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HomeMy WebLinkAboutNCS000370_Renewal Application_20150303BRIDGESTONE AMERICAS TIRE OPERATIONS, LLCPRIVATE February 26, 2015 Wilson Plant P.O. Box 1139 Wilson, North Carolina 27894-1139 SW Individual Permit Coverage Renewal Stormwater Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 Subject: NPDES Stormwater Permit Renewal Dear Sir or Madam: F?F—CEIV D P"A� we DEIqR*LAND QUALITY STORWa ER P Rk iT v G The Bridgestone Americas Tire Operations, LLC (BATO) Wilson, North Carolina facility operates under individual stormwater discharge permit number NCS000370. This permit was issued in August 2010, went into effect on September 1, 2010, and expires August 31, 2015. The enclosed package (1 original and 1 copy) is being submitted to fulfill the renewal requirements as stated by the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Energy, Mineral and Land Resources . This application package is intended to constitute a complete application for renewal and is being submitted 180 days prior to expiration, as required by the current permit, Part III Section B Condition 1. If you have any questions concerning this notification, please contact me at (252) 246-7485. S' cerely, I a Villegas —Wilson Plant Enclosures Cc: BATO —Wilson Plant; Environmental Department Year 1, Period 1 (Sample 1) Date: 10/14/2010 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.069 3.05 COD Mg/L N/A 58.9 126 Total Suspended Solids Mg/L N/A <2.5 269 Oil and Grease Mg/L N/A <5 <5 pH Standard N/A 7 7 Total Rainfall Inches 0.3 N/A N/A Rainfall Event Duration minutes 120 N/A N/A Year 1, Period 2 (Sample 2) Date: 6/27/2011 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.041 0.190 COD Mg/L N/A 33.8 31 Total Suspended Solids Mg/L N/A <5 55.6 Oil and Grease Mg/L N/A <5 <5 pH Standard N/A 4 6 Total Rainfall Inches 0.1 N/A N/A Rainfall Event Duration minutes 60 N/A N/A Year 2, Period 1 (Sample 3) Date: 01/27/2012 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.310 0.169 COD Mg/L N/A 49.9 199 Total Suspended Solids Mg/L N/A 38 344 Oil and Grease Mg/L N/A 62.2 35.5 pH Standard N/A 7 6 Total Rainfall Inches 1.8 N/A N/A Rainfall Event Duration minutes 90 N/A N/A BATO Wilson NPDES Permit Renewal Application Page 4 of 18 Year 2, Period 2 (Sample 4) Date: 9/06/2012 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.021 0.201 COD Mg/L N/A 30 26 Total Suspended Solids Mg/L N/A 6.4 10 Oil and Grease Mg/L N/A ND ND pH Standard N/A 7 6 Total Rainfall Inches 0.2 N/A N/A Rainfall Event Duration minutes 120 N/A N/A As noted in the DMR submittal for the Year 2 Period 2 sampling event, an initial sample was taken on August 25, 2012. However, it was determined that the samples were not taken within the first 30 minutes of discharge. A repeat sample was taken during the next representative storm event (09/06/12) to ensure the samples are taken in accordance with permit requirements. The results of this repeat sampling event were counted as the Year 2, Period 2 sampling. Year 3, Period 1 (Sample 5) Date: 12/29/12 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.118 <0.050 COD Mg/L N/A 32.2 27.9 Total Suspended Solids Mg/L N/A 8.8 46.7 Oil and Grease Mg/L N/A <5.0 <5.0 pH Standard N/A 6 6 Total Rainfall Inches 0.2 N/A N/A Rainfall Event Duration minutes 90 N/A N/A Year 3, Period 2 (Sample 6) Date: 10/07/13 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.081 0.172 COD Mg/L N/A 50.1 80.3 Total Suspended Solids Mg/L N/A 40.8 187 Oil and Grease Mg/L N/A <5 <5 pH Standard N/A 7 7 Total Rainfall Inches 0.6 N/A N/A Rainfall Event Duration minutes 180 N/A N/A BATO Wilson NPDES Permit Renewal Application Page 5 of 18 Year4, Period 1 (Sample 7) Date: 11/26/13 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.020 0.073 COD Mg/L N/A 10.3 12.3 Total Suspended Solids Mg/L N/A 3.75 6 Oil and Grease Mg/L N/A ND ND pH Standard N/A 6 6 Total Rainfall Inches 0.6 N/A N/A Rainfall Event Duration minutes 240 N/A N/A Year4, Period 2, (Sample 8) Date: 11/17/14 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.059 0.120 COD Mg/L N/A 24.9 22.1 Total Suspended Solids Mg/L N/A 7 11.6 Oil and Grease Mg/L N/A ND ND pH Standard N/A 6 7 Total Rainfall Inches 0.2 N/A N/A Rainfall Event Duration minutes 300 N/A N/A As noted in a letter to the Division of Water Resources on December 9, 2014 (Appendix D), due to an emergency at the facility, Sample 8 was not conducted between the dates designation in the permit (March 1, 2014- August 31, 2014). Hence, sampling conducted 11/17/2014 was assigned to Sample 8. Year 5, Period 1 (Sample 9) Date: 12/16/2014 Analytical Monitoring Data Units Rainfall Event Results East Outfall Results South Outfall Results Zinc, Total Mg/L N/A 0.110 0.073 COD Mg/L N/A 38.8 12.3 Total Suspended Solids Mg/L N/A 2 6 Oil and Grease Mg/L N/A ND ND pH Standard N/A 7 6 Total Rainfall Inches 0.2 N/A N/A Rainfall Event Duration minutes 1440 N/A N/A BATO Wilson NPDES Permit Renewal Application Page 6 of 18 SUMMARY OF VISUAL MONITORING RESULTS This section documents a summary of the qualitative monitoring required by Part II Section C of the current NPDES permit. The qualitative monitoring requires that 2 observations each year (one in the spring, one in the fall) be performed at each of the stormwater discharge outfalls (South and East). The qualitative monitoring performed during the term of this permit was performed twice each year and included monitoring for color, odor, clarity, floating solids, suspended solids, foam, oil sheen, erosion, and other obvious indicators of stormwater pollution. The table below summarizes the results of all required monitoring. Please note that the tenth and final sample required by the current permit has not been conducted as of the time of this submittal. Results for this sample will be submitted within 30 day of receipt of laboratory results. Note: For monitoring of clarity, floating solids, and suspended solids, a numerical scaled rating is applied. The following documents the scale used for each parameter: • Clarity: 1 is clear and 10 is very cloudy • Floating solids: 1 is no solids and 10 is the surface is covered in floating solids • Suspended solids: 1 is no solids and 10 is extremely muddy Date: 10/04/2010 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light brown Light brown Odor None None Clarity 1 2 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None BATO Wilson NPDES Permit Renewal Application Page 7 of 18 Year 1, Period 2 (Sample 2) Date: 06/27/2011 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light Brown Light Brown Odor None None Clarity 2 2 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None Year 2, Period 1 (Sample 3) Date: 01/27/2012 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light Brown Light Brown Odor None None Clarity 1 2 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None BATO Wilson NPDES Permit Renewal Application Page 8 of 18 Year 2, Period 2 (Sample 4) Date: 09/06/2012 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light Brown Light gray Odor None None Clarity 1 1 Floating Solids 3 1 Suspended Solids 2 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes Floating solids looked like natural organics rather than stormwater pollution None Year 3, Period 1(Sample 5) Date: 12/29/2012 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Greenish Greenish Odor None None Clarity 1 1 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None BATO Wilson NPDES Permit Renewal Application Page 9 of 18 Year 3, Period 2 (Sample 6) Date: 10/07/2013 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light Brown Light gray Odor None None Clarity 1 2 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None As noted in a letter to the Division of Water Resources on December 9, 2014 (Appendix D), due to an emergency at the facility, Sample 8 was not conducted between the dates designation in the permit (March 1, 2014- August 31, 2014). Hence, sampling conducted 11/17/2014 was assigned to Sample 8. Year 4, Period 1 (Sample 7) Date: 11/26/13 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light brown Light gray Odor None None Clarity 1 2 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None BATO Wilson NPDES Permit Renewal Application Page 10 of 18 Year 4 Period 2 (Sample 8) Date: 11/17/2014 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light brown/clear clear, no color Odor None None Clarity 1 1 Floating Solids 1 1 Suspended Solids 2 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None Year 5, Period 1 (Sample 9) Date: 12/16/2014 Qualitative Monitoring Data Parameter East Outfall Results South Outfall Results Color Light Brown/clear No color, clear Odor None None Clarity 1 1 Floating Solids 1 1 Suspended Solids 1 1 Foam None None Oil Sheen None None Erosion Evidence None None Other Obvious Indicators of Stormwater Pollution/Notes None None SUMMARY OF BEST MANAGEMENT PRACTICES BATO-Wilson implements stormwater management practices to reduce the source of potential stormwater pollutants whenever practicable. The specific stormwater management practices for the industrial activities in the South Drainage Areas and East Drainage Areas are summarized in the following text. East Outfall BMPs All stormwater from Drainage Area East discharges to a stormwater-settling pond. This pond has two containment booms in series to contain and collect any floating pollutants. An absorbent boom precedes the containment booms. BATO Wilson NPDES Permit Renewal Application Page 11 of 18 Zinc oxide and other zinc compounds are managed in the East Drainage Area. All handling, including unloading of zinc oxide and other zinc compounds, are done inside the mixing building. The Facility utilizes zinc oxide in 2,500-pound sacks and occasionally 50-pound bags. All baghouse equipment that collects zinc compound dust is regularly inspected for proper operation and promptly repaired as needed. All empty waste zinc oxide and other zinc compound bags are disposed of in an enclosed compactor container, then these packages are cover with plastic to the temporally storage area until departure for recycle. In 2011, filters were installed on exhaust fans in the mixing area to reduce dust. Additionally, stormwater drains outside mixing area were covered with hay bales that are replaced every other month. In 2011 BATO installed a dust collector which has been in operation since November 19th 2011.The wax/lube oil unloading areas are curbed areas designed for unloading tanker trucks or rail car tankers. The curbed areas are sized to contain the contents of a tanker truck or rail car tanker plus precipitation. This area drains to the stormwater settling ponds. The wax/lube oil storage tanks are located inside covered secondary containment areas. The containment areas are sized to contain the contents of the largest tank plus precipitation. Any stormwater collected within these containment areas is pumped out to the oil/water separator (0/WS) for treatment. The process solvent unloading area and tank farm are roofed and are surrounded by concrete dikes sized to contain the contents of a tanker truck and the largest tank, respectively. Because this area is roofed, very little stormwater comes into contact with the unloading or storage facilities. The secondary containment for each solvent tank is equipped with a sump and pump to collect overspill and rainwater. Fluids ponding in the containment structures are collected in sumps. The secondary solvent containment areas and sumps are checked weekly. Any collected rainwater is either allowed to dry or checked for the presence of solvents and then, if found to be solvent free, pumped out. Drummed hazardous waste at the drummed hazardous waste storage area is stored in a roofed area so as not to be exposed to stormwater. What stormwater does come into contact with the hazardous waste storage area is generally allowed to dry unless hazardous waste were to be spilled into the stormwater. In this event, the contaminated stormwater would be collected and disposed as hazardous waste. The drain from this area is permanently plugged. The storage area for totes of organic liquid is located beside the hazardous waste 90-day storage area. This area has a dike around it except for the entrance. Flow to a storm drain would be north, then east and then south. A spill in this area can be isolated by berming the entrance to the area. This area is also under roof. A tote of bleach is located outside within a containment dike. Stormwater collected is pumped to the process water sump for use as process water. The railroad unloading area is inside a portion of the factory designed to contain several rail cars. All unloading activities are indoors and protected from stormwater. Therefore, no stormwater contact occurs during the unloading operation. The truck unloading docks are equipped with side baffles. Trucks unloading bags and totes at the docks back up to the docks such that materials which are unloaded are not exposed to stormwater. BATO Wilson NPDES Permit Renewal Application Page 12 of 18 The containment structures of the process oil tanks are equipped with sumps for collection of overspill, dumped condensate, and rainwater. Water and product accumulations collected in the sumps are pumped to the plant's O/WS for treatment. The scrap manufacturing equipment stored in the East Drainage Area has the potential for contributing pollutants to stormwater if the scrap equipment is greasy, leaking oil, or rusting. To mitigate this, an equipment removal procedure is in place that requires equipment to be completely drained and free from leaks prior to being released for storage and scrapping. For additional assurance, during the periodic housekeeping inspections, the storage area and equipment capable of contributing pollutants to stormwater are visually inspected to verify there are no leaks. The oil demister area near mixing is inspected weekly as part of the SPCC inspection. The area is cleaned periodically to minimize oil exposure to stormwater. Containment has been installed with oil/water separation for stormwater. The #6 fuel oil unloading station is roofed. The fill connections of the unloading tanker truck are contained within a concrete curbed area. The curbed area is sized to contain the contents of a tanker truck plus precipitation. The fuel oil storage tank farm is roofed and enclosed within a containment dike sized to contain the contents of the largest tank plus precipitation. In the event of heavy rainfall, if stormwater collects in the containment, the oily water is pumped out and taken away by a qualified contractor. South Outfall BMPs The south outfall consists of the following potential sources for stormwater contamination: drum and used oil storage, air compressor condensate, lube oil storage area, gasoline storage tank, and truck loading/unloading areas. Any stormwater that gets into the drum storage area or the used oil storage area of the used oil/sludge storage building is pumped to a tank or tote and taken to the oil/water separator or pumped out by a contractor. This area is inspected weekly. Condensate and/or stormwater that get in the air compressor containment are pumped out by a contractor. This area is inspected weekly. Stormwater that gets into the tube Oil Storage Building is pumped to the curbed oil/water separation pit. This area is inspected weekly. The containment and oil/water separation pit at the gasoline storage tank are inspected weekly. The oil trap at the gasoline tank is cleaned as needed as determined by the weekly inspection. Trucks loading tires at the warehouse loading docks back up to the docks such that the tires are not exposed to stormwater. There is also a large gravel truck parking lot located on the south side of the warehouse. BATO Wilson NPDES Permit Renewal Application Page 13 of 18 For those materials that must be stored outside, not under cover and not within a bermed area, spill kits are readily available and employees who handle materials are trained in procedures to minimize the risk of spills as well as in proper spill response actions. SIGNIFICANT FACILITY CHANGES The facility has undergone some changes during the last 5 years which have potential impacts on stormwater runoff. These changes have been documented in the facility's SWPPP and are summarized in this section. • BATO was not able to continue using reclaimed water due to its quality and it caused several issues with equipment. It was also more expensive due to extra materials required to improve its quality. • A 150-gallon diesel fuel AST is also housed adjacent to the gasoline tank. This fuel tank is owned by landscaping contractor. CERTIFICATION OF DEVELOPMENT AND IMPLEMENTATION OF STORMWATER POLLUTION PREVENTION PLAN See Appendix C for the signed certification regarding the development and implementation of the Stormwater Pollution Prevention Plan for BATO Wilson. BATO Wilson NPDES Permit Renewal Application Page 14 of 18 Appendix A Renewal Application Form and Supplemental Information Form Permit Coverage A�A Renewal Application Form NPDES Permit Number NCDENR National Pollutant Discharge Elimination System Stormwater Individual Permit NCS000370 Please provide your permit number in box in the upper right hand corner, complete the information in the space provided below and return the completed renewal form along with the required supplemental information to the address indicated. Owner Information * Address to which permit correspondence will be mailed Owner / Organization Name: Bridgestone Americas Tire Operations, LLC Owner Contact: Michael Darr Mailing Address: 3001 Firestone Parkway Wilson NC 27894 Phone Number: 252 246 7266 Fax Number: E-mail address: darrmichael@bfusa.com Facility Information Facility Name: Bridgestone Americas Tire Operations, LLC Facility Physical Address: 3001 Firestone Parkway Wilson NC 27894 Facility Contact: Irma Villegas Mailing Address: 3001 Firestone Parkway Wilson NC 27894 Phone Number: 252 246 7485 Fax Number: E-mail address: villegasirma@bfusa.com Permit Information Permit Contact: Irma Villegas Mailing Address: 3001 Firestone Parkway Wilson NC 27894 Phone Number: 252 246 7485 Fax Number: E-mail address: villegasirma@bfusa.com Discharge Information Receiving Stream: Tiosnot Swamp and White Swamp Stream Class: C;Sw, NSW and C;NSW Basin: Neuse and Tar -Pamlico River Basins Sub -Basin: 03-04-07 and 03-03-03 Number of Outfalls: 2 Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a separate sheet if necessary. See "Significant Facility Changes" section in renewal application text. CERTIFICATION I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete and accurate. Signature `'�/ Date L hQe 6 2)� r r 421a.1 � IyOtl ger Print or type name of person signing above Title SW Individual Permit Coverage Renewal Stormwater Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 Please return this completed application form and requested supplemental information to: 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 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. 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. ty 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. 1 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. t 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. 1 V 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) Appendix C Certification of Development and Implementation of SWPPP STORMWATER ROLLUTION PREVENTION PLAN DEVELOPMENT ANb IMFI.EIVIENTA'fION CERTIFICAI'iON North Carolina Division of Energy, Mineral, and Land Resources - Storm water Permitting Facility Name: Bridgestone Americas Tire Operations, LLC Permit Number: NCS000370 Location Address: 3001 Firestone Parkway Wilson, NC 27893 Country: Wilson "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 PREVENTION PLAN WITH THIS CERTIFICATION. Signature OVK Date 2 --25 —I�( f��lCfl4s� r i 1?14M IR4#142leI- Print or type name of person signing above Title SPPP Certification 10/13 Appendix December 9, 2014 NC Division of Water Resources Correspondence •i 1 Wilson Plant P.O. Box 1139 Wilson, North Carolina 27894-1139 North Carolina Division of Water Resources Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: Stormwater Sampling Year 4, Period 2 (Sample 8) Analytical Results Dear Mr. Parnell: Bridgestone Americas Tire Operations, LLC ("Bridgestone") Wilson Plant operates under National Pollutant Discharge Elimination System (NPDES) permit number NCS000370. The permit requires semi-annual quantitative sampling of stormwater at the facility's two outfalls. The outfalls are named by their geographic locations, South and East. The 4th year, 2nd period (Sample 8) stormwater sample was due to be taken between March 1, 2014 and August 31, 2014. Due to emergency events at our facility, we did not collect Sample 8 during the sampling period. Per the instructions you gave the Bridgestone Wilson Plant during our November 5, 2014 phone conference, we proceeded to collect the sample on November 17, 2014 and are submitting the attached analytical results by way of this letter. The Bridgestone Wilson Plant regrets the delay in collecting samples during the specified timeframe, but confirms there were no unusual circumstances during the March 1 —August 31, 2014 period that would be expected to have impacted any stormwater quality during that timeframe, other than the fire events described below and for which the Department conducted an onsite review. For instance, during your on -site visit on May 22, 2014, there was confirmation that stormwater BMPs were in place and working properly. As mentioned above, on June 28, 2014 and July 5, 2014 Bridgestone Wilson Plant suffered two fires, for both of which we provided notice to NCDENR. In response, you visited the plant on July 1, 2014 with Mr. Cheng Zhang of NCDENR's Division of Water Resources to review Bridgestone's firewater collection and cleanup activities. No issues were found during that site visit. As you likely noted during your visit, we were extremely busy with fire response activities, which continued for the remainder of July, and unfortunately a human error happened in overlooking the sampling event scheduled for stormwater Sample 8. The Bridgestone Wilson Plant has an electronic compliance calendar, which is being upgraded to improve its functionality to prevent similar cases. p:\My Documents\Water-Stormwater\Filesl4 December 9, 2014 BRIIDGESTONE AMERICAS TIRE OPERATIONS, LLC Wilson Plant P.O. Box 1139 Wilson, North Carolina 27894-1139 Please find the analytical results for the facility's two outfalls in the attachment as required, the original and one copy are enclosed, the analytical results were received from the laboratory via electronic mail at the Bridgestone Wilson Plant on December 4, 2014. If you have any questions concerning this report, please contact Irma Villegas at (252) 246-7485. Sincerely, feI Darr Plant Manager, Wilson Plant Bridgestone Americas Tire Operations, LLC cc: BATO Wilson Environmental Department cc: Dave Parnell Division of Energy, Minerals, and Land Resources p:\My Documents\Water-Stormwater\Files14