norwood site of Michelin Aircraft Tire Corporation. This eliminated two of the potential pollution sources previously listed: the bagfilter / cyclone operation used to accumulate the rubber particulates (grindings), and the trailer formerly stationed outside to capture the rubber dust as it was funneled from the collector (the area around was a potential source of pollution). The Lacolene unloading station was improved by the addition of a concrete containment area designed to capture the contents of an entire tanker should it rupture during the transfer or unloading of the solvent. The station has drainage (under lock and key) and is inspected for accumulated rainwater. Any water is inspected for oil and debris before being released through the dike drain. A revised "Spill Reporting Procedure" and "Spill Reporting Form" were developed and implemented throughout the plant. An improved "Hazardous Waste Control Procedure" was developed and implemented. A "Facility Security Plan" was developed and implemented as required of all shippers & generators of Hazardous Waste by the Dept. of Transportation. The use of Chlorine gas was discontinued at the site and replaced with an environmentally friendly system. This eliminated the only Extremely Hazardous Substance in use at Norwood. - The Norwood site of MATC is implementing an ISO14001 environmental management system. The site plans on obtaining outside certification by the end of 2005. All employees will be involved with the development, monitoring and sustaining of the system. 17 March 2004 STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION N.C. Division of Water Quality, Stormwater and Geuercd Permits Unit Facility Name: MICHELIN AIRCRAFT TIRE CORPORATION Permit Number: NCS000373 Location Address: 40589 SOUTH STANLY SCHOOL NORWOOD, NC 28128 County: STANLY "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 it 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" "I certify that the SPPP has been developed, signed and retained at the facility location and the SPPP has been fully implemented at the named facility location in accordance with the terms and conditions of the stormwater general permit." "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 THE STORMWATER POLLUTION PREVENTION PLAN WITH THE CERTIFICATION. Signature Date 3 Print or type name of person signing above Title It SPPP Certification 2J99