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The Celotex Corporation - 2 - 27 March 2001 Inspection Report A review of the facility's Storm Water Pollution Prevention Plan (SWPPP)revealed the following: 1. Celotex uses diisocyanates,polyol, Genetron 141b, and a catalyst in manufacturing the insulation boards; 2. The unloading area has a cut-off valve which is closed during all unloading; and 3. The only non-storm water discharges at the facility consist of landscape irrigation and annual fire hydrant flushing. Due to the potential for the chemicals in Item 1 to be spilled in the unloading area, Celotex should test the first flush storm water for those chemicals using U.S. EPA Methods 8260 and,8270. Celotex should not discharge the first flush until the sample results show that it is only storm water. Since the constituents of those chemicals are not specified, Celotex should confirm the appropriateness of using those test methods with its laboratory and the chemical manufacturers. During a phone call with Mr. Dawson on 26 March, I discussed the need for testing the storm water in the unloading area prior to discharge. The presence of a cut-off valve allows Celotex to implement this best management practice (BMP)without any structural change. The SWPPP should be revised to incorporate this BMP and other BMPs that Celotex might add to its storm water pollution prevention program. Sampling for constituents of concern (COCs)would be conducted only once if the initial results show no discharge of chemicals and as long as the chemicals used in the process remain the same. If the initial results show CDCs or the chemicals used in the process change, then regular sampling for those chemicals would be incorporated in the monitoring program. SUMMARY: To address the issues observed during the inspection, Celotex should submit the following: 1. A report explaining the cause of the discharge(s) of chiller water, how much was discharge (if feasible), fate of the discharge, and steps taken or planned to prevent recurrence of the problem. The report also should describe the status of the chemical containers in the unloading area. In addition, the report should provide the steps taken or planned by Celotex to catch incidental spills of chemicals during unloading from rail tanks. 2. A report of results of soil sample(s) from one of the two stained areas along the railroad tracks as discussed during our inspection. The soil sample(s) should be analyzed using U.S. EPA Methods 8260 and 8270. 3. A revised SWPPP incorporating new BMPs. Approved: