Renewal Application
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APPLICATION SUMMARY Great Lakes Chemical Corporation-West Plant (GLCC West) is engaged in the manufacturing and production of Bromine. The facility is located in Marysville, Arkansas. The facility is currently permitted through the Arkansas Department of Environmental Quality (ADEQ), National Pollutant Discharge Elimination System (NPDES) Permit No. AR0043516. Sources that contribute to discharges at Outfall 001, listed in the above referenced permit modification, now consists of stormwater only. Each of the once referenced sources: i.e. steam condensate, sanitary wastewater and associated system piping, cooling tower and boiler blowdown, and fire water pond overflow, no longer exists on site and have been removed from Permit – AR0043516, modified as of September 13, 2016. The only media discharged from the Outfall 001 is stormwater. Included with this application package, documents necessary to complete the permit renewal process are: • Application Summary • Form 1 • FEMA Maps • Water Supply Sources • Form 2C • Area Maps • Flow Diagrams • PPS Form • Form 2F • Site Drainage Map • DMR Summary Tables • Laboratory Reports • CD – Chemtura 10-K and 10-Q (Filed 2014) MEASURES AND CONTROLS NPDES Permit AR004351B Part 111.4.d.lli: Measures and Controls. Each facility covered by this permit shaft develop a description of storm water management controls appropriate for the facility. and implement such controls. The appropriateness and priorities of controls in a plan shall reflect identified potential sources of pollutants at the facility ... GLCC-West is required to develop descriptions of appropriate Best Management Practices (BMPs) at a minimum for: 1) housekeeping, 2) preventative maintenance, 3) spill prevention and response procedures, 4) Inspections, 5) employee training, 6) non-storm water discharges 7) record keeping and reporting, 8) sedimentation and erosion control, and 9) management of runoff. These baseline BMPs and any site specific BMPs are addressed in the following subsections of this Plan. 1.0 Housekeeping NPDES Permit AR0043516 Part 111.4.d.iil(1): Good Housekeeping. Good housekeeping requires maintenance of areas which may contribute pollutants to storm water discharges in a clean, orderly manner. The following procedures and practices are used to maintain a clean and orderly site: 1) GLCC-West maintains multiple trash containers to collect waste paper and other industrial waste. 2) With the exception of all tail brine tanks, all process related liquid chemicals are stored in covered tanks, containers, totes, or drums or are located under cover. 3) Valves for secondary concrete containment of bulk petroleum tanks are kept closed during normal operations. Small quantity petroleum products (specialty oils and solvents) are located within a single concrete curbed area that provides secondary containment (PS 4). The containment area is drained with a sump pump and is controlled by a float switch and discharges directly to tail brine tanks. 5) All contractor paints (fresh and waste) and solvents are kept in a covered shed or inside a curbed concrete area. Covers or lids for paint and solvent containers are utilized if stored outdoors. 6) A trailer of sodium thiosulfate (hypo solution) is stored in the plant for operating personnel to neutralize potential spills. Hoses also supply ammonia to these areas for spill neutralization. 7) Absorbent material is stored at the warehouse . 8) GLCC·West uses drip pans to collect spills of oils and lubricants during routine dispensing operations. All oils collected in drip pans should be disposed of in the used oil tank at the drum storage area. 9) All used oil is collected and stored in the used oil tank at the petroleum storage area. Used oil is collected by a contract service as needed. 10) All process and storage tanks are clearly labeled as to their contents. 11) Extra material and equipment and scrap material is located in one centralized area southeast of the production area. 12) Chlorine unloading and bromine loading areas are located under cover. 13) Gravel, concrete, and grassy areas located in the production area are kept clear of litter & debris. 14) Debris to be disposed of is placed inside dumpsters. Debris is not stacked outside of the dumpsters. Offsite refuse disposal is performed by a contract service weekly, as needed. 2.0 Preventative Maintenance NPDES Permit AR0043516 Part 111.4.d.iii(2): Preventative Maintenance. A preventive maintenance program shall involve inspection and maintenance of storm water management devices (cleaning oil/water separators, catch basins, etc.) 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, and ensuring appropriate maintenance of such equipment and systems. GLCC·West preventative maintenance procedures are contained in a Mechanical Integrity Program Manual. A copy of this manual is located in the maintenance supervisor's office and is made part of this Plan by reference. The Mechanical Integrity Program Manual is an element of the Process Hazard Analysis (PHA). The PHA will be the master document for GLCC-West Process Safety Management (PSM), which Is mandated by OSHA requirements in 29 CFR 1910. The Mechanical Integrity Program Manual includes the following items (as they relate to potential storm water pollution): • Inspection and test procedures of equipment and instrumentation (Section 2, West Plant Inspection and Test Procedures; Section 3, West Plant Inspection and Test Frequency); and . • Maintenance procedures (Section 4, West Plant Maintenance Procedures and Check Sheets). Items covered by this program manual as they relate to storm water pollution include pressure vessels, storage tanks, process piping, relief and vent systems, emergency shutdown systems and alarms, and interlocks and pumps. In addition to the manual, the Mechanical Integrity Program includes the West Plant Inspection and Test Frequency Plan, a computerized scheduling and tracking program that is updated periodically. On file are equipment identification numbers, frequencies of next activity, last completion date for inspections and testing, and appropriate procedures to accommodate tasks to be performed. Actual field work performed is documented with Preventative Maintenance Order Check Sheets. 3.0 Spill Prevention and Response Procedures NPDES Permit AR0043516 Part 111.4.d.III(3): Spill Prevention and Response Procedures. Areas where potential spills which can contribute pollutants to storm water discharges can occur and their accompanying drainage points shall be identified clearly in the storm water pollution prevention plan. Where appropriate, specifying material handling procedures, storage requirements and use of equipment such as diversion valves in the plan should be considered .... Outfalls 001 and 006 have the most reasonable potential to experience the release of a spill. For Outfall 001, this is due to the chemicals and petroleum products that are loaded, unloaded, stored in bulk, and transported in this drainage basin. Outfall 006 has potential for· the same reasons as Outfall 001. but the potential is less. All in-line process tanks and feed tanks are monitored electronically, 24 hours a day. Within the confines of drainage basin 001, any spill or leak would either be contained within the confines of secondary containment, or would drain to either the west or south ditch. A full line of replacement pumps, motors and parts are available at the maintenance building and laydown area. Within the confines of drainage basin 006, a spill or leak beyond any secondary containment could not be diverted or contained. NPDES Permit AR0043516 Part 111.4.d.iii(3): Spill Prevention and Response Procedures . ... Procedures for cleaning up spills shall be identified in the plan and made available to the appropriate personnel. The necessary equipment to implement a clean up should be available to personnel . GLCC-West is covered by the South and Central Plant emergency brigades. Emergency brigade personnel are provided with industrial firefighting and emergency response training in addition to other job related training. In the event of a chemical spill or release of material that has the potential to affect the quality of storm water runoff, the individual who first notices the spill or release should notify unit personnel by radio, telephone, or messenger. The supervisor of the affected unit/area responds to the scene and assesses the situation. The supervisor notifies the site emergency coordinator and instructs the plant manager to contact the appropriate emergency response groups, company personnel, regulatory agencies, etc. During "off shift" hours, the Tower Technician performs these duties. The supervisor also notifies the site emergency coordinator. Details of further notification and response follows Section 5 of GLCC-West's Emergency Response Plan. Copies of the plan are located throughout the plant. The GLCC-West Emergency Response Plan should be followed for spills that cannot be effectively controlled by personnel in the immediate area. Refer to Section 4.4 Spills and Leaks for spill event documentation requirements and implementation . 4.0 Inspections NPDES Permit AR0043516 Part 111.4.d.lll(4): Inspections. In addition to or as part of the comprehensive site evaluation required under Part III.C.4.d (comprehensive site compliance evaluation) of this permit, qualified facility personnel shall be identified to inspect