Document 2VzozqgJgZnvLoLDVLrjMwzR

NPDES ID: GAIS13242 U.S. Environmental Protection Agency, Region 4 61 Forsyth Street SW, Atlanta, GA 30303 Water Compliance Inspection Report FACILITY DATA Effective Date: 06/01/2022 Expiration Date: 05/31/2027 Facility Name: American Woodmark Corporation - Jackson Operations SIC Code: 2434 Address: 1017 S Hwy 42 / Jackson, GA On-Site Representatives: David Headley Sjoerd Van Keulen, Project Manager Steve Dyar, Maintenance Manager Responsible Official: David Headley EHS Manager dheadley@woodmark.com (770) 775-6013 Ext.652 INSPECTION ENTRY DATES/TIMES Entry Date/Time: 3:30pm 08/13/2024 Exit Date/Time: 5:45pm 08/13/2024 NAMES OF STATE INSPECTORS GA EPD: Anam Mustafa, Michael Messinger, Adefola Olateru AREAS EVALUATED DURING INSPECTION (Check those areas evaluated) X Permit Self-Compliance Program Pretreatment X Records Compliance Schedule X Pollution Prevention X Facility Site Review Laboratory X Storm Water Effluent/ Receiving Waters X Operations & Maintenance Combined Sewer Overflow Flow Measurement Sludge Handling/ Disposal INSPECTION SUMMARY Sanitary Sewer Overflow Cabinets are manufactured at the company's other locations, and then assembled at this Facility. INSPECTOR SIGNATURE CELINA RUSSO Digitally signed by CELINA RUSSO Date: 2024.09.03 09:34:16 -04'00' Celina Russo, Environmental Engineer JEREMY JUDD Digitally signed by JEREMY JUDD Date: 2024.09.03 09:45:24 -04'00' Jeremy Judd, Environmental Engineer AHMAD Digitally signed by AHMAD DROMGOOLE DROMGOOLE 09:58:25 -04'00' Date: 2024.09.16 Ahmad Dromgoole, Section Chief Waterways and Wetlands Enforcement Section Page 1 of 6 OFFICE/PHONE NUMBER USEPA Region 4/ECAD-WEB-WWES 404-562-9804 USEPA Region 4/ECAD-WEB-WWES 404-562-9505 USEPA Region 4/ECAD-WEB-WWES 404-562-9212 Sector W: NPDES Industrial Stormwater Worksheet (Georgia) GPS Coordinates Receiving Water(s) or MS4 Site Acreage Date of NOI 1. FACILITY LOCATION INFORMATION Latitude UT of Panther Creek ~18-acre site, mostly indoors 10/2023 3317'12.15"N SIC Code Email on NOI (RO) Longitude Discharge to 303(d) or TMDL waters 2434 8355'57.62"W NA Weather Condition Sunny, warm MPitts@woodmark.com 2. STORMWATER POLLUTION PREVENTION PLAN (SWPPP) AND SUPPORTING DOCUMENTS PLAN TOPICS - Section 5 of Permit SWPPP available on-site YES NO N/E Part 5.3/7.6 A SWPPP binder, dated May 25, 2016 is kept onsite. An electronic copy of the SWPPP, dated X October 2017, was emailed to inspectors during the inspection. SWPPP Certification Signature/Date No signature page for Facility representative. Part 5.1.7 / Appendix B X SWPPP modified and updated to current conditions Part 5.2.1-2 X Pollution Prevention Team named in SWPPP Part 5.1.1 Pollution prevention team is to include: EHS Manager, Plant Manager, and Maintenance Manager. X Appendix B contains the names of individuals in those roles and more information on their responsibilities. Some of the names/contact info were out of date. Employee training schedule Part 5.1.2.2 Employees are to be trained at hiring and then on an annual basis. Training is to include SWPPP X contents, spill response procedures, good housekeeping, and pollution prevention. Site Description Facility assembles kitchen cabinets. Site Map See photo DSCN3022. Summary of potential pollutant sources and particular pollutants Part 5.1.3 X Part 5.1.3.3 X Part 5.1.4 Metal rack material and wood pallets, parked trucks parked, and four compactors (two for solid X waste, two for sawdust). Description of the Control Measures Identified structural controls include: - Coverings for all trash compacters or any other pollutant source - Secondary containment - Vegetative cover in all pervious areas to prevent erosion Part 5.1.5 X Page 2 of 6 Schedule and Procedures for Good Housekeeping Part 2.1.2.2, 5.1.6.1a To promote good housekeeping, the Facility shall (1) ensure equipment is working properly, (2) proper material storage practices, and (3) material inventory control to reduce waste due to X overstocking and maintaining SDSs. Schedule and Procedures for Preventative Maintenance Part 5.1.6.1 Prescribed preventative maintenance includes timely inspection of stormwater management devices X and facility equipment followed by prompt repairs. A more detailed schedule is not provided. Contains Spill Prevention and Response Procedures Schedule & Procedures for Monitoring Part 5.1.6.1.c X Part 5.1.6.2 SWPPP states that Facility SIC is 2434, which "falls under Sector W of the General Permit. Sector W does not require monitoring of stormwater discharges." Sector W facilities are not required to conduct benchmark monitoring. Per Part 8.W.3 of the Permit, Subsector W1, which includes SIC 2434, is X subject to indicator monitoring for pH, COD, and TSS. Per 6.2.1.1 of the Permit, indicator monitoring must be conducted annually (beginning January 1, 2023) within the first two calendar quarters. The SWPPP identifies a sampling location on the site map. Schedule & Procedures for ROUTINE Inspections Part 5.1.6.2.d.i Routine inspections are to be conducted quarterly by the EHS manager. A blank copy of the X inspection form was provided as a template. Schedule & Procedures for QUARTERLY VISUAL Inspections Part 5.1.6.2.d.ii, 4.2 Samples should be collected within the first 30 minutes of discharge through the outfall. Examinations shall document color, odor, turbidity, debris, solids, etc. According to the SWPPP, X Outfall 001 was not selected as the representative sampling location due to access issues. Instead, the storm drain in the southeastern corner (see photo DSCN3022) was selected because it receives the majority of runoff from the facility. A template form was provided for use. Schedule & Procedures for ANNUAL COMPREHENSIVE Inspections Instructions and a template checklist were provided for use. Part 5.1.6.2.d.iii, 4.3 X 3. SITE DESCRIPTION AND SWPPP Facility receives kitchen cabinet components (which are manufactured at other plant locations) and assembles them. Products are made to order, and all components arrive pre-finished. All production lines and support services are inside the building. The only activities exposed to stormwater are performed on the eastern side of the building near the loading/unloading bays. Storm drain inlets along the (paved) eastern side of the building drain northerly toward the tree line as shown in photo (see photo DSCN3022) before being directed into a low retention area. This retention area, when full, discharges towards the railroad. See photos DSCN3018-3020. According to Facility personnel, they have previously had discussions with GA EPD regarding a No Exposure Exclusion (NEE), for which it was determined that this site does not currently qualify. Cabinets and their components are designed for indoor use and are currently exposed to stormwater in the open top dumpsters. RECORD REVIEW Representative on-site 4. RECORD REVIEW Page 3 of 6 YES NO N/E X NOI Submitted to EPD Submitted via GEOS in October 2023. Records available onsite or "readily available" Part 5.4.1 X Part 5.4 X Records of incidents with spills, leaks, pollutant releases Part 5.4.3 Including: dates and description of incident and the corrective actions Facility reports no spills except for one incident with one of the sawdust compactors and a recent X leak on a compressor. Records of maintenance and repairs of control measures Corrective actions are tracked on the routine inspection forms. Part 5.4.4 X Records of employee training Employee training is currently managed by an online system. Part 5.4.11 X Records of ROUTINE quarterly inspections All inspections are conducted in-house by Facility personnel. Part 4.1/5.4.5 X Records of QUARTERLY VISUAL inspection of sw discharge (Collected in first 30 min of discharge; 0.1-inch storm; 72 hrs min from last rain) Part 4.2.1.2 X Records of ANNUAL Comprehensive inspections Records of Benchmark Sampling (annual unless exceeded) Not a permit requirement for this Facility. Part 4.3/5.4.5 X Part 6.1.3-4/8 X Representative Sampling App B.14.1 Indicator monitoring has not yet been conducted. If the facility wishes to perform visual sampling X and monitoring at the storm drain inlet identified in the SWPPP (see photo DSCN3022) instead of at Outfall 001 for easier access, this location should first be discussed with/approved by GA EPD. Non-stormwater certification onsite? (once/five years comprehensive e.g., dye/smoke testing) Visual assessment 01/26/22. Part 5.1.4.4/ X Impaired Stream Segment Sampling and Requirements? Not applicable for this Facility. Annual Reporting of Monitoring Data to EPD Appendix C Part 7.1 X X Indicator Monitoring Facility has not yet conducted any indicator monitoring, which was introduced as a requirement for X the 2022 permit cycle. Pollutant Sources 5. FIELD EVALUATION & PLAN IMPLEMENTATION Note location, quantitative description, design issue, O&M deficiencies, and pollutants offsite Loading/Unloading Area Everything is shipped in/out on trucks. Sawdust collected from the assembly line is loaded directly into a compactor, as shown in photo DSCN3013. Sawdust from the indoor mill is collected and loaded into a compactor at the location shown in photo DSCN3014. Page 4 of 6 Outdoor Storage Outdoor Manufacturing/ Processing Operations Metal rack material is stored outdoors as shown in photo DSCN3016. According to Facility personnel, unusable metals will be moved into the open top dumpster at the other end of the Facility for recycling. Recycling is collected approximately monthly. Cardboard is bailed and stored outside (see for example DSCN3014) while it awaits pickup for recycling. None. All processes are conducted indoors. Waste Treatment/ Storage/Disposal Areas The open top dumpster shown in photo DSCN3011 is used for cabinet waste and the compactor is used for trash. Facility also utilizes open top dumpsters as shown in photos DSCN3016 and DSCN3017 for pallets from warehouse and remnants from the mill. The dumpsters were not covered. Sediment & Erosion Controls (BMPs) Unloading/loading areas are all paved. Pervious surfaces around the site are vegetated. Spills / Leaks Handling / Good Housekeeping All maintenance activities and fluids are indoors, and spill kits are kept nearby. There is one floor drain inside which, according to Facility personnel, is connected to the sanitary sewer line. The storm drain inlets, as shown in photos DSCN3012 and DSCN3015, had some debris on the grates. Any outdoor sawdust is swept and collected as needed (approximately a couple of times a year). Once, there was a sawdust spill due to an issue with one of the compactors. The Facility vacuumed and cleaned out the pipes of the drainage system in response. As shown in photo DSCN3021, there was an oil leak from one of the compressors approximately one week prior to the day of the inspection. Facility personnel stated that the leak was promptly cleaned up. Staining on the asphalt shows that the leak did not reach a storm drain. 6. OUTFALL, STORMWATER DISCHARGE & RECEIVING WATER OBSERVATIONS OUTFALL, STORMWATER, DISCHARGE, & RECEIVING WATER Number & location of stormwater discharge(s)/outfall(s) consistent with SWP3 YES NO DESCRIPTION Water from the site's drainage system discharges into a retention X area, as shown in photo DSCN3022, which is identified as Outfall 001. Evidence of off-site accumulation of pollutants observed in receiving water X None observed. Non-stormwater discharge observed X None observed. Page 5 of 6 Exit interview conducted with: David Headley Preliminary findings discussed during the exit interview included: - Dumpsters should either be covered or otherwise managed using an equivalent BMP. - Maintenance activities/corrective actions, such as when the Facility cleaned out of the storm drain system after a sawdust spill, should also be tracked or recorded. - An electronic copy of the SWPPP was emailed to inspectors during the inspection. Photo Log is attached. Page 6 of 6 American Woodmark Corporation - Jackson Operations Stormwater CEI - August 13, 2024 Overview Map Imagery Date: 12/2022 Note: Due to camera error, GPS locations were not recorded for each photograph. GPS locations were approximated for the photos represented by red icons on the above map. White icons indicate photo locations sourced from the camera. American Woodmark Corporation - Jackson Operations Page 1 of 13 August 13, 2024 DSCN3011.JPG Description Time Stamp Date Stamp Attributes View of the loading area on the south side of the building. The open top dumpster is used for cabinet waste, and the compactor is used for solid trash. 03:46:18 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 2 of 13 August 13, 2024 DSCN3012.JPG Description Time Stamp Date Stamp Attributes Location of a storm drain inlet. Water drains northerly (approximately towards photographer's right). Tower visible in the background stores water for emergency fire suppression purposes. 03:49:08 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 3 of 13 August 13, 2024 DSCN3013.JPG Description Time Stamp Date Stamp Attributes Sawdust collection system for the assembly line loads sawdust into a compactor and hauled offsite. There was no sawdust spillage at the time of the inspection. 03:52:44 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 4 of 13 August 13, 2024 DSCN3014.JPG Description Time Stamp Date Stamp Attributes View of the dust collection system for the indoor mill. Sawdust is loaded into a compactor. 03:56:42 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 5 of 13 August 13, 2024 DSCN3015.JPG Description Time Stamp Date Stamp Attributes View of a storm drain inlet on the eastern side of the building. Debris had accumulated on the grate and was in need of cleaning. Water flows opposite of camera direction. Trailers are stored in the yard here. 03:58:46 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 6 of 13 August 13, 2024 DSCN3016.JPG Description Time Stamp Date Stamp Attributes View of outdoor storage area. Metals are used for rack work. Waste rack metals will be loaded into the dumpster at the front of the facility for recycling. Recycling pick up is about once per month. See also photo DSCN3017. 04:04:18 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 7 of 13 August 13, 2024 DSCN3017.JPG Description Time Stamp Date Stamp Attributes The two open top dumpsters on this end of the Facility contain miscellaneous wood debris including pallets from the warehouse and remnants from the mill. 04:05:26 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 8 of 13 August 13, 2024 DSCN3018.JPG Description Time Stamp Date Stamp Attributes Looking downgradient. Water from the storm drain system on the eastern side of the building discharges in the direction shown into this retention area. 04:12:26 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 9 of 13 August 13, 2024 DSCN3019.JPG Description Time Stamp Date Stamp Attributes Looking downgradient. Once water in the low retention area reaches a certain height, it discharges through the outlet structure and towards the railroad tracks, in the direction shown in photo DSCN3020. 04:15:42 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 10 of 13 August 13, 2024 DSCN3020.JPG Description Time Stamp Date Stamp Attributes Looking downgradient. Water from the retention area behind the parking lot discharges through the outlet structure and continues towards the railroad, in the direction shown here. 04:19:42 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 11 of 13 August 13, 2024 DSCN3021.JPG Description Time Stamp Date Stamp Attributes There was a recent oil leak on one of the Facility's compressors, which Facility personnel stated was cleaned up. Based on the residual staining on the asphalt, the leak did not reach a storm drain inlet. 04:34:30 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 12 of 13 August 13, 2024 DSCN3022.JPG Description Time Stamp Date Stamp Attributes View of the site map from the Facility's SWPPP 04:51:32 PM 08/13/2024 American Woodmark Corporation - Jackson Operations Page 13 of 13 August 13, 2024