November 18, 2011 Mr. John Kelley, Plant Manager Magnolia… · John Kelley, AMFUEL-Magnolia...

November 18, 2011

Mr. John Kelley, Plant Manager

AMFUEL-Magnolia

601 Firestone Drive

Magnolia, AR 71753

AFIN: 14-00040 NPDES Permit No.: ARR00B815

Dear Mr. Kelly:

On October 26, 2011, I performed an Industrial Storm Water inspection of the above referenced

facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and

Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the

following violations:

1. The Storm Water Pollution Prevention Plan (SWPPP) was not signed. This is a

violation of Part 4.6.12 of the permit.

2. The SWPPP needed to be updated to show current the current plant manager. This is

violation of Part 4.6.2 of the permit.

3. The facility did not have records of the quarterly visual inspections as required by the

permit and the SWPPP. This is a violation of Part 4.6.10.1 of the permit.

4. The facility did not have a copy of the annual comprehensive site compliance

evaluations for 2009 as required by the permit and SWPPP. This is a violation of Part

4.6.10.2 of the permit.

5. The facility did not have copies of employee training records as required by the permit

and SWPPP. This is a violation of 4.6.6.6 of the permit.

6. Housekeeping at the plant was inadequate. Specifically, trash, barrels, buckets and etc

were noted strewn around the south side of the property. This is a violation of Part

4.6.6.3 of the permit.

7. The facility had 500 gallon totes of MEK and 55 gallon barrels of various raw products

stored outside without any type of BMP (such as containment) to protect storm water

discharges from being contaminated in case of a release. This is a violation of Part

4.6.6.5 (b) of the permit.

John Kelley, AMFUEL-Magnolia

11/15/2011

Page - 2 -

NPDES Report

8. The facility has not replaced the rusted collection tank on the south side of the building

as noted in the facility 2010 annual comprehensive site compliance evaluation. This is

a violation of Part 4.6.10.2 (b) of the permit.

The above items require your immediate attention. Please submit a written response to these

findings to Water Division Enforcement Branch. This response should be mailed to the address

below, or e-mailed to [email protected]. This response should contain

documentation describing the course of action taken to correct each item noted. This corrective

action should be completed as soon as possible, and the written response with all necessary

documentations (i.e. photos) is due by December 1, 2011.

For additional information you may contact the Enforcement Branch by telephone at 501-682-0639

or by fax at 501-682-0910.

If I can be any assistance, please contact me at 870-86 2-0680.

Sincerely,

John W. Lamb

District 8 Field Inspector

Water Division

cc: Water Division Enforcement Branch

Water Division Permits Branch

mailto:[email protected]

ADEQ Water NPDES Inspection AFIN: «AFIN» Permit #: «Permit_»

NPDES Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Washington, D.C. 20460

NPDES Compliance Inspection Report

Form Approved

OMB No. 2040-0003

Section A: National Data System Coding

Transaction Code

NPDES

Yr/Mo/Day

Inspec. Type

Inspector

Fac. Type

1 N 2 5 3 A R R 0 0 B 8 1 5 11 12 1 1 1 0 2 6 17 18 W 19 S 20 2

Remarks

Inspection Work Days

Facility Evaluation Rating

BI

QA

-------------------------------Reserved------------------------------

67

69

70 2

71

N

72

N

73

74

75

80

Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also

include POTW name and NPDES permit number)

AMFUEL-Magnolia

601 Firestone Drive

Magnolia, AR

Entry Time/Date

12:25/ 10/26/2011

Permit Effective Date

7/1/2009

Exit Time/Date

15:40/10/26/2011

Permit Expiration Date

6/30/2014

Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s)

James Skinner, Maintenance Supervisor

Scott Murtry, M&P Manager

Other Facility Data

PDS 062318 Name, Address of Responsible Official/Title/Phone and Fax Number

John Kelley, Plant Manger 870-235-7201

AMFUEL-Magnolia

601 Firestone Drive

Magnolia, AR 71753

Contacted

Yes No

Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)

S Permit N

Flow Measurement N

Operations & Maintenance S

Sampling

U Records/Reports M

Self-Monitoring Program N

Sludge Handling/Disposal N

Pollution Prevention

U Facility Site Review N

Compliance Schedules N

Pretreatment N

Multimedia

N Effluent/Receiving Waters S

Laboratory U

Storm Water

Other:

Section D: Summary of Findings/Comments (Attach additional sheets if necessary)

See page 7 for details.

Name(s) and Signature(s) of Inspector(s) John W. Lamb

Agency/Office/Telephone/Fax

Arkansas Department of Environmental Quality

3400 West Hillsboro

El Dorado, AR 71730-(870)862-0680

Date

11/15/2011

Signature of Reviewer

Agency/Office/Phone and Fax Numbers

Date

Inspection Form Legend:


NPDES Report

S = Satisfactory, M = Marginal, U = Unsatisfactory, Y = Yes, N = No, NI = Not Implemented, NA = Not Applicable, NE = Not Evaluated –

If Y and a NI are check it means it is in the SWPPP but not implemented in the field which is a violation. SECTION A: PERMIT VERIFICATION

PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE

1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE

2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE

3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE

4. ALL DISCHARGES ARE PERMITTED: Y N NA NE

Comments:

SECTION B: STORM WATER POLLUTION PREVENTION PLAN EVALUATION

PERMITTEE SWPPP MEETS PERMIT REQUIRMENTS S M U NA NE

1. Is the SWPPP available for review by ADEQ? (Part 4.2) Y N NI NA NE

2. Does the SWPPP contain facility name, general permit tracking number, facility physical address, and SIC and NAICS codes? (Part 4.6.1)

Y N NI NA NE

3. Pollution Prevention Team

A. Does the SWPPP identify specific individuals or positions?(Part 4.6.2) Y N NI NA NE

B. Does the SWPPP outline the responsibilities of each member of the Pollution Prevention Team? (Part 4.6.2) Y N NI NA NE

4. Does the SWPPP contain a facility description (process diagram, general layout, storage of raw materials, the flow of goods and materials through the facility and seasonal variations)? (Part 4.6.3)

Y N NI NA NE

5. Does the facility site map contain the following items?

A) The size of the property in acres? (Part 4.6.4.a) Y N NI NA NE

B) The location and extent of significant structures and impervious surfaces? (Part 4.6.4.b) Y N NI NA NE

C) The direction of stormwater flow using arrows? (Part 4.6.4.c) Y N NI NA NE

D) The locations of all existing structural control measures? (Part 4.6.4.d) Y N NI NA NE

E) The locations of all receiving wasters in the immediate vicinity of the facility? (Part 4.6.4.e) Y N NI NA NE

F) The locations of all stormwater conveyances including ditches, pipes, and swales? (Part 4.6.4.f) Y N NI NA NE

G) The locations of potential pollutant sources? (Part 4.6.4.g) Y N NI NA NE

H) The locations of all stormwater monitoring points? (Part 4.6.4.h) Y N NI NA NE

I) The locations of stormwater inlets and outfalls with unique identification code for each outfall with indications if one or more outfall is being treated as “substantially identical” and an approximate outline of the areas draining to each outfall? (Part 4.6.4.i)

Y N NI NA NE

J) Where the stormwater discharges to municipal separate storm sewer system (MS4), if applicable? (Part 4.6.4.j)

Y N NI NA NE

K) The locations and descriptions of all non-stormwater discharges identified in the SWPPP? (Part 4.6.4.k) Y N NI NA NE

L) The locations of the following activities if they are exposed to precipitation? (Part 4.6.4.l) Y N NI NA NE

Fueling Stations Y N NI NA NE

Vehicle and equipment maintenance and/or cleaning areas Y N NI NA NE

Loading and unloading areas Y N NI NA NE

Locations used for the treatment, storage, or disposal of waste Y N NI NA NE

Liquid storage tanks Y N NI NA NE

Processing and storage areas Y N NI NA NE

Immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-byproducts used or created by the facility

Y N NI NA NE

Transfer areas for substances in bulk Y N NI NA NE

Machinery Y N NI NA NE

M) The locations and sources of run-on to the site from adjacent property that contains significant quantities of pollutants? (Part 4.6.4.m)

Y N NI NA NE


NPDES Report

6. A description of potential pollutant sources

A) An inventory of industrial activities which have been or may potentially be sources of significant amounts of pollutants? (Part 4.6.5.1)

Y N NI NA NE

B) An inventory of all types of materials handled at the site that might potentially be exposed to precipitation? (Part 4.6.5.2)

Y N NI NA NE

C) A list of significant spills and significant leaks of toxic or hazardous pollutants that have occurred in areas exposed to precipitation or drained to a stormwater conveyance for three years prior to the effective date of the permit. (Part 4.6.5.3)

Y N NI NA NE

D) A summary of existing discharge sampling data (Part 4.6.5.4) Y N NI NA NE

E) Risk Identification and Summary of Potential Pollutant Sources (Part 4.6.5.5) Y N NI NA NE

7. Measures and Controls –SWPPP must describe how these are used.

A) Best Management Practices (BMPs) (Part 4.6.6.1) Y N NI NA NE

B) Exposure Minimization (Part 4.6.6.2) Y N NI NA NE

C) Good Housekeeping (Part 4.6.6.3) Y N NI NA NE

D) Preventative Maintenance (Part 4.6.6.4) Y N NI NA NE

E) Spill Prevention and Response Procedures (Part 4.6.6.5) Y N NI NA NE

F) Employee Training Procedures (Part 4.6.6.6) Y N NI NA NE

G) Erosion and Sediment Control (Part 4.6.6.7) Y N NI NA NE

H) Management of Run-on and Runoff (Part 4.6.6.8) Y N NI NA NE

I) Additional Requirements for Salt Storage (Part 4.6.6.9) Y N NI NA NE

8. Authorized Non-stormwater Discharges (Part 4.6.7) – list must be in SWPPP Y N NI NA NE

9. Evaluations and Inspections (Part 4.6.10)

A) Visual Site Inspections (minimum 4/year) (Part 4.6.10.1) Y N NI NA NE

At least one visual inspection conducted during a rain event Y N NI NA NE

Inspections recorded and include: date of inspection, person doing inspection; major observations, and corrective actions required.

Y N NI NA NE

B) Comprehensive Site Compliance Evaluation (Annual) (Part 4.6.10.2) Y N NI NA NE

Comments::

See page 7

SECTION C: MONITORING

PERMITTEE MONITORING MEETS PERMIT REQUIRMENTS S M U NA NE

1. Is the facility one of the four Effluent Guideline Facilities in the Permit? (Cement MFG, Fertilizer MFG, Steam Electric coal pile, or Paving and Roofing Materials)(Part 3.1.1)

Y N NI NA NE

A) Are all outfalls from the regulated process being sampled? (Part 3.1.3) Y N NI NA NE

B) If coal pile run off is monitored, are all other stormwater flows excluded? (Part 3.1.1) Y N NI NA NE

2 Which of the monitoring categories is this facility subject to: (Part 3.3) Y1

A) Are samples being collected for each semi-annual monitoring period (Part 3.5) Y N NI NA NE

B) Are samples being collected from the location specified in the NOI and SWPPP (Part 3.6) Y N NI NA NE

C) Has the permittee determined that some of the outfalls are similar? (Part 3.7.1) Y N NI NA NE

Are the conditions on the ground still the same as documented for the similar outfalls (Part 3.7.1) Y N NI NA NE

D) Are all parameters for the monitoring category being sampled and analyzed? (Part 3.7.2) Y N NI NA NE

E) Were the samples collected during a measureable storm event? (Part 3.7.2.b) Y N NI NA NE

F) Were the samples properly preserved and analyzed? (Part 3.7.2) Y N NI NA NE

G) Are the sample locations suitable for the collection of a representative sample? (Part 3.3) Y N NI NA NE

3. Has any of the monitoring revealed an exceedance of the benchmark values for this facility?(Part 3.11.2) Y N NI NA NE

A) Has a process to develop a corrective action plan been started within 30 days of exceedances? (Part 3.11.2)

Y N NI NA NE

B) If four monitoring periods have passed without an exceedance of a benchmark value, has the permittee requested a reduction in monitoring? (Part 3.11.1)

Y N NI NA NE

Comments:


NPDES Report

SECTION D: RECORD KEEPING AND REPORTING

PERMITTEE RECORD KEEPING AND REPORTING MEETS PERMIT REQUIRMENTS S M U NA NE

1. Have DMRs for the previous year of monitoring been submitted to ADEQ and is a copy in the file? (Part 3.12.3.a)

Y N NI NA NE

Are the DMRs properly completed? Y N NI NA NE

Does the permittee have copies of lab reports and chain of custody records? Y N NI NA NE

Are the appropriate records of the measureable storm event and sampling being kept? (Part 3.7.2.e) Y N NI NA NE

2. Has a copy of the annual comprehensive evaluation been submitted to the agency and is a copy on file? (Part 3.12.3.b)

Y N NI NA NE

3. Is permittee keeping copies of inspections and corrective actions on file? (Part 4.6.10.1) Y N NI NA NE

4. Are copies of training records being kept on file? (Part 4.6.6.6) Y N NI NA NE

5. Is there a list of significant spills and leaks being maintained? (Part 4.6.5.3) Y N NI NA NE

Comments: See page 7

SECTION E: FACILITY TOUR

PERMITTEE FACILITY TOUR MEETS PERMIT REQUIRMENTS S M U NA NE

1. Any evidence of spills or leaks that have not been properly cleaned up as required by the SWPPP? Y N NI NA NE

2. Any evidence of erosion or un-stabilized ground? Y N NI NA NE

3. Any controls, structures, or storage areas that are not as identified in the SWPPP? Y N NI NA NE

4. Any non-stormwater discharges not identified in the SWPPP? (see Part 1.7 of permit for list of allowable non-stormwater discharges)

Y N NI NA NE

5. Any non-stormwater discharges that are not allowed under this permit? (see Part 1.7 of permit for list of allowable non-stormwater discharges)

Y N NI NA NE

6. Are BMPs being properly operated and maintained? (Part 6.1) Y N NI NA NE

7. Are housekeeping procedures being implemented and are they sufficient? Y N NI NA NE

Comments: See page 7


NPDES Report

NPDES Compliance Inspection Report

Further Explanation

Section B: The Storm Water Pollution Prevention Plan (SWPPP) was not signed.

Section B.3A. The SWPPP needed to be updated to show current the current plant manager.

Sections B.9A & D.3 The facility did not have records of the quarterly visual inspections as

required by the permit and the SWPPP.

Section B.9.B: The facility did not have a copy of the annual comprehensive site compliance

evaluations for 2009 as required by the permit and SWPPP.

Section B.9.B: The facility has not replaced the rusted collection tank on the south side of the

building as noted in the facility 2010 annual comprehensive site compliance evaluation.

Sections B.7.F & D.4: The facility did not have copies of employee training records as

required by the permit and SWPPP.

Sections B.7.C & E.6 & 7: Housekeeping at the plant was inadequate. Specifically, trash,

barrels, buckets and etc. were noted strewn around the south side of the property.

Sections B. 7.E & E.6: The facility had 500 gallon totes of MEK and 55 gallon barrels of

various raw products stored outside without any type of BMP (such as containment) to

protect storm water discharges from being contaminated in case of a release.


NPDES Report

Water Division NPDES Photographic Evidence Sheet

Location: AMFUEL-Magnolia

Photographer: John Lamb Witness: None

Photo # 1 Of 5 Date: 10/26/2011 Time: 14:33

Description: Rusted out tank on south side of building. Comprehensive site compliance evaluation

performed in December 2010 stated this tank was to be replaced, tank still in service



Description: One example of trash on site, housekeeping needs improvement


NPDES Report





Description: Another example of poor housekeeping. Barrel of unknown material exposed, trash lying next

to barrel on left



Description: Full totes of MEK, exposed with no containment, on tow motor road way.


NPDES Report





Description: Barrels of raw products stored outside on tow motor road without containment.


Photo # Of Date: Time:

Description:

This slide intentionally left blank

AMFUEL

SWPPP(Storm Water Pollution Prevention Plan)

Industrial General Permit Number: ARR000000Permit Tracking Number: ARROOB815

AFIN #14-00040

December 2011

This is a “controlled” documentRoutine distribution is restricted to the approved

distribution in the Storm Water Pollution Prevention Plan. All otherpersons in possession of this document have uncontrolled copies

and should call document controlfor revision level status.

Prepared By:

sEA•I NC.SAFETY & ENVIRONMENTAL ASSOCIATES, INC.

Notice “id Disdain””Program Approval 4Stormwater Pollution Prevention Plan Certification SEnvironmental Professional’s Certification 5Introduction 6

Changes to Plan/Permit Expiration/Renewal/Transfer/Termination 6Facility Information 7Pollution Prevention Team 7Facility Description 8

Process DescriptionSeasonal Variation oSite Drainage 9

Potential Pollution Sources 16Industrial Activities 18Esposed Materials 18Risk Identification and Potential Pollutant Sources 19Spills and Leaks 20Illicit Discharges 20Sampling Data 20

Measures and Controls 21Best Management Practices 21Minimize uxnosHousekeeping/.

21inistrative Control 22

Preventative Maintenance 22Spill Prevention and Response 23Employee Training 24Erosion and Sediment Control 2SManagement of Run-on and Run-off 2SSaltStorage 2SAuthorized Non-Storm Water Discharges 26Impaired Water Bodies and Water Quality Standards 26

Evaluations and Inspections 26Quarterly Visual Site Inspections 26Annual Site Compliance Evaluation Program 27

Monitoring Sampling and Reporting Requirements 28Sampling Parameters 28Monitoring Periods 29Monitoring Location 29Similar Outfalls 29Sampling ProceduresCorrective Action for Results Exceeding Benchmarks 30Record & Reporting icequirements 30Records 30Monitoring/Sampling Record Contents 31Discharge Monitoring Reports 31Annual Report 31Other Best Management Practices (BMP’s).

Pigures. Tables, and Exhibits

Pigure 4

Table 1Table 2Table 3Table 4

Table 5Table 6Exhibit 1Exhibit 2Exhibit 3Exhibit 4Eshibit 5Exhibit 6Exhibit 7

ExhibitS

‘-‘ loooerannv Man

Precipitation/Humidity/Snowfall Graphs 15Inventory of Exposed Activities, Materials, and Pollutants 17Summary of Watersheds 18Summary of Sampling Data 20Annual Site Compliance Evaluation Schedule 28Sampling Parameters for Outfalls 004 and 008 28Storm Water Records Summary 31General Storm Water Permit Es-iPictures Ex-2Spill Log Porm Ex-3Example Quarterly Visual Inspection Report Form Ex-4Training Attendance Roster Form and Agenda Es-SExample Annual Site Compliance Inspection Form Es-6Notice of Intent Records and ADEQ Correspondence Ex-7Discharge Monitoring Resort 1DMR Records Es-S

Figure 1 Facility MapFigure 2 Aerial View of the FacilityPigure 3

33

1,

Is

Page 2

United States laws and Federal regulations published as promulgated are in public domain.However, the compilation and arrangement along with other materials in this documentare subject to the copyright notice.

All rights reserved. SEA client receives an agreement which grants them the right toreproduce any and all portions, in any quantity, provided the copies are distributed only toemployees of the organization that receives rights under this agreement, orrepresentatives of the employees who provide written request to the organization thatreceives rights under this agreement.

Due to the constantly changing nature of government regulations, it is impossible toguarantee absolute accuracy of the materials contained herein. SEA, therefore, cannotassume any responsibility for omissions, errors, misprinting, or ambiguity containedwithin this publication and shall not be held liable in any degree for any loss or injurycaused by such omission, error, misprint or ambiguity presented in this document.

This document is designed to provide reasonably accurate and authoritative informationin regards to the subject matter covered. It is given to the user in consideration forcompensation with the understanding that SEA is not engaged in rendering legal,accounting, or other professional service unless such services are agreed upon by bothparties.

Questions or comments may be addressed to:

Safety & Environmental Associates, Inc.P0 Box 22608Little Rock, AR 72221-2608Office #: 501-568-3111Fax #: 501-515-6212Internet: www.seainc.net

Page 3

r-j

1 C,,

cC ct

0 z S

—

0

1 S -

0—

.

cC-

<C

cm

cCg

r.

—z C-

,)

o‘

—v-.

(

-cc,

-c0

C-f)

CC

,,—

C-,)

—

C-f)

.::C

fCz C-

f) 01

r0

Cd,

<cC

(0cC 0

0 (0 0

0) z-

2_-

—-(

0

>0

1z

-CO

0) Cd,

-0) C’

,

c-fl

(-.3

> 0 0 C’

ft t-.3

4 t) c

(0 cm (0 cC (0 t’j

I.

-C C 0) 0 —C 0) ft

0 0 1 ft0 (0 -c

i0 0 0 00 -C C 00 -C

(1,

ft

0 -c 0) ft (0 1 0 C ft

0 0 1 (0 (0 0 ft 0 0 0) 0

I AmFuel. SWPPP 5 of 33Storm Water Pollution Pravention Plan RW,n No 002 nifiW Eflecoo o. 8/24/2004LNoed John Kelly, Vice President Operations vaoOate 12/8/2011 All Previous

‘T,ared er Safety & Environmental Associates, Inc. A P.*o NO.: 10-6098 Qoobty o,owod. AG

Storm Water Pollution Prevention PlanCertification

I certify under penalty of law that this document and all attachments were prepared under my direction orsupervision in accordance with a system designed to assure that qualified personnel properly gather andevaluate the information submitted. Based on my inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the information, the information submitted is, to thebest of my knowledge and belief, true, accurate, and complete. I am aware that there are significantpenalties of fine and imprisonment for knowing violations.

I/ (/

1bWfell.v. Vice President Operations 7 Date

Environmental Professional’s Certification

I, Mike Richardson, having examined the AmFuel facility, and being familiar with the provisions of ArkansasNPDES General Permit No. AR000000 attest that this Storm Water Pollution Prevention Plan, as it relates toaffected outfalls, has been prepared in accordance with good engineering practices. This Plan, as revisedJanuary 24, 2011, has been prepared based upon my examination of the site and upon operational,procedural, and product information provided to me by AmFuel. This certification is contingent upon thefact that all information supplied, up to the date of this certification, is unquestionably accurate and wasprovided in good faith. This certification in no way relieves the owner or operator of the facility of theirduty to prepare and fully implement this Plan and to modify the Plan in accordance with the permit as maybe appropriate. This certification is valid only if this page has the original signature of the environmentalprofessional present on it.

Signature //i71

Date /z—-H LI

AmFuel. DocumentNo.: SWPPP Page No 6 of 33Storm Water Pollution Prevention Plan Revis:onNo.: 002 nigal EffecSve Date 8/24/2004

Approved By: John Kelly, Vice President Operations Rev:sion Date: 12/8/2011 Supersedes. All PreviousPreparedBy: Safety & Environmental Associates, Inc. SEAProjectNo.: 10-6098 QualftyRevewedBy: AG

Introduction

This Storm Water Pollution Prevention Plan (SWPPP) was prepared in accordance with and follows therequirements of the Arkansas NPDES Industrial General Permit ARR000000 for storm water dischargesassociated with industrial activity at the AmFuel facility under ADEQ tracking number ARROOB815.Exhibit 1 contains a copy of the current General Permit (IGP).

SWPPP Availability (IGP Section 4.2)

A copy of this SWPPP is required to be maintained at the facility, and made immediately available to theADEQ EPA, or US Fish and Wildlife Service upon inspection or request.

Changes to Plan

The SWPPP must be amended whenever there is a change in:

1. Facility Design;2. Construction;3. Operational Practices; or4. Maintenance practices that could have a significant effect on the potential for the discharge of

pollutants to surface waters.

The SWPPP also must be revised if it proves to be ineffective in eliminating or significantly minimizingpollutants from the sources identified. This determination will be made as a result of the findings of sitecompliance evaluations to be performed in accordance with this SWPPP.

Permit Expiration/Renewal

This facility operated under the 2004 Industrial General Permit (IGP) for the State of Arkansas(ARR000000) through the appeal process of the 2009 IGP. At the close of the appeal 8/27/2010, the ADEQprovided a compliance schedule for transitioning to the new permit, with the Notice of Intent (NO!) due by12/10/2010, new sampling requirements to become effective 1/1/2011, and SWPPP revision required by1/31/2011.

This facility now operates under the 2009 IGP, issued 6/30/2009, with an expiration date of 6/30/2014.

Permit Transfer/Termination

If the AmFuel facility undergoes a change in ownership, facility name or signatory authorization (i.e. a newcognizant official, responsible person, etc.), a Permit Transfer Form must be submitted (30 days prior tothe date the change will take place) to the Arkansas Department of Environmental Quality (ADEQ) inaccordance with Part 2.6 of the permit.

If the AmFuel facility is closed, a Notice of Termination (NOT) must be submitted to the ArkansasDepartment of Environmental Quality (ADEQ) in accordance with Part 2.7 of the permit.

AmFuel. Document No.: SWPPP Page No.: 7 of 33Storm Water Pollution Prevention Plan Revion No 002 Inital Effecove Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision DatE 12/8/2011 Supersedes: All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA Protect No. 10-6098 Quatty Reviewed By AG

Facility Information (IGP Section 4.6.1)

Facility Name: AmFuel

Permit Tracking Number: ARROOB81SAFIN: 14-00040Physical Address: 601 Firestone Drive, Magnolia, Arkansas 71753

SIC Code: 3069 “Fabricated Rubber Products, NEC (except rubberized fabric andgarments, gloves, life vests, wet suits, accessories, such as bibs and bathingcaps, rubber toys, bags made from rubberized fabric, rubber diaper covers,and rubber resilient floor coverings)”

NAICS Code: 326299 “All Other Rubber Product Manufacturing”Sector: Yl

Specific points of contact regarding information within this plan and emergency response are:

Program AdministratorJohn KellyVice President Operations870-235-7346 (phone)John.Kellv(äzodiacaerospace.com

Pollution Prevention Team (IGP Section 4.6.2)

The Pollution Prevention Team will meet at least annually to conduct and/or review the Annual SiteCompliance Evaluation, and to address issues relating to storm water pollution prevention, to reviewDMRs, etc. Informal meetings of Pollution Prevention Team members takes place on a more frequent basisas a routine part of day-to-day work activity.

Records of the official Pollution Prevention Team meetings will be in the form of the completed Annual SiteCompliance Evaluation forms, DMRs, and other correspondence/reports as needed. Records will beretained for a period of at least five years with the site environmental files. Items to be covered duringmeetings include:

1. Status of plant modifications and their effect or potential effect on storm water;2. Status of preventive maintenance program;3. Feedback on training programs;4. Summary of recent annual site compliance evaluation;5. Summary and discussion of recent monitoring results; and6. Review of written procedures and inspections, as necessary.

TEAM DUTIES AND RESPONSIBILITIES

The Pollution Prevention Team member positions and responsibilities are listed below:

Storm Water Pollution Prevention Plan Administrator (Vice President Operations)• Ensure annual site compliance evaluations are completed, and participates in review;• Ensure quarterly site inspections are completed;• Ensure employee training is completed;• Ensure recordkeeping and report submittals are completed;

AmFuel. Document No.. SWPPP Page No.. 8 of 33Storm Water Pollution Prevention Plan Revision No: 002 ni5 Effevtjve Date 8/24/2004

Approved By. John Kelly, Vice President Operations Revson Date: 1218/2011 Siçersedes: All PreviousPrepuredBy Safety & Environmental Associates, Inc. SEAPrReCtNO. 10-6098 QaalityRcnewedBy: AG

• Ensure this SWPPP is kept updated as necessary, including site/process changes that could impactstorm water discharges;

• Ensure adequate response is taken in the event of a spill or release, and corrective actions are takenas needed to address spills, leaks, benchmark exceedences, etc.;

• Ensure the necessary resources are assigned and that the elements of this SWPPP are implementedas stated;

• Ensure required sampling/monitoring and analyses are completed and Discharge MonitoringReports (DMRs) are submitted in a timely manner;

• Review plant modifications and/or process changes that could impact storm water and/or requirea SWPPP update;

• Act as liaison between AmFuel Management and regulatory agencies; and• Act as “responsible corporate official” and provide required certification signatures for this SWPPP,

Discharge Monitoring Reports (DMR5), and annual Site Compliance Evaluation inspections.

Assistant Storm Water Pollution Prevention Plan Administrator (VP Operations Designee)• Participates and/or assigns resources as needed for annual site compliance evaluations, quarterly

site inspections, sampling/monitoring/analyses, training, recordkeeping, reporting, etc.;• Responsible for implementation and operation of preventive maintenance program, including

maintaining Best Management Practices (BMP5) outlined in this plan;• Monitors process modifications, physical plant modifications, and assesses potential impacts to

storm water; and• Other duties as assigned by SWPPP Administrator.

Environmental Health & Safety Consultants (SEA Inc.)• On-call for technical assistance and emergency response;• Conduct and/or participate in quarterly site inspections and annual site compliance evaluations;• Conduct and/or coordinate storm water sampling, coordinate analyses by state-certified lab;• Coordinate and/or prepare Discharge Monitoring Reports;• Develop and/or present Storm Water Pollution Prevention Training & other training;• Assist with developing and/or maintaining SWPPP and other required storm water compliance

records, making BMP and/or corrective action recommendations; and• Other duties as assigned by SWPPP Administrator.

Facility Description (IGP Section 4.6.3)

The AmFuel manufacturing facility is located in Magnolia, AR at 601 Firestone Drive, Columbia County,71753 (latitude 33° 16’ 44.47”, longitude -93° 14’ 49.68”) (see Figure 2). The site occupies approximately74 acres with only approximately 16 acres being used for manufacturing operations. Approximately 70%of the property used for manufacturing operations is impervious, consisting of the buildings, pavement andparking areas; the pervious portions of the property are primarily vegetated with turf grass and forest. Theproperty is bordered on the West by mostly undeveloped property; to the North is a small residential area,to the East is Hwy 371 and then a large residential area; and to the South is a industrial/commercial area.The initial receiving body of water is an unnamed tributary of Big Creek that flows in a southwesterlydirection to Big Creek, then to Dorcheat Bayou, then to the Red River in Segment IA of the RedRiver Basin.

. AmFuel. DocunlefltNo. SWPPP Page No,. 9 of 33Storm Water Pollution Prevention Plan ReoonNo.. 002 niEffiraeDate 8/24/2004

AyproeedBy John Kelly, Vice President Operations Rev,oon Date, 12/8/2011 Supersede AN PreviousPrepared By. Safety & Environmental Associates, Inc. SEA PreCtNO,: 10-6098 Quality Reoiewed By: AG

Process Description

The primary activity at AmFuel is manufacturing high efficiency loud speakers. AmFuel is classified underthe Standard Industrial Classification (SIC) Code 3069 “Fabricated Rubber Products, NEC (exceptrubberized fabric and garments, gloves, life vests, wet suits, accessories, such as bibs and bathing caps,rubber toys, bags made from rubberized fabric, rubber diaper covers, and rubber resilient floor coverings)”and NAICS code 326299 “All Other Rubber Product Manufacturing”. The site’s ADEQ Arkansas FacilityIdentification Number is (AFIN) 14-00040 and operates under Industrial Storm Water General Permittracking number ARROOB815, NPDES Individual Permit Number AR0000434, EPAID #ARD008049298, andTitle V Permit #0982-AOP-R1 The facility does not have a wastewater treatment system and nor are thereregulated storage tanks (RST) on site.

AmFuel is engaged in the manufacture of fuel cells and coated fabrics products used in the aircraft industry.Production of fuel cells involves the fabrication of rubber containers of various shapes and sizes to fit insidethe bodies of all types of aircraft. Plaster molds and cardboard forms are made first to build the fuel cell on.Panels of fabric are cut out using templates and placed into build kits. Each fuel cell has a specific set oftemplates designed just for that cell. Metal fittings are integrated into the fabric in a separate process andfitted onto the molds with the fabric. Cement, made from rubber stock, solvents (toluene, methyl ethylketone (MEK), and methyl isobutyl ketone (MIBK)), and adhesives is used to glue the various pieces offabric together. Fuel cells are made of layers of fabric in stages called inner liner and outer ply. Each layermay require a specific type of material molded to the form that is later sprayed with a coat of cement ornylon in a spray booth. The cell is then autoclave cured and the form removed from the cell by soaking withwater in the wash pit. The cell is then tested for structural integrity and proper fit, repaired as needed, andthen routed to final finish for packing and shipping. Towable drum production is identical to that of fuelcells, except that metal cylinders are used as forms and no spray operations are performed on the drums.

Oil related activities serve several purposes at the facility. Jet Fuel is stored in above ground storage tanksfor use in testing procedures for fuel cells manufactured at the facility. Fuel cell testing includes filling theproduction unit with fuel so that all internal surfaces are in contact with the fuel. Oils and lubricants arestored in drums and portable containers and are used in the operation and maintenance of equipment.Used oil collected at the facility is stored in drums and is picked up as needed by a vendor for appropriatedisposal. Also, equipment and machinery used in the production process at the facility contain hydraulicfluids and lubricants.

Once the completed fuel cell has been tested and has the quality inspectors’ approval, it is packaged fortransportation and loaded onto trucks for delivery to the customers.

Seasonal Variation

Production activities at the AmFuel facility are not affected by seasonal variations such as weather,temperatures and precipitation.

Site Drainage

The facility drainage areas have been identified from an evaluation of the site drawings and a visualinspection of the site. A site map has been developed to assist in the identification of the specific drainagesystems associated with the Am Fuel facility (see Figure 1). This map incorporates all facility structures,property boundaries, significant materials, exposed industrial activities, roads, drainages and topography.This map provides the basis for the SWPPP and will be updated as needed to keep the plan current.

AmFuel. 000umentNo SWPPP PageNo 10of33Storm Water Pollution Prevention Plan Revision No,: 002 InSal Effect,ae Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date. 12/8/2011 Supersedes. All PreviousPreparedGy. Safety & Environmental Associates, Inc. SEAProjeotNo.: 10-6098 QualityReviewedBy’ AG

Figure 1 denotes all outfalls and drainage areas for the AmFuel facility. Outfall 001 water does not derivefrom storm water and is permitted by the city of Magnolia. Outfalls 002 and 003 are Non-Contact CoolingWater outfalls permitted by ADEQ. These outfalls continuously flow when the “Rolling Mills” are in use.Though these outfalls become mixed with storm water during significant storms, they are notrepresentative of the sites storm water or the points for potential contamination. The storm water outfallsare identified as discharge Outfalls 004, 005, 006, 007, 008, and 009.

The facility drainage areas (watersheds) are identified on Figure 1 from an evaluation of surfacetopographies and a visual inspection of the site and contributing watersheds. There are six (6) storm waterwatersheds that have been identified at the site. These are numbered WS-1 through WS-5. Each watershedcorrelates with a numbered discharge point as referenced below.

Each watershed is unique with respect to its drainage pattern, industrial activities, and potential pollutants.Watersheds WS-1 through WS-6 are described in some detail here.

Watershed WS-1/Outfall 004 is located East of the Waste Building (Latitude 33 16 40.3176 / Longitude -931450.2296) and consists of approximately two (2) on-site acres. This watershed area consists of roofdrainage associated with the Southwest end of the main operations building, a grassy area, the WasteBuilding, and a 20-yard waste bin. This watershed flows mainly south into a grassy circular drain and theninto a drain pipe that mixes with Non-Contact Cooling Water prior to exiting Outfall 003. Industrialactivities that occur in this watershed are drum management and forklift operations.

Watershed WS-2/Outfall 005 is located on the western side of the main operations building (Latitude 33 1641.3508 / Longitude -93 14 54.9414) and consists of approximately .10 on-site acres. This watershed areaconsists of roof drainage associated with the West end of the main operations building, a 40 yard trashcompactor, and a small patch of grass and then into a storm water drain that discharges to the West from apipe approximately 20 feet into the wood line. Other than vehicle traffic and the trash compactor, there arenot any industrial activities in this watershed.

Watershed WS-3/Outfall 006 is located on the northwestern side of the main operations building (Latitude33 16 43.0464 / Longitude -93 14 54.0522) and consists of approximately .75 on-site acres. Thiswatershed area consists of roof drainage from the northwest section of the main operations building and asmall patch of grass and then into a storm water drain that discharges to the North from a pipeapproximately 20 feet into the wood line. Other than vehicle traffic, there are not any industrial activities inthis watershed.

Watershed WS-4/Outfall 007 is located on the northern center and northeast side of the main operationsbuilding (Latitude 33 16 43.5966 / Longitude -93 1441.751) and consists of approximately three (3) on-site acres. This watershed area consists of the roof drainage associated with part of the north center andnortheast section of the main operations building that drains into a pipe under the building that dischargeson the south side of the building into a grassy swale and then away from the property into an unnamedtributary of Big Creek. Other than vehicle traffic, there are not any industrial activities in this watershed.

Watershed WS-5/Outfall 008 is located in the south center of the south side of the main operations building(Latitude 33 16 41.8692 / Longitude -93 1444.1672) and consists of approximately 4.5 on-site acres. Thiswatershed area consists of miscellaneous parts storage (metals), the Fuel Cell dipping water vat, fuelstorage tanks, the fuel test building, a 40 yard trash compactor, concrete walkways, and small patches ofgrass. This watershed appears to flow to the South and then West through grassy swales and pipes leadingto the circular concrete accumulation drain just West of Outfall 001. Other than vehicle or forklift traffic,industrial activities performed in this watershed are fueling, the emptying of the Fuel Cell dipping water

AmFuel. DooumentNo: SWPPP PageNo.: 11 of 33Storm Water Pollution Prevention Plan Revision No.: 002 Inigal EffectNe Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date. 12/8/2011 Supersedes: All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA ProjeotNo: 10-6098 Qualty Reviewed By: AG

vat, trash management, and storage of metal parts.

Watershed WS-6/Outfall 009 is located is located in the south center of the south side of the mainoperations building (Latitude 33 16 40.7856 / Longitude -93 14 45.2472) and consists of approximately5.65 on-site acres. This watershed area consists of vehicle and forklift traffic, drum handling, potable waterdrainage, condensate from steam, waste management, and non-contact cooling water state permittedoutfall 002. This watershed appears to flow southeast and south through concrete and grassy swales anddischarging to the South away from the property. Other than vehicle or forklift traffic, industrial activitiesperformed in this watershed are drum management, waste management, potable water usage, and a noncontact cooling water discharge point.

AmFuel. Document No.: SWPPP PaeNo.: 12 of 33Storm Water Pollution Prevention Plan Revision No.: 002 flied Effective Date: 8/24/2004

Approved By John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes: All Previous, Prepared By. Safety & Environmental Associates, Inc. SEA Project No.: 10-6098 Quality Reviewed By: AG

Figure 1: Site Map (IGP Section 4.6A)

rt—-’--—--——---— ____3

“jIl

IrPUM

.:::: ‘ISI, a.. t a.w

u1?O/

Pc ‘T %-ç a—:::v /

Jed Z87 1A — •- Y-• \ I

-—tK FRH— —,rFettvrwo DOCF - —

UNIT- — \1ç” \

-. %,

-:

4.— ‘) @ $M Se’\

2‘•‘J ••Ø• ,// Q)= %P6 TO - e - 3TheDTUS

1g<‘

j.sw,.mr

-J’ .- ( : ,

Y7 V - / A . \

- • 7:-:

\\, //

- 1/ /

______

L i

_______

ir r AMFUEL PPC4 -- a •.• a a - , •u ‘ M f4 / -

I Ta.....

AmFuel. DocumentNo. SWPPP PageNo.: 13 of 33Storm Water Pollution Prevention Plan Revision No.: 002 lni Effective Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA Project No.: 10-6098 Duality Reviewed By: AG

Figure 2: Aerial Photo of Facility

I AmFuelSite

I

I

en

.40’

I

ta

4

* a.114:

Range 21.0W)Source: .mapcard.com (date 9 , J09, Section 11, Towns

AmFuel. Document No.: SWPPP Page No.. 14 of 33Storm Water Pollution Prevention Plan RsvisonNo 002 Iniu Effective Date: 8/24/2004

°o John Kelly, Vice President Operations Reviffon Date: 12/8/2011 Serseties All PreviousPrepareciBy: Safety & Environmental Associates, Inc. SEAProjectNo.. 10-6098 QuattyReniewedBy: AG

Figure 3: Area/Topography Map

Source: www.mapcard.com (scale 1:100,000, year 1978, Section 11, Township 17.OS, Range 21.0W)

AmFuel. DocumentNo.: SWPPP PageNo.: 15 of 33Storm Water Pollution Prevention Plan Revision No.: 002 InWal Effectrve Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes: All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA PrsjectNo.: 1 0-6098 Quality Reviewed By: AG

12m11 inlOin9 in8 in7in6 in5 in4 in3112 inliii0 in

CityAverage

Citymorning

Cityafternoon

US morningaverage

US almoonaverage

The average annual precipitation for the area is approximately 48.6 inches, and the average number ofrainy days per year is 80.5.

Figure 4: Precipitation/Humidity/Snowfall Graphs for Magnolia, Arkansas

Precipitation

f—[ I •i’i 1 i IJan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Humidity

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Snowfall

City

US average

Source: httu:/fwww.citv-data.com

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Source: httu://www.weatherbase.com

AmFuel. DocumentNo.: SWPPP Page No: 16 of 33Storm Water Pollution Prevention Plan Revision No.: 002 loigal Effecte Date. 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes All PreviousPreparedBy: Safety & Environmental Associates, Inc. SEAProjeotNo 10-6098 QualityReviewedey: AG

Potential Pollution Sources (IGP Section 4.6.5)

All manufacturing operations occur within buildings and are not exposed to precipitation or storm water.However, there are some material storage areas and other activities that may impact storm water runoff.All Material Safety Data Sheets were reviewed from the on-site files to provide a basis for potentialpollution identification. In addition, each process and storage area at the site was inspected and thecontents evaluated for their potential as pollution sources. All MSDS sheets are available for inspection atthe throughout the facility during normal plant operating hours. Chemical and equipment storage arelimited to five separate areas: 1) within the main manufacturing building; 2) within the cement room; 3) inthe tank farm storing the fuel; 4) in the metal roofed building used for drum storage of product and waste;and 5) in one of two fuel test buildings. See the Exposed Materials section for more information on the formentioned areas.

All land area was inspected for potential pollution sources as well as surface water drainage. Chemicalcompounds were identified both from the standpoint of the storage location at the facility and in referenceto the transport routes within the facility. The following discussion reports the findings of this inspectionand identifies potential pollution prevention sources of storm water runoff.

Material InventoryA material inventory and site inspection was initiated by AmFuel and conducted by Safety andEnvironmental Associates, Inc. (SEA, Inc.). SEA was escorted throughout the facility by AmFuel staff.This inventory consisted of identifying materials and areas that could potentially be a pollutant thatare stored or used at this site. AmFuel uses oil, solvents, cements, and surface coatings which arestored in 55-gallon drums in several locations throughout the facility. Hazardous waste drumscontaining waste oil, surface coating, cement, and solvent are stored in Watershed 1 (WS-1) withina covered “pole barn” which has secondary containment curbing and spill containment pits.Periodically, drums of various materials may be temporarily exposed while in storage transition.Fuel storage tanks are exposed outdoors but do possess secondary containment.

Table 1 lists the significant exposed materials that were observed during the facility inspection.Where practical best management practices (BMP’s) will be used to minimize, if not eliminate,contamination of storm water. Precautions have been taken to assure that none of these potentialcontaminants are allowed to affect the quality of storm water run-off.

Table 1 lists all the potential pollutants stored at the facility that are exposed to precipitation andstorm water run-off. All other potential pollutants are stored inside the plant buildings and do notcome into contact with storm water run-off.

AmFuel. Document No.: SWPPP Page No.: 17 of 33Storm Water Pollution Prevention Plan Revision No.: 002 Inited Effecdve Date. 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date. 12/8/2011 Supersedes All PreviousPrepared By. Safety & Environmental Associates, Inc. SEA ProjeciNo.: 10-6098 Quality Remewed By AG

Table 1- Inventory of Exposed Activities, Materials and Potential Pollutants

Storm WaterOutfall AffectedI Area Description

004 & 009 Hazardous Waste Management activities

004,005,006,Roof Drainage

007

005

007 & 009

008

008

008 Fuel Storage Tanks Oil & Grease

TSS, pH, COD

TSS, pH, COD

Potential Pollutants

TSS, COD, pH, Total Zinc

TSS

TSS, pH, COD

TSS, Oil and Grease

TSS, COD, pH

TSS, PH, COD

Trash Compactor

Vehicle and Forklift Traffic

Metal Parts Storage

Fuel Cell dipping process water vat

008 Trash Compactor

009 ?aterial Handling activities..

rPRECAUTION: Any construction project disturbing >1 acre of ground, requires prior development of aconstruction-specific SWPPP and submittal of a Notice of Intent (NOl) and fees to ADEQ for a storm waterconstruction general permit.

AmFuel. DocumeetNo: SWPPP PageNo 18of33Storm Water Pollution Prevention Plan Revsion No.: 002 Insial Effectrve Date. 8/24/2004

edBy: John Kelly, Vice President Operations Revision Date 12/8/2011 Supersedes: All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA ProiectNo.: 10-6098 Quartly Reviewed By: AG

Table 2

Summary of Watersheds

AmFuel --- Magnolia, Arkansas Facility

Non-Water Off-Site On-Site Pervious Pervious TotalShed Area Area Surfaces Surfaces Area NPDES

Number (Acres) (Acres) (Acres) (Acres) (Acres) Permit

WS-1 0 2 1 1 2 Storm Water

WS-2 0 .10 .03 .07 .10 Storm Water

WS-3 0 .75 .20 .55 .75 Storm Water

WS-4 0 3 .5 2.5 3 Storm Water

WS-5 0 4.5 .5 4 4.5 Storm Water

WS-6 0 5.65 1 4.65 5.65 Storm Water

Total 0 16 3.23 12.77 16

Industrial Activities (IGP Section 4.6.5.1)

General industrial activities at the facility include 1) Fuel cell manufacturing; 2) Drum handling; 3)Chemical transfers; 4) Trash collection; 5) Outdoor storage of empty drums; 6) Forklift maneuvering, and6) Hazardous waste storage.

Exposed Materials (IGP Section 4.6.5.2)

Typical materials handled at the site include 1) Oil; 2) Fuel; 3) Various Solvents; 4) Cement (glue); 5) Emptydrums, 6) Waste containers, 7) Trash dumpster; 8) Pallets; and 9) Miscellaneous scrap metals (parts).Additional information has been provided below.

1. The main manufacturing building is enclosed to prevent exposure of the manufacturingoperations and chemicals to precipitation and storm water. Chemicals within the building aregenerally limited to drums and containers of solvents, surface coatings, and adhesives. While thereis no direct exposure, a liquid could be released to the outside since the building is not equippedwith secondary containment.

2. The cement room is enclosed to prevent exposure of the manufacturing operations and chemicalsto precipitation and storm water. Chemicals within the building are generally limited to drums and

AmFuel. Document No.: SWPPP Page No 19 of 33Storm Water Pollution Prevention Plan Resision No, 002 meal Effectiue Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date. 12/8/2011 Supersedes, All PreviousPrepared B Safety & Environmental Associates, Inc. s Prolect No.: 10-6098 Qual Revievied By: AG

containers of adhesives. The adhesives have a high viscosity and there is little likelihood that a spillof adhesive would be released to the outside.

3. Fuels are stored in above ground storage tanks for use in testing procedures for fuel cellsmanufactured at the facility. The tank farm has sufficient secondary containment for the stored fueland free board. Fuel is delivered to the facility approximately once per annual. The fuel deliveryarea is sloped so that any spilled fuel will drain into the secondary containment of the tank farm. Aspill or leak of fuel from the fuel storage tanks would not be released to the outside.

4. The metal shed is roofed to minimize exposure of the drums and containers of products and drumsof waste from precipitation and storm water. The only exposure to precipitation would be if rainwere blown in. The shed is equipped with secondary containment and the floor slopes to two blindsumps. A spill or leak from within the metal shed would not be released to the outside.

5. Fuel cells manufactured at the Amfuel facility are tested at one of the two fuel cell testing sites forleaks and structural integrity by filling the cells with fuel and/or water. The testing is performed inone of two fuel test buildings. All testing using fuel is performed in one building and all testing withwater is performed in the other. The testing with fuel occurs in the building adjacent to the fueltank farm. This building is enclosed to prevent exposure of the testing procedure and fuel toprecipitation and storm water. The building also has sufficient secondary containment and any spillor leak from within this building would not be released to the outside. The testing with wateroccurs in the building due east from the fuel test building. This building also has secondarycontainment and any spill or leak from within this building would not be released to the outside.The water does not contain any product or waste and is disposed of through the city water system.

6. There are other potentials for materials to be exposed to precipitation and storm water duringnormal operations. These include spills when unloading chemicals from delivery trucks and spillswhile transporting chemicals between the storage unit and the production or testing buildings.Materials management practices employed to minimize contact of these materials with storm waterrunoff are discussed in later sections, including the location and description of existing structuraland nonstructural control measures to reduce pollutants in storm water runoff.

Risk Identification and Potential Pollutant Sources (IGP Section 4.6.5.5)

Each of the activities and exposed materials listed in Table 1 are potential pollutant sources forparticulates (i.e. Total Suspended Solids/TSS) with some potential for pH impacts, Oil and Grease, andChemical Oxygen Demand (COD) as well.

The greatest risk of release of pollutants from the Amfuel facility to areas exposed to precipitation, or thatmight otherwise drain to a storm water conveyance, comes from the liquid chemical storage areas. Liquidstorage management practices are utilized to minimize the possibility of release of pollutants.

Drums and containers of solvents and hazardous waste (spent solvents) are stored in the metal shed and inthe main manufacturing building. In general, no more than 75 55-gallon drums are stored in the shed and25 55-gallon drums are stored in various locations of the manufacturing maximum spill would be 55gallons. Such an accident could occur while in storage, during truck unloading when delivered, duringtransfer to the building from storage, or within the manufacturing building during use. A spill duringstorage or within the metal shed would be captured within the secondary containment and would notresult in a release. The secondary containment, including the blind sumps, is designed to hold the entirecontent from the maximum number of drums stored in the shed plus precipitation.

Likewise, a spill or leak occurring within the tank farm would be captured within the secondarycontainment and would not result in a release. The secondary containment around the tank farm isdesigned to hold the entire content from the tanks plus precipitation. The containment is also designed to

. AmFuel. Document No.: SWPPP Page No.: 20 of 33Storm Water Pollution Prevention Plan Revision No: 002 Inigal Effectr,e Date. 8/24/2004

AtnprosedBy: John Kelly, Vice President Operations Revision Data 12/8/2011 Supersedes: AU Previous, Prepared By: Safety & Environmental Associates, Inc. SEA Project No: 10-6098 Qoalvy Rev,ewed By. AG

allow the trucks delivering product to park over a slanted driveway designed to funnel any spill or leakoccurring during unloading into the secondary containment of the tank farm.

Both fuel-testing buildings have secondary containment sufficient to contain any spill or leak within thebuildings. The maximum spill that could be expected within the manufacturing building or during transferbetween the metal shed and the manufacturing building would be 55 gallons. This volume would not besufficient to reach the waters of the State. However, if such an event occurred during a rainfall event orsoon after one, it is possible that pollutants would reach waters of the State. In this event, the pollutant ofconcern would be biochemical oxygen demand. Dilution would cause the impact to be minimum. In theevent of spill occurring outside of a secondary containment, additional preventative measures would beemployed including the use of booms to prevent the spill from leaving the Amfuel property and enteringinto the waters of the State.

Spills and Leaks (IGP Section 4.6.5.3)

There have been no known spills or leaks of significant toxic or hazardous materials at the AmFuel facilitywithin the last five (5) years. Facility staff searched the files at the facility for any reference to such spills orleaks and the facility management was interviewed regarding such events. No visible evidence of spills orleaks was identified.

Illicit Discharges (IGP Section 4.1)

The site was evaluated for non-storm water discharges on December 14, 2010. Visual observation ofprocess areas and storm drainage ditches during dry weather was the method used to identify non-stormwater discharges. Areas of direct observation included those areas where process and storage operationsare located and related activities occur. No illicit discharges were observed. Measures to identify illicitdischarges include routine observations during work activities, quarterly inspections, and an annualcompliance evaluation. If potential non-storm water discharges are identified in the future, a correctiveaction will be initiated, and the SWPPP will be updated accordingly.

Sampling Data (IGP Section 4.6.5.4)

Below is a summary of existing sampling data for storm water discharges from the facility. Space isprovided below for sampling data collected from lab reports during the term of this permit. DMRs will bemaintained with this SWPPP and/or in the facility’s environmental files.

Table 3- Summary of Sampling Data

COD TSS

AmFueF. DocsmentNo SWPPP PageNo.: 21 of 33L Storm Water Pollution Prevention Plan Reason No 002 InWal Effeotne Date: 8/24/2004

Approsed By: John Kelly, Vice President Operations Reaiaon Date. 12/8/2011 Supersedes: All PreviousPtepared By Safety & Environmental Associates, Inc. s Prnect No 10-6098 Osao RenAed By. AG

Measures and Controls (IGP Section 4.6.6)

The permit requires that the SWPPP describe storm water management controls appropriate for thefacility and then to implement them. Appropriateness and priorities of controls is determined by thepotential sources of pollutants at the facility and results of sampling. Structural and administrative controlmeasures will be reviewed during routine site inspections and if not achieving their intended effect ofminimizing pollutant discharges, the control measures must be modified expeditiously.

Existing Environmental Management Plans

The AmFuel facility presently follows additional safety and environmental programs that haverelevance to the SWPPP. The most important of these programs are the Spill Prevention Controland Countermeasure Plan, the Hazard Communication Program, and the contingency planning andRCRA training programs. Where overlap between these programs and the SWPPP exists, the goals,programs and personnel will be incorporated into the SWPPP without modification to the existingplans. An attempt will be made not to duplicate efforts where tasks are shared between programs.

Structural Control MeasuresStructural control measures are designed to reduce the potential for storm water pollution fromindustrial materials stored at the site. Structural control features have been installed at the facility.Roof drains provide controlled drainage and are directed to the various storm water discharges atthe site. Some of the roof drains discharge into a common pipeline where is combined water isdischarged into a collection pit and then discharged to the outfall.Throughout the facility, potential pollutants are stored inside and on concrete floors. Wherepossible, no potential contaminants will be directly exposed to precipitation and/or storm waterrunoff.Storm water at the facility does not require treatment prior to release. Good housekeeping,however, is essential in maintaining high quality site runoff. Normal housekeeping activities thatreduce the potential for contaminants to enter the storm water stream includes observing strictmaterials handling practices, maintaining a clean and litter free work environment, and randominspections of the facility to identify potential contaminants that might enter the surface water flow.AmFuel believes that to reduce the potential for surface water contamination will first require areduction in the exposure of site materials to precipitation. AmFuel, therefore, is attempting toprovide shelter from precipitation to as many potential pollution sources as possible.

Best Management Practices (BMPs)(IGP Section 4.6.6.1)

1. When practical, areas that store or possess “exposed” chemicals will maintain secondarycontainment.

2. Storm water contact with potential pollutants is minimized where possible by storing drums instorage buildings.

3. Chemical storage areas are routinely inspected for signs of leakage, spills, deterioration, and goodhousekeeping.

4. Some of the storm water runoffs travel through vegetated swales which serve as natural filtersbefore discharging from the AmFuel property.

Minimize Exposure (IGP Section 4.6.6.2)

1. The most serious potential pollutants identified at the facility are stored under cover to eliminateexposure and most of them have some form of secondary containment which provides further

AmFuel. DocumentNo.. SWPPP Page No.: 22 of 33Storm Water Pollution Prevention Plan Revision No 002 lnit Effectn,e Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date 12/8/2011 Supersedes: All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA ProectNo,: 10-6098 Quality Reneed By, AG

protection.2. Areas used for outdoor storage are periodically inspected.3. The facility has an established housekeeping program.

Housekeeping/Administrative Controls (IGP Section 4.6.6.3)

Housekeeping is a continuous practice carried out at the facility. Housekeeping is a major managementobjective, and it is AmFuels intent to minimize and regularly remove materials, which are exposed to windand rainfall. Elements of the site housekeeping program related to storm water management include, butare not limited to the following:

1. The solid waste dumpsters at the facility are emptied on a regular basis and the contents are takenoff-site for disposal by South Arkansas Recycling. AmFuel personnel notify the disposal servicewhen the dumpster is nearly full.

2. Long-term storage of out-of-service or other equipment shall be minimized. When possible, thismaterial shall be covered with tarps. Equipment that is stored outdoors shall be drained ofhydraulic fluid and cleaned as needed prior to storing outside.

3. Containerized liquid raw materials are primarily stored and used indoors.4. Storage of containers of liquids will be indoors and/or under roof.5. Empty drums that are stored outdoors prior to being picked up for recycling, are checked to be sure

they are empty, and are stored with lids/bungs in place.6. Areas of the facility exposed to storm water shall be kept free from debris and other waste. Outside

areas shall be maintained in a clean and orderly fashion. Trash barrels are provided for use inemployee parking and break areas to minimize loose litter that could reach drainage areas.

7. The ditch system shall be cleaned as needed to minimize the accumulation of debris.

Operation & MaintenanceOperation and maintenance practices ensure that processes and equipment are working well.Operation and maintenance housekeeping at the AmFuel facility include the following activities:

1. The facility maintains dry and clean surfaces by using brooms and shovels.2. Garbage and waste materials are collected and put into a solid waste container.3. Regular maintenance is performed on all production equipment.4. Routine inspections are conducted for leaks or conditions where raw materials, intermediatematerials, waste materials or products could lead to unintended discharges or make contact withstorm water.5. Training is provided on spill-reporting procedures.6. To assist in the minimization of unauthorized access to potential storm water pollutants such assolvents/hazardous waste, the facility has a perimeter fence that connects to the operationsbuilding. Perimeter doors on the operations building that serve as access points to the public aresecure during operational hours.

Preventative Maintenance (IGP Section 4.6.6.4)

A preventive maintenance program has been implemented involving inspections and maintenance of stormwater management devices. The inspections and testing of plant equipment and systems will be thecatalyst to uncover conditions that could cause breakdowns or failures that may result in a discharge ofpollutants to surface waters.

AmFuel. Document No. SWPPP Page No.. 23 of 33Storm Water Pollution Prevention Plan RevmionNo 002 lnifial Effecdve Date 8/24/2004

Approved 8y. John Kelly, Vice President Operations Revision Date 12/8/2011 Supersedes All PreviousPrepared By Safety & Environmental Associates, Inc. SEA PrOJeCtNO. 10-6098 Qualdy Reviewed By AG

Most of the machinery containing potential storm water pollutants at the AmFuel facility are not in alocation where a breakdown would threaten storm water with contamination. Therefore preventivemaintenance is not a crucial element of this facility’s Storm Water Pollution Prevention Plan but is stillconsidered an important element.

Spill Prevention and Response (IGP Section 4.6.6.5)

Establishing standard operating procedures such as safety and spill prevention procedures along withproper employee training can reduce accidental releases. Avoiding spills and leaks is preferable to cleaningthem up after they occur. Since chemical mediums have been identified, and most are stored within a spillcontainment area, a spill within any of those areas would be contained. The facility Emergency Action Plan,Contingency Plan, or Spill Prevention Control and Countermeasure Plan should be consulted in the event ofan uncontrolled spill. At a minimum, the following activities will be performed in the event of an accidentalrelease:

1. Identify the material and the source of the spill,2. Reduce or eliminate the source if possible,3. Contain the spilled material using soil berms, booms, absorbent material, etc. to prevent contact

with floor drains, outside drainage/discharge areas, etc.,4. Collect and dispose of spilled material in an appropriate manner (i.e. impervious concrete floors

will be wiped clean/dry, pervious dirt/gravel surfaces would be shoveled up to collect all wet ordiscolored material),

5. Make appropriate internal and external notifications (i.e. determine if RQ/reportable quantity isexceeded, etc.).

The SWPPP Administrator will maintain a spill log to document spills and leaks that occur at the facility.The spill log is located and maintained in Exhibit 3.

Spill kits and/or absorbent materials will be maintained in the following locations throughout the plantsite:

1. Hazardous Waste Storage Shed

In the requirement of a significant spill or leak, SEA Inc. will be available 24/7 to advise by telephone, andto assist with cleanup services, or referral to another qualified cleanup contractor (see below).

Emergency Response & Other Contractor Phone Numbers:

Safety & Environmental Associates, Inc. (SEA, safety & environmental consultants)24-hour Phone: 888-627-8740 or Office 501-568-3111

Rineco (hazardous waste transportation & disposal contactor)Contact: Bob Crawford or Marsha TisdalePhone: 501-778-9089 or 800-377-4692

Material Storage PracticesImproper storage can result in the release of materials and chemicals that can contaminate stormwater run-off. Proper storage techniques being implemented at the site include:

1. Adequate space to facilitate material transfer.2. Containers, drums and bags are stored away from direct traffic routes to prevent accidental spills.

AmFuel. Document No SWPPP Page No.: 24 of 33Storm Water Pollution Prevention Plan Reosion No: 002 Inidal Effectree Date: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA Prolect No 10-6098 Qualdy Reutewed By: AG

3. Containers of hazardous materials and waste are properly labeled to identify the contents andtheir hazards.4. Containers are stacked according to manufacturers’ instructions to avoid damaging thecontainers from improper weight distribution.5. Containers are stored on pallets or similar devices, when stored on the ground, to preventcorrosion of the containers, which can result when containers come in contact with moisture on theground.6. The responsibility of hazardous material inventory is assigned to a limited number of people whoare trained to handle hazardous materials. Appropriate drum handling equipment is provided suchas drum dollies and drum grabber forklift attachments.7. The centralized dust collection system discharges into a sealed roll-off container to preventfugitive discharge of dust/particulates, and is picked up for off-site recycling/disposal on a regularbasis to avoid overflow conditions.8. Plant trash is placed in a trash compactor with a sealed roll-off container that prevents contactwith precipitation.9. RCRA-empty 55-gallon drums are stored with bungs tightly in place, and empty drums are storedon their sides to prevent pooling of precipitation on the tops that could either contaminate thedrums or come in contact with residues on the drum tops.10. No plant trash is allowed in the scrap wood/wood panel roll-off container.11. All drums are closed according to the manufacturer’s closure instructions. Should closureinstructions not be immediately available, drums shall be closed according to industry standard forthe drum type and closure type until the correct closure instructions can be obtained.

Material Inventory Procedures

Keeping an up-to-date inventory of all materials present on the site will help to keep material costsdown, track how materials are stored and handled on-site, and identify which materials andactivities pose the most risk to the environment. The following procedures will be continuouslyadhered to at the facility:

1. An inventory of updated MSDS’s for those chemicals stored at the site;2. Containers will be labeled to show the name and type of chemicals as required by OSHA’s 29 CFR1910.1200 Hazard Communication Standard; and3. Hazardous materials that require special handling, storage use and disposal considerations shallbe clearly marked, accordingly.

Material Handling Procedures and Storage RequirementsAmFuel is continuously developing material handling procedures and storage requirements. Thefollowing activities have been identified as important and have been implemented at the site.

1. Effective housekeeping practices have been adopted by the AmFuel facility;2. Regular visual inspections to identify signs of wear on drums, containers, storage shelves, berms,sawdust and trash roll-off containers, etc., and to identify inadequate housekeeping or other cluesthat could lead to potential spills have been implemented; and3. Materials transfer procedures that reduce the chance of leaks or spills have been instituted.

Employee Training (IGP Section 4.6.6.6)

Employee training is essential to effective implementation of the SWPPP. The purpose of the trainingprogram is to teach personnel, at all levels, the responsibility, components and goals of the SWPPP. When

AmFuel. DocamentNo.: SWPPP Page No,: 25 of 33Storm Water Pollution Prevention Plan RevonNo,. 002 nigal Eftectrac Date 8/24/2004

Approved By: John Kelly, Vice President Operations Rovoon Date: 12/8/2011 Sapersedera All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA Project No 10-6098 Quatty Reaiewed By: AG

properly trained, personnel are more capable of preventing spills, responding safely and effectively to anaccident if one occurs and recognizing situations that could lead to storm water contamination.

A full employee-training program for site safety and health is already in place. The SWPPP program will beinstituted as a portion of this existing program. Good Housekeeping and Material Handling Practices will beconveyed to all employees during normal facility meetings. New employees receive an initial trainingsession at the commencement of their employment. Storm Water Plan training occurs annually.Attendance rosters and agendas from the training sessions will be maintained on file with departmenttraining records. An example of a storm water awareness outline is included in Exhibit 5.

Topics to be discussed at training sessions may include:

1. Explanation of storm water pollution;2. Locations of storm water outfall points affected by various operations;3. Identification of potential storm water pollution sources;4. Review of plan components;5. Spill reporting and response procedures; and6. Employee responsibilities related to minimizing potential storm water impact.

In addition to the formal training sessions, bulletin boards are located near time clocks, break areas, officeareas, and can be utilized to communicate information concerning housekeeping and other storm waterpollution issues.

Additional training conducted at AmFuel that may overlap with storm water BMPs, include but is notlimited to the following:

• Spill Prevention Control and Countermeasure (SPCC);• RCRA/Hazwaste Awareness;• DOT Hazmat Handling; and• OSHA Hazcom.

Erosion and Sediment Control (IGP Section 4.6.6.7)

The facility is relatively flat with some gentle sloped areas. For this reason sedimentation and erosion arenot an issue at the AmFuel facility. As shown on the site map, a portion of the facility in which industrialactivity occurs is paved, but vegetated drainages and underground piping generally control runoff from thesite. Within the facility there is a large percentage of the area open to storm water runoff. This area islocally drained to the vegetated drainages. Where possible, the exposed ground surface is re-vegetatedwhen denudation from storage or heavy traffic occurs.

Management of Run-on and Run-off (IGP Section 4.6.6.8)

AmFuel currently uses traditional storm water management techniques in controlling runoff. Vegetatedswales, catch basins, piping, and other controls are shown on the facility site map (Figure 1).

Salt Storage (IGP Section 4.6.6.9)

AmFuel does not maintain exposed storage piles as addressed by this section of the permit.

AmFuel. DocunentNo SWPPP PageNo. 26of33Storm Water Pollution Prevention Plan Revi&onNo: 002 InitEffecweDale 8/24/2004

APProved By. John Kelly, Vice President Operations Revioon Date: 12/8/2011 Supersedes All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA Pr*ctNo: 10-6098 QuatyReewedBy: AG

Authorized Non-Storm Water Discharges (IGP Sections 1.7 and 4.6.7)

A certification is provided on page 5 of this SWPPP that the site has been evaluated and has no illicit non-storm water discharges. The general permit authorizes the following specific types of non-storm waterdischarges.

1. Discharges from emergency firefighting activities;2. Fire hydrant flushing;3. Potable water sources including water line flushing’s;4. Runoff from irrigation using non-process water;5. Landscape watering provided all pesticides, herbicides, and fertilizers have been applied in

accordance with the approved labeling;6. Routine external building wash-down which does not use detergents;7. Pavement wash waters where spills or leaks of toxic or hazardous materials have not occurred

(unless all spilled material has been removed) and where detergents are not used;8. Air compressor condensate;9. Steam condensate;10. Uncontaminated condensate from air conditioners, coolers, and other compressors and from the

outside storage of refrigerated gases or liquids (such as the discharge of thawed condensate fromthe surface of liquid nitrogen tanks stored outdoors);

11. Incidental windblown mist from cooling towers that collects on rooftops or adjacent portions of thefacility, but not intentional discharges from the cooling tower (e.g., “piped” cooling tower blowdown or drains);

12. Uncontaminated groundwater or spring water (see turbidity note in IGP);13. Foundation/footing drains where flows are not contaminated with process materials such as

solvents (see turbidity note in IGP);14. Excavation dewatering (see turbidity note in IGP); and15. Non-process water used for dust suppression on roads.

Impaired Water Bodies and Water Quality Standards (IGP Sections 4.6.8-9)

To the best of the permittee’s knowledge, storm water that discharges from this site does not enter a waterbody that is on the most recent 3 03(d) list of impaired water bodies, or with an approved Total MaximumDaily Load (TM DL).

Evaluations and Inspections (IGP Section 4.6.10)

Quarterly Visual Site Inspections (IGP Section 4.6.10.1)

In accordance with the requirements of the general permit, qualified personnel shall conduct routinefacility inspections of the AmFuel facility at least four (4) times per year, to visually review the outfall andall storm water control measures used to comply with the permit.

These will typically be completed by a member of the Storm Water Pollution Prevention Team or aconsultant on a quarterly basis. A blank copy of the “Storm Water Quarterly Visual Inspection Form” isincluded as Exhibit 4, which outlines the required scope, and will serve as the required record, and shouldbe kept on-site with the SWPPP.

These inspections are part of the facility’s preventive maintenance program. Inspection items will includeexisting storm water drainage control measures, spill response equipment, and general housekeeping.

AmFuel. DocumentNo. SWPPP Page No,. 27 of 33Storm Water Pollution Prevention Plan RoaoonNO.: 002 InEffect,veDate. 8/24/2004

ApprooedBy. John Kelly, Vice President Operations Revon Date 12/8/2011 Supersedes All PreviousPrecareJBy Safety & Environmental Associates, Inc. SPrectNo.. 10-6098 Quatty Reviewed By. AG

Records of inspections will be maintained at the facility. In the event problems or concerns are documentedduring quarterly storm water inspections, follow-up of the resolution must also be documented to showtimely corrective action was taken. In the event recurring problems are discovered during quarterly stormwater inspections, the facility may consider increasing the inspection frequency until the issue(s) isresolved.

Wet Weather: At least one of the four inspections must be conducted during a period when storm waterdischarge is occurring to visually look for the presence of floating materials, visible sheen, discoloration,turbidity (cloudiness), odor, etc.

Dry Weather: At least one of the four inspections must be conducted during a period of dry weather tocheck for the presence of illicit non-storm water discharges (such as domestic wastewater, non-contactcooling water, or process wastewater that are not authorized by the permit).

Annual Site Compliance Evaluation Program (IGP Section 4.6.10.2)

In accordance with the requirements of the general permit, qualified personnel shall conduct sitecompliance evaluations no less than once per year. These evaluations will typically be completed by amember of the Storm Water Pollution Prevention Team or a consultant. At a minimum, annual sitecompliance evaluations will be performed under the guidance of the SWPPP Administrator or designee.Other team members and plant personnel will provide input as required to facilitate compliance with thepermit. All members of the team will participate on an as needed basis to implement any physical andprocedural changes identified during the inspection.

A blank copy of the EPA’s Multi-Sector General Permit “Annual Reporting Form” is included as Exhibit 6,which outlines the required scope of the Site Compliance Evaluation. Note: This form is not required bythe EPA or ADEQ, and should not be submitted to the EPA, but can be utilized as a tool to document theAnnual Site Compliance Evaluation.

The Annual Site Compliance Evaluation must generally include:• Visual inspection of areas contributing to a storm water discharge for evidence of (or the

potential for) pollutants to enter the drainage system.• Evaluate measures in place to determine if they’re adequate and properly implemented,

or if additional control measures are needed.• Observe structural storm water management measures, sediment and control measures

identified in the plan for adequacy.• Visually inspect spill response equipment for adequacy.• Assess compliance with the terms and conditions of the permit.• Review and confirm the accuracy of the Plan’s description of potential storm water

pollution sources at the site.• Review previous year’s sample results, compliance with benchmarks, and any related

corrective actions.• Determine the effectiveness of the Plan in controlling these sources by reviewing the site

for any physical or procedural changes that may impact storm water.• If the inspection determines improvements are needed, the SWPPP must be revised

within 30 days, and changes must be implemented within 90 days.• A report summarizing the Annual Site Compliance Evaluation must be signed/certified.

AmFuel. Document NO.: SWPPP Page No: 28 of 33Storm Water Pollution Prevention Plan Revision No.. 002 InidaIEBecteDate: 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/201 1 Supersedes: All PreviousPrepared By Safety & Environmental Associates, Inc. SEA PrcgectNo 10-6098 Osaaty Rua,emed so AG

Employee Participation

1. Incorporation of information sessions on good housekeeping practices into the facility’s employeetraining program. Practices to be discussed will include; solid waste elimination and removal,container storing, handling and labeling, record keeping and inspections.

2. Discussing good housekeeping and need to consider potential storm water pollution at employeemeetings.

3. Train management personnel and others responsible for outside areas in methods to preventpollution discharges to storm waters.

Table 4 summarizes the requirements associated with the annual compliance evaluation and the deadlinesfor achieving each requirement.

Table 4 — Annual Site Compliance Evaluation Schedule for AmFuel

Item Schedule

Previous Year’s Sample Results Review Prior to inspection

Annual Site Compliance Investigation (Checklist IsPrior to inspectionLocated In Exhibit 6)

Plan Revisions (Identified By Annual Inspection) Within two weeks following the inspection

Procedural/Physical Changes (Identified By AnnualWithin twelve weeks following the inspectionInspection)At least every 5-year permit cycle or after significantPlan Review/Recertificationmodifications to facility

Monitoring, Sampling and Reporting Requirements

IGP Part 3 specifies “Monitoring and Reporting Requirements” specifies the sampling parameters andreporting requirements for the facility. Numeric Effluent Limitations Guidelines (ELG) do not apply to thefacility.

Sampling Parameters (IGP Section 3.3 and 3.9)

The AmFuel facility is not subject to additional parameter benchmark monitoring under the “Sectors”provided in the 2009 Industrial Storm Water General Permit (based on facility SIC Code 3651 for“Household Audio and Video Equipment”). Benchmark value concentrations are not effluent limitations(i.e. not permit “limits”), but are provided in the general permit for use in determining effectiveness ofcontrol measures and knowing when corrective actions may be necessary to comply with permitrequirements.

Table 5 — Sampling Parameters for Outfalls 004 and 008Effluent Characteristics (Parameters) Sample Type Parameter Benchmark ValuespH Grab 60—9OsuChemical Oxygen Demand (COD) Grab 120 mg/ITotal Suspended Solids (TSS) ii Grab 100 mg/lQil & Grease Grab 15 mg/ltal Zinc Grab 0.684 mg/l

AmFuel. 000umeniNo SWPPP PageNo.: 29 of 33Storm Water Pollution Prevention Plan Revision No.. 002 lnigalEffectweDate: 8/24/2004

Approved By John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedee All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA Project No.: 10-6098 Quality Reviewed By. AG

Monitoring Periods (IGP Section 3.5)

The monitoring and reporting period is from January 1 to December 31. The facility must monitor at leasttwice during the calendar year (beginning 1/1/2011), with one sample taken in each of the following timeframes:

• Januaryl—June3O• July 1 — December 31• Additional Monitoring (IGP Section 3.12.4)

Note: if the permittee monitors any pollutant or outfall more frequently than required by thispermit, using test procedures specified in this permit, then the results of this monitoring shall alsobe included in the Discharge Monitoring Report.

Monitoring Location (IGP Section 3.6)

The AmFuel facility will monitor at Outfalls 001 and 003 as near as practical to the point it leaves theproperty, before the storm water joins or is diluted by any other waste stream.

Similar Outfalls (IGP Section 3.7.1)

Upon review of the facility activities and the potential pollution hazards for each outfall, the AmFuel facilityhas the following similar outfalls:

1.) 004, 005, 006 and 007; and2.) OO8andOO9.

Sampling Procedures (IGP Section 3.7.2)

Samples and measurements shall be representative of the volume and nature of the monitored discharge.If unable to sample during a monitoring period, a justification must be submitted with the DischargeMonitoring Report for that period.

Grab Sample (IPG Section 3.7.2 a)A minimum of one grab sample must be taken from the outfall within the first 30 minutes of adischarge resulting from a measurable storm event. If it is not possible to collect within the first 30minutes, the sample must be collected as soon as practicable and documentation kept with theSWPPP explaining why it was not possible to collect within the first 30 minutes.

Measurable Storm Event (IPG Section 3.7.2b)All required monitoring must be performed on a storm event that results in an actual dischargefrom the site (“measurable storm event”, or “qualifying storm event”) that follows the precedingmeasureable storm event by at least 72 hours (3 days).

Adverse Weather Conditions (IPG Section 3.7.2c)In the event weather conditions are dangerous or create inaccessibility and prevent the collectionof samples according to the relevant monitoring schedule (i.e. local flooding, high winds, lightning,hail, drought, extended frozen conditions, etc.), then a substitute sample must be taken during thesubsequent qualifying storm event. The facility must submit the reason for a failure to monitorwith the Discharge Monitoring Report for that period.

Sampling and Analytical Methods (IPG Section 3.7.2d)Appropriate sample containers for each monitoring parameter will be provided by an ADEQ

AmFuel. DocumentNo.: SWPPP Page No.: 30 of 33Storm Water Pollution Prevention Plan Revision No.: 002 Inigal Etfecve Date. 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes All PreviousPrepared By: Safety & Environmental Associates, Inc. SEA ProjectNo. 10-6098 QuahtyRev:ewedBy: AG

certified lab (i.e. glass 1 liter container with H2S04preservative for Oil & Grease, plastic 1 liter forTSS, etc.). Samples will be sealed, labeled appropriately, refrigerated and delivered using a chain-of-custody, as quickly as practicable to the lab for analyses.

At the time of this SWPPP update, suitable labs include, but are not limited to:Environmental Services Co. (Little Rock or Springdale) 501-221-2565, 479-750-1170American Interplex Corp. (Little Rock) 501-224-5060Data Testing Inc. (Fort Smith) 479-649-8378Gulf States Labs (Shreveport) 800-256-6110

Sampling Records and Reporting (IPG Section 3.7.2e)For each monitoring event, the permittee shall record the date and duration (hours) of the stormevent sampled; rainfall measurement (inches) of the event sampled; days since the previousmeasurable rainfall event; and an estimated total volume (gallons) of the discharge sampled.These field records shall be retained and reported with the DMR for the monitoring event.

Sampling Waiver (IPG Section 3.8.2)When a facility can demonstrate that the results of four (4) consecutive monitoring periodscomplies with the Benchmark Value for a particular parameter, the facility may request in writingto forego sampling requirements for that parameter (see permit Sections 3.8.2 and 3.11.1 foradditional details).

Corrective Action for Results Exceeding Benchmarks (IGP Section 3.11.2)

Benchmark values are not effluent limitations, therefore a benchmark exceedance is not a permit violation.However, if a sampling result for any parameter exceeds the parameter benchmark value, the facility shallcommence a corrective action process within 30 days.

• Determine and document a corrective action plan to address the benchmarkexceedance;

• Document the date that corrective actions are initiated, and are completed or expectedto be completed (then track project & document completion date);

• Investigate the cause and/or source of elevated pollutant levels;• Review the SWPPP and update as needed;• Include documentation of the corrective action findings and dates in the subsequent

annual report(s), and retain a copy onsite with the SWPPP; and• Once the corrective action plan has been determined, implement the corrective action

plan, make the necessary modification, and continue to perform monitoring (see permitSection 3.11.2 for additional details).

Record and Reporting Requirements (IGP Section 3.12)

Records (IGP Sections 3.12.1 and 6.1)The permittee shall maintain records of all monitoring information, quarterly inspection reports, annualcompliance evaluations, SWPPP, NOl, relevant maintenance records, corrective actions, etc., for at least 5years from the last date of coverage. Records will be maintained for at least one year after coverage underthis permit terminates.

AmFuel. Document No.: SWPPP Page No 31 of 33Storm Water Pollution Prevention Plan Revision No.: 002 lnioalEffecBveDate. 8/24/2004

Approved By: John Kelly, Vice President Operations Revision Date: 12/8/2011 Supersedes AN PreviousPrepared By: Safety & Environmental Associates, Inc. SEA ProjectNo: 10-6098 Quality Reviewed By AG

Table 6- Storm Water Records Sununary

StorageItem . . Minimum Record Retention

Requirements/Location

Quarterly Visual Inspection Records will be kept in Five years after coverage under theReports SWPPP Exhibit 4 permit terminates.Preventive Maintenance Records will be kept in on- Five years after coverage under theRecords site maintenance fil” permit terminates.Storm water sampling

‘ rresults collected as Inspection sheets will be kept Greater of 6 years from the date ofrequired by permit in on-site environmental files collection or after the term of the(includes lab reports and or with SWPPP permit.DMRS).Annual site compliance Inspection sheets will be kept

• . . Five years after the date of inspectionevaluations in SWPPP Exhibit 6

Records of spills, releases . . . . Five years after coverage under the• . . Spill Log in SWPPP Exhibit 3etc. affecting runoff quality permit terminates.

Records of data used to Records will be kept with Five years after coverage under thecomplete the NOl SWPPP permit terminatesStorm Water Pol1utiong SWPPP will be kept in facility Five years after coverage under thePrevention Plan 1office :

Employee Training Rosters Records will be kept in facility Five years after coverage under theand Agendas office permit terminates.

Monitoring/Sampling Records Contents (IGP Section 3.12.2)For each measurement or sample taken, the following information shall be recorded:

1. Date, exact place, method and time of sampling or measurement;2. Name of the individual who performed the sampling or measurement;3. Duration of the event (hours);4. Estimate of rainfall event (inches);5. Time (in days) since last measurable (> 0.1 inch) event;6. Estimate (in gallons) of total volume discharged;7. Dates the analyses were performed (on lab report);8. Name of the individual who performed the analyses (on lab report);9. The analytical techniques or methods used (on lab report); and10. The results of the analyses (on lab report).

Discharge Monitoring Reports (DMR) (IGP Section 3.12.3a)

Monitoring results shall be reported on Discharge Monitoring Report (DMR) forms due by January31 (forthe samples obtained from monitoring during the previous January-December period). DMRs shall besigned and certified by the owner, or a responsible corporate officer, or a duly authorized representative(see permit Section 6.9). Specific Storm Water DMR forms are available on the ADEQ website. The DMRshould be submitted with the Annual Report (below).

Annual Report (IGP Section 3.12.3b)

The permittee must submit an annual report to the ADEQ, along with the DMR (above), by January 31 eachyear for the previous calendar year. The Annual Report is not intended to be a lengthy document, but is

AmFuel. DocumentNo,: SWPPP Page No 32 of 33Storm Water Pollution Prevention Plan Revision No. 002 IndalEffectioeDate: 8/24/2004

AppooedBy: John Kelly, Vice President Operations RevisonOate 12/8/2011 Supesedes. All PreviousPrepared By Safety & Environmental Associates, Inc. SEA ProectNo. 10-6098 Quabty Reuewed By AG

intended to be a summary or activities, and should include the following:

• Facility name: AmFuel• Permit Tracking Number: ARRO0B815• Facility Physical Address: 601 Firestone Drive, Magnolia, Arkansas 71753• Contact Person Name, Title, Phone Number: John Kelly. Vice President Operations, 870-235-7346• Findings from the Comprehensive Site Evaluation• Findings from Quarterly Site Inspections & Visual Monitoring of Outfalls• Corrective Action Plans (including status of any C.A.’s not yet completed).Note: Check the ADEQ webpage in the future for an Annual Report template, which was not yetavailable at the time of this SWPPP update.

Other BMPs

In addition to the baseline BMPs discussed in the above subsections, AmFuel has also implemented severalother BMPs which include but are not limited to:

1. Employees are trained and held accountable to follow specified procedures and make intelligentmaterial handling decisions to reduce the potential of exposing materials to storm water; and

2. AmFuel reviews its raw material usage in an attempt to minimize HAPs (Hazardous Air Pollutants)from the solvents used in the facility.

‘J ‘j

r’i

>

Di

Di

CD

Di

z C cL Di

-t.

CD Di

Di

at CD CD cm Di

CD

Di

C Di

CD CD 0 CD

(I)

Di

CD 0 m C 3 CD Di

C’)

C’)

C 0 Di

CD Cl)

0 (1)

C,)

0 3 Di CD -o Cc

CD

0•

CD CD 0 -a Di z

C,)

o- -a -o z C

.) C.)

0 C.)

C.)

C C CD 0 CD -a CD Cn 0 CD D 0 a CD Di

0 C,) C r C (0 -o CD 0 c Cl,

C 0-,

C Co

GD C 0 0( > G)

Exhibit 1 - General Storm Water Permit

Exhibit 2 - Supplemental Pictures

Supplemental Pictures

Am

Fu

el

Pag

e1

Lis

tof

Significant

Spil

lsand

Leaks

&S

pil

lL

og

Record

all

significant

spills

and

leak

sof

to

xic

or

hazardous

po

llu

tan

ts

that

have

occu

rred

at

the

facil

ity

since

the

date

th

ree

years

prio

rto

the

effective

date

(1/1/2011)

ofth

ep

erm

it.

Significan

tsp

ills

include,

but

are

no

tlim

ited

to,

releases

of

oil

or

hazard

ou

ssubstances

inexcess

ofreportable

qu

an

tities

Yea

rpri

or

toef

fect

ive

dat

eof

per

mit

:2010

Date

Spil

lor

Log

Locati

on

Desc

ripti

on

Resp

on

seP

rocedure

Pre

ven

tiv

e(x

x/x

x/x

x)

Lea

kC

om

ple

ted

(as

indic

ate

dM

easu

res

Taken

By

on

site

map

)T

ype

of

Quanti

tyS

ou

rce,

IfR

easo

nA

mo

un

tof

Mate

rial

stil

lM

ate

rial

Kn

ow

nM

ate

rial

Expose

dto

Reco

vere

dS

torm

wate

r

(Yes/

No)

N/A

none

2nd

Yea

rp

rio

rto

effe

ctiv

edat

eofp

erm

it:

2C09

3rd

Yea

rp

no

rto

eff

cti

ve

dat

eofp

erm

it:

2008

Date

(xx/x

x/x

x)

N/A

Date

(xx/x

x/x

x)

N/A

Spil

lor

Leak

no

ne

Spil

lor

Leak

none

Log

Com

ple

ted

By

Log

Com

ple

ted

By

Lo

cati

on

(as

indic

ate

d

on

site

map)

Lo

cati

on

(as

indic

ate

d

on

site

map

)

Ty

pe

of

Mate

rial

Type

of

Mate

rial

Quanti

ty

Quanti

ty

Desc

ripti

on

So

urc

e,

If

Kn

ow

n

Desc

ripti

on

Sourc

e,

If

Kn

ow

n

Reaso

n

Reaso

n

Resp

on

seP

rocedure

Am

ou

nt

of

Mate

rial

Reco

vere

d

Mate

rial

stil

l

Expose

dto

Sto

rmw

ate

r

(Yes/

No

l

Resp

on

seP

rocedure

Am

ou

nt

of

Mate

rial

Reco

vere

d

Mate

rial

stil

l

Expose

dto

Sto

rmw

ate

r

IYes/N

o

Pre

venti

ve

Measu

res

Tak

en

Pre

venti

ve

Measu

res

Tak

en

Am

Fu

el

Pag

e2

Lis

tof

Sig

nif

icant

Sp

ills

and

Leaks

&S

pil

lL

og

Record

all

signif

icant

spil

lsand

leak

sof

tox

icor

hazard

ous

po

llu

tan

tsth

at

have

occu

rred

at

the

facil

ity

sin

ce

the

date

thre

eyears

pri

or

toth

eeff

ecti

ve

date

(1/1

/2011)

of

the

perm

it.

Sig

nif

icant

spil

lsin

clu

de,

but

are

no

tli

mit

ed

to.

rele

ases

of

oil

or

hazard

ou

ssu

bsta

nces

inexcess

ofre

port

able

qu

an

titi

es

Dat

eS

pill

or

Log

Loc

atio

nD

escr

ipti

on

Res

po

nse

Pro

cedure

Pre

ven

tiv

e(x

x/x

x/x

x)

Lea

kC

om

ple

ted

(as

indic

ated

Mea

sure

sT

aken

By

onsi

tem

ap)

Typ

eof

Quan

tity

Sou

rce,

IfR

easo

nA

mo

un

tof

Mat

eria

lst

ill

Mat

eria

lK

now

nM

ater

ial

Exp

osed

toR

eco

ver

edS

torm

wat

er(Y

es/N

o)

Storm Water Quarterly Inspection FormNote: Enter “NIA” on the lines that this inspection form does not apply.

Name of Facility: AmFuel NPDES Tracking No. ARROOB815

Name/Title of Person(s) Conducting Inspection and/or Sample:

Date & Time of Inspection:

Weather Conditions (dry, raining, etc.): Days Since last Rain Event:

Watershed #1 — East of the Waste Building Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:

Color El None El Other (describe):

Odor El None El Musty El Sewage El Sulfur El Sour El Petroleum/Gas El Solvents El Other (describe):

Clarity El Clear El Slightly Cloudy C] Cloudy El Opaque El Other

Floating Solids El No El Yes (describe):

Settled Solids** El No El Yes (describe):

Suspended Solids El No El Yes (describe):

Foam El No El Yes (describe):

Oil Sheen El None El Flecks El Globs El Sheen El Slick El Other (describe):

Debris in Outfall or Other Obvious Indicators of Storm Water Pollution El No El Yes (describe):

Packaged Hazardous WastelMaterial Storage & Handling: Leaks/Spilled Material El No El Yes (describe):

Condition of containers El OK El Problem (describe):

Pole-top or Slab Mounted Transformers: Condition LI OK El Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material C] No LI Yes (describe):

Condition of structure, equipment El OK El Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material LI No El Yes (describe):

Housekeeping around equipment El OK El Problem (describe):

Solid Waste/Trash Management: Leaks/Spilled Material C] No LI Yes (describe):


Housekeeping around containers El OK El Problem (describe):

Tank Hazardous Waste/Material Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material El No C] Yes (describe):

Condition of the tank(s) or Secondary Containment C] OK El Problem (describe):

Other: Leaks/Spilled Material C] No C] Yes (describe):

Housekeeping El OK El Problem (describe):

Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below (attach additional sheets asnecessary). Insert details

Watershed #2 — Western side of the main Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:operations building

Color El None El Other (describe):

Odor El None U Musty El Sewage Q Sulfur U Sour El Petroleum/Gas El Solvents El Other (describe):

Clarity El Clear El Slightly Cloudy El Cloudy El Opaque El Other

Floating Solids LI No El Yes (describe):

Settled Solids** El No Q Yes (describe):





Packaged Hazardous WastelMaterial Storage & Handling: Leaks/Spilled Material U No El Yes (describe):


Pole-top or Slab Mounted Transformers: Condition El OK El Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material El No U Yes (describe):


Outside Equipment Storage: Leaks/Spilled Material El No El Yes (describe):

Housekeeping around equipment LI OK U Problem (describe):

Solid WastelTrash Management: Leaks/Spilled Material El No El Yes (describe):

Condition of containers U OK U Problem (describe):

Housekeeping around containers U OK U Problem (describe):

Tank Hazardous WastelMaterial Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material LI No U Yes (describe):

Condition of the tank(s) or Secondary Containment U OK El Problem (describe):

Other: Leaks/Spilled Material U No LI Yes (describe):

Housekeeping U OK El Problem (describe):


Watershed#3 — Northwestern side of the main Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:operations building

LI None LI Other (describe):

LI None LI Musty LI Sewage LI Sulfur LI Sour LI Petroleum/Gas LI Solvents LI Other (describe):

LI Clear LI Slightly Cloudy [] Cloudy LI Opaque LI Other

Floating Solids LI No LI Yes (describe):

Settled Sof ids** LI No [1 Yes (describe):

Suspended Solids LI No LI Yes (describe):

Foam LI No LI Yes (describe):

Oil Sheen El None LI Flecks LI Globs LI Sheen LI Slick LI Other (describe):

Debris in Outfall or Other Obvious Indicators of Storm Water Pollution LI No LI Yes (describe):

Packaged Hazardous Waste/Material Storage & Handling: Leaks/Spilled Material LI No LI Yes (describe):

Condition of containers LI OK LI Problem (describe):

Pole-top or Slab Mounted Transformers: Condition LI OK LI Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material LI No LI Yes (describe):

Condition of structure, equipment LI OK LI Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material LI No LI Yes (describe):

Housekeeping around equipment LI OK LI Problem (describe):

Solid WastelTrash Management: Leaks/Spilled Material LI No LI Yes (describe):


Housekeeping around containers LI OK LI Problem (describe):

Tank Hazardous WastelMaterial Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material LI No LI Yes (describe):

Condition of the tank(s) or Secondary Containment LI OK LI Problem (describe):

Other: Leaks/Spilled Material LI No LI Yes (describe):

Housekeeping LI OK LI Problem (describe):


Watershed#4 — Northern center and northeast Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:side of the main operations building

LI None O ati; 1 (describe):

LI None LI Musty LI Sewage LI Sulfur Li Sour LI Petroleum/Gas LI Solvents LI Other (describe):

LI Clear Li Slightly Cloudy LI Cloudy LI Opaque LI Other


Settled Solids** LI No LI Yes (describe):


Foam LI No El Yes (describe):

Oil Sheen [] None LI Flecks LI Globs LI Sheen LI Slick LI Other (describe):


Packaged Hazardous Waste/Material Storage & Handling: Leaks/Spilled Material LI No LI Yes (describe):







Solid Waste/Trash Management: Leaks/Spilled Material LI No LI Yes (describe):








Watershed#5 — South center of the south side of Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:the main operations building

LI None LI Other (describe):

LI None LI Musty LI Sewage LI Sulfur LI Sour LI Petroleum/Gas LI Solvents LI Other (describe):

LI Clear LI Slightly Cloudy LI Cloudy LI Opaque LI Other


Settled Solids** LI No LI Yes (describe):


Foam LI No LI Yes (describe):

Oil Sheen LI None LI Flecks LI Globs LI Sheen LI Slick LI Other (describe):


Packaged Hazardous WastelMaterial Storage & Handling: Leaks/Spilled Material LI No LI Yes (describe):







Solid WastelTrash Management: Leaks/Spilled Material LI No LI Yes (describe):








Watershed#6 - South center of the south side of Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:the main operations building

El None El Other (describe):

fl None El Musty El Sewage El Sulfur El Sour El Petroleum/Gas El Solvents El Other (describe):

El Clear El Slightly Cloudy El Cloudy El Opaque El Other

Floating Solids Q No El Yes (describe):

Settled Solids** El No El Yes (describe):





Packaged Hazardous WastelMaterial Storage & Handling: Leaks/Spilled Material El No El Yes (describe):


Pole-top or Slab Mounted Transformers: Condition El OK El Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material El No El Yes (describe):


Outside Equipment Storage: Leaks/Spilled Material El No El Yes (describe):

Housekeeping around equipment El OK El Problem (describe):

Solid Waste/Trash Management: Leaks/Spilled Material El No El Yes (describe):


Housekeeping around containers El OK El Problem (describe):

Tank Hazardous WastelMaterial Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material El No El Yes (describe):

Condition of the tank(s) or Secondary Containment El OK El Problem (describe):

Other: Leaks/Spilled Material El No Li Yes (describe):

Housekeeping El OK El Problem (describe):


EXAMPLE STORM WATER AND SPILL PREVENTIONTRAINING OUTLINE

There are Federal and State regulations that are a part of the clean water act that govern what can gointo our storm drains.

Klipsch is required to maintain a general Storm Water Permit. This includes routine internalinspections as well as by the Arkansas Dept. of Environmental Quality.

This Storm Water Permit requires that we have a Storm Water Pollution Prevention Plan (SWPPP)which is kept on file in the office.

• The Pollution Prevention Plan includes Best Management Practices (BMP) which includescontrols such as:

o No dumping of any chemicals or other materials outside.o Prevention of spills from containers (drums of finish materials, waste, solvents, etc.).o Storing liquids indoors or under cover.o Performing maintenance indoors whenever possible.o Minimizing sedimentation (sawdust or other material carried off in storm water).

• The Storm Water Prevention Plan declares that only storm water can go down the StormDrains and ditches, no wastewater or illicit discharges. Examples of what NOT to drain ordump on the ground. ditch or storm drain:

o No pressure washing water from forklifts or other equipment outside.o No draining or rinsing drums or buckets.o No oily air compressor condensate.o No paint or solvents.o No mop water.o No chemicals.o No oil or diesel.

If in doubt, askyour Supervisor or H.R. Manager about where things should be disyosed ofi

Name:

____________________

ID #:

Signature:

_______________________

Date:

________

Discharge Monitoring Report Records

Watershed#4 – Northern center and northeast side of the main operations building

Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:

COLOR None Other (describe): Whitish water with visible powder

ODOR None Musty Sewage Sulfur Sour Petroleum/Gas Solvents Other (describe):

CLARITY Clear Slightly Cloudy Cloudy Opaque Other

Floating Solids No Yes (describe): White powder

Settled Solids** No Yes (describe):

Suspended Solids No Yes (describe): White Powder

Foam No Yes (describe):

Oil Sheen None Flecks Globs Sheen Slick Other (describe):

Debris in Outfall or Other Obvious Indicators of Storm Water Pollution No Yes (describe): White powder

Packaged Hazardous Waste/Material Storage & Handling: Leaks/Spilled Material No Yes (describe): Condition of containers OK Problem (describe):

Pole-top or Slab Mounted Transformers: Condition OK Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material No Yes (describe): Condition of structure, equipment OK Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material No Yes (describe): Housekeeping around equipment OK Problem (describe): The outside of the facility as a whole could use a little cleaning.

Solid Waste/Trash Management: Leaks/Spilled Material No Yes (describe): Evidence seems to suggest the housekeeping issue seems to result from the trash compactors. Condition of containers OK Problem (describe): Housekeeping around containers OK Problem (describe):

Tank Hazardous Waste/Material Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material No Yes (describe):

Condition of the tank(s) or Secondary Containment OK Problem (describe):

Other: Leaks/Spilled Material No Yes (describe): Housekeeping OK Problem (describe): See notes in other sections.

Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below (attach additional sheets as necessary). Insert details

CMichael Richardson

From: Michael RichardsonSent: Tuesday, April 05, 2011 2:22 PMTo: ‘[email protected]: [email protected]: 1st Qtr Storm Water InspectionAttachments: 1st Qtr Inspection 2011pdf

Importance: High

Alisa / Scott,

Please review the feedback below and determine a path forward to resolve potential storm water contamination (alsosee the attached form). Inspection documents such as this email, attached form, and the documented actions taken toresolve potential problems should be maintained in the SWPPP in the Quarterly Inspections section.

Outfall 007During the inspection white water with powder residue was observed flowing from the concrete pipe discharging toOutfall 007 (Southeast corner of the building). Please have maintenance research the possible sources of the potentialcontaminant. The only pipes that I am aware of that tie into that concrete pipe are the roof drains from the Northeastside of the building.

Entire FacilityThe facility as a whole could use some ttention in the housekeeping area to minimize trash pollution.

Please contact me if you have any questions or concerns regarding this feedback.

Thanks,

V(áe adENVIRONMENTAL SPECIALISTSMETY ND ENVIRONMEN AL ASSOCIATES, INC.(501) 5683111

Help consee the environment. Please think before you print this e-mail. Thank you

Confidentiality Notice: The information contained in this message is intended only for the use of the addressee, and may be confidentialand/or privileged. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intendedrecipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you havereceived this communication in error, please notify the sender immediately.

1

C—

Watershed#4 — Northern center and northeast Any Visible Water Discharge from outfall? (circle one) YES/NO If yes,side of the main operations building complete next section:

--

COLOR LI None Other (describe): Whitish water with visible powder

ODOR None LI Musty LI Sewage LI Sulfur LI Sour LI Petroleum/Gas LI Solvents LI Other (describe):

CLARITY LI Clear LI Slightly Cloudy Cloudy LI Opaque LI Other

Floating Solids LI No Yes (describe): White powder

Settled Solids** No LI Yes (describe):

Suspended Solids LI No Yes (describe): White Powder

Foam No LI Yes (describe):

Oil Sheen None LI Flecks LI Globs LI Sheen LI Slick LI Other (describe):

Debris in Outfall or Other Obvious Indicators of Storm Water Pollution LI No Yes (describe): White powder

Packaged Hazardous WastelMaterial Storage & Handling: Leaks/Spilled Material No LI Yes (describe):


Pole-top or Slab Mounted Transformers: Condition OK LI Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material No LI Yes (describe):

Condition of structure, equipment OK LI Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material No LI Yes (describe):

Housekeeping around equipment LI OK Problem (describe): The outside of the facility as a whole could use a little cleaning.

Solid WastelTrash Management: Leaks/Spilled Material L No Yes (describe): Evidence seems to suggest thehousekeeping issue seems to result from the trash compactors.

Condition of containers OK LI Problem (describe):

Housekeeping around containers OK LI Problem (describe):

Tank Hazardous Waste/Material Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material NoLI Yes (describe):

Condition of the tank(s) or Secondary Containment OK LI Problem (describe):

Other: Leaks/Spilled Material No LI Yes (describe):

Housekeeping LI OK Problem (describe): See notes in other sections.

Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below (attach additionalsheets as necessary). Insert details

Watershed#4 – Northern center and northeast side of the main operations building–Outfall 007

Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section:

None Other (describe): Whitish water with visible powder

None Musty Sewage Sulfur Sour Petroleum/Gas Solvents Other (describe):

Clear Slightly Cloudy Cloudy Opaque Other

Floating Solids No Yes (describe): White powder

Settled Solids** No Yes (describe):

Suspended Solids No Yes (describe): White powder


Oil Sheen None Flecks Globs Sheen Slick Other (describe):


Packaged Hazardous Waste/Material Storage & Handling: Leaks/Spilled Material No Yes (describe): Condition of containers OK Problem (describe):


Air Compressors: Oil Leaks/Spilled Material No Yes (describe): Condition of structure, equipment OK Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material No Yes (describe): Housekeeping around equipment OK Problem (describe):

Solid Waste/Trash Management: Leaks/Spilled Material No Yes (describe): Trash was present in the area from the trash compactors Condition of containers OK Problem (describe): Housekeeping around containers OK Problem (describe):

Tank Hazardous Waste/Material Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material No Yes (describe):

Condition of the tank(s) or Secondary Containment OK Problem (describe):

Other: Leaks/Spilled Material No Yes (describe): Housekeeping OK Problem (describe):

Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below (attach additional sheets as necessary). Insert details

CMichael Richardson

From: Michael RichardsonSent: Tuesday, July 05, 2011 5:06 PMTo: [email protected]: [email protected]: 2nd Qtr Storm Water InspectionAttachments: 2nd Qtr Inspection 2011.pdf

Alisa,

Attached you’ll find the 2 Qtr Storm Water Inspection form. All water sheds with the exception of #4 appeared to be incompliance. Please note that white powder has been observed near Outfall 007 for the second quarter which meansthere is stronger evidence that a potential contamination source must be identified and controlled immediately. Inotified James and William (Maintenance> of the issue the day of the visit (June 7,2011) and they were going to lookinto the source and determine how to prevent future occurrences. Please follow up with them to ensure they havefound the source and controls are in place. Secondly, please verify the facility is exercising the housekeeping policy andensuring trash is periodically picked up. Also, retain a copy of this email and the attached inspection document in yourStorm Water Pollution Prevention Plan for future reference. Please contact me if you have questions or concerns.

Thanks,

ENIRONMENiAL SPECIALIST

SAFETY AND ENVIRONMENTAL ASSOCIATES, INC.(501) 563i1i

Help consee the environment. Please think before you print this e-mail. Thank you

Confidentiality Notice: The information contained in this message is intended only for the use of the addressee, and may be confidentialand/or privileged. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intendedrecipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you havereceived this communication in error, please notify the sender immediately.

1

C C

Watershed#4 — Northern center and northeast Any Visible Water Discharge from outfall? (circle one) YES/NO If yes,side of the main operations building—Outfall 007 complete next section:

fl None Other (describe): Whitish water with visible powder

None Musty Sewage Sulfur Sour Petroleum/Gas Solvents Other (describe):

Clear Slightly Cloudy Cloudy D Opaque Other

Floating Solids E No Yes (describe): White powder

Settled Solids** No E Yes (describe):

Suspended Solids No Yes (describe): White powder


Oil Sheen None Flecks Globs E Sheen D Slick Other (describe):


Packaged Hazardous WastelMaterial Storage & Handling: Leaks/Spilled Material No fl Yes (describe):

Condition of containers OK Problem (describe):


Air Compressors: Oil Leaks/Spilled Material No E Yes (describe):

Condition of structure, equipment OK Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material No fl Yes (describe):

Housekeeping around equipment OK Problem (describe):

Solid WastelTrash Management: Leaks/Spilled Material No Yes (describe): Trash was present in the area fromthe trash compactors

Condition of containers OK U Problem (describe):

Housekeeping around containers OK fl Problem (describe):

Tank Hazardous WastelMaterial Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material NoU Yes (describe):

Condition of the tank(s) or Secondary Containment OK E Problem (describe):

Other: Leaks/Spilled Material No U Yes (describe):

Housekeeping U OK El Problem (describe):

Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below (attach additionalsheets as necessary). Insert details

Watershed#4 – Northern center and northeast side of the main operations building

Any Visible Water Discharge from outfall? (circle one) YES/NO If yes, complete next section.

X None Other (describe):

X None Musty Sewage Sulfur Sour Petroleum/Gas Solvents Other (describe):

Clarity X Clear Slightly Cloudy Cloudy Opaque Other

Floating Solids X No Yes (describe):

Settled Solids** X No Yes (describe):

Suspended Solids X No Yes (describe):

Foam X No Yes (describe):

Oil Sheen X None Flecks Globs Sheen Slick Other (describe):

Debris in Outfall or Other Obvious Indicators of Storm Water Pollution

X No Yes (describe):

Packaged Hazardous Waste/Material Storage & Handling: Leaks/Spilled Material X No Yes (describe): Condition of containers X OK Problem (describe):

Pole-top or Slab Mounted Transformers: Condition X OK Problem/Leak (describe):

Air Compressors: Oil Leaks/Spilled Material X No Yes (describe): Condition of structure, equipment X OK Problem (describe):

Outside Equipment Storage: Leaks/Spilled Material X No Yes (describe): Housekeeping around equipment OK X Problem (describe): Housekeeping needed exterior of the plant in this area.

Solid Waste/Trash Management: Leaks/Spilled Material X No Yes (describe): Condition of containers X OK Problem (describe): Housekeeping around containers X OK Problem (describe):

Tank Hazardous Waste/Material Storage & Handling (Chemical, Oil, Diesel, Gasoline, etc): Leaks/Spilled Material X No Yes (describe): Condition of the tank(s) or Secondary Containment X OK Problem (describe):

Other: Leaks/Spilled Material X No Yes (describe): Housekeeping X OK Problem (describe):

Detail any concerns, additional comments, descriptions of pictures taken, and any corrective actions taken below (attach additional sheets as necessary). This inspection was completed by Ashley Gay, SEA Inc. on 9/21/2011. The exterior of the plant, especially in the equipment storage area needs to be cleaned up; however I did not see any immediate risks to storm water during my inspection.

Exhibit H – MEK Totes in Containment

Exhibit I – Picture of New Tank

December 12, 2011 Mr. John Kelley, Plant Manager AMFUEL-Magnolia 601 Firestone Drive Magnolia, AR 71753 RE: ADEQ Response to an Inspection NPDES Permit: ARR00B815 AFIN: 14-00040 Mr. Kelley, The Department has received your response to the October 26, 2011 inspection of your facility by our District Field Inspector, John Lamb. The information submitted sufficiently addresses the concerns of the Department. Our Department expects the corrective actions taken will be maintained to ensure consistent compliance with the requirements of the permit. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. The Department will keep the inspection and response on file. If future violations occur that may require enforcement action, the Department will consider the inspection and response as required by the Pollution Control and Ecology Commission Regulation No. 7, Civil Penalties. This regulation requires the Department to consider the past history of your site and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. If you have any questions, please call 501-682-0636 or e-mail [email protected]. Sincerely,

Sandra J Farmer Enforcement Analyst Water Division Enforcement Branch

November 18, 2011 Mr. John Kelley, Plant Manager Magnolia… · John Kelley, AMFUEL-Magnolia...

Documents

Transcript of November 18, 2011 Mr. John Kelley, Plant Manager Magnolia… · John Kelley, AMFUEL-Magnolia...