STORMWATER 40 CFR 122.26 Eric Lassalle Smithfield Foods, Inc. Environmental Training Omaha, NE September 2010

1. STORMWATER40 CFR 122.26Eric Lassalle Smithfield Foods, Inc.Environmental TrainingOmaha, NE September 2010

2. What is stormwater? • Rain • Snow • Ice • Potable water, Non contact cooling water & Industrial wastewater? Stormwater is any water falling as a result of a precipitation event.

3. Where does stormwater go? • Stormwater that does not soak into the ground becomes stormwater run-off, flowing directly off impervious surfaces such as sidewalks, streets and parking lots to stormwater sewer systems or directly to rivers, lakes, streams, or oceans

4. Stormwater discharged into stormwater sewer systems or directly to a lake, creek, river or ocean is untreated, causing pollution to bodies of water used for drinking, swimming, boating and fishing

5. Trash Dirt Fertilizers Pesticides Animal Wastes Oil Residential Areas Business and Industry Agriculture Construction Parking Lots and Automotive Facilities Stormwater Pollutants and Sources

6. A facility uses Best Management Practices (BMP’s) to reduce stormwater pollution

7. There are two types of BMP’s: Structural Operational

8. Some examples of Structural BMP’s include: • Containments • Swales

9. Some examples of Operational BMP’s are: • Good Housekeeping • Regular Inspections • Spill Prevention and Response • Preventive Maintenance • Materials Handling • Waste Management Practices • Equipment Fueling/Repair

10. What does all this mean to you? Stormwater discharges associated with industrial activities fall under the National Pollutant Discharge Elimination System (NPDES). Determine if your facility is eligible for coverage under a general or individual NPDES Industrial Stormwater Permit.

11. If your facility requires a Stormwater Discharge Permit, you must have a Stormwater Pollution Prevention Plan (SWPPP, SW3P).

12. Site Assessment Introduction Material Inventory Exposed Significant Material General Location/Site Map Past Significant Spills and Leaks Non-stormwater Discharge Certification Site Assessment Inspection Existing Management Requirements EPCRA 313 Requirements Pollution Source Summary Your SWPPP should consist of:

13. Stormwater Management Plan Description of corrective actions taken based on site inspection Best Management Practices Identification Employee Training

14. Implementation Schedule Implement BMP’s Employee Training BMP Plan Emergency Phone Numbers Spill Prevention Plan / Response Team Members

15. Evaluation and Monitoring Annual Site Compliance Stormwater Monitoring Program Record Keeping and Reporting Retention of Records

16. List of Appendices To include: Permit Training Records List of Spills / Leaks Site Inspection Forms Evaluation Reports Data Reports Compliance Reports Material Inventory Flowcharts Maps

17. Remember… • Update your plan whenever information contained in it changes • Update your plan within 15 days if a spill occurs

18. Need Help? Stormwater compliance rules change or get updated constantly. How do you decide what you need to do to keep inspectors happy? Go to www.EPA.gov for the latest information on topics and dates. Smithfield Foods Environmental Staff

19. Top Compliance Areas • UPDATE & IMPLEMENT SW3P • FOLLOW PERMIT REQUIREMENTS • BEST MANAGEMENT PRACTICES (BMP’s) • DOCUMENTED TRAINING • DOCUMENTED INSPECTIONS • RECORDKEEPING • SITE STORMWATER CONVEYANCE DRAWINGS

20. OOOPS! • Ammonia spill kills fish • by Stephen Woodward • 11 months ago | 1812 views | 3  | 11  |  |  • view slideshow (3 images) • <<>> • MIDDLESBORO — A chemical spill at the Smithfield plant in Middlesboro on Saturday morning has led to the pollution of the downtown canal, killing all of the fish in its wake, according to responders.John Williams, Fisheries Biologist for the Kentucky Department of Fish and Wildlife Resources, said the ammonia leak was a “complete kill” and wiped out all of the fish from the spill site at the plant to the confluence downstream behind Walmart.Williams, who was onsite Monday, said he believed the ammonia stopped at the confluence before going into Yellow Creek.“I didn't see any dead fish below that,” said Williams.He said the majority of fish killed were carp, but he did find large mouth bass, sunfish, and crappie. Williams said it could take a year or two before the canal recovers from the chemical spill, unless the fish are restocked.According to Bell County Emergency Management Director Paul Wilson, ammonia was leaked into the air and water during a construction project at the Smithfield plant on Saturday. Wilson said the company was building an extension to the plant, but first had to cut the a line that used ammonia as part of the coolant system. The ammonia in the pipes had not been completely pumped out, so when the pipe was cut into, it spilled: some went airborne and some went into the creek. Allison Fleck, Public Relations Director for the Environmental Protection Agency based in Frankfort, said that, based on reports she had heard, the plant workers were cleaning out ammonia from the lines and some “inadvertently escaped.” Wilson described the leak as a “major release” and said it could be smelled by those nearby. He said it vaporized immediately.Initial reports on why the fish died have been conflicting. Williams said that he believed the fish were killed from a direct contact of ammonia to the fish and said that, based on reports he saw, the oxygen levels were not low enough to be lethal. But EPA Toxicologist Dr. Al Westerman said it was a combination of both ammonia contact and low oxygen levels caused by the ammonia. He said the chemical “instantaneously sucks the water out of the tissues.” Westerman added that breathing ammonia can burn the lungs.Fleck said that no water supplies have been affected and four oxidizing machines were currently running. She said water sampling will continue to insure no chemical residual.Wilson said he had heard of no reports of injuries sustained by plant workers or anyone nearby the spill. He said he and a representative from the State Fire Marshall's office were on scene when it first happened Saturday at around 11 a.m., along with the Middlesboro Police Department and the Middlesboro Fire Department. The EPA and Kentucky Department of Fish and Wildlife Resources were also on scene through the weekend.When contacted, Smithfield management did not have a statement ready by press time.Stephen Woodward is a Staff Writer for the Daily News. He may be contacted at swoodward@middlesborodailynews.com. Read more: The Middlesboro Daily News - Ammonia spill kills fish

21. McWane, Inc. Settlement Information Sheet (Washington, DC - July 14, 2010) The U.S. Environmental Protection Agency (EPA), the Justice Department, and the states of Alabama and Iowa announced that McWane Inc., a national cast iron pipe manufacturer headquartered in Birmingham, Ala., has agreed to pay $4 million to resolve more than 400 violations of federal and state environmental laws. The settlement, filed in federal court today, covers 28 of McWane’s manufacturing facilities in 14 states and also requires the company to perform seven environmental projects valued at $9.1 million.

22. All Facilities: To address systemic non-compliance relating to the CWA stormwater requirements, McWane revised its EMS, rewrote its corporate-wide guidance and implemented updated facility-specific operating procedures relating to stormwater management and control, and has committed to revising each facility-specific Stormwater Pollution Prevention Plan (SWPPP).  As part of its revised corporate-wide SWPPP improvements, McWane has agreed to a sampling and monitoring regime that exceeds federally mandated compliance requirements.

23. QUESTIONS?