IN THE CRRCUIT COURT OF THE STATE OF CREGON ¢ POR THE COUNTY OP MULTNOMAH Sw 28 3b IN THE STATE OF OREGON SEARCH WARRANT ‘TO ANY POLICE OFFICER OF THE STATE OF OREGO! YOU ARE HEREBY AUTHORIZED TO SEARCH: qui an Bas Belly ad premises of American Linen ~ Steiner Corporation (ALSCO), located at 1441 N, Columbia Boulevard, Portland, Multnomah County, OR 97217 dae Sil is described as follows: 1441 N. Columbia Boulevard, Portland, OR 97217, is located on the north Side of N. Columbia Boulevard, between Interstate 5 to the east and N, Interstate Placs to the west, in Mulftsomsh County, OR. itis bordered tothe east by the address of 1255 N. Columbia Boulevard and tothe Cone yA LN. Columbia Boulevard. The property is accessed via a paved deiveway running north ees Nt Columbia Boulevard under the railroad grade; with a white sign at N. Columbia Boulevard woh al eee Belated onit in green. The building itself is surounded by a chain lik fence with a gate on the southside of the building facing N. Columbia Boulevard. ‘The business office is accessed via publie onttanee va te south Side of the building. ALSCO is a multi-stoied commercial structure, ‘The building is painted white, with green ‘tims and ALSCO is painted om the side of the building in green on the south, north and east sides and che person of: 7 Red (Rodney) Baker, date of birth 03/25/64, described as a white male adult, with brown hair and blue eyes He is approximately 230 pounds and 6 feet 2 inches tall, ‘TO SEARCH, SAMPLE, SEIZE, DOCUMENT AND ANALYZE: Said evidenee to include but not limited to a peroxide barrel, pump and contents, condition of pretreatment imajuments including but not limited to sulfuric acid, lint removal screens and pH meters, pH peter recoe's to inclide stip charts forthe last 3 years, purchase documents regarding reagents, chemicals wnd inetrncone used cetaceans bet not limited to receipts forthe peroxide and pump, engineering logs, receipsleontiacis he cleotrical contractor wotk, Reuse Water Make-Up Repor's and other intemal pretreatment documents, condition Rk valves, devices, instruments or other water controls at ALSCO, notices of pending inspections on andwaitten notes and the company’s dry-erase board, employee records, cental processing units, laptop or nove meok computers, peripheral inpuvloutput devices such as keyboards, printers, searmers, plotter, monitors, and drives intended for removable media, related communications devices such as modems, cables and Swe uons, lectronic storage media such as hard disks, floppy disks, diskettes, compact dises, CID. ROMs DVDs, optical dises, Zip cartridges, thumb drives, printer buffers, smart cards, on elecconie notebooks, or any gizi storage medium, emails between Rod Baker, Rob Grubb, Paul Downard, Mark Inskeep, Daniel pombonsis, Daniel Maritt and Sbaum Shatto forthe past 3 years, contacts, agreements or eras between Rod Baket/ALSCO and Apex Labs, Rod Baker's cellular phone and texts forthe past 3 years and any other evidenceof the crimes of Unlawful Water Pottution in the Second Degree, Supplying False Information to Agency and Falsifying Business Records, . . execution, “ This warrant may be executed more than § lays but not more than 10 days stom the date of issuance. This warrant may be executed any time of the day or night, ISSUED this 220P ay op Sep tens bee 2014, at_ Wo o'clock Pon Cireuit AMY HOLMES HEHNIN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH OD e go THE STATE OF OREGON. ) 1 ot o™ ) SS. AFFIDAVIT FOR SEARCH WARRANT ny County of Multnomah ) sto . i © 1 Jeremy L. Richardson, being first sworn on oath do herby depose ant say BACKGROUND Tama police officer with the Oregon State Police and have been so employed for 16 Years. Tan currently assigned as ¢ Detective in the Special Investigations Unit of the Fish and ‘Wildlife Division; a position Ihave held since March 1, 2011, Lam responsible for the ‘vestigation of environmental crimes for the Oregon Department of Environmental Quality (DEQ). In that capacity, I have received traning in the investigation of Environmental Crimes inclacing but not limited to Unlawsil Air Pollution, Unlawful Water Pollution, Unlawful Disposal, Storage and Treatment of Hazardous Waste and Unlawful Transport of Hazardous Waste, Ihave attended over 70 hours of specialized training in environmental investigations ta 20) Criminal Eny ‘ronmental Investigations courses as well as the McCoys’ Resource Conservation ue Recovery Act Seminar, - As an employee of the Oregon State Police, I served as a Detective with the Oregon State FA Police Arson and Explosives Section for 4 years, and as a Trooper in the Patrol Division for more 25) than 7 years. Thave held certifications in fire origin and cause investigation, post-blast 26] investigation and was a certified accelerant detection canine handler. In that capacity, I 27) conducted detail-oriented, physical evidence-based examinations of crime scenes ranging from‘Svestigations in crimes ranging from Failure to Perform the Duties of a Driver to Arson in the 3) First Degree to Aggravated Murder. Ihave also Conducted investigations into related crimes such as Money Laundering, Theft by Decepticn, Forgery and Aggravated Theft. have been trained by and am a graduate of the Oregon State Police Recruit School and hold my basic, > Intermediate and advanced law enforcement certifications through the Oregon Department of 8} Public Safety Standards and Training. served as an employee of the Oregon State Police 9} Forensic Laboratory from 1996 until 1998, and have Certifications in both crime scene analysis 9} and latent fingemprint identification, Thave a Bachelor of Science degree in Biology from the i University of Oregon. Iam also-a certified Field ‘Training Officer with the Oregon State Police PURPOSE Tam investigating allegations that American Linen — ‘Steiner Corporation (ALSCO) and ‘the company's Chief Engineer, Rod Baker, and former Chief Engineer, Dan Maclit, intentionally 16] altered the company’s waste discharge water by dilution and the addition of hydrogen Peroxide, 17) in violation of ALSCO’s pre-treatment plan and their City of Portland Industrial. Wastewater Discharge Permit, have set forth facts ofthis investigation forthe purpose of securing a search watrant to “earch, sample, seize, document and analyze physical evidence related terminal acts under 22)" investigation that are believed to have been committed by Den Marit, 231 located at the facility and on the premises of American Linen-Steiner Corporation (ALSCO); 74) Iocated at 1441 N. Columbia Boulevard, Portland, Multnomah County, Oregon, andthe person oFRod Baker. Ihave not included exch and every fact known to me conceming this investigation but have set forth the facts that are necessary to establish Probable cause to believe that criminaleis in violation of Oregon Revised Statute(s) (ORSs) have occurred in Multnomah County, Oregon, including ORS 468.943, Unlawful Water Pollution in the Second Degree; ORS 468.953, Supplying False Information to Agency and ORS 165.080, Falsifying Business Records, Talso have set forth the facts to reasonably show that evidence pertinent to the investigation of these 11.5 ~ 12.5 for a total duration of more than 15 minutes in any calendar day. . pH excursions > 12.5 for a total duration of more than 5 minutes in any calendar day. c. pH excursions less than 5.0 regardless of duration during a calendar day. Bach occurrence shall be reported with the date, time, duration and the maximum or minimum pH excursion reached. The monthly report shall contain the total time (in minutes) that the pH was outside the limits set in Schedule A. ‘The permittee is required to continue using a strip-chart-recording pH meter for continuous pH recording of any other pH control system recorder that meets with City approval. A daily record shall be kept for each day of plant operation, excluding those days when there is no process activity. The records shall be maintained and must be available for direct review or photo duplication by City representatives, if required, 77. Treviewed Schedule A of ALSCO’s permit. The allowable daily limits for pH set in Schedule A of the ALSCO permit is a low of 5.0 standard units (su) and a high of 11.Ssu In Schedule A of ALSCO’s permit, BES identifies pH as a “pollutant of concer.” 78, talked with MeDaniel from the BES on September 10, 2014, about the pH requirements outlined in ALSCO’s permit. He toid me that per the permit, ALSCO is required to use a pH meter capable of taking and keeping readings. MeDaniel said disabling the recording device, leting the recording device run out of paper, or not maintaining the pH recordings for periodic review, individually or as a combined action, constitutes a violation of the BES issued permit. He said without having the recorded readings to review, ALSCO cannot accurately certify it has been in compliance with the pH conditions ofits permit. 79. I reviewed Schedule E of ALSCO’s permit, Schedule E is subtitled General Conditions. On page E6, of ALSCO’s permit, there is a Records Retention section that reads as follows: All records of monitoring activities and results, including all original strip chart recordings for continuous monitoring instrumentation (and calibration and Page 24 of 23,maintenance records), shall be retained by the permittee for a minimum of three years. This retention period shall be extended during the course of any unresolved litigation pertaining to the discharge of pollutants by the permittee, or whenever it is requested by the City, the Approval Authority (DEQ), or the Regional Administrator (EPA). 80. McDaniel also told me ALSCO periodically takes grab samples of its effluent and evaluates it for pH as part of its self-monitoring report. McDaniel said Rod Baker is the company official that certifies the self-monitoring report for ALSCO. McDaniel said the periodic grab sample, even if it falls in ALSCO’s allowable permit range of between 5.0 and 11.5 su, does not alleviate ALSCO from maintaining and evaluating the daily pH readings otherwise required by the permit to ensure the basic City thonitoring and requirements are met. 81. On page E2 of ALSCO’s permit, there is a Certification section that reads as follows: Legible copies of all applications, reports, and information submitted to the City shall be signed and certified as follows in accordance with 40 CFR 403.12. certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed {o assure that qualified personnel properly gather and evaluate the information submitted. Based on my inguiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, o the best of my knowledge and belief, true, accurate, and complete. Lam aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. 2 re 82. After receiving Grubb’s last image of the dry erase board which indicated that a waste water test would be conducted on September 10, 2014, I asked Grubb who wrote the note on the board, Grubb said he suspects an engineer's assistant named Tyson Gryffin wrote the note after receiving a text from Rod Baker to do so. Grubb said that Baker is known to text engineers at ALSCO on work-related issues. Grubb told me that he has sent text messages to Baker, and received texts from Baker, in the course of his employment at ALSCO. 83. On September 18, 2014, I asked Grubb what cellular phone number Rod Baker uses to send and receive text messages to/from the engineers. Grubb told me Baker uses his personal cell phone and provided the number as (503) 438-8829. Page 22 of 2384. On September 18, 2014, Downard provided me with a second skeich of the facility, The sketch shows the location of the two bypass valves used by the engineers to engage and disengage “smoke and mirrors” at in the “wash alley” at ALSCO. ‘The sketch also shows the location of the pH meter in the Boiler Room. I have attached this sketch as Exhibit 5. Respectfully submitted, Eric D. Martenson. Resided Agent in Charge Envirdamental Protection Agency — Criminal Investigation Division Subscribed and sworn to before me on J _of Soph bor. 2014 Con Mapbleb a / OREGON NOTARY PUBLIC’ PSP aan OFAC or DAWN KsioTN Gomez NOTARY PUBLIC OReeN OkMSSION no MY COMMSSON ExPMES MAS Soe Exhibit 1_Downard July Sketeh Exhibit 2_ALSCO 2010 Survey Exhibit 3 Fire Marshall Report Exhibit 4 ALSCO Permit Exhibit 5_Downard September Sketch where Page 23 of 23,Cm —— CITY OF PORTLAND----—-—__— ENVIRONMENTAL SERVICES ‘Water Pollution Contra! Laboratory 6543 North Burlington Avenue, Portland, Oregon 97203-5452 Dean Mantott, Director INDUSTRIAL AND COMMERCIAL a, ENVIRONMENTAL SURVEY ig ny, Part IT se nee “eat a “% ‘The federally mandated Pretreatment Program requires the City of Portland (the City) a! (40 CFR 403.8(9(2)), to devetop and implement procedures that: (2) Identify and locate all possible Industrial and Commercial Users which might be subject to the Publicly ‘Owned Treatment Works (POTW) Pretreatment Program requitements, 2). Characterize the type and volume of pollutants contributed to the POTW by the Industrial and Commercial Users as identified under (1) above. By completing the Industrial and Commercial Environmental Stavey, Patt I, you are helping the City complete its requirements, Confidential Information As outlined in 40 CFR 403.14 (a)-(c) and ORS 192.430, any information submitted to the City under the Pretreatment Program requirements may be claimed as confidential by the submitter, Any such claim must be asserted at the time of submission in the manner prescribed on the application form or instructions, or, in the case of other submissions, by stamping the words "confidential business {information on each page containing such information. Ifno claim is made at the time of submission, tho City may make the information available to the public without further notice: Ifa claim is asserted, “~~ the information will be treated in accordance with the procedures in 40 CFR patt 2 (Public Information) and ORS 192.440(2). Information and data provided to the City under these requirements that is effluent data shall bo available to the public without restriction. All other information, which is submitted to the State or POTW, shall be available to the public at least to the extent provided by 40 CFR 2,302 and ORS 192.4402). If, at any time, there is insufficient space to complete an answer, continite your response on a separate piece of paper. Indicate the sectlon and question number next to your response.INDUSTRIAL AND COMMERCIAL ENVIRONMENTAL SURVEY tO SECTION A, GENERAL INFORMATION Confidentiat information - Indicate those sections of this questionnaire that you wish to remain confidential and your basis for requiring confldentiality. (Wastewater characteristics cannot be confidential.) 1 Absea- Rue, : Conny Nas) Tas Na) 1d Ne Cohsmbrs Blod a _ (Pracllny Addass, Steet) - Pellano, Che. $127 spon oseetite wath cL, oa — (Gig Cole) «LO. Boy 17337 ‘Malng Ades SAPO. Bow) PowHano. a ata 47217 (City) (Statz) (Zip Code) 5. Provide the nef te ptcon ocx! nino oii in i qvenonsbe Dane mrad _ PRBLAR223% ‘Wiame} Phone) wk Engine oe S08 -2BE 23: (Tittey! (Fax) Page 1 of 13, Rev. 722808SE ‘ACILITY TYPE INFORMATION ION B.. 1. _Ust all business activities performed on-site. Attach additional sheets as needed. Business Activity SIC Cote 2, Check all applicable mianufacturing ot service activities performed at this facility: Manufacturing or Service Activities _ CPR Manufacturing or Service Activites CFR TT Aliminom Forming 467 T) Meat Products 482 1] Asbestos Manufacturing 407 [} Metal Molding and Casting (rouridties) ~~ 464 1] Battery Manufacturing 461 [| _ Metal Products and Machinery 438 {1 Bulldere' Paper and Board Mis 431 [] | Metal Pintsbing 433 1] Carbon Black Manufacturing 458 [|] Mineral Mining and Processing 436 [J Cement Manufacturing 411} Nonferrous Metals Forming/Metal an Powders 11 Centralized Waste Treatment 487 {} Nonferrous Metals Manufacturing aan [1 Coal Mining 434 [J Olland Gas Extraction 435 LT Coll Coating finetuding Can making 465] Ore Mining and Dressing 440 {1 Copper Forming 468 [ ] Organle Chemicals, Plastics, & Synthetic 414 Fibers 1]. Dairy Products Processing 405.1}, Paint Formulating 446 1] Blectsieal and Electronic Components 469 [|] Paving and Roofing Materials (Tars and 443 Asphalt) {1 Hlectropiating 418 [ ] Pesticide Chemicals (Formulating & 455 Packaging (1 Explosives Manufacturing 457] Petroleum Refining 419 foo Reedtots 412]. Pharmacentical Manufacturing 439 [. Fu - Persoalloy Manfacturing 424 {| _ Phosphate Manufactutting 492 1] Fertilizer Manufacturing 418 [1 Photographle Processing. "8" “SSS sagy [1 ruts and Vegetables Processing 407 {) _ Plastos Molding and Forming 463 (1 Glass Manufacturing 496 [} | Porcelain Enameling 468 (1 Grain mats 406 {] Pulp, Paper and Paperboard 430 (7 Gum and Wood Chemicals 484 [| Rubber Processing 428 [1 Hospitals 460 {| Seafood Processing 408 1) Ink Formotating 447 || Soap and Detergent Manufacturing. 417 [1 Inorganic Chemicals Manufacturing “415 {| |_ Steam Bleetxie Power Generating 423 (1 fron and Steel Manufacturing 420 {] Suifer Processing 408 {1 ‘Landfills and Incinerators [1 Textile Mitts 410 {J Laundry, industrial LJ ‘Timber Products Processing 499 YA Laundry, Unen [.] Transportation Equipment Cleaning (J Leather ‘Tanning and Finishing 428 Page 2 of 13 ‘or, 72373008,SECTION C, FACILITY OPERATIONS AND WATER USK INFORMATION Enter date production began or wall begin at this fatty: 17 Blo, Tua Gieledays per week of operation: Sun @ GOe @ sat ee oO ey Provide the following shift information: Shift Start Time ‘Total No. Employoes Domestic Use = 35 gallons/employee Js the business or proposed activity continuous thronghout the year, Yes pe} Nol} of seasonal? Yest Not 1 Indteate periods of maximum and minimum production: Maximum: Holidays Mintmom: LAnwary /Felrunres List the total days of operation or production for the last calendar year!_ZO6 days Do scheduled shutdowns occur? Yes!'] No —_—if "Yes" fist time pertodte) Prom: _ To From: To: Provide the applicable water “supply information requested below: Account ‘Usage (GPD) List Water Supply Source(s) Number Water Service, (#1): ISSO To, S21 Water Service, (62): Water Service, (#8): Surface Water: Well Water: Other (specity): so Total Daily Use| “74, 526 Page 4 of 18 ev, 198120089. ._ SECTION C, FACILITY OPERATIONS AND WATER USE INFORMATION, ‘Check all that are applicable to your facility and provide the appropriate flow information. Raw Water Discharged ‘Treatment * Sanitary | Storm | Combined yes | No Sewer Process Water Discharged [13.39] x ‘Alr Compressor L060 Air Pollution Control Unit] NIA Backwash Water NA Boiler Feed/Blowdown 1300 x x coving Wat. Caact | Goong Wats Navemnace| Mak [coins Tower/Biesd-oft | fia Equipment Washing 10 Irrigation Nia. ass Plant Cleanup/Washing | Wp ope hpaie ee toni a 7S NOTES: A Describe how this water is handled on-site. For example: flows to an evaporator, & drain fteld, etc. Lormperaser oolire walee 60 deed bn tut walee make wp Koa Wichtler Flows bo stowage tia seinieisice st Describe how this water Is handled off-site. For example: it ts reclaimed, recycled, ete. Page 5 of 18 Rev. Maa008THIS PAGE WAS INTENTIONALLY LEFT BLANK Page 6 of 13, Rov. 729/20810. uw SECTION C, FACILITY OPERATION AND WATER USe INFORMATION Check type(s} of meter) in use al your facility. Also indleate the number in use, Not } Discharge Meter(s): _Z_ Yes Nol } Credit Meter(s): Yes! J Ifa discharge meter is employed, list the manufacturer and describe the method of its operation, if known: Manufacturer: 4 Flow “$000 EERE peices na aa sewer bie nnd melenuny of doweshii melee sippy Eagles SECTION D, FACILITY MATERIAL STORAGE AND PROCESS INFORMATION. Complete the table below for all cheinicals greater than 25 gallons stored and used on-site, Hfyou are required to provide a report to the Portland Fire Bureau or the State Fire Marshall's Office, per the Superfund Amendments and Re-authorization Act of 1986 (SARA ide I) requirements, you may submit a copy of this report in leu of completing this table. Attach additional Chemical Name ‘amount Stored Storage SARA Joheck as appropriate] | Title 11? Inside Outslde Bxample: ‘Trichloroethene | 90 gallons UbFure AUD Waal. | dydalac, Ep/atatecd HOGAL. oil. bbonL. ole onl. Diesel Poet. 900 cat. Page 7 of 13 Ry. 7282008SECTION D. FACILITY MATERIAL STORAGE AND PROCESS INFORMATION 2. Doyou have Moor drains fa manufacturing or storage areas? yespY Nol | List the raw materials utilized or stored on site, Indieate quantity using appropriate units: 8 Stored [Chook as appropriate! | Daily Average inside outside (units) Example: __8/4" steel tubing Y 1,500 pounds a 4, List each product manufactured at this facility, mdicating the appropriate produetion units: Products Units/Time 150 per day Page 8 of 13 Rev, 1252008,L. SECTION E, FACILITY PROCESS WASTEWATER INFORMATION For each product listed in Section D, indicate the general characteristics of the wastewater generated during manufacturing proces Wasteviater Types ‘Reid and Acidic Wastes Alkali and Caustic Wastes Dyes, Coloring Agents Electroplating Wastes Fats, Grease (animal/vegetable) Glues Hot Wastes (> 140" F) Inks, Printing Wastes Metal Cleaning and Preparation Wastes Metal Finishing Wastes Paint, Pigment Wastes (Latex) Paint, Pigment Wastes (Solvent-based) Petroleum-based Oily Wastes Photographie Wastes, Pickling Wastes Radioactive Wastes ‘Soaps, Surfactants, Detergents Soluble Olls, Lubricants Waxes Solid or viscous material: Yes {1 Is the facility's wastewater pretreated? Ifyes, check all that apply: { }Atr Flotation pHleve: SS — MS, unknown 1 | paYes {_ ]Carbon Absorption Wastewater Types, Organic wastes “Alcohols Aldehydes, Ketones Benzene and Benzene Derivatives Ethers Flammable or explosive wastes Halogenated Organic Compounds Organic Acids Pesticides, Herbloides, Rodenticides Phicnol-containing Wastes Resins, Monomers Solvents, Thinners Other Organte Chemicals: {| High Strength Waste: BOD,, COD, TSS L} Toxies: Yes{ | No P< Don't Know] No P< Don’t Know f J [ 1 No Pretreatment System. {| Chemical Precipitation [| Chlorination | }Pvaporation | 1iittration {| Flow Equalization | 1Grease Trap [ 1Grit Removal Jon Exchange Pd Neutralization, pH Control {| O1l/Water Separation J Reverse Osmosis bd Screening/Grinder | 1Sedimentation { t {| Solvent Separation [ ] Biological ‘treatment, type: ___ { JOther Chemical Treatment, type: { } Rainwater Diversion, oF Storag t wl, Jother, spe: Lenk ne Design Capacity of Syster Page 9 of 13 f screens Coinkee Type) sulkue Acid phy app or, 1298008Constituent Name | Mass in Wastestream {this month) SECTION F, FACILITY WASTEWATER DISCHARGE INFORMATION. Cirele the months of the year when proves wastewater discharges do occur or are planned to occur: Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec ‘Are or will the process wastewater discharges be continuous? p<’ or batch? [ } Ibateh discharges occur or will occur, Indicate the following: a, Percent of discharge as batch: b, —Perventaischarge as continuons: fOD% ¢. Number of batch discharges at (W per week thours per discharge) Approximate volume of a batch discharge: gallons. Do you discharge any wastes to the public sewers, which, if disposed by other methods, would be regulated as a Resource Conservation and Recovery Act (RCRA) listed, or characteristic hazardous waste? 1 1¥es BQNo {1 Don't Know If Yes, please describe the wastes discharged to the sanitary sewer: ‘Type of Discharge: { |Continuous {| | Batch [| ] Other Concentration in Wastestream | Mass in Wasiestream (his month) (next 12 months) List each by-product or waste, identify process source of by-product or waste, indicating the appropriate production units, and check whether the material is reused, sent off-site for disposal, or recycled: std ‘By-products/Wastos Process Source | Daily Average Disposal (units) Example: Used cutting oll Cutting & staing 6. Circle the applicable disposal method and provide the required Information. For off-site reuse: For off-site disposal: For off-site recycling: ‘Users Name or Hauter’s Name Phone Wailing Adaress, Sirea7PO Boe oy Siate “ip Code DEQ permit number: Page 10 of 18 Rev, 7292008SECTION G. OTHER WASTES INFORMA1IT0! Cheek all that apply a), Equipment or vehicles used on-site, Indicate the number tn use: Fork ute 4 #_ Cranes} #@__ Trucks pd 6 25 ‘Tractors |} # Other (specify [1] b). Cleaning of equipment or vehicles: On-site | Off-elte | | Cleaned by facitty staff ] Mobile cleaning service (4 ©. Washwater discharged to: Sanitary sewer[ ] Storm sewer[ ] 100% recycled f 1 taken off-site Df! Other (specify) |} Check ail that apply: a), Equipment or vehicles serviced on-site, Indicate the number in use: Fork iifts py ¢_l Cranes ['] #__ | Trucks} Tractors) Other (specif |} b). Mobile services used? Yes >] Not | Services done: Inside| | © Outside | . Describe your disposal of used oil, steam cleaning wastes, anti-freeze, or other wastes: wid ol Db guitn bo aueuyehe ouh Bey babe b farm eg tote 250 gallon tr yer Ak C1 cline « Lisl add on she . yea. pak auap, hee Atheageal Do you have an ongoing groundwater remediation on site? Yes ix} Nol I Remediated groundwater is discharged to the: Sanitary sewer { | Storm sewer <1.” Other (specify) |_| Page 11 of 18 Rev. 7232008SECTION G. OTHER WASTES INFORMA TION 4, Provide the applicable information requested below: Discharge to: Stormwater Sources Area | Combined | storm | Santtary| on-site | Average (sq. ft) Sewer | Sewer | Sewer | Disposal |. (daily gpd) “Total facility area lio.coo eee a Roof area b3p00 “xk Mh poco 44,000 x hy. ‘Other impervious areas, ‘L600 5. List all Environmental control permits held for or issued to this facility: NPDES Permit(s) ‘Air Discharge Permit RCRA/EPA Permit Otter (specify) 6. Does thie facility have a current, written spill contingeney plan? Yes p<] Nol } 7... Até expansion plans scheduled seithin the next three years? Yes. do oo Nokg IN Yes, check the appropriate box(es) sor your facility's expansion plans: ‘Add New Products{ ] Same Products, additional capacity [ ] Expand Current Factliy |] New Facility |} Relocate: { } within Portland { ] outside of Portland {1 Page 12 of 13 ey. ta3008RESPONSISLE CORPORATE OFFICIAL CERUFICATION You have completed the Industrial and Commercial Environmental Survey, Part I. Sign and return, this questionnaire to the Industrial Source Control Division. Tcertify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons directly responsible for gathering the information, the information submitted fs, to the best of my knowledge and beltef, true, accurate, and complete. Iam aware that there are significant penalties for submitting false information, including the possibility of fine and Imprisonment for mowing violations. [40 CFR 403.6(a}(2)()} This certification is to be signed only by the Responsible Corporate Official as per 40 CFR 403.12(0(1) (eg. the president, treasurer, vice-president, general partner, or sole proprietor of the. facility). Responsible Corporate Official: lant 4), Bourn sosnis Genera MANAGER (Print name here) (Title) a LID ruatberreorns 505-259-8232 (Signature) (Phone} Date: Ii to Page 18 of 18 Rev. raues* #8 FACILITY INFORMATION REPORT * * * # Office of State Fire Marshal Community Right to Know - Hazardous Substance Information System | Confidential 4160 Portland Road NE, Salem Oregon 97305-1760 : | (503)378-3473 "PAX (503) 373-1825, Facility Name: ALSCO AMERICAN LINEN Reportable Qntys: Dept/Division: DIVISION OF STEINER CORP BHS Facil Owner/CEO/Reg Agent: R STEINER K STEINER 112r Facility: Send to Attn of: DAN MARLITT PSM Facility: Business Phone: (S03) 285-2233, Chemical Couns 8 E-Mail Address: DMARLITT@ALSCO.COM No.of Employees: 160 Location Address: 1481 N COLUMBIA BLVD cy: PORTLAND County MULTNOMAH sete: oR ZipCode: 97217- Mail Address: POBOX 17337 | ci PORTLAND | state oR Zip Code: 97217- j | cei Type ofBusiness Activity: LINEN SUPPLY NAICS Codes: 812331 LINEN SUPPL. 81332. INDUSTRIAL LAUNDERERS Subs is status: : Survey Mail Date: 9/3/2013 Survey Reveived by OSEM: 10/37/2011 Info Last Updated: 10/19/2011 Emergency Information: NFPA Placard: Y Placard Other: Y Sprinkles Y_—SitePlan: Emerg Contact DAN MARLITT Phone Day: (303)283-2233 Phone Night (360) 256.2648 Fire Dept Description: PORTLAND BUREAU OF FRR&EMS: Emergency Procedures: fraRouGi Ee : sano Page ofFacility 1D Nomber: ois1ag Chemical Trade Name: ECONOMY SOUR Hazardous Ingredient in Highest Concentration: SODIUM SILICOFLUORIDE CAS Number: 16893-85.9 UNNA Number; EA Pesticide Now ve Te cana Hazard Classitieation ] Physical State: SOLID S127 Chem: 64 | Unit of Measure: POUNDS. 313 Chem: | | Dayson Site: 365 PSMChem: | > Quantities Average Amt: 1,0004,999 Amt In: Maximum Amt: 1.000.4.999 Amt Out Storage Pressure ‘Temperature LBAG NORMAL PRESSURE NORMAL TEMPERATURE, 2.BOx NORMAL PRESSURE NORMAL TEMPERATURE, Chemical Storage Locations IniOut Building Floor Area Room ‘Quadrant Location Max Amt INSIDE MAIN’ ' WASH ALLEY NA E 1000-4999 (Chemical Trade Name: FACTOR PLUS Hazardous ingedint in Hight Concenteaon: NONYLPHENOXY POLYETHOXY GLYCOL 5 INNA Number: : Pure or Mix: Mix ENS Chem: Physical State: SOLID 112 Chem: iy Unit of Measure: POUNDS 313 Chem: es 365 PSMChem: ys on Sites [Quantities ———-——~ a Average Amt: 1,000-4,999 Amt in: 10.000-49.999 | Maximum Ame: 1000-4999 ‘Amt Out: Oot (Amoune angally rarsported in and Out of facity) Storage Pressure ‘Temperature LBAG NORMAL PRESSURE NORMAL TEMPERATURE 2,PLASTIC OR NON-METALLIC NORMAL PRESSURE NORMAL TEMPERATURE (Chemical Storage Locations In/Out Building Floor Area Room Quadrant Location Max Amt INSIDE MAIN’ 1 WASH ALLEY NA E 1000-4999) sauna. Page ofFacil ID Numbers 19140 Chemical Trade Name: HYDROGEN PEROXIDE Hazardous Ingredient in Highest Concentration: HYDROGEN PEROXIDE CAS Number: 7722-84-1 UNNA Number: 2014 EPA Pesticide No 5749-7 ~ a aa TT Hazard Classification Poreor Mi: Mix EHS Chem | Physical State: LIQUID 112 Chem: —N Fa | Unit of Measure: GALLONS 313 Chem: —N Dayson Site: 365 PSMChem: —Y J Quantities — oe ee —— Average Amt: 50-199 Amtin; © 30-199 Maximum Amt: 50-199 Amt Outs 0-4 (tnounc annually anspaed tn and Oat offi) ‘Stornge Pressure ‘Temperature LPLASTIC OR NON-METALLIC NORMAL PRESSURE NORMAL TEMPERATURE Chemical Storage Locations twvOut Building Floor area Root ‘Quadrant Location Max Amt INSIDE MAIN 1 SWAsH ALLEY WASH ALLEY se sa199 Chemical Trade Name: IMPERIAL INSTANT STARCH Hazardous Ingredient in Highest Concentration: STARCH CAS Number: 9005.25-8 LUNNA Number: EPA Pesticide No. | Pareor Mix: Pure EHS Chem: Hazard Classification 1 Physical State: SOLID 112r Chem: 7 | Unit of Measure: POUNDS. = Quantities —~ ———_— Average Amt: 1,000-4,999 Ame 10.000-49.999 Maximum Amt 1,000-4.999 Amt Out: 0-4 ‘(Amoantanruallytemsported In and Out of fit) Storage Pressure ‘Temperature LBAG NORMAL PRESSURE, NORMAL TEMPERATURE 2 ‘Chemical Storage Locations nO Building Floor Area Room (Quadrant Location Max Ame INSIDE MAIN 1 WASH ALLEY NA E 1000-4 999 erun01e Pape3 ofTD Numbers ers140 ‘Chemical Trade Name: ANTICLORE Hazardous Ingredient in Highest Concentration: SODIUM THIOSULFATE. CAS Number: 7772-98-7 UNNA Number: EPA Pesticide No. Pace EHS Chem: Hazard Classifieation ~~ i Physical State: SOLID Hr Chem: a | Unit of Measure: POUNDS 313 Chem: 365 PSMChem: Quantities ——— ~ “Average Amt: 00-999 AmtIn: —$.000.9,999 | | Maximum Amt: 500-999 ‘Amt 0 Od i I (Amount amuslly transported Jo and Out of faiity) Storage Pressure ‘Temperature LBAG NORMAL PRESSURE NORMAL TEMPERATURE 2,PLASTIC OR NON-METALLIC NORMAL PRESSURE, NORMAL TEMPERATURE Chemical Storage Locations ivOut Building Floor Area Room Quadrant Location Max Amt INSIDE MAIN 1 WASH ALLEY NA E 500-999 ‘Chemical Trade Name: ACCRUE Hazardous Ingredient in Highest Concentration: SPIROXAMINE TECHNICAL CAS Number: 11813430-8 UNNA Number: EPA Pesticide No. (eee a = Hazard Classification [Pure orMi vin | Physieal State: SOLID N 63 | | Unit of Measure: POUNDS N 45 | Dayson ite: 365 Ne | [Quantities Sosteenen contre narra | Average Amt: 1000-4999 AmtIn: — $0,000-99.099 Maximum Amt: 1.000-4:99 Amt Outs 0+ | (Amount annually transported In and Out of faciy) Pressure ‘Temperature ‘NORMAL PRESSURE, NORMAL TEMPERATURE ‘NORMAL PRESSURE, NORMAL TEMPERATURE Chemical Storage Locations In/Out Building Floor Area Room Quadrant Location Max Amt INSIDE MAIN 1 WASH ALLEY WASH ALLEY E 1,000-4,999 eros Pages ofFavilty 1D Number: 019140 Chemical Trade Name: DIESEL FUEL. Hazardous Ingredient in Highest Concentration: PETROLEUM MID-DISTILLATES CAS Number: 68476-34-6 UNNA Number: 1993, EPA Pesticide No. ~ - Hazard Classification Poreor Mix: Mix | Physical State: LIQUID 30 Unit of Measure: GALLONS | | Dayson Site: 365 i = Quantities. —————— ne Average Amt: 500.999 1.000-4.999 ' Maximum Amt: 500-999 o4 "Storage Pressure ‘Temperature 1ABOVEGROUND TANK NORMAL PRESSURE, NORMAL TEMPERATURE 2 ‘Chemical Storage Locations Inout Building Floor Ara Room Quadrant Location Max Amt OUTSIDE MAIN ‘cANOPIED BOILER SE 500.999 Chemical Trade Name: DRYORTH Hazardous Ingredient in Highest Concentration; SODIUM HYDROXIDE, CAS Number: 1310-732 UNNA Number: 1759 EPA Pesticide No. eee etna nis ces Hazard Classification ] Physical State: SOLID 112 Chem: 80 ' Unit of Measure: POUNDS 313 Chem: | | Dayson Site: 365 PSMChem: (Quantities ——— — Average Amt: 1,00044,999 | Maximum Amt: 1.000.999 m (Amount anally transporte. fn and Out of facility) Storage Pressure ‘Temperature 1.BAG NORMAL PRESSURE NORMAL TEMPERATURE 2.PLASTICOR NON-METALLIC NORMAL PRESSURE NORMAL TEMPERATURE Chemical Storage Locations vOut Building Floor area Room Quaérant —_Losation Max Amt INSIDE. MAIN 1 WASH ALLEY NA E 1.000499 nga Page ofSCrry or PortLanp — ——_— & ENVIRONMENTAL SERVICES ees sista ‘Water Pollution Control Laboratory Expization Date: 12/1/2015 Permit Nomber: 400.167 Page: i WASTEWATER DISCHARGE PERMIT ISSUED To; Steiner Corp -ALSCO sic cope: ms ‘PLANT TYPE: i Comercial Ene Laundry EPA CATEGORY: ‘Non-Categotical LOCATION: 1441 N. Columbia Boulevard Portland, Oregon 97317 MAILING ADDRESS: 1441 N: Columbia Boulevard Portland, Oregon 97217 RESPONSIBEE OFFICIAL: Dax Bourbons PHONE NUMBER: (503) 283-2233 PAX NUMBER: (sta) 26-2386 EXPIRATION DATE: 12/1/2015 INDUSTRIAL SOURCE Zi EQ E2201) CONTROL MANAGER Gerald W. Baumgartner, ‘Bffcctive Dato PREPARED BY: inj CHECKED BY : mt, SACUST RATE aan oD IRA W ATRNG INIA GE BIN ORC RP ANY “or lobilty accommodation equets all 03-25-7740, Oregon Relay Srv at -#00-782800,o¢ DD 509-825-6058,ee ISSUED TO: SIC CODE: PLANT TYPE: EPA CATEGORY: LOCATION: MAILING ADDRESS: RESPONSIBLE OFBICIAL: PHONE NUMBER: FAX NUMBER: EXPIRATION DATE: INDUSTRIAL SOURCE CONTROL MANAGER PREPARED BY: CHECKED BY Expiration Date : Permit Number: Page: WASTEWATER DISCHARGE PERMIT Steiner Corp ALSCO- m3 Commercial Linen Laundry ‘Non-Catogsical M41 N, Colombia Boulevard Pationd, Oregon 97217 i441 N, Columbia Boulevard Portland, Oregon 97217 Dan Bourbouais (603) 283-2233 (503) 283-2386 Iannis Gerald W, Baumgariner jh sannos 400.167 Effective Date SSACUSTOMIERUL-SSinerALSCOsian isa gratnentPERMATUGLO 2015 WASTEWATER DISCHARGE PERMIT Soe! Co-ALSCO oweExpiration Date: 12/1/2015 “TABLE OF CONTENTS Permit Number: 400.167 Page: ii ‘TABLE OF CONTENTS COVER: SIGNATURE PAGE i TABLE OF CONTENTS: ii INTRODUCTION: PERMITTED ACTIVITIES iit SCHEDULE A WASTEWATER DISCHARGE LIMITATIONS ALL B MONITORING AND REPORTING REQUIREMENTS — BI-+ c RESERVED: COMPLIANCE SCHEDULE, chi D SPECIAL CONDITIONS pit B GENERAL CONDITIONS EL F (OBNERAL DISCHARGE PROHIBITIONS FI APPENDIX, 1 DEFINITIONS 1s 2 SAMPLING LOCATION MAP 24-1 3 ACCIDENTAL SPILL PREVENTION PLAN 3d ‘SHCUSTERME Sie ALSCOUAnerc e-em seaenPERDAT2O10 2015 WASTEWATER DISCHAROR PERMIT Snes Comp ALSCO.eExpiration Date 12/4205 TABLE OF CONTENTS Pesmit Number: 400.167 Page: iti INTRODUCTION PERMITTED ACTIVITIES “The permittee is anthorined to discharge industrial wastesatr to the City of Portland's sewer system in ‘compliance with Chapter 17.34 ofthe City Code, the Bureau of Environmental Services Administrative Rois an¢ ay appioable provisions of federal or sate laws or regulations and in accordance with discharge point), effluent imitations, menitoring requirements, and all other conditions set forth hein. Itis the permitee’s duty o comply with all conditions ofthis permit. Any noncompliance with permit, requirements constitutes violation of Chapter 17.34 of Portlana’s City Code and, as suck, subject the permittee 1 enforcement action(s), SACUSTONERTL-SSisine-ALSCOVneiin Linegrtesien PERDMIT20102015 WASTEWATER DISCHARGE FRROIE Ser CapAtsCO teSCARDULE A Expiration Date: vos WASTEWATER DISCHARGE LIMITATIONS Permit Number: 400.167 Pag AL Schedule A WASTEWATER DISCHARGE LIMITATIONS [Listed helow are the waste discharge limitations not to be exceeded after the permit effective date. Applicable regulations include Chaptess 17.34 (Schecile F of this permit fists the General Discharge Prohibitions) and 17.36 of the Code of the City of Poztland. ‘The point of compliance withthe discharge ‘imitations shall be the sampling manhole in the parking lot south of the main building, Sampling point is designated as 1A. Poo * Pollutant Local | Categorical Limit, C7 Name Limit Daily =~ val mommy “Max wg) Daily Monthly ‘METALS "Avene a2 Cadmium on ‘Chyeminen 5.0 Copper 37 Lead 0.7 Meroacy 0.010 ‘Molybdenin’ La Nickel 28 Selenium 08 ilver od Zine a “NOMMBTALS NOROANICS Cyanide 12 - * pH 5.O-1LS au, NQNMEIDSLS (ORGANICS) 41,2-Dichloroethane 0.80 2)4-Diniinotoluene 0.12 ‘Aerylonitrile Loo Chlordane 0.08 Chiorsbonaene 020 Chlovoform | 0.20 Nitrobenzone. 2.00 Pentachlorophenol 9.04 ‘Trichloroothyione 0.20 * — Nom-polar Oil & Grease 110 Permit Specific Limits wee note 5 Notes: 1. This schedule may be revised upon written notification by the City to accommodaté process changes by the pemninee or a determined by the Ditector of Bnviconmental Services. 2. Insddition to the limits stated in Schedlule A, the permitiee shall comply with all other applicable City, State and Federal regulations. ‘SACUSTOMERUL Seine ALSCOM nessa Linealpnireninen PERRITOOI0 015 WASTEWATER DISCHARGE PEROT Stet CopatscoideeSCHEDULE A Expiration Date : 1015 WASTEWATER DISCHARGE LIMITATIONS: Permit Number 400.1697 Page: a2 3, The poltutantpasameters masked with ao asterisk (*) are the pollutans of concern, At rsiniman, the permittee is required monitor for pellutans of concern. ll firs are appliceble at the point of compliance, 4, The permittee is required 10 meet the MOST stringent limitation listed, denoted in bold type in the above table, when comparing the Local Limit column with the Categorical Limi columa, 5, This is a permit specific limit developed and implemented in accordance with Bureau of Environmental Services Administrative Rules, Section TI (4)) 6. ‘The City has Pollntant Prohibitions for certain individual organic compounds that are not amenable to iological tceatment or that have a screening value or locel limit that less than the practical ‘method detection level (MDL). Discharges containing concentrations ofa prohibited pollutant above the MDL, 2s listed in Appenclx 5, is « violation of City Cade and this permit. SACUSTOMErA s'SenesALSCOnerea LinelecetmontPERMINQO1D 2015 WASTEWATER DISCHARGE PERMIT Siner Corp ALSCO.t>SCHEDULE B Expiration Date: wno1s MONITORING AND Permit Number: 400.167 REPORTING REQUIREMENTS Page: BL Schedule B MONITORING AND REPORTING REQUIREMENTS IL, Periodic Compliance Self-Monitoring Report Feb | Nar | Ape | Wey [Jon | Jur [Aug | Sept | Oa [Nov | Der gs jas | as jas fs |g | is | is | as | os os Hi, Peviodic Compliance Self-Monitocing Report, Notes; 1, Periodic Compliance Reports are (o be submitted to the Industrial Source Control Division by the 15th of the month following the conclusion of the reporting period, Sarapling, analysis, and reporting will follow the schedule above, 2. Allolficial sampling shal be taken atthe approved sampling lovatton, (See Appendix 2: sampling Tocation map.) 3, ‘The ponmites stat analyze sermplen forall ised pavameters plus any other which might be ~ me expected to be present in significant quantities 4, Tho permittee shall submit all sol- monitoring results to the Industrial Source Contra? Division as ‘part oftheir monitoring and reporting requirements 5. All monitoring resus are to be mailed to Industrial Source Control Division Bureau of Environmental Services City of Porttand 6543 N. Burlington Ave. Portland, OR 97208 6 Periodic Compliance Reports are to be submited by the 15th of each month following the report period for each sampling location. The reports shall consist of: 4. Statement of compliamce/noncompliance, signed by the oicially designated contact person (statement is found on bottom of the self: monitaring report fox). ‘S9CUESTOMERUL-SGiene-ALSCOM mere anpeetmnenFRATI2010.20:5 WASTENATER DISCHARGE PERMIT Suier Carp ALSCO.doeSCHEDULE B Bxpiration Dates rans MONITORING AND Permit Number: 400.167 REPORTING REQUIREMENTS Page: B2 Schedule B MONITORING AND REPORTING REQUIREMENTS TL, Perioilic Compliance Self-Monitoring Report (Notes continued): Sample analysis results recorded on the appropriate sei: monitoring report form. : and chain of custody for sample collected, 6 Osiginals of al Inboratory analysis sheets showing who analyzed sample, date ane time sample was analyze, enalyticel methods used, metod detection limi, test result and quality assurancefsuality contol, ; 4. Copies of pH charts (if any) showing violations (Fany). Any other eports that may be required, £ Caloulations of monthly average if appropriate. 7. ‘The permite shall intact its laboratory tha, ifthe oil end areas (otal) concentration exceeds 4110 mg/L, the laboratory must determin the concentrations of the polar end non-polar oil and sprees factions, 8. "The City may reduce or increase the frequency of sampling, based on the analysieal results submitted. 9.°°°" “Re eh aO/ CFR 403.1260) if an industeial der Subject'o the reporting requitements of Schedule’B _monitors ny parameter from the official sampling locaton moxe frequently than required, using procedares specified in Schedule E146), the results oftheir monitoring aust be submited in the required report, ‘SSCUSTOMBRUL Sine: ALSCOMUtceg.LnenlpeetnenQ ERIM 010-205 WASTEWATER DISCHARGE PEROT Steer Corp ALSCOdoeSCHEDULE C Expiration Date: i2neo1s COMPLIANCE SCHEDULE Pesmit Nomber 400.167 Page cL Schedule COMPLIANCE SCHEDULE Not Applicable (optional) SxCUSTOMERNU.SStincr ALSCCMnase-LinenpetraninentFSRMITIOI0-2018 WASTEWATER DISCHARGE PERNT Steiner Corp AtsCO teeSCHEDULE D Expiration Date: 12712015 SPECIAL CONDITIONS Permit Namber: 400.167 Page: DL Schedule D SPECIAL CONDITIONS pt ‘The Industrial Source Control Division has approved the method of monitoring of the wastewater pHi at the time of discharge to the City Sewer system, This approval may be. revoked at any time, if ppl date are not representative ofthe Sampling data obtained fiom the sampling manhole. To enstre {hat the basic City monitoring and reporting requirements ase met, the permittee shall include a summary of significant pH excursions with its monthly reposting of parameters listed in Schedule 1B, This is in adcition fo the mandatory reposting of discharge violations within 24 hours of learning ‘of these violations, ‘Significant excursions are defined as: a. pH exoursions > 11.5, $ 12.5 fora total duration of more tha 15 minutes in any calender day. b, —_pHexemsions > 12.5 fora ttt duration of more than 5 rites in any’ cena dy. ¢. __pHexcnrsions les than 5.0 regardless of duration during a calendar day. inch occurrence shall be reported with the date, time, duration and the maximum or miniraum pli exeunsion reached, ‘The monthly report shall contain the total time (ip minutes) that the pH was ‘outside the limits st in Schedule A. ‘The permittee is required to continue using a strip-char-ecording pH{ meter for continuous pH, e recording or any other pH control system recorder that meets with City approval. A daily record ‘shall be kept for each day of plant operation, excluding those days when there is no process activity i ‘The records shall be: maintained and must be available for direct review or photo duplication by City representatives, if required. ‘Upon approval by the Industrial Source Control Division, pH monitoring may be performed a the designated point of accommodation instead of the point of compliance specified monitoring. The point of accommodation shall be located afterall wastestreams have been combined and ‘pretreatment has bee completed. Performing the pH monitoring at the pot of accommodation does not relieve the permitee of the responsiblity for maintsining compliance a the sampling, :manhole~-the pH limits are applicable et both the point of eceommedation and the point of compliance. SCUSToMETRUL sistlee- ALSCOMAnran LneleestnentERMFTUOI6-2018 WASTSWATER DISCHARGE PERMIT Sine Cap aLsCOseeSchedule & Expiration Date 12ninols GENERAL CONDITIONS Permit Number: 400.167 Page: EL Schedule GENERAL CONDITIONS 1. Accidental Spill Prevention Plan "fo comply with Section 17.34,090 of the City Code, the permittee shall sabmit a new or revised Accidental Spill Prevention Plan (ASPP) to the Industrial Wastewater Management Section 90 days: after the effective date ofthis permit The plems shall include the following elements. a, A description ofthe hazardous substances handled and their potential points of entry into the City sewer sysiem of storm runot b, A description ofthe measures to be taken to prevent entry atthe described points before a spill ocours ¢. —- Measures to be taken to contain a spill if one occu 4d, A desesiption of employee training in the prevention and control of spills ©. A posted notice informing employees of the requirement to notify the Burem of Environmental Services in case of spills or uncontrolled discharges. 2 Appeal ‘Upon receipt of fina industrial wastewater discharge permit, 2 penmittee may appeal any of is {erns or conditions tothe Code Hearings Officer in aecordance with procedures set out at Chapter 22.10 ofthe Portland City Code; provided thot such an appeal hal include a copy ofthe pent that isthe subject ofthe apoel, shall state the basis forthe appeal, and shall be filed with the Code Hleings Officer and the Bureau of Environmental Services. Be Authontzed Disch All discharge ad activities authorized herein shall be consistent withthe terms and conditions of| this permit, Chapter 17.34 of the City Code and the Administrative rules. The discharge of any pollutant in excess of these limits shall constieute a violation of the terms and conditions ofthis permit. 4, Bypass or Diversion ‘The diversion oF bypass (the imtensional diversion of wastestreans from any portion of a permittee’ tweatmentfecility) of emy discharge, from facilities used by the permitiee, co maintain compliance ‘with the terms and conditions of this permit is prohibited except 8, When unavoidable to prevent loss of life or severe property damage: ‘When excessive storm drainage or runoff would damage facilities necessary for compliance ‘with the terms and conditions of this permit. SACUSTOMERML-sseieALSCOMAMtaenenigeeetnersPERMIT2010-2018 WASTEWATER DISCHARGE FERMI Slee Corp-aLsCO dee‘Schedule f Expiration Date 12/2015 GENERAL CONDITIONS Permit Number: 400.167 Page: ER 4. Bypass or Diversion (continued) ‘The petmitce shall immediately wotily the City in writing of each such diversion or bypass, in cordance with the procetire specified in condition No, 23. 5 Cente Legible copies of all applications, reports, and information submitted to Une City shall be signed and ‘costified us follows in accordance with 40 CFR 403.12, J ceriify nder penalty of law thee this document and all ataclrnents were prepared under my direction or supervision in accordance with a system designed t assure that qualified persennel properly gathr and eveiate the information submited. Based on my inquiry ofthe person oF ‘persons who martage the system, oF those persons directly responsible for gathering the ‘information, the information submitted is, tothe best of my knowledge and belief. true, accurate, ad complete. Lam asvare tha there are signfican! penalties for subrmiting false information, inckualing the possibility of fine and imprisonment jor krowing violations, i. Chemical Storage (Chemicals shall be stored in a manner that will prevent the entry of these substances into the sanitary, combined sewer, or storm sewer system or waters ofthe ste. Continuous Compliance CComiplisnice with Schedute B, No. 25 shall not relieve de permittee from responsibility to maintain ‘continuous compliance with the conditions ofthis permit. Dilution Prohibition Tris unlawful fora dischargers use difution a5. partial or complete substinie for adequate een ta esi uae treatment t achieve compliance withthe standards and limitations set forth in this permit. ‘The ‘Director may impose mass limitations on dischargers who arc using dilution to meet the applicable [pretreatment standards or the requirement sel forth in this permit. Enforeement Provision A violation of any conditions, standards or requireents of this permit constitutes @ violation of ‘Chapter 17.34 ofthe City Code and eny rules promulgated thereunder. Therefore, the City may seek any or all of the remedies or penalties provided for in Section 17.34.110 of the City Code, including recovery of costs ineurred by the City in response tothe following: 2, Any violation by the permittee of the provisions in this Industrial Wastewaler Discharge Permit b, Any violation bythe permite ofthe provisions ofthe City Code ‘S\CUSTOMBRUU. Stier ALSCOMedan-Jnniperenen PERMIT2O10015 WASTE Carp ALSCO.doeSchedule B Expiration Date impos GENERAL CONDITIONS Permit Number: A067 10, rt 2 Page: Fa Bnforcement Proviston (continued) ©. Any violation by the permittee of at Enforcement Action requisement with zespect to “provisions set forth inthis Industrial Wastewater Disehayge Permit and the City Code and ‘Administrative Rules. ‘The range or severity of enforcement actions taken by the City against the permittee will he determined by, but 1 limited to, che nature, magnitude, dacation, and frequeney of the violation as provided by City Code and Administrative Roles, Extra-Strength Sewer Charge (ESSC) ‘Discharges exceeding 300 mg/l for the 5-day biochemical oxygen demand (BOD) or 350 mg/L. (otal suspended solids (TSS) concentrations (as defined in Section 17-36.050(1) of the City Code) shall be subject to the extra-trength sewer charge (SSC) established in Section 17.36.060(1). Hazardous Waste Notification ‘The industrial user shall notify the Industrial Source Cont Division Section, the POTW, the BPA, Regional Waste Management Division Director, and State hazardous waste authorities in writing of any discharge into the POTW of a substance, which, if otherwise disposed of, woutd be hazardous ‘waste under 40 CFR Part 261. Such notification must include the nate ofthe awardous waste as set forth in 40 CFR Part 261, the EPA hazardous waste number, ad the type of discharge (Continuous, batch, or other). Ifthe industrial user discharges moze than 100 kilograms of such ‘waste per calendar month to the POTWY, the notification shall also contain the following information 10 the extent such Information is known and readily evailable to the industrial user. a ‘identification of the hazaedous constiments contained in the wastes, an estimation of the mass andl ‘concentration of such constituents in the wastestream discharged daring that calendar month, and aa estimation of the mass of constituents in the wastestream expected to be discharged during the following 12 months. Tuspeetion and Entry ‘The permittee shall, at all seasonable times, allow authorized representatives ofthe City: To enterthe permittee's premises where an effiuent source or disposal system is located or where any records associated with this permit are kept, b, To have nvcess fo any required records and permission to copy these records. At no time ‘can wastewater effluent data be claimed or held as confidential information ¢. To inspect and evaluate any monitoring equipment or monitoring methods sequired by this permit. 4, To sumple any discharge to the sewer system. SACUSTOM ERE: Stene-ALSCOMAmeten-nenpetnttPERMTROOIO-2015 WASTEWATER DISCHARGE PERM Sse CapniscoidaeEopiration Date 12/1/2015 ScheduteR GENERAL CONDITIONS Permit Nomber: 400.167 Page: Ba 13, Liability ‘The City of Portland, its offices, agents oremployees shall not sustain any liability due tothe ‘ssuance of this permit ar the eonstrueion gr maintenance of facilities resulting from this permit 14, Monitoring b. “The permittee shall recor the following information: * The exact date, time, and plsce of sampling % Name af parson who collected the sample(s) * Type of sample(s) collected * ‘The dates analyses were pesfornied * Who perforied the snalyses * The analytical techniques or methods wsed * The resus of all required analyses * —Whethee quality assurance and quality contro! laboratory procedines are followed Snmples and measurements taken to meet the requirements ofthe above condition, shal be representative of the effluent. Grab sampling techniques mast be used for samples ‘collected for pH, evaside, phenol, sulfide, voalile organic compounds an oll endl grease monitoring, Att sampling sd analytical metbods used to meet the melting serplterents specified i ‘this permit shall, unless otherwise approved in writing by the City, confor to the Guidelines Establishing Test Procedures for the Analysis of Pollutants as specified in 40 CFR, Part 136. Laboratory quality assurance and quality control programs should be documented, EPA QAIQC programs shoutd be followed ‘The permittee is required to document proper installation, and maintenance of flow ‘monitoring and sampling equipment. ‘the vesults ofthe permittees wastewater analysis indicate tht a noncompliance hes ‘occured, the permittee must notify the City's Industiat Souree Control Division Section within 24 hours of becoming aware of the noncompliance. The permittee must also repeat the smpiing within 24 hours of the effluent noncompliance or next process day and submit the analysis tothe City within 30 days after becoming aware ofthe noncompliance. ‘The permittee shall take all rezsonable steps to minimize or correct ny adverse impact to the POTW or the environment resulting from noncompliance with this permit, including such accelerated or additional monitoring as necessary to determine the nature and impact of the non-comalying discharge. SHCUSTOMERUL-SSieler- ALT America Lneneeescnea PERMIT 2010-2018 WASTEWATER DISCHAROE PERMIT State Compa scOidoe‘Schedule 1 ‘Expiration Date wno1s GENERAL CONDITIONS Permit Number: 400.167 Page: BS 14, Monitoring (continued) & requested, de permite shall provide or split discharge samples with the City of Poland ‘Water Pollution Contrl Laboratory, 15, Permit Modification ‘This permit may be modified with 30 days prior written notification, in whale or in par, for causes including but not limited to the following: & —_Acchange in the City's NPDES permit or any other condition that requires either a emporery or permanent elimination of any sutborized discharge. b, "To incorporate new or revised federal, state, of local pretreatment standards or requirements, Information indicating thatthe permitted discharge poses a threat fo the City’s collection and treatment system, POTW personnel, or the receiving waters and sludge, 4. Tocorrect ypographical or other enor in the permit, Any significant change in the vouime of a permitted discharge 16, Permit Renewal ‘This permit is issued to a specific entity and camnot be transfered by he industrial user and must be seneved pursuant to Section 17.34.070 of the Code of the City of Pertiand and Permit Applications must be received 90 days ptior to iti date ot tr pain ’., Inthe event the pomittee plans to cease operations atthe present location, and plans to relocate within the City of Poland’ jurisdeton and contine the sean penited sctivities ¢ _The permitted industrial process being significantly altered or changed so that pollutants ‘not specifically mentioned inthe current permit are present inthe permittees discharge. 17, Permit Suspension or Termination 4 Violation of sny zens or conditions of this pemnit or any applicable rue, standard, or order of the director of the Bureau of Environmental Services, 1b, Obtaining this permit by miszepresentation or faluve co fully disclose all relevant facts, cc. _Falsifying self-monitoring reports, Tampering with monitoring equipment. SICUSTOMERU Sener ALSCOlsrieninenpeveinen'PERATOOIO2O1S WASTEWATER DISCHARGE PERMIT Sune CexpAtSCO doeSchedule B Expiration Date 12/t0ts ‘GENERAL CONDITIONS Permit Number: 400.167 Page: Bo 17, Permit Suspension or Termination (eontinued) c. Refusing to allow prompt access tthe facility premises and records. {allure to meet efflven limitations 8 Failure to pay fines. h, Failure to meet compliance schedules. 38 Plant Closure Tnthe event the permitte plans to cease operations atthe present business location, and not to relocate within the City of Portlan!s jurisdiction, the permits shall inform this office, in waiting, 60 days prior to plant closure 19. Property Rights or Priviteges “The issuance ofthis permit does not convey any sroperty rights in either real or personal property, ocany exclusive privileges; it does not authorize any injury to private property or any invasion of personal rights; and it docs not authorize any infringements or federal, state, or local laws oF regulations. ‘Records Retention Atlrecords of monitoring ativities and reals, including all original srlp clvart recordings for ‘continuous monitoring instrumentation (and calibration and maintenance records), shall be retained by the permitice or a minimum of three years. Tis retention period shall be extended during the ‘course of any unresolved litigation pertaining tothe discharge of poltutants by the permittee, or ‘whenever it is requested by the City, the Approval Authority (DEQ), the Regional Administator (ePay: * ‘Reporting Requirements 2, Accidental or Siug Loading If accidental or slug loading tothe sanitary sewer occurs, the permittee ball notify the City Permit Manages immediately. If no answer, then call the City Duty Officer at 503-823- 7180, which is 2 24-hour holine available 7 days a week. A formal writen report, iscvesing cirarmstances and remedies, shal! be submitted to the City within $ days ofthe occurence, b. Changes in Wastewater Characteristics ‘The permittee shall pive notice to the Industrial Source Control Division Section 90 days before any facility expansion, production increase, or rocess medications tat reat in new or substanally increased discharges ora change in the nature ofthe discharge SSCUSTOMERUL.Siner ALSCOAmnson-LinenptenmePERMETZO102015 WASTEWATER DISCHARGS PERMIT See CopalsCOdeeSchedule E Expiration Date innois GENERAL CONDITIONS Permit Number: 400.167 Page: By 24, Reporting Requirements (continued) Change in representative If the zesponsibie corporate official changes, notify the City within £0 days, as per 40 CFR 403.12(1) 22, Severability “The provisions of this permit are severable, end if any provision of this permit or the application of ‘any provision of this permit to any circumstance is held invali, the application of such provision to the other circumstances and the remsainde- ofthis permit shall not be affected, 23, Significant Non-Compltance “The City of Portland is required to sannally publish in the Oregonian newspaper a lst of Industrial ‘Users that, at any time daring the previous 12 months, were in significant non-compliance (SNC) ‘with protreatment requirements. SNC is determined ifa violation meets one or moze ofthe following criteries 4, Violations of wastewater discharge limits: ‘4 Chronic violations — when sixty-six percent (66%) or more of all of the measurements taken for the some polutant exceed the respective discharge Timit for that pollutant ) county of Multnomah ) 6 i 1, Jeremy L. Richardson, being first sworn on oath do hereby depose and say: : : BACKGROUND, el Iam a police officer with the Oregon State Police and have been so employed for 16 | Yeats, Lam currently assigned as « Detective in the Special Investigations Unit ofthe Fish and in| Wildlife Division; @ position I have held since March 1, 2011. Tam responsible for the 13| investigation of environmental crimes for the Oregon Department of Environmental Quality 14) (QQ). In that capacity, I have received training in the investigation of Environmental Crimes 15 including but not limited to Unlavefial Air Pollution, Unlawful Water Pollution, Unlawful 16. ae fi so | Pisosal, Storage and Treatment of Hazardous Waste and Unlawil Transport of Hazardous ep /s Wester Phaveraitended over 70 hours:of specialized training in environmental.investigatigns 10... 19| include the Western States Introduction to Environmental Enforcement and Introduction to 20| Criminal Environmental Investigations courses as well as the McCoys’ Resource Conservation 21) and Recovery Act Seminar. 2 As an employee of the Oregon State Police, I served as a Detective with the Oregon State 2B 4) Police Arson and Explosives Section Zor 4 years, and as a Troopet in the Patrol Division for more 95) than 7 years, Ihave held certifications in fire origin and cause investigation, post-blast, gation and was a certified accelerant detection canine handler. In that capacity, 1 conducted detail-oriented, physical evidence-based examinations of erime scenes ranging fromwor ww ee ae fire origin and cause investigations to motor vehicle crash investigations. I have conducted investigations in crimes ranging from Failure to Perform the Duties of a Driver to Arson in the First Degree to Aggravated Murder. I have also conducted investigations into related crimes such as Money Laundering, Theft by Deception, Forgery and Aggravated Theft, I have been trained by and am a graduate of the Oregon State Police Recruit School and hold my basic, intermediate and advanced law enforcement certifications through the Oregon Department of Public Safety Standards and Training. I served as an employee of the Oregon State Police Forensic Laboratory from 1996 until 1998, and have certifications in both crime scene analysis, and latent fingerprint identification. I have a Bachelor of Science degree in Biology from the University of Oregon. I am also a certified Field Training Officer with the Oregon State Police. PURPOSE Lam investigating allegations that American Linen — Steiner Corporation (ALSCO) and ‘the company’s Chief Engineer, Rod Baker, and former Chief Engineer, Dan Marlitt, intentionally altered the company’s waste discharge water by dilution and the addition of hydrogen peroxide, in violation of ALSCO’s pre-treatment plan and their City of Portland Industrial Wastewater Discharge Permit. Thave set forth facts of this investigation for the purpose of securing a search warrant to search, sample, seize, document and analyze physical evidence related to criminal acts under investigation that are believed to have been committed by Dan Marlitt, Rod Baker and ALSCO located at the facility and on the premises of American Linen-Steiner Corporation (ALSCO);, located at 1441 N. Columbia Boulevard, Portland, Multnomah County, Oregon, and the person of Rod Baker. I have not included each and every fact known to me conceming this investigation ‘but have set forth the facts that are necessary to establish probable cause to believe that criminaltw & Soe aay acts in violation of Oregon Revised Siatute(s) (ORSs) have occurred in Multnomah County, Oregon, including ORS 468.943, Unlawful Water Pollution in the Second Degree; ORS 468.953, Supplying False Information to Agency and ORS 165.080, Falsifying Business Records. [also have set forth the facts to reasonably show that evidence pertinent to the investigation of these ctimes will be located at American Linen-Steiner Corporation (ALSCO) located at 1441 N. Columbia Boulevard, Portland, Multnomah County, Oregon. ‘The facts set forth in this affidavit are based on knowledge obtained from my review of an affidavit written by Special Agent (SA) Eric Martenson; who I know to be employed as a Special Agent with the U.S. Environmental Protection Agency (EPA) Criminal Investigations Division, and from conversations I have had with SA Martenson; Said affidavit is incorporated herein as Appendix A to this affidavit. LEGAL BACKGROUND Based on my review of Oregon Administrative Rules, Oregon State Statutes, Portland City Code and my training and experience, | know the following: ‘Pknow that in order to restore and maintain the quality of public waters and to protect the. public health and general weltare ofthe people ofthe State of Oregons under the authority of ORS 468.020. The Environmental Quality Commission (EQC) adopts rules listed in Oregon Administrative Rules (OAR) Chapter 340, Division 45, Regulations Pertaining to NPDES (National Pollutant Discharge Elimination System) and WPCE (Water Pollution Control Facility) Permits to perform the functions required under ORS 468B. Tknow OAR 340-045-0010(12), Definitions, states: (12) NPDES Permit means a waste discharge permit issued in accordance with the National Poltutant Discharge Blimination System authorized by the Federal Act and OAR Chapter 340, division 045.Row Boe wa Tknow the City of Portland operates two wastewater treatment facilities which receive wastewater from both domestic and industrial sources. The City of Portland is allowed to operate these treatment facilities under a valid NPDES permit issued by the DEQ under OAR 340, division 045, The City of Portland’s NPDES permit, #70725, under Schedule Es Pretreatment, Part 6; Control Mechanisms is required to regulate discharges from significant industrial users. T know Chapter 17.34 of the Portland City Code regulates industrial discharge.to the City’s wastewater treatment facilities. I know Portland City Code 17.34,070, requires industrial users obtain Industrial ‘Wastewater Discharge Permits if they meet the criteria of the City's Code. Linow Portland City Code 17.34.050, states that the Industrial Wastewater Discharge Permit generally requires the industrial user to reduce the amount of pollutants in its wastewater by installing or modifying a pretreatment facility. I know the permit issued fo Steiner Corp-ALSCO, by the City of Portland, Permit # 400-167 ;,under Schedule’ B; Monitoring and Reporting Requirements; requires that the industrial user monitor the amount of pollutants in their discharge and report the results; representative of their wastewater discharge, to the City of Portland Bureau of Environmental Services (BES), at prescribed intervals, I know OAR 340-045-0015(4), states: that while a person discharging wastes into a sewerage system is not required to obtain a DEQ pemnit if the owner of the sewerage system has a valid NPDES permit, they must comply with all applicable laws, rules and regulations regarding water pollution. This nule is adopted under the statutory authority of ORS 468.202, 468.020 and 468B.035,Tknow that ORS 468.943, Unlawful Water Pollution in the Second Degree; states: (1) A person commits the offense of unlawful water pollution in the second degree if the person with criminal negligence violates ORS chepter 468B or any rule, standard, license, permit or order adopted or issued under ORS chapter 468B. (2) Subject to ORS 153.022, Unlawful Water Pollution in the Second Degree is a Class misdemeanor. Tknow ORS 468.953 Supplying False Information to Agency, states: (1) A person commits the-crime of supplying false information to any agency if the person: (a) Makes any faise material statement, representation or certification knowing it to be faise, in any application, notice, plan, record, report or other document requited by any provision of ORS chapter 465, 466,468, 4684 or 468B or any rule adopted pursuant to ORS chapter 465, 466,468, 468A or 4688; (b) Omits any material or required information, knowing it to be required, from any document described in paragraph (a) of this subsection; ot (c) Alters, conceals or fails to file or maintain any document described in paragraph (a) of this subsection in knowing violation of any provision of ORS chapter 465, 466, 468, 468A or 468B or any rule adopted, pursuant to ORS chapter-465; 466; 468: 468. or 468B. (2) Supplying false information is.a.Class.C.felony. Tknow that ORS 165.080, Falsifying Business Records, states: (1) A person commits the crime of falsifying business records if, with intent to defraud, the person: (a) Makes or causes a false entry in the business records of an enterprise; or (¢) Fails to make a true entry in the business records of an enterprise in violation of a known duty imposed upon the person by law or by the nature of the position of the person; or (d) Prevents the making of a true entry or causes the omission thereof in the business records of an enterprise. (2) Falsifying business records is a Class A misdemeanor.aa w ee FACTS On September 8, 2014, I met with SA Erie Martenson with the U.S. EPA, I know that SA Martenson is assigned to the Criminal Investigations Division of the U.S. BPA and is responsible for investigating environmental crimes. J also know that SA Martenson has been employed in this capacity for 1L years. SA Martenson provided to me his notarized affidavit setting forth the facts he had observed during his investigation of American Linen ~ Steiner Corporation (ALSCO); incorporated herein as Appendix A to this affidavit, Thave confirmed through the Oregon Secretary of State website that ALSCO is still an activé assumed buisiness name in the State of Oregon, with an Authorized Representative of Steve Larson in Salt Lake City, Utah, and a Registrant of the Steiner Corporation. On March 14, 2010, ALSCO changed its listed Principal Place of Business to 505 E South Temple in Salt Lake City, Utah. However, prior to that date, ALSCO listed its Principal Place of Business as 1441 N Columbia Boulevard in Portland, Oregon. Thavve vonfirmed through the website PortlandMaps.com that the property location of 1441 N. Columbia Boulevard is still owned by Steiner Corp and ALSCO INC. Thave reviewed the BES Wastewater Discharge Permit for Steiner Corp-ALSCO, permit 4.400.167. ‘The plant type is listed as a Commercial Linen Laundry, with a site address of 1441 N. Columbia Boulevard, Portland, Multnomah County, Oregon, 97217. Thave conducted a Law Enforcement Data System/National Crime Index Center {LEDS/NCIC) search on each of the following subjects identified by SA Martenson in his affidavit.Daniel Marlit, date of birth 2/19/48, has no Computerized Criminal History (CCH) and possesses a valid State of Washington driver's license. Robert Grubb, date of birth 11/19/66, holds a valid Oregon driver's license and is listed as having applied for a concealed weapons permit in 1992. Robert Grubb does not have a CCH. Shaun Shatto, date of birth 12/02/66, holds a valid Oregon driver’ license andi sted in LEDS as baving a 1992 charge of menacing with no complaint filed. Paul Downard, date of birth 10/01/66, possesses a valid Oregon driver's license, and is listed as having been convieted of Harassment in 1988, with dismissed charges of Assault IV, Possession of controlled substance, Use of invalid operator’s license and Failure to pay a fine for Pailute to carry an operator's license. Rodiney Baker, date of birth 03/23/64, possesses a valid Oregon driver's license. Rodney Baker is also listed in LEDS/NCIC as a Registered Sex Offender with x 1997 conviction for Felony Criminal Sexual Misconduct in the 2" Degree in Michigan. SA Martenson provided me with an enforcement history for ALSCO, provided to him, and maintained byBES! ALSCO -has 5 enforcement actions against their Portland facility,.cs0s between 2001 and 2010, for exceeding its allowable wastewater parameters for oil and grease on 3 occasions, for filing a late report on 1 occasion and for exceeding the allowable pH in its wastewater on 1 occasion, SA Martenson also told me that Wes McDaniel with the BES told him, that ALSCO received a notice of violation from the BES for exceeding its ellowable limit for oil and grease on July 30, 2014. I know from SA Martenson’s attached affidavit that peroxide was added to the wastewater discharge at ALSCO, the company limited the washing of shop rags at the facilitywk wn an during sampling days and that the recycled water (water reuse) system was tumed off at the company’s washers to ereate dilution of the wastewater discharge. 1 also know from the aforementioned facts that dilution is specifically prohibited in ALSCO’s industrial Wastewater permit, the addition of peroxide is not a prescribed pretreatment step in ALSCO’s pretreatment plan; and further, these acts do not provide a representative wastewater sample for regulatory purposes; as required in ALSCO’s Industrial Wastewater permit. [know from my training, experience, and the aforementioned information from SA Martenson, that it is common for businesses to keep records of their supply purcbases such as receipts, bills and invoices: These purchases can include chemical reagents used in the pretreatment process as well as pumps, meters, filters and other hardware used by a business.to. conduct its pretreatment work. T know from my training and experience that businesses commonly keep records of their employees’ contact information, terms of employment, training and credentials and disciplinary proceedings. Tknow:that these documents are commonly kept atthe facilities for reference by, the employees.and managers: 1 know from the aforementioned information provided by SA Martenson that ALSCO completes their own intemal documents reflecting their water use such as the Reuse Water Make-up Report. These documents corroborate the increased water use caused by dilution from shutting off the recycled water system on the washing machines on test days. know from my training. experience, and the aforementioned information from SA Martenson, that it is common for individuals working for a company or department to communicate both in person, on the phone and by electronic means such as emails and text messages.ew aw 26 27 Based upon my training and experience, itis common for owners and employees of a business to use digital devices for the generation and storage of business-related records, including billing invoices, bid solicitations, contracts, and inspection records, as well as email accounts used to transmit "Digital devices” which includes any electronic device capable of processing andior storing data in digital form, including, but not limited to: central processing units, laptop or notebook computers, peripheral input/output devices such as keyboards, printers, scanners, plotters, monitors, and drives intended for removable media, related communications devices such as modems, cables and connections, electronie storage media (such as bard disks, floppy disks, diskettes, compact discs, CD-ROMs, DVDs; optical discs, Zip cartridges, thumb drives, printer buffers, smart cards, or electronic notebooks, or any other storage medium), and clectronieidigital security devices wireless communication devices such as telephone paging devices, beepers, mobile or cellular telephones, smart phones, personal data assistants (“PDAS”), iPods/iPads, Blackberries, digital cameras, digital gaming devices I know from my training and experience that in erder to completely and accurately retrieve data maintained. in computer hardware and computer-related documentation, 9 insure, accuracy and completeness of such data, and to prevent the loss of the data either from accidental or programmed destruction, it is often necessary that such computer equipment be processed by a qualified computer specialist in a laboratory setting T know that the Northwest Regional Computer Forensic Laboratory (hezein after referred toes RCFL), Portland, OR, is staffed with individuals who are specially trained and certified in the retrieval of electronic records from computers, phone and other electronic equipment, and are capable of imaging these devices for the purpose of analyzing the documents stored on them RCFL employees will be accompanying us on the warrant to assist with the search, seizure and‘analysis of computerized and electronic records, specifically emails between ALSCO employees 2| and ALSCO’s analytical lab (APEX). 3 know that SA Martenson with the US EPA has specific knowledge related to the 4) aforementioned facts of this case as well as knowledge of the Federal Clean Water Act and 5) oregon Revised Statutes related to Water Pollution, Therefore, SA Martenson and other EPA ; Special Agents will be accompanying us on the warrant fo assist with this investigation ‘i [mow from my training and experience that the DEQ also employs individuals in their 9) Laboratory and Environmental Assessment Division, who are trined and experienced in the 10| collection, analysis and identification of chemicals, such as Natural Resource Specialist Thomas 11) Lossen. ‘Therefore, employees from the DEQ Laboretory and Environmental Assessment a Division will be accompanying us on the warrant to assist with sampling the contents of the = peroxide barrel and any other potential chemicals. rc | know thatthe Portland BES has employees with specific training and experience related 16| to Industrial Wastewater permits and pretreatment programs. These employees, such as Permit Manager Wesley McDaniel, can employ that knowledge and experience to accurately assess is > whether or not a company is in compliance with their Industrial Wastewater permit and 19) an], 2*eeemERt lan, Therefore, employees from te Portland BES wil be accompanying ws on the 9; | warrant to assist with this investigation as it pertains to examining the condition of any 22) equipment and any violations of ALSCO Industrial Wastewater Permit B T have probable cause to believe, from: the aforementioned information and SA 24) Martenson’s affidavit that Rod Baker, Dan Marlitt and ALSCO have committed the erimes of "| Unlawful Water Polfution in the Second Degree, Supplying False Information to Agency and c Falsifying Business Records, Evidence related to these crimes, including, but not limited to a 108 aaw peroxide barrel, pump and contents, condition of pretreatment instruments including but not limited to sulfur acid, lint removal screens and pH meters, pH meter records to include strip, charts for the last 3 years, purchase documents regerding reagents, chemicals and instruments used on site including but not limited to receipts for the peroxide and pump, engineering logs, receipts/contracts for electrical contractor work, Reuse Water Make-Up Reports and other internal pretreatment documents, condition of valves, devices, instruments or other water controls at ALSCO, notices of pending inspections on handwritten notes and the company’s dry- erase board, employee records, central processing units, laptop or notebook computers, petipheral input/output devices such as keyboards, printers, scanners, plotters, monitors, and drives intended for removable media, related communications devices such as modems, cables and connections, electronic storage media such as hard disks, floppy disks, diskettes, compact discs, CD-ROMs, DVDs, optical dises, Zip cartridges, thumb drives, printer buffers, smart cards, or electronic notebooks, or any other storage medium, emails between Rod Baker, Rob Grubb, Paul Downard, Mark Inskeep, Daniel Bourbonais, Daniel Marlitt and Shaun Shatto for the past 3 yeats; contracts, agreements or emails between Rod Baker/ALSCO and Apex Labs, Rod Baker's cellular phone and texts for the past 3 years and any other evidence of the crimes of Unlawful ‘Water Pollution in the Second Degree, Supplying False Information to Ageney and Falsifying Business Records. Said evidence is currently located at the facility and premises of American Linen-Steiner Corporation (ALSCO) located at 1441 N. Columbia Boulevard, Portland, Multnomah County, OR 97217, and the person of Rod Baker. DESCRIPTION OF LOCATIONS TO BE SEARCHED “The facility and premises of American Linen- Steiner Corporation (ALSCO) located at 1441 N, Columbia Boulevard, Portland, Multnomah County, Oregon, 97015, is located on the ulBoe So & 19) north side of N. Columbia Boulevard, between Interstate 5 to the east and N. Interstate Place to the west, in Mulmomah County, OR, It is bordered to the east by the address of 1255 N. Columbia Boulevard and to the west by 1601 N. Columbia Boulevard. The property is accessed via @ paved driveway running north from N. Columbia Boulevard under the railroad grade; with a white sign at N, Columbia Boulevard with ALSCO painted oni ia green, The building itselfis surrounded by a chain link fence with a gate on the south side of the building facing N. Columbia Boulevard. ‘The business office is accessed via a public entrance on the south side of the building. ALSCO is a muhti-storied commercial structure. ‘The building is painted white, with green trim; and ALSCO is painted on the side of the building in green on the south, north and east sides. Rod (Rodney) Baker, date of birth 03/23/64, is a white male adult, with brown hair and blue eyes. He is approximately 230 pounds and 6 feet 2 inches tal respectfully request the court to authorize @ warrant to search, semple, seize, document and analyze said evidence. Ble cue, their CIRCUM COURT JUDGE AMY HOLMES HEHNNAPPENDIX A. SWORN AFFIDAVIT. I, Erie Martenson, being first duly swom, hereby depose and state as follows: INTRODUCTION AND AGENT BACKGROUND Tam a Special Agent with the United States Environmental Protection Agency (EPA) Criminal Investigation Division. Ihave been a Special Agent with the EPA Criminal Investigation Division (CID) since October of 2002. Prior to my employment with the EPA CID, I was an Active Duty Officer of the United States Coast Guard from 1997 until 2002. Tam 21997 graduate of the United States Coast Guard Academy in New London, CT, where I graduated with a B.S. in Government, I am also a 1998 graduate of the United States Coast Guard’s Maritime Law Enforcement Boarding Officer School. I am a graduate of the nine- ‘week Criminal Investigator Training Program and the nine week Environmental Investigation Basic Program held at the Federal Law Enforcement Training Center. During the course of my duties at EPA CID, | investigate those individuals and companies that commit egregious violations of environmental laws and regulations. | have also written affidavits for search ‘warrants and participated in search warrants in an effort to fitid évidence of criminal activities. 1 am currently employed as the Resident Agent in Charge for the EPA CID Resident Office in Portland, OR. HA i 2. Asa Special Agent for EPA CID, I am authorized to conduct investigations of alleged violations of federal environmental statutes, including the Federal Water Pollution Control Act, Title 33, United States Code, Section 1251 et seg., as amended, commonly referred to as the Clean Water Act (CWA), and other Federal laws including Title 18, United States Code, Section 1001 (False Statements), Title 18, United States Code, Section 1341 (Mail/Wire Fraud), and Title 18, United States Code, Section 371 (Conspiracy). 3. Thave been conducting an investigation into the illegal practice of adding chemicals to an industrial discharge, and otherwise adjusting an industrial discharge, which feeds into the City of Portland’s Bureau of Environmental Services (BES) sewer system. The practices are alleged to have occurred at a permitted discharge point in violation of a BES Page 1 of 23,issued CWA discharge permit to a large industrial laundry named American Linen — Steiner Corporation, also known as ALSCO. The ALSCO facility is located at 1441 N. Columbia Blvd, Portland, Oregon 97217. ALSCO hes a current wastewater discharge permit, No, 400.167, with, the City of Portland’s BES. 4 ‘The facts set forth in this affidavit are based on my personal knowledge, knowledge obtained during my participation in this investigation from other individuals, including other law enforcement officers, my review of documents and records related to this investigation, communications with others who have personal knowledge of the events and circumstances described herein, and information gained through my training and experience. Because this affidavit is submitted for the limited purpose of establishing probable cause in support of the application for a search warrant, it does not set forth each and every fact that I or others have learned during the course of this investigation. PURPOSE OF AFFIDAVIT This affidavit is made in support of an application for a search warrant to search, sample, seize, document, and analyze physical evidence at the facility and on the premises of American Linen - Steiner Corporation (ALSCO) located at 1441 North Columbia Blvd, Poriland, Multnomah County, Oregon. For the reasons contained herein, J have probable cause to believe there is evidence that ALSCO has knowingly violated the Clean Water Act by © discharging a non-representative effluent into the City of Portiand’s publically owned sewer system in violation of the BES issued discharge permit, in violation of 33 U.S.C. § 1319. CLEAN WATER ACT STATUTORY and REGULATORY FRAMEWORK 6. The Clean Water Act (CWA) was originally passed as the Federal Water Pollution Control Act, 33 U.S.C. §§ 1251 et seq. Itestablishes a regulatory control program to restore and maintain the chemical, physical, and biological integrity of the nation’s waters, The heart of the CWA is the total prohibition of all discharges of any pollutant from point sources, including pipes and ditches, into waters of the United States, unless permitted and within certain limits. 33 US.C. § 13110) Page 2 of 23,7. To meet the objective of the CWA, a pretreatment program was developed by EPA that regulates Industrial Users that discharge into Publicly Owned Treatment Works (POTWs). ‘The pretreatment program protects the operation of the POTW and prevents the discharge of pollutants which pass through or interfere with a POTW without receiving. adequate treatment. The federal regulations governing the CWA pretreatment program are codified at Title 40 of the Code of Federal Regulations (CFR), Part 403, These regulations «establish “general prohibition standards” (40 CFR § 403.5) and also include “specific prohibition standards.” 40 CFR § 403.5(b) (8), 8 The term “pretreatment” refers to the reduction, elimination, or alteration in the nature of the pollutant content of wastewater prior to the discharge of such wastewater to the POTW. 40 CFR § 403.3¢q). 9, The term “pollutants” is defined under the Act to include sewage, garbage, sewage sludge, chemical wastes, biological materials, and industrial, municipal and agricultural, waste, 33 U.S.C. § 1362(6). 10. The primary means for regulating the discharge of pollutants into waters of the United States is through the issuance of permits in accordance with the National Pollutant Discharge Elimination System (NPDES) by the Permitting Authority pursuant to 33 U.S.C. § 1342. A State can be the Permitting Authority if such State has a NPDES program approved by the BPA, 11. A Memorandum of Agreement (MOA) between EPA and the Oregon Department of Environmental Quality (DEQ) was approved September 26; 1973, to establish the state’s environmental agency. On March 2, 1979, EPA approved a modification of that Memorandum of Agreement (MOA) which transferred to DEQ the authority to regulate federal facilities under the NPDES program, In addition, there were two other modifications to the 1973 MOA: (1) DEQ received the pretreatment program authority on March 12, 1981; and (2) DEQ received the general permit program authority on February 23, 1982, On April 13, 2010, EPA's Region 10 Administrator signed the most recent MOA, replacing all other previous NPDES MOAs and MOA amendments between DEQ and EPA previously entered into, 12, NPDES permits are issued by the DEQ upon application and aeceptance of specific terms and conditions, such as wastewater effluent limitations, that are set forth in the pennits, Wastewater "effluent" is generally defined as the waters that are discharged from a Page 3 of 23sewage treatment plant after the in-flowing sewage, or “influent,” has been treated. NPDES permits typically establish limitations on the amounts and concentrations of pollutants that a person may discharge to the receiving waterway. Such permits also typically include requirements governing sampling and analysis of wastewater, reporting and record keeping. 13. One major source of water pollution comes from POTWs, which receive and treat wastewater generated by industrial, commercial and domestic facilities served by the POTW. In most cases, wastewater is introduced to a POTW through a collection (sewer) system. Afier treating the influent, a POTW discharges the effluent to a receiving waterway. Since the treatment process is not 100 percent complete, some water pollutants remain in the effluent. Therefore, like any other facility discharging effluent to a receiving waterway, the CWA requires that POTWs discharge wastewater only in accordance with the terms of an NPDES permit 14... A POTW’s ability to operate effectively (and, therefore, comply with its NPDES permit) depends in large measure upon the nature and quantity of the wastewater introduced fo the POTW. In particular, certain pollutants may: (A) be capable of evading treatment and thus move directly through the POTW and into the receiving waterway (a phenomenon known as pass-through”); or (B) disrupt the POTW’s treatment process, thereby causing other pollutants to be discharged to the receiving waterway without proper treatment (a phenomenon known as “interference” 15... In recognition of this fact, the CWA authorizes EPA to promulgate “pretreatment” standards feglating the introduction of pollutants to POTWs. 33 US.C§ 1317(b) and (c). These regulations are known as “pretreatment” regulations because they regulate wastewater prior to its eventual treatment at the POTW. EPA’s federal pretreatment regulations impose requirements on both POTWs and any “industrial user” (IU). The terms “industrial User” and “User” are identically defined to mean “a source of Indirect Discharge.” 40 CER § 403.3(h). The terms “Indirect Discharge” and “Discharge” are both defined to mean “the introduction of pollutants into the POTW from any non-domestic source regulated under Section [1317(b), (c) or (d)] of the [CWA]? that introduces pollutants to the POTW. 40 CFR $403.3(g), 16. BPA’s pretreatment regulations require that any POTW (or combination of POTWs opersied by the same authority) with a total design flow of greater than 5 million Page 4 of 23,gallons per day (“mgd”) and which receive from IUs pollutants that pass-through, interfere or are otherwise subject to categorical standards must establish a pretreatment program. 40 CFR § 403.8, 17, The POTW’s pretreatment program must be such that it provides the POT V with comprehensive regulatory powers to control the introduction of pollutants to the POTW. See 40 CER § 403.8( (setting forth required elements for POTW programs), POTWs most often achieve this control by enacting an enforceable sewer ordinance. However, POTWs are also required to issue permits (or some other individual control mechanism) to each “significant industrial user” (“STU”), 40 CFR § 403.8(1)(1)(i). The term “SIU” subject to categorical pretreatment standards and “[a}ny other industrial user that: (A) defined to, include all 1Us discharges an average of more than 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, non-contact cooling and boiler blowdown wastewater); (B) contributes 2 process waste stream which makes up 5 percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or (C) is designated as such oon the basis that the industrial user has @ reasonable potential for adversely affecting the POTW’s operation or for violating any pretreatment standard or requirement ...” 40 CFR § 403.3(0). 18. ‘The City of Portland’s BES is a unit of goverment in the State of Oregon that is responsible for safely and efficiently conveying and treating wastewater generated by industrial, ccommercial and residential sources located in the City of Portland, Oregon... Wastewater from. WESE SeWeid mio VE 1 the BES's POTW trentnieht plant and is subject to various treatment techniques, including the use of biological microorganisms that break down organic pollutants in the influent. ae 19, The CWA’s regulations (40 CFR § 403.8(0)(2)) requires Portland's sewage treatment plants operated by the BES (the Columbia Boulevard Wastewater Treatment Plant and the Tyron Creek Wastewater Treatment Plant) to have NPDES permits because the total design flow treated by the BES’s facilities combined is well in excess of 5 million gallons per day. 20, ‘The BES is authorized to discharge treated wastewaters in accordance with an NPDES Perit. The BES is required by the general pretreatment regulations to establish a federally-enforceable pretreatment program. See 40 CFR § 403.8(a). Per EPA regulations, BES Page 5 of 23developed a pretreatment program and submitted it to the DEQ, which has authority under the general pretreatment regulations to act es the “approval authority” for POTW pretreatment programs in the State of Oregon. The DEQ approved BES’s pretreatment program on March 3, 1983. 21. ‘The CWA provides that “[a}fter the effective date of any effluent standard or prohibition or pretreatment standard promulgsted under this section, it shall be unlawful for any ‘owner or operator of any source to operate any source in violation of any such effluent standard or prohibition or pretreatment standard,” 33 U.S.C. § 1317(d). Thus, any violation of a pretreatment standard is a violation of Section 1317 of the CWA. 22. BES’s approved program, the City of Portland’s Sanitary Discharge Ordinance (“Ordinance”), City Code Chapter 17.34, gives the BES direction and authority to administer Portland’s sanitary and combined sewer discharge regulations and the city’s Industrial Pre- ‘Treatment Permit Program. 23, The approved program, as required by 40 CFR § 403.8(f)(1)(ii), includes the authority to issue permits to TUs that require compliance with Federal, State and local standards. ‘These NPDES permits require the BES to manage discharges to the POTW. In 1982, Portland began permitting industrial users and requiring them to pretreat wastewater discharged to the sewer system, INVESTIGATION SUMMARY 24. On June 20, 2014, Wesley McDaniel, a Permit Manager in the Pollution Prevention Permit Section at BES told me he had met with a former ALSCO maintenance engineer named Paul Downard. MeDaniel said Downard had been instructed by his supervisor to add nydrogen peroxide to the effluent on days the BES sampled ALSCO’s wastewater and on days ALSCO sampled its own wastewater, MeDaniel showed me dated notes provided to hin by Downard instructing him to add hydrogen peroxide to the effluent stream and tum off the plant's water re-use system. 25. On August 14, 2014, McDaniel told me ALSCO elects to sample its own. ‘wastewater monthly, McDaniel told me the BES calculates a discharge risk analysis (DRA) for large industrial users including ALSCO. He said the BES determined that because ALSCO is Page 6 of 23an Extra Strength Industrial User that discharges approximately 70,000 gallons of wastewater daily to the POTW, its DRA requires monthly testing by the BES 26. On July 1, 2014, interviewed Downard. Downard told me he worked at ALSCO for approximately six and a half years as a maintenance engineer. Upon starting work at ALSCO, he worked for Dan Marlitt, ALSCO’s Chief Engineer. He said Marlitt showed him how to set up the hydrogen peroxide pump and turn off the water re-use system within the first month of his employment, Downard said Marlitt, and the engineers who worked for him, called the process “smoke and mirrors.” Downard said Marlitt retired a few years ago, but his replacement Rod Baker, continues to employ “smoke and mirrors” on sample days. Downard said Baker fired him in late May 2014 for installing a speaker wire and not admitting to it when asked. 27. On July 1, 2014, Tinterviewed Rob Grubb, another ALSCO engineer introduced tome by Downard. Grubb said he wanted to be interviewed because he thought highly of Paul Downard. Grubb is currently employed as a maintenance engineer at ALSCO: he has been employed by ALSCO in that same capacity for the last seven years. Grubb said he has been instructed to set up “smoke and mirrors” the entire duration of his employment by Chief Engineers Dan Marlit and Rod Baker. Grubb said the engineer setting up “smoke and misrors” has to ensuze the hydrogen peroxide pump is on and the ALSCO’s water re-use system is off Grabb said Marlit gave the instructions vie a hand-written note. He said Baker gives the signal tosetup “smoke and mirrors” by writing what day a. wastewater test will be on a dry.erase board: Grubb estimates he sét up “smoke and mirvors” at least 20 times during’his*eniployment at ALSCO 28, interviewed Grubb and Downard separately on July 1, 2014. Both engineers told me the same process for setting up “smoke and mirrors” at ALSCO on BES test days, Which was described as follows: a. The BES arrives in « marked vehicle during daylight hours to install a sampling device in a manhole in the parking lot in front of ALSCO. Per the instruetion of the Chief Engineer, one of the desk workers in the front office contacts the Chief Engineer to tell him the BES is on site upon sighting the vehicle. Page 7 of 2329) Upon receiving the notice from the front office worker(s), the Chief Engineer tells the engineers that a wastewater test is being conducted the next day by writing a note or by announcing the test on a dry erase board. ‘The engineer who sets up “smoke and mirrors” turns off the water re-use system typically employed by ALSCO on a non-test day; this step involves the turning of some valves. The engineer also has to turn on a small pump which carries hydrogen peroxide from a plastic barrel in “wash alley” and deposits it in a trough in the floor that carries the wastewater out of the facility to the POTW. ‘The Chief Engineer also alerts the Production Manager and/or the Assistant Production Manager that the BES is testing wastewater. This notification to Production Manager and/or the Assistant Production Manager cues the Production, side of ALSCO to limit the washing of shop rags on a test day because such rags are contaminated with oils and greases which is.a pollutant being sampled for on test day. ‘The day after the BES wastewater test, the engineer has to turn back on the water re-use system, The engineer also has to tum off the pump at the hydrogen peroxide barrel. The Production side of ALSCO no longer limits its shop rag washing. ‘Both Grubb and Downard told me the “smoke and mirrors” process differs-on days when ALSCO samples its own wastewater'as a condition of its permit. This process.was. a, described as follows: The Chief Engineer decides when ALSCO will sample its own wastewater and communicates that day to the engineers via a written note on the dry erase board. ‘The Chief Engineer then communicates the day of ALSCO’s self-test to the Production Side of ALSCO. On ALSCO’s self-test day, the assigned engineer turns off ALSCO’s water reuse system and tums on the hydrogen peroxide pump while the Production Side fimits the washing of shop rags. The day afier ALSCO’s self-test day, the assigned engineer tums ALSCO’s water reuse system back on and tums off the hydrogen peroxide pump. The Production Side no longer limits its washing of shop rags. Page 8 of 23,30. Grubb took a picture of the barrel of hydrogen peroxide set up on May 22, 2014, as part of “smoke and mirrors” at ALSCO and provided it to me on July 1, 2014. Grubb said this picture accurately depicts where the barrel is kept at ALSCO, namely in the room known as the “wash alley.” ‘The silver-colored device mounted to the yellow rail above the barrel is the pump and the rectangular hole in the floor provides aceess to the trough carrying the wastewater. 31. On July 1, 2014, Grubb provided me with other pictures he took on May 22, 2014, of the black barrel shown above. One picture shows a white rectangular label on top of the drum identifying the contents as peroxide while another picture identifies the source of the barrel as a chemical supply company named Univar in Portland, Oregon, 32. On July 1, 2014, Grubb told me Baker bought the pump mounted in the photo to replace a broken pump unit. Grubb said the pump mounted in the photo works by a 110 elecirical circuit and it plugs into a line coming down from the ceiling Page 9 of 23,33. On July 1, 2014, Downard told me ALSCO hired an electrical contractor to install the electrical line the pump is plugged into. He said ALSCO maintains engineering log books reflecting work such as this. He said the log books were maintained in the Chief Engineer’s office during his employment at ALSCO. 34. On July 1, 2014, Downard told me the Chief Engineer, Rod Baker, arranged the purchases of the hydrogen peroxide for delivery to ALSCO while he worked there, Downard told me Dan Marlitt used to order the hydrogen peroxide for delivery to ALSCO prior to being relieved by Baker 35. On July 1, 2014, Grubb told,me he assumes the hydrogen peroxide is currently bought by Rod Beker and that Dan Marlitt bought the hydrogen peroxide used at ALSCO. during his tenure as Chief Engineer. 36. On July 1, 2014, Grubb told me he kept some of the notes given to him by Dan Marlitt and provided them to Downard before Downard met with BES. | showed Grubb some. of the notes including this one below. He confirmed they were the ones he kept. LAE 37, In addition to the notes he provided to Downard, Grubb supplied him with a REUSE WATER MAKE-UP REPORT from 2011 that was then given to me by the BES. According to the report from January 2011, the highest water usage day was January 5, 2011 The second highest reading is from January 25, 2011 (consistent with the above note.) Ihave Page 10 of 23,another note from Grubb dated January 5, 2011, indicating the water re-use be turned off on January 5, 2011 38. John Holtrop, an Environmental Specialist in the BES Extra Strength Sewer Charge Program told me that turning off the water re-use system at ALSCO as part of “smoke and mirrors” would result in high water usage by ALSCO on those days that “smoke and mirrors” is employed at the facility. As part of a sampling event conducted by the BES in March 2014, more fully explained later in this affidavit, Holtrop provided me with evidence that ALSCO’s water usage went up on the day BES tested ALSC( 39. "s effluent in March 2014. Grubb has provided me with pictures he took of the dry erase board outside the boiler room near “wash alley” where the engineers are told when the wastewater test days are so they can set up “smoke and mirrors.” Grubb sent me pictures of the dry erase board taken on Page 11 of 23June 3, June 4, July 9, July 29, August 4, August 20, and September 9, 2014, which all indicated the next test day at ALSCO. The picture of the dry erase board below was taken on June 4, 2014: 40. Grubb sent me videos of the pump sending hydrogen peroxide from the barrel to the hole in “wash alley” via email on July 29, August 10, August 21, and September. 10,2014. ‘When I talked to Grubb about the videos he sent to me, he confirmed he took the videos on days when either ALSCO or BES was taking samples of ALSCO’s effluent for testing, 41 Downard told me the Chief Engineer tells the Production Manager and Assistant Production Manager, Mark Inskeep and Shaun Shatto respectively, when test days are so the Production Side knows to limit, or not wash at all, the amount of shop rags laundered on test Gays, Downard told me the shop rags are generally dirtier and more contaminated with chemicals, oils, and greases, than other laundry being washed at ALSCO. 42. Downard said fore Dan Marlitt retired from ALSCO, he would post notes for the Production Managers similar to what he would give to the engineers. Downard said the new Chief Engineer, Rod Baker, uses emails to tell the Production Managers when the wastewater Page 12 of 23,test days are. Downard sent me a picture of a text exchange he had with Assistant Production Manager Shaun Shatto on July 7, 2014, as proof that Rod Baker emails the Production Managers to alert them when test days are. 43. On September 18, 2014, Downard told me Shaun Shatto told him on September 16, 2014, that he had received another email from Baker regarding a waste water test day. Downard told me be routinely saw Shatto working on a computer inside the Production Office while he worked at ALSCO. Downard said he routinely saw Mark Inskeep working on‘another computer inside the Production Office alongside Shatio, Downard said Shatto shared the ‘Pioduetioh Office with Mark Inskeep. He Said the Podiiction Office is or the ‘first floor of the ALSCO facility. Downard said he indicated the location of the Production Office on a map of the facility he drew for me on July 1, 2014. The map is attached to this affidavit 44. Dowmard said the Chief Enginecr’s Office is located upstairs near the west side of the building. During his time at ALSCO, Downard routinely saw Rod Baker working on a computer in the office, He said Dan Marlitt routinely worked on a computer in that office when he was ALSCO’s Chief Engineer; he added that during Marlitt’s time as Chief Engineer, two computers were used in the office. 45. Wes McDaniel at BES provided me with emails sent to him by Rod Baker. One email, dated June 24, 2014, was sent from email address rhaker(@alsco.com. The email itself included a signature block indicating it was sent from Rod Baker, Chief Engineer, ALSCO, Page 13 of 23,