STORM WATER POLLUTION PREVENTION PROGRAM (SWPPP) STORMWATER MONITORING PLAN (SMP) FACILITY INFORMATION TABLES CADG SMP REPORT FORMS APPENDICES

Transcription

1 STORM WATER POLLUTION PREVENTION PROGRAM (SWPPP) STORMWATER MONITORING PLAN (SMP) FACILITY INFORMATION TABLES CADG SMP REPORT FORMS APPENDICES

2 THE CALIFORNIA AUTO DISMANTLERS GROUP (CADG) STORMWATER MANAGEMENT PROGRAM (SMP)

3 CADG SMP TABLE OF CONTENTS 1.0 STORM WATER POLLUTION PREVENTION PLAN... Section 1: Page Regulatory Background... Section 1: Page Overview... Section 1: Page Storm Water Pollution Prevention Plan Objectives... Section 1: Page Pollution Prevention Team... Section 1: Page Pollution Source Identification and Assessment... Section 1: Page Facility Description and Operations Review... Section 1: Page Materials Inventory... Section 1: Page Dust and Particulate Generating Activities... Section 1: Page Site Drainage and Surface Conditions... Section 1: Page Significant Spills and Non-Stormwater Discharges.. Section 1: Page Assessment Summary... Section 1: Page Draining Automotive Fluids... Section 1: Page Dismantling of Vehicles and automotive Parts... Section 1: Page Storing Auto Parts and Auto Bodies... Section 1: Page Shipping and Receiving... Section 1: Page - 14 Table 7: Pollutants and Pollutant Sources... Section 1: Page Best Management Practices... Section 1: Page Operating Activities... Section 1: Page Facilities Maintenance and Housekeeping Practices Section 1: Page Spill Prevention and Response... Section 1: Page Employee Training... Section 1: Page Sediment and Erosion Control:... Section 1: Page Operation Specific BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page CADG SMP Baseline BMPs... Section 1: Page - 33 Table Of Contents - Page - 1

4 1.7.8 CADG SMP Baseline BMPs... Section 1: Page Reporting and Record Keeping Requirements... Section 1: Page Weekly Facility Inspections... Section 1: Page Annual Comprehensive Site Compliance Evaluation (ACSCE)... Section 1: Page CADG SMP Assistance... Section 1: Page Annual Report... Section 1: Page SMP Revisions... Section 1: Page Reporting Requirements... Section 1: Page Record Keeping... Section 1: Page STORM WATER MONITORING PLAN... Section 2: Page Storm Water Monitoring Plan Objectives... Section 2: Page Identify/Implement of Baseline and Site-Specific BMPs Section 2: Page Weekly Facility Inspections Reports... Section 2: Page Monthly Wet and Dry Condition Observation Reports. Section 2: Page Sampling and Testing of Stormwater Run-Off... Section 2: Page Monthly Wet and Dry Condition Observations... Section 2: Page Wet Condition Observation Requirements... Section 2: Page Non-Stormwater Discharge Observe Requirement... Section 2: Page Monthly Rain Activity Report... Section 2: Page CADG SMP Sample Plan... Section 2: Page Sampling and Analysis Protocol... Section 2: Page Sampling and Reporting Responsibilities... Section 2: Page - 8 SECTION 3: TABLE OF CONTENTS Report 1: General Facility Information...Section 3 Report 2: General Operational and Pollution Prevention Plan Team Information...Section 3 Report 3: Off-Site Stormwater Discharge Information...Section 3 Report 4: Stormwater Run-On Information...Section 3 Report 5: Non-Stormwater Discharge Information...Section 3 Report 6: Operational Activities, Locations and Management Practices...Section 3 Report 7: Vehicle and Parts Storage Practices Information...Section 3 Report 8: Materials Inventory Storage Practices...Section 3 Table Of Contents - Page - 2

5 SECTION 4: TABLE OF CONTENTS Weekly Facility Inspection Report (2 Pages).... Section 4 Wet Condition Observation Report Section 4 Non-Stormwater Discharge Observation Report Section 4 Monthly Rain Activity Report Section 4 Table B: Discharge Inspection Log Section 4 SECTION 5: TABLE OF CONTENTS Appendix 1: Facility Maps and Figures Section 5 Appendix 2: WDID (NOI) Application and Number Confirmation Section 5 Appendix 3: CADG SMP Sample Plan Section 5 Appendix 4: BMP Specifications and Diagrams Section 5 Appendix 5: Annual Reports Section 5 Appendix 6: CADG SMP BMP(s) Employee Training Log Section 5 Appendix 7: General Permit Section 5 Appendix 8: CADG SMP Instructions and Correspondence...Section 5 Appendix 9: SWPPP Amendment Summary Report Section 5 Appendix 10: Certifications Section 5 Table Of Contents - Page - 3

6 ACRONYM GLOSSARY ABH... After Business Hours BBH... Before Business Hours BMP(s)...Best Management Practice(s) BOD...Biochemical Oxygen Demand CADG... California Auto Dismantlers Group COD...Chemical Oxygen Demand ACSCE... Annual Comprehensive Site Compliance Evaluation CWA... Clean Water Act DMV... Department of Motor Vehicles EAP...Emergency Action Plan ECMS... Environmental Compliance Management Services GENERAL PERMIT...General Industrial Storm Water Permit HMMP... Hazardous Materials Management Procedures IIPP...Injury and Illness Prevention Plan NOI... Notice of Intent NOT... Notice of Termination NPDES... National Pollution Discharge Elimination System NSD...Non-Stormwater Discharge QC... Quality Control S/C...Specific Conductance SMP...Stormwater Monitoring Program SWPPP...Storm Water Pollution Prevention Plan SWPPT...Storm Water Pollution Prevention Team SWRCB... State Water Resources Control Board TDS...Total Dissolved Solids TOC... Total Organic Carbon TRPH... Total Recoverable Petroleum Hydrocarbons TSS... Total Suspended Solids USEPA...US Environmental Protection Agency WDID... Waste Discharge Identification (I.D.) Acronym Glossary - Page - 1

7 1.0 STORM WATER POLLUTION PREVENTION PLAN 1.1 Regulatory Background A 1972 amendment to the federal Clean Water Act (CWA) prohibited the discharge of pollutants to the waters of the United States from any point source, including pollutants from stormwater run-off, unless the discharge was specifically permitted in accordance with the National Pollution Discharge Elimination System (NPDES) program. In November 1990, the US Environmental Protection Agency (USEPA) promulgated final regulations which established application requirements for stormwater discharge permits. These regulations require industrial facilities which discharge stormwater run-off into surface waters, either directly or indirectly via a stormwater conveyance system (i.e., storm sewer), to obtain an NPDES discharge permit sanctioning the stormwater discharge. The regulations allowed authorized states to issue general or individual NPDES permits. In response to the new stormwater permit requirements, in December 1991, the California State Water Resources Control Board, the state agency responsible for the administration and enforcement of the NPDES program within the state, issued California's General Industrial Storm Water Permit (GENERAL PERMIT). The GENERAL PERMIT applies to the majority of industrial facilities which discharge stormwater run-off to surface waters. In April, 1997 the State Water Resources Control Board revised and reissued the GENERAL PERMIT. 1.2 Overview The GENERAL PERMIT requires dischargers to do the following: < Eliminate non-stormwater discharges to storm drains, including illicit connections by October 1, 1992; < Develop and implement a Storm Water Pollution Prevention Plan (SWPPP) by October 1, 1992; and < Effective January 1, 1993 monitor and test the facility's stormwater discharges. CADG SMP Manual Section 1: Page - 1

8 There are four major components to the GENERAL PERMIT which dischargers must comply with: 1. Preparation and submittal of the Permit's Notice of Intent (NOI also referred to as a WDID) Application. Submittal of the NOI (WDID) application formally notifies the Water Board of the facility's intent to comply with the GENERAL PERMIT. 2. Documentation of the development and implementation of the facility's Storm Water Pollution Prevention Plan (SWPPP). While this document is considered a public report and must be made available to public agencies upon request, there is no requirement to submit it to the Water Board for approval prior to implementation; 3. Documentation of the development and implementation of the facility's Storm Water Monitoring Plan. Like the SWPPP, the Monitoring Plan is a public document and must be made available to the public upon request, but does not need to be submitted to the Water Board for approval prior to implementation; and 4. Conduct and document an Annual Comprehensive Site Compliance Inspection and submit to the Regional Water Quality Control Board an Annual Storm Water Report By July 1 of each year. The purpose of the Annual Inspection and Report is to evaluate the effectiveness of the facility's stormwater pollution prevention efforts and to certify the facility's compliance with the requirements of the GENERAL PERMIT. California's GENERAL PERMIT allows industrial facilities with like or similar operational activities to participate in a group stormwater monitoring program. Participation in an approved group monitoring program reduces the level of stormwater sampling and analysis that each participant would otherwise be required to accomplish over the course of the permit period. In 1992, on behalf of California's automobile dismantling and parts recycling industries, and in response to the GENERAL PERMIT, Environmental Compliance Management Services (ECMS) formed and established the California Auto Dismantlers Group Stormwater Monitoring Program (CADG SMP). CADG SMP Manual Section 1: Page - 2

9 This document describes and establishes the California Auto Dismantlers Stormwater Management Program (SMP) 1 in general and the Facility s Stormwater Pollution Prevention and Monitoring Program Specifically. This document has been developed on behalf of the CADG SMP participating membership. Participation and compliance with the requirements of the CADG SMP is an integral part of this facility s ongoing compliance with the GENERAL PERMIT. Compliance with the terms and conditions of this document is required to participate in ECMS' CADG SMP. This participating facility applied for, and was approved for, permit coverage under the GENERAL PERMIT effective. This facility has been an active member of the CADG SMP since. 1.3 Storm Water Pollution Prevention Plan Objectives All dischargers must develop, retain on site and implement a Storm Water Pollution Prevention Plan (SWPPP) which emphasizes Best Management Practices (BMPs). The goal of the SWPPP is to improve water quality by reducing the pollutants contained in stormwater discharges. The SWPPP must be prepared in accordance with good engineering practices. The SWPPP identifies the sources of pollution at the facility and describes the measures that will be implemented to prevent or control the discharge of pollutants into stormwater run-off. A SWPPP has two major objectives: Objective One: To help identify the sources of pollution from industrial activities which impact the quality of stormwater discharges; and Objective Two: To describe and ensure the implementation of practices to reduce pollutants in stormwater discharges associated with industrial activities. 1 This document, its format, forms and content is the property of ECM Services and may not be used by any third party without the express permission of ECM Services. Use of this document, its forms and content is limited to active participants of the CADG SMP. CADG SMP Manual Section 1: Page - 3

10 The required elements of the SWPPP are: < Source Identification; < Practices to Reduce Pollutants; < Assessment of Potential Pollution Sources; < A Materials Inventory; < A Preventive Maintenance Plan; < Spill Prevention and Response Procedures; < General Stormwater Management Practices; < Employee Training; < Facility Inspections; < Record Keeping; and < Elimination of Unpermitted Non-stormwater Discharges. The development of a SWPPP involves four steps: Step One: Formation of a team of qualified facility personnel who will be responsible for preparing the SWPPP and assisting the SMP Coordinator in the implementation of the site's overall SMP; Step Two: Assessment of potential stormwater pollution sources; Step Three: Selection and implementation of appropriate best management practices and controls; and CADG SMP Manual Section 1: Page - 4

11 Step Four: Periodic evaluation of the SWPPP's effectiveness in preventing or reducing stormwater pollution and the facility's compliance with the terms and conditions of the permit. Best Management Practices (BMPs) are schedules of activities, prohibitions, operational and maintenance practices and other management practices which are expressly designed to reduce and eliminate the pollution of the waters of the United States, including stormwater run-off. There are two general categories of BMPs: First Category: Operational and Administrative (i.e, Non-Structural) Controls which are designed to minimize and eliminate stormwater exposure to the source of potential pollutants. Second Category: Structural Controls which are engineered systems designed to remove pollutants from stormwater run-off and/or reduce the volume of stormwater which is discharged off-site. This section describes and establishes this facility's Storm Water Pollution Prevention Plan (SWPPP) in accordance with the requirements of the GENERAL PERMIT. While the SWPPP's BMPs emphasizes source controls in minimizing stormwater pollution, facility personnel, through participation in the CADG SMP, will identify and implement structural controls when source controls prove to be ineffective in controlling stormwater pollution at the site. 1.4 Pollution Prevention Team The first step in developing the SWPPP is to identify individuals within the facility's organization who will be members of the facility s Storm Water Pollution Prevention Team (SWPPT). The SWPPT is made up of key on-site personnel who are familiar with the facility and its operations. The SWPPT is comprised of representatives from all phases of the facility's operations. It includes personnel from management, operations, waste material handling, maintenance, and shipping and receiving. CADG SMP Manual Section 1: Page - 5

12 The SWPPT is responsible for developing the SWPPP and assisting in its implementation, maintenance, and revision. The SWPPT provides structure and direction to the facility's stormwater management program. It also provides a point of contact for other facility personnel and regulatory officials to discuss specific aspects of the site s SWPPP. Organization and management of the site's SWPPT is the responsibility of the site's SMP Coordinator. The SMP Coordinator is responsible for insuring and certifying on the Annual Report that the site is in compliance with the GENERAL PERMIT and the CADG SMP requirements. This person must be an owner/operator of the business, or representative of the owner/operator, who has the authority to make resources (i.e, personnel, equipment and funds) available to insure that the site complies with the GENERAL PERMIT and the CADG SMP requirements. The SWPPT has been formed for this facility and is responsible for the following: < Implementing GENERAL PERMIT, CADG SMP and SWPPP requirements; < Defining and agreeing upon an appropriate set of goals for the facility's stormwater management program; < Being aware of changes that are made in facility operations and determining whether any changes must be made to the facility's stormwater management and pollution prevention efforts; < Maintaining a clear line of communication with, and between, management and operations to ensure a cooperative partnership; < Overseeing routine materials inventory and recommending ways to reduce or eliminate the use of hazardous materials and generation of wastes; < Implementing and overseeing employee training and the SWPPP/CADG SMP inspection programs; CADG SMP Manual Section 1: Page - 6

13 < Identifying potential pollutant sources and recommending ways to alleviate problem areas through changes in operations, equipment, layout, and materials; < Coordinating the implementation of best management practices, reviewing the effectiveness of both the SWPPP and CADG SMP and updating the SWPPP as needed; and < Reporting the results, and problems when encountered, to the appropriate agencies and organizations. The Storm Water Pollution Prevention Team (Section 3) identifies this facility personnel who have been assigned to the SWPPT, along with their responsibilities. A copy of this roster shall be posted at the facility so that other facility employees are aware of who is responsible for stormwater management. If site personnel notice potential sources of pollutants or have suggestions to help reduce stormwater pollution, they should notify the appropriate team member. Active participation of all site personnel in helping to identify and eliminate potential stormwater pollution sources is vital to the success of the facility's stormwater management efforts. 1.5 Pollution Source Identification and Assessment The second step in the development of a SWPPP is to identify and assess potential sources at the site which may reasonably be expected to contribute significant amounts of pollutants to stormwater discharges including discharges of pollutants from nonstormwater sources. The potential sources of stormwater pollution are identified by conducting a materials inventory, evaluating past spills and leaks, identifying any non-stormwater discharges and/or illicit connections to the site's stormwater conveyances, and evaluating existing stormwater quality data. This assessment provides a risk-based approach by assisting in targeting the most important pollutant sources for corrective and/or preventive action. CADG SMP Manual Section 1: Page - 7

14 A description of the site (Section 3) and a site map (Section 5) were prepared based on information obtained from the review of site documents and the site reconnaissance conducted by the site s SWPPT. Potential pollutant sources identified at the site, and possible routes of stormwater exposure to the identified pollutant sources, are summarized with the following: Facility Description and Operations Review The facility's operational practices consists of vehicle dismantling and recycling activities (SIC 5015). Industrial activities typical of this type of facility include the following: < Draining Automotive Fluids (e.g., Oils, Antifreeze, Fuels, Freon, Etc.): Standard practice is to drain the automotive fluids (i.e., motor oils, antifreeze, transmission fluids, windshield washer fluids and freon) from the automotive parts prior to dismantling or storage. Routine fluid removal is conducted at the facility s Vehicle Processing Area (reference the facility s site map). Fluid draining and removal is accomplished either by gravity flow or vacuum evacuation of the fluid reservoir. Residual fluids are intentionally left in the automotive part to provide sufficient lubrication and protection against corrosion and seizing of internal components. Because the majority of the vehicles received at the site are damaged to some extent, there is no standard volume of fluids recovered per vehicle. Refer to Section 3 for a listing of the number of vehicles processed at the site on an annual basis and the quantities of fluids and wastes generated. < Dismantling Automobiles for Resale, for Reuse, or for Scrap: Standard practice at the site is to routinely remove engines, transmissions, radiators, batteries, rear ends, manifolds and gear boxes, while the vehicle is the Processing Area. Tires designated for resale are removed and stored outside in racks and/or stacked on the ground. Tires designated as waste tires are stored onsite until shipped for offsite recycling or disposal. CADG SMP Manual Section 1: Page - 8

15 Sheet metal parts (i.e., doors, hoods, bumpers, windshields, mirrors, seats, etc.) are typically left on the vehicle, and stored with the vehicle body in the site s vehicle storage area (see site map), until the part is either sold or until the vehicle is prepared for shipment offsite for scrap metal recovery. Sheet metal parts (i.e., non-fluid bearing parts) are removed from the vehicle either at the Processing Area, in the vehicle storage area, or for vehicles being prepared for offsite shipment, in either the site s two staging areas. < Storing Auto Parts and/or Auto Bodies for Resale, for Reuse, or for Scrap: Preprocessed vehicles are typically received and staged in the site s vehicle holding area (see site map) until processed (i.e., drained and dismantled). Once a vehicle has been processed, it is then moved to the site s vehicle storage area (see site map), where the vehicle is staged up, off the ground on welded tire rims, tires, blocks or in racks. Typically, dismantled and drained automotive parts are stored inside or outside off the ground and undercover (see site map). Batteries are inspected at the time of removal. Damaged batteries that may leak battery acids are stored in the site s designated hazardous waste storage area until shipped offsite for recycling or disposal. Batteries which are not damaged and that will be sold to a battery reclaimer are stored inside or outside, off the ground and undercover (see site map). Processed vehicle bodies that will not be retained onsite in the facility designated storage areas, and previously stored processed vehicle bodies being prepared for offsite shipment, will be temporality staged at the site s Vehicle Staging/Shipping and Receiving (see site map). Vehicles bodies being staged for offsite shipment typically are shipped within 15 working days of being staged. < Crushing Automobile Bodies and Shells for Transport and Sale for Scrap Metal Recovery (Sic 5093): Vehicles may either crushed onsite at the facility s designated crush area (see site map) by site personnel or the facility will contract to have the vehicles crushed onsite prior to shipment offsite for scrap metal recovery. CADG SMP Manual Section 1: Page - 9

16 < Shipping and Receiving: Shipping and receiving activities are limited to receipt of preprocessed vehicles; scraped auto-bodies and auto parts being shipped offsite for metal recovery; pick-up and shipment offsite of wastes for recycling or disposal; and customer pick-up and/or shipment of purchased parts. Vehicle and parts shipping and receiving activities are limited to the areas identified on the facility s site map. Waste materials are loaded onto the Waste Hauler s vehicle at the point of generation and storage. Automotive waste fluids are pumped from the site s storage tanks and drums into tanker trucks permitted to transport waste automotive fluids. Section 3 Reports describes this facility's general operating practices and locations, operational management practices, facility's storage practices Materials Inventory Section 3; Materials Inventory, lists the types and quantities of significant materials routinely handled at the facility which may pose a potential threat to the site's stormwater discharge. Automotive waste fluids are stored in above ground storage tanks located undercover and on a concrete pad. Section 3 summarizes the facility's management practice for each listed material. Spill clean-up supplies are maintained throughout the facility where automotive fluids are handled or stored. At a minimum, the following spill clean-up supplies are maintained onsite: < Dry absorbent (i.e. Kitty Litter or clay absorbent); < Brooms, shovels for sweeping and picking up contaminated absorbents; < Clean rags for wiping up residual spilled fluids; and < Container with secured lid for storing collected contaminated absorbent until disposal. CADG SMP Manual Section 1: Page - 10

17 Spills are routinely cleaned upon discovery, using dry techniques. The collected contaminated absorbent and rags are stored in a can or drum, equipped with a secured lid, until the used absorbent or dirty rags can be shipped offsite for disposal or recycling for reuse Dust and Particulate Generating Activities The site does not engage in any activity which results in a point source discharge (i.e., emission stack ) of dust or particulates. The facility does not engage in any activity which is regulated by, or requires a permit issued by, local Air Quality Control Board. The potential sources of dust and particulate at the site are incidental to the site s industrial activities and fugitive in nature. As such, it is not practical to quantify these potential sources. Potential sources of fugitive dusts and particulate at the auto dismantling facility include dirt and debris transported onsite with the receipt of the pre-processed vehicles; dirt and debris that is transported onsite from transport and shipping trucks, customer vehicles and employee vehicles; and dust, particulates and debris that is deposited onsite from offsite sources by wind dispersion. The types of dust, debris and particulate include dirt; rust from corroded metallic parts; paint chips and flakes from corroded painted surfaces; metal chips and flakes from plated metal surfaces (i.e., chromium and aluminum); glass chips from windows and mirrors; plastic chips from trimming and molding, wiring and tubing; and poly foam particulates from seat cushions and linings Site Drainage and Surface Conditions Section 3 describes the site's physical conditions (i.e, size, percent impervious surfaces, etc.). In this section the site's stormwater discharge point, as well as the drainage areas and operational areas associated with each discharge location are described. CADG SMP Manual Section 1: Page - 11

18 Section 3 describes the locations at the site where stormwater runs onto the site from offsite sources and the site's approved non-stormwater discharges Significant Spills and Non-Stormwater Discharges There have been no significant spills and/or leaks at the site since the facility started operations at its present location. Significant spills considered included, but are not limited to, releases of oil or hazardous substances in excess of reportable quantities. This facility does not discharge unpermitted non-storm waters to the facility's stormwater drainage system. All discharges to the site's stormwater/surface drainage system are permitted in accordance with the GENERAL PERMIT Assessment Summary Based on the findings of facility SWPPT s site inspection and operational review, and knowledge regarding auto dismantling practices obtained through participation in the CADG SMP, the following industrial activities, and their associated pollutants, would reasonable be expected to impact the quality of the site s stormwater discharges: Draining Automotive Fluids: Standard practice at the auto dismantling facility is to drain the automotive fluids (i.e., motor oils, antifreeze, transmission fluids, windshield washer fluids and freon) from the automotive parts prior to dismantling or storage. Routine fluid removal is conducted at the facility s Vehicle Processing Area (see site map). Potential routes of stormwater exposure are limited to surface drainage coming in contact with the dismantling pad. Potential pollutants and their sources include the following: < Oil and grease stains on the concrete dismantling pad; and < Automotive fluids ( oils, fuel, etc) spills or leaks to the dismantling pad and surrounding areas. CADG SMP Manual Section 1: Page - 12

19 Dismantling of Vehicles and Automotive Parts: Typically, the resalable/repairable automotive parts are removed at the same time that the vehicles are drained. Standard practice is to routinely remove engines, transmissions, radiators, batteries, rear ends, manifolds and gear boxes prior to storage, while the vehicle is the Processing Area. Potential routes of stormwater exposure are limited to surface drainage coming in contact with the following work areas: < The dismantling pad; < Parts staged on the dismantling pad waiting to be moved to the designated storage areas; and < Stained concrete in the main yard from spills or leaks during transport of parts to and from the designated storage areas; Potential pollutants and their sources include oil and grease stains on the concrete dismantling and in the main yard areas Storing Auto Parts And Auto Bodies: Once a vehicle has been processed (dismantled and/or drained), it is then moved to the site s vehicle storage area (see site map), where the vehicle is staged up, off the ground. Typically, dismantled and drained automotive parts are stored inside a buildings or structure or outside, off the ground and undercover. Sheet metal parts are typically stored either inside, undercover or outside, off the ground. Tires are either stored outside in racks, or stacked on the ground. Potential routes of stormwater exposure are limited to rainfall coming in contact with auto bodies and processed auto parts. Potential pollutants and their sources include the following: < Dirt; rust from corroded metallic parts; paint chips and flakes from corroded painted CADG SMP Manual Section 1: Page - 13

20 surfaces; metal chips and flakes from plated metal surfaces (i.e., chromium and aluminum); glass chips from windows and mirrors; plastic chips from trimming and molding, wiring and tubing; and poly foam particulates from seat cushions and linings; and < Dried, harden oil and chemical residues (i.e, residual lubricating greases on door joints, dried antifreeze residues, etc) Shipping and Receiving: Shipping and receiving activities are limited to receipt of pre-processed vehicles; scraped auto-bodies and auto parts being shipped offsite for metal recovery; pick-up and shipment offsite of wastes; and customer pick-up and/or shipment of purchased parts. Potential routes of stormwater exposure are limited to the following: < Rainfall coming in contact with auto bodies and processed auto parts; and < Stained concrete and bare ground in the main yard from spills or leaks from vehicles being staged for processing or shipment. Potential pollutants and their sources include the following: < Dirt; rust from corroded metallic parts; paint chips and flakes from corroded painted surfaces; metal chips and flakes from plated metal surfaces (i.e., chromium and aluminum); glass chips from windows and mirrors; plastic chips from trimming and molding, wiring and tubing; and poly foam particulates from seat cushions and linings; and < Automotive fluids ( oils, fuel, etc) from spills or leaks from vehicles being staged in the site s shipping and receiving areas. A summary of the site's Potential Stormwater Pollutants and their sources are summarized in Table 7 on the following page: CADG SMP Manual Section 1: Page - 14

21 TABLE 7 POLLUTANTS AND POLLUTANT SOURCES ACTIVITY/OPERATION POLLUTANT SOURCE Fluid Draining Vehicle Dismantling and Crushing Parts and/or Vehicle Storage Parts Washing and/or Cleaning Shipping and Receiving Hazardous Materials and/or Waste Management Equipment and/or Site Maintenance Oil & Grease, Petroleum Fuel Hydrocarbons, Ethylene Glycol Oil & Grease, Metals, Suspended Solids, Acids, Dissolved Solids Oil & Grease, Ethylene Glycol, TSS, TDS, Metals Halogenated Organic Compounds, Detergents (Acidic/alkaline), TSS, TDS, COD, Metals, Oil & Grease, Inorganic Salts TSS, BOD, Oils, Greases, Detergents, Metals, TDS, COD Oils, Greases, Petroleum Fuel Hydrocarbons, Ethylene Glycol, Halogenated Hydrocarbons, Detergents, Acids, Metals TSS, BOD, Oils, Greases, Detergents, Metals, TDS, COD Motor Oils & Fluids, Fuels, Antifreeze Batteries, Corroded / Chipped Metallic Parts, Filters, Tires & Rims, Engine Blocks, Drive Lines, Mufflers Leaking Engines / Transmissions / Brake Lines / Radiators, Chipped & Corroded Metallic Parts & Painted Surfaces Solvent Cleaning and Waterbased Washing or Oily / Dirty / Corroded Parts Dirt / Dust, Vegetation, Wash Downs of Work Areas, Motor Oils from leaks, Debris (Metal, Glass & Plastic Chips) from Corroded Auto Bodies & Parts Use / Generation / Handling & Storage of Motor Oils & Fluids, Fuels, Solvents, Detergents / Cleaners, Waste Waters, Antifreeze Dirt / Dust, Vegetation, Vehicle Washing, Waste Disposal (Oily Rags, Filters), Oil & Grease, Fuels, Wash Downs of Work Areas CADG SMP Manual Section 1: Page - 15

22 1.6 Best Management Practices Once potential and existing sources of stormwater contamination have been identified, the next step is to select proper measures to eliminate or reduce pollutant loadings in the stormwater discharges. Best Management Practices (BMPs) are measures used to prevent or mitigate stormwater from becoming contaminated with pollutants. BMPs are broad ranging and may include processes, procedures, and structural controls. The BMPs selected reduce and/or prevent contamination by stressing the importance of stormwater management and employee awareness of potential pollutant sources. California's GENERAL PERMIT requires each facility covered by the permit to develop a description of stormwater management controls appropriate for the facility, and implement such controls. At a minimum, the stormwater management controls shall address, the following components: < Good Housekeeping, < Preventive Maintenance, < Visual Inspections, < Spill Prevention and Response, < Employee Training, < Record keeping and Reporting, < Non-Stormwater Discharges; and < Sediment and Erosion Control Management of Run-Off. CADG SMP Manual Section 1: Page - 16

23 The BMPs implemented at this facility emphasizes controlling exposure of stormwater to the site's industrial operations. Pollution reduction and elimination at the source has proven to be an effective approach in protecting the environment. This site s stormwater exposure control BMPs have been developed in concert with the CADG SMP s Best Management Practices. The BMPs developed through the CADG SMP are comprehensive and detailed in nature. The CADG SMP BMPs describe, in detail, what types of stormwater BMPs must be in place when a specific industrial activity is conducted under specified conditions. As a condition of inclusion into the CADG SMP, the auto dismantling facility is obligated to adopt and implement all of the applicable CADG SMP s BMPs. Additionally, in accordance with the requirements of the General Permit, the facility s SWPPT, as well as the CADG SMP Group Leader, are obligated to identify any other BMPs, in addition to the BMPs identified though the CADG SMP, that are implemented, or needs to implemented, at the facility. To date neither the facility s SWPPT, nor the CADG SMP Group Leader, have identified any additional BMPs that either are being implemented at the site, or that need to be implemented site. The site s SWPPT has determined that the CADG SMP BMPs are applicable to the site s industrial activities and associated sources, and types, of stormwater pollution. BMPs to be implemented, and maintained at all times, at the site include the following: Operating Activities In order for auto dismantling facilities to be in compliance with the GENERAL PERMIT they have to implement at least one of the following BMPs: < Drain automotive fluids prior to storage of vehicles and/or parts outside. Processing (i.e., draining and dismantling) activities shall be conducted under the following conditions: C Drain/dismantle inside a building or enclosed structure; or CADG SMP Manual Section 1: Page - 17

24 C Drain/dismantle undercover on a bermed concrete pad or paved surface. If the pad/surface is not bermed, then absorbent material must be laid out on the pad prior to draining a vehicle or part to collect/contain ant leaks or spills; or C Drain/dismantle on a uncovered bermed pad. If the pad/surface is not bermed, then absorbent material must be laid out on the pad prior to draining a vehicle or part to collect/contain any leaks or spills. Note: Under this option processing activities may only be conducted during dry weather conditions; or C Collect and treat, prior to discharge, all storm water that has come in contact with work areas, storage areas and/or stored vehicles and auto parts. < Each facility shall designate a holding area separate from the facility's vehicle storage area. Vehicles being held for processing and/or revised junk vehicles may only be staged in the designated holding areas. Designated holding areas shall be visually inspected daily for evidence of leaks. < Any vehicle in the facility's designated storage area shall be drained of automotive fluids. The only exceptions are for those facilities which met either of the following conditions: C All vehicles and parts which contain automotive fluids are stored inside or undercover so there is no contact with stormwater; and/or C All stormwater that has come in contact with work areas, storage areas and/or stored vehicles and auto parts is collected and treated prior to discharge. < Vehicles shall not be stored in such a manner so that the axles and/or underbody of the vehicle is in contact with the ground, regardless whether the ground is paved or not. Vehicles shall be stored on tires, rims, racks, stands or some devise which prevent contact of underbody and axles with the ground; CADG SMP Manual Section 1: Page - 18

25 < Burned vehicles and severely damaged vehicles shall be stored off the ground and under complete cover. Tarps may be used to cover burned and severely damaged vehicles under the following conditions: C Tarps must be made of plastic or water resistant coth material and must be a minimum of 9 mil in thickness and have reinforced eyelets. C Tarps must be of sufficient size to completely cover the burned and/or damaged areas of the salvaged vehicle. C Tarps must be secured in place with a strap or other type of tie-down device in such a matter to prevent the tarp from sagging or pulling loose during a storm event.. < Store all vehicles and parts which contain automotive fluids inside or undercover (including fluid bearing parts which remain on the vehicle during storage) so there is no contact with stormwater. Oil/fluid bearing parts may only be left on the vehicle under the following conditions: C The fluid is removed from the part. C All lines, valves, plugs and/or ports are closed, plugged and/or crimped and taped to prevent any leak or spill. C The part is kept undercover at all times. C The vehicle is stored off the ground at least 12" to provide a clear view of the area beneath the vehicle. C No part or component of the underbody, including axles, lines, etc, are allowed to extend beyond the underbody of the vehicle. CADG SMP Manual Section 1: Page - 19

26 C Vehicles stored in each site s storage yard will be marked with the date that the vehicle was processed for storage. Once every 60 days (every other month) the stored vehicle s fluid reservoirs will be checked to determine if residual fluids have collected in the reservoirs during storage. If fluids are detected in the reservoirs, the collected fluids will be removed within five working days. Vehicles may be "held" up to thirty (30) days from the date that the Department of Motor Vehicles (DMV) releases the vehicle to the participating facility for dismantling and/or resale. Vehicles held for more than the 30 day period are considered "stored". Vehicles must be processed (i.e, fluids drained) within the 30 day holding period. The only exception to the 30 day holding time limit is when a vehicle is classified as "revised junk". A vehicle that has been classified as revised junk will be sold as-is, without any processing. If a revised junk vehicle has not sold within 180 days, the vehicle will be re-classified for dismantling or scrap. The re-classified vehicle will then be processed within 30 days of re-classification Facilities Maintenance and Housekeeping Practices Good housekeeping practices are designed to maintain a clean and orderly work environment. A clean work environment reduces the possibility of accidental spills caused by mishandling of chemicals or equipment and should reduce safety hazards to facility personnel. The following good housekeeping measures will be implemented and monitored in an effort to prevent pollutants from entering stormwater discharges: < Improved Operation and Maintenance: Facility equipment (crushers, forklifts, welders, tools, etc) shall be maintained and operated in accordance with the manufacturers recommendations. At a minimum, a maintenance log shall be maintained for all motorized and energized equipment. There shall be no wash-downs of facility grounds or parking areas unless the wash water run-off can be captured and/or diverted away from storm drains, stormwater drainage ditches, gutters, creeks and/or adjacent grounds and surfaces. CADG SMP Manual Section 1: Page - 20

27 At no time shall wash waters or associated dirt, oils and debris be allowed to come in contact with stormwater or surface drainage, and/or be allowed to drain/discharge offsite. < Material Storage Practices: All hazardous materials and wastes shall be stored undercover and on a bermed pad. Trash/waste drums and bins shall be kept covered at all times when not in use to prevent rainfall from coming in contact with the container s contents. Spilled oils, hazardous materials or waste fluids shall be cleaned in accordance with the facility's Spill Response Procedures (reference the site's Emergency Action Plan). All spills and leaks which occur outside, or which may potential migrate outside, shall be immediately cleaned using dry techniques such as absorbents (i.e, rags, sweep, kitty litter, etc), sweeping and/or shoveling. Soils stained with oils, or other wastes shall be removed to a depth that shows no evidence of staining or adsorption, then back-filled with clean dirt. All clean-up wastes shall be properly managed and stored to prevent contact with storm waters and/or stormwater run-off. No more than 500 waste tires may be stored onsite at any one time unless the site is a permitted Waste Tire Storage Facility. Waste tires may only be stored onsite either in rows or neatly stacked. The facility shall not maintain a waste tire pile onsite. In accordance with State fire prevention requirements, waste tires shall be stored at least 50 feet from any fence line or structure. < Material Inventory Procedures: The SWPPT shall be responsible for maintaining an up-to-date inventory of all hazardous and non-hazardous materials used at the site. Chemicals shall be handled with adequate precaution following the procedures outlined in the facility's hazardous material management procedures. CADG SMP Manual Section 1: Page - 21

28 Hazardous and toxic materials used at the site shall be identified, quantified, and managed in compliance with federal, state, and local regulations. Furthermore, when feasible, materials shall be recycled, reclaimed, and/or reused to reduce the volume of materials brought into the facility, and less or non-toxic materials, will be substituted for toxic materials. < Employee Participation: Frequent training of employees in good housekeeping techniques reduces the possibility of materials being mishandled. Motivating employees to reduce spillage and waste generation is an effective pollution prevention technique. The following methods will be used to involve employees in the good housekeeping practices: C Information on good housekeeping practices will be distributed during employee training sessions; C Good housekeeping measures will be discussed at employee meetings; C Employees will be informed of activities that could potentially cause contamination of stormwater and the importance of carefully conducting these activities in areas that do not discharge/drain to storm conveyances; and C BMPs will be posted in all work and employee rest areas Spill Prevention and Response Spills and leaks are the most significant contributors of stormwater pollutants at the site. The facility's Hazardous Materials Management Procedures (HMMP), Injury and Illness Prevention Plan (IIPP) and Emergency Action Plan (EAP) include a summary of the steps that will be taken by site personnel to identify and characterize potential spills, to eliminate and reduce spill potential, and to respond to spills when they occur in an effort to prevent pollutants from entering the site's stormwater drainage system. The HMMP, IIPP and EAP are incorporated into this SWPPP by reference. CADG SMP Manual Section 1: Page - 22

29 1.6.4 Employee Training Since the facility's employees are responsible for, and contribute to, the site's housekeeping and maintenance, all employees are provided training on implementation and enforcement of the BMPs. An employee training program will be created, and implemented at the facility to inform employees of the components and goals of the CADG SMP and the site's SWPPP. A CADG SMP BMP(s) Employee Training Log will be used to track all employee training (Section 5). The intent of the employee training program is to create an overall sensitivity to pollution prevention concerns. In addition, the effectiveness of the training program will be evaluated routinely, but at least annually, to verify that information has been communicated effectively to the employees. The training program will consist of both formal and informal training which will focus on the site's BMPs. Initial training is provided to all new employees as well as annual refresher training Sediment and Erosion Control: To control erosion and minimize the amount of soils that are discharged off-site with the site's stormwater run-off, the facility shall, at the minimum, implement the following control measures: < Vehicle and parts storage areas shall be paved with concrete/asphalt and/or covered with vegetation (grass or ground covering) and/or covered with 3/4 inch, or larger, diameter rock /gravel to a depth of at least 3 inches. Surface Drainage Areas shall be installed (Section 5: Appendix 1-Figure 1: Surface Drainage Area) and maintained at the facility where more than 20% of the storage areas are uncovered, bare ground. < Divert surface drainage away from eroded areas until the area can be stabilized with either rock/gravel, pavement, re-grading or other erosion control measures. CADG SMP Manual Section 1: Page - 23

30 < Filtration systems shall be used and maintained during the wet season (October 1 to May 31) to remove suspended and floating dirt, debris and pollutants from stormwater prior to offsite discharge. Filtration systems include straw bales, sandtraps and other filtering media (i.e, absorbent pads, oil/water separators, sediment traps, etc) staged immediately upgradient of the point of discharge (for offsite sheet flow) and/or at storm drain inlets (Section 5: Appendix 1-Figure 2: Bale Installation Instructions for proper straw bale installation). The only exception to this requirement is if all stormwater drainage is retained onsite and/or chemically or physically treated prior to discharge. 1.7 Operation Specific BMPs The operation-specific BMPs that shall be implemented and maintained at all times at the facility are summarized in Section through The status and effectiveness of each BMP listed in Sections through are summarized in Sections through 1.7.8: CADG SMP Manual Section 1: Page - 24

31 CADG SMP BASELINE BMPS ACTIVITY POLLUTANTS SOURCES BEST MANAGEMENT PRACTICES (BMPs) Hazardous Oils, Greases, Use, Generation, A. Store hazardous materials & wastes undercover, on a sealed surface Materials & Petroleum Fuel Handling & equipped with secondary containment in secured and labeled containers. Waste Storage Hydrocarbons, Ethylene Glycol, Halogenated Hydrocarbons, Acids, Metals, Waste Waters, Detergents Storage of Motor Oils & Fluids, Fuels, Solvents, Antifreeze, Wash Waters & Detergents B. Label the waste containers with the name, description of the waste and the current storage start date. Keep the containers, containment and storage areas clean, dry and free of spills, oil residues, trash, debris. C. Maintain spill clean-up supplies in the waste storage areas. D. Maintain a current inventory of hazardous materials & wastes (batteries, waste oils, Freon, antifreeze, oil filters, oily rags, used air filters, recycled fuels, etc) generated onsite. E. Inspect hazardous materials and wastes storage areas daily for proper implementation and maintenance of control measures and containment integrity. F. Train employees on proper hazardous materials use and hazardous wastes control/disposal procedures at the initial time of employment, then at least annually. CADG SMP Manual Section 1: Page - 25

32 ACTIVITY POLLUTANTS SOURCES BEST MANAGEMENT PRACTICES (BMPs) Operational Activities (Draining of Fluids, Dismantling & Vehicle Dismantling) Oil & Grease, Petroleum Fuel Hydrocarbons, Ethylene Glycol, Metals, Suspended Solids, Acids, Dissolved Solids Motor Oils & Fluids, Fuels, Antifreeze, Batteries, Corroded & Chipped Metallic Parts, Filters, Tires & Rims, Engine Blocks, Drive Lines, Mufflers A. Operational activities (fluid draining, vehicle dismantling, parts cleaning) shall be performed inside/undercover and/or on a paved or concrete bermed pad in accordance with Section 1: Subsection 1.6. B. Only sheet metal parts and non-fluid bearing parts (windows, doors, mirrors, seats, etc) may be dismantled in the storage area. C. Perform operational activities only in designated work areas. D. Drain motor oils, Freon, antifreeze and transmission and brake lines upon arrival onsite during 30 day holding period prior to storage. E. When operational activities can not be performed on a bermed pad, absorbent must be laid down prior to conducting any operational activity. Care shall be taken to immediately contain, capture and clean up any discharge or spills of waste auto fluids to the ground. F. Maintain spill clean-up supplies at all draining & dismantling areas. G. Do not leave full drip pans or open waste containers unattended. Transfer wastes to the proper containers as soon as practical, but at the minimum at the end of each shift. H. Train all employees on proper operational procedures and control measures at the time of initial employment, then at least annually thereafter. I. Inspect operation work areas daily to insure proper implementation and maintenance of operational procedures and control measures. CADG SMP Manual Section 1: Page - 26