Document Rar9Dj95NvqXXYbJv6d9Bjg18

CWA COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Facility: Chemtrade Logistics, Inc. - East St. Louis Works 2500 Kings Highway East St. Louis, Illinois 62201 NPDES Permit Number: IL0000647 and ILR001080 Purpose: To evaluate compliance with applicable stormwater regulations under the National Pollutant Discharge Elimination System (NPDES) permit program and the Clean Water Act (CWA). Date of Inspection: March 31, 2022 EPA Region 5 Water Enforcement Compliance Assurance Representatives: Keith Middleton, Environmental Engineer, middleton.keith@epa.gov, 312-886-6465 Valerie Dooling, Environmental Engineer/Scientist, dooling.valerie@epa.gov, 312-886- 7167 Facility Representatives: Robb Woolen, Environmental Health and Safety Manger, Chemtrade Logistics, rwoolen@chemtradelogistics.com, 618-271-2430, ext 150 Gustavo (Gus) Tonding, Plant Manager, Chemtrade Logistics, Gtonding@chemtradelogistics.com 618-271-2430 Report Prepared by: Keith Middleton, Environmental Engineer Digitally signed by KEITH KEITH MIDDLETON MIDDLETON Inspector Signature: _________________________D_at_e_: 2_0_2_2._0_5._2_3 _14_:_52_:_05_-_0_5'_00_'______________ Approver Name and Title: Ryan Bahr, Section 2 Supervisor, Water Enforcement and Compliance Assurance Branch Approver Signature and Date: Bahr, Ryan Digitally signed by Bahr, Ryan ________________________D_a_t_e:_2_0_2_2_.0_5_.2_4_1_5_:4_6_:0_7_-_0_5_'0_0_' ____ Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 INTRODUCTION On March 31, 2022, representatives from the U.S. Environmental Protection Agency, Region 5 conducted a Compliance Evaluation Inspection at the Chemtrade Solutions LLC - East St. Louis Works in East St. Louis, Illinois ("facility"). The purpose of this inspection was to evaluate this facility's compliance with the CWA and the facility's two National Pollutant Discharge Elimination System Permits ("NPDES permits"). This inspection consisted of the following: an opening conference, discussions concerning the facility's Stormwater Pollution Prevention Plan (SWPPP), compliance with this facility's NPDES permits, facility walk-through, and a closing conference. Any findings and concerns that EPA identified during the inspection are listed in the section entitled "Areas of Concern" starting on page 13 of this report. FACILITY BACKGROUND This facility is owned and operated by Chemtrade Solutions LLC ("Chemtrade"). According to the facility's 2017 Stormwater Pollution Prevention Plan (SWPPP), this facility is located on a 153-acre site that consists of approximately 10 acres of manufacturing process area. Production of chemicals started at this facility in the 1880's. According to Robb Woolen, Chemtrade purchased this facility from another chemical production company, General Chemical, in approximately 2007. There are 29 employees that work at this facility. Chemical production occurs 24 hours a day, seven days a week within three shifts. The facility's Standard Industrial Classification (SIC) code is 2819 (Industrial Inorganic Chemicals, Not Elsewhere Classified). This facility produces water/wastewater treatment chemicals, such as dry aluminum sulfate (Alum) and Polyaluminum chloride hydroxide sulphate (PAC), and additional proprietary blends of PAC and certain polymers. Final products are either wet or dry and are stored at the facility after production prior to be shipped. Raw materials stored at the facility and used in production include: wet Alum, sulfuric acid, alumina hydrate (Hydrate), aluminum chloride, hydrochloric acid, aluminum chlorohydrate, soda ash and certain polymers. Raw materials are brought to the facility either by rail car or truck. Final products are shipped out from the facility by truck. Receiving Waters During the inspection, EPA was informed by facility representatives that Rose Creek was the receiving waters for the facility's two permitted outfalls. Rose Creek is located just beyond the facility's southern property boundary. Rose Creek is a small drainage ditch that is not identified on the most current USGS topographic map. EPA was also told during the inspection by facility employees that Rose Creek drains to the west to Rose Lake. National Pollutant Discharge Elimination System Permit Illinois Environmental Protection Agency (Illinois EPA) has issued this facility both an individual National Pollutant Discharge Elimination System (NPDES) permit (permit no. 2 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 IL0000647) for its wastewater discharge and a general industrial stormwater NPDES permit (permit no. ILR001080). NPDES Permit - IL0000647 This facility's current individual NPDES wastewater permit ("Individual Permit") became effective on August 1, 2019 and expires on July 31, 2024. A copy of this permit is included in this inspection report as Attachment B. The facility's Individual Permit identifies one wastewater discharge location (Outfall 001) that includes a stormwater component. Outfall 001 has effluent limitations for pH, temperature, total suspended solids (TSS), Oil and Grease, and total residual chlorine. The Individual Permit also identifies a stormwater only discharge outfall (Outfall 002). Outfall 002 has no effluent limits associated with the discharge; it does have stormwater requirements in Special Condition 9 of this Individual Permit (along with the stormwater that is discharged from Outfall 001). Both of these outfalls are identified in the permit to discharge to Rose Creek. The stormwater specific requirements of Special Condition 9 include, among other requirements: The development of a Stormwater Pollution Prevention Plan (SWPPP); The creation of a site map; Quarterly visual assessment of stormwater discharges; Annual inspection and report; Construction authorization for treatment equipment; and Reporting to Illinois EPA. NPDES Permit - ILR001080 This facility's current NPDES general industrial stormwater permit ("Stormwater Permit") became effective on April 5, 2017 and expires on March 31, 2022. On the date of this report, this permit had been administratively extended by Illinois EPA. A copy of this permit is included in this inspection report as Attachment C. It is not clear when Chemtrade originally submitted an NOI for this facility to the Illinois EPA to initiate Stormwater Permit coverage, although the facility has provided EPA a copy of the most recent submitted Stormwater Permit renewal from October 28, 2013. The requirements of this Stormwater Permit overlap with some of the conditions of Special Condition 9 in the Individual Permit; the following are some of the additional stormwater compliance conditions: Allowable non-stormwater discharges are identified; Routine facility inspections; Additional SWPPP documentation requirements (initial copy of NOI, copy of Stormwater permit, documentation of maintenance, all inspection reports, description of any deviation from visual assessment/monitoring, description of corrective actions taken, benchmark sampling exceedances, changes in pollutant of concerns, and changes in facility status); De-icing storage requirements; 3 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 Additional spill prevention and response provisions Additional employee training requirements; and Additional corrective action requirements; In addition, the Stormwater Permit includes benchmark monitoring within Attachment 1, Subsector C2 (Industrial Inorganic Chemicals) in the Stormwater Permit, that the facility would be subject to due to its SIC code. This requires the facility to have conducted benchmark monitoring for four discharge events commencing within 180 days of the effective date of this permit. Pollutant parameters to be analyzed for this industrial subsector include: total aluminium, total iron, and nitrate plus nitrite nitrogen. The full benchmark requirements for this facility are located within the Stormwater Permit, Attachment 1 (Attachment C of this report). Permit Compliance EPA's public compliance tracking website, EPA ECHO (www.echo.epa.gov), indicates that this facility did not submit DMRs for the months of November 2018, April 2019, May 2019, June 2019, and July 2019 and its annual stormwater inspections from 2016, 2019, and 2020 to the Illinois EPA. EPA ECHO also indicated that the Illinois EPA sent a letter of violation/warning letter to the facility on October 9, 2019 regarding the NPDES permit compliance issues. During the inspection, EPA learned that Chemtrade and the Illinois EPA were in the process of negotiating an enforcement action based on the missing DMR submittals. The Illinois EPA enforcement action did not include the missing annual stormwater inspection submittals. 4 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 SITE INSPECTION Exhibit 1: Chemtrade - East St. Louis Works Facility Location1 Source: EPA WATERS Geo Viewer (2018) Initial Inspection Discussion The EPA inspection team, consisting of Mr. Middleton and Ms. Dooling, arrived at the facility at approximately 8:30 am on Thursday, March 31, 2022. The weather was cloudy and dry with a temperature of approximately 40 Fahrenheit. According to weather information from the National Weather Service, a nearby municipality (Edwardsville, Illinois) received more than 2.5 inches on the previous day. EPA inspectors drove up to a closed gate at the facility and identified themselves as EPA inspectors. After entering the facility's property, parking at the main office, and waiting in the office waiting room, EPA inspectors met Robb Woolen and proceeded to meet in his office. EPA spoke with Mr. Woolen, explained that EPA was here to conduct a CWA industrial stormwater inspection and presented their inspector credentials to Mr. Woolen. Mr. Woolen is this facility's Environmental, Health, and Safety (EHS) Manager and has been in this position since February 2022.Next, EPA discussed the overall purpose of this inspection and EPA's Confidential Business Information (CBI) provisions. EPA then went over the documents it would be requesting copies of as part of its inspection. These requested documents are identified on page 12 of this inspection report. Initially, Mr. Woolen began looking through his files to find these documents. During this search, Mr. 1 Notes on Exhibit 1: The cyan box is the facility's main production area, the yellow box is the facility's main office and, the green circle is the recycle water pond. 5 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 Woolen provided EPA a site map from the facility's Spill Prevention, Control, and Countermeasure (SPCC) plan that showed the two onsite outfall locations, the corresponding drain locations in the parking lot, and the different chemical storage locations within the facility. EPA began reviewing this map. EPA and Mr. Woolen then agreed that the facility would send these requested documents after the inspection. EPA and Mr. Woolen then began discussing the facility's industrial processes and its compliance with associated environmental rules and regulations related to stormwater. The following is a summary of the discussions EPA had with facility's representatives before a walk-through of the site. Facility Processes and Wastewater Generation EPA and Mr. Woolen discussed the facility process and the wastewater generation. Mr. Woolen informed EPA that this facility does not discharge process wastewater to Rose Creek through Outfall 001. Instead this facility stores its wastewater and then ships the wastewater out for treatment via tanker trucks, using Illini Environmental, an environmental contracting service. Illini Environmental is located in Caseyville, Illinois. Mr. Woolen estimated that approximately 4,700 gallons of week of wastewater are shipped out each week from this facility. Photograph 71 in Attachment A shows the wastewater storage tank. Chemtrade is potentially considering a future project that would treat wastewater and allow for its reuse in this facility's production processes. The facility is connected to and uses city water from Illinois American Water in its processes, along with recycled process water stored in a lined pond ("recycle water pond"). The recycle water pond also contains captured rainwater and pumped stormwater runoff from the facility's containment dikes. This stored water in the recycle water pond can be used, untreated, in the facility's production processes. This facility utilizes a septic system for sanitary wastewater generated onsite. Stormwater Pollution Prevention Plan When EPA was interviewing Mr. Woolen in his office, both Mr. Middleton and Ms. Dooling quickly reviewed this facility's SWPPP. EPA then took pictures of the facility's SWPPP; Photographs 1-27 in Attachment A are of the SWPPP that EPA briefly reviewed during the inspection. EPA received an electronic copy of the SWPPP from Mr. Woolen, via email, on April 14, 2022. During the inspection, EPA told facility representatives that EPA would conduct a more comprehensive review of the SWPPP after the inspection. The SWPPP was developed by AECOM and was dated December 2017. The SWPPP was signed on the second page by an what appears to be an AECOM engineering/consultant representative along with two other unknown signatures. Section 1 includes basic facility information, the facility's stormwater pollution prevention team, and a description of the production activities at the facility. Section 2 includes a description of the potential pollutant 6 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 sources, areas of potential spills and leaks and non-stormwater discharge evaluation. Also of note, Section 2 includes a statement that no salt is stored at this facility and that baseline stormwater samples should be taken from Outfall 001 for the first four quarters following the issuance of the permit. Section 3 of the facility's SWPPP includes stormwater control measures such as the facility's good housekeeping protocols, stormwater maintenance, spill response procedures, erosion/sediment controls, and employee training. Section 4 of the facility's SWPPP includes schedules and procedures for onsite stormwater monitoring. Section 5 contains the facility's inspection procedures, including the routine facility inspections, the quarterly visual observations of discharges, and the annual facility inspection. Section 6 of the facility's SWPPP was blank and determined by Chemtrade to be not applicable to this facility. Section 7 includes the SWPPP certification page, the copy EPA reviewed during the inspection (Photograph X of Attachment A) and received on April 14, 2022 was unsigned. Section 8 contains the procedures to modify the SWPPP. The SWPPP also contains a number of attachments, including the SWPPP site map and the water permits associated with this facility. Site Inspections EPA also asked Mr. Woolen about the missing annual stormwater site inspections. Mr. Woolen acknowledged that annual stormwater inspections in 2020 and 2021 had not been conducted by the previous EHS officer, and that individual had not conducted quarterly reports from the second quarter of 2019 to the third quarter of 2021. In the fourth quarter of 2021, an acting EHS officer for the facility, Rick Bullis, did conduct a quarterly stormwater site inspection. Other Items Discussed: - Mr. Woolen indicated to EPA that the facility had attempted to jet the Outfall 001 drain and sewer in this location to remove a potential blockage in January 2022. The blockage at Outfall 001 prevented discharge from the outfall. This problem was not resolved with the sewer cleaning. Zachary Wanersten, a process engineer at this facility, also discussed this issue with EPA. - Mr. Woolen currently fills out the NetDMRs for electronic submittal to Illinois EPA. - Mr. Woolen will be conducting the annual and quarterly stormwater inspections moving forward. Mr. Woolen indicated to EPA that he had planned to do a quarterly stormwater inspection today. - When conducting the quarterly visual inspection, Mr. Woolen told EPA that he will also be testing the stormwater sample for pH. - Mr. Woolen told EPA that an engineering consultant, Burns and McDonnell, was under contract and would soon begin updating the facility's current SWPPP. - Bill Revis was this facility's EHS manager from approximately April 2019 to October 2021. Rick Bullis was the acting facility EHS manager from October 2021 until Mr. Woolen was hired. 7 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 - Mr. Woolen and Gus Tonding, Plant Manager, informed EPA that they were not aware of any spills that have occurred onsite in the last year. Facility Walk-Through At approximately 10:40 am, Mr. Middleton, Ms. Dooling and Mr. Woolen were joined in Mr. Woolen's office by Gus Tonding. Soon after, EPA and the facility representatives began a walkthrough of the facility, starting with the stormwater drains in the parking lot/paved area south of the facility's main office building. The first stormwater drain observed was tributary to Outfall 002 (Photographs 28 and 29 in Attachment A). EPA looked in the drain and noticed that there was water flowing in the drain to the south towards Outfall 002. EPA asked Mr. Woolen where he would take a sample when he conducted its visual observation during the quarterly stormwater inspection. Mr. Woolen answered that he takes a sample at the stormwater drain. Next, EPA and facility representatives walked a short distance to the parking lot drain tributary to Outfall 001. This drain had water ponded above it and was not draining or flowing at the time of the inspection (Photographs 30 and 31 in Attachment A). Facility representatives indicated that they believed the sewer downstream of this location was collapsed and blocking the flow. Next EPA and facility representatives walked to the southwest corner of the facility to look at the salt storage shed. Along the way, EPA observed an empty building in between the stormwater drains and the salt storage shed. Facility representatives indicated that this building would likely be removed soon. EPA could also observe the building along the west property boundary of the site, seen in Photograph 34 of Attachment A. Mr. Tonding told EPA that empty totes are currently stored in this building; there is also a warm/heated room in the building where polymers are stored. EPA then observed the salt storage building (Photograph 35 of Attachment A). EPA was told by facility representatives that the salt pile in the building was filled up once a year and the salt was used for deicing during the winter. EPA then noticed a small amount of salt that was outside of the enclosed storage area and potentially exposed to stormwater; EPA did not observed any clear evidence that this small amount of salt in this area had eroded or contributed to stormwater runoff recently. Approximately 35 feet east of the salt storage shed, EPA did observe evidence of erosion with a gray/white residue associated with it leading offsite towards Rose Creek. There was no flow occuring from this location at the time of this inspection. It was unclear to EPA whether the residue was salt or gravel particles. After observing the salt storage shed and the potential erosion east of salt storage shed, EPA and facility representatives walked to the stormwater outfall access gate along the south property boundary that is used in order to observe Outfall 001 and Outfall 002. After walking through the access gate and entering railroad property with facility representatives, EPA observed Rose Creek. Rose Creek appeared to be relatively stagnant at the time of the inspection with standing water located in the creek. The area around the creek was muddy and wet from the previous 8 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 day's precipitation with tall grass/vegetation located on both sides of the creek. EPA viewed the Outfall 002 discharge location to Rose Creek (Photograph 38 and 39 in Attachment A). The drainage pipe was partially buried, and it was difficult to tell if water was being discharged from Outfall 002 during the inspection. After EPA observed Outfall 002, both EPA and facility representatives began looking for Outfall 001. During this time, EPA observed additional evidence of erosion near the stormwater outfall access gate from the facility's property to the rail yard (Photograph 41 in Attachment A). After approximately 10 minutes, the facility representatives found Outfall 001 (Photograph 42 in Attachment A). Outfall 001 was partially buried and looked slightly collapsed. Outfall 001 did not appear to be discharging during the time the outfall was observed by EPA. EPA and facility representatives then walked back through the access gate and re-entered facility property. EPA then observed a tanker truck filling up with finished product (Photograph 43 in Attachment A). There was a containment pad within the paved/gravel surface area that would contain small spills if they occurred when filling tanker trucks with product. Next, east of the stormwater outfall access gate EPA observed additional potential erosion, , leading from the facility through the property fence to the off site railroad property (Photograph 44 in Attachment A). Then, EPA and the facility representatives began walking the southern portion of the facility's main production area. The product storage tanks shown in Photograph 46 in Attachment A demonstrate the facility's use of primary containment dikes (approximately 24inch high concrete barriers) for each tank storage location in the main production area with smaller secondary containment in the facility's paved areas nearby. Rainwater captured in the primary containment dikes is pumped to the wastewater tank . As EPA and the facility representatives kept walking along the southern portion of the facility's main production area, EPA noticed a dumpster that was rusted out, with an orange material leaking out of the bottom of the dumpster. EPA was unclear what this orange material was; it appeared to have congealed into a solid-like material within standing water at the time of this inspection. This dumpster was exposed to stormwater and there was no primary or secondary containment structure that would prevent runoff during a heavy precipitation event. Next, EPA and the facility representatives began walking through the two main production buildings to the north side of the facility's main production area. During this portion of the walk through, EPA observed discarded Hydrate that was left between buildings and potentially exposed to stormwater (Photographs 51 and 52). Facility representatives indicated that any stormwater in this location would be contained in this area and not tributary to the storm sewer system. When EPA reached the northern portion of the facility's main production area, EPA noticed that there was more white material on the ground near the rail car unloading area. Facility representatives indicated that this was also Hydrate. EPA did not observe any erosion of this material to any drainage way or drain in this location of the facility. EPA and facility representatives then looked at a drainage ditch, located north of the facility's main production area ("north drainage ditch"). The north drainage ditch is designed to flow into 9 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 the storm sewer system (tributary to Outfall 001), but a culvert within the access road to the stormwater pond and the back of the facility's main office had been crushed/blocked to the point where the upstream portion of the ditch, shown in Photograph 56 in Attachment A, did not drain. Facility representatives indicated that a work order was in place to fix the culvert. EPA continued walking with facility representatives to the east along the north drainage ditch, north of the main production area. As EPA walked east, the north drainage ditch became less defined and the ponded water seemed to have a milky gray/white appearance (Photographs 59, 60, and 61). EPA then observed an older portion of the facility that was no longer in active production. This area was in the process of being decommissioned and cleaned-up. The industrial process that was previously utilized in this location of the facility required diatomaceous earth, a natural clay-like substance, as filter material for a finished manufactured product. The diatomaceous earth had accumulated within this diked containment area over the years and was now being removed (Photograph 64 in Attachment A). The diked containment area was uncovered and exposed to stormwater. Facility representatives indicated that the accumulated water in the containment area was pumped to the recycle water pond (Photograph 63 in Attachment A) and reused in the facility's production process and that the facility was currently having the diatomaceous earth removed and hauled off-site. EPA observed white material on the paved access road tracked from the diatomaceous earth removal area to the upper portion of the north drainage ditch. EPA and the facility representatives then walked to the west along the north drainage ditch and proceeded north up a hill to the recycle water pond. On the way up the hill to the recycle water pond on a graveled access road, EPA observed erosion down the access road towards the north drainage ditch at the foot of the hill (Photograph 65 in Attachment A). EPA and the facility representatives then viewed the recycle water pond at the top of the hill. The recycle water pond is a lined pond that stores both rainwater and process water before that water is used in the facility's production process. EPA observed that the water level with the previous day's rain looked high, facility representatives indicated that there is not a level sensor associated with the pond, but facility employees track the water level throughout the day (Photographs 65 and 66 in Attachment A). Neither Mr. Woolen or Mr. Tonding were aware of a time when the recycle water pond overtopped its banks nor were they aware of a time where the recycle water pond was dry. EPA also observed the water in recycle water pond had an orange discoloration, especially on the sides of the pond (Photograph 66 in Attachment A). Next, EPA and facility representatives walked to the scrap material storage yard that was located east and north of the facility's main office. Photograph 68 in Attachment A shows the portion of the scrap yard north of the facility's main office. EPA did not observe any stormwater drains in this location. EPA and facility representatives then walked north to the above ground diesel and waste oil storage tanks area. These tanks were located on a concrete pad with dike containment on three sides. Next, EPA observed an unused containment pad filled with water which had drums at the end of the pad (Photograph 70 in Attachment A). Facility representatives indicated 10 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 to EPA that these drums were empty. EPA did not observe any stormwater drains near the ground diesel and waste oil storage tanks area. EPA and facility representatives then walked back through the facility's main production area to the wastewater storage tank. The wastewater storage tank was within the facility's Hydrate processing area on the second floor of the building (Photograph 71 in Attachment A). EPA and facility representatives next left the production area and walked to the wastewater filling area, used by Illini Environmental to empty the wastewater storage tank into trucks to haul the wastewater offsite for treatment. Near the filling area, EPA noticed a second stormwater drain that was not shown on the facility's provided site map (Photographs 72 and 73 in Attachment A). EPA also observed that a hose was discharging water that was flowing to the stormwater drain (Photograph 74 in Attachment A). Mr. Woolen indicated that this was a steam condensate pipe from the facility's process building that was being used to route steam away from the wastewater filling area. Mr. Woolen also indicated that he believed this stormwater drain was connected to Outfall 002. EPA observed discarded white material, possibly Hydrate, that was exposed to stormwater and located upstream of the stormwater drain. EPA saw that there was previous evidence that it appeared like the white material had flowed toward the stormwater drain with runoff (Photograph 73 in Attachment A). EPA also observed some full chemical storage totes in the vicinity of the wastewater filling area. Mr. Woolen told EPA that these totes held wastewater that was unable to be accepted by Illini Environmental, due to a low pH measurement of the wastewater. EPA finished its walk-through of the site at approximately 12:15 pm and walked back to the Mr. Woolen's office in the facility's main office building for the closing conference. Closing Conference In Mr. Woolen's office, Mr. Middleton began the closing conference at approximately 12:36 pm. Ms. Dooling, Mr. Tonding, Mr. Woolen were all present for the closing conference. In addition, Chris Miller, Acting Regional Manager for Environmental Health and Safety for Chemtrade, participated in the closing conference via phone. Before the closing conference began, EPA asked Mr. Miller about the large piece of facility property north and northeast of the main facility production area. Mr. Miller told EPA that this area has inactive holding ponds that had been previously used as a dumping area by the facility until approximately the 1980s. After a cement recycler reused some of the materials in this location off-site, this portion of the facility went dormant. Chemtrade has recently been in discussions with the Illinois EPA on developing a Resource Conservation and Recovery Act (RCRA) corrective action plan. Mr. Miller also told EPA that currently, any of the stormwater runoff from the piled material in this location would drain back into the holding ponds. There is also on-going ground water monitoring occuring within this portion of the site. 11 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 EPA then went over the preliminary concerns it found during its inspection, some of which are listed below. EPA indicated that it would review the information it had requested when it receives it and follow-up as needed with Mr. Woolen after the inspection. EPA also told facility representatives that it would develop an inspection report that summarized its inspection of this facility and anticipated that it would provide a copy of the report in approximately 60 days to Chemtrade. After EPA answered the facility representatives' inspection report procedural questions and why this site was selected for an CWA inspection, the closing conference ended at approximately 12:55pm. EPA ended the inspection and exited the facility at approximately 1:00 pm. DOCUMENTS OBTAINED DURING THE INSPECTION: A. Facility Site Map DOCUMENTS REQUESTED DURING THE INSPECTION: Current Stormwater Pollution Prevention Plan Last 3 years of Annual Stormwater Inspections Quarterly inspections in the last three years. Notice of intent for SW permit originally submitted to Illinois EPA Current NPDES permit (IL0000647) Training listed and records available Illinois EPA October 2019 letter of violation/warning letter Last NPDES permit application Various safety data sheets for chemical used by facility DOCUMENTS OBTAINED AFTER THE INSPECTION: On April 14, 2022, EPA received the following documents electronically from Mr. Woolen, by email. A. Stormwater Pollution Prevention Plan, dated December 2017 B. Updated facility contacts page in SWPPP, dated April 4, 2022 C. Current NPDES permit (IL0000647) D. General Industrial Stormwater NPDES permit (ILR001080) E. March 1, 2021 to March 1, 2022 Annual Stormwater Inspection F. March 1, 2020 to March 1, 2021 Annual Stormwater Inspection G. Basic Process Block Diagram (Chemtrade - East St. Louis Works) H. NPDES permit application for IL0000647 I. Site Map of Facility, dated December 5, 2017 12 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 J. Stormwater/SWPPP Training Quiz K. Permit renewal for ILR001080 with Notice of Intent, dated October 28, 2013 L. Notice of Violation Letter from Illinois EPA to Chemtrade, dated October 4, 2019 M. Settlement Offer Letter from Illinois EPA to Chemtrade, dated February 28, 2022 N. Settlement Offer Response from Chemtrade to Illinois EPA, dated March 11, 2022 O. SWPPP training PowerPoint P. Safety Data Sheet - Dry Aluminum Sulfate Q. Safety Data Sheet - Liquid Aluminum Sulfate R. Safety Data Sheet - Diatomaceous Earth S. Safety Data Sheet - Soda Ash (Sodium Carbonate) AREAS OF CONCERN: EPA has identified areas of concern based on findings during the inspection of the Chemtrade Logistics - East St. Louis Works and based on a post-inspection review of the information provided to EPA by facility representatives. An enumerated list of the areas of concern are listed below: 1. Quarterly Visual Observations of Discharges: Section J.1 of the Stormwater Permit and Special Condition 9, Section H of the Individual Permit requires the facility to perform and document a quarterly visual observation of a stormwater discharge associated with industrial activity from each outfall. In addition, Section 5 of the facility's SWPPP included procedures on conducting the quarterly visual observations. After EPA's inspection, EPA received this facility's quarterly visual observations of stormwater from the first quarter of 2019, the fourth quarter of 2021, and the first quarter of 2022. EPA did not receive quarterly visual observations from the second quarter of 2019 to third quarter of 2021. 2. Annual Site Inspections: Section K.1 of the Stormwater Permit and Special Condition 9, Section I of the Individual Permit requires this facility to submit a copy of its annual site stormwater inspection to the Illinois EPA. In addition, Section K.5 of the Stormwater Permit requires Chemtrade to retain the annual site inspections on file for at least three years. When EPA asked for the copies of the annual site inspections for the last three years, Mr. Woolen indicated that the facility had not conducted an annual site inspection in 2020 and 2021. On April 14, 2022, Chemtrade sent EPA the first page of the March 1, 2020 to March 1, 2021 and the March 1, 2021 to March 1, 2022 annual site inspections. This submittal did not include EPA's annual reporting form, which documents the result of the inspection and is included in Attachment G in the facility's SWPPP. The submittal also did not meet the requirements contained in the Stormwater Permit (Section K.1) due to the lack of quarterly inspections attached to the annual site inspection report and the Individual Permit (Special Condition 9, Section R) requirement because of the results of the inspection were not included in the submittal. In addition, EPA did not receive an annual site inspection for the March 1, 2019 to March 1, 2020 timeframe. 13 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 3. Routine Facility Inspections: Section G.1 of the Stormwater Permit requires this facility to conduct a routine facility stormwater inspection at least quarterly. EPA does not have any evidence that these routine facility inspections had been conducted from the aecond quarter of 2019 to the third quarter of 2020. In addition, EPA is unclear if the routine facility inspection that were conducted if those inspections: : a. Occurred after at least 0.25 inches of rain; and b. Had a member of the SWPPP team was present during each of the routine facility inspections. 4. Housekeeping Issues: During the inspection, EPA observed a dumpster rusting out at its bottom and located in standing water. This dumpster was leaking out an orange material at the bottom (Photograph 48 in Attachment A). EPA also observed discarded raw material used in the facility's chemical production (Photographs 49, 59, 60, 61, 73, and 74) throughout the site with the potential to be exposed to stormwater. Section F.2.c of the Stormwater Permit and Special Condition 9, Section F.3 requires the maintenance of clean, orderly facility areas that discharge stormwater. 5. North Drainage Ditch: During EPA's walkthrough of the site, EPA observed the north drainage ditch, located north of the facility's main production area. EPA notes the following concerns regarding the north drainage ditch: a. Facility representatives noted that a collapsed culvert was blocking entry of the flow from the north drainage ditch into the facility's stormwater system. This blockage may indicate improper operation and maintenance of an onsite facility and/or system of treatment and control (Attachment H, General Conditions #5 of the Individual Permit). EPA notes that facility representatives did indicate that a work order had been put in to fix the culvert. b. Because of the collapsed culvert, the north drainage ditch had backed up and was ponded east of the culvert. EPA observed further upstream a white residue within the ponded stormwater (Photographs 60 and 61 in Attachment A). Near this location, the facility had a diatomaceous earth removal operation on-going. It also appeared that there may be some tracking of the diatomaceous earth from the removal area. EPA is concerned that this material may flow into the facility stormwater system and be discharged to Rose Creek, especially once the collapsed culvert is fixed. 6. Recycle Water Pond: During EPA's inspection, EPA was told by facility representatives that there was no level sensor measuring the water surface elevation in the recycle water pond. Although it was indicated to EPA that the pond would be monitored on a daily basis, EPA is concerned that the pond could overtop if a large amount of recycle water needed to be stored at the pond during a heavy precipitation event. The overtopping of the recycle water pond could be an indication of improper operation and maintenance of an onsite facility and/or system of treatment and control (Attachment H, General Conditions #5 of the Individual Permit). EPA observed during the inspection that the overtopping water from the recycle water pond would likely flow towards the north drainage ditch and enter the facility's stormwater sewer system. 14 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 7. On-site Storage of Salt: During EPA's inspection, EPA observed a building on the southwest corner of the facility's property that was being used for salt storage. Facility representatives indicated that this salt was used during the winter as a deicer for the facility's roads and parking lots. The facility's SWPPP had conflicting information on the use and storage of salt onsite; both Sections 2.4 and 3.7 indicated that no salt was stored onsite at the facility. Section F.2.h of the Stormwater Permit requires that the storage of deicing materials, such as salt, be identified in the facility's SWPPP. In addition, EPA observed an area near the salt storage building of potential erosion with a white/gray residue (Photograph 36 in Attachment A). EPA is unclear if this white/gray residue is potentially excess salt or sediment that may have eroded offsite towards Rose Creek. 8. Potential On-Site Erosion Areas: Within EPA's walkthrough of the facility, EPA observed four different locations of potential onsite erosion (Photographs 36, 41, 44, and 65 in Attachment A). Three of these locations (Photographs 36, 41, and 44 in Attachment A) appeared to flow offsite to the south toward the rail yard. Section F.2.f of the Stormwater Permit requires the facility to minimize erosion by stabilizing exposed soils at the facility or use structural/non-structural controls measures to prevent the discharge of sediment. EPA did not observe any measures or any other best management practices (BMPs) at the four locations noted above. Note that during EPA's review of the materials submitted by Chemtrade on April 14, 2022; a map (Attachment E) within the Stormwater Permit renewal indicated the potential for erosion in four locations along the southern property, in similar locations to where EPA observed the potential erosion evidence. The facility's SWPPP contained no reference or discussion of these potential erosion areas on the southern property boundary. 9. Stormwater Pollution Prevention Plan: EPA has reviewed the facility's SWPPP and compared it with the requirements in its currently effective Stormwater Permit and Individual Permit. EPA has the following concerns: a. Section E.1.a of the facility's Stormwater Permit and Special Condition 9, Section A.1 of the facility's Individual Permit requires that the SWPPP be designed for a storm event equal or greater than a 25-year, 24-hour rainfall event. EPA is unclear if this design criteria has been met within the facility's current SWPPP; EPA found no reference in the SWPPP to the 25-year, 24-hour rainfall event. b. Section E.5.a of the Stormwater Permit and Special Condition 9, Section E.1 of the Individual Permit requires a topographic map to be included with the SWPPP. In the facility's SWPPP, this map is labeled as the "general location map" and is Attachment A of the SWPPP. After EPA's review of this map, the location of Rose Creek was not shown on the facility's general location map, as required by both the Stormwater Permit and the Individual Permit in the above referenced sections, respectively. c. Section E.5.b of the Stormwater Permit and Special Condition 9, Section E.2 of the Individual Permit requires a site map to be included with the SWPPP. In the 15 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 facility's SWPPP, this map was included in Attachment B. After EPA's review of this map, EPA notes the following concerns: i. The aerial used for the site map appears to be out-of-date and does not show all of the onsite buildings that make up the current facility. ii. There is no outline of the stormwater drainage areas for the stormwater outfalls, as required by Section E.5.b.ii of the Stormwater Permit and Special Condition 9, Section E.2.ii of the Individual Permit; iii. The diatomaceous earth removal area on the far east-side of the facility was not listed as a disposal site and/or as an activity that generates significant quantities of dust or particulates (Section E.5.b.iv of the Stormwater Permit and Special Condition 9, Section E.2.iv of the Individual Permit) iv. The existing dikes and drain/pump locations, used as primary stormwater containment for raw or finished storage materials in on-site storage tanks were not identified on the map as required by Section E.5.b.v of the Stormwater Permit and Special Condition 9, Section E.2.v of the Individual Permit. v. The location of Rose Creek was not shown on the facility's general location map, as required by the Section E.5.b.vi of the Stormwater Permit and Special Condition 9, Section E.2.vi of the Individual Permit. vi. During EPA's inspection, EPA observed several potential areas of soil erosion. These potential areas of soil erosion were not shown on the facility's SWPPP site map as required by Section E.5.b.vii of the Stormwater Permit and Special Condition 9, Section E.2.viii of the Individual Permit. Please also see Concern #8. vii. All material loading, unloading, and transfer locations are required to be shown on the SWPPP, pursuant to Section E.5.b.ix of the Stormwater Permit and Special Condition 9, Section E.2.ix of the Individual Permit. EPA is concerned that potential loading/unloading sites were not shown on the building on the facility's west boundary (north of salt storage building) and the diatomaceous earth removal area on the facility east side. viii. Although EPA notes that stormwater flow arrows are used on the site map, EPA is concerned that the flow direction arrow for Rose Creek is incorrect. ix. Section E.5.b.xvii of the Stormwater Permit requires that the location of any material storage areas, including deicing materials, be identified on the site map. During the inspection, EPA learned that deicer (salt) is stored in a building on the southwest corner of the site. This storage location is not identified in the SWPPP's site map. Please also see Concern #7. d. The facility's SWPPP does not have any summary of previous sampling data describing pollutants in its stormwater discharges, pursuant to Section E.5.f of the Stormwater Permit. 16 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 e. Section E.5.c.ii of the Stormwater Permit requires that the facility's SWPPP have a list of pollutants that have the potential to be exposed to stormwater and discharged from the site. In addition, the facility must document all significant material that have been handled, treated, stored or disposed of, and that have been exposed to stormwater in the three years prior to the date the facility prepares or amends its SWPPP. In EPA's review of the SWPPP, neither diatomaceous earth, soda ash (sodium carbonate), nor salt were listed in the relevant portions of Section 2 within the facility's SWPPP. f. Special Condition 9, Section E.5 in the Individual Permit required that the SWPPP list both the size of the facility and the percent of impervious area of the facility. The facility's SWPPP only listed the size of the facility, in acres, and not the percent of impervious area of the facility. g. Section E.16.a within this facility's Stormwater Permit requires that a copy of the Notice of Intent (NOI) to be kept with the SWPPP. During the inspection, EPA discovered that a copy of the NOI was not with the SWPPP. h. Section E.16.d of the Stormwater Permit requires that the facility include all inspection reports, including Routine Facility Inspection Reports and its Quarterly Visual Assessment Reports, and benchmark monitoring results within the SWPPP. EPA did not find these documents during its review of the facility's SWPPP onsite, nor were these documents included in the SWPPP submitted to EPA by Chemtrade on April 14, 2022. i. Section E.16.e of the Stormwater Permit requires that the facility include any deviation from the schedule for visual assessments and/or monitoring, and the reasons for the deviations. There is no visual assessment information included in the SWPPP nor is there an explanation of this deviation. j. Page 2 of the SWPPP included facility contacts with facility names in Section 1.2 and the stormwater pollution prevention team's titles identified in Section 1.3. During the inspection, EPA noted that the names in this section were no longer working at the facility and that there were no names within the stormwater pollution prevention team section. On April 14, 2022, Mr. Woolen emailed EPA an updated version of the facility contacts (Section 1.2 of the facility's SWPPP) with his name identified as the SWPPP contact. It is unclear if the stormwater pollution prevention team was also updated with specific facility personnel. k. Section 2.3 of the SWPPP indicates that salt (deicer) is not stored at the facility. Salt is also not listed as a potential pollutant in Section 2.1 of the SWPPP. During EPA's inspection, EPA observed the salt storage building on the southwest corner of the site (Photograph 35 in Attachment A) and the potential for salt to discharge in stormwater runoff offsite (Photograph 36 in Attachment A). Please also see Concern #7. l. Section 3.2 of the SWPPP indicates that routine good housekeeping inspections are performed by the Plant Manager, EHS Supervisor or their designee on a daily basis. EPA is concerned if these inspections are being conducted at this frequency, given the issues identified in Concern #4. 17 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 m. Section 3.9 of the SWPPP identifies the SWPPP employee training requirements. EPA is unclear which Chemtrade employees have attended the training or the date of when the training was conducted annually, pursuant to the requirements in the Stormwater Permit, Section F.2.g and the Individual Permit, Special Condition 9, Section F.7. EPA did receive a SWPPP quiz used and the SWPPP training PowerPoint after the inspection on April 14, 2022. EPA was not provided any documentation related to the actual completion of the SWPPP employee training by facility employees. n. The benchmark monitoring in Section 4 of the SWPPP stipulates that samples would be taken from just Outfall 001 and not Outfall 002. EPA is unclear why samples would be collected from just one outfall, noting that there is no justification in the SWPPP that Outfall 001 and Outfall 002 are "identical" pursuant to Section E.11.d of the Stormwater Permit nor is there justification indicating that the outfalls should be considered Representative Outfalls, pursuant to Section J.2.g of the Stormwater Permit and Special Condition 9, Section H.5 of the Individual Permit. o. Section E.14 of the Stormwater Permit and Special Condition 9, Section E.14 of the Individual Permit requires the signature and title of the person responsible for the preparation of the SWPPP. The second page has signatures, but no printed names or titles. Both the version that EPA reviewed during the inspection and the SWPPP sent to EPA on April 14, 2022 do not have facility signatures or titles in Section 7 (SWPPP Certification) within the facility's SWPPP. 10. Benchmark Monitoring: Section 2.5 of the SWPPP suggest there is a summary of previous stormwater sampling data, but no summary is included. In addition, Section 4 of the SWPPP includes protocol for benchmark monitoring. The Stormwater Permit requires benchmark monitoring (Attachment 1, Section C, subpart c) for this type of facility for total iron, total aluminium, and nitrate plus nitrite (nitrogen), due to this facility's SIC code and subsector (SIC code 2819, Subsector C2). EPA was unable to obtain any stormwater benchmark monitoring results during the inspection. Within the April 14, 2022 submitted information, the permit renewal for the Stormwater Permit included grab and composite sampling from Outfall 002 performed on June 24, 1993 (Attachment F). Only the composite sample included all of the required benchmark monitoring parameters. EPA is concerned about this sampling for the following reasons: a. It was not identified specifically as the benchmark monitoring; b. It was not included in the SWPPP; c. The sampling occurred approximately 29 years ago (Section J.2.e of the Stormwater Permit requires benchmark monitoring commencing no later than 180 days after the effective date of the Stormwater Permit); and d. Two of the benchmark monitoring parameters results exceed benchmark monitoring limits (total iron and total aluminum). 18 Chemtrade Logistics LLC - East St. Louis Works (IL0000647) - March 31, 2022 11. Unidentified Stormwater Drain Tributary to Stormwater Outfall 002: During EPA's inspection, EPA observed an unidentified stormwater drain near the truck loading area on the west side of the facility's main production area (Photographs 72, 73, and 74). EPA is concerned that Hydrate, upstream of the stormwater drain and exposed to stormwater, may be entering the stormwater drain and being discharged to Rose Creek as a pollutant. 12. Potential Non-Stormwater Discharge to Unidentified Stormwater Drain: During the inspection, EPA observed a discharge of condensate from a steam release pipe over pavement to an unidentified stormwater drain that is tributary to Outfall 002. Although the Stormwater Permit (Section A.9.x) allows for "[u]ncontaimted condensate from air conditioners, coolers, other compressors, and from the outside storage of refrigerated gases or liquids," it is unclear to EPA if this release meets this criteria because it is unclear if the condensate is uncontaminated. This discharge also flows over pavement to the stormwater drain and the runoff could acquire pollutants on the pavement before flowing into the stormwater drain. 13. Discharges From Outfall 001: This facility has reported to the Illinois EPA that they have not discharged non-contact cooling water or pump lubrication/seal water via Outfall 001 in the last five years.2 Facility representatives indicated to EPA that the there is a potential connection for the process wastewater to Outfall 001 but it is currently unused. During the time of EPA's inspection, the stormwater sewer to Outfall 001 from the parking lot is blocked and likely not to be discharging to Rose Creek. This blockage may indicate improper operation and maintenance of an onsite facility and/or system of treatment and control (Attachment H, General Conditions #5 of the Individual Permit). In addition, EPA was not able to independently confirm during the inspection that there was not or had not been process wastewater discharges to the Outfall 001 storm sewer system. Facility representatives did tell EPA that there had not been any process water discharges to Outfall 001 and that it was being considered to remove the possible connection of the process wastewater from Outfall 001. LIST OF ATTACHMENTS: A. Photograph Log B. Chemtrade Logistics - East St. Louis Works: Individual NPDES Permit (IL0000647) C. Chemtrade Logistics - East St. Louis Works: General Industrial Stormwater NPDES Permit (ILR001080) D. Chemtrade's December 2017 SWPPP E. Potential Soil Erosion Map (from General Chemical's 2013 Stormwater Permit Renewal) F. June 24, 1993 Stormwater Sampling Results from Outfall 002 2 Note that the Individual Permit requires that the Outfall 001 compliance sample be taken before mixing with stormwater. If there was no process wastewater discharged to Outfall 001, there would be no sample to take before the mixing of stormwater with the process wastewater, and therefore no discharge, even if a stormwater discharge from Outfall 001 occurred. 19 Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 Attachment A: Chemtrade Logistics LLC - East St. Louis Works Photolog EPA Inspection March 31, 2022 All photos taken by Valerie Dooling, Environmental Engineer/Scientist, U.S. EPA Camera: Canon PowerShot SX230 HS 1: IMG_0606 Description: Cover page for the facility's 2017 Stormwater Pollution Prevention Plan (SWPPP) Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:54 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 2: IMG_0607 Description: 2017 SWPPP - Page 2 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:54 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 3: IMG_0608 Description: 2017 SWPPP - Page 3 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 4: IMG_0609 Description: 2017 SWPPP - Page 4 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 5: IMG_0610 Description: 2017 SWPPP - Page 5 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 6: IMG_0611 Description: 2017 SWPPP - Page 6 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 7: IMG_0612 Description: 2017 SWPPP - Page 7 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 8: IMG_0613 Description: 2017 SWPPP - Page 8 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 9: IMG_0614 Description: 2017 SWPPP - Page 9 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:56 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 10: IMG_0615 Description: 2017 SWPPP - Page 10 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:56 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 11: IMG_0616 Description: 2017 SWPPP - Page 11 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:56 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 12: IMG_0617 Description: 2017 SWPPP - Page 12 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:56 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 13: IMG_0618 Description: 2017 SWPPP - Page 13 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:56 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 14: IMG_0619 Description: 2017 SWPPP - Page 14 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:57 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 15: IMG_0620 Description: 2017 SWPPP - Page 15 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:57 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 16: IMG_0621 Description: 2017 SWPPP - Page 16 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:57 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 17: IMG_0622 Description: 2017 SWPPP - Page 17 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:58 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 18: IMG_0623 Description: 2017 SWPPP - Page 18 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 19: IMG_0624 Description: 2017 SWPPP - Page 19 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:58 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 20: IMG_0625 Description: 2017 SWPPP - Page 20 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:58 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 21: IMG_0626 Description: 2017 SWPPP - Page 21 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:58 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 22: IMG_0627 Description: 2017 SWPPP - Page 22 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:58 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 23: IMG_0628 Description: 2017 SWPPP - Page 23 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:58 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 24: IMG_0629 Description: 2017 SWPPP - Page 7 Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:59 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 25: IMG_0630 Description: 2017 SWPPP -Site Map Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 9:55 am Note: The bottom of this picture has been obscured due to personally identifiable information being visible in the photograph. Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 26: IMG_0631 Description: 2017 SWPPP - First page of Stormwater General Permit Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 10:00 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 27: IMG_0632 Description: Qurterly stormwater inspection form Location: N/A Camera Direction: N/A Date/Time: March 31, 2022 - 10:00 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 28: IMG_0633 Description: Outfall 002 parking lot drain Location: West parking lot, south of main office Camera Direction: N/A Date/Time: March 31, 2022 - 10:45 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 29: IMG_0634 Description: Outfall 002 parking lot drain with facility in the background Location: West parking lot, south of main office Camera Direction: Northeast Date/Time: March 31, 2022 - 10:46 am 30: IMG_0635 Description: Outfall 001 drain full of water Location: West parking lot, southwest of main office Camera Direction: Southwest Date/Time: March 31, 2022 - 10:46 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 31: IMG_0636 Description: Outfall 001 drain, full of water, with facility in the background Location: Service road; south of the facility's main office, southwest of facility's production area Camera Direction: Northeast Date/Time: March 31, 2022 - 10:49 am 32: IMG_0637 Description: South property line of facility, looking east Location: Near stormwater outfall access gate Camera Direction: East Date/Time: March 31, 2022 - 10:50 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 33: IMG_0638 Description: Southern property boundary, looking west Location: Near stormwater outfall access gate Camera Direction: West Date/Time: March 31, 2022 - 10:50 am 34: IMG_0639 Description: Storage shed with empty totes and other chemical storage, northwest of salt storage building Location: Service Road, west of facility's production area Camera Direction: Northwest Date/Time: March 31, 2022 - 10:55 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 35: IMG_0640 Description: Salt storage building Location: Southwest corner of the facility, west of facility's production area Camera Direction: West Date/Time: March 31, 2022 - 10:56 am 36: IMG_0641 Description: Erosional pathway with gray/white residue Location: Southwest corner of the facility, near salt storage building Camera Direction: Southwest Date/Time: March 31, 2022 - 10:58 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 37: IMG_0642 Description: Rose Creek, looking upstream Location: In between facility's southern property boundary and rail yard Camera Direction: East Date/Time: March 31, 2022 - 11:03 am 38: IMG_0643 Description: Outfall 002 final discharge location to Rose Creek (yellow circle added to image for emphasis) Location: In between facility's southern property boundary and rail yard Camera Direction: North Date/Time: March 31, 2022 - 11:03 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 39: IMG_0644 Description: Stormwater Outfall 002 discharge location to Rose Creek Location: North of rail yard, along Rose Creek Camera Direction: North Date/Time: March 31, 2022 - 11:03 am 40: IMG_0645 Description: Pool of water/mud downstream of Stormwater Outfall 002 in Rose Creek Location: North of rail yard, along Rose Creek Camera Direction: North Date/Time: March 31, 2022 - 11:04 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 41: IMG_0646 Description: Erosional pathway from facility property Location: Stormwater outfall access gate Camera Direction: North Date/Time: March 31, 2022 - 11:10 am 42: IMG_0647 Description: Outfall 001 final discharge location to Rose Creek (yellow circle added to image for emphasis) Location: North of rail yard, along Rose Creek Camera Direction: North Date/Time: March 31, 2022 - 11:12 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 43: IMG_0648 Description: Final wet product filling area; note containment dike on filling pad Location: Southern portion of production facility Camera Direction: Northeast Date/Time: March 31, 2022 - 11:16 am 44: IMG_0649 Description: Evidence of previous erosion under fence Location: Southern portion of production facility; east of stormwater access gate Camera Direction: Southwest Date/Time: March 31, 2022 - 11:18 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 45: IMG_0650 Description: Totes of product, located behind containment dike Location: Southern portion of production facility; Camera Direction: Northeast Date/Time: March 31, 2022 - 11:19 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 46: IMG_0651 Description: Secondary containment dikes, with larger, primary containment dikes located below product storage tanks Location: Southern portion of production facility Camera Direction: Northwest Date/Time: March 31, 2022 Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 47: IMG_0652 Description: Close-up of primary containment dike within storage tanks area Location: Southern portion of production facility Camera Direction: East Date/Time: March 31, 2022 - 11:21 am 48: IMG_0653 Description: Waste dumpster, with material that has leaked out Location: Southern portion of production facility; east of the storage tanks pictured above Camera Direction: South Date/Time: March 31, 2022 - 11:23 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 49: IMG_0654 Description: Dried material next to the south wall of the older portion of the facility's main production area Location: Southern portion of production facility Camera Direction: East Date/Time: March 31, 2022 - 11:25 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 50: IMG_0655 Description: Duplicate of photograph 49 Location: Southern portion of production facility Camera Direction: East Date/Time: March 31, 2022 - 11:25 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 51: IMG_0656 Description: Outside of drying building with discarded Hydrate potentially exposed to stormwater Location: Facility production area Camera Direction: Northeast Date/Time: March 31, 2022 - 11:29 am 52: IMG_0657 Description: Outside of drying buliding with discarded Hydrate in-between buildings Location: Facility production area Camera Direction: East Date/Time: March 31, 2022 - 11:29 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 53: IMG_0658 Description: Discarded Hydrate near rail car unloading area Location: Northern portion of production facility Camera Direction: Southeast Date/Time: March 31, 2022 - 11:31 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 54: IMG_0659 Description: Drainage ditch north of facility's main production area Location: Northern portion of production facility Camera Direction: West Date/Time: March 31, 2022 - 11:35 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 55: IMG_0660 Description: Ponded water within the drainage ditch north of the facility's main production area Location: Northern portion of production facility Camera Direction: East Date/Time: March 31, 2022 - 11:31 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 56: IMG_0661 Description: Drainage ditch north of the facility's production area, looking upstream of a damaged culvert Location: Northern portion of production facility Camera Direction: East Date/Time: March 31, 2022 - 11:36 am 57: IMG_0662 Description: Drainage ditch north of the facility's production area, looking downstream of a damaged culvert Location: Northern portion of production facility Camera Direction: West Date/Time: March 31, 2022 - 11:36 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 58: IMG_0663 Description: Drainage ditch north of the facility's production area Location: Northern portion of production facility; raw materials loading area Camera Direction: West Date/Time: March 31, 2022 - 11:38 am 59: IMG_0664 Description: Drainage ditch north of the facility's production area; note the white/discolored material in ponded drainage ditch Location: Northern portion of production facility Camera Direction: West Date/Time: March 31, 2022 - 11:39 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 60: IMG_0665 Description: Drainage ditch north of the facility's production area; note the white/discolored material in ponded drainage ditch Location: Northern portion of production facility Camera Direction: West Date/Time: March 31, 2022 - 11:42 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 61: IMG_0666 Description: Drainage ditch north of the facility's production area; note the white/discolored material in ponded drainage ditch Location: Northern portion of production facility Camera Direction: Northwest Date/Time: March 31, 2022 - 11:42 am 62: IMG_0667 Description: Previous facility process location that utlized diatomaceous earth filter material Location: Northern portion of production facility Camera Direction: Southwest Date/Time: March 31, 2022 - 11:45 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 63: IMG_0668 Description: Previous facility process location, as shown in photograph 62, with dewatering pump shown Location: Northern portion of production facility Camera Direction: South Date/Time: March 31, 2022 - 11:45 am 64: IMG_0669 Description: Previous facility process location, as shown in photograph 62, zoomed in on dried out filter material Location: Northern portion of production facility Camera Direction: Southwest Date/Time: March 31, 2022 - 11:49 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 65: IMG_0670 Description: Evidence of erosion on the access road leading up to the recycle water pond Location: North of facility's production area; south of stormwater pond Camera Direction: South Date/Time: March 31, 2022 - 11:53 am 66: IMG_0671 Description: Recycle water pond Location: North of facility's production area; east of facility's main office Camera Direction: Northeast Date/Time: March 31, 2022 - 11:58 am Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 67: IMG_0672 Description: Recycle water pond Location: North of facility's production area; east of facility's main office Camera Direction: North Date/Time: March 31, 2022 - 11:58 am 68: IMG_0673 Description: Scrap material storage yard Location: North of facility's main office Camera Direction: East Date/Time: March 31, 2022 - 12:01 pm Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 69: IMG_0674 Description: Diesel and waste oil storage tanks Location: North of facility's main office Camera Direction: Northeast Date/Time: March 31, 2022 - 12:02 pm 70: IMG_0675 Description: Empty drums in water within unused contaiment pad next to the waste oil/diesel tanks Location: North of facility's main office Camera Direction: East Date/Time: March 31, 2022 - 12:03 pm Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 71: IMG_0676 Description: Process wastewater storage tank Location: Within the Hydrate production facility Camera Direction: N/A Date/Time: March 31, 2022 - 12:07 pm Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 72: IMG_0677 Description: Upstream stormwater drain tributary to stormwater outfall 002 Location: Southwest of facility's production area Camera Direction: Southwest Date/Time: March 31, 2022 - 12:09 pm Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 73: IMG_0678 Description: Evidence of previous runoff to stormwater drain in photogarph 72 Location: Southwest of facility's production area Camera Direction: Southwest Date/Time: March 31, 2022 - 12:10 pm Chemtrade Logistics LLC - East St. Louis Works - IL0000347 - March 31, 2022 74: IMG_0679 Description: Evidence of previous runoff with Hydrate to stormwater drain in photograph 72 Note condesate hose on top left with water flowing toward drain. Location: Southwest of facility's production area Camera Direction: Northeast Date/Time: March 31, 2022 - 12:10 pm Attachment B ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILUNOIS 62794-9276 (217) 782-3397 JB PRITZKER, GOVERNOR JOHN J. KIM, DIRECTOR 217/782-0610 July 25, 2019 Chemtrade Logistics Inc. 2500 Kings Highway East St. Louis, IL 62201 Re: Chemtrade Logistics lnc. East St. Louis Works NPDES Permit No. IL0000647 Bureau ID: W1638000005 Final Permit Gentlemen: Attached is the final NPDES Permit for your discharge. The Permit as issued covers discharge limitations, monitoring, and reporting requirements. Failure to meet any portion of the Permit could result in civil and/or criminal penalties. The Illinois Environmental Protection Agency is ready and willing to assist you in interpreting any of the conditions of the Permit as they relate specifically to your discharge. Pursuant to the Final NPDES Electronic Reporting Rule, all permittees must report DMRs electronically. The Agency utilizes NetDMR, a web based application, which allows the submittal of electronic Discharge Monitoring Reports instead of paper Discharge Monitoring Reports (DMRs). More information regarding NetDMR can be found on the Agency website, https://www2.illinois.gov/ epa/topics/water-guality/surface-water/ netdrnr/Pages/guick-answer-guide.aspx. If your facility is not registered in the NetDMR program, a supply of preprinted paper DMR Forms will be sent to your facility during the interim period prior to your registration in the NetDMR program. Additional information and instructions will accompany the preprinted DMRs. Please see the attachment regarding the electronic reporting rule. The attached Permit is effective as of the date indicated on the first page of the Permit. Until .the effective date of any re-issued Permit, the limitations and conditions of the previously-issued Permit remain in full effect. You have the right to appeal any condition of the Permit to the Illinois Pollution Control Board within a 35 day period following the issuance date. Should you have questions concerning the Permit, please contact Mark E. Liska at 217/782-0610. Darin E. LeCrone, P.E. Manager, Industrial Unit, Permit Section Division of Water Pollution Control DEL:MEL:19040401.docx Attachment: Final Permit cc: Compliance Assurance Section Collinsville Region SWIMRPC Records Billing 4302 N. Main St., Rockford, IL 61103 (815) 987-7760 595 S. State, Elgin, IL 60123 (847) 608-31 31 2125 S. First St., O,ompoign, IL 61820 (217) 278-5800 2009 Mall St., Collinsville, IL 62234 (618) 346-5120 9511 Harrison St., Des Plaines, IL 60016 (847) 294-4000 5407 N. University St., Arbor I 13, Peoria, IL 61614 (309) 693-5462 2309 W. Main St., Suite 116, Marlon, IL 62959 (618) 993-7200 100 W. Randolph, Suite 10-300, Chicago, IL 60601 (312) 814-6026 PLEASE PRINT ON RECYQED PAPER Attachment C Attachment 1 Subpart A - Sector A - Timber Products. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as defined in this attachment. The sectorspecific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. A.1 Covered Storm water Discharges. The requirements in Subpart A apply to storm water discharges associated with industrial activity from Timber Products facilities as specified below. Sector A: TIMBER PRODUCTS Subsector (May be subject to more than one Sector/subsector) SIC Code or Activity Code Activity Represented A1 2421 General sawmills and planning mills A2 2491 Wood Preserving A3 2411 Log Storage and Handling A4 2426 Hardwood Dimension and Flooring Mills 2429 Special Product Sawmills not elsewhere classified 2431-2439 Millwork, Veneer, Plywood, and structural wood (see Sector W) 2448 Wood Pallets and Skids 2449 Wood Containers not elsewhere classified 2451, 2452 Wood Buildings and Mobile Homes 2493 Reconstituted Wood Products 2499 Wood Products not elsewhere classified 2441 Nailed and Lock Corner Wood Boxes and Shook A.2 A.2.1 Limitation on Coverage Prohibition of Discharges. Not covered by this permit: storm water discharges from areas where there may be contact with the chemical formulations sprayed to provide surface protection. These discharges must be covered by a separate NPDES permit. 1-1 Attachment 1 A.2.2 A.3 A.3.1 A.4 A.4.1 A.4.2 A.4.3 A.5 A.6 Authorized Non-Storm water Discharges. Also authorized by this permit, provided the non-storm water component of the discharge is in compliance with the requirements in Part E.6 of this permit: discharges from the spray down of lumber and wood product storage yards where no chemical additives are used in the spray-down waters and no chemicals are applied to the wood during storage. Additional Technology-Based Effluent Limits. Good Housekeeping. In areas where storage, loading and unloading, and material handling occur, perform good housekeeping to limit the discharge of wood debris, minimize the leachate generated from decaying wood materials, and minimize the generation of dust. Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: processing areas, treatment chemical storage areas, treated wood and residue storage areas, wet decking areas, dry decking areas, untreated wood and residue storage areas, and treatment equipment storage areas. Inventory of Exposed Materials. Where such information exists, if your facility has used chlorophenolic, creosote, or chromium-copper-arsenic formulations for wood surface protection or preserving, document in your SWPPP the following: areas where contaminated soils, treatment equipment, and stored materials still remain and the management practices employed to minimize the contact of these materials with storm water runoff. Description of Storm water Management Controls. Document measures implemented to address the following activities and sources: log, lumber, and wood product storage areas; residue storage areas; loading and unloading areas; material handling areas; chemical storage areas; and equipment and vehicle maintenance, storage, and repair areas. If your facility performs wood surface protection and preservation activities, address the specific control measures, including any BMPs, for these activities. Additional Inspection Requirements. If your facility performs wood surface protection and preservation activities, inspect processing areas, transport areas, and treated wood storage areas monthly to assess the usefulness of practices to minimize the deposit of treatment chemicals on unprotected soils and in areas that will come in contact with storm water discharges. Sector-Specific Benchmarks Table A-1 identifies benchmarks that apply to the specific subsectors of Sector A. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. 1-2 Attachment 1 Subsector (You may be subject to requirements for more than one sector/subsector) Subsector A1. General Sawmills and Planning Mills (SIC 2421) Table A-1 Parameter Chemical Oxygen Demand (COD) Total Suspended Solids (TSS) Benchmark Monitoring Concentration 120.0 mg/L 100 mg/L Total Zinc (freshwater)2 Total Zinc (saltwater)1 Hardness Dependent Subsector A2. Wood Preserving (SIC 2491) Total Arsenic (freshwater)2 Total Arsenic (saltwater)1 Total Copper (freshwater)2 Total Copper (saltwater)1 0.09 mg/L 0.15 mg/L 0.069 mg/L Hardness Dependent 0.0048 mg/L Subsector A3. Log Storage and Total Suspended Solids (TSS) 100 mg/L Handling (SIC 2411) Subsector A4. Hardwood Dimension Chemical Oxygen Demand 120.0 mg/L and Flooring Mills; Special Products (COD) Sawmills, not elsewhere classified; Millwork, Veneer, Plywood, and Total Suspended Solids (TSS) 100.0 mg/L Structural Wood; Wood Pallets and Skids; Wood Containers, not elsewhere classified; Wood Buildings and Mobile Homes; Reconstituted Wood Products; and Wood Products Facilities not elsewhere classified (SIC 2426, 2429, 2431-2439 (except 2434), 2441, 2448, 2449, 2451, 2452, 2493, and 2499) 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L Copper (mg/L) 0.0038 0.0056 0.0090 0.0123 0.0156 0.0189 0.0221 0.0253 0.0285 Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 1-3 Attachment 1 Freshwater Hardness Range 225-249.99 mg/L 250+ mg/L Copper (mg/L) 0.0316 0.0332 Zinc (mg/L) 0.25 0.26 A.7 Effluent Limitations Based on Effluent Limitations Guidelines Table A-2 identifies effluent limits that apply to the industrial activities described below. Compliance with these effluent limits is to be determined based on discharges from these industrial activities independent of commingling with any other waste streams that may be covered under this permit. Industrial Activity Discharges resulting from spray down or intentional wetting of logs at wet deck storage areas 1 Monitor annually. Table A-21 pH Debris (woody material such as bark, twigs, branches, heartwood, or sapwood) 6.0 - 9.0 s.u No discharge of debris that will not pass through a 2.54-cm (1-in.) diameter round opening 1-4 Attachment 1 Subpart B - Sector B - Paper and Allied Products. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as defined in this attachment. The sectorspecific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. B.1 Covered Storm water Discharges. The requirements in Subpart B apply to storm water discharges associated with industrial activity from Paper and Allied Products Manufacturing facilities, as specified below. SECTOR B: PAPER AND ALLIED PRODUCTS Subsector (May be subject to more than one Sector/subsector) SIC Code or Activity Code Activity Represented B1 2631 Paperboard Mills B2 2611 Pulp Mills 2621 Paper Mills 2652-2657 Paperboard Containers and Boxes 2671-2679 Converted Paper and Paperboard Products, Except Containers and Boxes B.2 Sector-Specific Benchmarks. Table B-1 identifies benchmarks that apply to the specific subsectors of Sector B. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table B-1. Subsector (You may be subject to requirements for more than one sector/subsector) Subsector B1. Paperboard Mills (SIC Code 2631) Parameter Chemical Oxygen Demand (COD) Benchmark Monitoring Concentration 120 mg/L 1-5 Attachment 1 Subpart C - Sector C - Chemical and Allied Products Manufacturing, and Refining. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as defined in this attachment. The sectorspecific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. C.1 Covered Storm water Discharges. The requirements in Subpart C apply to storm water discharges associated with industrial activity from Chemical and Allied Products Manufacturing, and Refining facilities, as specified below. Subsector (May be subject to more than one Sector/subsector) C1 C2 C3 C4 C5 SECTOR C: CHEMICALS ANS ALLIED PRODUCTS SIC CODE or ACTIVITY CODE Activity Represented 2873-2879 Agricultural Chemicals 2812-2819 Industrial Inorganic Chemicals 2841-2844 Soaps, Detergents, and Cleaning Preparations: Perfumes, Cosmetics and Other Toilet Preparations 2821-2824 Plastic Materials and Synthetic Resins, Synthetic Rubber, Cellulosic and other Man-Made Fibers Except Glass 2833-2836 Medicinal Chemicals and Botanical Products: Pharmaceutical Preparations; in vitro and in vivo Diagnostic Substances; and Biological Products, Except Diagnostic Substances 2851 Paints, Varnishes, Lacquers, Enamels, and Allied Products 2861-2869 Industrial Organic Chemicals 2891-2899 Miscellaneous Chemical Products 3952 (limited to list of paints and inks) Inks and Paints, Including China Painting Enamels, India Ink, Drawing Ink, Platinum Paints for Burnt Wood or Leather Work, Paints for China Painting, Artist's Paints and Artists Watercolors 2911 Petroleum Refining 1-6 Attachment 1 C.2 C.2.1 Limitations on Coverage. Prohibition of Non-Storm water Discharges. The following are not covered by this permit: non-storm water discharges containing inks, paints, or substances (hazardous, nonhazardous, etc.) resulting from an onsite spill, including materials collected in drip pans; wash water from material handling and processing areas; and wash water from drum, tank, or container rinsing and cleaning. C.3 Sector-Specific Benchmarks Table 8.C-1 identifies benchmarks that apply to the specific subsectors of Sector C. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table C-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration Subsector C1. Agricultural Chemicals Nitrate plus Nitrite 0.68 mg/L (SIC 2873-2879) Nitrogen Total Lead (freshwater)2 Hardness Dependent Total Lead (saltwater)1 0.21 mg/L Total Iron 1.0 mg/L Total Zinc (freshwater)2 Hardness Dependent Total Zinc (saltwater)1 0.09 mg/L Phosphorus 2.0 mg/L Subsector C2. Industrial Inorganic Chemicals Total Aluminum 0.75 mg/ L (SIC 2812-2819) Total Iron 1.0 mg/L Nitrate plus Nitrite 0.68 mg/L Nitrogen Subsector C3. Soaps, Detergents, Cosmetics, Nitrate plus Nitrite 0.68 mg/L and Perfumes (SIC 2841-2844) Nitrogen Total Zinc (freshwater)2 Hardness Dependent Total Zinc (saltwater)1 0.09 mg/L Subsector C4. Plastics, Synthetics, and Resins Total Zinc (freshwater)2 Hardness Dependent (SIC 2821-2824) Total Zinc (saltwater)1 0.09 mg/L 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. . Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L Lead (mg/L) 0.014 0.023 0.045 0.069 Zinc (mg/L) 0.04 0.05 0.08 0.11 1-7 Attachment 1 Freshwater Hardness Range 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Lead (mg/L) 0.095 0.122 0.151 0.182 0.213 0.246 0.262 Zinc (mg/L) 0.13 0.16 0.18 0.20 0.23 0.25 0.26 C.4 Effluent Limitations Based on Effluent Limitations Guidelines Table C-2 identifies effluent limits that apply to the industrial activities described below. Compliance with these effluent limits is to be determined based on discharges from these industrial activities independent of commingling with any other waste streams that may be covered under this permit. Industrial Activity Runoff from phosphate fertilizer manufacturing facilities that comes into contact with any raw materials, finished product, by-products or waste products (SIC 2874) 1 Monitor annually. Table C-21 Parameter Total Phosphorus (as P) Fluoride Effluent Limit 105.0 mg/L, daily maximum 35 mg/L, 30-day avg. 75.0 mg/L, daily maximum 25.0 mg/L, 30-day avg. 1-8 Attachment 1 Subpart D - Sector D - Asphalt Paving and Roofing Materials and Lubricant Manufacturing. You must comply with Part 8 sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as defined in this attachment. The sectorspecific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. D.1 Covered Storm water Discharges. The requirements in Subpart D apply to storm water discharges associated with industrial activity from Asphalt Paving and Roofing Materials and Lubricant Manufacturing facilities, as specified below. SECTOR D: ASPHALT PAVING AND ROOFING MATERIALS AND LUBRICANTS Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented D1 2952, 2952 Asphalt Paving and Roofing Materials D2g 2992,2999 Miscellaneous Products of Petroleum and Coal D.2 D.2.1 Limitations on Coverage. The following storm water discharges associated with industrial activity are not authorized by this permit: Discharges from petroleum refining facilities, including those that manufacture asphalt or asphalt products, that are subject to nationally established effluent limitation guidelines found in 40 CFR Part 419 (Petroleum Refining); or D.2.2 Discharges from oil recycling facilities; or D.2.3 Discharges associated with fats and oils rendering. D.3 Sector-Specific Benchmarks Table D-1 identifies benchmarks that apply to the specific subsectors of Sector D. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table D-1. Subsector Subsector D1. Asphalt Paving and Roofing Materials (SIC 2951, 2952) Parameter Total Suspended Solids (TSS) Benchmark Monitoring Concentration 100 mg/L 1-9 Attachment 1 D.4 Effluent Limitations Based on Effluent Limitations Guidelines Table D-2 identifies effluent limits that apply to the industrial activities described below. Compliance with these effluent limits is to be determined based on discharges from these industrial activities independent of commingling with any other waste streams that may be covered under this permit. Table D-21 Industrial Activity Parameter Discharges from asphalt emulsion facilities. 1Monitor annually. Effluent Limit Total Suspended Solids (TSS) pH Oil and Grease 23.0 mg/L, daily maximum 15.0 mg/L, 30-day avg. 6.0 - 9.0 s.u. 15.0 mg/L, daily maximum 10 mg/L, 30-day avg. 1-10 Attachment 1 Subpart E - Sector E - Glass, Clay, Cement, Concrete, and Gypsum Products. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as defined in this attachment. The sectorspecific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. E.1 Covered Storm water Discharges. The requirements in Subpart E apply to storm water discharges associated with industrial activity from Glass, Clay, Cement, Concrete, and Gypsum Products facilities, as specified below. SECTOR E: GLASS, CLAY, CEMENT, CONCRETE, AND GYPSUM PRODUCTS Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented E1 3251-3259 Structural Clay Products 3261-3269 Pottery and Related Products E2 3271-3275 Concrete, Gypsum. And Plaster Products E3 3211 Flat Glass 3221, 3229 Glass and Glassware, Pressed or Blown 3231 Glass Products Made of Purchased Glass 3241 Hydraulic Cement 3281 Cut Stone and Stone Products 3291-3299 Abrasive, Asbestos, and Miscellaneous Nonmetallic Mineral Products E.2 E.2.1 Additional Technology-Based Effluent Limits. Good Housekeeping Measures. With good housekeeping, prevent or minimize the discharge of spilled cement, aggregate (including sand or gravel), kiln dust, fly ash, settled dust, or other significant material in storm water from paved portions of the site that are exposed to storm water. Sweep or vacuum at regular intervals or use other equivalent measures to minimize the presence of these materials. Indicate in your SWPPP the frequency of sweeping, vacuuming or other equivalent measures. Determine the frequency based on the amount of industrial activity occurring in the area and the frequency of precipitation, but it must be performed at least once a week if cement, aggregate, kiln dust, fly ash, or settled dust are being handled or processed. You must also prevent the exposure of fine granular solids (cement, fly ash, 1-11 Attachment 1 E.3 E.3.1 E.3.2 E.4 kiln dust, etc.) to storm water, where practicable, by storing these materials in enclosed silos, hoppers, or buildings, or under other covering. Additional SWPPP Requirements. Drainage Area Site Map. Document in the SWPPP the locations of the following, as applicable: bag house or other dust control device; recycle/sedimentation pond, clarifier, or other device used for the treatment of process wastewater; and the areas that drain to the treatment device. Discharge Testing. For facilities producing ready-mix concrete, concrete block, brick, or similar products, include in the non-storm water discharge testing a description of measures that ensure that process wastewaters resulting from washing trucks, mixers, transport buckets, forms, or other equipment are discharged in accordance with NPDES requirements or are recycled. Sector-Specific Benchmarks. Table E-1 identifies benchmarks that apply to the specific subsectors of Sector E. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table E-1. Subsector (You may be subject to requirements for more than one sector/subsector) Subsector E1. Clay Product Manufacturers (SIC 3251-3259, 3261-3269) Subsector E2. Concrete and Gypsum Product Manufacturers (SIC 3271-3275) Parameter Benchmark Monitoring Concentration Total Aluminum Total Suspended Solids (TSS) Total Iron 0.75 mg/L 100 mg/L 1.0 mg/L E.5 Effluent Limitations Based on Effluent Limitations Guidelines Table 8.E-2 identifies effluent limits that apply to the industrial activities described below. Compliance with these limits is to be determined based on discharges from these industrial activities independent of commingling with any other waste streams that may be covered under this permit. Industrial Activity Discharges from material storage piles at cement manufacturing facilities 1Monitor annually. Table E-21 Parameter Total Suspended Solids (TSS) pH Effluent Limit 50 mg/L, daily maximum 6.0 - 9.0 s.u. 1-12 Attachment 1 Subpart F - Sector F - Primary Metals. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as defined in this attachment. The sectorspecific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. F.1 Covered Storm water Discharges. The requirements in Subpart F apply to storm water discharges associated with industrial activity from Primary Metals facilities, as specified below. Subsector (May be subject to more than one sector/subsector) F1 F2 F3 F4 F5 SECTOR F: PRIMARY METALS SIC Code or Activity Code Activity Represented 3312-3317 Steel Works, Blast Furnaces, and Rolling and Finishing Mills 3321-3325 Iron and Steel Foundries 3351-3357 Rolling Drawing , and Extruding of Nonferrous Metals 3363-3369 Nonferrous Foundries (Castings) 3331-3339 Primary Smelting and Refining of Nonferrous Metals 3341 Secondary Smelting and Refining of Nonferrous Metals 3398, 3399 Miscellaneous Primary Metal Products F.2 F.2.1 Additional Technology-Based Effluent Limits Good Housekeeping Measures. As part of your good housekeeping program, include a cleaning and maintenance program for all impervious areas of the facility where particulate matter, dust, or debris may accumulate, especially areas where material loading and unloading, storage, handling, and processing occur; and, where practicable, the paving of areas where vehicle traffic or material storage occur but where vegetative or other stabilization methods are not practicable (institute a sweeping or vacuuming program in these areas too). For unstabilized areas where sweeping or vacuuming is not practicable, use storm water management devices such as sediment traps, vegetative buffer strips, filter fabric fence, sediment filtering boom, gravel outlet protection, or other equivalent measures that effectively trap or remove sediment. 1-13 Attachment 1 F.3 F.3.1 F.3.2 F.4 F.5 Additional SWPPP Requirements. Drainage Area Site Map. Identify in the SWPPP where any of the following activities may be exposed to precipitation or surface runoff: storage or disposal of wastes such as spent solvents and baths, sand, slag and dross; liquid storage tanks and drums; processing areas including pollution control equipment (e.g., baghouses); and storage areas of raw material such as coal, coke, scrap, sand, fluxes, refractories, or metal in any form. In addition, indicate where an accumulation of significant amounts of particulate matter could occur from such sources as furnace or oven emissions, losses from coal and coke handling operations, etc., and could result in a discharge of pollutants to waters of the United States. Inventory of Exposed Material. Include in the inventory of materials handled at the site that potentially may be exposed to precipitation or runoff, areas where deposition of particulate matter from process air emissions or losses during material-handling activities are possible Additional Inspection Requirements. As part of conducting your routine facility inspections at least quarterly, address all potential sources of pollutants, including (if applicable) air pollution control equipment (e.g., baghouses, electrostatic precipitators, scrubbers, and cyclones), for any signs of degradation (e.g., leaks, corrosion, or improper operation) that could limit their efficiency and lead to excessive emissions. Consider monitoring air flow at inlets and outlets (or use equivalent measures) to check for leaks (e.g., particulate deposition) or blockage in ducts. Also inspect all process and material handling equipment (e.g., conveyors, cranes, and vehicles) for leaks, drips, or the potential loss of material; and material storage areas (e.g., piles, bins, or hoppers for storing coke, coal, scrap, or slag, as well as chemicals stored in tanks and drums) for signs of material losses due to wind or storm water runoff. Sector-Specific Benchmarks. Table F-1 identifies benchmarks that apply to the specific subsectors of Sector F. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Subsector (You may be subject to requirements for more than one sector/subsector) Subsector F1. Steel Works, Blast Furnaces, and Rolling and Finishing Mills (SIC 3312-3317) Subsector F2. Iron and Steel Foundries (SIC 3321-3325) Subsector F3. Rolling, Drawing, and Extruding of Nonferrous Metals Table F-1. Parameter Total Aluminum Total Zinc (freshwater)2 Total Zinc (saltwater)1 Total Aluminum Total Suspended Solids (TSS) Total Copper (freshwater)2 Total Copper (saltwater)1 Total Iron Total Zinc (freshwater)2 Total Zinc (saltwater)1 Total Copper (freshwater)2 Total Copper (saltwater)1 Benchmark Monitoring Concentration 0.75 mg/L Hardness Dependent 0.09 mg/L 0.75 mg/L 100 mg/L Hardness Dependent 0.0048 mg/L 1.0 mg/L Hardness Dependent 0.09 mg/L Hardness Dependent 0.0048 mg/L 1-14 Attachment 1 Table F-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration (SIC 3351-3357) Total Zinc (freshwater)2 Hardness Dependent Total Zinc (saltwater)1 0.09 mg/L Subsector F4. Nonferrous Foundries Total Copper (freshwater)2 Hardness Dependent (SIC 3363-3369) Total Copper (saltwater)1 0.0048 mg/L Total Zinc (freshwater)2 Hardness Dependent Total Zinc (saltwater)1 0.09 mg/L 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Copper (mg/L) 0.0038 0.0056 0.0090 0.0123 0.0156 0.0189 0.0221 0.0253 0.0285 0.0316 0.0332 Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 0.25 0.26 1-15 Attachment 1 Subpart G - Sector G - Metal Mining. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR G: METAL MINING (ORE MINING AND DRESSING) Subsector (May Be Subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented G1 1021 Copper Ore and Mining Dressing Facilities G2 1011 Iron Ores 1021 Copper Ores 1031 Lead and Zinc Ores 1041, 1044 Gold and Silver Ores 1061 Ferroalloy Ores, Except Vanadium 1081 Metal Mining Services 1094,1099 Miscellaneous Ores G.1 G.1.1 Covered Storm water Discharges. The requirements in Subpart G apply to storm water discharges associated with industrial activity from Metal Mining facilities, including mines abandoned on Federal lands as specified in Attachment 2 of this permit. Coverage is required for metal mining facilities that discharge storm water contaminated by contact with, or that has come into contact with, any overburden, raw material, intermediate product, finished product, byproduct, or waste product located on the site of the operation. Covered Discharges from Inactive Facilities. All storm water discharges. G.1.2 Covered Discharges from Active and Temporarily Inactive Facilities. Only the storm water discharges from the following areas are covered: Waste rock and overburden piles if composed entirely of storm water and not combining with mine drainage; Topsoil piles; Offsite haul and access roads; Onsite haul and access roads constructed of waste rock, overburden or spent ore if composed entirely of storm water and not combining with mine drainage; Onsite haul and access roads not constructed of waste rock, overburden or spent ore except if mine drainage is used for dust control; 1-16 Attachment 1 Runoff from tailings dams or dikes when not constructed of waste rock or tailings and no process fluids are present; Runoff from tailings dams or dikes when constructed of waste rock or tailings and no process fluids are present, if composed entirely of storm water and not combining with mine drainage; Concentration building if no contact with material piles; Mill site if no contact with material piles; Office or administrative building and housing if mixed with storm water from industrial area; Chemical storage area; Docking facility if no excessive contact with waste product that would otherwise constitute mine drainage; Explosive storage; Fuel storage; Vehicle and equipment maintenance area and building; Parking areas (if necessary); Power plant; Truck wash areas if no excessive contact with waste product that would otherwise constitute mine drainage; Unreclaimed, disturbed areas outside of active mining area; Reclaimed areas released from reclamation requirements prior to December 17, 1990; Partially or inadequately reclaimed areas or areas not released from reclamation requirements. G.1.3 G.1.4 G.2 G.2.1 Covered Discharges from Exploration and Construction of Metal Mining and/or Ore Dressing Facilities. All storm water discharges. Covered Discharges from Facilities Undergoing Reclamation. All storm water discharges. Limitations on Coverage. Prohibition of Storm water Discharges. Storm water discharges not authorized by this permit: discharges from active metal mining facilities that are subject to effluent limitation guidelines for the Ore Mining and Dressing Point Source Category (40 CFR Part 440). NOTE: Storm water runoff from these sources are subject to 40 CFR Part 440 if they are mixed with other discharges subject to Part 440. In this case, they are not eligible for coverage under this permit. Discharges from overburden/waste rock and overburden/waste rock-related areas are not subject to 40 CFR Part 440 unless they: (1) drain naturally (or are intentionally diverted) to a point source; and (2) combine with ''mine drainage'' that is otherwise regulated under the Part 440 regulations. For such sources, coverage under this permit would be available if the discharge composed entirely of storm water does not combine with other sources of mine drainage that are not subject to 40 CFR Part 440, and meets the other eligibility criteria contained in Part A of the permit. Permit applicants bear the initial responsibility for determining if they are eligible for coverage under this permit, or must seek coverage under another NPDES permit. Illinois EPA recommends that permit applicants contact Illinois EPA for assistance to determine the nature and scope of the ''active mining area'' on a mineby-mine basis, as well as to determine the appropriate permitting mechanism for authorizing such discharges. 1-17 Attachment 1 G.2.2 Prohibition of Non-Storm water Discharges. Not authorized by this permit: adit drainage, and contaminated springs or seeps discharging from waste rock dumps that do not directly result from precipitation events. G.3 G.3.1 Definitions. The following definitions are not intended to supersede the definitions of active and inactive mining facilities established by 40 CFR 122.26(b)(14)(iii). Mining operation - Consists of the active and temporarily inactive phases, and the reclamation phase, but excludes the exploration and construction phases. G.3.2 Exploration phase - Entails exploration and land disturbance activities to determine the viability of a site. The exploration phase is not considered part of "mining operations." G.3.3 Construction phase - Includes the building of site access roads and removal of overburden and waste rock to expose mineable minerals. The construction phase is not considered part of "mining operations." G.3.4 Active phase - Activities including the extraction, removal or recovery of metal ore. For surface mines, this definition does not include any land where grading has returned the earth to a desired contour and reclamation has begun. This definition is derived from the definition of "active mining area" found at 40 CFR 440.132(a). The active phase is considered part of "mining operations." G.3.5 Reclamation phase - Activities undertaken, in compliance with applicable mined land reclamation requirements, following the cessation of the "active phase", intended to return the land to an appropriate post-mining land use in order to meet applicable Federal and State reclamation requirements. The reclamation phase is considered part of "mining operations." G.3.6 Active metal mining facility - A place where work or other activity related to the extraction, removal, or recovery of metal ore is being conducted. For surface mines, this definition does not include any land where grading has returned the earth to a desired contour and reclamation has begun. This definition is derived from the definition of "active mining area" found at 40 CFR 440.132(a). G.3.7 Inactive metal mining facility - A site or portion of a site where metal mining and/or milling occurred in the past but is not an active facility as defined above, and where the inactive portion is not covered by an active mining permit issued by the applicable State or Federal agency. An inactive metal mining facility has an identifiable owner / operator. Sites where mining claims are being maintained prior to disturbances associated with the extraction, beneficiation, or processing of mined materials and sites where minimal activities are undertaken for the sole purpose of maintaining a mining claim are not considered either active or inactive mining facilities and do not require an NPDES industrial storm water permit. G.3.8 Temporarily inactive metal mining facility - A site or portion of a site where metal mining and/or milling occurred in the past but currently are not being actively undertaken, and the facility is covered by an active mining permit issued by the applicable State or Federal agency. G.3.9 Final Stabilization - A site or portion of a site is "finally stabilized" when it has implemented all applicable Federal and State reclamation requirements. 1-18 Attachment 1 G.4 G.5 G.5.1 Effluent Limits for Clearing, Grading, and Excavation Activities. Clearing, grading, and excavation activities being conducted as part of the exploration and construction phase of mining activities are covered under this permit. During clearing, grading, and excavation activities you must obtain a General NPDES Permit For Storm Water Discharges From Construction Site Activities. Additional Effluent Limits. Employee Training. Conduct employee training at least annually at active and temporarily inactive sites. G.5.2 Storm water Controls. Apart from the control measures you implement to meet your effluent limits, where necessary to minimize pollutant discharges, implement the following control measures at your site. The potential pollutants shall determine the priority and appropriateness of the control measures selected. G.5.2.1 Storm water Diversions: Divert storm water away from potential pollutant sources where practicable. The following are some options: interceptor or diversion controls (e.g., dikes, swales, curbs, or berms); pipe slope drains; subsurface drains; conveyance systems (e.g., channels or gutters, open-top box culverts, and waterbars; rolling dips and road sloping; roadway surface water deflector and culverts); or their equivalents. G.5.2.2 Capping: When capping is necessary to minimize pollutant discharges in storm water, identify the source being capped and the material used to construct the cap. G.5.2.3 Treatment: If treatment of storm water (e.g., chemical or physical systems, oil and water separators, artificial wetlands) is necessary to protect water quality, describe the type and location of treatment used. Passive and/or active treatment of storm water runoff is encouraged where practicable. Treated runoff may be discharged as a storm water source regulated under this permit provided the discharge is not combined with discharges subject to effluent limitation guidelines for the Ore Mining and Dressing Point Source Category (40 CFR Part 440). G.5.3 Discharge Testing. Test or evaluate all outfalls covered under this permit for the presence of specific mining-related non-storm water discharges such as seeps or adit discharges, or discharges subject to effluent limitations guidelines (e.g., 40 CFR Part 440), such as mine drainage or process water. Alternatively (if applicable), you may keep a certification with your SWPPP consistent with Part G.6.6. G.6 Additional SWPPP Requirements. G.6.1 G.6.2 Nature of Industrial Activities. Briefly document in your SWPPP the mining and associated activities that can potentially affect the storm water discharges covered by this permit, including a general description of the location of the site relative to major transportation routes and communities. Site Map. Document in your SWPPP the locations of the following (as appropriate): mining or milling site boundaries; access and haul roads; outline of the drainage areas of each storm water outfall within the facility with indications of the types of discharges from the drainage areas; location(s) of all permitted discharges covered under an individual NPDES permit, outdoor equipment storage, fueling, and maintenance areas; 1-19 Attachment 1 materials handling areas; outdoor manufacturing, outdoor storage, and material disposal areas; outdoor chemicals and explosives storage areas; overburden, materials, soils, or waste storage areas; location of mine drainage (where water leaves mine) or other process water; tailings piles and ponds (including proposed ones); heap leach pads; off-site points of discharge for mine drainage and process water; surface waters; boundary of tributary areas that are subject to effluent limitations guidelines; and location(s) of reclaimed areas. G.6.3 Potential Pollutant Sources. For each area of the mine or mill site where storm water discharges associated with industrial activities occur, identify the types of pollutants (e.g., heavy metals, sediment) likely to be present in significant amounts. Consider these factors: the mineralogy of the ore and waste rock (e.g., acid forming); toxicity and quantity of chemicals used, produced, or discharged; the likelihood of contact with storm water; vegetation of site (if any); and history of significant leaks or spills of toxic or hazardous pollutants. Also include a summary of any existing ore or waste rock or overburden characterization data and test results for potential generation of acid rock. If any new data is acquired due to changes in ore type being mined, update your SWPPP with this information. G.6.4 Documentation of Control Measures. Document all control measures that you implement consistent with your SWPPP. If control measures are implemented or planned which were not part of your original SWPPP (e.g., substituting a less toxic chemical for a more toxic one), update your SWPPP to include descriptions of said measures. G.6.5 Employee Training. All employee training(s) must be documented in the SWPPP. G.6.6 Certification of Permit Coverage for Commingled Non-Storm water Discharges: If you are able, consistent with Part G.5.3 above, to certify that a particular discharge composed of commingled storm water and non-storm water is covered under a separate NPDES permit, and that permit subjects the non-storm water portion to effluent limitations prior to any commingling, retain such certification with your SWPPP. This certification must identify the non-storm water discharges, the applicable NPDES permit(s), the effluent limitations placed on the non-storm water discharge by the permit(s), and the points at which the limitations are applied. G.7 Additional Inspection Requirements. Except for areas of the site subject to clearing, grading, and/or excavation activities conducted as part of the exploration and construction phase, which are subject to Part G.4.2.1, inspect sites at least quarterly unless adverse weather conditions make the site inaccessible. Sites which discharge to waters designated as Tier 2 or 2.5 or waters which are impaired for sediment or nitrogen must be inspected monthly, unless subject to G.4.3. See Part G.8.4 for inspection requirements for inactive and unstaffed sites. G.8 Monitoring and Reporting Requirements. (See also Part 6 of the permit.) Note: There are no Part G.8 monitoring and reporting requirements for inactive and unstaffed sites. G.8.1 Benchmark Monitoring for Active Copper Ore Mining and Dressing Facilities. Table G-1 identifies benchmarks that apply to active copper ore mining and dressing facilities. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. 1-20 Attachment 1 Table G-1 Subsector (You may be subject to requirements for more than one sector/subsector) Subsector G1. Active Copper Ore Mining and Dressing Facilities (SIC 1021) Parameter Total Suspended Solids (TSS) Nitrate plus Nitrite Nitrogen Chemical Oxygen Demand (COD) Benchmark Monitoring Concentration 100 mg/L 0.68 mg/L 120 mg/L G.8.2 Benchmark Monitoring Requirements for Discharges From Waste Rock and Overburden Piles at Active Metal Mining Facilities. For discharges from waste rock and overburden piles, perform benchmark monitoring once in the first year for the parameters listed in Table G-2, and twice annually in all subsequent years of coverage under this permit for any parameters for which the benchmark has been exceeded. You are also required to conduct analytic monitoring for the parameters listed in Table G-3 in accordance with the requirements in Part G.6.3. The Director may also notify you that you must perform additional monitoring to accurately characterize the quality and quantity of pollutants discharged from your waste rock and overburden piles. Subsector (Discharges may be subject to requirements for more than one sector/subsector) Subsector G2. Iron Ores; Copper Ores; Lead and Zinc Ores; Gold and Silver Ores; Ferroalloy Ores, Except Vanadium; and Miscellaneous Metal Ores (SIC Codes 1011, 1021, 1031, 1041, 1044, 1061, 1081, 1094, 1099) (Note: when analyzing hardness for a suite of metals, it is more cost effective to add analysis of calcium and magnesium, and have hardness calculated than to require hardness analysis separately) Table G-2. Parameter Total Suspended Solids (TSS) Turbidity pH Hardness (as CaCO3; calc. from Ca, Mg)2 Total Antimony Total Arsenic (freshwater)2 Total Arsenic (saltwater)1 Total Beryllium Total Cadmium (freshwater)2 Total Cadmium (saltwater)1 Total Copper (freshwater)2 Total Copper (saltwater)1 Total Iron Total Lead (freshwater)2 Total Lead (saltwater)1 Total Mercury (freshwater)2 Total Mercury (saltwater)1 Total Nickel (freshwater)2 Total Nickel (saltwater)1 Benchmark Monitoring Concentration 100 mg/L 50 NTU 6.0-9.0 s.u. no benchmark value 0.64 mg/L 0.15 mg/L 0.069 mg/L 0.13 mg/L Hardness Dependent 0.04 mg/L Hardness Dependent 0.0048 mg/L 1.0 mg/L Hardness Dependent 0.21 mg/L 0.0014 mg/L 0.0018 mg/L Hardness Dependent 0.074 mg/L 1-21 Attachment 1 Table G-2. Subsector (Discharges may be subject to requirements for more than one Parameter Benchmark Monitoring Concentration sector/subsector) Total Selenium (freshwater)2 0.005 mg/L Total Selenium (saltwater)1 0.29 mg/L Total Silver (freshwater)2 Hardness Dependent Total Silver (saltwater)1 0.0019 mg/L Total Zinc (freshwater)2 Hardness Dependent Total Zinc (saltwater)1 0.09 mg/L 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Cadmium (mg/L) 0.0005 0.0008 0.0013 0.0018 0.0023 0.0029 0.0034 0.0039 0.0045 0.0050 0.0053 Copper (mg/L) 0.0038 0.0056 0.0090 0.0123 0.0156 0.0189 0.0221 0.0253 0.0285 0.0316 0.0332 Lead (mg/L) 0.014 0.023 0.045 0.069 0.095 0.122 0.151 0.182 0.213 0.246 0.262 Nickel (mg/L) 0.15 0.20 0.32 0.42 0.52 0.61 0.71 0.80 0.89 0.98 1.02 Silver (mg/L) 0.0007 0.0007 0.0017 0.0030 0.0046 0.0065 0.0087 0.0112 0.0138 0.0168 0.0183 Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 0.25 0.26 G.8.3 Additional Analytic Monitoring Requirements for Discharges From Waste Rock and Overburden Piles at Active Metal Mining Facilities. In addition to the monitoring required in Part G.8.2 for discharges from waste rock and overburden piles, you must also conduct monitoring for additional parameters based on the type of ore you mine at your site. Where a parameter in Table G-3 is the same as a pollutant you are required to monitor for in Table G-2 (i.e., for all of the metals), you must use the corresponding benchmark in Table G-2 and you may use any monitoring results conducted for Part G.8.2 to satisfy the monitoring requirement for that parameter for Part G.6.3. For radium and uranium, which do not have corresponding benchmarks in Table G-2, there are no applicable benchmarks. The frequency and schedule for monitoring for these additional parameters is the same as that specified in Part E.9.b. 1-22 Attachment 1 Table G-3. Additional Monitoring Requirements for Discharges from Waste Rock and Overburden Piles Supplemental Requirements Pollutants of Concern Type of Ore Mined Total Suspended pH Solids (TSS) Metals, Total Tungsten Ore X X Arsenic, Cadmium (H), Copper (H), Lead (H), Zinc (H) Nickel Ore X X Arsenic, Cadmium (H), Copper (H), Lead (H), Zinc (H) Aluminum Ore X X Iron Mercury Ore X X Nickel (H) Iron Ore X X Iron (Dissolved) Platinum Ore Cadmium (H), Copper (H), Mercury, Lead (H), Zinc (H) Titanium Ore X X Iron, Nickel (H), Zinc (H) Vanadium Ore X X Arsenic, Cadmium (H), Copper (H), Lead (H), Zinc (H) Molybdenum X X Arsenic, Cadmium (H), Copper (H), Lead (H), Mercury, Zinc (H) Uranium, Radium, and X X Chemical Oxygen Demand, Vanadium Ore Arsenic, Radium (Dissolved and Total), Uranium, Zinc (H) Note: An "X" indicated for TSS and/or pH means that you are required to monitor for those parameters. (H) indicates that hardness must also be measured when this pollutant is measured. G.8.4 Inactive and Unstaffed Sites - Conditional Exemption from No Exposure Requirements for Quarterly Visual Assessments and Routine Facility Inspections. As a Sector G facility, if you are seeking to exercise a waiver from the quarterly visual assessment and routine facility inspection requirements for inactive and unstaffed sites (including temporarily inactive sites), you are conditionally exempt from the requirement to certify that "there are no industrial materials or activities exposed to storm water". This exemption is conditioned on the following: If circumstances change and your facility becomes active and/or staffed, this exception no longer applies and you must immediately begin complying with the quarterly visual assessment requirements; and EPA retains the authority to revoke this exemption and/or the monitoring waiver where it is determined that the discharge causes, has a reasonable potential to cause, or contributes to an instream excursion above an applicable water quality standard, including designated uses. Subject to the two conditions above, if your facility is inactive and unstaffed, you are waived from the requirement to conduct quarterly visual assessments and routine facility inspections. You are encouraged to inspect your site where you have reason to believe that severe weather or natural disasters may have damaged control measures or increased discharges. 1-23 Attachment 1 Table G-4. Applicability of the Multi-Sector General Permit to Storm water Runoff From Active Mining and Dressing Sites, Temporarily Inactive Sites, and Sites Undergoing Reclamation Discharge/Source of Discharge Note/Comment Piles Waste rock/overburden If composed entirely of storm water and not combining with mine drainage. See note below. Topsoil -- Roads constructed of waste rock or spent ore Onsite haul roads If composed entirely of storm water and not combining with mine drainage. See note below. Offsite haul and access roads -- Roads not constructed of waste rock or spent ore Onsite haul roads Except if mine drainage is used for dust control Offsite haul and access roads -- Milling/concentrating Runoff from tailings dams and dikes when Except if process fluids are present and only if constructed of waste rock/tailings composed entirely of storm water and not combining with mine drainage. See Note below. Runoff from tailings dams/dikes when not Except if process fluids are present constructed of waste rock and tailings Concentration building If storm water only and no contact with piles Mill site If storm water only and no contact with piles Ancillary areas Office and administrative building and housing If mixed with storm water from the industrial area Chemical storage area -- Docking facility Except if excessive contact with waste product that would otherwise constitute mine drainage Explosive storage -- Fuel storage (oil tanks/coal piles) -- Vehicle and equipment maintenance -- area/building Parking areas But coverage unnecessary if only employee and visitor-type parking Power plant Truck wash area Except when excessive contact with waste product that would otherwise constitute mine drainage Reclamation-related areas Any disturbed area (unreclaimed) Only if not in active mining area Reclaimed areas released from reclamation -- requirements prior to Dec. 17, 1990 Partially/inadequately reclaimed areas or -- areas not released from reclamation requirements 1-24 Attachment 1 Table G-4. Applicability of the Multi-Sector General Permit to Storm water Runoff From Active Mining and Dressing Sites, Temporarily Inactive Sites, and Sites Undergoing Reclamation Discharge/Source of Discharge Note/Comment Note: Storm water runoff from these sources are subject to the NPDES program for storm water unless mixed with discharges subject to 40 CFR Part 440 that are regulated by another permit prior to mixing. Non-storm water discharges from these sources are subject to NPDES permitting and may be subject to the effluent limitation guidelines under 40 CFR Part 440. Discharges from overburden/waste rock and overburden/waste rock-related areas are not subject to 40 CFR Part 440 unless: (1) it drains naturally (or is intentionally diverted) to a point source; and (2) combines with ''mine drainage'' that is otherwise regulated under the Part 440 regulations. For such sources, coverage under this permit would be available if the discharge composed entirely of storm water does not combine with other sources of mine drainage that are not subject to 40 CFR Part 440, as well as meeting other eligibility criteria contained in Part 1.1 of the permit. Permit applicants bear the initial responsibility for determining the applicable technology-based standard for such discharges. EPA recommends that permit applicants contact the relevant NPDES permit issuance authority for assistance to determine the nature and scope of the ''active mining area'' on a mine-by-mine basis, as well as to determine the appropriate permitting mechanism for authorizing such discharges. G.9. G.9.1 G.9.2 Termination of Permit Coverage Termination of Permit Coverage for Sites Reclaimed After December 17, 1990. A site or a portion of a site that has been released from applicable state or federal reclamation requirements after December 17, 1990, is no longer required to maintain coverage under this permit. If the site or portion of a site reclaimed after December 17, 1990, was not subject to reclamation requirements, the site or portion of the site is no longer required to maintain coverage under this permit if the site or portion of the site has been reclaimed as defined in Part G.3.5. Termination of Permit Coverage for Sites Reclaimed Before December 17, 1990. A site or portion of a site that was released from applicable state or federal reclamation requirements before December 17, 1990, or that was otherwise reclaimed before December 17, 1990, is no longer required to maintain coverage under this permit if the site or portion of the site has been reclaimed. A site or portion of a site is considered to have been reclaimed if: (1) storm water runoff that comes into contact with raw materials, intermediate byproducts, finished products, and waste products does not have the potential to cause or contribute to violations of state water quality standards, (2) soil disturbing activities related to mining at the sites or portion of the site have been completed, (3) the site or portion of the site has been stabilized to minimize soil erosion, and (4) as appropriate depending on location, size, and the potential to contribute pollutants to storm water discharges, the site or portion of the site has been revegetated, will be amenable to natural revegetation, or will be left in a condition consistent with the post-mining land use. 1-25 Attachment 1 Sector-Specific Requirements for Industrial Activity Subpart H - Sector H - Coal Mines and Coal Mining-Related Facilities. Discharges from coal mines and coal mining related facilities are regulated under individual or general NPDES permits and by 35 Ill. Adm. Code Subtitle D: Mine Related Water Pollution. 1-26 Attachment 1 Subpart I - Sector I - Oil and Gas Extraction. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR I: OIL AND AS EXTRACTION AND REFINING Subsector (May be subject to more than one sector/subsector) SIC Code of Activity Code Activity Represented I1 1311 Crude Petroleum and Natural Gas 1321 Natural Gas Liquids 1381-1389 Oil and Gas Field Services I.1 Covered Storm water Discharges. The requirements in Subpart I apply to storm water discharges associated with industrial activity from Oil and Gas Extraction facilities as identified by the SIC Codes specified in Attachment 2 of this permit. I.1.1 Discharges of storm water runoff from field activities or operations associated with oil and gas exploration, production, processing, or treatment operations or transmission facilities are exempt from NPDES permit coverage unless, in accordance with 40 CFR 122.26(c)(1)(iii), the facility: Has had a discharge of storm water resulting in the discharge of a reportable quantity for which notification is or was required pursuant to 40 CFR 117.21 or 40 CFR 302.6 at any time since November 16, 1987; or Has had a discharge of storm water resulting in the discharge of a reportable quantity for which notification is or was required pursuant to 40 CFR 110.6 at any time since November 16, 1987; or Contributes to a violation of a water quality standard. Any storm water discharges that require permit coverage as a result of meeting one of the conditions of 122.26(c)(1)(iii) may be covered under this permit unless otherwise required to obtain coverage under an alternative NPDES general permit or an individual NPDES permit. I.2 Limitations on Coverage. I.2.1 Storm water Discharges Subject to Effluent Limitation Guidelines. This permit does not authorize storm water discharges from petroleum drilling operations that are subject to 1-27 Attachment 1 nationally established effluent limitation guidelines found at 40 CFR Part 435, respectively. I.2.2 Non-Storm water Discharges. Discharges of vehicle and equipment wash water, including tank cleaning operations, are not authorized by this permit. Alternatively, wash water discharges must be authorized under a separate NPDES permit, or be discharged to a sanitary sewer in accordance with applicable industrial pretreatment requirements. I.3 Additional Technology-Based Effluent Limits. I.3.1 Vegetative Controls. Implement vegetative practices designed to preserve existing vegetation, where attainable, and revegetate open areas as soon as practicable after grade drilling. Implement appropriate vegetative practices, such as the following (or equivalent measures): temporary or permanent seeding, mulching, sod stabilization, vegetative buffer strips, and tree protection practices. Begin implementing appropriate vegetative practices on all disturbed areas within 14 days following the last activity in that area. I.4 Additional SWPPP Requirements. I.4.1 Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: Reportable Quantity (RQ) releases; locations used for the treatment, storage, or disposal of wastes; processing areas and storage areas; chemical mixing areas; construction and drilling areas; all areas subject to the effluent guidelines requirements for "No Discharge" in accordance with 40 CFR 435.32; and the structural controls to achieve compliance with the "No Discharge" requirements. I.4.2 Potential Pollutant Sources. Also document in your SWPPP the following sources and activities that have potential pollutants associated with them: chemical, cement, mud, or gel mixing activities; drilling or mining activities; and equipment cleaning and rehabilitation activities. In addition, include information about the reportable quantity (RQ) release that triggered the permit application requirements: the nature of the release (e.g., spill of oil from a drum storage area), amount of oil or hazardous substance released, amount of substance recovered, date of the release, cause of the release (e.g., poor handling techniques and lack of containment in the area), areas affected by the release (i.e., land and water), procedure to clean up release, actions or procedures implemented to prevent or improve response to a release, and remaining potential contamination of storm water from release (taking into account human health risks, the control of drinking water intakes, and the designated uses of the receiving water). I.4.3 Erosion and Sedimentation Control. Unless covered by EPA's Construction General Permit (CGP), the additional documentation requirements for sediment and erosion controls for well drillings and sand/shale mining areas include the following: I.4.3.1 Site Description. Also include a description in your SWPPP of the nature of the exploration activity, estimates of the total area of site and area disturbed due to exploration activity, an estimate of runoff coefficient of the site, a site drainage map, including approximate slopes, and the names of all receiving waters. I.4.3.2 Vegetative Controls. Document vegetative practices used consistent with the SWPPP. 1-28 Attachment 1 I.5 Additional Inspection Requirements. All erosion and sedimentation control measures must be inspected either: 1) every 7 days; or 2) once every 14 calendar days and within 24 hours of a storm event of 0.25 inches or greater. 1-29 Attachment 1 Subpart J - Sector J - Non-Metallic Mineral Mining and Dressing. Discharges from non-coal mines and related facilities are regulated under individual permits by 35 Ill. Adm. Code Subtitle D: Mine Related Water Pollution or ILG84. 1-30 Attachment 1 Subpart K - Sector K - Hazardous Waste Treatment, Storage, or Disposal Facilities. Facilities treating, storing or disposing of hazardous waste are required to obtain individual or general NPDES Permits pursuant to Section B.2. of this permit. 1-31 Attachment 1 Subpart L - Sector L - Landfills, Land Application Sites, and Open Dumps. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR L: LANDFILLS, LAND APPLICATION SITES AND OPEN DUMPS Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented L1 LF All Landfill, Land Application Sites and Open Dumps L2 LF All Landfill, Land Application Sites and Open Dumps, except Municipal Solid Waste Landfill (MSWLF) Areas Closed in Accordance With 40 CFR 258.60 L.1 L.2 L.3 L.3.1 L.4 L.4.1 L.4.2 Covered Storm water Discharges. The requirements in Subpart L apply to storm water discharges associated with industrial activity from Landfills and Land Application Sites as identified by the Activity Code specified in Attachment 2 of this permit. Industrial Activities Covered by Sector L. This permit may authorize storm water discharges for Sector L facilities associated with waste disposal at landfills, land application sites that receive or have received industrial waste, including sites subject to regulation under Subtitle D of RCRA. This permit does not cover discharges from landfills that receive only municipal wastes. Limitations on Coverage. Prohibition of Non-Storm water Discharges. The following discharges are not authorized by this permit: leachate, gas collection condensate, drained free liquids, contaminated ground water, laboratory wastewater, and contact wash water from washing truck and railcar exteriors and surface areas that have come in direct contact with solid waste at the landfill facility. Discharges from open dumps as defined under RCRA are also not authorized under this permit. Definitions. Contaminated storm water - storm water that comes into direct contact with landfill wastes, the waste handling and treatment areas, or landfill wastewater. Some areas of a landfill that may produce contaminated storm water include (but are not limited to) the open face of an active landfill with exposed waste (no cover added); the areas around wastewater treatment operations; trucks, equipment, or machinery that has been in direct contact with the waste; and waste dumping areas. Drained free liquids - aqueous wastes drained from waste containers (e.g., drums) prior to landfilling. 1-32 Attachment 1 L.4.3 L.4.4 L.4.5 L.5 L.5.1 L.5.2 L.6 L.6.1 L.6.2 L.7 L.7.1 Landfill wastewater - as defined in 40 CFR Part 445 (Landfills Point Source Category) all wastewater associated with, or produced by, landfilling activities except for sanitary wastewater, non-contaminated storm water, contaminated groundwater, and wastewater from recovery pumping wells. Landfill process wastewater includes, but is not limited to, leachate; gas collection condensate; drained free liquids; laboratoryderived wastewater; contaminated storm water; and contact wash water from washing truck, equipment, and railcar exteriors and surface areas that have come in direct contact with solid waste at the landfill facility. Leachate - liquid that has passed through or emerged from solid waste and contains soluble, suspended, or miscible materials removed from such waste. Non-contaminated storm water - storm water that does not come into direct contact with landfill wastes, the waste handling and treatment areas, or landfill wastewater. Non-contaminated storm water includes storm water that flows off the cap, cover, intermediate cover, daily cover, and/or final cover of the landfill. Additional Technology-Based Effluent Limits. Preventive Maintenance Program. As part of your preventive maintenance program, maintain the following: all elements of leachate collection and treatment systems, to prevent commingling of leachate with storm water; the integrity and effectiveness of any intermediate or final cover (including repairing the cover as necessary), to minimize the effects of settlement, sinking, and erosion. Erosion and Sedimentation Control. Provide temporary stabilization (e.g., temporary seeding, mulching, and placing geotextiles on the inactive portions of stockpiles) for the following: materials stockpiled for daily, intermediate, and final cover; inactive areas of the landfill or open dump; landfills or open dump areas that have gotten final covers but where vegetation has yet to establish itself; and land application sites where waste application has been completed but final vegetation has not yet been established. Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: active and closed landfill cells or trenches, active and closed land application areas, locations where open dumping is occurring or has occurred, locations of any known leachate springs or other areas where uncontrolled leachate may commingle with runoff, and leachate collection and handling systems. Summary of Potential Pollutant Sources. (Document in your SWPPP the following sources and activities that have potential pollutants associated with them: fertilizer, herbicide, and pesticide application; earth and soil moving; waste hauling and loading or unloading; outdoor storage of significant materials, including daily, interim, and final cover material stockpiles as well as temporary waste storage areas; exposure of active and inactive landfill and land application areas; uncontrolled leachate flows; and failure or leaks from leachate collection and treatment systems. Additional Inspection Requirements. Inspections of Active Sites. Except in arid and semi-arid climates, inspect operating landfills, open dumps, and land application sites at least once every 7 days. Focus on areas of landfills that have not yet been finally stabilized; active land application areas, areas used for storage of material and wastes that are exposed to precipitation, 1-33 Attachment 1 L.7.2 L.8 L.8.1 L.9 stabilization, and structural control measures; leachate collection and treatment systems; and locations where equipment and waste trucks enter and exit the site. Ensure that sediment and erosion control measures are operating properly. For stabilized sites and areas where land application has been completed, or where the climate is arid or semi-arid, conduct inspections at least once every month. Inspections of Inactive Sites. Inspect inactive landfills, open dumps, and land application sites at least quarterly. Qualified personnel must inspect landfill (or open dump) stabilization and structural erosion control measures, leachate collection and treatment systems, and all closed land application areas. Additional Post-Authorization Documentation Requirements. Recordkeeping and Internal Reporting. Keep records with your SWPPP of the types of wastes disposed of in each cell or trench of a landfill or open dump. For land application sites, track the types and quantities of wastes applied in specific areas. Sector-Specific Benchmarks Table L-1 identifies benchmarks that apply to the specific subsectors of Sector L. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table L-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration1 Subsector L1. All Landfill, Land Application Sites and Open Dumps (Industrial Activity Code "LF") Subsector L2. All Landfill, Land Application Sites and Open Dumps, except Municipal Solid Waste Landfill (MSWLF) Areas Closed in Accordance with 40 CFR 258.60 (Industrial Activity Code "LF") Total Suspended Solids (TSS) Total Iron 100 mg/L 1.0 mg/L 1Benchmark monitoring required only for discharges not subject to effluent limitations in 40 CFR Part 445 Subpart B (see Table L-2 above). L.10. Effluent Limitations Based on Effluent Limitations Guidelines Table L-2 identifies effluent limits that apply to the industrial activities described below. Compliance with these effluent limits is to be determined based on discharges from these industrial activities independent of commingling with any other waste streams that may be covered under this permit. 1-34 Attachment 1 Table L-21 Industrial Activity Parameter Effluent Limit Discharges from non- Biochemical Oxygen Demand 140 mg/L, daily maximum hazardous waste landfills (BOD5) 37 mg/L, monthly avg. maximum subject to effluent limitations in 40 CFR Part 445 Subpart B. Total Suspended Solids (TSS) Ammonia 88 mg/L, daily maximum 27 mg/L, monthly avg. maximum 10 mg/L, daily maximum 4.9 mg/L, monthly avg. maximum Alpha Terpineol 0.033 mg/L, daily maximum 0.016 mg/L monthly avg. maximum Benzoic Acid 0.12 mg/L, daily maximum 0.071 mg/L, monthly avg. maximum p-Cresol 0.025 mg/L, daily maximum 0.014 mg/L, monthly avg. maximum Phenol 0.026 mg/L, daily maximum 0.015 mg/L, monthly avg. maximum Total Zinc 0.20 mg/L, daily maximum 0.11 mg/L, monthly avg. maximum pH Within the range of 6-9 standard pH units (s.u.) 1 Monitor annually. As set forth at 40 CFR Part 445 Subpart B, these numeric limitations apply to contaminated storm water discharges from MSWLFs that have not been closed in accordance with 40 CFR 258.60, and to contaminated storm water discharges from those landfills that are subject to the provisions of 40 CFR Part 257 except for discharges from any of the following facilities: (a) landfills operated in conjunction with other industrial or commercial operations, when the landfill receives only wastes generated by the industrial or commercial operation directly associated with the landfill; (b) landfills operated in conjunction with other industrial or commercial operations, when the landfill receives wastes generated by the industrial or commercial operation directly associated with the landfill and also receives other wastes, provided that the other wastes received for disposal are generated by a facility that is subject to the same provisions in 40 CFR Subchapter N as the industrial or commercial operation, or that the other wastes received are of similar nature to the wastes generated by the industrial or commercial operation; (c) landfills operated in conjunction with CWT facilities subject to 40 CFR Part 437, so long as the CWT facility commingles the landfill wastewater with other non-landfill wastewater for discharge. A landfill directly associated with a CWT facility is subject to this part if the CWT facility discharges landfill wastewater separately from other CWT wastewater or commingles the wastewater from its landfill only with wastewater from other landfills; or (d) landfills operated in conjunction with other industrial or commercial operations when the landfill receives wastes from public service activities, so long as the company owning the landfill does not receive a fee or other remuneration for the disposal service. 1-35 Attachment 1 Subpart M - Sector M - Automobile Salvage Yards. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR M: AUTOMOBILE SALVAGE YARDS Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented M1 5015 Automobile Salvage Yards M.1 M.2 M.2.1 Covered Storm water Discharges. The requirements in Subpart M apply to storm water discharges associated with industrial activity from Automobile Salvage Yards as identified by the SIC Code specified in Attachment 2 of this permit. Additional Technology-Based Effluent Limits. Spill and Leak Prevention Procedures. Drain vehicles intended to be dismantled of all fluids upon arrival at the site (or as soon thereafter as practicable), or employ some other equivalent means to prevent spills and leaks. M.2.2 Employee Training. If applicable to your facility, address the following areas (at a minimum) in your employee training program: proper handling (collection, storage, and disposal) of oil, used mineral spirits, anti-freeze, mercury switches, and solvents. M.2.3 Management of Runoff. Implement appropriate management practices, such as the following: berms or drainage ditches on the property line (to help prevent run-on from neighboring properties); berms for uncovered outdoor storage of oily parts, engine blocks, and above-ground liquid storage; installation of detention ponds; and installation of filtering devices and oil and water separators. M.3 M.3.1 Additional SWPPP Requirements. Drainage Area Site Map. Identify locations used for dismantling, storage, and maintenance of used motor vehicle parts. Also identify where any of the following may be exposed to precipitation or surface runoff: dismantling areas, parts (e.g., engine blocks, tires, hub caps, batteries, hoods, mufflers) storage areas, and liquid storage tanks and drums for fuel and other fluids. M.3.2 Potential Pollutant Sources. Assess the potential for the following to contribute pollutants to storm water discharges: vehicle storage areas, dismantling areas, parts storage areas (e.g., engine blocks, tires, hub caps, batteries, hoods, mufflers), and fueling stations. M.4 Additional Inspection Requirements. Immediately (or as soon thereafter as practicable) inspect vehicles arriving at the site for leaks. Inspect quarterly for signs of leakage all equipment containing oily parts, hydraulic fluids, any other types of fluids, or mercury 1-36 Attachment 1 switches. Also, inspect quarterly for signs of leakage all vessels and areas where hazardous materials and general automotive fluids are stored, including, but not limited to, mercury switches, brake fluid, transmission fluid, radiator water, and antifreeze. M.5 Sector-Specific Benchmarks. Table M-1 identifies benchmarks that apply to Sector M. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table M-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration Subsector M1. Automobile Salvage Yards (SIC 5015) Total Suspended Solids (TSS) Total Aluminum 100 mg/L 0.75 mg/L Total Iron 1.0 mg/L Total Lead (freshwater)2 Hardness Dependent Total Lead (saltwater)1 0.21 mg/L 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Lead (mg/L) 0.014 0.023 0.045 0.069 0.095 0.122 0.151 0.182 0.213 0.246 0.262 1-37 Attachment 1 Subpart N - Sector N - Scrap Recycling and Waste Recycling Facilities. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR N: SCRAP RECYCLING FACILITES Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented N1 5093 Scrap Recycling and Waste Recycling Facilities Except Source Separated Recycling N2 5093 Source Separated Recycling Facility N.1 N.2 N.2.1 N.3 N.3.1 Covered Storm water Discharges. The requirements in Subpart N apply to storm water discharges associated with industrial activity from Scrap Recycling and Waste Recycling facilities as identified by the SIC Code specified under attachment 2 of this permit. Limitation on Coverage. Separate permit requirements have been established for recycling facilities that receive, process, and do wholesale distribution of only source-separated recyclable materials primarily from non-industrial and residential sources (i.e., common consumer products including paper, newspaper, glass, cardboard, plastic containers, and aluminum and tin cans). This includes recycling facilities commonly referred to as material recovery facilities (MRF). Prohibition of Non-Storm water Discharges. Non-storm water discharges from turnings containment areas are not covered by this permit. Discharges from containment areas in the absence of a storm event are prohibited unless covered by a separate NPDES permit. Additional Technology-Based Effluent Limits. Scrap and Waste Recycling Facilities (Non-Source Separated, Nonliquid Recyclable Materials). Requirements for facilities that receive, process, and do wholesale distribution of nonliquid recyclable wastes (e.g., ferrous and nonferrous metals, plastics, glass, cardboard, and paper). These facilities may receive both nonrecyclable and recyclable materials. This section is not intended for those facilities that accept recyclables only from primarily non-industrial and residential sources. N.3.1.1 Inbound Recyclable and Waste Material Control Program. Minimize the chance of accepting materials that could be significant sources of pollutants by conducting inspections of inbound recyclables and waste materials. Following are some control measure options: (a) provide information and education to suppliers of scrap and recyclable waste materials on draining and properly disposing of residual fluids (e.g., from vehicles and equipment engines, radiators and transmissions, oil filled transformers, and individual 1-38 Attachment 1 N.3.1.2 N.3.1.3 N.3.1.4 N.3.1.5 containers or drums) and removal of mercury switches from vehicles before delivery to your facility; (b) establish procedures to minimize the potential of any residual fluids from coming into contact with precipitation or runoff; (c) establish procedures for accepting scrap lead-acid batteries (additional requirements for the handling, storage, and disposal or recycling of batteries are contained in the scrap lead-acid battery program provisions in Part 8.N.3.2.6); (d) provide training targeted for those personnel engaged in the inspection and acceptance of inbound recyclable materials; and (e) establish procedures to ensure that liquid wastes, including used oil, are stored in materially compatible and non-leaking containers and are disposed of or recycled in accordance with the Resource Conservation and Recovery Act (RCRA). Scrap and Waste Material Stockpiles and Storage (Outdoor). Minimize contact of storm water runoff with stockpiled materials, processed materials, and nonrecyclable wastes. Following are some control measure options: (a) permanent or semi-permanent covers; (b) sediment traps, vegetated swales and strips, catch basin filters, and sand filters to facilitate settling or filtering of pollutants; (c) dikes, berms, containment trenches, culverts, and surface grading to divert runoff from storage areas; (d) silt fencing; and (e) oil and water separators, sumps, and dry absorbents for areas where potential sources of residual fluids are stockpiled (e.g., automobile engine storage areas). Stockpiling of Turnings Exposed to Cutting Fluids (Outdoor Storage). Minimize contact of surface runoff with residual cutting fluids by: (a) storing all turnings exposed to cutting fluids under some form of permanent or semi-permanent cover, or (b) establishing dedicated containment areas for all turnings that have been exposed to cutting fluids. Any containment areas must be constructed of concrete, asphalt, or other equivalent types of impermeable material and include a barrier (e.g., berms, curbing, elevated pads) to prevent contact with storm water run-on. Storm water runoff from these areas can be discharged, provided that any runoff is first collected and treated by an oil and water separator or its equivalent. You must regularly maintain the oil and water separator (or its equivalent) and properly dispose of or recycle collected residual fluids. Scrap and Waste Material Stockpiles and Storage (Covered or Indoor Storage). Minimize contact of residual liquids and particulate matter from materials stored indoors or under cover with surface runoff. Following are some control measure options: (a) good housekeeping measures, including the use of dry absorbents or wet vacuuming to contain, dispose of, or recycle residual liquids originating from recyclable containers, or mercury spill kits for spills from storage of mercury switches; (b) not allowing wash water from tipping floors or other processing areas to discharge to the storm sewer system; and (c) disconnecting or sealing off all floor drains connected to the storm sewer system. Scrap and Recyclable Waste Processing Areas. Minimize surface runoff from coming in contact with scrap processing equipment. Pay attention to operations that generate visible amounts of particulate residue (e.g., shredding) to minimize the contact of accumulated particulate matter and residual fluids with runoff (i.e., through good housekeeping, preventive 1-39 Attachment 1 N.3.1.6 N.3.1.7 N.3.1.8 N.3.2 N.3.2.1 maintenance, etc.). Following are some control measure options: (a) regularly inspect equipment for spills or leaks and malfunctioning, worn, or corroded parts or equipment; (b) establish a preventive maintenance program for processing equipment; (c) use dry-absorbents or other cleanup practices to collect and dispose of or recycle spilled or leaking fluids or use mercury spill kits for spills from storage of mercury switches; (d) on unattended hydraulic reservoirs over 150 gallons in capacity, install protection devices such as lowlevel alarms or equivalent devices, or secondary containment that can hold the entire volume of the reservoir; (e) containment or diversion structures such as dikes, berms, culverts, trenches, elevated concrete pads, and grading to minimize contact of storm water runoff with outdoor processing equipment or stored materials; (f) oil and water separators or sumps; (g) permanent or semipermanent covers in processing areas where there are residual fluids and grease; (h) retention or detention ponds or basins; sediment traps, and vegetated swales or strips (for pollutant settling and filtration); (i) catch basin filters or sand filters. Scrap Lead-Acid Battery Program. Properly handle, store, and dispose of scrap lead-acid batteries. Following are some control measure options (a) segregate scrap lead-acid batteries from other scrap materials; (b) properly handle, store, and dispose of cracked or broken batteries; (c) collect and dispose of leaking lead-acid battery fluid; (d) minimize or eliminate (if possible) exposure of scrap lead-acid batteries to precipitation or runoff; and (e) provide employee training for the management of scrap batteries. Spill Prevention and Response Procedures. (See also Part 2.1.2.4)Install alarms and/or pump shutoff systems on outdoor equipment with hydraulic reservoirs exceeding 150 gallons in the event of a line break. Alternatively, a secondary containment system capable of holding the entire contents of the reservoir plus room for precipitation can be used. Use a mercury spill kit for any release of mercury from switches, anti-lock brake systems, and switch storage areas. Supplier Notification Program. As appropriate, notify major suppliers which scrap materials will not be accepted at the facility or will be accepted only under certain conditions. Waste Recycling Facilities (Liquid Recyclable Materials). Waste Material Storage (Indoor). Minimize or eliminate contact between residual liquids from waste materials stored indoors and from surface runoff. The plan may refer to applicable portions of other existing plans, such as Spill Prevention, Control, and Countermeasure (SPCC) plans required under 40 CFR Part 112. Following are some control measure options (a) procedures for material handling (including labeling and marking); (b) clean up spills and leaks with dry absorbent materials, a wet vacuum system; (c) appropriate containment structures (trenching, curbing, gutters, etc.); and (d) a drainage system, including appurtenances (e.g., pumps or ejectors, manually operated valves), to handle discharges from diked or bermed areas. Drainage should be discharged to an appropriate treatment facility or sanitary sewer system, or otherwise disposed of properly. These discharges may require coverage under a separate NPDES wastewater permit or industrial user permit under the pretreatment program. 1-40 Attachment 1 N.3.3 N.3.2.2 Waste Material Storage (Outdoor). Minimize contact between stored residual liquids and precipitation or runoff. The plan may refer to applicable portions of other existing plans, such as SPCC plans required under 40 CFR Part 112. Discharges of precipitation from containment areas containing used oil must also be in accordance with applicable sections of 40 CFR Part 112. Following are some control measure options (a) appropriate containment structures (e.g., dikes, berms, curbing, pits) to store the volume of the largest tank, with sufficient extra capacity for precipitation; (b) drainage control and other diversionary structures; (c) corrosion protection and/or leak detection systems for storage tanks; and (d) dry-absorbent materials or a wet vacuum system to collect spills. N.3.2.3 Trucks and Rail Car Waste Transfer Areas. Minimize pollutants in discharges from truck and rail car loading and unloading areas. Include measures to clean up minor spills and leaks resulting from the transfer of liquid wastes. Following are two control measure options: (a) containment and diversionary structures to minimize contact with precipitation or runoff, and (b) dry cleanup methods, wet vacuuming, roof coverings, or runoff controls. Recycling Facilities (Source-Separated Materials). The following identifies considerations for facilities that receive only source-separated recyclables, primarily from non-industrial and residential sources. N.3.3.1 Inbound Recyclable Material Control. Minimize the chance of accepting nonrecyclables (e.g., hazardous materials) that could be a significant source of pollutants by conducting inspections of inbound materials. Following are some control measure options: (a) providing information and education measures to inform suppliers of recyclables about acceptable and nonacceptable materials, (b) training drivers responsible for pickup of recycled material, (c) clearly marking public drop-off containers regarding which materials can be accepted, (d) rejecting nonrecyclable wastes or household hazardous wastes at the source, and (e) establishing procedures for handling and disposal of nonrecyclable material. N.3.3.2 Outdoor Storage. Minimize exposure of recyclables to precipitation and runoff. Use good housekeeping measures to prevent accumulation of particulate matter and fluids, particularly in high traffic areas. Following are some control measure options (a) provide totally enclosed drop-off containers for the public; (b) install a sump and pump with each container pit and treat or discharge collected fluids to a sanitary sewer system; (c) provide dikes and curbs for secondary containment (e.g., around bales of recyclable waste paper); (d) divert surface water runoff away from outside material storage areas; (e) provide covers over containment bins, dumpsters, and roll-off boxes; and (f) store the equivalent of one day's volume of recyclable material indoors. N.3.3.3 Indoor Storage and Material Processing. Minimize the release of pollutants from indoor storage and processing areas. Following are some control measure options (a) schedule routine good housekeeping measures for all storage and processing areas, (b) prohibit tipping floor wash water from draining to the storm sewer system, and (c) provide employee training on pollution prevention practices. 1-41 Attachment 1 N.4 N.4.1 N.4.2 N.5 N.5.1 N.6 N.3.3.4 Vehicle and Equipment Maintenance. Following are some control measure options for areas where vehicle and equipment maintenance occur outdoors (a) prohibit vehicle and equipment wash water from discharging to the storm sewer system, (b) minimize or eliminate outdoor maintenance areas whenever possible, (c) establish spill prevention and clean-up procedures in fueling areas, (d) avoid topping off fuel tanks, (e) divert runoff from fueling areas, (f) store lubricants and hydraulic fluids indoors, and (g) provide employee training on proper handling and storage of hydraulic fluids and lubricants. Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP the locations of any of the following activities or sources that may be exposed to precipitation or surface runoff: scrap and waste material storage, outdoor scrap and waste processing equipment; and containment areas for turnings exposed to cutting fluids. Maintenance Schedules/Procedures for Collection, Handling, and Disposal or Recycling of Residual Fluids at Scrap and Waste Recycling Facilities. If you are subject to Part N.3.1.3, your SWPPP must identify any applicable maintenance schedule and the procedures to collect, handle, and dispose of or recycle residual fluids. Additional Inspection Requirements. Inspections for Waste Recycling Facilities. The inspections must be performed quarterly, pursuant to Section E.8 of this permit, and include, at a minimum, all areas where waste is generated, received, stored, treated, or disposed of and that are exposed to either precipitation or storm water runoff. Sector-Specific Benchmarks. Table N-1 identifies benchmarks that apply to Sector N. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Subsector (You may be subject to requirements for more than one sector/subsector) Subsector N1. Scrap Recycling and Waste Recycling Facilities except those only receiving source-separate recyclable materials primarily from nonindustrial and residential sources (SIC 5093) Table N-1. Parameter Chemical Oxygen Demand (COD) Total Suspended Solids (TSS) Total Recoverable Aluminum Total Copper (freshwater)2 Total Copper (saltwater)1 Total Recoverable Iron Total Lead (freshwater)2 Total Lead (saltwater)1 Total Zinc (freshwater)2 Total Zinc (saltwater)1 Benchmark Monitoring Concentration 120 mg/L 100 mg/L 0.75 mg/L Hardness Dependent 0.0048 mg/L 1.0 mg/L Hardness Dependent 0.21 mg/L Hardness Dependent 0.09 mg/L 1-42 Attachment 1 Table N-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Copper (mg/L) 0.0038 0.0056 0.0090 0.0123 0.0156 0.0189 0.0221 0.0253 0.0285 0.0316 0.0332 Lead (mg/L) 0.014 0.023 0.045 0.069 0.095 0.122 0.151 0.182 0.213 0.246 0.262 Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 0.25 0.26 1-43 Attachment 1 Subpart O - Sector O - Steam Electric Generating Facilities. Steam electric power generating facilities are required to obtain individual or general NPDES Permits pursuant to Section B.3. of this permit. Attachment 1 Subpart P - Sector P - Land Transportation and Warehousing. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR P: LAND TRANSPORTATION AND WAREHOUSING Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented P1 4011,4013 Railroad Transportation 4111-4173 Local and Highway Transportation 4212-4231 (except 4221-4225) 4311 Motor Freight Transportation and Warehousing United States Postal Service 5171 Air Transportation Facilities P.1 P.2 P.2.1 P.3 P.3.1 Covered Storm water Discharges. The requirements in Subpart P apply to storm water discharges associated with industrial activity from Land Transportation and Warehousing facilities as identified by the SIC Codes specified under attachment 2 of this permit. Limitation on Coverage Prohibited Discharges This permit does not authorize the discharge of vehicle/equipment/surface wash water, including tank cleaning operations. Such discharges must be authorized under a separate NPDES permit, discharged to a sanitary sewer in accordance with applicable industrial pretreatment requirements, or recycled on-site. Additional Technology-Based Effluent Limits. Good Housekeeping Measures. In addition to the Good Housekeeping requirements in Section E.6.c, you must do the following. Recommended control measures are discussed as indicated: P.3.1.1 Vehicle and Equipment Storage Areas. Minimize the potential for storm water exposure to leaky or leak-prone vehicles/equipment awaiting maintenance. Implement appropriate control measures, such as the following (or other equivalent measures): use of drip pans under vehicles/equipment, indoor storage of vehicles and equipment, installation of berms or dikes, use of absorbents, roofing or covering storage areas, and cleaning pavement surfaces to remove oil and grease. 1-44 Attachment 1 P.3.2 P.4 P.4.1 P.3.1.2 Fueling Areas. Minimize contamination of storm water runoff from fueling areas. Implement appropriate control measures, such as the following (or other equivalent measures): Covering the fueling area; using spill/overflow protection and cleanup equipment; minimizing storm water run-on/runoff to the fueling area; using dry cleanup methods; and treating and/or recycling collected storm water runoff. P.3.1.3 Material Storage Areas. Maintain all material storage vessels (e.g., for used oil/oil filters, spent solvents, paint wastes, hydraulic fluids) to prevent contamination of storm water and plainly label them (e.g., "Used Oil," "Spent Solvents," etc.). Consider the following (or other equivalent measures): storing the materials indoors; installing berms/dikes around the areas; minimizing runoff of storm water to the areas; using dry cleanup methods; and treating and/or recycling collected storm water runoff. P.3.1.4 Vehicle and Equipment Cleaning Areas. Minimize contamination of storm water runoff from all areas used for vehicle/equipment cleaning. Implement appropriate control measures, such as the following (or other equivalent measures): performing all cleaning operations indoors; covering the cleaning operation, ensuring that all wash water drains to a proper collection system (i.e., not the storm water drainage system); treating and/or recycling collected wash water, or other equivalent measures. P.3.1.5 Vehicle and Equipment Maintenance Areas. Minimize contamination of storm water runoff from all areas used for vehicle/equipment maintenance. Implement appropriate control measures, such as the following (or other equivalent measures): performing maintenance activities indoors; using drip pans; keeping an organized inventory of materials used in the shop; draining all parts of fluid prior to disposal; prohibiting wet clean up practices if these practices would result in the discharge of pollutants to storm water drainage systems; using dry cleanup methods; treating and/or recycling collected storm water runoff, minimizing run on/runoff of storm water to maintenance areas. P.3.1.6 Locomotive Sanding (Loading Sand for Traction) Areas. Implement appropriate control measures, such as the following (or other equivalent measures): covering sanding areas; minimizing storm water run on/runoff; or appropriate sediment removal practices to minimize the offsite transport of sanding material by storm water. Employee Training. Train personnel at least once a year and address the following activities, as applicable: used oil and spent solvent management; fueling procedures; general good housekeeping practices; proper painting procedures; and used battery management. Additional SWPPP Requirements. Drainage Area Site Map. Identify in the SWPPP the following areas of the facility and indicate whether activities occurring there may be exposed to precipitation/surface runoff: Fueling stations; vehicle/equipment maintenance or cleaning areas; storage areas for vehicle/equipment with actual or potential fluid leaks; loading/unloading areas; areas where treatment, storage or disposal of wastes occur; liquid storage tanks; processing areas; and storage areas. 1-45 Attachment 1 P.4.2 P.4.3 P.4.4 P.5 Potential Pollutant Sources. Assess the potential for the following activities and facility areas to contribute pollutants to storm water discharges: Onsite waste storage or disposal; dirt/gravel parking areas for vehicles awaiting maintenance; illicit plumbing connections between shop floor drains and the storm water conveyance system(s); and fueling areas. Describe these activities in the SWPPP. Description of Good Housekeeping Measures. You must document in your SWPPP the good housekeeping measures you implement consistent with Part P.3. Vehicle and Equipment Wash water Requirements. If applicable, attach to or reference in your SWPPP, a copy of the NPDES permit issued for vehicle/equipment wash water or, if an NPDES permit has not been issued, a copy of the pending application. If an industrial user permit is issued under a local pretreatment program, attach a copy to your SWPPP. In any case, implement all non-storm water discharge permit conditions or pretreatment conditions in your SWPPP. If wash water is handled in another manner (e.g., hauled offsite), describe the disposal method and attach all pertinent documentation/information (e.g., frequency, volume, destination, etc.) in the plan. Additional Inspection Requirements. Inspect all the following areas/activities: storage areas for vehicles/equipment awaiting maintenance, fueling areas, indoor and outdoor vehicle/equipment maintenance areas, material storage areas, vehicle/equipment cleaning areas and loading/unloading areas. 1-46 Attachment 1 Subpart Q - Sector Q - Water Transportation. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR Q: WATER TRANSPORTATION Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented Q1 4412-4499 Water Transportation Facilities Q.1 Q.2 Q.2.1 Covered Storm water Discharges. The requirements in Subpart Q apply to storm water discharges associated with industrial activity from Water Transportation facilities as identified by the SIC Codes specified under Attachment 2 of this permit. Limitations on Coverage. Prohibition of Non-Storm water Discharges. Not covered by this permit: bilge and ballast water, sanitary wastes, pressure wash water, and cooling water originating from vessels. Q.3 Q.3.1 Additional Technology-Based Effluent Limits. Good Housekeeping Measures. You must implement the following good housekeeping measures in addition to the requirements of Section E.6.c: Q.3.1.1 Pressure Washing Area. If pressure washing is used to remove marine growth from vessels, the discharge water must be permitted by a separate NPDES permit. Collect or contain the discharges from the pressures washing area so that they are not co-mingled with storm water discharges authorized by this permit. Q.3.1.2 Blasting and Painting Area. Minimize the potential for spent abrasives, paint chips, and overspray to discharge into receiving waters or the storm sewer systems. Contain all blasting and painting activities or use other measures to minimize the discharge of contaminants (e.g., hanging plastic barriers or tarpaulins during blasting or painting operations to contain debris). At least once per month, you must clean storm water conveyances of deposits of abrasive blasting debris and paint chips. Q.3.1.3 Material Storage Areas. Store and plainly label all containerized materials (e.g., fuels, paints, solvents, waste oil, antifreeze, batteries) in a protected, secure location away from drains. Minimize the contamination of precipitation or surface runoff from the storage areas. Specify which materials are stored indoors, and containment or enclosure or use other measures for those stored outdoors. If abrasive blasting is performed, discuss the storage and disposal of spent abrasive materials generated at the facility. Implement an inventory control plan to limit the presence of potentially hazardous materials onsite. 1-47 Attachment 1 Q.3.1.4 Engine Maintenance and Repair Areas. Minimize the contamination of precipitation or surface runoff from all areas used for engine maintenance and repair. Implement appropriate control measures, such as the following (or their equivalents): performing all maintenance activities indoors, maintaining an organized inventory of materials used in the shop, draining all parts of fluid prior to disposal, prohibiting the practice of hosing down the shop floor, using dry cleanup methods, and treating and/or recycling storm water runoff collected from the maintenance area. Q.3.1.5 Material Handling Area. Minimize the contamination of precipitation or surface runoff from material handling operations and areas (e.g., fueling, paint and solvent mixing, disposal of process wastewater streams from vessels). Implement appropriate control measures, such as the following (or their equivalents): covering fueling areas, using spill and overflow protection, mixing paints and solvents in a designated area (preferably indoors or under a shed), and minimizing runoff of storm water to material handling areas. Q.3.1.6 Dry-dock Activities. Routinely maintain and clean the dry-dock to minimize pollutants in storm water runoff. Address the cleaning of accessible areas of the dry-dock prior to flooding, and final cleanup following removal of the vessel and raising the dock. Include procedures for cleaning up oil, grease, and fuel spills occurring on the dry-dock. Implement appropriate control measures, such as the following (or their equivalents): sweeping rather than hosing off debris and spent blasting material from accessible areas of the drydock prior to flooding and making absorbent materials and oil containment booms readily available to clean up or contain any spills. Q.3.2 Employee Training. As part of your employee training program, address, at a minimum, the following activities (as applicable): used oil management, spent solvent management, disposal of spent abrasives, disposal of vessel wastewaters, spill prevention and control, fueling procedures, general good housekeeping practices, painting and blasting procedures, and used battery management. Q.3.3 Preventive Maintenance. As part of your preventive maintenance program, perform timely inspection and maintenance of storm water management devices (e.g., cleaning oil and water separators and sediment traps to ensure that spent abrasives, paint chips, and solids will be intercepted and retained prior to entering the storm drainage system), as well as inspecting and testing facility equipment and systems to uncover conditions that could cause breakdowns or failures resulting in discharges of pollutants to surface waters. Q.4 Q.4.1 Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: fueling; engine maintenance and repair; vessel maintenance and repair; pressure washing; painting; sanding; blasting; welding; metal fabrication; loading and unloading areas; locations used for the treatment, storage, or disposal of wastes; liquid storage tanks; liquid storage areas (e.g., paint, solvents, resins); and material storage areas (e.g., blasting media, aluminum, steel, scrap iron). Q.4.2 Summary of Potential Pollutant Sources. Document in the SWPPP the following additional sources and activities that have potential pollutants associated with them: outdoor manufacturing or processing activities (e.g., welding, metal fabricating) and 1-48 Attachment 1 significant dust or particulate generating processes (e.g., abrasive blasting, sanding, and painting.) Q.5 Additional Inspection Requirements. Include the following in all quarterly routine facility inspections: pressure washing area; blasting, sanding, and painting areas; material storage areas; engine maintenance and repair areas; material handling areas; dry-dock area; and general yard area. Q.6 Sector-Specific Benchmarks. Table Q-1 identifies benchmarks that apply to Sector Q. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table Q-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration Subsector Q1. Water Transportation Total Aluminum 0.75 mg/L Facilities (SIC 4412-4499) Total Iron Total Lead 1.0 mg/L Hardness Dependent (freshwater)2 Total Lead 0.21 mg/L (saltwater)1 Total Zinc Hardness Dependent (freshwater)2 Total Zinc (saltwater)1 0.09 mg/L 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Lead (mg/L) 0.014 0.023 0.045 0.069 0.095 0.122 0.151 0.182 0.213 0.246 0.262 Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 0.25 0.26 1-49 Attachment 1 Subpart R - Sector R - Ship and Boat Building and Repair Yards. You must comply with Part 8 sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR R: SHIP AND BOAT BUILDING AND REPAIRING YARDS SECTOR (May be subject to more than one sector/subsector SIC Code or Activity Code Activity Represented R1 3731,3732 Ship and Boat Building or Repairing Yards R.1 R.2 R.2.1 R.3 R.3.1 Covered Storm water Discharges. The requirements in Subpart R apply to storm water discharges associated with industrial activity from Ship and Boat Building and Repair Yards as identified by the SIC Codes specified under Attachment 2 of this permit. Limitations on Coverage. Prohibition of Non-Storm water Discharges. Discharges containing bilge and ballast water, sanitary wastes, pressure wash water, and cooling water originating from vessels are not covered by this permit. Additional Technology-Based Effluent Limits. Good Housekeeping Measures. R.3.1.1 Pressure Washing Area. If pressure washing is used to remove marine growth from vessels, the discharged water must be permitted as a process wastewater by a separate NPDES permit. R.3.1.2 Blasting and Painting Area. Minimize the potential for spent abrasives, paint chips, and overspray to discharging into the receiving water or the storm sewer systems. Contain all blasting and painting activities, or use other measures to prevent the discharge of the contaminants (e.g., hanging plastic barriers or tarpaulins during blasting or painting operations to contain debris). When necessary, regularly clean storm water conveyances of deposits of abrasive blasting debris and paint chips. R.3.1.3 Material Storage Areas. Store and plainly label all containerized materials (e.g., fuels, paints, solvents, waste oil, antifreeze, batteries) in a protected, secure location away from drains. Minimize the contamination of precipitation or surface runoff from the storage areas. If abrasive blasting is performed, discuss the storage and disposal of spent abrasive materials generated at the facility. Implement an inventory control plan to limit the presence of potentially hazardous materials onsite. R.3.1.4 Engine Maintenance and Repair Areas. Minimize the contamination of precipitation or surface runoff from all areas used for engine maintenance 1-50 Attachment 1 R.3.2 R.3.4 R.4 R.4.1 R.4.2 and repair. Implement appropriate control measures, such as the following (or their equivalents): performing all maintenance activities indoors, maintaining an organized inventory of materials used in the shop, draining all parts of fluid prior to disposal, prohibiting the practice of hosing down the shop floor, using dry cleanup methods, and treating and/or recycling storm water runoff collected from the maintenance area. R.3.1.5 Material Handling Area. Minimize the contamination of precipitation or surface runoff from material handling operations and areas (e.g., fueling, paint and solvent mixing, disposal of process wastewater streams from vessels). Implement appropriate control measures, such as the following (or their equivalents): covering fueling areas, using spill and overflow protection, mixing paints and solvents in a designated area (preferably indoors or under a shed), and minimizing storm water run-on to material handling areas. R.3.1.6 Dry-dock Activities. Routinely maintain and clean the dry-dock to minimize pollutants in storm water runoff. Clean accessible areas of the dry-dock prior to flooding and final cleanup following removal of the vessel and raising the dock. Include procedures for cleaning up oil, grease, or fuel spills occurring on the dry-dock. Implement appropriate control measures, such as the following (or their equivalents): sweeping rather than hosing off debris and spent blasting material from accessible areas of the dry-dock prior to flooding, and having absorbent materials and oil containment booms readily available to clean up and contain any spills. Employee Training. As part of your employee training program, address, at a minimum, the following activities (as applicable): used oil management, spent solvent management, disposal of spent abrasives, disposal of vessel wastewaters, spill prevention and control, fueling procedures, general good housekeeping practices, painting and blasting procedures, and used battery management. Preventive Maintenance. As part of your preventive maintenance program, perform timely inspection and maintenance of storm water management devices (e.g., cleaning oil and water separators and sediment traps to ensure that spent abrasives, paint chips, and solids will be intercepted and retained prior to entering the storm drainage system), as well as inspecting and testing facility equipment and systems to uncover conditions that could cause breakdowns or failures resulting in discharges of pollutants to surface waters. Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: fueling; engine maintenance or repair; vessel maintenance or repair; pressure washing; painting; sanding; blasting; welding; metal fabrication; loading and unloading areas; treatment, storage, and waste disposal areas; liquid storage tanks; liquid storage areas (e.g., paint, solvents, resins); and material storage areas (e.g., blasting media, aluminum, steel, scrap iron). Potential Pollutant Sources. Document in your SWPPP the following additional sources and activities that have potential pollutants associated with them (if applicable): outdoor manufacturing or processing activities (e.g., welding, metal fabricating) and significant dust or particulate generating processes (e.g., abrasive blasting, sanding, and painting). 1-51 Attachment 1 R.4.3 R.5 Documentation of Good Housekeeping Measures. Document in your SWPPP any good housekeeping measures implemented to meet the effluent limits in Part R.3. R.4.3.1 Blasting and Painting Areas. Document in the SWPPP any standard operating practices relating to blasting and painting (e.g., prohibiting uncontained blasting and painting over open water or prohibiting blasting and painting during windy conditions, which can render containment ineffective). R.4.3.2 Storage Areas. Specify in your SWPPP which materials are stored indoors, and contain or enclose or use other measures for those stored outdoors. Additional Inspection Requirements. (See also Part 3.1) Include the following in all quarterly routine facility inspections: pressure washing area; blasting, sanding, and painting areas; material storage areas; engine maintenance and repair areas; material handling areas; dry-dock area; and general yard area. 1-52 Attachment 1 Subpart S - Sector S - Air Transportation. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR S: AIR TRANSPORTATION FACILITIES Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented S1 5412-4581 Air Transportation Facilities S.1 S.2 S.2.1 S.2.2 S.3 S.3.1 Covered Storm water Discharges. The requirements in Subpart S apply to storm water discharges associated with industrial activity from Air Transportation facilities identified by the SIC Codes specified under Attachment 2 of this permit. Limitation on Coverage Limitations on Coverage. This permit authorizes storm water discharges from only those portions of the air transportation facility that are involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling and lubrication), equipment cleaning operations or deicing operations. Note: "deicing" will generally be used to imply both deicing (removing frost, snow or ice) and anti-icing (preventing accumulation of frost, snow or ice) activities, unless specific mention is made regarding anti-icing and/or deicing activities. Prohibition of Non-Storm water Discharges. This permit does not authorize the discharge of aircraft, ground vehicle, runway and equipment wash waters; nor the dry weather discharge of deicing chemicals. Such discharges must be covered by separate NPDES permit(s). Note that a discharge resulting from snowmelt is not a dry weather discharge. Additional Technology-Based Effluent Limits. Good Housekeeping Measures. S.3.1.1 Aircraft, Ground Vehicle and Equipment Maintenance Areas. Minimize the contamination of storm water runoff from all areas used for aircraft, ground vehicle and equipment maintenance (including the maintenance conducted on the terminal apron and in dedicated hangers). Implement appropriate control measures, such as the following practices (or their equivalents): performing maintenance activities indoors; maintaining an organized inventory of material used in the maintenance areas; draining all parts of fluids prior to disposal; prohibiting the practice of hosing down the apron or hanger floor; using dry cleanup methods; and collecting the storm 1-53 Attachment 1 S.3.1.2 S.3.1.3 S.3.1.4 S.3.1.5 S.3.1.6 water runoff from the maintenance area and providing treatment or recycling. Aircraft, Ground Vehicle and Equipment Cleaning Areas. (See also Part S.3.6) Clearly demarcate these areas on the ground using signage or other appropriate means. Minimize the contamination of storm water runoff from cleaning areas. Aircraft, Ground Vehicle and Equipment Storage Areas. Store all aircraft, ground vehicles and equipment awaiting maintenance in designated areas only and minimize the contamination of storm water runoff from these storage areas. Implement appropriate control measures, such as the following, including any BMPs (or their equivalents): storing aircraft and ground vehicles indoors; using drip pans for the collection of fluid leaks; and perimeter drains, dikes or berms surrounding the storage areas. Material Storage Areas. Maintain the vessels of stored materials (e.g., used oils, hydraulic fluids, spent solvents, and waste aircraft fuel) in good condition, to prevent or minimize contamination of storm water. Also plainly label the vessels (e.g., "used oil," "Contaminated Jet A," etc.). Minimize contamination of precipitation/runoff from these areas. Implement appropriate control measures, such as the following (or their equivalents): storing materials indoors; storing waste materials in a centralized location; and installing berms/dikes around storage areas. Airport Fuel System and Fueling Areas. Minimize the discharge of fuel to the storm sewer/surface waters resulting from fuel servicing activities or other operations conducted in support of the airport fuel system. Implement appropriate control measures, such as the following control measures (or their equivalents): implementing spill and overflow practices (e.g., placing absorptive materials beneath aircraft during fueling operations); using only dry cleanup methods; and collecting storm water runoff. Source Reduction. Minimize, and where practicable eliminate, the use of urea and glycol-based deicing chemicals, in order to reduce the aggregate amount of deicing chemicals used and/or lessen the environmental impact. Chemical options to replace ethylene glycol, propylene glycol and urea include: potassium acetate; magnesium acetate; calcium acetate; and anhydrous sodium acetate. S.3.1.6.1 Runway Deicing Operation: Minimize contamination of storm water runoff from runways as a result of deicing operations. Evaluate whether over-application of deicing chemicals occurs by analyzing application rates, and adjust as necessary, consistent with considerations of flight safety. Implement appropriate control measures, such as the following options (or their equivalents): metered application of chemicals; pre-wetting dry chemical constituents prior to application; installing a runway ice detection system; implementing anti-icing operations as a preventive measure against ice buildup. S.3.1.6.2 Aircraft Deicing Operations. Minimize contamination of storm water runoff from aircraft deicing operations. Determine whether excessive application of deicing chemicals occurs and adjust as 1-54 Attachment 1 S.3.2 S.4 necessary, consistent with considerations of flight safety. This evaluation should be carried out by the personnel most familiar with the particular aircraft and flight operations in question (versus an outside entity such as the airport authority). Use benign alternative deicing/anti-icing techniques and agents as well as containment measures for all applied chemicals where practicable. Implement appropriate control measures, such as the following options (or their equivalents) for reducing deicing fluid use: forced-air deicing systems, computer-controlled fixed-gantry systems, infrared technology, hot water, varying glycol content to air temperature, enclosed-basket deicing trucks, mechanical methods, solar radiation, hangar storage, aircraft covers, and thermal blankets for MD-80s and DC-9s. Use ice-detection systems and airport traffic flow strategies and departure slot allocation systems where practicable. S.3.1.7 Management of Runoff. Where deicing operations occur, implement a program to control or manage contaminated runoff to minimize the amount of pollutants being discharged from the site. Where practicable, install a centralized deicing pad to recover deicing fluid following application, or where impracticable, use vacuum/collection trucks (glycol recovery vehicles). Also, consider these control measure options (or their equivalents): a dedicated deicing facility with a runoff collection/ recovery system; using vacuum/collection trucks; storing contaminated storm water/deicing fluids in tanks and releasing controlled amounts to a publicly owned treatment works; collecting contaminated runoff in a wet pond for biochemical decomposition (be aware of attracting wildlife that may prove hazardous to flight operations); and directing runoff into vegetative swales or other infiltration measures. Recover deicing materials when these materials are applied during non-precipitation events (e.g., covering storm sewer inlets, using booms, installing absorptive interceptors in the drains, etc.) to prevent these materials from later becoming a source of storm water contamination. Used deicing fluid should be recycled whenever possible. Deicing Season. You must determine the seasonal timeframe (e.g., DecemberFebruary, October - March) during which deicing activities typically occur at the facility. Implementation of control measures, including any BMPs, facility inspections and monitoring must be conducted with particular emphasis throughout the defined deicing season. If you meet the deicing chemical usage thresholds of 100,000 gallons glycol and/or 100 tons of urea, the deicing season you identified is the timeframe during which you must obtain the four required benchmark monitoring event results for deicing-related parameters, i.e., BOD, COD, ammonia and pH. See also Part S.6. Additional SWPPP Requirements. An airport authority and tenants of the airport are encouraged to work in partnership in the development of a SWPPP. If an airport tenant obtains authorization under this permit and develops a SWPPP for discharges from his own areas of the airport, prior to authorization, that SWPPP must be coordinated and integrated with the SWPPP for the entire airport. Tenants of the airport facility include air passenger or cargo companies, fixed based operators and other parties who have contracts with the airport authority to conduct business operations on airport property and whose operations result in storm water discharges associated with industrial activity. 1-55 Attachment 1 S.4.1 S.4.2 S.4.3 S.4.4 8.S.5 S.6 Drainage Area Site Map. Document in the SWPPP the following areas of the facility and indicate whether activities occurring there may be exposed to precipitation/surface runoff: aircraft and runway deicing operations; fueling stations; aircraft, ground vehicle and equipment maintenance/cleaning areas; storage areas for aircraft, ground vehicles and equipment awaiting maintenance. Potential Pollutant Sources. (See also Part 5.2.3) In your inventory of exposed materials, describe in your SWPPP the potential for the following activities and facility areas to contribute pollutants to storm water discharges: aircraft, runway, ground vehicle and equipment maintenance and cleaning; aircraft and runway deicing operations (including apron and centralized aircraft deicing stations, runways, taxiways and ramps). If you use deicing chemicals, you must maintain a record of the types (including the Material Safety Data Sheets [MSDS]) used and the monthly quantities, either as measured or, in the absence of metering, as estimated to the best of your knowledge. This includes all deicing chemicals, not just glycols and urea (e.g., potassium acetate), because large quantities of these other chemicals can still have an adverse impact on receiving waters. Tenants or other fixed-based operations that conduct deicing operations must provide the above information to the airport authority for inclusion with any comprehensive airport SWPPPs. Vehicle and Equipment Wash water Requirements. Attach to or reference in your SWPPP, a copy of the NPDES permit issued for vehicle/equipment wash water or, if an NPDES permit has not been issued, a copy of the pending application. If an industrial user permit is issued under a local pretreatment program, include a copy in your SWPPP. In any case, if you are subject to another permit, describe your control measures for implementing all non-storm water discharge permit conditions or pretreatment requirements in your SWPPP. If wash water is handled in another manner (e.g., hauled offsite, retained onsite), describe the disposal method and attach all pertinent documentation/information (e.g., frequency, volume, destination, etc.) in your SWPPP. Documentation of Control Measures Used for Management of Runoff: Document in your SWPPP the control measures used for collecting or containing contaminated melt water from collection areas used for disposal of contaminated snow. Additional Inspection Requirements. At a minimum conduct facility inspections at least monthly during the deicing season (e.g., October through April for most mid-latitude airports). If your facility needs to deice before or after this period, expand the monthly inspections to include all months during which deicing chemicals may be used. The Director may specifically require you to increase inspection frequencies. Sector-Specific Benchmarks. Table S-1 identifies benchmarks that apply to Sector S. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. 1-56 Attachment 1 Table S-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration For airports where a single permittee, or a combination of permitted facilities use more Biochemical Oxygen Demand (BOD5)1 30 mg/L than 100,000 gallons of glycol-based deicing chemicals and/or 100 tons or more of urea on an average annual basis, monitor the first four parameters in ONLY those outfalls that collect runoff from areas where deicing activities occur (SIC 4512-4581). Chemical Oxygen Demand (COD)1 Ammonia1 pH1 120 mg/L 2.14 mg/L 6.0 - 9.0 s.u. 1 These are deicing-related parameters. Collect the four benchmark samples, and any required follow-up benchmark samples, during the timeframe defined in Part 8.S.3.2 when deicing activities are occurring. S.7 Effluent Limitations Based on Effluent Limitations Guidelines S.7.1 Airfield Pavement Deicing. Existing and new primary airports with 1,000 or more annual jet departures ("non-propeller aircraft") that discharge wastewater associated with airfield pavement deicing commingled with storm water must either use non-ureacontaining deicers or meet the effluent limit in Table S-2. S.7.2 Aircraft Deicing. Airports meeting the definition of a new source ("new airports") with 10,000 annual departures located in cold climate zones must collect 60 percent of aircraft deicing fluid after deicing. See 40 CFR 449.11 for the Airport Effluent Limitation Guidelines requirements for this new source category. Discharges of the collected aircraft deicing fluid directly to waters of the U.S. are not eligible for coverage under this permit. S.7.3 Monitoring, Reporting and Recordkeeping. For new airports subject to the effluent limitations in S.7.2, you must comply with the monitoring, reporting and recordkeeping requirements outlined in 40 CFR 449.20(a)(1) and (2). 1-57 Attachment 1 Industrial Activity Existing and new primary airports with 1,000 or more annual jet departures that discharge wastewater associated with airfield pavement deicing that contains urea commingled with storm water Table S-2 Parameter Ammonia as Nitrogen Effluent Limit 14.7 mg/L, daily maximum 1-58 Attachment 1 Subpart T - Sector T - Treatment Works. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR T: TREATMENT WORKS Subsector (May be subject to more than one Sector/subsector T1 SIC Code or Activity Code TW Activity Represented Treatment works treating domestic sewage or any other sewage or any other sewage sludge or wastewater treatment device or system used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge that are located within the confines of the facility with a design flow of 1.0 MGD or more, or required to have a an approved pretreatment program under 40 CFR Part 403. Not included are farm lands, lands used for domestic gardens or lands used for sludge management where sludge is beneficially reused and are not physically located within the confines of the facility or areas that are in compliance with Section 405 of the CWA T.1 T.2 T.2.1 T.2.2 T.3 T.3.1 Covered Storm water Discharges. The requirements in Subpart T apply to storm water discharges associated with industrial activity from Treatment Works as identified by the Activity Code specified under Attachment 2 of this permit. Industrial Activities Covered by Sector T. The requirements listed under this part apply to all existing point source storm water discharges associated with the following activities: Treatment works treating domestic sewage, or any other sewage sludge or wastewater treatment device or system used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge; that are located within the confines of a facility with a design flow of 1.0 million gallons per day (MGD) or more; or are required to have an approved pretreatment program under 40 CFR Part 403. The following are not required to have permit coverage: farm lands, domestic gardens or lands used for sludge management where sludge is beneficially reused and which are not physically located within the facility, or areas that are in compliance with Section 405 of the CWA. Limitations on Coverage. Prohibition of Non-Storm water Discharges. Sanitary and industrial wastewater and equipment and vehicle wash water are not authorized by this permit. 1-59 Attachment 1 T.4 T.4.1 T.4.2 T.5 T.5.1 T.5.2 T.5.3 T.6 Additional Technology-Based Effluent Limits. Control Measures. In addition to the other control measures, evaluate implementation of the following additional control measures: routing storm water to the treatment works; or covering exposed materials (i.e., from the following areas: grit, screenings, and other solids handling, storage, or disposal areas; sludge drying beds; dried sludge piles; compost piles; and septage or hauled waste receiving station). Employee Training. At a minimum, training must address the following areas when applicable to a facility: petroleum product management; process chemical management; spill prevention and controls; fueling procedures; general good housekeeping practices; and proper procedures for using fertilizer, herbicides, and pesticides. Additional SWPPP Requirements. Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: grit, screenings, and other solids handling, storage, or disposal areas; sludge drying beds; dried sludge piles; compost piles; septage or hauled waste receiving station; and storage areas for process chemicals, petroleum products, solvents, fertilizers, herbicides, and pesticides. Potential Pollutant Sources. Document in your SWPPP the following additional sources and activities that have potential pollutants associated with them, as applicable: grit, screenings, and other solids handling, storage, or disposal areas; sludge drying beds; dried sludge piles; compost piles; septage or hauled waste receiving station; and access roads and rail lines. Wastewater and Wash water Requirements. Keep a copy of all your current NPDES permits issued for wastewater and industrial, vehicle and equipment wash water discharges or, if an NPDES permit has not yet been issued, a copy of the pending application(s) with your SWPPP. If the wash water is handled in another manner, the disposal method must be described and all pertinent documentation must be retained onsite. Additional Inspection Requirements. Include the following areas in all inspections: access roads and rail lines; grit, screenings, and other solids handling, storage, or disposal areas; sludge drying beds; dried sludge piles; compost piles; and septage or hauled waste receiving station. 1-60 Attachment 1 Subpart U - Sector U - Food and Kindred Products. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR U: FOOD AND KINDRED PRODUCTS Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented U1 2041-2048 Grain Mill Products U2 2074-2079 Fats and Oils Products U3 2011-2015 Meat Products 2021-2026 Dairy Products 2032-2038 Canned, Frozen, Preserved Fruits, Vegetables and Food Specialties 2051-2053 Bakery Products 2061-2068 Sugar and Confectionery Products 2082-2087 Beverages 2091-2099 Miscellaneous Food Preparations and Kindred Products 2111-2141 Tobacco Products U.1 U.2 U.2.1 U.3 U.3.1 U.4 U.4.1 Covered Storm water Discharges. The requirements in Subpart U apply to storm water discharges associated with industrial activity from Food and Kindred Products facilities as identified by the SIC Codes specified in Attachment 2 of this permit. Limitations on Coverage. Prohibition of Non-Storm water Discharges. The following discharges are not authorized by this permit: discharges containing boiler blowdown, cooling tower overflow and blowdown, ammonia refrigeration purging, and vehicle washing and clean-out operations. Additional Technology-Based Limitations. Employee Training. Address pest control in your employee training program. Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP the locations of the following activities if they are exposed to precipitation or runoff: vents and stacks from cooking, 1-61 Attachment 1 U.4.2 U.5 U.6 drying, and similar operations; dry product vacuum transfer lines; animal holding pens; spoiled product; and broken product container storage areas. Potential Pollutant Sources. Document in your SWPPP, in addition to food and kindred products processing-related industrial activities, application and storage of pest control chemicals (e.g., rodenticides, insecticides, fungicides) used on plant grounds. Additional Inspection Requirements. Inspect on a quarterly basis, at a minimum, the following areas where the potential for exposure to storm water exists: loading and unloading areas for all significant materials; storage areas, including associated containment areas; waste management units; vents and stacks emanating from industrial activities; spoiled product and broken product container holding areas; animal holding pens; staging areas; and air pollution control equipment. Sector-Specific Benchmarks. Table U-1 identifies benchmarks that apply to the specific subsectors of Sector U. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Subsector (You may be subject to requirements for more than one Sector / Subsector) Subsector U1. Grain Mill Products (SIC 2041-2048) Subsector U2. Fats and Oils Products (SIC 2074-2079) Table U-1. Parameter Total Suspended Solids (TSS) Biochemical Oxygen Demand (BOD5) Chemical Oxygen Demand (COD) Nitrate plus Nitrite Nitrogen Total Suspended Solids (TSS) Benchmark Monitoring Concentration 100 mg/L 30 mg/L 120 mg/L 0.68 mg/L 100 mg/L 1-62 Attachment 1 Subpart V - Sector V - Textile Mills, Apparel, and Other Fabric Products. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR V: TEXTILE MILLS, APPAREL, AND OTHER FABRIC MANUFACTURING; LEATHER AND LEATHER PRODUCTS Subsector (May be subject to more than one sector/subsector SIC Code or Activity Code Activity Represented V1 211-2299 Textile Mill Products 2311-2399 Apparel and Other Finished Products Made From Fabrics and Similar Materials 3131-3199 Leather and Leather Products (note: see sector Z1 for Leather Tanning and Finishing) V.1 V.2 V.2.1 V.3 V.3.1 Covered Storm water Discharges. The requirements in Subpart V apply to storm water discharges associated with industrial activity from Textile Mills, Apparel, and Other Fabric Product manufacturing as identified by the SIC Codes specified under attachment 2 of this permit. Limitations on Coverage. Prohibition of Non-Storm water Discharges. The following are not authorized by this permit: discharges of wastewater (e.g., wastewater resulting from wet processing or from any processes relating to the production process), reused or recycled water, and waters used in cooling towers. If you have these types of discharges from your facility, you must cover them under a separate NPDES permit. Additional Technology-Based Limitations. Good Housekeeping Measures. V.3.1.1 Material Storage Areas. Plainly label and store all containerized materials (e.g., fuels, petroleum products, solvents, and dyes) in a protected area, away from drains. Minimize contamination of the storm water runoff from such storage areas. Also consider an inventory control plan to prevent excessive purchasing of potentially hazardous substances. For storing empty chemical drums or containers, ensure that the drums and containers are clean (consider triple-rinsing) and that there is no contact of residuals with precipitation or runoff. Collect and dispose of wash water from these cleanings properly. V.3.1.2 Material Handling Areas. Minimize contamination of storm water runoff from material handling operations and areas. Implement appropriate control measures, such as the following (or their equivalents): use of spill and overflow 1-63 Attachment 1 V.3.2 V.4 V.4.1 V.4.2 V.5 protection; covering fueling areas; and covering or enclosing areas where the transfer of material may occur. When applicable, address the replacement or repair of leaking connections, valves, transfer lines, and pipes that may carry chemicals, dyes, or wastewater. V.3.1.3 Fueling Areas. Minimize contamination of storm water runoff from fueling areas. Implement appropriate control measures, such as the following (or their equivalents): covering the fueling area, using spill and overflow protection, minimizing run-on of storm water to the fueling areas, using dry cleanup methods, and treating and/or recycling storm water runoff collected from the fueling area. V.3.1.4 Above-Ground Storage Tank Area. Minimize contamination of the storm water runoff from above-ground storage tank areas, including the associated piping and valves. Implement appropriate control measures, such as the following (or their equivalents): regular cleanup of these areas; including measures for tanks, piping and valves explicitly in your SPCC program; minimizing runoff of storm water from adjacent areas; restricting access to the area; inserting filters in adjacent catch basins; providing absorbent booms in unbermed fueling areas; using dry cleanup methods; and permanently sealing drains within critical areas that may discharge to a storm drain. Employee Training. As part of your employee training program, address, at a minimum, the following activities (as applicable): use of reused and recycled waters, solvents management, proper disposal of dyes, proper disposal of petroleum products and spent lubricants, spill prevention and control, fueling procedures, and general good housekeeping practices. Additional SWPPP Requirements. Potential Pollutant Sources. Document in your SWPPP the following additional sources and activities that have potential pollutants associated with them: industry-specific significant materials and industrial activities (e.g., backwinding, beaming, bleaching, backing bonding, carbonizing, carding, cut and sew operations, desizing, drawing, dyeing locking, fulling, knitting, mercerizing, opening, packing, plying, scouring, slashing, spinning, synthetic-felt processing, textile waste processing, tufting, turning, weaving, web forming, winging, yarn spinning, and yarn texturing). Description of Good Housekeeping Measures for Material Storage Areas. Document in the SWPPP your containment area or enclosure for materials stored outdoors in connection with Part V.3.1.1 above. Additional Inspection Requirements. Inspect, at least monthly, the following activities and areas (at a minimum): transfer and transmission lines, spill prevention, good housekeeping practices, management of process waste products, and all structural and nonstructural management practices. 1-64 Attachment 1 Subpart W - Sector W - Furniture and Fixtures. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below: The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR W: FURNITURE AND FIXTURES Subsector (May be subject to more than one sector/subsector) W1 SIC Code or Activity Code 2434 Activity Represented Wood Kitchen Cabinets 2511-2599 Furniture and Fixtures W.1 W.2 W.2.1 Covered Storm water Discharges. The requirements in Subpart W apply to storm water discharges associated with industrial activity from Furniture and Fixtures facilities as identified by the SIC Codes specified under Attachment 2 of this permit. Additional SWPPP Requirements. Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: material storage (including tanks or other vessels used for liquid or waste storage) areas; outdoor material processing areas; areas where wastes are treated, stored, or disposed of; access roads; and rail spurs. 1-65 Attachment 1 Subpart X - Sector X - Printing and Publishing. You must comply with Part 8 sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR X: PRINTING AND PUBLISHING Sector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented X1 2711-2796 Printing, Publishing, and Allied Industries X.1 X.2 X.2.1 Covered Storm water Discharges. The requirements in Subpart X apply to storm water discharges associated with industrial activity from Printing and Publishing facilities as identified by the SIC Codes specified under Attachment 2 of this permit. Additional Technology-Based Effluent Limits. Good Housekeeping Measures. X.2.1.1 Material Storage Areas. Plainly label and store all containerized materials (e.g., skids, pallets, solvents, bulk inks, hazardous waste, empty drums, portable and mobile containers of plant debris, wood crates, steel racks, and fuel oil) in a protected area, away from drains. Minimize contamination of the storm water runoff from such storage areas. Also consider an inventory control plan to prevent excessive purchasing of potentially hazardous substances. X.2.1.2 Material Handling Area. Minimize contamination of storm water runoff from material handling operations and areas (e.g., blanket wash, mixing solvents, loading and unloading materials). Implement appropriate control measures, such as the following (or their equivalents): using spill and overflow protection, covering fueling areas, and covering or enclosing areas where the transfer of materials may occur. When applicable, address the replacement or repair of leaking connections, valves, transfer lines, and pipes that may carry chemicals or wastewater. X.2.1.3 Fueling Areas. Minimize contamination of storm water runoff from fueling areas. Implement appropriate control measures, such as the following (or their equivalents): covering the fueling area, using spill and overflow protection, minimizing runoff of storm water to the fueling areas, using dry cleanup methods, and treating and/or recycling storm water runoff collected from the fueling area. X.2.1.4 Above Ground Storage Tank Area. Minimize contamination of the storm water runoff from above-ground storage tank areas, including the associated piping and valves. Consider the following (or their equivalents): regularly cleaning these areas, explicitly addressing tanks, piping and valves in the SPCC program, minimizing storm water runoff from adjacent areas, restricting 1-66 Attachment 1 X.2.2 X.3 X.3.1 access to the area, inserting filters in adjacent catch basins, providing absorbent booms in unbermed fueling areas, using dry cleanup methods, and permanently sealing drains within critical areas that may discharge to a storm drain. Employee Training. As part of your employee training program, address, at a minimum, the following activities (as applicable): spent solvent management, spill prevention and control, used oil management, fueling procedures, and general good housekeeping practices. Additional SWPPP Requirements. Description of Good Housekeeping Measures for Material Storage Areas. In connection with Part X.2.1.1, describe in the SWPPP the containment area or enclosure for materials stored outdoors. 1-67 Attachment 1 Subpart Y - Sector Y - Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR Y: RUBBER, MISCELLANEOUS PLASTIC PRODUCTS, AND MISCELLANEOUS MANUFACTURING INDUSTRIES Subsector (May be subject to more than one sector/subsector SIC Code or Activity Code Activity Represented Y1 3011 Tires and Inner Tubes 3021 Rubber and Plastics Footwear 3052,3053 Gaskets, Packing and Sealing Devices, and Rubber and Plastic Hoses and Belting 3061,3069 Fabricated Rubber Products, Not Elsewhere Classified Y2 3081-3089 Miscellaneous Plastics Products 3931 Musical Instruments 3942-3949 Dolls, Toys, Games, and Sporting and Athletic Goods 3951-3955 (except 3952-see Sector C) Pens, Pencils, and other artist's materials 3961,3965 Costume Jewelry, Costume Novelties, Buttons, and Miscellaneous Notions, Except Precious Metals 3991-3999 Miscellaneous Manufacturing Industries Y.1 Y.2 Y.2.1 Covered Storm water Discharges. The requirements in Subpart Y apply to storm water discharges associated with industrial activity from Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries facilities as identified by the SIC Codes specified under Attachment 2 of this permit. Additional Technology-Based Effluent Limits. Controls for Rubber Manufacturers. Minimize the discharge of zinc in your storm water discharges. Parts 8.Y.2.1.1 to 8.Y.2.1.5 give possible sources of zinc to be reviewed and list some specific control measures to be implemented (or their equivalents). In addition to these control measures the following include some additional general control 1-68 Attachment 1 Y.2.2 Y.3 Y.3.1 Y.4 measure options to be evaluated for implementation: using chemicals purchased in pre-weighed, sealed polyethylene bags; storing in-use materials in sealable containers, ensuring an airspace between the container and the cover to minimize "puffing" losses when the container is opened, and using automatic dispensing and weighing equipment. Y2.1.1 Zinc Bags. Ensure proper handling and storage of zinc bags at your facility. Following are some control measure options: employee training on the handling and storage of zinc bags, indoor storage of zinc bags, cleanup of zinc spills without washing the zinc into the storm drain, and the use of 2,500pound sacks of zinc rather than 50- to 100-pound sacks. Y.2.1.2 Dumpsters. Minimize discharges of zinc from dumpsters. Following are some control measure options: covering the dumpster, moving the dumpster indoors, or providing a lining for the dumpster. Y.2.1.3 Dust Collectors and Baghouses. Minimize contributions of zinc to storm water from dust collectors and baghouses. Replace or repair, as appropriate, improperly operating dust collectors and baghouses. Y.2.1.4 Grinding Operations. Minimize contamination of storm water as a result of dust generation from rubber grinding operations. One control measure option is to install a dust collection system. Y.2.1.5 Zinc Stearate Coating Operations. Minimize the potential for storm water contamination from drips and spills of zinc stearate slurry that may be released to the storm drain. One control measure option is to use alternative compounds to zinc stearate. Controls for Plastic Products Manufacturers. Minimize the discharge of plastic resin pellets in your storm water discharges. Control measures to be implemented (or their equivalents) include minimizing spills, cleaning up of spills promptly and thoroughly, sweeping thoroughly, pellet capturing, employee education, and disposal precautions. Additional SWPPP Requirements. Potential Pollutant Sources for Rubber Manufacturers. Document in your SWPPP the use of zinc at your facility and the possible pathways through which zinc may be discharged in storm water runoff. Sector-Specific Benchmarks. Table Y-1 identifies benchmarks that apply to Sector Y. These benchmarks apply to both your primary industrial activity and any co-located industrial activities. Table Y-1. Subsector (You may be subject to requirements for more than one sector/subsector) Subsector Y1. Rubber Products Manufacturing (SIC 3011, 3021, 3052, 3053, 3061, 3069) Parameter Total Zinc (freshwater)2 Total Zinc (saltwater)1 1-69 Benchmark Monitoring Concentration Hardness Dependent 0.09 mg/L Attachment 1 Table Y-1. Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 0.25 0.26 1-70 Attachment 1 Subpart Z - Sector Z - Leather Tanning and Finishing. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR Z: LEATHER TANNING AND FINISHING Subsector (May be subject to more than one sector/subsector) SIC Code of Activity Code Activity Represented Z1 3111 Leather Tanning and Finishing Z.1 Z.2 Z.2.3 Covered Storm water Discharges. The requirements in Subpart Z apply to storm water discharges associated with industrial activity from Leather Tanning and Finishing facilities as identified by the SIC Code specified under Attachment 2 of this permit. Additional Technology-Based Effluent Limits. Good Housekeeping Measures. Z.2.3.1 Storage Areas for Raw, Semi-processed, or Finished Tannery By-products. Minimize contamination of storm water runoff from pallets and bales of raw, semi-processed, or finished tannery by-products (e.g., splits, trimmings, shavings). Store or protect indoors with polyethylene wrapping, tarpaulins, roofed storage, etc. where practicable. Place materials on an impermeable surface and enclose or put berms (or equivalent measures) around the area to prevent storm water run-on and runoff where practicable. Z.2.3.2 Material Storage Areas. Label storage containers of all materials (e.g., specific chemicals, hazardous materials, spent solvents, waste materials) and minimize contact of such materials with storm water. Z.2.3.3 Buffing and Shaving Areas. Minimize contamination of storm water runoff with leather dust from buffing and shaving areas. Implement dust collection enclosures, preventive inspection and maintenance programs, or other appropriate preventive measures where practicable. Z.2.3.4 Receiving, Unloading, and Storage Areas. Minimize contamination of storm water runoff from receiving, unloading, and storage areas. If these areas are exposed, implement appropriate control measures, such as the following (or their equivalents): covering all hides and chemical supplies, diverting drainage to the process sewer, or grade berming or curbing the area to prevent storm water runoff. Z.2.3.5 Outdoor Storage of Contaminated Equipment. Minimize contact of storm water with contaminated equipment. Implement appropriate control measures, such as the following (or their equivalents): covering equipment, 1-71 Attachment 1 Z.3 Z.3.1 Z.3.2 diverting drainage to the process sewer, and cleaning thoroughly prior to storage. Z.2.3.6 Waste Management. Minimize contamination of storm water runoff from waste storage areas. Implement appropriate control measures, such as the following (or their equivalents): covering dumpsters, moving waste management activities indoors, covering waste piles with temporary covering material such as tarpaulins or polyethylene, and minimizing storm water runoff by enclosing the area or building berms around the area. Additional SWPPP Requirements. Drainage Area Site Map. Identify in your SWPPP where any of the following may be exposed to precipitation or surface runoff: processing and storage areas of the beamhouse, tanyard, and re-tan wet finishing and dry finishing operations. Potential Pollutant Sources. (See also Part 5.2.3) Document in your SWPPP the following sources and activities that have potential pollutants associated with them (as appropriate): temporary or permanent storage of fresh and brine-cured hides; extraneous hide substances and hair; leather dust, scraps, trimmings, and shavings. 1-72 Attachment 1 Subpart AA - Sector AA - Fabricated Metal Products You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR AA: FABRICATED METAL PRODUCTS Subsector (May be subject to more than one sector/subsector) AA1 SIC Code or Activity Code Activity Represented 3411-3499 (except 3479) Fabricated Metal Products, Except Machinery and Transportation Equipment, and Coating, Engraving, and Allied Services 3911-3915 Jewelry, Silverware, and Plated Ware AA2 3479 Fabricated Metal Coating and Engraving AA.1 Covered Storm water Discharges. The requirements in Subpart AA apply to storm water discharges associated with industrial activity from Fabricated Metal Products facilities as identified by the SIC Codes specified under Attachment 2 of this permit. AA.2 Additional Technology-Based Effluent Limits. AA.2.1 Good Housekeeping Measures. AA.2.1.1 Raw Steel Handling Storage. Minimize the generation of and/or recover and properly manage scrap metals, fines, and iron dust. Include measures for containing materials within storage handling areas. AA.2.1.2 Paints and Painting Equipment. Minimize exposure of paint and painting equipment to storm water. AA.2.2 Spill Prevention and Response Procedures. Ensure that the necessary equipment to implement a cleanup is available to personnel. The following areas should be addressed AA.2.2.1 Metal Fabricating Areas. Maintain clean, dry, orderly conditions in these areas. Use dry clean-up techniques where practicable. AA.2.2.2 Storage Areas for Raw Metal. Keep these areas free of conditions that could cause, or impede appropriate and timely response to, spills or leakage of materials. Implement appropriate control measures, such as the following (or their equivalents): maintaining storage areas so that there is easy access in the event of a spill, and labeling stored materials to aid in identifying spill contents. AA.2.2.3 Metal Working Fluid Storage Areas. Minimize the potential for storm water contamination from storage areas for metal working fluids. 1-73 Attachment 1 AA.2.2.4 Cleaners and Rinse Water. Control and clean up spills of solvents and other liquid cleaners, control sand buildup and disbursement from sand-blasting operations, and prevent exposure of recyclable wastes. Substitute environmentally benign cleaners when possible. AA.2.2.5 Lubricating Oil and Hydraulic Fluid Operations. Minimize the potential for storm water contamination from lubricating oil and hydraulic fluid operations. Use monitoring equipment or other devices to detect and control leaks and overflows where practicable. Install perimeter controls such as dikes, curbs, grass filter strips, or equivalent measures where practicable. AA.2.2.6 Chemical Storage Areas. Minimize storm water contamination and accidental spillage in chemical storage areas. Include a program to inspect containers and identify proper disposal methods. AA.2.3 Spills and Leaks. In your spill prevention and response procedures pay attention to the following materials (at a minimum): chromium, toluene, pickle liquor, sulfuric acid, zinc and other water priority chemicals, and hazardous chemicals and wastes. AA.3 Additional SWPPP Requirements. AA.3.1 Drainage Area Site Map. Document in your SWPPP where any of the following may be exposed to precipitation or surface runoff: raw metal storage areas; finished metal storage areas; scrap disposal collection sites; equipment storage areas; retention and detention basins; temporary and permanent diversion dikes or berms; right-of-way or perimeter diversion devices; sediment traps and barriers; processing areas, including outside painting areas; wood preparation; recycling; and raw material storage. AA.3.2 Potential Pollutant Sources. Document in your SWPPP the following additional sources and activities that have potential pollutants associated with them: loading and unloading operations for paints, chemicals, and raw materials; outdoor storage activities for raw materials, paints, empty containers, corn cobs, chemicals, and scrap metals; outdoor manufacturing or processing activities such as grinding, cutting, degreasing, buffing, and brazing; onsite waste disposal practices for spent solvents, sludge, pickling baths, shavings, ingot pieces, and refuse and waste piles. AA.4 Additional Inspection Requirements AA.4.1 Inspections. At a minimum, include the following areas in all inspections: raw metal storage areas, finished product storage areas, material and chemical storage areas, spent solvents and chemical storage areas, recycling areas, loading and unloading areas, equipment storage areas, paint areas, drainage from roof and vehicle fueling and maintenance areas. Potential pollutants include chromium, zinc, lubricating oil, solvents, aluminum, oil and grease, methyl ethyl ketone, steel, and related materials. 1-74 Attachment 1 AA.5 Sector-Specific Benchmarks. Table AA-1 Subsector (You may be subject to requirements for more than one sector/subsector) Parameter Benchmark Monitoring Concentration Subsector AA1. Fabricated Metal Total Aluminum 0.75 mg/L Products, except Coating (SIC 34113499; 3911-3915) Total Iron Total Zinc (freshwater)2 1.0 mg/L Hardness Dependent Total Zinc (saltwater)1 0.09 mg/L Nitrate plus Nitrite Nitrogen 0.68 mg/L Subsector AA2. Fabricated Metal Total Zinc (freshwater)2 Hardness Dependent Coating and Engraving (SIC 3479) Total Zinc (saltwater)1 0.09 mg/L Nitrate plus Nitrite Nitrogen 0.68 mg/L 1Saltwater benchmark values apply to storm water discharges into saline waters where indicated. 2 The freshwater benchmark values of some metals are dependent on water hardness. For these parameters, permittees must determine the hardness of the receiving water (see Attachment 3, "Calculating Hardness in Receiving Waters for Hardness Dependent Metals," for methodology), in accordance with Part 6.2.1.1, to identify the applicable `hardness range' for determining their benchmark value applicable to their facility. Hardness Dependent Benchmarks follow in the table below: Freshwater Hardness Range 0-24.99 mg/L 25-49.99 mg/L 50-74.99 mg/L 75-99.99 mg/L 100-124.99 mg/L 125-149.99 mg/L 150-174.99 mg/L 175-199.99 mg/L 200-224.99 mg/L 225-249.99 mg/L 250+ mg/L Zinc (mg/L) 0.04 0.05 0.08 0.11 0.13 0.16 0.18 0.20 0.23 0.25 0.26 1-75 Attachment 1 Subpart AB - Sector AB - Transportation Equipment, Industrial or Commercial Machinery Facilities. You must comply with Part 8 sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR AB: TRANSPORTATION EQUIPMENT, INDUSTRIAL or COMMERCIAL MACHINERY Subsector (May be subject to more than one sector/subsector) SIC Code or Activity Code Activity Represented AB1 3511-3599 Industrial and Commercial Machinery, Except Computer (except and Office Equipment (See Sector AC) 3571-3579) 3711-3799 Transportation Equipment Except Ship and Boat Building and (except Repairing (See Sector R) 3731, 3732) AB.1 Covered Storm water Discharges. The requirements in Subpart AB apply to storm water discharges associated with industrial activity from Transportation Equipment, Industrial or Commercial Machinery facilities as identified by the SIC Codes specified in Attachment 2 of this permit. AB.2 AB.2.1 Additional SWPPP Requirements. Drainage Area Site Map. Identify in your SWPPP where any of the following may be exposed to precipitation or surface runoff: vents and stacks from metal processing and similar operations. 1-76 Attachment 1 Subpart AC- Sector AC -Electronic and Electrical Equipment and Components, Photographic and Optical Goods. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR AC: ELECTRONIC, ELECTRICAL, PHOTOGRAPHIC< AND OPTICAL GOODS Sector (May be subject to one or more sectors/subsectors AC1 SIC Code or Activity Code 3571-3579 Activity Represented Computer and Office Equipment 3812-3873 Measuring, Analyzing, and Controlling Instruments; Photographic and Optical Goods, Watches and Clocks 3612-3699 Electronic and Electrical Equipment and Components, except Computer Equipment AC.1 Covered Storm water Discharges. The requirements in Subpart AC apply to storm water discharges associated with industrial activity from facilities that manufacture Electronic and Electrical Equipment and Components, Photographic and Optical goods as identified by the SIC Codes specified in Attachment 2 of this permit. AC.2 Additional Requirements. No additional sector-specific requirements apply. 1-77 Attachment 1 Subpart AD - Sector AD - Storm water Discharges Designated by the Director as Requiring Permits. You must comply with sector-specific requirements associated with your primary industrial activity and any co-located industrial activities, as specified below. The sector-specific requirements apply to those areas of your facility where those sector-specific activities occur. These sector-specific requirements are in addition to any requirements specified elsewhere in this permit. SECTOR AD: NONCLASSIFIED FACILITES AD1 Other storm water discharges designated by the Director as needing a permit (see 40 CFR 122.26(a)(9)(i)(C) & (D) or any facility discharging storm water not described by any of Sectors A-AC. NOTE: Facilities may not elect to be covered under Section AD. Only the Director may assign a facility to Sector AD AD.1 Covered Storm water Discharges. Sector AD is used to provide permit coverage for facilities designated by the Director as needing a storm water permit, and any discharges of storm water associated with industrial activity that do not meet the description of an industrial activity covered by Sectors A-AC. AD.1.1 Eligibility for Permit Coverage. Because this sector is primarily intended for use by discharges designated by the Director as needing a storm water permit (which is an atypical circumstance), and your facility may or may not normally be discharging storm water associated with industrial activity, you must obtain the Director's written permission to use this permit prior to submitting an NOI. If you are authorized to use this permit, you will still be required to ensure that your discharges meet the basic eligibility provisions of this permit at Part 1.1. AD.2 Sector-Specific Benchmarks and Effluent Limits. The Director will establish any additional monitoring and reporting requirements for your facility prior to authorizing you to be covered by this permit. Additional monitoring requirements would be based on the nature of activities at your facility and your storm water discharges. 1-78 Attachment D Stormwater Pollution Prevention Plan CHEMTRADE 2500 Kingshighway East St. Louis, Illinois 62201 618-271-2430 SWPPP Contact(s): CHEMTRADE Plant Manager EHS Supervisor 2500 Kingshighway East St. Louis, Illinois 62201 618-271-2430 (phone) 618-271-5530 (fax) SWPPP Preparation Date: December 2017 Quality information Prepared by Checked by AECOM Revision History Revision Revision date Details Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Verified by Not Applicable Approved by Authorized Name Position Distribution List # Hard Copies PDF Required Association / Company Name i Prepared for: CHEMTRADE 2500 Kingshighway East St. Louis, Illinois 62201 Prepared by: AECOM 1001 Highlands Plaza Drive West Suite 300 St. Louis, MO 63110 aecom.com Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Copyright 2017 by AECOM All rights reserved. No part of this copyrighted work may be reproduced, distributed, or transmitted in any form or by any means without the prior written permission of AECOM. ii Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Contents SECTION 1: FACILITY DESCRIPTION AND CONTACT INFORMATION...................................................... 1 1.1 Facility Information ................................................................................................................. 1 1.2 Contact Information/Responsible Parties.................................................................................. 2 1.3 Stormwater Pollution Prevention Team .................................................................................... 2 1.4 Activities at the Facility ........................................................................................................... 3 1.5 General Location Map ............................................................................................................ 4 1.6 Site Map................................................................................................................................ 4 SECTION 2: POTENTIAL POLLUTANT SOURCES ....................................................................................... 5 2.1 Industrial Activity and Associated Pollutants ............................................................................. 5 2.2 Spills and Leaks..................................................................................................................... 7 2.3 Non-Storm water Discharges Evaluation .................................................................................. 7 2.4 Salt Storage .......................................................................................................................... 7 2.5 Sampling Data Summary ........................................................................................................ 7 SECTION 3: STORMWATER CONTROL MEASURES................................................................................... 8 3.1 Minimize Exposure................................................................................................................. 8 3.2 Good Housekeeping............................................................................................................... 8 3.3 Maintenance.......................................................................................................................... 8 3.4 Spill Prevention and Response................................................................................................ 9 3.5 Erosion and Sediment Controls ............................................................................................. 11 3.6 Management of Runoff ......................................................................................................... 11 3.7 Salt Storage Piles or Piles Containing Salt ............................................................................. 12 3.8 MSGP Sector-Specific Non-Numeric Effluent Limits ................................................................ 12 3.9 Employee Training ............................................................................................................... 12 3.10 Non-Stormwater Discharges ................................................................................................. 12 3.11 Waste, Garbage and Floatable Debris ................................................................................... 12 3.12 Dust Generation and Vehicle Tracking of Industrial Materials ................................................... 12 SECTION 4: SCHEDULES AND PROCEDURES FOR MONITORING ......................................................... 13 SECTION 5: INSPECTIONS .......................................................................................................................... 14 SECTION 6: DOCUMENTATION TO SUPPORT ELIGIBILITY CONSIDERATIONS UNDER OTHER FEDERAL LAWS ........................................................................................................................................... 15 6.1 Documentation Regarding Endangered Species. .................................................................... 15 6.2 Documentation Regarding Historic Properties......................................................................... 15 6.3 Documentation Regarding NEPA Review (if applicable) .......................................................... 15 SECTION 7: SWPPP CERTIFICATION ......................................................................................................... 16 SECTION 8: SWPPP MODIFICATIONS ........................................................................................................ 17 SWPPP ATTACHMENTS .............................................................................................................................. 18 Attachment A - General Location Map Attachment B - Site Map Attachment C - General NPDES Permit IRL00 Attachment D - Non-Storm Water Discharges Certification Attachment E - Water Pollution Control Permit Attachment F - Quarterly Visual Observation Form for Stormwater Runoff Attachment G - IEPA Annual Facility Inspection Report EPA Industrial SWPPP Template, January 13, 2009 iii Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 1: FACILITY DESCRIPTION AND CONTACT INFORMATION 1.1 Facility Information Facility Information Name of Facility: CHEMTRADE Street: 2500 Kingshighway City: East St. Louis County or Similar Subdivision: St. Clair Permit Tracking Number: ILR00 State: IL ZIP Code: 62201 (if covered under a previous permit) Latitude/Longitude Latitude: 38 38 ' 46.96 '' N Longitude: 90 05 ' 26.59'' W Method for determining latitude/longitude (check one): USGS topographic map (specify scale: ) Other (please specify): Google Earth Imagery EPA Web site GPS Is the facility located in Indian Country? Yes No If yes, name of Reservation, or if not part of a Reservation, indicate "not applicable." Is this facility considered a Federal Facility? Yes No Estimated area of industrial activity at site exposed to stormwater: 10 (acres) Discharge Information Does this facility discharge stormwater into an MS4? Yes No If yes, name of MS4 operator: NA Name(s) of water(s) that receive stormwater from your facility: Rose Creek Are any of your discharges directly into any segment of an "impaired" water? Yes No If Yes, identify name of the impaired water (and segment, if applicable): NA Identify the pollutant(s) causing the impairment: NA For pollutants identified, which do you have reason to believe will be present in your discharge? NA For pollutants identified, which have a completed TMDL? NA Do you discharge into a receiving water designated as a Tier 2 (or Tier 2.5) water? Yes No Are any of your stormwater discharges subject to effluent guidelines? Yes No If Yes, which guidelines apply? NA EPA Industrial SWPPP Template, January 13, 2009 1 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Primary SIC Code or 2-letter Activity Code: 2819 (SIC Code) Identify your applicable sector and subsector: Chemical and Allied Products: Basic Industrial Inorganic Chemicals 1.2 Contact Information/Responsible Parties Facility Operator (s): Name: CHEMTRADE Address: 2500 Kingshighway City, State, Zip Code: East St. Louis, Illinois 62201 Telephone Number: 618-271-2430 Email address: spaterson@chemtradelogistics.com Fax number: 618-271-5530 Facility Owner (s): Name: CHEMTRADE Address: 155 Gordon Baker Road City, State, Zip Code: Toronto, Ontario, Canada M2H 3N5 Telephone Number: 416-496-5856 Email address: spaterson@chemtradelogistics.com Fax number: 416-496-9414 SWPPP Contact: Name: Steve Caruso - Plant Manager Telephone number: 618-271-2430 ext. 147 Email address: scaruso@chemtradelogistics.com Fax number: 618-271-5530 1.3 Stormwater Pollution Prevention Team Staff Names Plant Manager (or designee) EHS Supervisor (or designee) Individual Responsibilities Ensure SWPPP is implemented as specified and reviewed/revised as required. Manage Environmental Health & Safety for the East St. Louis Plant as they pertain to the SWPPP Ensure SWPPP is implemented as specified and reviewed/revised as required. EPA Industrial SWPPP Template, January 13, 2009 2 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Updated April 4, 2022 Primary SIC Code or 2-letter Activity Code: 2819 Identify your applicable sector and subsector: Chemical and Allied Products: Basic Industrial Inorganic Chemicals 1.2 Contact Information/Responsible Parties Facility Operator (s): Name: CHEMTRADE Address: 2500 Kingshighway City, State, Zip Code: East St. Louis, Illinois 62201 Telephone Number: 618- 271-2430 Email address: gtonding@chemtradelogistics.com Fax number: 618-271-5530 Facility Owner (s): Name: CHEMTRADE Address: 155 Gordon Baker Road City, State, Zip Code: Toronto, Ontario, Canada M2H 3N5 Telephone Number: 416-496-5856 Email address: gtonding@chemtradelogistics.com Fax number: 416-496-9414 SWPPP Contact: Name: Rob Woolen - Site EHS Telephone number: 618-367-9130 Email address: rwoolen@chemtradelogistics.com Fax number: 618-271-5530 EPA Industrial SWPPP Template, January 13, 2009 7 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 1.4 Activities at the Facility The CHEMTRADE East St. Louis facility is approximately 153 acres in total size. Of this total area, approximately 10 acres are occupied by manufacturing processes areas, storage areas, structures, and roadways directly associated with plant operations. The General Location Map and Site Map are provided in Attachments A and B, respectively. Operations at the East St. Louis facility include the manufacture of liquid and dry alum, Polyaluminium chloride hydroxide sulphate (PAC) and Clarion. Raw materials and finished product are received and shipped from the facility by rail cars and over-the-road trucks. The liquid alum manufacturing process involves reacting sulfuric acid with aluminum hydrate in a batch digestion process. The alum liquor is then cooled, diluted to the desired concentration, and shipped by bulk tank trucks or stored in the alum warehouse as alum product. Aluminum Chloride is produced by reacting hydrochloric acid with hydrate alumina in a batch digestion process. Once the product is produced, it is then shipped out of the facility in bulk or put into an indoor storage area. The PAC process involves reacting aluminum chloride (produced as previously described) with aluminum metal. Following production the PAC is either packaged, shipped out in bulk, or stored in poly tanks. Clarion is produced by mixing liquid alum with various materials in a proprietary blend. The product is then either shipped out in bulk or placed in an indoor storage area. The plant also produces dry aluminum sulfate by producing molten alum as stated above. The molten alum is then cooled in a dry alum pan conveyor system. The solidified product is then crushed and ground prior to packaging in bags. The material is then shipped or placed in an indoor storage area. Sulfuric and hydrochloric acid are received by railcar or tank trucks and are unloaded into the appropriate storage tanks. Alumina hydrate and occasionally dry alum are received by hopper rail car and unloaded into storage silos. Numerous forklifts and other vehicles are operated at the facility during the manufacturing processes. The facility also maintains a diesel fuel tank used for the fueling of on-site vehicles and equipment. Routine maintenance of vehicles and equipment may also be performed at the facility. When not in use forklifts and other vehicles used at the facility are stored in warehouses or garages located at the facility. Raw materials and finished product are delivered to and shipped from the site by trucks or rail on a daily basis. Trucks and railroad locomotives used for the shipment of raw material or finished product are not stored permanently at the facility, however, may be onsite during unloading and loading operations. Any material spilled on the vehicle during loading/unloading is clean from the vehicle using dry methods or water as needed. Any water generated during this process flow into drains connected to the facilities process water recycling system. EPA Industrial SWPPP Template, January 13, 2009 3 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Empty, out-of-service ASTs, scrap metal, empty storage containers and pallets are also typically staged at the facility at various locations for an undetermined duration. 1.5 General Location Map A USGS topographic map showing the general location of the CHEMTRADE facility is provided in Attachment A. 1.6 Site Map The Site Map of the CHEMTRADE facility is provided in Attachment B. EPA Industrial SWPPP Template, January 13, 2009 4 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 2: POTENTIAL POLLUTANT SOURCES 2.1 Industrial Activity and Associated Pollutants The following is a list of major materials used, stored, or produced on-site that are exposed to storm water and/or have the potential to pollute storm water runoff. Locations of the materials storage is provided on the Site Map of the facility (Attachment B). Storm water management practices conducted for each of these materials are also listed in the table. Material Aluminum Sulfate Poly Aluminum Chloride Sulfuric Acid Alumina Hydrate Storage Method (Number of ASTs containing material) Outdoor ASTs (7) and associated piping Industrial Activity Storage, Material Transfer Outdoor ASTs (8) and associated piping Storage, Material Transfer Outdoor ASTs (2) and associated piping Storage, Material Transfer Outdoor AST (1) and associated piping Storage, Material Transfer Aluminum Chloride Outdoor AST (1) and associated piping Storage, Material Transfer Hydrochloric Acid Outdoor AST (1) and associated piping Storage, Material Transfer Potential for Contact with Storm Water Storm Water Management Practices Potential for spills during material transfer operations. Potential for tank leaks. Potential for spills during material transfer operations. Potential for tank leaks. Potential for spills during material transfer operations. Potential for tank leaks. Potential for spills during material transfer operations. Potential for tank leaks. Potential for spills during material transfer operations. Potential for tank leaks. Potential for spills during material transfer operations. Potential for tank leaks. Regular Inspections, Good Housekeeping, Secondary Containment Structure, Process Water Recycling System Drains Regular Inspections, Good Housekeeping, Secondary Containment Structure, Process Water Recycling System Drains Regular Inspections, Good Housekeeping, Secondary Containment Structure, Process Water Recycling System Drains Regular Inspections, Good Housekeeping, Secondary Containment Structure, Process Water Recycling System Drains Regular Inspections, Good Housekeeping, Secondary Containment Structure, Process Water Recycling System Drains Regular Inspections, Good Housekeeping, Secondary Containment Structure, Process Water Recycling System Drains EPA Industrial SWPPP Template, January 13, 2009 5 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Material Aluminum Chlorohydrate Storage Method (Number of ASTs containing material) Outdoor AST (1) and associated piping Industrial Activity Storage, Material Transfer Diesel Fuel Outdoor AST (1) and associated piping Storage, Vehicle/Equip ment Fueling Waste Oil Outdoor AST (1) and associated piping Waste Oil Storage Raw Materials and Finished Product Wood Pallets, Empty Containers, Scrap Metal, Empty ASTs, Scrap Piping UN Rated Poly Intermediate Bulk Containers (IBC) Ground Surface, Concrete Pad Storage, Materials Transfer, Loading and Unloading Operations Storage Potential for Contact with Storm Water Potential for spills during material transfer operations. Potential for tank leaks. Potential for spills during tank or equipment filling operations. Potential for tank, piping, or hose leaks. Potential for spills while loading tank or removing waste oil from tank for disposal Potential for spills during filling or leakage during movement throughout facility. Precipitation or runoff coming in direct contact with materials. Storm Water Management Practices Regular Inspections, Good Housekeeping, Secondary Containment Structure Regular Inspections, Good Housekeeping, Secondary Containment Structure, Supervision of activities while fueling equipment or filling of the AST Regular Inspections, Good Housekeeping, Secondary Containment Structure, Supervision of activities while filling the tank or removing waste oil for disposal. Secondary Containment Structures, Supervision by Facility Personnel While Totes are Being Moved Free of Contamination, Raw Material, or Finished Products, Containers Are Empty and Sealed EPA Industrial SWPPP Template, January 13, 2009 6 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 2.2 Spills and Leaks Areas of Site Where Potential Spills/Leaks Could Occur Potential Spill/Leak Locations Main Processing and Production Areas Warehouse Area Office Building and Parking Areas Diesel Fuel AST Waste Oil ASTM Tanker Truck Loading/Unloading Area Railcar Loading/Unloading Area Potentially Affected Outfalls SW001, SW002 SW001, SW002 SW001, SW002 SW001, SW002 SW001, SW002 SW001, SW002 SW001, SW002 Description of Past Spills/Leaks No significant spills or leaks outside of secondary containment systems have occurred at the CHEMTRADE facility within the past three years. 2.3 Non-Storm water Discharges Evaluation Non-storm water discharge through Outfall SW001 and Outfall SW002 not in accordance with allowable sources specified in Section A.9 of the General NPDES Permit (Attachment C) do not occur at the CHEMTRADE facility. Process wastewater and stormwater accumulating within the secondary containment systems of ASTs and loading/unloading areas is diverted into and processed by the facilities waste water recycling system and not discharged through the stormwater outfalls. Routine inspections and preventative maintenance are performed on the recycling system and secondary containment systems to ensure they are in good working order and will not allow the unpermitted discharge of non-stormwater from the facility. The Non-Storm Water Discharges Certification for the facility is provided in Attachment D. 2.4 Salt Storage Not Applicable. Salt is not stored at the CHEMTRADE facility. 2.5 Sampling Data Summary In accordance with the General NPDES Permit dated for the facility, baseline storm water samples shall be collected from Outfall SW001 quarterly for the first four quarters following the issuance of the permit. EPA Industrial SWPPP Template, January 13, 2009 7 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 3: STORMWATER CONTROL MEASURES 3.1 Minimize Exposure All storage systems at the facility are closed top and surrounded by a secondary containment system. These secondary containment systems are impervious and are designed to contain spilled or leaked materials until they can be recovered. Rainwater captured within the secondary containment systems typically evaporates. If excess rainwater or weather conditions do not facilitate evaporation of rainwater, the rainwater is pumped from the secondary containment systems into the facilities process wastewater recycling system. The recycling system consists of two 33,900 gallon holding tanks, a 66'X68'X6' recycle pond with a 60 mil HDPE geomembrane liner, and all associated pipes, pumps and appurtenances necessary to treat approximately 5,000 gpd DAF of spent process wastewater, contact storm water, and non-contact storm water with zero discharge. The Water Pollution Control Permit associated with the facilities recycling system is provided in Attachment E. In the truck and railcar unloading/loading areas, drainage systems are contained by curbing and sloped surfaces which direct flow toward grated collection basins. This water is then pumped into the facilities water recycling system. During operations there are no bulk material storage piles subjected to runoff or wind blowing. Bulk materials are stored within buildings or beneath covered areas at the facility. 3.2 Good Housekeeping Routine Good Housekeeping Inspections are performed by the Plant Manager, EHS Supervisor or their designee on a daily basis. All municipal waste, garbage, and floatable debris generated at the facility are stored in covered roll-off boxes or trash dumpsters. The dumpsters are emptied on a weekly basis by a local refuse disposal company. Waste/Used Oil is collected and removed for recycling as necessary by a licensed transporter. Hazardous waste is also removed for disposal as necessary by a licensed transporter. 3.3 Maintenance Routine daily and weekly inspections are carried out by the Plant Manager, EHS Supervisor, or designee. These routine inspections ensure no leaks or spills impact storm water from the site. The routine inspections include the following: Outdoor storage containers and piping are visually inspected for deterioration or leaks. Pumps are observed to be operational. Shut-off valves are operational and no leaks are observed. Foundation supports and containment dikes are in good condition. Secondary containment systems are free of excess storm water and debris. EPA Industrial SWPPP Template, January 13, 2009 8 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 Truck and rail car loading/unloading areas are clean and free of debris. In addition to routine inspections, regularly scheduled preventative maintenance is carried out upon storage containers, piping, secondary containment systems, pumps and other ancillary equipment as needed. Storm water conveyance systems onsite such as drains and pipes are cleaned at a minimum annually of debris and vegetation to ensure clear flow of storm water, and screens are kept clear of obstructing materials. Cleaning and maintenance is performed more frequently as conditions warrant. Preventative maintenance and repairs are tracked by CHEMTRADE's corporate Incident Management System (IMS). 3.4 Spill Prevention and Response Spill and Leak Prevention Spill kits are available across the site to contain small spills or releases. Outdoor tanks containing raw materials and finished products and ancillary piping and equipment are within secondary containment systems. Hazardous waste is kept in sealed drums and transferred off-site for disposal by a licensed transporter. Regular inspection and maintenance prevent leakage from storage containers, while best practices in careful material handling, including the use of drip pans, prevent spills during regular operations. Outdoor transfer operations of materials to or from a container, tank, vendor truck, or rail car are monitored continuously by facility personnel to ensure un-noticed leakage, overfilling, or failure of the tank or ancillary piping and equipment does occur. Small drip buckets or adsorbent pads are placed as needed at pipe connections to collect leaked liquid materials. Spill Response Procedures The following is a description of the immediate actions to be taken by facility personnel in the event of a spill or release to nearby waterways: In case of a spill, notify the EHS Supervisor and/or Plant Manager. EHS Supervisor and/or Plant Manager will give instructions to employees. In the event of a release equal to or exceeding the reportable quantity of oil, notifications will be made immediately to IEMA, LEPC, NRC, IEPA and other relevant agencies. No employees will re-enter the area until the EHS Supervisor and/or Plant Manager give the "all clear". If there has been a release or spill, the EHS Supervisor and/or Plant Manager will respond and report their findings as follows: o Immediately identify the type of release, location of spill, and actual extent of release. o Assess the interaction of the discharged substance with water and/other substances stored at the facility. EPA Industrial SWPPP Template, January 13, 2009 9 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 o Assess the interaction of the discharged substance with local surface waters, including Rose Creek. o Assess possible hazards to human health and the environment due to the release, considering both direct and indirect effects. o The Report must include: Name and telephone number of the EHS Supervisor. CHEMTRADE's address What time the release occurred What quantity was released Possible impacts on the environment During an Emergency release the EHS Supervisor and/or Plant Manager will take reasonable measures necessary so that the release does not spread. These measures include: o Set up a response operations center in the main office for directing and coordinating response operations. o Assess and implement prompt removal actions to contain and remove the substance released. Direct employees to stop the source of the discharge if possible and safe to do so. o Coordinate rescue and response actions with response personnel. o Initiate and direct immediate cleanup activities. Deploy available secondary containment measures, including sealing the facility if the leak is indoors and utilizing spill kits to prevent spills from entering waterways. o If the plant stops operation because of a release, monitor for leaks or ruptures in valves, pipes, or other equipment, wherever appropriate. Immediately after an emergency, provide for treating, storing, or disposing of recovered waste. The following is a description of the immediate actions to be taken by facility personnel in the event of a spill either inside the facility, or to the environment: Notify the EHS Supervisor and/or Plant Manager. Extinguish or eliminate sources of ignition. Turn off vehicles and machinery near the spill. Identify the material released. If the identity of the material is known, tell the EHS Supervisor and/or Plant Manager. Consult SDS documents to determine the identification and characteristics of the material. Attempt to stop the release at its source. Examples include turning off pumps, shutting valves and plugging leaks. Make sure no danger to human health exists before you take action. If there is an immediate threat such as smoke or fire, activate the fire alarm to evacuate the area. Contain the material; EPA Industrial SWPPP Template, January 13, 2009 10 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 o Use absorbent materials and create dikes using shovels and brooms o Clean up spilled material. Pump recovered material into a container Shovel used absorbent materials into open top drums. Make sure materials placed into drums are compatible. Compatibility information can be found on the SDS Close drum lids and label the drum o Decontaminate tools and equipment used in the cleanup. After cleaning tools and equipment, return them to the spill kit as appropriate. EHS Supervisor and/or Plant Manager will arrange for proper disposal of the materials. 3.5 Erosion and Sediment Controls The portion of the Site in which the manufacturing processes occur is generally flat to gently sloping towards the interior of the Site. The majority of this area is impervious to water infiltration or erosion and consists of pavement, buildings, and secondary containment structures associated with the numerous ASTs and piping found on the Site. Non-impervious areas are also flat to gently sloping and are gravel or grass covered. No ditches or swales subject to erosion are present at the facility. The flowline and sides of the ditches and swales observed at the facility are gently sloped, rip-rap armored, and not subject to erosion from stormwater runoff. 3.6 Management of Runoff Rainwater captured within the secondary containment systems typically evaporates. If excess rainwater or weather conditions do not facilitate evaporation of rainwater, the rainwater is pumped from the secondary containment systems into the facilities water recycling system In the truck and railcar unloading/loading areas, drainage systems are contained by curbing and sloped surfaces which direct flow toward grated collection basins. This water is then pumped into the facilities water recycling system. Storm water runoff from roads, parking areas, gravel/grass areas, and other non-process areas of the facility is transported by sheet flow towards drains and ditches located throughout the facility and discharged via two storm water outfalls designated Outfall SW001 and Outfall SW002 (Attachment B). Runoff from the southwest side of the plant is collected in a storm water drain. The storm water then proceeds through a buried pipe to Outfall SW001 and subsequently discharged into Rose Creek. Runoff from the north side of the plant, former sulfuric acid plant, former alum milling area, office area, and warehouse area flow into ditches which drain into a central road pump and agitator. From the pump and agitator, the storm water flows through buried pipes and is discharged via Outfall SW002 and into Rose Creek. Storm water from the south side of the facility is collected in storm water drains and ditches and subsequently flows through a buried pipe to Outfall SW002. EPA Industrial SWPPP Template, January 13, 2009 11 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 3.7 Salt Storage Piles or Piles Containing Salt Not Applicable. Salt is not stored at the CHEMTRADE facility. 3.8 MSGP Sector-Specific Non-Numeric Effluent Limits Not Applicable. MSGP Sector-Specific Effluent Limits do not apply to the CHEMTRADE facility. 3.9 Employee Training The Plant Manager is responsible for implementation of this SWPPP and shall ensure all required employee training is provided. Training is conducted on an annual basis via the CHEMTRADE computer based training system. Employees are informed of the best management practices to reduce pollutants entering the storm water, are educated in spill response procedures, and provided with examples of maintenance and housekeeping procedures to ensure a clean, safe facility exists. Employee records of completed training are maintained electronically on the CHEMTRADE computer based training program. 3.10 Non-Stormwater Discharges Recycling and reuse of process wastewater is performed by the facilities is an on-site recycling system. Process wastewater is not discharged through Outfall SW001 or Outfall SW002. 3.11 Waste, Garbage and Floatable Debris All municipal waste, garbage, and floatable debris generated at the facility is stored in covered roll-off boxes or trash dumpsters. The dumpsters are emptied on a weekly basis by a local refuse disposal company. Weekly inspections of municipal waste dumpsters and the surrounding areas are conducted to the Plant Manager, EHS Supervisor, or their designee. In addition, all employees monitor work areas and implement best management practices during daily work activities ensure waste, garbage, and floatable debris do not impact storm water. 3.12 Dust Generation and Vehicle Tracking of Industrial Materials Vehicular travel throughout the Site occurs on paved or concrete surfaces. Dust is not generated from vehicular traffic movement on the facility's paved and concrete surfaces. Following loading and off-loading operations, vehicles are inspected to ensure loose raw, final, or waste material are not present on the trucks which could be tracked offset. The driver of the truck inspects the vehicle for loose materials and completes a checklist which documents the inspection. The paperwork is given to the plant operator and is then filed with the bill of lading and processed through CHEMTRADE's shipping department. If loose materials were observed on the truck during the initial inspection, the truck is cleaned by dry or wet methods and then re-inspected. During wet cleaning only potable water without any detergent or other cleaner is used. EPA Industrial SWPPP Template, January 13, 2009 12 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 4: SCHEDULES AND PROCEDURES FOR MONITORING In accordance with the General NPDES Permit, benchmark monitoring is being performed quarterly for the first year of the General NPDES Permit. 1. Sample Location(s). Benchmark stormwater samples shall be collected from Outfall SW001. 2. Pollutant Parameters to be Sampled and Numeric Limitations Benchmark samples shall be collected quarterly for the first year of the NPDES Permit and analyzed for the following parameters. Samples shall meet the corresponding effluent numeric limits of each of the parameters. Parameter Total Aluminum Total Iron Nitrate plus Nitrite Nitrogen Numeric Limit 0.75 mg/L 1.0 mg/L 0.68 mg/L 3. Monitoring Schedules Storm water discharge Benchmark Sampling will be conducted quarterly for the first four quarters following the Effective Date of the NPDES permit, not commencing later that 180 days after the effective date of the permit. Storm water sample results from all four quarterly sampling events shall be submitted to IEPA with the annual inspection report within 60 days of the final quarter of benchmark sampling. 4. Procedures Benchmark storm water samples will be collected by the EHS Supervisor or designee Storm water samples will be collected quarterly for the first four full quarters following the Effective Date of NPDES Permit Number ILR00 for the facility. Storm water samples will be collected Outfall SW001. Storm water samples will be collected in laboratory supplied sample containers and placed in a chilled cooler for shipment or delivery to the analytical laboratory under chain of custody control. Samples shall be analyzed by Teklab Inc. located in Collinsville, Illinois. EPA Industrial SWPPP Template, January 13, 2009 13 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 5: INSPECTIONS The following inspections occur on-site: Routine Facility Inspections: Routine, visual daily and weekly inspections are carried out by the Plant Manager, EHS Supervisor, or designee. These routine inspections ensure no leaks or spills contaminate storm water from the site. The routine inspections include the following: Outdoor storage containers and piping are visually inspected for deterioration or leaks. Pumps are observed to be operational. Shut-off valves are operational and no leaks are observed. Foundation supports and containment dikes are in good condition. Secondary containment systems are free of excess storm water and debris. Truck and rail car loading/unloading areas are clean and free of debris. Any observed deficiency is immediately addressed and repairs or alterations are made as necessary. Significant repairs and alterations are tracked by CHEMTRADE's corporate Incident Management System (IMS). Quarterly Visual Observation of Discharges: Once per quarter, the EHS Supervisor or designee will visually inspect the discharge from each outfall on site for pollutants. Discharge samples will be collected less than one hour after runoff begins discharging from the facility, and will be collected from storm events greater than 0.1 inch in magnitude and at least 72 hours after the most recent storm event. The observation of each sample will document color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, and other obvious indicators of storm water pollution. If indicators of storm water pollution are noted during the visual inspection, a water sample will be taken and the outfall will be monitored for that parameter. In the event a stormwater discharging event does not occur during a quarter, certification of no stormwater discharge is required. These inspections and certifications will be recorded and stored with a copy of the SWPPP at the facility for a minimum of three years. A sample inspection report is included in Attachment F. Annual Facility Inspection: Once per year, the EHS Supervisor or designee will conduct a full site inspection and documented review of the SWPPP. This inspection will evaluate areas on site where materials and activities are exposed to storm water, structural storm water controls, and storm water outfalls. During this inspection, the inspector will confirm that the site map, potential storm water pollutant sources, outfalls, and control in place are accurately described in the SWPPP. Observations that require a response from the facility will be documented, as well as the subsequent response. Observations that require a modification of this SWPPP will also be documented. A copy of the annual inspections will be maintained with the SWPPP at the facility for a minimum of three years. In addition, the annual inspection report shall be submitted to the IEPA as stated in the General NPDES for the facility. The annual inspection report form can be found in Attachment G. EPA Industrial SWPPP Template, January 13, 2009 14 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 6: DOCUMENTATION TO SUPPORT ELIGIBILITY CONSIDERATIONS UNDER OTHER FEDERAL LAWS 6.1 Documentation Regarding Endangered Species. Not applicable. 6.2 Documentation Regarding Historic Properties Not applicable. 6.3 Documentation Regarding NEPA Review (if applicable) Not applicable. EPA Industrial SWPPP Template, January 13, 2009 15 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 7: SWPPP CERTIFICATION I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name: Signature: Title: Date: EPA Industrial SWPPP Template, January 13, 2009 16 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SECTION 8: SWPPP MODIFICATIONS This plan shall be amended whenever there is a change in construction, operation, or maintenance which may affect the discharge of significant quantities of pollutant to the waters of Illinois or if a facility inspection indicates that an amendment is needed. If CHEMTRADE is notified by the IEPA that the plan does not meet the requirements of the NPDES permit, CHEMTRADE shall make changes and submit the revised plan to the Agency. Amendments will be made within 30 days of construction or operational changes at the facility related to storm water management or of receiving notification from IEPA requesting revisions, and will be submitted to the IEPA. A record of amendments to this plan can be found under the Revision History Section of Page i. EPA Industrial SWPPP Template, January 13, 2009 17 Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 SWPPP ATTACHMENTS Attachment A - General Location Map Attachment B - Site Map Attachment C - General NPDES Permit IRL00 Attachment D - Non-Storm Water Discharges Certification Attachment E - Water Pollution Control Permit Attachment F - Quarterly Visual Observation Form for Stormwater Runoff Attachment G - IEPA Annual Facility Inspection Report EPA Industrial SWPPP Template, January 13, 2009 Attachment A Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 Wa s te o il AST - No t in S e r v ic e D ie s e l fu e l A S T S cr a p m a te r ia ls , du m p s te rs , pa l le ts O u tf a l 0 1 in le t O u tf a l 0 0 1 S u lfu r ic A ci d A S T s S to r m w a t er in le t A lu m i n u m S u lfa t e A S T s A lu m i n a H y dr a te AST A lu m i n u m C h lo ri d e AST H y dr o c h lo r ic A ci d A S T R a ilc a r l oa d i n g /u n lo a d in g a re a O u tf a l 0 2 in le t P o ly A l u m in u m C h lo ri d e A S T s P o ly A l u m in u m C h lo ri d e A S T O u tf a l 0 0 2 F or m e r m a te r ia ls st o ra g e pa d A S T R e m o ve d 1 inch = 2,000 feet 0 1,000 2,000 4,000 Feet 1001 Highlands Plaza Dr. Suite300 St. Louis, MO 63110 Property Boundary DRAWN BY: Service Layer Credits: Copyright: 2011 National Geographic Society, i-cubed IJP Document Path: P:\Projects\Systems\GIS_Projects\Chemtrade\Fall_2017\MXD\Site_Location_Map.mxd Site Location Map Fall 2017 Chemtrade Solutions, LLC 2500 Kingshighway Fairmont City, Illinois DATE: 11/2/2017 PROJECT NUMBER: 60538642 FIGURE 1 Attachment B Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 1001 Highlands Plaza Dr. Suite300 St. Louis, MO 63110 m Stormwater Drain m Water Recycling System Drain po Stormwater Outfall "! AST (Not present at time of photo) Stormwater Flow Direction Document Path: P:\Projects\Systems\GIS_Projects\Chemtrade\Fall_2017\MXD\SWPPP.mxd Service Layer Credits: 2017 DigitalGlobe CNES (2017) Distribution Airbus DS 2017 HERE 2017 Microsoft Corporation DRAWN BY: IJP 1 inch = 100 feet 0 50 100 200 Feet Site Features Map Fall 2017 Chemtrade Solutions, LLC 2500 Kingshighway Fairmont City, Illinois DATE: 12/5/2017 PROJECT NUMBER: 60538642 FIGURE 2 Attachment C Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 Attachment D Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 NON-STORM WATER DISCHARGES CERTIFICATION Inspections are conducted annually at the CHEMTRADE facility to confirm that non-allowable, non-storm water flows are entering into the storm water discharge system. Date of evaluation: __________________ Description of the evaluation criteria used: A visual inspection was conducted of facility storm water and non-storm water discharges, site storm water management systems, and operational areas and activities potentially exposed to precipitation. Each outfall was tracked to its source to ensure that non-storm water discharge was not entering the outfall. List of the outfalls or onsite drainage points that were directly observed during the evaluation: o SW001 Outfall into Rose Creek o SW002 Outfall into Rose Creek Allowable types of non-storm water discharge(s) and source locations: The following non-storm water discharges were noted during the annual inspection and considered allowable non-storm water discharges under the General NDPES Permit No. IRL00 condition (A)(9)(a): o o o o In addition to the above evaluation, ongoing monitoring efforts occur to ensure non-storm water discharges do not enter the storm water stream. Outflows are visually inspected annually for visible sheens or evidence of chemicals or other materials in the storm water flow. Excess storm water collected on-site in secondary containment structures is pumped into the facilities waste water recycling system. I certify based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. Name: Title: Signature: Date: Attachment E Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 Attachment F Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 Attachment G Stormwater Pollution Prevention Plan (SWPPP) CHEMTRADE, December, 2017 EPA Industrial SWPPP Template, January 13, 2009 Attachment E f Attachment F