Document nmkrxkq0p5O6by44zX48bD4Vw

CWA COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: Compliance Evaluation Inspection Facility: National Maintenance & Repair Incorporated 401 South Hawthorn Street Hartford, Illinois 62048 Madison County 38.83049250658026, -90.10714556993825 Mailing Address: National Maintenance & Repair Incorporated P.O. Box 38 Hartford, Illinois 62048 NPDES ICIS Tracking Number: IL0068055 and ILP000420 Date of Inspection: March 23, 2023 EPA Representatives: Benjamin Atkinson, Inspector, 312-353-8243 atkinson.ben@epa.gov Cheryl Burdett, Inspector, 312-886-1463 burdett.cheryl@epa.gov State Representatives: None Facility Representatives: Jeff Poston, General Manager, 618-334-0273 jposton@nmrinc.com Rick Naugle, Hull Manager, 618-225-2614 rnaugle@nmrinc.com Travis Flowers, Gas Free Manager, 618-610-7048 TFlowers@nmrinc.com Nate Brooks, Environmental Consultant, 618-372-3740 NateBrooks@EnviroLifeConsulting.com Atkinson, Benjamin Date: 2023.05.26 19:05:54 -05'00' Digitally signed by Atkinson, Benjamin Inspector Signature: ____________________________________________________ Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor, Water Enforcement and Compliance Assurance Branch RYAN BAHR Digitally signed by RYAN BAHR Date: 2023.05.30 12:59:52 -05'00' Approver Signature and Date: ____________________________________________ 1 National Maintenance & Repair March 23, 2023 1. BACKGROUND The purpose of this report is to describe, evaluate and document the National Maintenance & Repair Incorporated facility's (the Facility) compliance with the Clean Water Act (CWA). This inspection was performed pursuant to Section 308(a) of the Federal Water Pollution Control Act, as amended. The Facility is a shipyard and repair operation which provides marine and rail repair services. The Facility falls under SIC codes 3731 - Shipbuilding & Repairing and 4491 - Marine Cargo Handling. The Facility is comprised of both water borne and land-based facilities. The Facility discharges sanitary and pretreated wastewater to a gravity sewer in Hartford, IL which ultimately discharges to the City of Wood River Wastewater Treatment Plant. The discharge to the sewer includes wastes collected at the Gas Free Plant which undergo pretreatment prior to discharge to the sewer. The Facility's Gas Free Plant cleans tank barges which have been used to transport chemical or petroleum cargos. Discharges from the Gas Free Plant fall under the requirements of 40 CFR Part 422 Subpart C - Tank Barges and Ocean/Sea Tankers Transporting Chemical and Petroleum Cargos. The Facility has a State of Illinois permit (Permit No. 2020-EP-65303) to operate the pretreatment system at the Gas Free Plant. Permit No. 2020-EP-65303 was issued July 1, 2020 and expires May 31, 2025. The Facility has coverage under NPDES Permit No. IL0068055 (the Permit) which authorizes discharges at three outfall locations. The three outfalls all discharge to the Mississippi River. Outfalls 001 and 002 are stormwater outfalls. Outfall 003 is barge list water (water used at the Gas Free Plant to fill a barge's forward or aft void compartments to cause the vessel to list there by aiding the wash operations). The Permit was issued and became effective March 10, 2017 and had an expiration date of February 28, 2022. The Facility has submitted their reapplication and are requesting alternative Total Suspended Solids effluent limits for Outfall 003. 2. Facility Information The Facility provides marine and rail repair services. These services include: barge/towboat repairs; new construction and refurbishment; drydocks; outdoor sandblasting and painting; engine sales, installation, and repairs; steering system and cylinder repairs; propeller repairs; metal fabrications, shaft and rudder repair; gas free certifications; fuel sales and service; and electrical repairs. including floating cranes, a machine shop, a fabrication shop, a propeller shop, an engine shop, parts warehouse, outdoor storage yard, and the Gas Free Plant. The Facility has approximately 125 employees. The main shipyard operates 24/6 Monday - Saturday. The Gas Free Plant operates two shifts (7:00 AM - 3:30 PM and 3:30 PM - 12:00 AM). The Facility sits on approximately 18 acres. Approximately 10 acres of the site, containing the Machine Shop, Warehouse, Engine Shop, Propeller Shop, Yard Storage, and Component Rebuild, are surrounded by a levee. The stormwater from the area within the levee is collected at two points and manually pumped to Outfalls 001 and 002. Mr. Nate Brooks of EnviroLife Consulting LLC conducts the quarterly visual observations of the discharges and annual facility inspection associated with the Permit. The Facility personnel noted that they had experienced recuring problems meeting limits at Outfall 003. The Facility personnel stated that the background levels of pollutants in the intake water from the Mississippi exceeded their discharge limits and that, as a result of settling, the discharged water often contained lower levels of pollutants than when pumped into the barge voids. Table 1, below, shows effluent exceedances associated with Outfall 003 for the period of October 2018 - March 2023. For that period, there were 36 reported exceedances. 2 National Maintenance & Repair March 23, 2023 Table 1. Effluent Exceedances at Outfall 003 Parameter Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total [as Fe] Solids, total suspended Solids, total suspended Iron, total [as Fe] Solids, total suspended Solids, total suspended Iron, total [as Fe] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total [as Fe] Solids, total suspended Solids, total suspended Solids, total suspended Iron, total [as Fe] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total [as Fe] Solids, total suspended Solids, total suspended Iron, total [as Fe] Limit Units 15 mg/L 30 mg/L 15 mg/L 30 mg/L 2 mg/L 15 mg/L 30 mg/L 2 mg/L 15 mg/L 30 mg/L 2 mg/L 30 mg/L 15 mg/L 30 mg/L 15 mg/L 30 mg/L 15 mg/L 15 mg/L 30 mg/L 15 mg/L 2 mg/L 15 mg/L 30 mg/L 15 mg/L 2 mg/L 15 mg/L 15 mg/L 15 mg/L 15 mg/L 15 mg/L 30 mg/L 15 mg/L 2 mg/L 30 mg/L 15 mg/L 2 mg/L Limit Type 30DA AVG DAILY MX 30DA AVG DAILY MX 30DA AVG 30DA AVG DAILY MX 30DA AVG 30DA AVG DAILY MX 30DA AVG DAILY MX 30DA AVG DAILY MX 30DA AVG DAILY MX 30DA AVG 30DA AVG DAILY MX 30DA AVG 30DA AVG 30DA AVG DAILY MX 30DA AVG 30DA AVG 30DA AVG 30DA AVG 30DA AVG 30DA AVG 30DA AVG DAILY MX 30DA AVG 30DA AVG DAILY MX 30DA AVG 30DA AVG Monitoring Month 11/30/2018 11/30/2018 12/31/2018 12/31/2018 12/31/2018 1/31/2019 1/31/2019 1/31/2019 2/28/2019 2/28/2019 2/28/2019 11/30/2019 11/30/2019 2/29/2020 2/29/2020 3/31/2020 3/31/2020 8/31/2020 9/30/2020 9/30/2020 9/30/2020 4/30/2021 5/31/2021 5/31/2021 5/31/2021 12/31/2021 3/31/2022 5/31/2022 6/30/2022 9/30/2022 2/28/2023 2/28/2023 2/28/2023 3/31/2023 3/31/2023 3/31/2023 DMR Value 39 39 45 45 2.4 32 32 2.07 52 52 3.24 39 39 40 40 32 32 28 49 49 2.08 21 41 41 2.12 17 24 27 30 16 64 64 3.42 38 38 2.36 Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L % Exceedance 160 30 200 50 20 113 7 4 247 73 62 30 160 33 167 7 113 87 63 227 4 40 37 173 6 13 60 80 100 7 113 327 71 27 153 18 3 National Maintenance & Repair March 23, 2023 The pretreatment system at the Gas Free Plant consists of a series of six settling/oil separation barge compartments (total capacity of 403,200 gallons), a 5,000 gallon surge' tank with belt skimmer, a three compartment chemical reaction unit, a 6 ft. diameter by 7.5 ft. deep recycle pressurization dissolved air flotation unit, a 300 gallon sludge conditioning tank, a 500 gallon sludge holding tank, a 10 cubic ft. plate type filter press, a 60 gallon pH adjust tank, and a 30,000 gpd DAF (43,000 gpd DMF). At the time of the inspection, the plate filter press was non-operational. Oil recovered during the barge cleaning operations is either burned in the Facility's boiler or sold as waste oil. Chemicals used in the pretreatment system include: Caustic - BULAB 959, 3 Ach - BULAB 5091, Sulfuric acid, Nitrogen, Microbe PLUS, Polymer - BULAB 5545, Ach - WC 368, and Phosphorus. Mr. Purrander "Pete" Cornwell (the Operator) is the pretreatment plant operator and has a Class K Wastewater Treatment Works Operator certification. The Operator collects samples in accordance with the Illinois EPA Water Pollution Control Permit. Samples are picked up and analyzed by Tek Lab of Collinsville. The Operator stated that the pH reported in the monthly monitoring reports was the pH measured by the lab. At the time of the Inspection, no baseline report as required by 40 CFR 403.12 was known to have been submitted to the US EPA, the Control Authority. Monthly monitoring reports, as required by the Illinois EPA Water Pollution Control Permit, are submitted by the Facility to IEPA, Village of Hartford, and the City of Wood River. The Illinois EPA Water Pollution Control Permit also requires submittal of those monthly monitoring reports to the US EPA; however, the Facility has not included US EPA on those submittals. At the time of the Inspection, no Periodic Reports on Continued Compliance as required by 40 CFR 403.12(e) are known to have been submitted to the Control Authority. At the time of the Inspection, the Facility was not aware of any exceedances of pretreatment limits in the previous two years. The Facility additionally has an Air Permit IL000119801AAE and is a large quantity Hazardous Waste Generator. Hazardous Waste is collected and disposed of by Safety Kleen. There is a pond within the levee which is Owned by Nicor National and is an archived superfund site. 3.1 Facility Inspection - Interview EPA Inspectors Ben Atkinson and Cheryl Burdett (the Inspectors) arrived at the Facility at approximately 11:50 AM. The Inspectors were met by Mr Jeff Poston and Mr Rick Naugle and led to a conference room. The Inspectors introduced themselves, presented their credentials, and explained the purpose of the inspection. Following introductions, the Inspectors explained that they would like to begin with the interview portion of the inspection followed by a walkthrough of the Facility including the pretreatment operation. The Inspectors also notified the Facility of their ability to claim information as Confidential Business Information (CBI). No information was claimed as CBI at that time. The Inspectors began by asking for general Facility information including address, NICS/SIC codes, pre-treatment permit information, number of employees, and operating schedule, and a brief explanation of the industrial activity that took place on-site. This information is included in the previous sections. The Inspectors were joined by Mr. Travis Flowers. The Inspectors asked the facility to provide an explanation of the pretreatment operations at the Facility. The information provided is included in the previous section. 4 National Maintenance & Repair March 23, 2023 3.2 Facility Inspection - Walkthrough Following the Interview portion of the inspection, the Inspectors left the site to obtain the required PPE and returned. The Inspectors began the walkthrough of the Facility at the Gas Free Plant. The Inspectors walked across the walkway bridge to the Pretreatment Barge and observed the oil/water separation and storage barges at the Gas Free Plant (photos 1 and 2). The Inspectors then walked into the Pretreatment Building on the Pretreatment Barge and observed the pretreatment system including the Surge Tank (photos 3 and 4). An outboard motor was observed on the side of the Surge Tank. Facility Personnel stated this was not part of treatment. The Inspectors then observed the three-part Reaction Tank, Disolved Air Flotation unit, and pH adjustment tanks (photos 5-9). The Inspectors observed the composite sampler used to collect BOD and COD samples required by the Illinois EPA Water Pollution Control Permit (photo 10). The Inspectors then walked around and observed the other side of the threepart Reaction Tank and Disolved Air Flotation Tank (photo 11). The Inspectors then observed the control panel and flow meter panel along the wall (photo 12). The Operator then showed the Inspectors his Wastewater Treatment Works Operator Certificate (photo 14). The Inspectors then observed the barrels of coagulant, caustic, and acid used in treatment (photos 15 and 16). The Inspectors then walked to the north end of the Gas Free Plant and observed the hoses used to pump the list water into and out of the barges being serviced (Outfall 003) (photos 17-19). While walking back south across the oil/water separation barges, the Inspectors observed a pool of green liquid on the deck of one of the barges (photo 20). The Inspectors asked what the pool of green liquid was and the facility personnel stated that they didn't know what it was, that is was unusual, and that it would be cleaned up soon. The Inspectors walked back south to the Pretreatment Barge and observed storage totes holding sludge from the Disolved Air Flotation unit waiting to be hauled away (photos 26, 27, and 29). The Inspectors also observed multiple barrels of caustic to be used for pH adjustment in the pretreatment process. The Operator stated that adjustments in the operation of the pretreatment system resulted in a reduced need for the caustic resulting in a surplus supply. The Inspectors walked back to shore and drove back to the north side of the facility and recommenced the inspection within the levee. The Inspectors observed the area in the southeast of the levee where waste storage is located. The Inspectors when walked to the collection point for Outfall 002 (photos 3133). The Inspectors then walked north and observed the Yard Storage area (photo 34). The Inspectors continued north and observed a Frac tank which is used to store liquid waste from the Engine Shop (photo 35). The Inspectors observed an area where runoff from the storage area is collected and pumped to the Frac tank (photos 36-42). The Inspectors continued north and west and observed the collection pit for Outfall 001 at the loading dock (photos 43- 45). The Inspectors then walked north over the levee and observed where Outfall 001 outlets to the gravel lot north of the levee (photos 46 and 47). The Inspectors then walked southwest and observed the outlet of Outfall 002 along the east bank of the Mississippi River (photos 48 and 49). The Inspectors then returned to the conference room and prepared for the closing conference. 5 National Maintenance & Repair March 23, 2023 5. Closing Conference The Inspectors held a closing conference during which they requested the following documents and information. 1) SIC Code 2) List of chemicals used in pretreatment 3) Flow diagram of pretreatment process 4) The last six months of monthly monitoring data for the pretreatment program 5) A copy of the Industrial stormwater permit 6) A copy of the SWPPP 7) The last six months of inspection/sampling related to Industrial Stormwater 8) A copy of the baseline report as described in 40 CFR 403.12 if one had been previously submitted. The Facility Personnel stated that they would make the documents electronically available. The requested information was provided by email on April 6, 2023. No baseline monitoring report was known by the Facility to have been submitted, The Facility did submit the Raw Wastewater Analysis - 2020, Treated Wastewater Analysis - 2020, and Wastewater Pollution Control Permit -2022 ANNUAL report as additional information. The Inspectors then shared the following areas of the concern identified during the Inspection: 1) It was noted that the Illinois EPA Water Pollution Control Permit required pH to be sampled in accordance with 40 CFR 136 methods and that those methods dictate a 15-minute holding time for pH samples. To the extent that reported values are provided by lab, the samples were likely not meeting that holding time. 2) The Baseline Monitoring Report and Periodic Reports on Continued Compliance as required by 40 CFR 403.12 were not submitted to U.S.EPA. Following the review of the submitted documents, EPA has identified the following additional areas of concern: 1) The exceedances of Total Suspended Solids from Outfall 003. 2) The exceedances of Iron from Outfall 003. 3) NPDES Permit IL0068055 Special Condition 8 E 1 requires "A topographic map extending one-quarter mile beyond the property boundaries of the facility, showing: the facility, surface water bodies, wells (including injection wells), seepage pits, infiltration ponds, and the discharge points where the facility's storm water discharges to a municipal storm drain system or other water body." No topographic map was observed in the Stormwater Pollution Prevention Plan. 4) NPDES Permit IL0068055 Special Condition 8 E 6 requires "A summary of existing sampling data describing pollutants in storm water discharges." No such summary was found in the Stormwater Pollution Prevention Plan. 5) The green liquid observed on the deck of the oil/water separation barge (photo 20) may have the potential to discharge pollutants to the Mississippi river. 6 National Maintenance & Repair March 23, 2023 List of appendices: Appendix 1 - Aerial Map Appendix 2 - Photo Log Appendix 3 - Pretreatment System Diagram and Operation Procedures Appendix 4 - Most Recent 6 Months of Pretreatment Monthly Monitoring Reports Appendix 5 - Most Recent 6 Months of NDPES Permit DMRs Appendix 6 - Quarterly Stormwater Outfall Observation for 2022 4th Qtr. and 2023 1st Qtr. Appendix 7 - NPDES Permit IL0068055 Appendix 8 - SWPPP Appendix 9 - Illinois EPA Water Pollution Control Permit Appendix 10 - Raw Wastewater Analysis - 2020 Appendix 11 - Treated Wastewater Analysis - 2020 Appendix 12 -- Wastewater Pollution Control Permit -2022 Annual Priority Pollutants Report Appendix 13 - 2023 Annual Stormwater Report 7 Appendix 1 Appendix 2 National Maintenance & Repair, Inc. EPA Inspection March 23, 2023 All photos taken by Ben Atkinson, Enforcement Officer, U.S. EPA Camera: PENTAX Optio WG-1 GPS 1: IMGP0012 Description: Looking north along the oil/water separation and storage barges at the Gas Free Plant. Location: North end of the Pretreatment Barge at the Gas Free Plant. Camera Direction: North Date/Time: March 23, 2023 2:54 PM 2: IMGP0013 Description: Looking north along the oil/water separation and storage barges at the Gas Free Plant. Location: North end of the Pretreatment Barge at the Gas Free Plant. Camera Direction: North Date/Time: March 23, 2023 2:54 PM Page 1 National Maintenance & Repair March 23, 2023 3: IMGP0014 Description: Surge Tank in Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge. Camera Direction: South Date/Time: March 23, 2023 2:57 PM 4: IMGP0015 Description: Surge Tank in Pretreatment Barge at the Gas Free Plant. Note the outboard motor hanging on the side of the Surge Tank. Facility Personnel stated that this was not part of the treatment. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: South Date/Time: March 23, 2023 2:57 PM Page 2 National Maintenance & Repair March 23, 2023 5: IMGP0016 Description: Three part Reaction Tank in the Pretreatmet Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: East Date/Time: March 23, 2023 2:58 PM 6: IMGP0017 Description: Three part Reaction Tank in the Pretreatmet Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: East Date/Time: March 23, 2023 2:58 PM Page 3 National Maintenance & Repair March 23, 2023 7: IMGP0018 Description: Disolved Air Flotation Tank in the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: East Date/Time: March 23, 2023 2:58 PM 8: IMGP0019 Description: Disolved Air Flotation Tank in the Pretreatment Barge at the Gas Free Plant (blue tank), pH Adjustment Tank (near), and Sludge Conditioning Tank (behind pH Adjustment Tank). Location: Pretreatment Barge at Gas Free Plant. Camera Direction: Northeast Date/Time: March 23, 2023 2:59 PM Page 4 National Maintenance & Repair March 23, 2023 9: IMGP0020 Description: Disolved Air Flotation Tank in the Pretreatment Barge at the Gas Free Plant (blue tank), pH Adjustment Tank (near), and Sludge Conditioning Tank (behind pH Adjustment Tank). Location: Pretreatment Barge at Gas Free Plant. Camera Direction: Northeast Date/Time: March 23, 2023 3:00 PM 10: IMGP0021 Description: Composite Sampler located in the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at Gas Free Plant. Camera Direction: West Date/Time: March 23, 2023 3:01 PM Page 5 National Maintenance & Repair March 23, 2023 11: IMGP0022 Description: Three part Reaction Tank (left) and Disolved Air Flotation Tank (right) located in the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at Gas Free Plant. Camera Direction: Northwest Date/Time: March 23, 2023 3:03 PM 12: IMGP0023 Description: Control panel and flow meter along the west wall of the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at Gas Free Plant. Camera Direction: West Date/Time: March 23, 2023 3:03 PM Page 6 National Maintenance & Repair March 23, 2023 13: IMGP0024 Description: Piping connecting tanks in the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: South Date/Time: March 23, 2023 3:04 PM 14: IMGP0025 Description: Industrial Pretreatment Operator Certificate. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: Southeast Date/Time: March 23, 2023 3:12 PM Page 7 National Maintenance & Repair March 23, 2023 15: IMGP0026 Description: Coagulant, caustic, and acid drums supplying chemical feeds for treatment to the pretreatment process in the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: West Date/Time: March 23, 2023 3:18 PM 16: IMGP0027 Description: Coagulant, caustic, and acid drums supplying chemical feeds for treatment to the pretreatment process in the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: West Date/Time: March 23, 2023 3:18 PM Page 8 National Maintenance & Repair March 23, 2023 17: IMGP0028 Description: Garbarge collection bin at the north end of the Gas Free Plant barges. Location: North End of the Gas Free Plant Barges. Camera Direction: North Date/Time: March 23, 2023 3:23 PM 18: IMGP0029 Description: Outfall 003. Hoses at the north end of the Gas Free Plant barges. These hoses are used to fill the the void compartments of barges to cause the vessel to list. Following the washing operation, the list water is pumped from the void compartment back to the Mississippi River. Location: North end of the Gas Free Plant. Camera Direction: East Date/Time: March 23, 2023 3:24 PM Page 9 National Maintenance & Repair March 23, 2023 19: IMGP0030 Description: Outfall 003. Hoses at the north end of the Gas Free Plant barges. These hoses are used to fill the the void compartments of barges to cause the vessel to list. Following the washing operation, the list water is pumped from the void compartment back to the Mississippi River. Location: North end of the Gas Free Plant. Camera Direction: East Date/Time: March 23, 2023 3:27 PM 20: IMGP0031 Description: A green liquid was observed on the deck of one of the oil/water separation barges. Location: Oil/water seperation barge at the Gas Free Plant. Camera Direction: East Date/Time: March 23, 2023 3:30 PM Page 10 National Maintenance & Repair March 23, 2023 21: IMGP0032 Description: Mistake Photo Location: Camera Direction: Date/Time: March 23, 2023 3:31 PM 22: IMGP0033 Description: Looking north along the oil/water separation and storage barges at the Gas Free Plant. Location: Oil/water separation barge at the Gas Free Plant. Camera Direction: North Date/Time: March 23, 2023 3:32 PM Page 11 National Maintenance & Repair March 23, 2023 23: IMGP0034 Description: Looking north along the oil/water separation and storage barges at the Gas Free Plant. Location: Oil/water separation barge at the Gas Free Plant. Camera Direction: North Date/Time: March 23, 2023 3:32 PM 24: IMGP0035 Description: Stormwater collection drain on surface of oil/water seperation barge at the Gas Free Plant. Location: oil/water sepertion barge at the Gas Free Plant. Camera Direction: Down Date/Time: March 23, 2023 3:33 PM Page 12 National Maintenance & Repair March 23, 2023 27: IMGP0038 Description: Totes filled with sludge from the Dissolved Air Flotation unit waiting to be hauled away. Location: Outside the Pretreatment Barge at the Gas Free Plant. Camera Direction: West Date/Time: March 23, 2023 3:35 PM 28: IMGP0039 Description: Barrels of caustic intended to be used to adjust pH in the pretreatment operation. operation of the system reduced the volume of caustic needed resulting is a surplus supply. Location: Outside the Pretreatment Barge at the Gas Free Plant. Camera Direction: West Date/Time: March 23, 2023 3:36 PM Changes in Page 14 National Maintenance & Repair March 23, 2023 29: IMGP0040 Description: Entrance to the pretreatment building on the Pretreatment Barge. Location: Pretreatment Barge at Gas Free Plant. Camera Direction: Southwest Date/Time: March 23, 2023 3:38 PM 30: IMGP0041 Description: Walkway to the Pretreatment Barge at the Gas Free Plant. Location: Pretreatment Barge at the Gas Free Plant. Camera Direction: Southeast Date/Time: March 23, 2023 3:38 PM Page 15 National Maintenance & Repair March 23, 2023 31: IMGP0042 Description: Stormwater collection pit and pump for Outfall 002. Location: Stormwater collection pit south of the Propeller Shop. Camera Direction: Southwest Date/Time: March 23, 2023 3:54 PM 32: IMGP0043 Description: Stormwater collection pit and pump for Outfall 002. Location: Stormwater collection pit south of the Propeller Shop. Camera Direction: South Date/Time: March 23, 2023 3:54 PM Page 16 National Maintenance & Repair March 23, 2023 33: IMGP0044 Description: Stormwater collection pipe inlet south of Yard Storage area. Location: South of Yard Storage area. Camera Direction: South Date/Time: March 23, 2023 3:55 PM 34: IMGP0045 Description: Looking North at Yard Storage area east of Propeller Shop. Location: North of Stormwater collection pit. Camera Direction: North Date/Time: March 23, 2023 3:57 PM Page 17 National Maintenance & Repair March 23, 2023 35: IMGP0046 Description: Frac tank which is used as liquid waste storage for the Engine Shop. This area has mutlipe fuel storage tanks and waste tanks. Runoff from this area would flow to the collection pit with is pumped to the Frac Tank. The Frac Tank is emptied as needed to the Gas Free Plant for treatment. Location: South of the Engine Shop. Camera Direction: West Date/Time: March 23, 2023 3:59 PM 36: IMGP0047 Description: Collection pit for runoff from this area which is pumped to the Frac Tank and does not discharge to the site's stormwater outfalls. Location: South of the Engine Shop. Camera Direction: South Date/Time: March 23, 2023 4:01 PM Page 18 National Maintenance & Repair March 23, 2023 37: IMGP0048 Description: Collection pit for runoff from this area which is pumped to the Frac Tank and does not discharge to the site's stormwater outfalls. Location: South of the Engine Shop. Camera Direction: Southwest Date/Time: March 23, 2023 4:01 PM 38: IMGP0049 Description: Drain which collects runoff and conveys it to the collection pit for pumping to the Frac Tank. Location: South of the Engine Shop. Camera Direction: Down Date/Time: March 23, 2023 4:02 PM Page 19 National Maintenance & Repair March 23, 2023 39: IMGP0050 Description: Waste stroage drums stored in area where runoff is collected and pumped to frac tank. Location: South of the Engine Shop. Camera Direction: South Date/Time: March 23, 2023 4:02 PM 40: IMGP0051 Description: Waste stroage drums stored in area where runoff is collected and pumped to frac tank. Location: South of the Engine Shop. Camera Direction: South Date/Time: March 23, 2023 4:02 PM Page 20 National Maintenance & Repair March 23, 2023 41: IMGP0052 Description: Secondary containment around fuel barrels. EPA observed that the red hose protruding over the edge of the secondary containment led down to the collection pit which is pumped to the frac tank. The hose was observed to not be conveying any liquid at the time of the inspection. Location: South of the Engine Shop. Camera Direction: West Date/Time: March 23, 2023 4:03 PM 42: IMGP0053 Description: Secondary containment around fuel barrels stored in area where runoff is collected and pumped to frac tank. Location: South of the Engine Shop. Camera Direction: Southeast Date/Time: March 23, 2023 4:04 PM Page 21 National Maintenance & Repair March 23, 2023 43: IMGP0054 Description: Collection grate for Outfall 001 located in the loading dock. Location: North side of the Machine Shop, within the levee perimeter. Camera Direction: Down Date/Time: March 23, 2023 4:07 PM 44: IMGP0055 Description: Collection grate for Outfall 001 located in the loading dock. Location: North side of the Machine Shop, within the levee perimeter. Camera Direction: Southwest Date/Time: March 23, 2023 4:07 PM Page 22 National Maintenance & Repair March 23, 2023 45: IMGP0056 Description: Manhole cover over the collection pit for Outfall 001. Location: North side of the Machine Shop, within the levee perimeter. Camera Direction: Down Date/Time: March 23, 2023 4:08 PM 46: IMGP0057 Description: Outfall 001 located north of the Machine shop outside the levee perimeter. to the gravel parking lot. Location: Outside the levee perimeter north of the Machine Shop. Camera Direction: South Date/Time: March 23, 2023 4:11 PM Outfall 001 discharges Page 23 National Maintenance & Repair March 23, 2023 47: IMGP0058 Description: Looking southeast from along the northern levee perimeter from Outfall 001. Location: Outside the levee perimeter north of the Machine Shop. Camera Direction: Southeast Date/Time: March 23, 2023 4:11 PM 48: IMGP0059 Description: Outfall 002 which discharges to the Mississippi River just north of the Office Building. Location: East bank of the Mississippi River north of the Office Building. Camera Direction: Southwest Date/Time: March 23, 2023 4:15 PM Page 24 National Maintenance & Repair March 23, 2023 49: IMGP0060 Description: Outfall 002 which discharges to the Mississippi River just north of the Office Building. Location: East bank of the Mississippi River north of the Office Building. Camera Direction: South Date/Time: March 23, 2023 4:15 PM Page 25 National Maintenance & Repair March 23, 2023 Appendix 3 Appendix 4 Chemical Analysis for: Water Pollution Control Permit Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. September Month Grab Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): pH: TSS: Mercury: Cadmium: Chromium: Copper: Lead: Nickel: Zinc: 1-methylphenanthrene: Bis(2-ethylhexyl)phthalate: Sample Collected: <6 mg/L <6 mg/L 9.53 15 mg/L <0.00020 mg/L <0.0020 mg/L <0.0050 mg/L <0.0050 mg/L <0.0150 mg/L 0.0493 mg/L 0.0302 mg/L ND<0.030 mg/L ND<0.038 mg/L 8-Hour Composite Sample Analysis: COD: BOD: Sample Collected: 280 mg/L 67 mg/L Mid-Month Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): Sample Collected: --- mg/L <6 mg/L 2022 Year 09/20/22 Date 09/20/22 Date 09/12/22 Date MONTHLY REPORT Page 2 of 3 Monthly report for: Number of Vessels Cleaned: Water Pollution Control Permit Report Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. September Month 13 2022 Year Commodities Contained in Vessels: 1. Lube Oil 2. Slop Oil 3. Diesel Fuel 4. Xylenes 5. Gasoline 6. 7. 8. 9. 10. Wastewater Analysis Completed by: Days Discharging Treated Wastewater to Sewer: Total Amount of Treated Wastewater: Total Average per Day: Teklab, Inc. (Colinsville, IL) 13 228,198 17,554 days gallons gallons Prepared for: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 MONTHLY REPORT Prepared by: 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Page 3 of 3 Chemical Analysis for: Water Pollution Control Permit Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. October Month Grab Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): pH: TSS: Mercury: Cadmium: Chromium: Copper: Lead: Nickel: Zinc: 1-methylphenanthrene: Bis(2-ethylhexyl)phthalate: Sample Collected: <6 mg/L <6 mg/L 6.89 21 mg/L <0.00020 mg/L <0.0020 mg/L <0.0050 mg/L <0.0050 mg/L <0.0150 mg/L 0.0553 mg/L 0.0632 mg/L ND<0.030 mg/L ND<0.038 mg/L 8-Hour Composite Sample Analysis: COD: BOD: Sample Collected: 233 mg/L <10 mg/L Mid-Month Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): Sample Collected: 6 mg/L <6 mg/L 2022 Year 10/25/22 Date 10/25/22 Date 10/14/22 Date MONTHLY REPORT Page 2 of 3 Monthly report for: Number of Vessels Cleaned: Water Pollution Control Permit Report Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. October Month 8 2022 Year Commodities Contained in Vessels: 1. Xylene 2. Diesel Fuel 3. Ethanol Benzene 4. Glycol 5. Ethanol 6. 7. 8. 9. 10. Wastewater Analysis Completed by: Days Discharging Treated Wastewater to Sewer: Total Amount of Treated Wastewater: Total Average per Day: Teklab, Inc. (Colinsville, IL) 5 97,640 19,528 days gallons gallons Prepared for: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 MONTHLY REPORT Prepared by: 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Page 3 of 3 Chemical Analysis for: Water Pollution Control Permit Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. November Month Grab Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): pH: TSS: Mercury: Cadmium: Chromium: Copper: Lead: Nickel: Zinc: 1-methylphenanthrene: Bis(2-ethylhexyl)phthalate: Sample Collected: <6 mg/L <6 mg/L 7.16 7 mg/L <0.00020 mg/L <0.0020 mg/L <0.0050 mg/L <0.0050 mg/L <0.0150 mg/L 0.0458 mg/L 0.0440 mg/L ND<0.030 mg/L ND<0.038 mg/L 8-Hour Composite Sample Analysis: COD: BOD: Sample Collected: 194 mg/L <10 mg/L Mid-Month Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): Sample Collected: <5 mg/L <5 mg/L 2022 Year 11/29/22 Date 11/29/22 Date 11/14/22 Date MONTHLY REPORT Page 2 of 3 Monthly report for: Number of Vessels Cleaned: Water Pollution Control Permit Report Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. November Month 12 2022 Year Commodities Contained in Vessels: 1. Mixed Xylene 2. Diesel Fuel 3. Slop Oil 4. Hydraulic Oil 5. Ethanol 6. Lube Oil 7. 8. 9. 10. Wastewater Analysis Completed by: Days Discharging Treated Wastewater to Sewer: Total Amount of Treated Wastewater: Total Average per Day: Teklab, Inc. (Colinsville, IL) 5 74,753 14,951 days gallons gallons Prepared for: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 MONTHLY REPORT Prepared by: 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Page 3 of 3 Chemical Analysis for: Water Pollution Control Permit Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. December Month Grab Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): pH: TSS: Mercury: Cadmium: Chromium: Copper: Lead: Nickel: Zinc: 1-methylphenanthrene: Bis(2-ethylhexyl)phthalate: Sample Collected: 17 mg/L 10 mg/L 7.60 30 mg/L <0.00020 mg/L <0.0020 mg/L <0.0050 mg/L <0.0050 mg/L <0.0150 mg/L 0.0527 mg/L 0.0504 mg/L ND<0.030 mg/L ND<0.038 mg/L 8-Hour Composite Sample Analysis: COD: BOD: Sample Collected: 279 mg/L 27 mg/L Mid-Month Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): Sample Collected: 10 mg/L 9 mg/L 2022 Year 12/13/22 Date 12/13/22 Date 12/06/22 Date MONTHLY REPORT Page 2 of 3 Monthly report for: Number of Vessels Cleaned: Water Pollution Control Permit Report Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. December Month 5 2022 Year Commodities Contained in Vessels: 1. Mixed Xylene 2. Diesel Fuel 3. Slop Oil 4. 5. 6. 7. 8. 9. 10. Wastewater Analysis Completed by: Days Discharging Treated Wastewater to Sewer: Total Amount of Treated Wastewater: Total Average per Day: Teklab, Inc. (Colinsville, IL) 4 70,717 17,679 days gallons gallons Prepared for: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 MONTHLY REPORT Prepared by: 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Page 3 of 3 Chemical Analysis for: Water Pollution Control Permit Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. January Month Grab Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): pH: TSS: Mercury: Cadmium: Chromium: Copper: Lead: Nickel: Zinc: 1-methylphenanthrene: Bis(2-ethylhexyl)phthalate: Sample Collected: 11 mg/L <6 mg/L 7.21 73 mg/L <0.00020 mg/L <0.0020 mg/L <0.0050 mg/L <0.0050 mg/L <0.0150 mg/L 0.0578 mg/L 0.294 mg/L ND<0.060 mg/L ND<0.075 mg/L 8-Hour Composite Sample Analysis: COD: BOD: Sample Collected: 1570 mg/L 895 mg/L Mid-Month Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): Sample Collected: 6 mg/L <6 mg/L 2023 Year 01/26/23 Date 01/26/23 Date 01/18/23 Date MONTHLY REPORT Page 2 of 3 Monthly report for: Number of Vessels Cleaned: Water Pollution Control Permit Report Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. January Month 13 2023 Year Commodities Contained in Vessels: 1. Xylene 2. Deisel Fuel 3. Slop Oil 4. Resin Oil 5. Thermal Oil 6. Hydraulic Oil 7. Jet Fuel 8. 9. 10. Wastewater Analysis Completed by: Days Discharging Treated Wastewater to Sewer: Total Amount of Treated Wastewater: Total Average per Day: Teklab, Inc. (Colinsville, IL) 9 149,727 16,636 days gallons gallons Prepared for: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 MONTHLY REPORT Prepared by: 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Page 3 of 3 Chemical Analysis for: Water Pollution Control Permit Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. February Month Grab Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): pH: TSS: Mercury: Cadmium: Chromium: Copper: Lead: Nickel: Zinc: 1-methylphenanthrene: Bis(2-ethylhexyl)phthalate: Sample Collected: 10 mg/L 9 mg/L 7.06 365 mg/L <0.00020 mg/L <0.0020 mg/L <0.0050 mg/L 0.0103 mg/L <0.0150 mg/L 0.0477 mg/L 0.283 mg/L ND<0.120 mg/L ND<0.150 mg/L 8-Hour Composite Sample Analysis: COD: BOD: Sample Collected: 2220 mg/L 1100 mg/L Mid-Month Sample Analysis: Hexane Extract Material: Hexane Extract Material (SGT): Sample Collected: 12 mg/L <6 mg/L 2023 Year 02/23/23 Date 02/23/23 Date 02/15/23 Date MONTHLY REPORT Page 2 of 3 Monthly report for: Number of Vessels Cleaned: Water Pollution Control Permit Report Permit No. 2020-EP-65303 National Maintenance & Repair, Inc. February Month 9 2023 Year Commodities Contained in Vessels: 1. Slop Oil 2. Diesel Fuel 3. 4. 5. 6. 7. 8. 9. 10. Wastewater Analysis Completed by: Days Discharging Treated Wastewater to Sewer: Total Amount of Treated Wastewater: Total Average per Day: Teklab, Inc. (Colinsville, IL) 8 152,679 19,085 days gallons gallons Prepared for: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 MONTHLY REPORT Prepared by: 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Page 3 of 3 Appendix 5 Appendix 6 Appendix 7 Appendix 8 National Maintenance & Repair, Inc. SWPPP TABLE OF CONTENTS I. POLICIES AND PROCEDURES II. INTRODUCTION III. ENVIRONMENTAL COMPLIANCE POLICY IV. STORM WATER MANAGEMENT CONTROLS A. PERSONNEL B. PREVENTIVE MAINTENANCE C. GOOD HOUSEKEEPING D. SPILL PREVENTION AND RESPONSE V. STORM WATER MANAGEMENT PRACTICES A CONTAINMENT B. DEBRIS CONTROL C. WASTE CHEMICAL DISPOSAL D. SAND BLASTING AND PAINT REMOVAL E. PAINTING F. MATERIAL STORAGE AREAS G. ENGINE REPAIR/REBUILD AREAS H. MATERIAL HANDLING AREAS I. DRY DOCK AREAS J. GENERAL YARD AREA VI. EMPLOYEE TRAINING VII. INSPECTION PROCEDURE VIII. OTHER PROGRAMS WHICH AFFECT THE SWPPP APPENDIX A - NATIONAL MAINTENANCE AND REPAIR STANDARD OPERATING PROCEDURES FOR STORM WATER POLLUTION PREVENTION, CONTROL AND HANDLING, STORING AND DISPOSING OF REGULATED WASTE APPENDIX B - REGULATED WASTE DISPOSAL CHART APPENDIX C - NMR SITE MAPS Revised Mar. 2018 Page 2 of 15 National Maintenance & Repair, Inc. SWPPP I. POLICIES AND PROCEDURES All personnel covered within the scope of this policy shall be trained initially upon employment and once annually regarding the contents and specific responsibilities regarding implementation of this policy and related applicable environmental laws and regulations. Training in policy compliance will include record keeping, spill reporting, and spill remediation. Responsibilities: 1. The President and Senior Vice President Operations are responsible for issuing this policy and overseeing its implementation. 2. The Safety Director is designated as the company's "Environmental Officer'' and will be responsible for: a) researching appropriate environmental laws and regulations for applicability to the company, b) updating this policy as necessary, c) conducting inspections of company facilities and procedures to determine compliance, d) conducting/managing training, e) preparing procedures and assisting operating managers with procedures to assure compliance. 3. Managers and supervisors are responsible for directly and indirectly supervising to assure that all work and actions taken are in compliance with the policy. This supervision includes taking the actions necessary to prevent the direct or indirect unpermitted discharge of pollutants to waterways. It will include both verbal and written instructions and procedures to leadmen and other personnel as necessary to assure compliance. 4. Leadmen and other employees are responsible for adhering to all procedures, both written and verbal, to assure compliance with this policy to prevent unpermitted discharges to the river. In the absence of specific instructions, they must take the necessary actions to comply with this policy, intended to prevent pollutants from entering waterways. Notifications: Any employee who becomes aware of an unpermitted discharge into the waterways, either from a company facility or vessel or in the vicinity of a company facility or vessel by an outside source, known or unknown, shall immediately notify his supervisor/manager and/or the Environmental Officer. The supervisor/manager or the Environmental Officer will gather appropriate data on the incident and immediately notify the: National Oil Spill Response Coordinator 800-424-8802 Revised Mar. 2018 Page 3 of 15 National Maintenance & Repair, Inc. SWPPP If for any reason immediate contact cannot be made with the National Oil Spill Response Coordinator, the notification should then be made to: United States Coast Guard 314-539-3824 The following information or estimates are to be provided when making the notification: 1. Location of spill 2. Size of spill 3. Type of spill 4. Weather and river conditions 5. Method of clean up in progress 6. Additional equipment needed 7. Condition of vessel and tow (if involved) The initial call is not to be delayed awaiting complete or final information, as the response centers need early notice. Other notifications including those to the ''qualified individual" will be in accordance with the Company's Facility Response Plan approved February 16, 1995 and the Company's Vessel Response Plan, Control Number 01274, approved December 30, 1994. The "Qualified Individual" is the Senior VicePresident Operations. Response: As soon as the notifications are complete (and only if the spill came from a National facility or vessel), the manager/supervisor or Environmental Officer will take the necessary action(s) and/or those directed by the "Qualified Individual" to prevent a further spill, contain the existing spill, and begin cleanup of the spill from a company facility or vessel. Further response will be in accordance with the above-referenced response plans. Enforcement: Violation of this policy shall be cause for disciplinary action up to and including discharge for the first offense and may subject both the employee(s) and the company to criminal prosecution and/or civil penalty. Revised Mar. 2018 Page 4 of 15 National Maintenance & Repair, Inc. SWPPP Procedures: Each operating department as necessary in conjunction with the Environmental Officer is to establish appropriate written work practices for their area to assure that their operations prevent unpermitted discharges to the river. These written procedures are to be based on the "Best Management Practices for Ship and Boat Building and Repairing Facilities" (60 FR 50993) and, at a minimum, should identify the method(s) of storing material on or near deck barges, crane barges, dry docks, etc.; the methods of operating, cleaning, repairing, etc.; and the same equipment and the proper disposition of the various types of wastes the department would either generate or receive. These procedures and this policy will be the main subject of annual training. Procedures for work practices common to numerous departments will be coordinated by the Environmental Officer to assure compatibility and compliance with this policy. All written procedures in a department will be filed in a binder available to any department employee. Copies of all departments' procedures will be maintained by the Environmental Officer. Any questions about this policy, procedures or compliance with appropriate environmental laws or regulations should be directed to the Environmental Officer. Revised Mar. 2018 Page 5 of 15 National Maintenance & Repair, Inc. SWPPP INTRODUCTION National Maintenance & Repair, Inc. (NMR or facility) is a shipyard and engine repair facility located in Hartford, Illinois. The company operates four (4) floating dry docks as well as a floating barge cleaning operation referred to as the Gas Free Plant (GFP). The industrial activities at NMR include barge and boat repair, barge construction, barge and boat cleaning, metal fabrication, engine rebuilding/repair and engine component rebuilding. Provided in Appendix B is a listing, by department, of all significant materials used at the facility that may have the potential to contaminate storm water. The facility encompasses approximately 18 acres and is composed of the following structures or vessels: Office barge and associated work barges Four dry docks Machine shop Warehouse Engine shop Propeller shop Component rebuild Barge cleaning work barge Approximately 10 acres of the compound, containing the Machine Shop, Warehouse, Engine Shop, Propeller Shop, and Component Rebuild, are surrounded by a levee that directs all storm water into a retention pit/basin before it is pumped into the Mississippi. The pumping action is not automatic but must be initiated by NMR personnel. The work barges, crane barges, and GFP are provided with containment to prevent oil releases into the river. All mobile cranes have containment pans designed to capture leaking oil or hydraulic fluid. Methods for onsite storage and disposal of significant material are in Appendix A & B. Revised Mar. 2018 Page 6 of 15 National Maintenance & Repair, Inc. SWPPP II. ENVIRONMENTAL COMPLIANCE POLICY Purpose: To establish a program which assures that National Maintenance & Repair, Inc. (NMR), in its commitment to the conservation and preservation of national resources, is in full compliance with not only the wording, but with the spirit and intent of applicable federal, state and/or local environmental laws and regulations. Scope: This policy is applicable to all NMR officers, managers, supervisors, non-exempt salaried employees and all hourly employees, both shore-based and crew members. It is also applicable to hired contractors, to whom a copy will be furnished upon request. Policy: It is the policy of NMR to comply with all federal, state and local environmental laws and regulations. These laws and regulations generally prohibit the discharge of any pollutant (i.e., oil, contaminated water, sand, trash, garbage, steel, welding rods, etc.) into the waterways or into areas that subsequently could end up in the waterways unless authorized by permit. No unpermitted discharges will be allowed from a NMR facility or vessel. Nothing will be left stored or uncontained in an area or location where it may inadvertently be discharged into the river. Revised Mar. 2018 Page 7 of 15 National Maintenance & Repair, Inc. SWPPP III. STORMWATER MANAGEMENT CONTROLS A. Personnel 1. The President and Senior Vice President Operations are responsible for issuing this plan and overseeing its implementation. 2. The Safety Manger is designated as the company's Environmental Officer and will be responsible for a) researching environmental laws and regulations which are applicable to this plan; b) updating this plan as necessary; c) conducting inspections of company facilities and procedures to determine compliance; d) conducting/managing training; and e) preparing procedures to assure compliance and assisting operating managers with said procedures. 3. Managers and supervisors are responsible for directly and indirectly supervising employees to ensure that all work and actions taken are in compliance with this policy. This supervision includes taking the actions necessary to prevent the direct or indirect unpermitted discharge of pollutants into the waterways. 4. Leadmen and other employees are responsible for adhering to all procedures to ensure compliance with this plan for preventing unpermitted discharges to the river B. Preventative Maintenance The pumps and motors located at the catch basin used to collect water before it is pumped into the river are maintained and operated by Engine Shop personnel. C. Good Housekeeping Details on housekeeping for both the plant and individual shops can be found in Appendix A, Storm Water and Regulated Waste Standard Operating Procedures (SOP's). Revised Mar. 2018 Page 8 of 15 National Maintenance & Repair, Inc. SWPPP D. Spill Prevention and Response 1. The two areas where significant materials can enter the river directly are the Gas Free Plant and Hull Branch work barges. In the event of a spill, the Facility response plan, Coast Guard control number 01274 will be implemented. This plan covers in detail the personnel, equipment, and procedures to be used in the event of a significant spill in the river. The area surrounded by the levee is contained and can be cleaned up without any danger of material entering the river. If any contamination in the catch basin water is suspected, the personnel responsible for pumping the water will contact either the Environmental Officer or V.P. Operations before proceeding. 2. Other prevention and response guidelines are covered in Appendix A. Revised Mar. 2018 Page 9 of 15 National Maintenance & Repair, Inc. SWPPP STORM WATER MANAGEMENT PRACTICES A. Containment 1. The plant-wide accumulation area for any material that may cause storm water contamination is behind the trash compactor located within the confines of the levy. 2. Barrels of waste containing high liquid content will be kept in the barrel and hauled off as a unit. 3. Containers storing liquids such as fuels, paints, solvents and waste oil shall not be placed in an area where rupture of the container would result in the material entering the river. Such containers will be stored east of the levy or furnished with spill containment. 4. Procedures to contain material with potential for contaminating storm water are provided in Appendix A. B. Debris Control 1. The control of debris that may contaminate the river water is covered in Appendix A. C. Waste Chemical Disposal 1. Chemicals and contaminants will be disposed of according to Appendix B, Regulated Waste Disposal Chart. Disposal procedures for items not listed on the chart will be determined on an individual basis by the Environmental Officer. D. Sandblasting and Paint Removal 1. Uncontained blasting or sanding is prohibited over open water. 2. Work areas being blasted will be covered with a tarp to prevent sand and paint chips from entering the river. If possible, the ends of the dry dock will be tarped to contain grit and paint. 3. Blasting will not be done on windy days which may breach containment systems. E. Painting 1. Painting areas will be covered to the maximum extent practical to prevent over spray from entering the river. 2. Uncontained spraying over open water is prohibited. Revised Mar. 2018 Page 10 of 15 National Maintenance & Repair, Inc. SWPPP 3. Paints and solvent will not be mixed on the docks where a spill would result in contamination entering the river. 4. Only trained individuals will be allowed to paint. The people will have expert knowledge on spraying techniques elimination of over spray and the use of spray equipment that delivers more paint to the target and less over spray. D. Material Storage Areas 1. All stored and containerized materials such as fuels, paints, solvents, oil, and antifreeze will be stored in the designated locations provided east of the levy or provided with spill containment. 2. All material that is considered waste must be disposed of according to Appendix A & B 3. All spills will be cleaned up with sorbent material provided at the warehouse and on the docks. Once the spill is contained the contaminated sorbent material will be disposed of in the regulated waste dumpster at the direction of the Environmental Officer. E. Engine Repair/Rebuild Areas 1. All liquid runoff from inside the engine shop must be diverted to the liquid waste storage container located outside the cleaning areas. At no time will any liquid runoff be allowed into the storm water runoff. 2. The liquid waste storage container will be disposed of as needed at the Gas Free Plant, which has the necessary permits to handle the waste. 3. The vehicle service area behind the engine shop will be monitored for any signs of oil spill or contamination. If any contamination is found, then the area will be remediated in accordance with state and federal regulatory requirements. F. Material handling areas 1. See the USCG-approved Facility Operations Manual for waste water handling and treatment procedures. G. Dry Dock Areas 1. Oily rags, oil dry and used paint cans will be disposed of in special drums located on the dock. 2. Oil filters will be placed in the regulated waste barrels. Revised Mar. 2018 Page 11 of 15 National Maintenance & Repair, Inc. SWPPP 3. Grease from boats will be placed in drums along with oily rags and oil dry. 4. Metal drums will be placed on the dry docks to collect welding rods. 5. Prior to flooding, the dry-dock will be swept clean of debris. A salaried supervisor will note the condition of the dry-dock before it goes down. 6. Floatable and low-density waste, such as wood and plastic, will be removed prior to submerging the dock. 7. Prior to submerging the dock, sand blast grit will be removed to the extent reasonably practical using manual methods. 8. Sand blast grit will be kept separate from other wastes. 9. Used sand blast grit will be kept covered to prevent mixing with rain water. 10. All barrels will be taken to a staging area on the dock for transport to the drum storage areas behind the Engine Shop. 11. No free oil, hydraulic fluid, or grease will be left in a position where it may wash into the river. Spills or leaks will have sorbent placed on them and swept up immediately. H. General Yard Areas 1. The yard is to be cleared of waste regularly to minimize loss of accumulated debris into the river. Details in the classification of debris and how it is to be handled are provided in departmental SOPs and the Regulated Waste Disposal Chart (Appendix A & B). Revised Mar. 2018 Page 12 of 15 National Maintenance & Repair, Inc. SWPPP EMPLOYEE TRAINING A. All employees will receive annual environmental training on the company's environmental compliance policy, pollution control, spilt clean up, and company and shop SOP's. B. All Hull Department leadmen and group leaders will be trained on more specific aspects of dry dock and plant pollution controls. C. All salaried supervisors will receive annual training detailing their responsibilities related to their specific work areas. D. Annual training will be held in April of each year. - Revised Mar. 2018 Page 13 of 15 National Maintenance & Repair, Inc. SWPPP INSPECTION PROCEDURES A. Quarterly environmental inspections will be conducted by either the Environmental Officer or his designated representative. This inspection will be accomplished using a checklist of items that will ensure compliance with the Storm Water Pollution Control Plan. The results of these inspections may be reviewed by the president of National Maintenance & Repair as well as the VP Operations to ensure follow-up and compliance. B. Annual plant inspection by the VP Operations and company president. Revised Mar. 2018 Page 14 of 15 National Maintenance & Repair, Inc. SWPPP OTHER PROGRAMS WHICH AFFECT THE SWPPP Vessel Response Plan 1. This is a detailed plan which plots out the action to be taken in the course of a major oil spill. The plan is resubmitted every 3 years to the Coast Guard for approval. 2. Coast Guard Facility Operations Manual for wastewater handling and treatment 3. National Maintenance & Repair Environmental Compliance Policy. This policy covers the responsibilities of all employees at National Maintenance & Repair in complying with state and federal environmental regulations and provides instruction on actions to be taken in the event of a threatened release into the river. The policy is disseminated to all employees through the employee handbook and annual training. Revised Mar. 2018 Page 15 of 15 National Maintenance & Repair, Inc. SWPPP Appendix A APPENDIX A NATIONAL MAINTENANCE AND REPAIR (NMR) STANDARD OPERATING PROCEDURES (SOPs) FOR STORM WATER POLLUTION PREVENTION, CONTROL AND HANDLING, STORING AND DISPOSING OF REGULATED WASTE Revised Mar. 2018 Page 1 of 5 National Maintenance & Repair, Inc. SWPPP Appendix A SOPs FOR STORM WATER POLLUTION PREVENTION CONTROL AND REGULATED WASTE 1. The Environmental Officer (EO) is responsible for the disposition and removal of all non-hazardous (solid) and hazardous waste on the plant. All questions or concerns regarding solid or hazardous waste handling and the SOP are to be addressed to the Environmental Officer (EO). 2. The accumulation area for solid waste is the area behind the trash compactor. Barrels of waste should not be dropped off there unless it has been authorized by the EO or his representative. 3. The yard is to be cleared of waste on a regular basis to minimize loss of accumulated debris into the river. Details in the debris classification and handling are provided in the department SOP's and the Regulated Waste Disposal Chart. Direct all questions regarding unlisted wastes to the EO. 4. Each department will be responsible for segregation of wastes (see the applicable SOP). 5. Barrels of waste with high liquid contents will be kept in the barrel and hauled off as a unit. 6. Guidelines for disposal of regulated waste will be closely followed. If an instance arises that is not covered by the guidelines, contact the EO for guidance. 7. Containers storing liquids such as fuels, paint, solvents, and waste oil shall not be placed in an area where rupture of the container may result in a material release into the river. Such containers will be stored east of the levy or provided with secondary containment. 8. Immediate response to all spills is required. Major oil spills will be covered by the Spill Prevention, Control, & Countermeasures (SPCC) Plan. Incidental releases onto the ground are to be handled as follows: A. Stop the source of the spill. B. Contain the liquid. C. Cover the spill with absorbent material. D. Sweep up the absorbent and place it in a non-hazardous waste drum. Revised Mar. 2018 Page 2 of 5 National Maintenance & Repair, Inc. SWPPP Appendix A SOPs FOR HULL DEPARTMENT STORM WATER POLLUTION PREVENTION CONTROL AND REGULATED WASTE DISPOSAL 1. Regulated waste will be kept separate from non-regulated waste. 2. Oily rags, oil dry, and uses paint cans will be considered regulated waste and disposed of in special drums placed on the dock. 3. Oil filters will be placed in the regulated waste barrels. 4. Grease from boats will be placed in drums along with oily rags and oil dry. 5. Metal drums will be placed at the dry docks for collecting spent welding rods. 6. Prior to flooding, the dry-dock will be swept clean of debris. A salaried supervisor will make a note in the dry dock log detailing the cleanliness of the dock before it is submerged. 7. Floatable and low-density waste such as wood and plastic will be removed prior to submerging the dock. 8. Sand blast grit will be kept separate from scrap metal, welding rods, and other wastes. 9. All grease and oil will be removed from the working surface of work flats and dry docks before any such material has a chance of washing into the river due to rain or other conditions. 10. Hull department supervisors will keep track of all full barrels of waste that are taken off the dock for proper invoicing purposes. 11. All barrels containing non-hazardous waste must be marked as such. Stickers are available for placement on each drum, along with instructions as to proper disposal and appropriate expense invoicing. Hull branch secretaries will be responsible for handing out these stickers. 12. All barrels will be removed to a staging area on the dock for transport to the drum storage areas behind the engine shop. 13. No free oil, hydraulic fluid, or grease will be left in a position where it can wash into the river. Spills or leaks will be covered with absorbent and swept up immediately Revised Mar. 2018 Page 3 of 5 National Maintenance & Repair, Inc. SWPPP Appendix A SOPs FOR ENGINE SHOP STORM WATER POLLUTION PREVENTION CONTROL AND REGULATED WASTE 1. All waste is to be placed in the proper container. Separate containers will be provided for both regulated and non-regulated waste. 2. Oily rags, oil dry and used paint cans will be considered regulated waste and will be disposed in special drums placed in the shop. 3. Oil filters will be placed in special draining cans and drained for 48 hours. The recovered oil will be sent to the gas free plant, and the drained filters will be handled as non-regulated waste. 4. All paper, tape and respirator cartridges will be disposed of in special waste bins. Revised Mar. 2018 Page 4 of 5 National Maintenance & Repair, Inc. SWPPP Appendix A SOPs FOR MACHINE SHOP STORM WATER POLLUTION PREVENTION CONTROL AND REGULATED WASTE 1. All waste is to be placed in the proper container. Separate containers will be provided for both regulated waste and non-regulated waste. 2. Oily rags, oil dry, oil pigs and used paint cans will be considered regulated waste and disposed of in special drums placed in shop. Revised Mar. 2018 Page 5 of 5 National Maintenance & Repair, Inc. SWPPP Appendix B APPENDIX B REGULATED WASTE DISPOSAL CHART WASTE HAZARD PAINTS Epoxy Water/Latex Base Oil Base Paint Thinners MAY BE FLAMMABLE POISONOUS USED OILS Hydraulic Oil Gear Oil Engine Oil FLAMMABLE POISONOUS ANTIFREEZE POISONOUS DON'T DO Sanitary Sewer Storm Drains Empty cans should be allowed to dry, then crushed and thrown into the special waste barrels. Latex & Water Base: leave cans open, allow to dry and dispose as unregulated garbage Oil Base: Allow solvents to evaporate, and place can into special waste barrels Paint Thinners: Large amounts should be taken to GFP for processing. Small amounts can be mixed with rags and placed in special waste barrels Used oil should not be used as dust suppressant, burned, placed into dumpster or be allowed to spill into the river, even the smallest quantity Used oil that is not contaminated with solid waste should be brought to GFP for processing. Small quantities should be placed in a waste oil drum Storm Sewer/Soil Take to GFP for disposal BATTERIES CORROSIVE POISONOUS Dumpster Contact Environmental Officer for disposal instructions PETROLEUM PRODUCTS Gasoline Diesel Fuel Kerosene FLAMMABLE Sanitary Sewer Storm Drain Take product to GFP for disposal Revised Mar. 2018 Page 1 of 5 National Maintenance & Repair, Inc. SWPPP Appendix B WASTE DEGREASERS Solvents Mineral Spirits Paint Thinners HAZARD MAY BE FLAMMABLE DON'T Sanitary Sewer Storm Drain DO Sen non-chlorinated solvents to GFP for disposal. Chlorinated solvents must be disposed of as hazardous waste MACHINE TOOL COOLANT & WATER-SOLUBLE OIL OILY RAGS, CLEAN SWEEP, OTHER OIL SOAKED CELLULOSE PRODUCTS CLASSIFIED AS NONHAZARDOUS REGULATED WASTE THROW INTO GARBAGE DUMPSTERS Dispose in special Non-Hazardous waste barrels OIL FILTERS AEROSOL CANS EXPLOSION SAND BLAST GRIT Puncture Throw in regular dumpster Place in special hopper for disposal Revised Mar. 2018 Page 2 of 5 National Maintenance & Repair, Inc. HULL DEPARTMENT WASTE STREAM NON-REGULATED WASTE RAIN SUITS SODA CANS PAPER PRODUCTS WELDING RODS USED TOW ROPE USED LIGHT BULBS OIL FILTERS REGULATED WASTE OILY RAGS OILY GLOVES OIL DRY EMPTY PAINT CANS GREASE FROM BOATS SWPPP Appendix B Revised Mar. 2018 Page 3 of 5 National Maintenance & Repair, Inc. ENGINE SHOP WASTE STREAM NON-REGULATED WASTE PAPER CARDBOARD BRAKE KLEEN CANS SMALL PIECES OF WOOD STYROFOAM CUPS FOOD ITEMS METAL SHAVINGS SODA CANS PRESSURIZED CANS PLASTIC BAGS PLASTIC SHRINK WRAP RUBBER ITEMS DRAINED OIL FILTERS REGULATED WASTE OILY RAGS OIL DRY USED PAINT CANS USED RESPIRATOR FILTERS PAPER AND TAPE USED FOR SPRAY PAINTING SWPPP Appendix B Revised Mar. 2018 Page 4 of 5 National Maintenance & Repair, Inc. MACHING SHOP WASTE STREAM NON-REGULATED WASTE PAPER TOWELS EMPTY HAND CLEANER CONTAINERS MILD STEEL CHIPS NYLON TURNINGS HARD SURFACE TURNINGS NEOPRENE & RUBBER WORN HARD SURFACE TURNINGS COLD ROLLED STEEL USED FLUX KEVLAR GASKET MATERIAL CUTLASS BEARINGS MILD STEEL ALLOY WELDING RODS/WIRE ROLLING BEARINGS SAW BLADES USED CUTTING TOOLS REGULATED WASTE PAINT CANS OIL & GREASE FROM SPARE PARTS CUTTING OIL WATER SOLUBLE OIL HYDRAULIC OIL SOLVOCOTE OIL DRY OIL PIGS ANTI-SEIZE BLUE LAYOUT FLUID (CHLORINATED) SPOT-CHECK DEVELOPER (CHLORINATED) SPOT-CHECK CLEANER (CHLORINATED) Revised Mar. 2018 SWPPP Appendix B Page 5 of 5 National Maintenance & Repair, Inc. SWPPP Appendix C Gas Free Plant (GFP) The National Gas Free plant is primarily a water-based facility. The shore side of the facility consists of a parking lot and a single concrete containment for transfers operations. Waste roll offs, vacuum boxes, portable storage containers, and tanks are occasionally deployed on the shore at this site. Revised Mar. 2018 Page 2 of 3 National Maintenance & Repair, Inc. SWPPP Appendix C Description of Outfall 003 During the barge cleaning process, river water is pumped into the forward (or aft) void compartments of the barge to provide a gradient (or list) to the vessel. This list water allows barge washwater to flow efficiently to the vessel's sumps for removal from the barge. After the washing operation is complete, the list water is pumped from the void compartment back into the Mississippi River. At no time does barge washwater and list water mix. The drawing below illustrates the above description. Revised Mar. 2018 Page 3 of 3 Appendix 9 Appendix 10 http://www.teklabinc.com/ March 19, 2020 Mark Clark Sr National Maintenance and Repair P.O. Box 38 Foot of Hawthorne Street Hartford, IL 62048 TEL: (618) 219-0941 FAX: (618) 255-5770 RE: Raw Waste Water WorkOrder: 20030812 Dear Mark Clark Sr: TEKLAB, INC received 2 samples on 3/12/2020 11:35:00 AM for the analysis presented in the following report. Samples are analyzed on an as received basis unless otherwise requested and documented. The sample results contained in this report relate only to the requested analytes of interest as directed on the chain of custody. NELAP accredited fields of testing are indicated by the letters NELAP under the Certification column. Unless otherwise documented within this report, Teklab Inc. analyzes samples utilizing the most current methods in compliance with 40CFR. All tests are performed in the Collinsville, IL laboratory unless otherwise noted in the Case Narrative. All quality control criteria applicable to the test methods employed for this project have been satisfactorily met and are in accordance with NELAP except where noted. The following report shall not be reproduced, except in full, without the written approval of Teklab, Inc. If you have any questions regarding these tests results, please feel free to call. Sincerely, Marvin L. Darling Project Manager (618)344-1004 ex 41 mdarling@teklabinc.com Page 1 of 8 Report Contents Client: National Maintenance and Repair Client Project: Raw Waste Water This reporting package includes the following: Cover Letter Report Contents Definitions Case Narrative Accreditations Laboratory Results Receiving Check List Chain of Custody 1 2 3 4 5 6 8 Appended http://www.teklabinc.com/ Work Order: 20030812 Report Date: 19-Mar-2020 Page 2 of 8 Definitions http://www.teklabinc.com/ Client: National Maintenance and Repair Client Project: Raw Waste Water Work Order: 20030812 Report Date: 19-Mar-2020 Abbr Definition * Analytes on report marked with an asterisk are not NELAP accredited CCV Continuing calibration verification is a check of a standard to determine the state of calibration of an instrument between recalibration. CRQL A Client Requested Quantitation Limit is a reporting limit that varies according to customer request. The CRQL may not be less than the MDL. DF Dilution factor is the dilution performed during analysis only and does not take into account any dilutions made during sample preparation. The reported result is final and includes all dilution factors. DNI Did not ignite DUP Laboratory duplicate is a replicate aliquot prepared under the same laboratory conditions and independently analyzed to obtain a measure of precision. ICV Initial calibration verification is a check of a standard to determine the state of calibration of an instrument before sample analysis is initiated. IDPH IL Dept. of Public Health LCS LCSD MBLK MDL MS MSD MW Laboratory control sample is a sample matrix, free from the analytes of interest,spiked with verified known amounts of analytes and analyzed exactly like a sample to establish intra-laboratory or analyst specific precision and bias or to assess the performance of all or a portion of the measurement system. Laboratory control sample duplicate is a replicate laboratory control sample that is prepared and analyzed in order to determine the precision of the approved test method. The acceptable recovery range is listed in the QC Package (provided upon request). Method blank is a sample of a matrix similar to the batch of associated sample (when available) that is free from the analytes of interest and is processed simultaneously with and under the same conditions as samples through all steps of the analytical procedures, and in which no target analytes or interferences should present at concentrations that impact the analytical results for sample analyses. "The method detection limit is defined as the minimum measured concentration of a substance that can be reported with 99% confidence that the measured concentration is distinguishable from method blank results." Matrix spike is an aliquot of matrix fortified (spiked) with known quantities of specific analytes that is subjected to the entire analytical procedures in order to determine the effect of the matrix on an approved test method's recovery system. The acceptable recovery range is listed in the QC Package (provided upon request). Matrix spike duplicate means a replicate matrix spike that is prepared and analyzed in order to determine the precision of the approved test method. The acceptable recovery range is listed in the QC Package (provided upon request). Molecular weight ND Not Detected at the Reporting Limit NELAP NELAP Accredited PQL RL RPD SPK Surr TIC TNTC Practical quantitation limit means the lowest level that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operation conditions. The reporting limit the lowest level that the data is displayed in the final report. The reporting limit may vary according to customer request or sample dilution. The reporting limit may not be less than the MDL. Relative percent difference is a calculated difference between two recoveries (ie. MS/MSD). The acceptable recovery limit is listed in the QC Package (provided upon request). The sp ke is a known mass of target analyte added to a blank sample or sub-sample; used to determine recovery deficiency or for other quality control purposes. Surrogates are compounds which are similar to the analytes of interest in chemical composition and behavior in the analytical process, but which are not normally found in environmental samples. Tentatively identified compound: Analytes tentatively identified in the sample by using a library search. Only results not in the calibration standard will be reported as tentatively identified compounds. Results for tentatively identified compounds that are not present in the calibration standard, but are assigned a specific chemical name based upon the l brary search, are calculated using total peak areas from reconstructed ion chromatograms and a response factor of one. The nearest Internal Standard is used for the calculation. The results of any TICs must be considered estimated, and are flagged with a "T". If the estimated result is above the cal bration range it is flagged "ET" Too numerous to count ( > 200 CFU ) # - Unknown hydrocarbon C - RL shown is a Client Requested Quantitation Limit H - Holding times exceeded J - Analyte detected below quantitation limits ND - Not Detected at the Reporting Limit S - Spike Recovery outside recovery limits X - Value exceeds Maximum Contaminant Level Qualifiers B - Analyte detected in associated Method Blank E - Value above quantitation range I - Associated internal standard was outside method criteria M - Manual Integration used to determine area response R - RPD outside accepted recovery limits T - TIC(Tentatively identified compound) Page 3 of 8 Client: National Maintenance and Repair Client Project: Raw Waste Water Accreditations State Illinois Kansas Louisiana Louisiana Oklahoma Arkansas Illinois Kentucky Missouri Missouri Dept IEPA KDHE LDEQ LDEQ ODEQ ADEQ IDPH UST MDNR MDNR Cert # 100226 E-10374 166493 166578 9978 88-0966 17584 0073 00930 930 NELAP NELAP NELAP NELAP NELAP NELAP Exp Date 4/10/2020 4/30/2020 6/30/2020 6/30/2020 8/31/2020 3/14/2021 5/31/2021 3/3/2020 5/31/2021 1/31/2022 http://www.teklabinc.com/ Work Order: 20030812 Report Date: 19-Mar-2020 Lab Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville http://www.teklabinc.com/ Page 5 of 8 Laboratory Results http://www.teklabinc.com/ Client: National Maintenance and Repair Client Project: Raw Waste Water Lab ID: 20030812-001 Matrix: WASTE WATER Work Order: 20030812 Report Date: 19-Mar-2020 Client Sample ID: Raw Waste Water Collection Date: 03/12/2020 8:00 Analyses Certification RL Qual Result Units DF EPA 1664A Hexane Extractable Material NELAP 6 23 mg/L 1 EPA 1664A, (TOTAL) PETROLEUM HYDROCARBONS Hexane Extractable Material (SGT) NELAP 6 12 mg/L 1 STANDARD METHOD 4500-H B 2000, LABORATORY ANALYZED Lab pH NELAP 1.00 5.84 1 STANDARD METHODS 2540 D 1997 Total Suspended Solids NELAP 60 110 mg/L 10 EPA 600 245.1 R3.0 (TOTAL) Mercury NELAP 0.00020 < 0.00020 mg/L 1 EPA 600 4.1.4, 200.7R4.4, METALS BY ICP (TOTAL) Cadmium NELAP Chromium NELAP Copper NELAP Lead NELAP Nickel NELAP Zinc NELAP 0.0020 0.0050 0.0050 0.0150 0.0050 0.0100 < 0.0020 mg/L 1 0.0105 mg/L 1 0.0240 mg/L 1 0.0271 mg/L 1 0.105 mg/L 1 0.932 mg/L 1 EPA 600 625.1 (MODIFIED), SEMI-VOLATILE ORGANIC COMPOUNDS BY GC/MS 1-Methylphenanthrene * 0.060 ND mg/L 10 Bis(2-ethylhexyl)phthalate * 0.075 ND mg/L 10 Surr: 2-Fluorobiphenyl * 36.3-102 66.0 %REC 10 Surr: Nitrobenzene-d5 * 15-314 73.8 %REC 10 Surr: p-Terphenyl-d14 * 10-112 47.4 %REC 10 Elevated reporting limit due to sample extract composition. Date Analyzed Batch 03/18/2020 10:03 R274329 03/19/2020 15:10 R274329 03/12/2020 14:42 R274072 03/18/2020 11:40 R274341 03/13/2020 9:35 163108 03/17/2020 11:14 03/14/2020 0:04 03/14/2020 0:04 03/14/2020 0:04 03/14/2020 0:04 03/14/2020 0:04 163112 163112 163112 163112 163112 163112 03/17/2020 3:35 03/17/2020 3:35 03/17/2020 3:35 03/17/2020 3:35 03/17/2020 3:35 163205 163205 163205 163205 163205 Page 6 of 8 Laboratory Results http://www.teklabinc.com/ Client: National Maintenance and Repair Client Project: Raw Waste Water Lab ID: 20030812-002 Matrix: WASTE WATER Work Order: 20030812 Report Date: 19-Mar-2020 Client Sample ID: Raw Waste Water Collection Date: 03/12/2020 8:00 Analyses Certification EPA 600 410.4 Chemical Oxygen Demand NELAP STANDARD METHODS 5210 B 2001 Biochemical Oxygen Demand NELAP RL Qual 500 125 Result Units DF 11200 mg/L 10 6350 mg/L 25 Date Analyzed Batch 03/13/2020 14:59 R274112 03/13/2020 15:22 163159 Page 7 of 8 Receiving Check List Client: National Maintenance and Repair Client Project: Raw Waste Water http://www.teklabinc.com/ Work Order: 20030812 Report Date: 19-Mar-2020 Carrier: Jacob Wilson Completed by: On: 12-Mar-2020 Amanda R. Ham Received By: AMD Reviewed by: On: 12-Mar-2020 Elizabeth A. Hurley Chain of custody 1 Extra pages included 0 Shipping container/cooler in good condition? Yes No Not Present Temp C Type of thermal preservation? None Ice Blue Ice Dry Ice Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes No Chain of custody agrees with sample labels? Yes No Samples in proper container/bottle? Yes No Sample containers intact? Yes No Sufficient sample volume for indicated test? Yes No All samples received within holding time? Yes No Reported field parameters measured: Field Lab NA Sample analyses to be measured in the field and/or within 15 minutes of collection were analyzed in the lab as soon as practicable. These analyses include Chlorine (demand, free and/or residual), Carbon Dioxide, Dissolved Oxygen, Ferrous Iron, pH, and Sulfite. Container/Temp Blank temperature in compliance? Yes No When thermal preservation is required, samples are compliant with a temperature between 0.1C - 6.0C, or when samples are received on ice the same day as collected. Water - at least one vial per sample has zero headspace? Yes Water - TOX containers have zero headspace? Yes Water - pH acceptable upon receipt? Yes NPDES/CWA TCN interferences checked/treated in the field? Yes No No VOA vials No No TOX containers No NA No NA Additional nitric acid (71912) was needed upon arrival at the laboratory. - KMT/aham - 3/12/2020 12:52:34 PM Samples are labeled as Monthly Grab and Monthly Comp. - KMT/aham - 3/12/2020 12:53 PM Page 8 of 8 Appendix 11 http://www.teklabinc.com/ March 30, 2020 Mark Clark Sr National Maintenance and Repair P.O. Box 38 Foot of Hawthorne Street Hartford, IL 62048 TEL: (618) 219-0941 FAX: (618) 255-5770 RE: March Waste Water WorkOrder: 20031247 Dear Mark Clark Sr: TEKLAB, INC received 2 samples on 3/19/2020 10:05:00 AM for the analysis presented in the following report. Samples are analyzed on an as received basis unless otherwise requested and documented. The sample results contained in this report relate only to the requested analytes of interest as directed on the chain of custody. NELAP accredited fields of testing are indicated by the letters NELAP under the Certification column. Unless otherwise documented within this report, Teklab Inc. analyzes samples utilizing the most current methods in compliance with 40CFR. All tests are performed in the Collinsville, IL laboratory unless otherwise noted in the Case Narrative. All quality control criteria applicable to the test methods employed for this project have been satisfactorily met and are in accordance with NELAP except where noted. The following report shall not be reproduced, except in full, without the written approval of Teklab, Inc. If you have any questions regarding these tests results, please feel free to call. Sincerely, Marvin L. Darling Project Manager (618)344-1004 ex 41 mdarling@teklabinc.com Page 1 of 8 Report Contents Client: National Maintenance and Repair Client Project: March Waste Water This reporting package includes the following: Cover Letter Report Contents Definitions Case Narrative Accreditations Laboratory Results Receiving Check List Chain of Custody 1 2 3 4 5 6 8 Appended http://www.teklabinc.com/ Work Order: 20031247 Report Date: 30-Mar-2020 Page 2 of 8 Definitions http://www.teklabinc.com/ Client: National Maintenance and Repair Client Project: March Waste Water Work Order: 20031247 Report Date: 30-Mar-2020 Abbr Definition * Analytes on report marked with an asterisk are not NELAP accredited CCV Continuing cal bration verification is a check of a standard to determine the state of calibration of an instrument between recal bration. CRQL A Client Requested Quantitation Limit is a reporting limit that varies according to customer request. The CRQL may not be less than the MDL. DF Dilution factor is the dilution performed during analysis only and does not take into account any dilutions made during sample preparation. The reported result is final and includes all dilution factors. DNI Did not ignite DUP Laboratory duplicate is a replicate aliquot prepared under the same laboratory conditions and independently analyzed to obtain a measure of precision. ICV Initial calibration verification is a check of a standard to determine the state of cal bration of an instrument before sample analysis is initiated. IDPH IL Dept. of Public Health LCS LCSD MBLK MDL MS MSD MW Laboratory control sample is a sample matrix, free from the analytes of interest,spiked with verified known amounts of analytes and analyzed exactly l ke a sample to establish intra-laboratory or analyst specific precision and bias or to assess the performance of all or a portion of the measurement system. Laboratory control sample duplicate is a replicate laboratory control sample that is prepared and analyzed in order to determine the precision of the approved test method. The acceptable recovery range is listed in the QC Package (provided upon request). Method blank is a sample of a matrix similar to the batch of associated sample (when available) that is free from the analytes of interest and is processed simultaneously with and under the same conditions as samples through all steps of the analytical procedures, and in which no target analytes or interferences should present at concentrations that impact the analytical results for sample analyses. "The method detection limit is defined as the minimum measured concentration of a substance that can be reported with 99% confidence that the measured concentration is distinguishable from method blank results." Matrix spike is an aliquot of matrix fortified (spiked) with known quantities of specific analytes that is subjected to the entire analytical procedures in order to determine the effect of the matrix on an approved test method's recovery system. The acceptable recovery range is listed in the QC Package (provided upon request). Matrix spike duplicate means a replicate matrix spike that is prepared and analyzed in order to determine the precision of the approved test method. The acceptable recovery range is listed in the QC Package (provided upon request). Molecular weight ND Not Detected at the Reporting Limit NELAP NELAP Accredited PQL RL RPD SPK Surr TIC TNTC Practical quantitation limit means the lowest level that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operation conditions. The reporting limit the lowest level that the data is displayed in the final report. The reporting limit may vary according to customer request or sample dilution. The reporting limit may not be less than the MDL. Relative percent difference is a calculated difference between two recoveries (ie. MS/MSD). The acceptable recovery limit is listed in the QC Package (provided upon request). The spike is a known mass of target analyte added to a blank sample or sub-sample; used to determine recovery deficiency or for other quality control purposes. Surrogates are compounds which are similar to the analytes of interest in chemical composition and behavior in the analytical process, but which are not normally found in environmental samples. Tentatively identified compound: Analytes tentatively identified in the sample by using a l brary search. Only results not in the calibration standard will be reported as tentatively identified compounds. Results for tentatively identified compounds that are not present in the calibration standard, but are assigned a specific chemical name based upon the library search, are calculated using total peak areas from reconstructed ion chromatograms and a response factor of one. The nearest Internal Standard is used for the calculation. The results of any TICs must be considered estimated, and are flagged with a "T". If the estimated result is above the calibration range it is flagged "ET" Too numerous to count ( > 200 CFU ) # - Unknown hydrocarbon C - RL shown is a Client Requested Quantitation Limit H - Holding times exceeded J - Analyte detected below quantitation limits ND - Not Detected at the Reporting Limit S - Sp ke Recovery outside recovery limits X - Value exceeds Maximum Contaminant Level Qualifiers B - Analyte detected in associated Method Blank E - Value above quantitation range I - Associated internal standard was outside method criteria M - Manual Integration used to determine area response R - RPD outside accepted recovery limits T - TIC(Tentatively identified compound) Page 3 of 8 Client: National Maintenance and Repair Client Project: March Waste Water Accreditations State Illinois Kansas Louisiana Louisiana Oklahoma Arkansas Illinois Kentucky Missouri Missouri Dept IEPA KDHE LDEQ LDEQ ODEQ ADEQ IDPH UST MDNR MDNR Cert # 100226 E-10374 166493 166578 9978 88-0966 17584 0073 00930 930 NELAP NELAP NELAP NELAP NELAP NELAP Exp Date 1/31/2021 4/30/2020 6/30/2020 6/30/2020 8/31/2020 3/14/2021 5/31/2021 3/3/2020 5/31/2021 1/31/2022 http://www.teklabinc.com/ Work Order: 20031247 Report Date: 30-Mar-2020 Lab Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville Collinsville http://www.teklabinc.com/ Page 5 of 8 Laboratory Results http://www.teklabinc.com/ Client: National Maintenance and Repair Client Project: March Waste Water Lab ID: 20031247-001 Matrix: WASTE WATER Work Order: 20031247 Report Date: 30-Mar-2020 Client Sample ID: March Waste Water Collection Date: 03/19/2020 8:20 Analyses Certification RL Qual Result Units DF EPA 1664A Hexane Extractable Material NELAP 6 8 mg/L 1 EPA 1664A, (TOTAL) PETROLEUM HYDROCARBONS Hexane Extractable Material (SGT) NELAP 6 < 6 mg/L 1 STANDARD METHOD 4500-H B 2000, LABORATORY ANALYZED Lab pH NELAP 1.00 5.78 1 STANDARD METHODS 2540 D 1997 Total Suspended Solids NELAP 6 16 mg/L 1 EPA 600 245.1 R3.0 (TOTAL) Mercury NELAP 0.00020 < 0.00020 mg/L 1 EPA 600 4.1.4, 200.7R4.4, METALS BY ICP (TOTAL) Cadmium NELAP Chromium NELAP Copper NELAP Lead NELAP Nickel NELAP Zinc NELAP 0.0020 0.0050 0.0050 0.0150 0.0050 0.0100 < 0.0020 mg/L 1 < 0.0050 mg/L 1 < 0.0050 mg/L 1 < 0.0150 mg/L 1 0.0945 mg/L 1 0.241 mg/L 1 EPA 600 625.1 (MODIFIED), SEMI-VOLATILE ORGANIC COMPOUNDS BY GC/MS 1-Methylphenanthrene * 0.012 ND mg/L 2 Bis(2-ethylhexyl)phthalate NELAP 0.015 ND mg/L 2 Surr: 2-Fluorobiphenyl * 36.3-102 46.3 %REC 2 Surr: Nitrobenzene-d5 * 15-314 75.7 %REC 2 Surr: p-Terphenyl-d14 * 10-112 42.5 %REC 2 Elevated reporting limit due to sample extract composition. Date Analyzed Batch 03/24/2020 16:02 R274541 03/25/2020 14:50 R274541 03/19/2020 15:43 R274379 03/24/2020 11:33 R274498 03/20/2020 10:08 163357 03/20/2020 16:44 03/20/2020 16:44 03/20/2020 16:44 03/20/2020 16:44 03/20/2020 16:44 03/20/2020 16:44 163349 163349 163349 163349 163349 163349 03/25/2020 7:30 03/25/2020 7:30 03/25/2020 7:30 03/25/2020 7:30 03/25/2020 7:30 163387 163387 163387 163387 163387 Page 6 of 8 Laboratory Results http://www.teklabinc.com/ Client: National Maintenance and Repair Client Project: March Waste Water Lab ID: 20031247-002 Matrix: WASTE WATER Work Order: 20031247 Report Date: 30-Mar-2020 Client Sample ID: March Composite Collection Date: 03/19/2020 9:00 Analyses Certification EPA 600 410.4 Chemical Oxygen Demand NELAP STANDARD METHODS 5210 B 2001 Biochemical Oxygen Demand NELAP RL Qual 500 125 Result Units DF 11000 mg/L 10 7480 mg/L 25 Date Analyzed Batch 03/20/2020 14:43 R274416 03/19/2020 18:18 163363 Page 7 of 8 Receiving Check List Client: National Maintenance and Repair Client Project: March Waste Water http://www.teklabinc.com/ Work Order: 20031247 Report Date: 30-Mar-2020 Carrier: Jacob Wilson Completed by: On: 19-Mar-2020 Amber M. Dilallo Received By: AMD Reviewed by: On: 19-Mar-2020 Marvin L. Darling Chain of custody 1 Extra pages included 0 Shipping container/cooler in good condition? Yes No Not Present Temp C Type of thermal preservation? None Ice Blue Ice Dry Ice Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes No Chain of custody agrees with sample labels? Yes No Samples in proper container/bottle? Yes No Sample containers intact? Yes No Sufficient sample volume for indicated test? Yes No All samples received within holding time? Yes No Reported field parameters measured: Field Lab NA Sample analyses to be measured in the field and/or within 15 minutes of collection were analyzed in the lab as soon as practicable. These analyses include Chlorine (demand, free and/or residual), Carbon Dioxide, Dissolved Oxygen, Ferrous Iron, pH, and Sulfite. Container/Temp Blank temperature in compliance? Yes No When thermal preservation is required, samples are compliant with a temperature between 0.1C - 6.0C, or when samples are received on ice the same day as collected. Water - at least one vial per sample has zero headspace? Yes Water - TOX containers have zero headspace? Yes Water - pH acceptable upon receipt? Yes NPDES/CWA TCN interferences checked/treated in the field? Yes No No VOA vials No No TOX containers No NA No NA Additional Nitric Acid (72122) was needed upon arrival at the laboratory for March Waste Water. - ktaylor - 3/19/2020 10:31:40 AM Page 8 of 8 Appendix 12 March 23, 2023 Collinsville Regional Manager Illinois EPA-Division of Water Pollution Control 1101 Eastport Plaza Dr., Ste. 100 Collinsville, Illinois 62234 Chessie Brame Village of Hartford 140 W. Hawthorne St. Hartford, Illinois 62048-1012 Illinois Environmental Protection Agency DWP, Compliance Assurance Section 1021 North Grand Avenue East Springfield, Illinois 62794-9276 Water Department City of Wood River 100 Anderson Avenue Wood River, Illinois 62095 Enclosed are the analytical results for priority pollutants listed in 40 CFR 122 Appendix D, Table II, as required annually for Water Pollution Control Permit No. 2020-EP-65303 for the year of 2022 . Prepared for: Prepared by: Foot of Hawthorne St. Hartford, IL 62048 (618) 254-7451 16532 Conrad Rd. Brighton, IL 62012 (618) 372-3470 Please contact me at (618) 372-3740 if you have any questions or concerns. Sincerely, Nathaniel Brooks EnviroLife Consulting LLC ANNUAL REPORT Page 1 of 2 Chemical Analysis for: Water Pollution Control Permit Permit No. 2014-EP-58860 National Maintenance & Repair, Inc. Sample Analysis: 1,1,1-Trichloroethane 1,1,2,2-Tetrachloroethane 1,1,2-Trichoroethane 1,1-Dichloroethane 1,1-Dichloroethene 1,2-Dichloroethane 1,2-Dichloropropane 1,3-Dichloropropene, Total 2-Chloroethyl vinyl ether Acrolein Acrylonitrile Benzene Bromodichloromethane Bromoform Bromomethane Carbon tetrachloride Chlorobenzene Chloroethane Chloroform Chloromethane cis-1,3-Dichloropropene Dibromochloromethane Ethylbenzene Methylene chloride Tetrachloroethene Toluene trans-1,2-Dichloroethene Trichloroethene Vinyl Chloride Sample Collected: ND<0.0020 ND<0.0020 ND<0.0005 ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0050 ND<0.0200 ND<0.0050 ND<0.0005 ND<0.0020 ND<0.0020 ND<0.0050 ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0050 --------------ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0005 ND<0.0020 ND<0.0020 ND<0.0020 ND<0.0020 2022 Year 02/15/23 Date mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L ANNUAL REPORT Page 2 of 2 Appendix 13