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STORM WATER POLLUTION PREVENTION PLAN (SWPPP) DETROIT BULK STORAGE FACILITY 115 ROSA PARKS BLVD.

DETROIT, MICHIGAN

Prepared for

DETROIT BULK STORAGE, INC. P.O. BOX 18285 RIVER ROUGE, MICHIGAN 48218
AKT PEERLESS PROJECT NO. 8235F-2-16 MAY 29, 2013

TABLE OF CONTENTS

1.0 2.0

GENERAL FACILITY INFORMATION .............................................................................. 3 OVERVIEW ................................................................................................................. 4 2.1 2.2 INTRODUCTION ........................................................................................................4 OBJECTIVES ..............................................................................................................4

3.0

FACILITY DESCRIPTION ............................................................................................... 4 3.1 3.2 3.3 3.4 3.5 FACILITY LAYOUT......................................................................................................4 FACILITY OPERATIONS..............................................................................................5 WATER SUPPLY AND SANITARY DISCHARGE ...........................................................5 STORM WATER DISCHARGE .....................................................................................5 STORM WATER POLLUTION PREVENTION TEAM ....................................................5

4.0

POTENTIAL SOURCES OF POLLUTANTS ........................................................................ 6 4.1 4.2 4.3 4.4 SITE MAP ..................................................................................................................6 INVENTORY OF EXPOSED SIGNIFICANT MATERIALS ................................................6 LIST OF PAST SPILLS AND LEAKS...............................................................................7 SUMMARY OF SAMPLING DATA ..............................................................................7

5.0

BEST MANAGEMENT PRACTICES ................................................................................. 7 5.1 NON-STRUCTURAL CONTROLS.................................................................................7 5.1.1 5.1.2 5.1.3 5.1.4 5.1.5 5.1.6 5.1.7 5.1.8 5.2 Prevention Maintenance .............................................................................7 Quarterly Comprehensive Inspections ........................................................8 Good Housekeeping Practices .....................................................................8 Spill Prevention and Response Procedures .................................................9 Soil Erosion and Sedimentation Control Measures ...................................10 Employee Training .....................................................................................10 Total Maximum Daily Load Requirements ................................................10 List of Significant Materials Still Present....................................................11

STRUCTURAL CONTROLS ........................................................................................11

6.0 7.0

EVALUATION OF NON-STORM WATER DISCHARGES.................................................. 11 RECORD KEEPING AND REPORTING .......................................................................... 11 7.1 ANNUAL REVIEW....................................................................................................11

TABLE OF CONTENTS (continued) 7.2 8.0 RECORD KEEPING AND REPORTING FORMS ..........................................................12

CERTIFICATION OF THE SWPPP ................................................................................. 12

QUALIFICATIONS FIGURES Figure 1 .................................................................................................. Topographic Location Map Figure 2 ........................................................................... Site Map with Surface/Drainage Features APPENDICES Appendix A .......................................................................................... General Storm Water Permit Appendix B ............................................................................ Record Keeping and Reporting Forms Appendix C .........................................................................................MDEQ Spill or Release Report Appendix D .......................................................................................... Product Delivery Procedures Appendix E ................. City of Detroit Storm Water Management Program Plan (November 2011) Appendix F ............................................................................................................................... TMDL Appendix G .............................................................................................. Fugitive Dust Control Plan

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STORM WATER POLLUTION PREVENTION PLAN DETROIT BULK STORAGE FACILITY DETROIT, MICHIGAN AKT PEERLESS PROJECT NO. 8235F-2-16
1.0 GENERAL FACILITY INFORMATION Detroit Bulk Storage, Inc. 115 Rosa Parks Blvd. Detroit, Michigan 48209 Noel Frye Vice President (313) 999-9015 Detroit Bulk Storage, Inc. P.O. Box 18241 River Rouge, Michigan 48218

Name of Facility: Facility Address: Facility Contact: Name: Title: Telephone: Mailing Address:

Emergency Contact: Name: Title Telephone: Certified Storm Water Operators: John Frye Coordinator (313) 999-0874 Noel Frye, Certification #12398 John Frye*

* MDEQ Industrial Storm Water Course completed. Certification Number not yet available. Primary SIC Code: Receiving Water: 4491 Detroit River

2.0 2.1

OVERVIEW INTRODUCTION

This storm water pollution prevention plan (SWPPP) covers operations at the Detroit Bulk Storage facility (DBS) in Detroit, Michigan. It has been developed as required by Part I B of Michigans National Pollutant Discharge Elimination System (NPDES) general permit for storm water discharges and in accordance with good engineering practices. This SWPPP describes this facility and its operations, identifies potential sources of storm water pollution at the facility, recommends appropriate best management practices (BMPs) or pollution control measures to reduce the discharge of pollutants in storm water runoff, and provides for periodic review of the SWPPP. The General Storm Water Permit MIS310000 is presented in Appendix A. This SWPPP becomes effective May 6, 2013. The non-structural and structural controls that will be implemented as part of this plan are described in Sections 5.1 and 5.2, respectively. 2.2 OBJECTIVES

The goal of the storm water permit program is to improve the quality of surface waters by reducing the amount of pollutants potentially contained in the storm water runoff being discharged. The objective of this SWPPP is three-fold: 1. Identify potential sources of storm water pollution at DBS; 2. Describe BMPs which are to be used at DBS; and 3. Provide other elements such as a facility inspection program, a site compliance evaluation program, and a record keeping and reporting program. 3.0 3.1 FACILITY DESCRIPTION FACILITY LAYOUT

The Detroit Bulk Storage facility (DBS) is a leased portion of a larger parcel of land located at 115 Rosa Parks Blvd, Detroit, Wayne County, Michigan. The DBS facility comprises approximately 9-acres of land. The Detroit River flows southwest and adjoins the property to the south. The following table summarizes information at the facility: Building Administrative Office (Mobile Trailer) Square Footage 250 Primary Use office/administrative duties

The remainder of the property consists of asphalt, concrete and brick paved parking areas and

driveways. The location of the site is presented as Figure 1. A Site Map is presented as Figure 2. 3.2 FACILITY OPERATIONS

The DBS facility is utilized as a marine terminal and storage operation for bulk storage of mainly crushed limestone aggregate and petroleum coke (Pet Coke). A mobile office trailer is located near the gated entrance of the DBS facility. No other buildings are present at the site. Petroleum coke and limestone are staged along the western and eastern portions of the site respectively while awaiting ship and/or truck loading and transport. One 1,000-gallon diesel above-ground storage tank (AST) is located on the northeast side of the site near the office trailer. The AST is used for fueling heavy equipment used onsite. 3.3 WATER SUPPLY AND SANITARY DISCHARGE

The mobile office trailer is not connected to the municipal water or sanitary sewer systems. There are no floor drains. Portable sanitation facilities are utilized at the site. 3.4 STORM WATER DISCHARGE

There were formerly three storm water catch basins located at the site. One was located in the asphalt surface on the south side of the Pet Coke storage pile. Two additional catch basins were located on the north side of the Pet Coke storage pile within the unpaved portion of the site. All three catch basins were recently permanently closed and sealed with concrete. See Figure 2 for the approximate locations of the abandoned catch basins. As a result, no storm water will be discharged from the site into the Detroit River. Through use of site grading, storm water will be directed over land to the unpaved northern portion of the site where infiltration and evaporation will occur. 3.5 STORM WATER POLLUTION PREVENTION TEAM

The storm water pollution prevention team is responsible for developing, implementing, maintaining, and revising this SWPPP. The members of the team are familiar with the management and operations of DBS. The members of the team and their primary responsibilities are as follows:
Name and Title
Noel Frye, Vice President

Responsibilities
Implementing and maintaining BMPs, keeping and submitting required records and reports, conducting annual inspections, conducting site compliance evaluations, training employees, and signing the SWPPP and non-storm water certifications.

Name and Title


John Frye, Facility Contact, Spill Coordinator

Responsibilities
Assisting with implementation and maintenance of BMPs, assisting in conducting annual inspections, and assisting in conducting annual site evaluations.

4.0 4.1

POTENTIAL SOURCES OF POLLUTANTS SITE MAP Property boundaries; Site structures; Outside storage and disposal areas for significant materials; Storm water discharge outfalls; Storm water and non-storm water contributing to each outfall; Structural runoff controls; Location of NPDES permitted discharges other than storm water; Areas of vegetation; Areas of exposed and/or erodible soils; Impervious surfaces (roof, asphalt, concrete) Nearest receiving surface water (Detroit River); Areas of known or suspected impacts on surface waters as designated under Part 201 of the Michigan Act; and Locations where the following activities are exposed to storm water: -maintenance of vehicles, machines, and equipment -loading/unloading areas -petroleum storage area

A Site Map of the facility, presented as Figure 2, depicts the following features:

4.2

INVENTORY OF EXPOSED SIGNIFICANT MATERIALS

Significant materials used and stored at the facility, and the potential methods of exposure to storm water, are presented in the following table.

Diesel AST

1,000-gallon capacity AST is located in the northwest area of the site by the office trailer.

Leakage of AST product into groundwater at the subject property; spills resulting from product delivery operations and/or during dispensing of product on to ground surface Small spills from maintenance or leakage of hydraulic fluids and oils onto ground surface. Migration of particulate/sediment into the Detroit River. (Existing storm water catch basins will be immediately and permanently closed and sealed with concrete.)

Excavators and trucks

Trucks are stored near the office trailer while not in use. Excavator does not have a specific storage location. Storage/Staging Area

Petroleum Coke

4.3

LIST OF PAST SPILLS AND LEAKS

There are no known spills or leaks of pollution materials at the facility within the last three years. 4.4 SUMMARY OF SAMPLING DATA

No storm water sampling data is currently available for the facility. 5.0 BEST MANAGEMENT PRACTICES

The following storm water management controls, or BMPs, will be implemented to minimize the potential of pollutants to enter the storm water discharged from DBS. 5.1 NON-STRUCTURAL CONTROLS

Non-structural controls are work practices that are specifically intended to reduce the amount of pollution getting into surface waters. They are generally implemented to address the problem at the source. The following sections describe non-structural controls at the facility. 5.1.1 Prevention Maintenance The following equipment and activities are included in the preventive maintenance program.
Equipment
Double walled steel 1,000-gallon diesel AST Excavator and site trucks

Activity
The AST is checked regularly for leaks. Excavator and site truck equipment are maintained regularly.

Frequency
Weekly Inspected daily or per use

Equipment
Spill control kits

Activity
Spill control kits will be stored in the office trailer in the event of a release during vehicle maintenance activities. The contents of the spill control kits are inventoried and restocked if necessary.

Frequency
Quarterly; or after each use

Petroleum Coke (Pet Coke)

Storage event. Storm catch basins on the site have been closed and sealed with concrete. Area between asphalt pad and seawall will be built up and graded to prevent storm runoff (currently under construction). During ship loading, small amounts of Pet Coke fragments may fall from the inadvertently conveyor as the product is transported into the ships hold. A temporary diversion chute and gondola box will be installed under the loading conveyor at the ship/pier interface to capture any Pet Coke product fragments that may inadvertently fall off the conveyor belt during ship loading operations.

Diversion chute, gondola box installation will be inspected during each ship loading event. Any fragments that are not captured in the gondola will be cleaned up.

5.1.2 Quarterly Comprehensive Inspections Comprehensive inspections of the facility, including equipment and plant areas, will be conducted quarterly as required by the permit. The results of the inspections will be recorded on the Comprehensive Inspection forms contained in Appendix B. These completed forms will be kept on file with the SWPPP for a minimum of three years. The comprehensive quarterly inspections will be completed according to the following schedule: First quarter - on or before March 31st, Second quarter on or before June 30th, Third quarter on or before September 30th Fourth quarter on or before December 31st. 5.1.3 Good Housekeeping Practices Good housekeeping practices are designed to maintain a clean and orderly work environment. This will reduce the potential for significant materials to come in contact with storm water.

The following practices are included in DBS good housekeeping routine. 1. Routinely inspect for leaks or spills. 2. Ensure spill clean up procedures are understood by employees. 3. Ensure that all chemical substances are properly labeled. 4. Pick up waste materials every two weeks. 5. Inspect catch basin caps and the pier-side berm are intact and undamaged. 5.1.4 Spill Prevention and Response Procedures Spills and leaks are the largest industrial source of storm water pollution. This SWPPP specifies material handling procedures and storage requirements for significant materials. Equipment and procedures necessary for cleaning up spills and preventing the spilled materials from being discharged have also been identified. All current employees are aware of the proper procedures. Employees are provided training during initial orientation and annually thereafter. Spill control kits are located in the office trailer, which is depicted on Figure 2, Site Map. Spill control kits include the following materials: Granular absorbent material Oil pads

The following procedures have been developed for spill response for DBS: 1. Don the appropriate personal protection equipment (e.g., gloves, goggles); 2. Stop the flow of material from the source by up-righting fallen containers or using plugs or patches 3. Place absorbent material down-gradient from the spilled material; 4. Place a fire extinguisher near the area of release during cleanup operations, if a combustibility hazard exists; 5. Notify the following facility representative: John Frye, Site Spill Coordinator (313) 999-0874 6. Place used absorbent material and/or any impacted soil into a disposal bag or a 55gallon drum pending characterization and proper disposal. Upon notification of the spill, the Site Coordinator will complete a Significant Spill Report form (Appendix B). Depending upon the quantity and location of the spill, certain state or federal release reporting requirements may need to be met. A copy of the Michigan Department of Environmental Quality (MDEQ) Spill or Release Report Form is located in Appendix C. Any materials used from the spill control kits will be reordered and replaced.

5.1.5 Soil Erosion and Sedimentation Control Measures No areas are present at the facility, which represent a high potential for significant soil erosion. Portions of the site that are not paved with asphalt, concrete or brick pavers are depicted on Figure 2. This area of the property is fairly level and no functioning storm drains are present. Furthermore this area is covered with coarse gravel to prevent sediment runoff during high volume rain events. Because Pet Coke staging at the DBS terminal will be intermittent during the shipping season, temporary sediment discharge prevention measures have been installed and include: A temporary diversion chute and gondola box are installed under the loading conveyor at the ship/pier interface to capture any Pet Coke product fragments that may inadvertently fall off the conveyor belt during ship loading operations. Pet coke that falls from the front end loaders while transporting from the bulk pile to the conveyor hopper is routinely collected and returned to the bulk pile or hopper to prevent/minimize spreading of the material.

5.1.6 Employee Training The following is a description of the employee training programs that have been implemented to inform appropriate personnel at all levels of responsibility of the components and goals of the SWPPP.
Topic
Preventive Maintenance Good housekeeping practices Spill Response Procedures Operator Training for Industrial Sites (MDEQ video tape)

Employees
All All All All

Frequency
Upon initial thereafter. Upon initial thereafter. Upon initial thereafter. Upon initial thereafter. hiring hiring hiring hiring and and and and annually annually annually annually

5.1.7 Total Maximum Daily Load Requirements A copy of the City of Detroit Storm Water Management Program Plan is included as Appendix E. To date, only TDML levels for Escherichia coli (E. coli) have been established for the Detroit River. Based on Table 11 in the 2008 MDEQ Total Maximum Daily Load for E. coli for the Detroit River document, the Waste Load Allocation (WLA) for Industrial sites covered under the General Permit MIS310000 has been set at 1.92E+10 cfu/day. AKT Peerless does not expect

that the Detroit Bulk Storage would contribute measurable E. coli counts to this WLA with no material source on site and no known illicit connections/discharges. However, if changes to the site occur in the future that result in a potential material source of E. coli, additional evaluation will be conducted at that time. 5.1.8 List of Significant Materials Still Present The non-structural controls outlined above appear to be sufficient in minimizing the potential for significant materials to enter storm water at the facility. 5.2 STRUCTURAL CONTROLS

The northern and eastern areas of the property are covered with a mix of concrete, brick pavers and coarse gravel, the middle and western portion of the site where the Pet Coke is stored is covered by asphalt. Rail spurs with associated ballast material are located along the river bank between the seawall and the asphalt pad. All storm drain catch basins on the site have been permanently closed and capped with concrete. The area between the edge of the asphalt storage pad to the rail spurs and concrete seawall is being graded with milled asphalt in order to direct storm runoff away from the river. Surface contouring in this manner will prevent potential polluting materials from migrating outside the bulk storage area. 6.0 EVALUATION OF NON-STORM WATER DISCHARGES

The permit requires that all discharge locations be evaluated for the presence of unauthorized non-storm water discharges. Any unauthorized storm water discharges must be eliminated, or covered under another NPDES permit. No unauthorized storm water discharges have been identified at the property. A site Fugitive Dust Control Plan addresses potential discharge of Pet Coke directly into the Detroit River by means other than storm water runoff. The Fugitive Dust Control Plan is included as Appendix G. 7.0 RECORD KEEPING AND REPORTING

Records of all preventive maintenance inspections, the quarterly comprehensive site inspections, records of employee training sessions, the annual report, and records describing incidents such as spills or other discharges that can affect the quality of storm water runoff will be retained at DBS for at least three years. Examples of the record keeping forms are included as Appendix B of this plan. These records will be made available to the MDEQ upon request. 7.1 ANNUAL REVIEW

The SWPPP will be reviewed and updated annually and a written summary of the review will be retained on site. Based on the results of the annual review, the SWPPP will be amended accordingly to ensure continued compliance. This will include any changes that have been made at the facility, the reason for the changes, any spills that occurred, actions taken as a

result of the spill, inspection results, and any other information relevant to the SWPPP. This SWPPP will be evaluated and updated on an annual basis or whenever significant changes to DBS site operations are planned. Plan updates will be based on information obtained from the routine inspections, Quarterly comprehensive inspections, and record keeping and reporting procedures prescribed herein. Next scheduled evaluation and update: on or before October 1, 2014 7.2 RECORD KEEPING AND REPORTING FORMS

A master copy of the following record keeping and reporting forms are provided in Appendix B: 8.0 Preventive Maintenance Good Housekeeping Quarterly Comprehensive Inspection Employee Training Significant Spill Report Annual Review CERTIFICATION OF THE SWPPP

I certify under penalty of law that the storm water drainage system in this SWPPP has been tested or evaluated for the presence of non-storm water discharges either by me, or under my direction and supervision. I certify under penalty of law that this SWPPP has been developed in accordance with good engineering practices. To the best of my knowledge and belief, the information submitted is true, accurate, and complete. At the time this plan was completed, no unauthorized discharges were present. I am aware that there are significant penalties for submitting false information, including the possibility of fine or imprisonment for knowing violations. (Signature of Site Operator) John Frye (Printed Name)

(Date)

(Signature of Corporate Officer) Noel Frye (Printed Name) Vice President

(Date) (Title)

FIGURES

APPENDIX A GENERAL STORM WATER PERMIT

PERMIT NO. MIS310000

STATE OF MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY


NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM WASTEWATER DISCHARGE GENERAL PERMIT
STORM WATER FROM INDUSTRIAL ACTIVITY IN CYCLE-YEAR 3 WATERSHEDS
In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251 et seq; the "Federal Act"), Michigan Act 451, Public Acts of 1994, as amended (the "Michigan Act"), Parts 31 and 41, and Michigan Executive Orders 1991-31, 1995-4 and 1995-18, storm water associated with industrial activity, as defined under 40 CFR 122.26(b)(14)(i-ix) and (xi), or as deemed necessary under Section 402(p)(2)(E) of the Federal Act, and other storm water which is adequately regulated by this general permit is authorized to be discharged from facilities specified in individual certificates of coverage in accordance with effluent limitations, monitoring requirements and other conditions set forth in this general National Pollutant Discharge Elimination System (NPDES) permit (the permit). The applicability of this permit shall be limited to facilities which discharge storm water to surface waters of the state located within a cycle-year 3 watershed, as listed in http://www.deq.state.mi.us/documents/deqwater-npdes-basins-BY01map.pdf. This permit does not authorize discharges determined by the Michigan Department of Environmental Quality (the Department) to need individual NPDES permits or different general permits, or that may cause or contribute to a violation of the Water Quality Standards. In order to constitute a valid authorization to discharge, this permit must be complemented by a certificate of coverage (COC) issued by the Department. Unless specified otherwise, all contact with the Department required by this permit shall be to the position indicated in the COC. This permit shall take effect April 1, 2008. The provisions of this permit are severable. After notice and opportunity for a hearing, this permit may be modified, suspended or revoked in whole or in part during its term in accordance with applicable laws and rules. This permit shall expire at midnight, April 1, 2013. Issued September 19, 2007.

Original Permit Signed by William Creal William Creal, Chief Permits Section Water Bureau

PERMIT NO. MIS310000

Page 2 of 24

PERMIT FEE REQUIREMENTS


In accordance with Section 324.3118 of the Michigan Act, the permittee shall make payment of an annual storm water fee to the Department for each January 1 the permit is in effect regardless of occurrence of discharge. The permittee shall submit the fee in response to the Department's annual notice. The fee shall be postmarked by March 15 for notices mailed by February 1. The fee is due no later than 45 days after receiving the notice for notices mailed after February 1.

CONTESTED CASE INFORMATION


The terms and conditions of this permit shall apply to an individual facility on the effective date of a COC for the facility. The Department of Labor and Economic Growth may grant a contested case hearing on this permit in accordance with the Michigan Act. Any person who is aggrieved by this permit may file a sworn petition with the State Office of Administrative Hearings and Rules of the Michigan Department of Labor and Economic Growth, setting forth the conditions of the permit which are being challenged and specifying the grounds for the challenge. The Department of Labor and Economic Growth may grant a contested case hearing on the COC issued to an individual facility under this permit in accordance with Rule 2192(c) (Rule 323.2192 of the Michigan Administrative Code).

PERMIT NO. MIS310000

Page 3 of 24

PART I

Section A. Discharge Authorization


During the period beginning on the effective date of this permit and an individual COC and lasting until the expiration of this permit or termination of the individual COC, the permittee is authorized to discharge storm water to the surface waters of the State of Michigan.

Section B. Schedules and Certifications


A Notice of Intent (NOI) or other Department-approved application shall be submitted to the Department to obtain a COC authorizing discharge under this permit. The permittee must comply with the schedule and certification requirements in either Part I.B.1. or Part I.B.2., below.

1.

Schedules and Certifications for New Storm Water General Permit Applicants

Applicants requesting first-time authorization to discharge storm water associated with an industrial activity under a general permit shall comply with the following requirements prior to submittal of an NOI or other Department-approved application to be covered under this permit: a. Schedule A first-time applicant will not receive a COC issued under this permit unless the NOI or application is accompanied by certification of compliance with the certified operator and Storm Water Pollution Prevention Plan (SWPPP) requirements of this permit as follows: 1) Certified Operator The applicant shall have a storm water operator certified by the Department, as required by Section 3110 of the Michigan Act. The certified operator shall have supervision over the facilitys storm water treatment and control measures included in the SWPPP. SWPPP The applicants SWPPP shall be developed in accordance with Parts I.C.1. through I.C.3. and ready for implementation prior to submittal of an NOI or other application to be covered under this permit. The SWPPP shall be signed by the certified operator and the permittee. Applicants shall be fully ready to carry out the activities specified in their SWPPP and comply with this permit in order to be issued a COC. New facilities shall have a COC issued under this permit prior to commencement of discharge of storm water associated with industrial activity.

2)

b.

Certification When submitting an NOI or other application for this permit, the permittee shall also submit a written certification that the facility is in compliance with the requirements identified in Parts I.B.1.b.1) through 5). The certification shall be a written statement that the SWPPP has been completed and is being implemented. It is not necessary to submit the SWPPP to the Department unless requested. New facilities shall fulfill the requirements of Parts I.B.1.b.4) and 5) when industrial activity begins. 1) The facility has a certified storm water operator as required in Part I.B.1.a.1). All operators names and certification numbers shall be included in the written certification. If a certified operators number is not available at the time the written certification is submitted, provide the date the operator took the certification exam, the location of the Departments office where the exam was taken, and the signature of the person who took the exam. The source identification requirements of the SWPPP are completed and identified in the plan (see Part I.C.1.). Non-structural preventative measures and source controls are being implemented (see Part I.C.2.). The structural controls for prevention and treatment (see Part I.C.3.), if needed, are installed and operational. If no structural controls are needed, indicate so in writing. Non-storm water discharges are eliminated or authorized by an NPDES permit (see Part I.D.3.).

2)

3) 4)

5)

PERMIT NO. MIS310000

Page 4 of 24

Part I Section B. Schedules and Certifications


2. Schedules and Certifications for Storm Water Dischargers with Previous Permit Requirements for a SWPPP
A permittee who has been authorized to discharge storm water under a permit other than this permit, which required a SWPPP, and who submits an NOI or other application for authorization to discharge under this permit, shall comply with the following: a. Schedule Continue development and implementation of the SWPPP in accordance with the schedule established under the individual permit, or general permit and COC, held previous to this permit. That schedule shall be enforceable under this permit. Certification 1) When submitting an NOI or other application for this permit, the permittee shall also submit a written certification that the facility is in compliance with its current storm water general permit and COC or the SWPPP requirements of its individual permit. The certification shall be a written statement that the SWPPP has been completed and is being implemented. The written certification shall include the name and certification number of the certified storm water operator. It is not necessary to submit the SWPPP to the Department unless requested to do so. The applicant shall have a storm water operator certified by the Department, as required by Section 3110 of the Michigan Act. The certified operator shall have supervision over the facility's storm water treatment and control measures included in the SWPPP.

b.

2)

PERMIT NO. MIS310000

Page 5 of 24

PART I

Section C. SWPPP
1. Source Identification
To identify potential sources of significant materials that can pollute storm water and subsequently be discharged from the facility, the SWPPP shall, at a minimum, include the following items: a. A site map identifying the following: 1) buildings and other permanent structures; 2) storage or disposal areas for significant materials; 3) secondary containment structures and descriptions of what they contain; 4) storm water discharge outfalls (numbered for reference); 5) location of storm water and non-storm water inlets contributing to each outfall; 6) location of NPDES permitted discharges other than storm water; 7) outlines of the drainage areas contributing to each outfall; 8) structural runoff controls or storm water treatment facilities; 9) areas of vegetation (with brief description such as lawn, old field, marsh, wooded, etc); 10) areas of exposed and/or erodible soils; 11) impervious surfaces (roofs, asphalt, concrete); 12) name and location of receiving water(s); and 13) areas of known or suspected impacts on surface waters as designated under Part 201 (Environmental Response) of the Michigan Act. A list of all significant materials that could pollute storm water. For each material listed, the SWPPP shall include each of the following descriptions: 1) Ways in which each type of material has been or has reasonable potential to become exposed to storm water (e.g., spillage during handling; leaks from pipes, pumps, and vessels; contact with storage piles, contaminated materials or soils; waste handling and disposal; deposits from dust or overspray; etc.). An evaluation and written description of the reasonable potential for contribution of significant materials to runoff from at least the following areas or activities: a. loading, unloading, and other material handling operations; b. outdoor storage including secondary containment structures; c. outdoor manufacturing or processing activities; d. significant dust or particulate generating processes; e. discharge from vents, stacks and air emission controls; f. on-site waste disposal practices; g. maintenance and cleaning of vehicles, machines and equipment; h. areas of exposed and/or erodible soils; i. Sites of Environmental Contamination listed under Part 201 (Environmental Response) of the Michigan Act; j. areas of significant material residues; k. areas where animals congregate (wild or domestic) and deposit wastes; and l. other areas where storm water may contact significant materials. Identification of the outfall(s) through which the material may be discharged if released.

b.

2)

3) c.

A listing of significant spills and significant leaks of polluting materials that occurred at areas that are exposed to precipitation or that otherwise discharge to a point source at the facility. The listing shall include spills that occurred over the three (3) years prior to the effective date of a COC authorizing discharge under this permit. The listing shall

PERMIT NO. MIS310000

Page 6 of 24

PART I

Section C. SWPPP
include the date, volume and exact location of release, and the action taken to clean up the material and/or prevent exposure to storm water runoff or contamination of surface waters of the state. Any release that occurs after the SWPPP has been developed shall be controlled in accordance with the SWPPP and is cause for the SWPPP to be updated as appropriate within 14 calendar days of obtaining knowledge of the spill or loss. d. If there is a Total Maximum Daily Load (TMDL) established by the Department for the receiving water, which restricts the discharge of any of the identified significant materials or constituents of those materials, then the SWPPP shall identify the level of control for those materials necessary to comply with the TMDL, and an estimate of the current annual load of those materials via storm water discharges to the receiving stream. A summary of existing storm water discharge sampling data (if available) describing pollutants in storm water discharges associated with industrial activity at the facility. This summary shall be accompanied by a description of the suspected source(s) of the pollutants detected.

e.

2.

Preventive Measures and Source Controls, Non-Structural

To prevent significant materials from contacting storm water at the source, the SWPPP shall, at a minimum, include each of the following non-structural controls: a. A program which includes a schedule for routine preventive maintenance. The preventative maintenance program shall consist of routine inspections and maintenance of storm water management and control devices (e.g., cleaning of oil/water separators and catch basins, routine housekeeping activities, and cleaning out catch basins) as well as inspecting and testing plant equipment and systems to uncover conditions that could cause breakdowns or failures resulting in discharges of pollutants to surface waters. The routine inspection shall include those areas of the facility in which significant materials have the reasonable potential to contaminate runoff. A log of the inspection and corrective actions shall be maintained on file by the permittee, and shall be retained in accordance with Part I.D.1. A schedule for comprehensive site inspection to include visual inspection of equipment, plant areas, and structural pollution prevention and treatment controls to be performed at least quarterly. The permittee may request Department approval of an alternate schedule for comprehensive site inspections. A report of the results of the comprehensive site inspection shall be prepared and retained in accordance with Part I.D.1. The report shall identify any incidents of non-compliance with the SWPPP or this permit. If there are no reportable incidents of non-compliance, the report shall contain a certification that the facility is in compliance with this permit. A description of good housekeeping procedures to maintain a clean, orderly facility. Good housekeeping procedures shall include routine inspections of the areas of the facility in which the procedures are implemented. The routine inspections of good housekeeping procedures may be combined with the routine inspections for the preventative maintenance program. A description of material handling procedures and storage requirements for significant materials. Equipment and procedures for cleaning up spills shall be identified in the SWPPP and made available to the appropriate personnel. The procedures shall identify measures to prevent spilled materials or material residues on the outside of containers from being discharged into storm water. The SWPPP may include, by reference, requirements of either a Pollution Incident Prevention Plan (PIPP) prepared in accordance with the Part 5 Rules (Rules 324.2001 through 324.2009 of the Michigan Administrative Code); a Hazardous Waste Contingency Plan prepared in accordance with 40 CFR 264 and 265 Subpart D, as required by Part 111 of the Michigan Act; or a Spill Prevention Control and Countermeasure (SPCC) plan prepared in accordance with 40 CFR 112. Identification of areas which, due to topography, activities, or other factors, have a high potential for significant soil erosion. The SWPPP shall also identify measures used to control soil erosion and sedimentation. A description of employee training programs which will be implemented to inform appropriate personnel at all levels of responsibility of the components and goals of the SWPPP. The SWPPP shall identify periodic dates for such training.

b.

c.

d.

e.

f.

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Section C. SWPPP
g. Identification of actions to limit the discharge of significant materials in order to comply with TMDL requirements. Identification of significant materials expected to be present in storm water discharges following implementation of non-structural preventative measures and source controls.

h.

3.

Structural Controls for Prevention and Treatment

Where implementation of the measures required by Part I.C.2. does not control storm water discharges in accordance with Part I.D.2., the SWPPP shall provide a description of the location, function, and design criteria of structural controls for prevention and treatment. Structural controls may be necessary: 1) To prevent uncontaminated storm water from contacting or being contacted by significant materials; or

2) If preventive measures are not feasible or are inadequate to keep significant materials at the site from contaminating storm water. Structural controls shall be used to treat, divert, isolate, recycle, reuse or otherwise manage storm water in a manner that reduces the level of significant materials in the storm water and provides compliance with the Water Quality Standards as identified under Part I.D.2.

4.
a.

Keeping Plans Current


The permittee shall review the SWPPP annually after it is developed and maintain written summaries of the reviews. Based on the review, the permittee shall amend the SWPPP as needed to ensure continued compliance with the terms and conditions of this permit. The SWPPP developed under the conditions of a previous permit shall be amended as necessary to ensure compliance with this permit. The SWPPP shall be updated or amended whenever changes or spills at the facility increase or have the potential to increase the exposure of significant materials to storm water, or when the SWPPP is determined by the permittee or the Department to be ineffective in achieving the general objectives of controlling pollutants in storm water discharges associated with industrial activity. Updates based on increased activity or spills at the facility shall include a description of how the permittee intends to control any new sources of significant materials or respond to and prevent spills in accordance with the requirements of Parts I.C.1., I.C.2., and I.C.3. of this permit. The Department or authorized representative may notify the permittee at any time that the SWPPP does not meet minimum requirements. Such notification shall identify why the SWPPP does not meet minimum requirements. The permittee shall make the required changes to the SWPPP within 30 days after such notification from the Department or authorized representative, and shall submit to the Department a written certification that the requested changes have been made. Amendments shall be signed and retained with the SWPPP on site pursuant to Part I.C.6.a.

b. c.

d.

e.

5.

Certified Operator Update

If the certified operator is changed or an additional certified operator is added, the permittee shall provide the name and certification number of the new certified operator to the Department. The new operator shall review and sign the SWPPP.

6.
a.

Signature and SWPPP Review


The SWPPP shall be signed by the storm water certified operator and by either the permittee or an authorized representative in accordance with 40 CFR 122.22. The SWPPP shall be retained on-site at the facility which generates the storm water discharge. The permittee shall make the SWPPP, reports, log books, storm water discharge sampling data (if collected), and supporting documents available upon request to the Department or authorized representative.

b.

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PART I

Section D. Special Conditions


1. Record Keeping
The permittee shall maintain records of all SWPPP related inspection and maintenance activities. Records shall also be kept describing incidents such as spills or other discharges that can affect the quality of storm water runoff. All such records shall be retained for three years. The following records are required by this permit:

Routine maintenance inspections (Part I.C.2.a.) Good housekeeping inspections (Part I.C.2.c.) The routine maintenance inspection and good housekeeping inspection may be combined. Comprehensive inspection reports (Part I.C.2.b.) Written summaries of the annual SWPPP review. (Part I.C.4.a)

2.

Water Quality Standards

At the time of discharge, there shall be no violation of the Water Quality Standards in the receiving waters as a result of the storm water discharge. This requirement includes, but is not limited to, the following conditions: a. In accordance with Rule 323.1050 of the Water Quality Standards, the receiving waters shall not have any of the following unnatural physical properties as a result of this discharge in quantities which are or may become injurious to any designated use: turbidity, color, oil films, floating solids, foams, settleable solids, suspended solids, or deposits. Any unusual characteristics of the discharge (i.e., unnatural turbidity, color, oil film, floating solids, foams, settleable solids, suspended solids, or deposits) shall be reported within 24 hours to the Department followed by a written report within five (5) days detailing the findings of the investigation and the steps taken to correct the condition. Any pollutant for which a level of control is specified to meet a Total Maximum Daily Load (TMDL) established by the Department shall be controlled at the facility so that its discharge is reduced by the amount specified in the waste load allocation of the TMDL. Any reduction achieved through implementation of the non-structural controls or structural controls in accordance with Parts I.C.2. or I.C.3. shall count toward compliance with the TMDL.

b.

c.

3.

Prohibition of Non-Storm Water Discharges

Discharges of material other than storm water shall be in compliance with an NPDES permit (other than this permit) issued for the discharge. Storm water shall be defined to include all of the following non-storm water discharges provided pollution prevention controls for the non-storm water component are identified in the SWPPP: a. b. c. d. e. f. g. h. i. j. k. discharges from fire hydrant flushing; potable water sources including water line flushing; water from fire system testing and fire fighting training without burned materials or chemical fire suppressants; irrigation drainage; lawn watering; routine building wash down which does not use detergents or other compounds; pavement wash waters where contamination by toxic or hazardous materials have not occurred (unless all contamination by toxic or hazardous materials have been removed) and where detergents are not used; air conditioning condensate; springs; uncontaminated ground water; and foundation or footing drains where flows are not contaminated with process materials such as solvents.

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PART I

Section D. Special Conditions


Discharges from fire fighting activities are authorized by this permit, but are exempted from the requirement to be identified in the SWPPP.

4.

Request for Discharge of Water Treatment Additives

In the event a permittee proposes to discharge water additives, the permittee shall submit a request to discharge water additives to the Department for approval. Such requests shall be sent to the Surface Water Assessment Section, Water Bureau, Department of Environmental Quality, P.O. Box 30273, Lansing, Michigan 48909, with a copy to the Department contact listed on the COC. Instructions to submit a request electronically may be obtained via the Internet (http://www.michigan.gov/deq and on the left side of the screen click on Water, Water Quality Monitoring, and Assessment of Michigan Waters; then click on the Water Treatment Additive List which is under the Information banner). Written approval from the Surface Water Assessment Section to discharge such additives at specified levels shall be obtained prior to discharge by the permittee. Additional monitoring and reporting may be required as a condition for the approval to discharge the additive. A request to discharge water additives shall include all of the following water additive usage and discharge information: a. b. c. d. e. f. g. Material Safety Data Sheet; the proposed water additive discharge concentration; the discharge frequency (i.e., number of hours per day and number of days per year); the monitoring point from which the product is to be discharged; the type of removal treatment, if any, that the water additive receives prior to discharge; product function (i.e. microbiocide, flocculant, etc.); a 48-hour LC50 or EC50 for a North American freshwater planktonic crustacean (either Ceriodaphnia sp., Daphnia sp., or Simocephalus sp.); and the results of a toxicity test for one other North American freshwater aquatic species (other than a planktonic crustacean) that meets a minimum requirement of Rule 323.1057(2) of the Water Quality Standards.

h.

Prior to submitting the request, the permittee may contact the Surface Water Assessment Section by telephone at 517-335-1180 or via the Internet at the address given above to determine if the Department has the product toxicity data required by items g. and h. above. If the Department has the data, the permittee will not need to submit product toxicity data.

5.

Tracer Dye Discharges

This permit does not authorize the discharge of tracer dyes without approval from the Department. Requests to discharge tracer dyes shall be submitted to the Department in accordance with Rule 1097 (Rule 323.1097 of the Michigan Administrative Code).

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PART I

Section D. Special Conditions


6. Facility Contact
The Facility Contact was specified in the application. The permittee may replace the facility contact at any time, and shall notify the Department in writing within 10 days after replacement (including the name, address and telephone number of the new facility contact). a. The facility contact shall be (or a duly authorized representative of this person): for a corporation, a principal executive officer of at least the level of vice president, or a designated representative, if the representative is responsible for the overall operation of the facility from which the discharge described in the permit application or other NPDES form originates, for a partnership, a general partner, for a sole proprietorship, the proprietor, or for a municipal, state, or other public facility, either a principal executive officer, the mayor, village president, city or village manager or other duly authorized employee. A person is a duly authorized representative only if: the authorization is made in writing to the Department by a person described in paragraph a. of this section; and the authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity such as the position of plant manager, operator of a well or a well field, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters for the facility (a duly authorized representative may thus be either a named individual or any individual occupying a named position).

b.

Nothing in this section obviates the permittee from properly submitting reports and forms as required by law.

7.
a.

Portable Industrial Facilities


Storm water discharges from satellite locations of a portable industrial facility may be authorized by obtaining a COC issued under this permit. To obtain a COC, an NOI or other Department-approved application must be submitted to the Permits Section of the Water Bureau for a primary mailing address of the owner or operator of the portable facility. Following receipt of a COC, if the portable facility is to be moved to a satellite location, the permittee shall notify the Department of the relocation, in writing, at least 10 days prior to start-up at the satellite location. Written notification shall include the location (township, range, section, and quarter-quarter section) of the current and proposed sites for the portable facility, the receiving water for the discharge, and the anticipated date of the move. Failure to notify the Department concerning the satellite location is a permit violation. The permittee shall submit an NOI or other Department-approved application for each portable facility that could be moved to a satellite location. A SWPPP shall be in place for each facility at the time of start-up and shall be modified for each new location as necessary.

b.

8.

Expiration and Reissuance

On or before October 1, 2012, a permittee seeking continued authorization to discharge under this permit beyond the permits expiration date shall submit to the Department a written request containing such information, form, and fees as required by the Department. Without an adequate request, a permittees authorization to discharge will expire on April 1, 2013. With an adequate request, a permittee shall continue to be subject to the terms and conditions of the expired permit until the Department takes action on the request unless this permit is terminated or revoked. If this permit is terminated or revoked, all authorizations to discharge under the permit shall expire on the date of termination or revocation. If this permit is modified, the Department will notify the permittee of any required action. Without an adequate response, a permittees authorization to discharge will terminate on the effective date of the modified permit. With an adequate

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PART I

Section D. Special Conditions


response, a permittee shall be subject to the terms and conditions of the modified permit on the effective date of the modified permit unless the department notifies the permittee otherwise. If a discharge is terminated, the permittee shall request termination of discharge authorization.

9.
a. b.

Termination of General Permit Coverage


all storm water discharges associated with industrial activity are eliminated; or industrial activity has ceased and no significant materials remain or are exposed to storm water.

A permittee may submit a request to the Department to terminate the COC for a facility when:

10.

Requirement to Obtain Individual Permit

The Department may require any person who is authorized to discharge by a COC and this permit, to apply for and obtain an individual NPDES permit if any of the following circumstances apply: a. b. c. the discharge is a significant contributor to pollution as determined by the Department on a case-by-case basis; the discharger is not complying or has not complied with the conditions of the permit; a change has occurred in the availability of demonstrated technology or practices for the control or abatement of waste applicable to the point source discharge; effluent standards and limitations are promulgated for point source discharges subject to this permit; and the Department determines that the criteria under which the permit was issued no longer apply.

d. e.

Any person may request the Department to take action pursuant to the provisions of Rule 2191 (Rule 323.2191 of the Michigan Administrative Code).

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PART II

Section A. Definitions
This list of definitions may include terms not applicable to this permit. Acute toxic unit (TUA) means 100/LC50 where the LC50 is determined from a whole effluent toxicity (WET) test which produces a result that is statistically or graphically estimated to be lethal to 50% of the test organisms. Bioaccumulative chemical of concern (BCC) means a chemical which, upon entering the surface waters, by itself or as its toxic transformation product, accumulates in aquatic organisms by a human health bioaccumulation factor of more than 1000 after considering metabolism and other physiochemical properties that might enhance or inhibit bioaccumulation. The human health bioaccumulation factor shall be derived according to R 323.1057(5). Chemicals with half-lives of less than 8 weeks in the water column, sediment, and biota are not BCCs. The minimum bioaccumulation concentration factor (BAF) information needed to define an organic chemical as a BCC is either a field-measured BAF or a BAF derived using the biota-sediment accumulation factor (BSAF) methodology. The minimum BAF information needed to define an inorganic chemical as a BCC, including an organometal, is either a field-measured BAF or a laboratory-measured bioconcentration factor (BCF). The BCCs to which these rules apply are identified in Table 5 of R 323.1057 of the Water Quality Standards. Biosolids are the solid, semisolid, or liquid residues generated during the treatment of sanitary sewage or domestic sewage in a treatment works. This includes, but is not limited to, scum or solids removed in primary, secondary, or advanced wastewater treatment processes and a derivative of the removed scum or solids. Bulk biosolids means biosolids that are not sold or given away in a bag or other container for application to a lawn or home garden. Certificate of Coverage (COC) means a document, issued by the Department, which authorizes a discharge under this permit. Chronic toxic unit (TUC) means 100/MATC or 100/IC25, where the maximum acceptable toxicant concentration (MATC) and IC25 are expressed as a percent effluent in the test medium. Class B Biosolids refers to material that has met the Class B pathogen reduction requirements or equivalent treatment by a Process to Significantly Reduce Pathogens (PSRP) in accordance with the Part 24 Rules. Processes include aerobic digestion, composting, anaerobic digestion, lime stabilization and air drying. Daily concentration is the sum of the concentrations of the individual samples of a parameter divided by the number of samples taken during any calendar day. If the parameter concentration in any sample is less than the quantification limit, regard that value as zero when calculating the daily concentration. The daily concentration will be used to determine compliance with any maximum and minimum daily concentration limitations (except for pH and dissolved oxygen). When required by the permit, report the maximum calculated daily concentration for the month in the MAXIMUM column under QUALITY OR CONCENTRATION on the Discharge Monitoring Reports (DMRs). For pH, report the maximum value of any individual sample taken during the month in the MAXIMUM column under QUALITY OR CONCENTRATION on the DMRs and the minimum value of any individual sample taken during the month in the MINIMUM column under QUALITY OR CONCENTRATION on the DMRs. For dissolved oxygen, report the minimum concentration of any individual sample in the MINIMUM column under QUALITY OR CONCENTRATION on the DMRs. Daily loading is the total discharge by weight of a parameter discharged during any calendar day. This value is calculated by multiplying the daily concentration by the total daily flow and by the appropriate conversion factor. The daily loading will be used to determine compliance with any maximum daily loading limitations. When required by the permit, report the maximum calculated daily loading for the month in the MAXIMUM column under QUANTITY OR LOADING on the DMRs. Department means the Michigan Department of Environmental Quality. Detection Level means the lowest concentration or amount of the target analyte that can be determined to be different from zero by a single measurement at a stated level of probability.

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PART II

Section A. Definitions
EC50 means a statistically or graphically estimated concentration that is expected to cause 1 or more specified effects in 50% of a group of organisms under specified conditions. Fecal coliform bacteria monthly is the geometric mean of the samples collected in a calendar month (or 30 consecutive days). The calculated monthly value will be used to determine compliance with the maximum monthly fecal coliform bacteria limitations. When required by the permit, report the calculated monthly value in the AVERAGE column under QUALITY OR CONCENTRATION on the DMRs. Fecal coliform bacteria 7-day is the geometric mean of the samples collected in any 7-day period. The calculated 7-day value will be used to determine compliance with the maximum 7-day fecal coliform bacteria limitations. When required by the permit, report the maximum calculated 7-day concentration for the month in the MAXIMUM column under QUALITY OR CONCENTRATION on the DMRs. Flow Proportioned sample is a composite sample with the sample volume proportional to the effluent flow. Grab sample is a single sample taken at neither a set time nor flow. IC25 means the toxicant concentration that would cause a 25% reduction in a nonquantal biological measurement for the test population. Individual Permit means a site-specific NPDES permit. Inlet means a catch basin, roof drain, conduit, drain tile, retention pond riser pipe, sump pump, or other point where storm water or wastewater enters into a closed conveyance system prior to discharge off site or into waters of the state. Interference is a discharge which, alone or in conjunction with a discharge or discharges from other sources, both: 1) inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal; and 2) therefore, is a cause of a violation of any requirement of the POTW's NPDES permit (including an increase in the magnitude or duration of a violation) or, of the prevention of sewage sludge use or disposal in compliance with the following statutory provisions and regulations or permits issued thereunder (or more stringent state or local regulations): Section 405 of the Clean Water Act, the Solid Waste Disposal Act (SWDA) (including Title II, more commonly referred to as the Resource Conservation and Recovery Act (RCRA), and including state regulations contained in any state sludge management plan prepared pursuant to Subtitle D of the SWDA), the Clean Air Act, the Toxic Substances Control Act, and the Marine Protection, Research and Sanctuaries Act. [This definition does not apply to sample matrix interference.] Land Application means spraying or spreading biosolids or a biosolids derivative onto the land surface, injecting below the land surface, or incorporating into the soil so that the biosolids or biosolids derivative can either condition the soil or fertilize crops or vegetation grown in the soil. LC50 means a statistically or graphically estimated concentration that is expected to be lethal to 50% of a group of organisms under specified conditions. Maximum acceptable toxicant concentration (MATC) means the concentration obtained by calculating the geometric mean of the lower and upper chronic limits from a chronic test. A lower chronic limit is the highest tested concentration that did not cause the occurrence of a specific adverse effect. An upper chronic limit is the lowest tested concentration which did cause the occurrence of a specific adverse effect and above which all tested concentrations caused such an occurrence. MGD means million gallons per day. Monthly frequency of analysis refers to a calendar month. When required by this permit, an analytical result, reading, value or observation must be reported for that period if a discharge occurs during that period.

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PART II

Section A. Definitions
Monthly concentration is the sum of the daily concentrations determined during a reporting month (or 30 consecutive days) divided by the number of daily concentrations determined. The calculated monthly concentration will be used to determine compliance with any maximum monthly concentration limitations. When required by the permit, report the calculated monthly concentration in the AVERAGE column under QUALITY OR CONCENTRATION on the DMRs. For minimum percent removal requirements, the monthly influent concentration and the monthly effluent concentration shall be determined. The calculated monthly percent removal, which is equal to 100 times the quantity [1 minus the quantity (monthly effluent concentration divided by the monthly influent concentration)], shall be reported in the "MINIMUM" column under "QUALITY OR CONCENTRATION" on the DMRs. Monthly loading is the sum of the daily loadings of a parameter divided by the number of daily loadings determined in the reporting month (or 30 consecutive days). The calculated monthly loading will be used to determine compliance with any maximum monthly loading limitations. When required by the permit, report the calculated monthly loading in the AVERAGE column under QUANTITY OR LOADING on the DMRs. National Pretreatment Standards are the regulations promulgated by or to be promulgated by the Federal Environmental Protection Agency pursuant to Section 307(b) and (c) of the Federal Act. The standards establish nationwide limits for specific industrial categories for discharge to a POTW. New Facility means a facility located on a newly-developed or redeveloped site which is ready to begin industrial operations on or after the effective date of this permit. NOI means Notice of Intent to be covered by this permit. No observed adverse effect level (NOAEL) means the highest tested dose or concentration of a substance which results in no observed adverse effect in exposed test organisms where higher doses or concentrations result in an adverse effect. Noncontact Cooling Water is water used for cooling which does not come into direct contact with any raw material, intermediate product, by-product, waste product or finished product. Nondomestic user is any discharger to a POTW that discharges wastes other than or in addition to water-carried wastes from toilet, kitchen, laundry, bathing or other facilities used for household purposes. Partially treated sewage is any sewage, sewage and storm water, or sewage and wastewater, from domestic or industrial sources that is treated to a level less than that required by the permittee's National Pollutant Discharge Elimination System permit, or that is not treated to national secondary treatment standards for wastewater, including discharges to surface waters from retention treatment facilities. Point Source Discharge means a discharge from any discernible, confined, and discrete conveyance, including but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container or rolling stock. Changing the surface of land or establishing grading patterns on land will result in a point source where the runoff from the site is ultimately discharged to waters of the state. Polluting Materials means oil and any material, in solid or liquid form, identified as polluting material under the Part 5 Rules (Rules 324.2001 through 324.2009 of the Michigan Administrative Code). Pretreatment is reducing the amount of pollutants, eliminating pollutants, or altering the nature of pollutant properties to a less harmful state prior to discharge into a public sewer. The reduction or alteration can be by physical, chemical, or biological processes, process changes, or by other means. Dilution is not considered pretreatment unless expressly authorized by an applicable National Pretreatment Standard for a particular industrial category. POTW is a publicly owned treatment works.

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PART II

Section A. Definitions
Quantification level means the measurement of the concentration of a contaminant obtained by using a specified laboratory procedure calculated at a specified concentration above the detection level. It is considered the lowest concentration at which a particular contaminant can be quantitatively measured using a specified laboratory procedure for monitoring of the contaminant. Quarterly frequency of analysis refers to a three month period, defined as January through March, April through June, July through September, and October through December. When required by this permit, an analytical result, reading, value or observation must be reported for that period if a discharge occurs during that period. Regional Administrator is the Region 5 Administrator, U.S. EPA, located at R-19J, 77 W. Jackson Blvd., Chicago, Illinois 60604. Secondary Containment Structure means a unit, other than the primary container in which significant materials are packaged or held, which is required by State or Federal law to prevent the escape of significant materials by gravity into sewers, drains, or otherwise directly or indirectly into any sewer system or to the surface or ground waters of this state. Significant industrial user is a nondomestic user that: 1) is subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR Chapter I, Subchapter N; or 2) discharges an average of 25,000 gallons per day or more of process wastewater to a POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); contributes a process waste stream which makes up five (5) percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or is designated as such by the permittee as defined in 40 CFR 403.12(a) on the basis that the industrial user has a reasonable potential for adversely affecting the POTW's treatment plant operation or violating any pretreatment standard or requirement (in accordance with 40 CFR 403.8(f)(6)). Significant Materials means any material which could degrade or impair water quality, including but not limited to: raw materials; fuels; solvents, detergents, and plastic pellets; finished materials such as metallic products; hazardous substances designated under section 101(14) of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (See 40 CFR 372.65); any chemical the facility is required to report pursuant to section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA); polluting materials (as defined above); Hazardous Wastes as defined in Part 111 of the Michigan Act; fertilizers; pesticides; and waste products such as ashes, slag, sludge, and plant and animal wastes that have the potential to be released with storm water discharges. Significant Spills and Significant Leaks means any release of a polluting material reportable under the Part 5 Rules (Rules 324.2001 through 324.2009 of the Michigan Administrative Code). Storm Water means storm water runoff, snow melt runoff, surface runoff and drainage, and non-storm water included under the conditions of Part I.D.3. SWPPP means the Storm Water Pollution Prevention Plan prepared in accordance with Parts I.B. and I.C. of this permit. Tier I value means a value for aquatic life, human health or wildlife calculated under R 323.1057 of the Water Quality Standards using a tier I toxicity database. Tier II value means a value for aquatic life, human health or wildlife calculated under R 323.1057 of the Water Quality Standards using a tier II toxicity database. Total Maximum Daily Load or TMDL means the amount of pollutant load a water body such as a lake or stream can assimilate and still meet Water Quality Standards. Toxicity Reduction Evaluation (TRE) means a site-specific study conducted in a stepwise process designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm the reduction in effluent toxicity. Water Quality Standards means the Part 4 Water Quality Standards promulgated pursuant to Part 31 of Act No. 451 of the Public Acts of 1994, as amended, being Rules 323.1041 through 323.1117 of the Michigan Administrative Code.

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PART II

Section A. Definitions
Weekly frequency of analysis refers to a calendar week which begins on Sunday and ends on Saturday. When required by this permit, an analytical result, reading, value or observation must be reported for that period if a discharge occurs during that period. Yearly frequency of analysis refers to a calendar year beginning on January 1 and ending on December 31. When required by this permit, an analytical result, reading, value or observation must be reported for that period if a discharge occurs during that period. 24-Hour Composite sample is a flow proportioned composite sample consisting of hourly or more frequent portions that are taken over a 24-hour period. 3-Portion Composite sample is a sample consisting of three equal volume grab samples collected at equal intervals over an 8-hour period. 7-day concentration is the sum of the daily concentrations determined during any 7 consecutive days in a reporting month divided by the number of daily concentrations determined. The calculated 7-day concentration will be used to determine compliance with any maximum 7-day concentration limitations. When required by the permit, report the maximum calculated 7-day concentration for the month in the MAXIMUM column under QUALITY OR CONCENTRATION on the DMRs. 7-day loading is the sum of the daily loadings of a parameter divided by the number of daily loadings determined during any 7 consecutive days in a reporting month. The calculated 7-day loading will be used to determine compliance with any maximum 7-day loading limitations. When required by the permit, report the maximum calculated 7-day loading for the month in the MAXIMUM column under QUANTITY OR LOADING on the DMRs.

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PART II

Section B. Monitoring Procedures 1. Representative Samples

Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge.

2.

Test Procedures

Test procedures for the analysis of pollutants shall conform to regulations promulgated pursuant to Section 304(h) of the Federal Act (40 CFR Part 136 - Guidelines Establishing Test Procedures for the Analysis of Pollutants), unless specified otherwise in this permit. Requests to use test procedures not promulgated under 40 CFR Part 136 for pollutant monitoring required by this permit shall be made in accordance with the Alternate Test Procedures regulations specified in 40 CFR 136.4. These requests shall be submitted to the Chief of the Permits Section, Water Bureau, Michigan Department of Environmental Quality, P.O. Box 30273, Lansing, Michigan, 48909-7773. The permittee may use such procedures upon approval. The permittee shall periodically calibrate and perform maintenance procedures on all analytical instrumentation at intervals to ensure accuracy of measurements. The calibration and maintenance shall be performed as part of the permittees laboratory Quality Control/Quality Assurance program.

3.

Instrumentation

The permittee shall periodically calibrate and perform maintenance procedures on all monitoring instrumentation at intervals to ensure accuracy of measurements.

4.

Recording Results

For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: 1) the exact place, date, and time of measurement or sampling; 2) the person(s) who performed the measurement or sample collection; 3) the dates the analyses were performed; 4) the person(s) who performed the analyses; 5) the analytical techniques or methods used; 6) the date of and person responsible for equipment calibration; and 7) the results of all required analyses.

5.

Records Retention

All records and information resulting from the monitoring activities required by this permit including all records of analyses performed and calibration and maintenance of instrumentation and recordings from continuous monitoring instrumentation shall be retained for a minimum of three (3) years or longer if requested by the Regional Administrator or the Department.

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PART II

Section C. Reporting Requirements 1. Start-up Notification

If the permittee will not discharge during the first 60 days following the effective date of the facilitys COC, the permittee shall notify the Department within 14 days following the effective date of the COC, and then 60 days prior to the commencement of the discharge.

2.

Submittal Requirements for Self-Monitoring Data

Part 31 of Act 451 of 1994, as amended, specifically Section 324.3110(3) and Rule 323.2155(2) of Part 21 allows the department to specify the forms to be utilized for reporting the required self-monitoring data. Unless instructed on the effluent limitations page to conduct Retained Self Monitoring the permittee shall submit self-monitoring data via the Michigan DEQ Electronic Environmental Discharge Monitoring Reporting (e2-DMR) system. The permittee shall utilize the information provided on the e2-Reporting website @ http://secure1.state.mi.us/e2rs/ to access and submit the electronic forms. Both monthly summary and daily data shall be submitted to the department no later than the 20th day of the month following each month of the authorized discharge period(s).

3.

Retained Self-Monitoring Requirements

If instructed on the effluent limits page (or otherwise authorized by the Department in accordance with the provisions of this permit) to conduct retained self-monitoring, the permittee shall maintain a year-to-date log of retained self-monitoring results and, upon request, provide such log for inspection to the staff of the Department (Department as defined on the COC). Retained self-monitoring results are public information and shall be promptly provided to the public upon written request from the public. The permittee shall certify, in writing, to the Department, on or before January 10th of each year, that: 1) all retained self-monitoring requirements have been complied with and a year-to-date log has been maintained; and 2) the application on which this permit is based still accurately describes the discharge. With this annual certification, the permittee shall submit a summary of the previous years monitoring data. The summary shall include maximum values for samples to be reported as daily maximums and/or monthly maximums and minimum values for any daily minimum samples. Retained self-monitoring may be denied to a permittee by notification in writing from the Department. In such cases, the permittee shall submit self-monitoring data in accordance with Part II.C.2., above. Such a denial may be rescinded by the Department upon written notification to the permittee. Reissuance or modification of this permit or reissuance or modification of an individual permittees authorization to discharge shall not affect previous approval or denial for retained self-monitoring unless the Department provides notification in writing to the permittee.

4.

Additional Monitoring by Permittee

If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified above, the results of such monitoring shall be included in the calculation and reporting of the values required in the Discharge Monitoring Report. Such increased frequency shall also be indicated. Monitoring required pursuant to Part 41 of the Michigan Act or Rule 35 of the Mobile Home Park Commission Act (Act 96 of the Public Acts of 1987) for assurance of proper facility operation shall be submitted as required by the Department.

PERMIT NO. MIS310000

Page 19 of 24

PART II

Section C. Reporting Requirements 5. Compliance Dates Notification


Within 14 days of every compliance date specified in this permit, the permittee shall submit a written notification to the Department indicating whether or not the particular requirement was accomplished. If the requirement was not accomplished, the notification shall include an explanation of the failure to accomplish the requirement, actions taken or planned by the permittee to correct the situation, and an estimate of when the requirement will be accomplished. If a written report is required to be submitted by a specified date and the permittee accomplishes this, a separate written notification is not required.

6.

Noncompliance Notification

Compliance with all applicable requirements set forth in the Federal Act, Parts 31 and 41 of the Michigan Act, and related regulations and rules is required. All instances of noncompliance shall be reported as follows: a. 24-hour reporting - Any noncompliance which may endanger health or the environment (including maximum daily concentration discharge limitation exceedances) shall be reported, verbally, within 24 hours from the time the permittee becomes aware of the noncompliance. A written submission shall also be provided within five (5) days. Other reporting - The permittee shall report, in writing, all other instances of noncompliance not described in a. above at the time monitoring reports are submitted; or, in the case of retained self-monitoring, within five (5) days from the time the permittee becomes aware of the noncompliance.

b.

Written reporting shall include: 1) a description of the discharge and cause of noncompliance; and 2) the period of noncompliance, including exact dates and times; or, if not corrected, the anticipated time the noncompliance is expected to continue, and the steps taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.

7.

Spill Notification

The permittee shall immediately report any release of any polluting material which occurs to the surface waters or groundwaters of the state, unless the permittee has determined that the release is not in excess of the threshold reporting quantities specified in the Part 5 Rules (Rules 324.2001 through 324.2009 of the Michigan Administrative Code), by calling the Department at the number indicated in the COC, or if the notice is provided after regular working hours call the Departments 24-hour Pollution Emergency Alerting System telephone number, 1-800-292-4706 (calls from out-of-state dial 1-517-373-7660). Within ten (10) days of the release, the permittee shall submit to the Department a full written explanation as to the cause of the release, the discovery of the release, response (clean-up and/or recovery) measures taken, and preventative measures taken or a schedule for completion of measures to be taken to prevent reoccurrence of similar releases.

8.

Upset Noncompliance Notification

If a process "upset" (defined as an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee) has occurred, the permittee who wishes to establish the affirmative defense of upset, shall notify the Department by telephone within 24-hours of becoming aware of such conditions; and within five (5) days, provide in writing, the following information: a. b. c. that an upset occurred and that the permittee can identify the specific cause(s) of the upset; that the permitted wastewater treatment facility was, at the time, being properly operated; and that the permittee has specified and taken action on all responsible steps to minimize or correct any adverse impact in the environment resulting from noncompliance with this permit.

In any enforcement proceedings, the permittee, seeking to establish the occurrence of an upset, has the burden of proof.

PERMIT NO. MIS310000

Page 20 of 24

PART II

Section C. Reporting Requirements 9.


a.

Bypass Prohibition and Notification


Bypass Prohibition - Bypass is prohibited unless: 1) bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;

2) there were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if adequate backup equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass; and 3) b. the permittee submitted notices as required under 9.b. or 9.c. below.

Notice of Anticipated Bypass - If the permittee knows in advance of the need for a bypass, it shall submit prior notice to the Department, if possible at least ten (10) days before the date of the bypass, and provide information about the anticipated bypass as required by the Department. The Department may approve an anticipated bypass, after considering its adverse effects, if it will meet the three (3) conditions listed in 9.a. above. Notice of Unanticipated Bypass - The permittee shall submit notice to the Department of an unanticipated bypass by calling the Department at the number indicated in the COC (if the notice is provided after regular working hours, use the following number: 1-800-292-4706) as soon as possible, but no later than 24 hours from the time the permittee becomes aware of the circumstances. Written Report of Bypass - A written submission shall be provided within five (5) working days of commencing any bypass to the Department, and at additional times as directed by the Department. The written submission shall contain a description of the bypass and its cause; the period of bypass, including exact dates and times, and if the bypass has not been corrected, the anticipated time it is expected to continue; steps taken or planned to reduce, eliminate, and prevent reoccurrence of the bypass; and other information as required by the Department. Bypass Not Exceeding Limitations - The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of 9.a., 9.b., 9.c., and 9.d., above. This provision does not relieve the permittee of any notification responsibilities under Part II.C.10. of this permit. Definitions 1) Bypass means the intentional diversion of waste streams from any portion of a treatment facility.

c.

d.

e.

f.

2) Severe property damage means substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production.

10.

Notification of Changes in Discharge

The permittee shall notify the Department, in writing, within 10 days of knowing, or having reason to believe, that any activity or change has occurred or will occur which would result in the discharge of: 1) detectable levels of chemicals on the current Michigan Critical Materials Register, priority pollutants or hazardous substances set forth in 40 CFR 122.21, Appendix D, or the Pollutants of Initial Focus in the Great Lakes Water Quality Initiative specified in 40 CFR 132.6, Table 6, which were not acknowledged in the application or listed in the application at less than detectable levels; 2) detectable levels of any other chemical not listed in the application or listed at less than detection, for which the application specifically requested information; or 3) any chemical at levels greater than five times the average level reported in the complete application (see the COC for the date(s) the complete application was submitted). Any other monitoring results obtained as a requirement of this permit shall be reported in accordance with the compliance schedules.

PERMIT NO. MIS310000

Page 21 of 24

PART II

Section C. Reporting Requirements 11. Changes in Facility Operations


Any anticipated action or activity, including but not limited to facility expansion, production increases, or process modification, which will result in new or increased loadings of pollutants to the receiving waters must be reported to the Department by a) submission of an increased use request (application) and all information required under Rule 323.1098 (Antidegradation) of the Water Quality Standards or b) by notice if the following conditions are met: 1) the action or activity will not result in a change in the types of wastewater discharged or result in a greater quantity of wastewater than currently authorized by this permit; 2) the action or activity will not result in violations of the effluent limitations specified in this permit; 3) the action or activity is not prohibited by the requirements of Part II.C.12.; and 4) the action or activity will not require notification pursuant to Part II.C.10. Following such notice, the permit may be modified according to applicable laws and rules to specify and limit any pollutant not previously limited.

12.

Bioaccumulative Chemicals of Concern (BCC)

Consistent with the requirements of Rules 323.1098 and 323.1215 of the Michigan Administrative Code, the permittee is prohibited from undertaking any action that would result in a lowering of water quality from an increased loading of a BCC unless an increased use request and antidegradation demonstration have been submitted and approved by the Department.

13.

Transfer of Ownership or Control

In the event of any change in control or ownership of facilities from which the authorized discharge emanates, the permittee shall submit to the Department 30 days prior to the actual transfer of ownership or control a written agreement between the current permittee and the new permittee containing: 1) the legal name and address of the new owner; 2) a specific date for the effective transfer of permit responsibility, coverage and liability; and 3) a certification of the continuity of or any changes in operations, wastewater discharge, or wastewater treatment. If the new permittee is proposing changes in operations, wastewater discharge, or wastewater treatment, the Department may propose modification of this permit in accordance with applicable laws and rules.

PERMIT NO. MIS310000

Page 22 of 24

PART II

Section D. Management Responsibilities 1. Duty to Comply

All discharges authorized herein shall be consistent with the terms and conditions of this permit and the facilitys COC. The discharge of any pollutant identified in this permit and/or the facilitys COC more frequently than or at a level in excess of that authorized shall constitute a violation of the permit. It is the duty of the permittee to comply with all the terms and conditions of this permit and the facilitys COC. Any noncompliance with the Effluent Limitations, Special Conditions, or terms of this permit or the facilitys COC constitutes a violation of the Michigan Act and/or the Federal Act and constitutes grounds for enforcement action; for COC termination, revocation and reissuance, or modification; or denial of an application for permit or COC renewal.

2.

Operator Certification

The permittee shall have the waste treatment facilities under direct supervision of an operator certified at the appropriate level for the facility certification by the Department, as required by Sections 3110 and 4104 of the Michigan Act.

3.

Facilities Operation

The permittee shall, at all times, properly operate and maintain all treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance includes adequate laboratory controls and appropriate quality assurance procedures.

4.

Power Failures

In order to maintain compliance with the effluent limitations of this permit and prevent unauthorized discharges, the permittee shall either: a. provide an alternative power source sufficient to operate facilities utilized by the permittee to maintain compliance with the effluent limitations and conditions of this permit; or upon the reduction, loss, or failure of one or more of the primary sources of power to facilities utilized by the permittee to maintain compliance with the effluent limitations and conditions of this permit, the permittee shall halt, reduce or otherwise control production and/or all discharge in order to maintain compliance with the effluent limitations and conditions of this permit.

b.

5.

Adverse Impact

The permittee shall take all reasonable steps to minimize any adverse impact to the surface waters or groundwaters of the state resulting from noncompliance with any effluent limitation specified in this permit including, but not limited to, such accelerated or additional monitoring as necessary to determine the nature and impact of the discharge in noncompliance.

6.

Containment Facilities

The permittee shall provide facilities for containment of any accidental losses of polluting materials in accordance with the requirements of the Part 5 Rules (Rules 324.2001 through 324.2009 of the Michigan Administrative Code). For a Publicly Owned Treatment Work (POTW), these facilities shall be approved under Part 41 of the Michigan Act.

PERMIT NO. MIS310000

Page 23 of 24

PART II

Section D. Management Responsibilities 7. Waste Treatment Residues


Residuals (i.e. solids, sludges, biosolids, filter backwash, scrubber water, ash, grit, or other pollutants or wastes) removed from or resulting from treatment or control of wastewaters, including those that are generated during treatment or left over after treatment or control has ceased shall be disposed of in an environmentally compatible manner and according to applicable laws and rules. These laws may include, but are not limited to, the Michigan Act, Part 31 for protection of water resources, Part 55 for air pollution control, Part 111 for hazardous waste management, Part 115 for solid waste management, Part 121 for liquid industrial wastes, Part 301 for protection of inland lakes and streams, and Part 303 for wetlands protection. Such disposal shall not result in any unlawful pollution of the air, surface waters or groundwaters of the state.

8.

Right of Entry

The permittee shall allow the Department, any agent appointed by the Department or the Regional Administrator, upon the presentation of credentials: a. to enter upon the permittees premises where an effluent source is located or in which any records are required to be kept under the terms and conditions of this permit; and at reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect process facilities, treatment works, monitoring methods and equipment regulated or required under this permit; and to sample any discharge of pollutants.

b.

9.

Availability of Reports

Except for data determined to be confidential under Section 308 of the Federal Act and Rule 2128 (Rule 323.2128 of the Michigan Administrative Code), all reports prepared in accordance with the terms of this permit shall be available for public inspection at the offices of the Department and the Regional Administrator. As required by the Federal Act, effluent data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in Section 309 of the Federal Act and Sections 3112, 3115, 4106 and 4110 of the Michigan Act.

PERMIT NO. MIS310000

Page 24 of 24

PART II

Section E. Activities Not Authorized by This Permit 1. Discharge to the Groundwaters


This permit does not authorize any discharge to the groundwaters. Such discharge may be authorized by a groundwater discharge permit issued pursuant to the Michigan Act.

2.

Facility Construction

This permit does not authorize or approve the construction or modification of any physical structures or facilities. Approval for such construction for a POTW must be by permit issued under Part 41 of the Michigan Act. Approval for such construction for a mobile home park, campground or marina shall be from the Water Bureau, Michigan Department of Environmental Quality. Approval for such construction for a hospital, nursing home or extended care facility shall be from the Division of Health Facilities and Services, Michigan Department of Consumer and Industry Services upon request.

3.

Civil and Criminal Liability

Except as provided in permit conditions on "Bypass" (Part II.C.9. pursuant to 40 CFR 122.41(m)), nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance, whether or not such noncompliance is due to factors beyond the permittees control, such as accidents, equipment breakdowns, or labor disputes.

4.

Oil and Hazardous Substance Liability

Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee may be subject under Section 311 of the Federal Act except as are exempted by federal regulations.

5.

State Laws

Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable state law or regulation under authority preserved by Section 510 of the Federal Act.

6.

Property Rights

The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize violation of any federal, state or local laws or regulations, nor does it obviate the necessity of obtaining such permits, including any other Department of Environmental Quality permits, or approvals from other units of government as may be required by law.

APPENDIX B RECORD KEEPING AND REPORTING FORMS

DETROIT BULK STORAGE FACILITY

BIWEEKLY INSPECTION AND GOOD HOUSEKEEPING REPORT


Date: Inspected by (printed): Signature: The biweekly inspection and good housekeeping report must be completed at minimum every two weeks. Events such as ship loading should trigger a good-housekeeping inspection and report even if two weeks has not elapsed since the previous inspection. Areas Inspected
Concrete storm catch basin caps intact and undamaged 1,000-gallon Diesel Fuel AST and piping no spills or staining. Loading and unloading areas Spill Control Kits stocked and available Grounds (in general) trash/litter removed Property boundaries Excavators and Loading Equipment Trucks Product storage areas Pet Coke on asphalt pad

Time:

Observations

Actions Taken

DETROIT BULK STORAGE FACILITY

EMPLOYEE TRAINING
Date of Session: Trainer: Time:

(Printed)

(Signature) Signature:

Attendees (name, printed):

Topics Covered:

DETROIT BULK STORAGE FACILITY

SIGNIFICANT SPILL REPORT


Date of Occurrence: Discovered by Whom: Location:

Material Type & Volume:

Cause of Spill:

Corrective Action Taken:

Agencies/Persons Contacted:

Signature

DETROIT BULK STORAGE FACILITY

ANNUAL REVIEW SUMMARY


Date: Inspected by (printed): Signature: Annual SWPPP Review Checklist Check Box Item
Facility general information, personnel information, and training is current and accurate Site map is current and accurate New processes and related controls documented Spills have recorded and reported appropriately Routine preventive maintenance, housekeeping and employee training records available in SWPPP file Comprehensive quarterly site inspection reports completed, signed and available in SWPPP file

Comment/Action Taken

Plan/Facility Changes:

Reason for Changes:

DETROIT BULK STORAGE FACILITY

ANNUAL REVIEW SUMMARY (cont.)


Spills/Corrective Actions:

Plan Amendments Needed:

DETROIT BULK STORAGE FACILITY Quarterly Comprehensive Inspection Report Date: Inspected by (printed): Signature: Activity Area #1 Fueling Area Check Box Activity Area #2 Material Handling and Storage Check Box Item
Permanent concrete storm drain caps are intact and undamaged Berm along pier is intact. No signs of erosion or breakthrough All Pet Coke storage pile is exclusively on asphalt pad. Access roads assessed for track-out

Item
Spill clean-up materials located near fueling station Fuel pump shutoffs function properly Fuel dispensing equipment properly maintained Overflow protection devices on tank system Fueling station protected from damage

Comment/Action Taken

Comment/Action Taken

DETROIT BULK STORAGE FACILITY Quarterly Comprehensive Inspection Report Activity Area #3 Vehicle and Machine Maintenance Check Box Activity Area #4 General Check Box Item
Trash materials and litter are removed from grounds Property perimeter barriers/fences intact Biweekly reports complete and in the SWPPP file Any new employees have received SWPPP training

Item
Vehicles and machines checked for leaks Maintenance areas cleaned. Oil removed from machines is properly containerized and recycled Containers are properly labeled, stored off of the ground and protected from damage

Comment/Action Taken

Comment/Action Taken

Other:__________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________

APPENDIX C MDEQ SPILL OR RELEASE REPORT

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

SPILL OR RELEASE REPORT


NOTE: Some regulations require a specific form to use and procedures to follow when reporting a release. Those forms and procedures MUST be used and followed if reporting under those regulations. This report form is to aid persons reporting releases under regulations that do not require a specific form. This report form is not required to be used. To report a release, some regulations require a facility to call the PEAS Hotline at 800-292-4706, or DEQ District Office that oversees the county where it occurred, and other regulating agencies and provide the following information. A follow-up written report may be required. Keep a copy of this report as documentation that the release was reported. If you prefer to submit this report electronically by FAX or email, contact the regulating agency for the correct telephone number or e-mail address. See the DEQ website on Spill/Release Reporting for more reporting information.
Please print or type all information.
NAME AND TITLE OF PERSON SUBMITTING WRITTEN REPORT TELEPHONE NUMBER (provide area code)

NAME OF BUSINESS

RELEASE LOCATION (provide address if different than business, if known, and give directions to the spill location. Include nearest highway, town, road intersection, etc.)

STREET ADDRESS

CITY

STATE

ZIP CODE

BUSINESS TELEPHONE NUMBER (provide area code)

SITE IDENTIFICATION NUMBER AND OTHER IDENTIFYING NUMBERS (if applicable)

COUNTY

TOWNSHIP

TIER/RANGE/SECTION (if known)

RELEASE DATA. Complete all applicable categories. Check all the boxes that apply to the release. Provide the best available information regarding the release and its impacts. Attach additional pages if necessary.
DATE & TIME OF RELEASE (if known) _____/_____/_____ ___________am/pm DATE & TIME OF DISCOVERY _____/_____/_____ ___________am/pm DURATION OF RELEASE (if known) TYPE OF INCIDENT

___________________ days ___________________ hours ___________________ minutes

Explosion Fire Leaking container Loading/unloading release

Pipe/valve leak or rupture Vehicle accident Other _________________ ______________________


PHYSICAL STATE RELEASED (indicate if solid, liquid, or gas)

MATERIAL RELEASED (Chemical or trade name) CHECK HERE IF ADDITIONAL MATERIALS LISTED ON ATTACHED PAGE.

CAS NUMBER or HAZARDOUS WASTE CODE

ESTIMATED QUANTITY RELEASED (indicate unit e.g. lbs, gals, cu ft or yds)

FACTORS CONTRIBUTING TO RELEASE

SOURCE OF LOSS

Equipment failure Operator error Faulty process design


TYPE OF MATERIAL RELEASED

Training deficiencies Unusual weather conditions Other _______________________________________


MATERIAL LISTED ON or DEFINED BY

Container Railroad car Pipeline


IMMEDIATE ACTIONS TAKEN

Ship Tank Tanker

Truck Other _______ ____________ Diversion of release to treatment Decontamination of persons or equipment Monitoring Other _____________

Agricultural: manure, pesticide, fertilizer Chemicals Flammable or combustible liquid Hazardous waste Liquid industrial waste Oil/petroleum products or waste Salt Sewage Other________________________ Unknown
RELEASE REACHED

CAA Section 112(r) list (40 CFR Part 68) CERCLA Table 302.4 (40 CFR Part 302) EPCRA Extremely Hazardous Substance (40 CFR Part 355) Michigan Critical Materials Register or permit NREPA Part 31, Part 5 Rules polluting material NREPA Part 111 or RCRA hazardous waste NREPA Part 121 liquid industrial waste Other list ____________________________ Unknown

Containment Dilution Evacuation Hazard removal Neutralization System shut down

Distance from spill location to Surface waters (include name of river, lake, drain involved) ___________________________________________ surface water, in feet___________ Drain connected to sanitary sewer (include name of wastewater treatment plant and/or street drain, if known) ________________________________ Drain connected to storm sewer (include name of drain or water body it discharges into, if known) _________________________________________ Groundwater (indicate if it is a known or suspected drinking water source and include name of aquifer, if known) _____________________________ __________________________________________________________________________________________________________________________ Soils (include type e.g. clay, sand, loam, etc.) __________________________________________________________________________________ Ambient Air Spill contained on impervious surface

THIS IS A MASTER COPY. PLEASE MAKE COPIES AS NEEDED.

Page 1 of 2 EQP 3465 (Rev. 02/05)

EXTENT OF INJURIES, IF ANY

WAS ANYONE HOSPITALIZED?

Yes No

NUMBER HOSPITALIZED:____

TOTAL NUMBER OF INJURIES TREATED ON-SITE:

__________________

DESCRIBE THE INCIDENT, THE TYPE OF EQUIPMENT INVOLVED IN THE RELEASE, HOW THE VOLUME OF LOSS WAS DETERMINED, ALONG WITH ANY RESULTING ENVIRONMENTAL DAMAGE CAUSED BY THE RELEASE. IDENTIFY WHO IMMEDIATELY RESPONDED TO THE INCIDENT (own employees or contractor include cleanup company name, contact person, and telephone number). ALSO IDENTIFY WHO DID FURTHER CLEANUP ACTIVITIES, IF PERFORMED OR KNOWN WHEN REPORT SUBMITTED CHECK HERE IF DESCRIPTION OR ADDITIONAL COMMENTS ARE INCLUDED ON ATTACHED PAGE

ESTIMATED QUANTITY OF ANY RECOVERED MATERIALS AND A DESCRIPTION OF HOW THOSE MATERIALS WERE MANAGED (include disposal method if applicable) CHECK HERE IF DESCRIPTION OR ADDITIONAL COMMENTS ARE INCLUDED ON ATTACHED PAGE

ASSESSMENT OF ACTUAL OR POTENTIAL HAZARDS TO HUMAN HEALTH (include known acute or immediate and chronic or delayed effects, and where appropriate, advice regarding medical attention necessary for exposed individuals.) CHECK HERE IF DESCRIPTION OR ADDITIONAL COMMENTS ARE INCLUDED ON ATTACHED PAGE

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY NOTIFIED:

OTHER ENTITIES NOTIFIED:

INITIAL CONTACT BY:

Telephone

Fax

Email

Other National Response Center (NRC): 800-424-8802 US Coast Guard Office:


Detroit Grand Haven Sault Ste. Marie

Date: ________
_________

Time: _____
______

DATE/TIME INITIAL CONTACT:_____________________________ PEAS: 800-292-4706 Baraga Bay City Cadillac Crystal Falls Detroit Gaylord Grand Rapids Log Number Assigned _______________ Divisions or Offices Contacted: Air Quality Land & Water Management Office Geological Survey Remediation and Redevelopment Waste and Hazardous Materials Water Bureau

DEQ District or Field Office Gwinn Jackson Kalamazoo Lansing Newberry Warren Wyoming

US Department of Transportation US Environmental Protection Agency 911 (or primary public safety answering point) Local Fire Department Local Police and/or State Police Local Emergency Planning Committee State Emergency Response Commission via MI SARA Title III Program Wastewater Treatment Plant Authority Hazmat Team Local Health Department

________ ________ ________ ________ ________ ________ ________ ________ ________ ________ ________

_____ _____ _____ _____ _____ _____ _____ _____ _____ _____ _____ _____

DEQ Office locations are subject to change

NAME AND TITLE OF PERSON MAKING INITIAL REPORT: _______________________________________________________

Department of Labor & Economic Growth MIOSHA Michigan Department of Agriculture: 800-405-0101

Department of Labor & Economic Growth Fire Safety ________

Other _______________________________________________________ DEQ STAFF CONTACTED & PHONE NUMBER: PERSON CONTACTED & PHONE NUMBER:

DATE WRITTEN REPORT SUBMITTED

SIGNATURE OF PERSON SUBMITTING WRITTEN REPORT

THIS IS A MASTER COPY. PLEASE MAKE COPIES AS NEEDED.

Page 2 of 2 EQP 3465 (Rev. 02/05)

APPENDIX D PRODUCT DELIVERY PROCEDURES

83/19/2009

13:58

9893882045

PAGE

02/03

GAS-FUEL OIL, LIGBT ENDS LOADING & UNLOADING CLEAN NQ SMQKD~Q 1. 2. 3. Stop before entering racic & chcclc for hot spots & fires (electrical, and brakes), close valves. All electrical equipment must be off before entering rack: engine must be off while loading. Proceed to rack and hook up, if you can not get a ground, check to see if you have a compartment full, if trailer is empty, and then check electrical hookup. If you lose ground while loading, check to see if you have touched a sensor. Check your loading & cornpartment sizes before starting to load Make sure you have the right customer card and proceed to load. After loading unhook everything and get paperworic.

4. 5. 6. 7.

NO SMQKJN~ S. At customers, inform them of product & gallons, also make sure you know color code. If not absolutely sure, talk to someone responsible and get product into right taok. At station with underground tanks, driver m ust m ake sure hoses and tight fills are protected from traffic and other hazards. At station with above ground tanks where you pump and you have a quick cou.pJ.ers on discharge hose, malce sure the Cam Locks are wired shut. Never let product dri.p from valves or fittings onto ground, stop immediately and repair leaks. Safety hats and goggles will he worn when loading & unloading when required When pumping off load after hooking up, start pump first, then open valve to receive tank, then open valve on your trailer.

9. 10.

11. 12. 13.

03/19/2009

13:58

9893862045

PAGE

03/03

14.

Check hoses at every loading to make sure they are safe to use. Never shut off valve you arc pumping against as long as your pumping product. Let truck idle first three mi~iutes of pumping and check for leaks or bad hoses or fittings, if OK bring up to normal operating speed. Diive must stay within 25 feet of loading valves while loading & unloading. Driver must never sleep while unloading. If custonier can not 1.~old all of product ordered, call dispatch as to what to do with product. When unloading is completed all compartments ii~ust be checked visually from on top of unit & then dome covers will be closed. Dispatch must be notified immediately in case of: A) Accident or breakdown B) Spills, regardless of size C) Mis-delivery D) Mixed product In case of an accident a preliminary report is to be filled out at the scene and a complete report is to be filled out and filed with the company within 24 hours. Outside power sources (bulldozer & loaders) are not to push a unit. Use caution when towing. Never drain hoses on ground or driveway, always leave area as clean or cleaner than is was when you got there. If you get product on you, in your eyes or mouth, flush with plenty of water., ~~otj~ dispatch.

15.
16.

17. 1 8. 19.

20.
21.

22.

23. 24.

25.

APPENDIX E CITY OF DETROIT STORM WATER MANAGEMENT PLAN (NOVEMBER 2011)

CITY OF DETROIT

This is the html version of the file http://www.dwsd.org/downloads_n/about_dwsd/npdes/cod_swmpp_2011.pdf. Google automatically generates html versions of documents as we crawl the web.

Page 1

CITY OF DETROIT

STORM WATER MANAGEMENT PROGRAM PLAN

Revised November, 2011

http://webcache.googleusercontent.com/...h49WrrTKYJ:www.dwsd.org/downloads_n/about_dwsd/npdes/cod_swmpp_2011.pdf+&cd=1&hl=en&ct=clnk&gl=us[2/28/2013 9:08:06 AM]

CITY OF DETROIT

Page 3 2

TABLE OF CONTENTS

1.0

INTRODUCTION
1.1 Purpose 1.2 Regulatory Requirements 1.3 Summary of Prior Submittals 1.4 Affected City Departments

2.0

DETROITS EXISTING STORM WATER CONVEYANCE SYSTEM


2.1 Storm Water Conveyed through Combined Sewers

2.2 Municipally Owned Separate Storm Sewers


2.3 Privately Owned Storm Sewers Discharging Directly to the River

3.0 '
4.0

NESTED JURISDICTIONS

WATER QUALITY
4.1 Detroit River 4.2 Rouge River

4.3 Factors which Negatively Impact Water Quality


4.4 Water Quality Stress Update I STORM WATER MANAGEMENT PROGRAM PLAN (SWMPP)

5.0

5.1 BMPs and Stormwater Management Activities Through October, 2011 5.1.1 Total Maximum Daily Load 5.1.2 Public Education Program
5.1.3 Public Involvement and Participation 5.1.4 Illicit Discharge Elimination Program 5.1.5 Post-Construction New Development and Redevelopment Projects 5.1.6 Construction Storm Water Runoff Control 5.1.7 Pollution Prevention/Good Housekeeping for Municipal Operations

5.2 Measurable Goals ' ~


5.3 Implementation Efforts For The Coming Year 5.3.1 Schedule/Frequency/Record Keeping/Responsible Agency 5.3.2 BMP Activities For the November, 2011 October, 2012 Period

6.0

SUMMARY

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TABLES
Table 1 Total Maximum Daily Loads (from 2009 General Permit)

Table 2 Known Outfalls for Detroits Municipal Separate Storm Sewer System Table 3 TMDL Wet Weather Inspection Results for Outfalls > 36 Diameter
Table 4 TMDL Wet Weather Sampling Results for Outfalls > 36 Diameter Table 5 Dry Weather Inspection and Sampling Results . 7 Table 6 Status of BMP Implementation for the March, 2010 October, 2011 Perio

Table 7 Proposed BMPs to be undertaken in the November, 2011 October, 2012 Period FIGURES
Figure 1 Index Map of Known Separate Storm Sewer Outfalls Figure 2 Storm Sewer Outfalls - Belle Isle and Detroit River St Figure 3 Storm Sewer Outfalls - Rouge River Between I-96 and Seven Mile Figure 4 Storm Sewer Outfalls - Rouge Park . _ Figure 5 Storm Sewer Outfalls - Rouge River Near Jefferson Ave.

APPENDICES
A. Certicate of Coverage (11/5/04) and Storm Water Discharge Permit (2/23/03) B. Withdrawal Notice from MDEQ for 2008 General Permit (Nov. 30, 2010) C. Communications with MDEQ D. Previous Submittal Addressing Citys Legal Authority E. Excerpt of City Code Regarding Authority to Prohibit Discharges to the Storm System F. Update of Individual NPDES Storm Water Discharge Permits in Detroit '

G. Investigation of Belle Isle Service Yard

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1.0 INTRODUCTION 1.1 Purpose

This Storm Water Management Program Plan (SWMPP) has been prepared to fulll the
requirements of the NPDES permit issued to the City of Detroit for the stormwater discharged from the Municipal Separate Storm Sewer System (MS4). This document updates and supersedes the previous SWMPP which was prepared in March 2010, and is submitted to comply with the requirements of the NPDES permit dated February 25, 2003 which is currently in effect. A Certicate of Coverage was issued to the City of Detroit by the Michigan Department of Environmental Quality (MDEQ) on November 5, 2004. The Certicate of Coverage and Permit are included as Appendix A. Prior to November, 2010 Detroits stormwater discharges were

regulated under a new General Permit issued by MDEQ in 2008. However, the 2008 General
Permit was subsequently withdrawn by MDEQ, leaving the 2003 Permit as the document which

establishes the regulatory requirements for Detroits stormwater discharges. A copy of the
withdrawal notice from MDEQ for the 2008 General Permit is included as Appendix B. Detroits previous SWMPP dated March, 2010 was developed to meet the requirements of the

new General Stormwater NPDES Permit issued by MDEQ on May 22, 2008. The 2008 Permit
included several new regulatory requirements including the control of stormwater pollutants to conform to Total Maximum Daily Load (TMDL) limits, restrictions on the quantity of stormwater allowed to be discharged from new development projects, sampling and reporting on November 30, 2010 in order to resolve a Contested Case Hearing request led by multiple permittees who objected to the terms and conditions_imposed by the new permit. As a result of the withdrawal, the 2003 Permit is the controlling regulatory document governing discharges from Detroits Municipal Separated Storm Sewer System. '

discharges from large diameter storm sewer pipes, a modied timetable for Annual Reports, and a number of other provisions. MDEQ withdrew the 2008 General Stormwater Permit on

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This updated SWMPP summarizes the activities undertaken since the March 2010 document was

submitted, including some work taken in response to the 2008 Permit requirements which are no longer in effect. The SWMPP addresses all current permit requirements, and sets forth the implementation schedule for activities to be conducted over the next 12 months.

1.2 Regulatory Requirements The Cityof Detroits storm water discharges are currently regulated by the general storm water discharge permit issued on February 23, 2003 to individual municipalities (the jurisdictional general storm water permit, MIS040000). The discharge permit species that permittees are to develop, implement, and enforce a SWMPP to reduce the discharge of pollutants from the

drainage system to the Maximum Extent Practicable (MEP). The MEP requirement must be met
by implementing Best Management Practices (BMPS) to address the six minimum measures including:

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1. Public education Program - Education and outreach on storm water impacts;


2. Public involvement and participation; 3. Illicit discharge elimination program; 4. Post-construction Storm Water Management Program for new development and redevelopment projects; 5. Construction storm water runoff control; 6. Pollution prevention/good housekeeping for municipal operations.

The permit requires that the permittees SWMPP list specic BMPs that will be implemented for
each of the topics above. The SWMPP must include measurable goals for each listed BMP and the perrnittee must demonstrate that the goals are met. The permittee must also demonstrate the effectiveness of the public education program and illicit discharge elimination program. In addition, the BMPs proposed by Detroit in the March, 2010 SWMPP also addressed the need to reduce pollutants in storm water discharges from the MS4 consistent with TMDLs approved by the United States Environmental Protection Agency. The applicable TMDLs and pollutants for Detroits storrnwater discharges are summarized in Table 1.

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TABLE 1 APPLICABLE TOTAL MAXIMUM DAILY LOADS


NAME OF TMDL POLLUTANT OF CONCERN Rouge River Sedimentation/Siltation (Biota) Rouge River E. coli Detroit River E. coli

1.3 Summary of Prior Submittals The City of Detroit led an application dated July 17,2008 requesting coverage under MDEQs General Storrnwater Jurisdictional Permit, and the submittal included a list of 48 municipal separated storm sewer discharges. The drainage area for each outfall was reviewed by eld investigation which determined that a number of the small outfalls were actually roadway underdrains or bridge foundation drains rather than storm sewers (see August 13, 2009 letter in Appendix C), leaving a total of 32 municipal storm sewer outfalls. Subsequently, one new storm sewer with an outlet to the Rouge River have been constructed by the Department of Public Works at Ridge Road south of McNichols to handle roadway drainage. This results in a total of 33 municipally owned storm sewer outfalls which are covered by the NPDES permit. The inventory of municipal storm sewers is discussed in more detail in Section 2.2 of this report.

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The City submitted an alternate approach for managing post-construction storm water runoff in a
letter dated May 4, 2009 (see Appendix C) in response to new requirements imposed by the 2008

revised General Permit. Those requirements have since been eliminated due to MDEQs
withdrawal of the 2008 Permit. Shortly after the issuance of Detroits rst storm water discharge permit, the City also submitted supplemental information to MDEQ regarding the Citys legal authority to perform tasks which may need to be undertaken as part of the storm water management effort. This information was transmitted to MDEQ in a letter dated April 27, 2005 (see Appendix D). As part of the April 2007 SWMPP, the City included documentation that the City has the legal authority to prohibit discharges into the storm drainage system. Copies of the applicable regulations are included in Appendix E. 1.4 Affected City Departments Discharges from municipally-owned storm sewers within the City of Detroit are not the
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CITY OF DETROIT

responsibility of a single municipal department or agency. Rather, several City departments have been actively involved in the development of the Storm Water Management Program, with the Detroit Water and Sewerage Department serving as the lead agency with the responsibility of coordinating the efforts to be undertaken to comply with the NPDES permit and the Certicate of Coverage. _ Other participating City agencies include the Recreation Department, the Planning

and Development Department, the Department of Public Works, the Building, Safety Engineering and Environment Department, the General Services Department, the Department of
Environmental Affairs, the Detroit Economic Growth Corporation, the Greater Detroit Resource Recovery Authority and the Law Department.

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2.0 DETROITS EXISTING STORM WATER CONVEYANCE SYSTEM


2.1 Storm Water Conveyed throughCombined Sewers

Most of the storm water runoff from the City of Detroit is conveyed through the Citys combined sewer system which uses a single pipe to convey sanitary waste from residences, industries and
businesses, along with storm water drainage. The combined sewer system services the entire population of the City of Detroit, with a service area estimated at 97,240 acres. Of that, nearly _ 60,000 acres are tributary to the Main Branch of the Rouge River, which is approximately 15% of the rivers overall watershed. The combined sewers convey all dry weather ow, and a large accordance with NPDES permit MI0022802.

portion of the wet weather ow to the wastewater treatment plant at 9300 W. Jefferson in

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The wastewater treatment plant provides primary and secondary treatment with phosphorus removal, disinfection and dechlorination prior to discharge to the Detroit River. The NPDES permit for the wastewater treatment plant establishes efuent limits for several pollutant parameters, along with sampling and reporting requirements for the discharge. During dry weather periods, the plant processes approximately 600 million gallons per day, but has the capacity to accept-wet weather ows up to 1,700 million gallons per day through the primary treatment process. In accordance with the permit, full secondary treatment is currently given to

all flows up to 930 million gallons per day, with the excess wet weather flows above that
threshold receiving primary treatment and disinfection. The secondary treatment capacity will I increase to 980 million gallons per day after completing an upgrade to the clariers in 2015. The NPDES permit authorizes the discharge of combined sewage during wet weather events when the transport and treatment capacity of the collection system and the wastewater plant is exceeded. Combined sewage is discharged at 78 permitted locations along the Detroit and Rouge Rivers. The City is implementing a Long Term CSO Control Program to ensure that combined sewage discharges receive adequate treatment, consistent with state and federal

environmental regulatory requirements. Within the combined sewer system service area, there are several small tracts where separate storm sewers have been constructed and are utilized to convey storm water. However, these
storm sewers reconnect to the combined sewer system at a downstream point, and do not discharge directly to receiving waters. As such, they are an integral part of the Citys combined

sewer system, and the resulting discharges of combined sewage through the permitted CSO outfalls are authorized by NPDES Permit Ml0022802.
2.2 Municipally Owned Separate Storm Sewers Detroits MS4 has a very limited service area consisting primarily of parkland with river frontage, and a small amount of roadway drainage from City streets adjacent to the Rouge River or from bridges over river crossings. A comprehensive investigation of the Citys MS4 system has identied 33 municipally-owned storm sewers including 15 outfalls to the Detroit River and

its tributaries, and 18 outfalls to the Rouge River. These storm sewer discharges are shown in Table 2. The inventory of municipal storm sewers has been updated to reect the recent

Page 10

construction of a new outfall on Ridge Road south of McNichols where roadway drainage is being conveyed to the Rouge River. The location of all of the storm sewer outfalls is displayed on Figures 1 - 5. As shown on Figures 1 5, these storm sewers serve an area which includes portions of Belle Isle, portions of Rouge Park and the City streets which traverse that area, portions of two other small parks, plus a few roadways adjacent to the Rouge River. In addition, there are three known storm sewer outfalls on property now owned by DWSD which was acquired from Detroit Marine Terminal. These three outfalls drain vacant land adjacent to the wastewater treatment plant facilities, and the property is not being used for wastewater treatment

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CITY OF DETROIT

processes at this time. 2.3 Privately Owned Storm Sewers Discharging Directly to the River There are several private property owners along the Detroit and Rouge Rivers who convey storm water directly to a receiving water through a privately owned storm drainage system. The' sanitary and process wastewater from these sites is typically connected toDWSDs combined sewer system. In some instances the facility may be inactive or out of business, or the property may be vacant, in which case there is no discharge of sanitary or process wastewater. The City of Detroit has no legal authority over the discharge of storm water from privately owned storm

sewers, and has not inventoried or located these outfalls. Several private entities with storm
sewers discharging directly to the river have applied for and received NPDES discharge permits for their storm water. These entities are listed in Appendix F. A

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fun .3501 mm.mEO


0025 Born

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utmmmmsom

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CITY OF DETROIT

3.0 ' NESTED JURISDICTIONS


The City of Detroit has identied three nested jurisdictional areas where storm water discharge permits have been issued to other governmental entities within the City of Detroit. These include the Michigan Department of Transportation, Wayne County Roads, and Wayne County Drains.

The City of Detroit has reviewed the storm water discharge permits issued to these three entities, , and has determined that the Citys Storm Water Management Program Since can be implemented independent of the activities being undertaken by the three nested jurisdictions. the drainage areas are distinct and the tributary areas do not overlap or abut one another, there is no
necessity to coordinate the storm water management efforts of these permittees with nested . jurisdictions.

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4.0 WATER QUALITY 4.1 Detroit River

The Detroit River is the connecting channel between Lake St. Clair and Lake Erie, and serves as

the international border between United States and Canada. The average flow through the Detroit River is approximately 190,000 cfs, with velocities typically in excess of two feet per V second. Extensive urban development has taken place along the shoreline, and the river receives numerous wastewater discharges from industrial and municipal treatment facilities. Water quality of the Detroit River during dry weather periods is typically excellent, with
dissolved oxygen levels consistently exceeding the state water quality standard of 7.0 mg/l. Minor uctuations in dissolved oxygen concentrations have been observed at the head end of the Detroit River on an infrequent basis. Typically, these dissolved oxygen changes are very small, and have been attributed to changes in photosynthetic activity of biological organisms in Lake St. Clair during overcast periods. During wet weather periods, the Detroit River receives large volumes of treated and untreated combined sewage overows at many discharge points within the City of Detroit. River monitoring data shows that the dissolved oxygen level of the Detroit (CSO) discharge events. The river is capable of assimilating these intermittent wet weather pollutant loads with relatively minor changes in dissolved oxygen levels. ' By contrast, the intermittent combined sewage discharges frequently generate exceedances of water quality standards for bacteria (E. coli) during and after wet weather periods. Sampling studies along the Detroit River have shown that the CS0 plume tends to follow the shoreline with very little transverse migration of pollutants across the channel because of the high velocity and strong current. There is only one bathing beach on the Detroit River which is situated at Belle Isle, and prior studies confirm that pollutants from Detroits combined sewer overows do not adversely affect the beach. Other conventional pollutants, including nutrients, oil and grease, chloride and ammonia, are

River continues to meet water quality standards during and after the combined sewer overow

found in the Detroit River, but at relatively low concentrations. Advancements in municipal and
industrial wastewater treatment facilities have led to a steady decline in concentrations of these

pollutants over time. ' Detectable levels of toxic organics and heavy metals can be found in the Detroit River, and in
more concentrated amounts in sediment deposits at various locations along the river. Persistent bioaccumulative pollutants such as mercury, PCB and dioxin are a water quality concern due to the potential for uptake of these pollutants by biota and the eventual bioaccumulation in sh and

other aquatic life. Fish consumption advisories have been issued for the Detroit River for some
pollutants. MDEQ has designated the Detroit River as a water body which is not expected to attain water quality standards with technology-based controls for several pollutant parameters. Specically, in January, 2009 a TMDL was issued for pathogens in the Detroit River. In addition, the Detroit

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River has been designated as requiring a TMDL study for PCB, DDT, TCDD (dioxins), and

15

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mercury. MDEQs current schedule calls for that Detroit River TMDL to be prepared in 2015.

No TMDL has been issued for phosphorus and none is planned at this time. It is not anticipated that the attainment of water quality standards pursuant to these TMDLs will be dependent on
implementation of the storm water management BMPs or other storm water pollution prevention

activities which are proposed to be undertaken by the City of Detroit.


4.2 Rouge River

The Rouge River is a major tributary to the Detroit River covering a drainage area of
approximately 467 square miles over portions of Wayne, Oakland and Washtenaw Counties. The watershed is home to more than 1.5 million people, and more than 66% of the area has been developed for residential, commercial, institutional, industrial and transportation uses. The Rouge River is the most urbanized and densely populated watershed in Michigan. There are four main branches to the Rouge River, including the Main Branch, the Upper Branch, the Middle Branch, and the Lower Branch. The Main Branch of the Rouge River is the portion of the watershed which lies predominantly within the City of Detroit, and which receives drainage from much of the Citys west side. Numerous water quality studies have been conducted on the Rouge Riverto assess water quality, including the Rouge River National Wet Weather Demonstration Project. These studies document the presence of extremely poor water quality within the Main Branch of the Rouge River during both dry and wet weather periods, although the wet weather problems are more pronounced. Dissolved oxygen level_s in the river fall below the 5.0 mg/l state water quality standard at times, and concentrations have approached zero on occasions near the conuence with the Detroit River. Improvements in dissolved oxygen concentrations have been recorded in recent years, most likely as a result of sewer separation and CS0 treatment facilities which have been built in Detroit and at several upstream suburban locations. Several upstream communities are also working to identify and eliminate illicit connections to their storm sewers, and to undertake storm water pollution prevention' activities. Bacteria problems have been documented throughout much of the Rouge River, with violations of the state water quality standards being recorded during both dry and wet weather periods at many locations. Bacteria concentrations are in part attributable to the discharge of untreated combined sewage, as well as other sources within the watershed. Other problem parameters which affect water quality in the Rouge River include nutrients, heavy metals and organic pollutants, and high concentrations of suspended solids. The Rouge River is subject to widely varying ow rates between dry and wet weather periods. In some areas, sediment deposits have been identified along the river bottom, and these deposits may be scoured out and washed downstream during some high ow events. Sediment deposits
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can include organic pollutants which exert an oxygen demand on the river during warm weather periods when decomposition occurs. In addition, riverbank erosion is problematic in various sectors of the Rouge River where the wet weather high ows may scour the stream bank. The biological community within the Rouge River tends to reect pollutant tolerant species and limited diversity of organisms. A portion of the Rouge River is a concrete lined channel for

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APPENDIX F TMDL

APPENDIX G FUGITIVE DUST CONTROL PLAN

COMBINED FUGITIVE DUST CONTROL PLAN FOR DETROIT BULK STORAGE FACILITY 115 ROSA PARKS BLVD. DETROIT, MICHIGAN

Prepared for

DETROIT BULK STORAGE, INC. P.O. BOX 18285 RIVER ROUGE, MICHIGAN 48218
AKT PEERLESS PROJECT NO. 8235F-1-18 MAY 14, 2013

TABLE OF CONTENTS 1.0 2.0 3.0 4.0 GENERAL FACILITY INFORMATION .............................................................................. 1 INTRODUCTION AND PURPOSE ................................................................................... 2 RESPONSIBILITY.......................................................................................................... 2 FACILITIES .................................................................................................................. 2 4.1 5.0 6.0 FACILITY OPERATIONS..............................................................................................2

POTENTIAL SOURCES OF FUGITIVE DUST..................................................................... 2 FUGITIVE DUST CONTROLS ......................................................................................... 3 6.1 6.2 6.3 6.4 6.5 PETROLEUM COKE OPERATIONS ............................................................................ 3 STONE AGGREGATE OPERATIONS .......................................................................... 3 ACTIVE STORAGE PILES ........................................................................................... 4 INACTIVE STORAGE PILES........................................................................................ 5 TRAFFIC ROUTES ..................................................................................................... 5

7.0 8.0 9.0

POLLUTION CONTROL EQUIPMENT ............................................................................. 6 ADMINISTRATIVE CONTROLS ...................................................................................... 6 PLAN REVISIONS......................................................................................................... 6

QUALIFICATIONS FIGURES Figure 1 ........................................................................................... Subject Property Location Map Figure 2 ............................................................................................................................... Site Map APPENDICES Appendix A ............................................................................ Record Keeping and Reporting Forms Appendix B .............................................................................................................. Plan Change Log

COMBINED FUGITIVE DUST CONTROL PLAN FOR DETROIT BULK STORAGE FACILITY DETROIT, MICHIGAN AKT PEERLESS PROJECT NO. 8235F-1-18
1.0 GENERAL FACILITY INFORMATION Detroit Bulk Storage, Inc. 115 Rosa Parks Blvd. Detroit, Michigan 48209 Noel Frye Vice President (313) 999-9015 Detroit Bulk Storage, Inc. P.O. Box 18241 River Rouge, Michigan 48218

Name of Facility: Facility Address: Facility Contact: Name: Title: Telephone: Mailing Address:

Emergency Contact: Name: Title Telephone: Primary SIC Code: Receiving Water: John Frye Coordinator (313) 999-0874 4491 Detroit River

2.0

INTRODUCTION AND PURPOSE

This Combined Fugitive Dust Control Plan (FDCP) covers operations at the Detroit Bulk Storage (DBS) facility on the Detroit River in Detroit, Michigan. This plan contains best management practices to minimize visible fugitive dust and is revised as needed to reflect changing conditions at the facility or new technology or control methods. 3.0 RESPONSIBILITY

All employees involved in activities that have the potential to generate fugitive dust are instructed to identify visible emissions and address the fugitive dusts once identified. All employees will use their instruction, experience and judgment in the implementation of this plan to determine whether particular measures, in addition to those which are required on a regular basis, should be applied to reduce the potential for fugitive dust. Each employee has the responsibility and authority to cease any operation that may result in the transport of visible fugitive dust off the property. If guidance is needed, employees are to immediately contact their supervisor for instructions. The supervisor will evaluate operating conditions and any and implement this plan or any other measures necessary to address fugitive dust. 4.0 FACILITIES

The DBS facility is situated on approximately 10 acres in Detroit, Wayne County, Michigan. The location of the property is depicted on Figure 1, Subject Property Location Map. The Detroit River flows southwest and adjoins the property to the south. The property consists of asphalt and concrete paved parking areas and driveways, and a gravel area on the northern portion of the property. A Site Map with truck traffic patterns, Petroleum Coke (Pet Coke) storage, stone aggregate storage and conveyor loading areas are depicted on Figure 2. 4.1 FACILITY OPERATIONS

The DBS facility is utilized as a marine terminal and storage operation for stone aggregates and Petroleum Coke transported via the Detroit River. A 250 square foot mobile trailer functions as the facility office and is located by the main entrance at the northeast corner of the facility. 5.0 POTENTIAL SOURCES OF FUGITIVE DUST

Potential dust-producing products handled at the site include Petroleum Coke (Pet Coke), 31A gravel, 21A aggregate stone, and 2 4 aggregate used for rail ballast. The following operations represent the potential to generate fugitive dust: A) Vessel loading and truck loading/unloading conveying products to lake vessels from the dock or dumping and/or loading trucks at the dock.

B) Storage pile maintenance/product transfer (active piles) moving products from one location on the dock to another, compacting piles, and/or shaping piles to lessen wind profile and/or improve storage characteristics. C) Storage piles (inactive piles) storing piles in an undisturbed state for at least 24 hours. D) Vehicle traffic operating mobile material handling equipment, haul trucks and other vehicles on the dock. E) Transfer of products - from front end loader to feed hopper, from feed hopper to transfer conveyor belt, and transfer from conveyor belt to ships hold. 6.0 6.1 FUGITIVE DUST CONTROLS PETROLEUM COKE OPERATIONS A) Handling of Pet Coke will include using front end loaders to remove material from the bulk storage pile and to transfer the material into conveyor/stacker feed hopper. Dust suppression using water with surfactant will be employed during the transfer process including initial loading of the hopper as needed. The dust suppression equipment will consist of truck mounted water cannons and misting/water bars. B) The transfer route between the Pet Coke storage piles and the hopper will also be wetted with the watering trucks as needed. Spilled material will be cleaned up throughout the loading process. C) The area around the hopper and below the conveyor will be maintained throughout the process including removal of all Pet Coke debris from around the hopper and conveyor. A rigid barrier wall or Geofabric tarp will be installed below the conveyor between the ship and the pier to eliminate the material from entering the Detroit River during conveyance to the ship. D) The conveyor/stacker and hopper will be equipped with a misting bar. E) Minimum drop heights at the terminus of the stacker will be maintained as material is conveyed to the ship holds. F) Pet Coke handling/loading process will be curtailed if winds exceed 30 mph sustained and/or 45 mph gusts. G) Truck traffic route will be swept daily or as needed. H) Daily recordkeeping will include weather conditions (wind direction/speed), volume of material loaded, volume of water/surfactant applied, equipment maintenance, unusual incidents/problems. I) A Dock Supervisor will be onsite during the ship loading process to observe if any dust is generated during the process. 6.2 STONE AGGREGATE OPERATIONS A) Handling of stone aggregates will include using front end loaders to remove material from the bulk storage pile and transferring the materials into trucks.

B) Dust suppression equipment such as truck mounted water cannons and misting/water bars may be utilized to prevent fugitive dust emissions. C) Daily recordkeeping will include weather conditions (wind direction/speed). 6.3 ACTIVE STORAGE PILES A) Controls such as water application and/or pavement sweeping may be applied as necessary if fugitive dusts are observed from storage of these materials. Water will be applied to storage piles of materials during transferring, compacting, pile shaping, truck loading/unloading, and vessel loading at the discretion of site personnel. Material transfers, pile compaction and storage pile shaping are completed prior to receiving bulk materials to unload in the shortest time possible, reducing the time duration of material drops and allowing quicker wetting and sealing of piles. To the extent that material transfers, pile compaction and/or pile shaping are required after receipt of materials, these activities are initiated as soon as it is safe to do so in the course of normal operating hours. Pile profiles will be maintained as low as practical to minimize wind shear. B) Active Pet Coke storage pile faces may be sloped at the end of any workday when it is known that an operator will not be working at the dock the next day(s) to minimize sloughing which reduces the effectiveness of wetting. C) During dry conditions, water is applied to the working areas of the active storage pile as needed. Wetting the active, working portions of storage pile reduces overwatering and reduces visible dust from pile maintenance, bulk material transfers to and from trucks and transfers to docked vessels. Water is not typically applied: a) on days when 0.3 inches of precipitation or more falls on the site; and b) when conditions in active bulk material storage piles indicate adequate moisture is present. Under extreme weather conditions, surfactant /encrusting agents may be used during storage pile maintenance, material transfers and truck or railcar loading operations as needed. Unless presented with extreme weather conditions, water is only applied during non-freezing conditions. D) Stacker operations and storage pile maintenance of Pet Coke will be curtailed when sustained wind speeds exceed 30 miles per hour (mph) or gusts exceed 45 mph unless such operations are deemed essential by facility management. E) During the warm, dry weather conditions, personnel will monitor wind speeds and the weather forecast, and frequently observe the facility for visible dust generation. As conditions warrant, personnel may arrange to increase the amount of water or frequency of application from the water cannons or arrange for spot application of water by other means. F) Spilled Pet Coke material within 100 meters (328 feet) of the pile will be removed. G) During freezing weather months, typically November through March, storage pile heights will be maintained as low as possible to reduce wind profiles. Activities that reduce storage pile heights will only be conducted during periods when sustained winds are less than 25 mph. Operators may also apply surfactant to minimize the potential for air-borne visible dust to leave the property. Operators monitor the following conditions when storage piles are active to determine if surfactant should be applied:
4

Temperatures of 28 F and not rising1, Presence of fine particulate in the active working face of the pile, and Low antecedent or pre-existing product moisture (i.e. less than 6 - 8%) as evidenced by above normal visible airborne dust. 6.4 INACTIVE STORAGE PILES A) Controls such as water application or pavement sweeping may be applied as necessary if fugitive dusts are observed from storage of these materials. Storage piles and weather are visually monitored each working day and water is applied as needed to control visible dust or to prepare for forecasted high winds. B) Newly received materials being transferred to a final storage location are considered "active" and are managed as outlined in 6.3 above. C) During non-freezing weather, the potential for Pet Coke fugitive dust is controlled using water application (see Sections 6.B). In seasons of freezing weather (typically November through March), the heights of uncovered piles are maintained as low as possible to reduce the wind profile of the piles. Activities associated with reducing Pet Coke pile height to limit wind exposure are only performed during periods of low wind and may be followed by application of water or pile sealing with surfactant as needed. D) Under extreme weather conditions1, heavy equipment operation on storage piles is limited to only those operations deemed essential by facility management. E) To address the potential for wind erosion, inactive Pet Coke storage piles may be tarped or have a surfactant/encrusting agent applied each fall to seal the non-active portions of the pile. Active portions of the piles are addressed in Section 6.B. 6.5 TRAFFIC ROUTES A) Vehicle speeds will be limited to 15 mile per hour on the property. B) During dry conditions, water may be misted onto paved vehicle travel routes within the 100 meter spilled Pet Coke material zone to address the potential for dust generated from traffic as warranted. Additional water is applied if the normal application frequency is insufficient to control visible dust. Water is not applied during freezing conditions. C) Trucks hauling bulk materials into or out of the dock area will be covered with tarps to address the potential for material being blown or spilled from the trucks.

(1) Extreme weather conditions may include, but are not limited to, freezing temperatures with low pre-existing product moisture; prolonged dry, windy conditions; sustained winds exceeding 30 mph; or wind gusts exceeding 45 mph.

7.0

POLLUTION CONTROL EQUIPMENT A. Monitoring Instrumentation 1. The wind speed and direction, precipitation and relative humidity will be monitored and recorded. Instrumentation will be maintained and operated on site on a continuous basis. 2. Instrumentation shall be operated according to manufacturers instructions. 3. Monitoring device downtime will be documented or logged.

8.0

ADMINISTRATIVE CONTROLS A) Training - All employees involved in activities that have the potential to generate fugitive dust will be trained: 1. To identify conditions that could result in visible dust leaving the facility, and 2. In methods to address this potential before visible dust leaves the facility. This Fugitive Dust Control Plan is part of the training material. B) C) Recordkeeping - The facility will maintain daily records of the implementation of this Fugitive Dust Control Plan on forms such as the examples in Appendix A or any other method that retains the following compliance information: Dust control systems maintenance and inspections Number of loads applied by water truck. Employee training on fugitive dust controls. Weather conditions (i.e., wind conditions, moisture, freezing conditions, snow cover). Dust control equipment inspections. Monitoring instrumentation inspections and maintenance. Pet Coke product inventory. Wind speed and direction. Records will be maintained for a minimum of five (5) years.

9.0

PLAN REVISIONS

Fugitive Dust Plan revisions will be documented in a Plan Change Log for inclusion by addendum. An example Plan Change Log is included in Appendix B.

FIGURES

APPENDIX A RECORDKEEPING AND REPORTING FORMS DAILY CHECKLIST

EXAMPLE Maintenance and Inspection of Dust Control Equipment Control Equipment Water System (pump and cannons) Water Truck Routine Maintenance Frequency Inspection Interval Monthly Daily Monthly Items Inspected 1. 2. 3. 1. 2. 3. 1. 2. 3. 1. Piping Valves Fittings Engine oil Engine Coolant Portable Pump Tires Piping Valves Spare Parts

Engine oil changed at 150 hours

EXAMPLE Daily Checklist


Date: ______________________ Weather (circle all that apply): Operator Unloading Trucks: _______________________

Rain or Snow Snow cover

High Winds Sunny

Freezing Cloudy

Wind Speed Forecast: ______ mph or knots Yes No NA

GENERAL FACILITY
Extreme weather conditions present, such as: freezing temperatures with low product moisture; prolonged dry, windy conditions; sustained winds exceeding 30 mph; wind gusts exceed 45 mph that require surfactant or encrusting agents and/or snow-producing equipment to be used during or after pile creation or maintenance, material transfer or truck or railcar loading?

Initials

Operations stopped or limited to reduce emissions: Truck unloading; Transfer from storage pile to feed hopper Transfer from hopper to conveyor Vessel loading Equipment operated on piles (does not include load-out from working face of piles) Dust is visible at a distance of 4 feet or more from or above storage piles, transfers (including loading and unloading), and/or roads? If yes, indicate corrective measures: ______________________________________________________________________________________ Water applied to inactive storage piles by (circle all that apply): portable water cannon on cannons water truck Surfactant applied to inactive storage piles? Controls applied to working area of active storage piles (piles created or added to during loading or unloading and piles maintained)? Circle control(s) used: Pile center used to reduce dust If not, circle reason(s): Raining wet product Bucket kept close to load no dust Loaded out of wind freezing Water Applied other

Active storage pile faces sloped at the end of the day when an operator will not be working at the dock the next day(s)? Storage pile heights maintained as low as possible to reduce wind profiles? Any emissions from facility that may cause injurious effects to human health or safety, animal life, plant life of significant economic value, or property, or may cause unreasonable interference with the comfortable enjoyment of life and property? Drop distance from vessel hold to conveyor minimized to within 5-7 feet of the boom or as conditions warrant, thereafter (NA if no vessel loading)? Storage pile compaction and/or shaping completed before receiving additional bulk materials by truck? VESSEL LOADING Vessel-loading stacker set at lowest height during initial fill and maintained within 5-7 feet of hold entry or as conditions warrant thereafter (NA if no vessel loading)?

APPENDIX B PLAN CHANGE LOG

EXAMPLE FUGITIVE DUST PLAN CHANGE LOG Rev & Date Rev 1, 05/10/2013 Rev 2, 07/08/2013 Description of Change Revised format (describe revision) Section 6.C Inactive Piles revised to include (insert revision language)