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Storm Water Pollution Prevention Manual Appendix C - Sample SWPPP

This storm water pollution prevention plan (SWPPP) deals with the Verona Galvanizing, Inc., a hot dip galvanizing facility on Sawmill Road in southern Montgomery County, Texas. The SWPPP provides information and guidance for employees of the facility in complying with the Environmental Protection Agency’s final NPDES general permit for storm water discharges associated with industrial activity as published in the Federal Register on June 4, 2015. This plan was originally created in 1996 and has been modified to meet the 2015 Multi-Sector General Permit requirements for the Sector AA - Fabricated Metal Products category. Much of the plan remains the same. A few of the sampling guidelines have changed so pay special attention to your issued permit requirements.

The certification form shown in Figure C.1 must be completed before the effective date of the plan.

This certification must be completed by an authorized signatory before the effective date of the Plan.

Signed: _______________________________________________________________________

Name: _______________________________________________________________________

Title: _______________________________________________________________________

Company: _______________________________________________________________________

Address: _______________________________________________________________________

Telephone: _______________________________________________________________________

Date: _______________________________________________________________________

Figure C.1 - Certification of SWPPP

American Galvanizers Association 2015

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Certification of Storm Water Pollution Prevention Plan

I certify 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 gathered and

evaluated the information submitted. Based on my inquiry of the person or persons who manage the

system, or those persons directly responsible for gathering the information, the information submitted is, to

the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant

penalties for submitting false information, including the possibility of fines and imprisonment for knowing

violations.


Pollution Prevention Team

The following individuals make up the pollution prevention team. They are responsible for developing storm water pollution prevention plan and implementing the storm water pollution prevention measures identified in the plan:

Each pollution prevention team member has specific responsibilities in maintaining and implementing the SWPPP, as indicated in Table C.1. Note that certain individuals may have more than one responsibility and therefore may be listed at more than one location in this table.

TABLE C.1 - Storm Water Pollution Prevention TeamResponsibility Name PhonePrimary Emergency Contact

Secondary Emergency Contact

Signatory

Plan Development

Plan Implementation

Plan Revision

Employee Training

Inspections

Preventive Maintenance

Spill Response

Potential Pollutant Sources

The following sections describe the existing conditions on the site including site drainage and topography, existing materials, and operations conducted at the site.

Storm Water Drainage

Figure C.2 illustrates the site drainage map, which shows the following:

1. The site topography and pattern of storm water drainage

2. Paved areas

3. Parking areas


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4. Fueling areas

5. Earthen areas

6. Vegetated areas

7. Building locations

8. Site boundaries

The facility occupies approximately 0.8 acres of land. The site is roughly rectangular, with the long axis orients in the east-west direction. The maintenance shop and main facility are located at the east end of the facility. A concrete sidewalk starts at the back (west end) of the facility and runs almost the entire length of the remainder of the site. The concrete sidewalk is located along the east-west axis and serves as a break point for storm water run-off, causing water to flow either north or south. The concrete pavement at the facility also forms a break point near the center of the site along the north-south axis, which causes the run-off to flow east and west. Therefore, the four quadrants of the property drain to separate discharge points.

All four quadrants of the property are within the drainage area of Panther Branch, a tributary of Spring Creek. Spring Creek discharges into Lake Houston on the San Jacinto River. The San Jacinto River system discharges into the Galveston Bay on the Gulf of Mexico. The site is not served by a regulated municipal separate storm sewer system.

Southwest quadrant

Storm water run-off from the western portion of the facility drains into the Sawmill Road drainage system, which discharges into a tributary of Panther Branch. Storm water run-off on the south side of the concrete sidewalk in this portion of the facility will flow south until it reaches a curb, which runs the entire length of the south side of the site, where it will then be directed into a curb inlet that outfalls into the Sawmill Road drainage system

Northwest quadrant

Storm water run-off on the north side of the concrete sidewalk in the western portion of the site will either leave the site through a gate located in the northwest corner of the site or make its way into the wooded area located immediately north of the site. The run-off leaving the site through the gate will flow down a paved drive directly onto Sawmill Road where it will empty into the drainage system via curb inlets. The storm water run-off will flow into the wooded area immediately north of the site and will either flow down towards Sawmill Road or the run-off will eventually drain into a storm sewer inlet on the north side of the wooded area near Knox Industries.

Southeast quadrant

Storm water run-off from the eastern portion of the site makes its way eastward to Grogans Mill Road. Run-off from the south side of the process building and concrete sidewalk in this portion of the site will flow south until it reaches the curb that runs along the south side of the facility. The storm run-off will then be directed east toward the access road where it will either empty into a grated storm inlet in the southeast corner of the site or flow through the south entry gate. The flow entering the grated inlet drains into a 12-in storm sewer pipe which crosses beneath the access road. The run-off that leaves the site through the south entry gate will flow over the access road and empty into the same drainage ditch.


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Northeast quadrant

Storm water run-off from the north side of the process building and the concrete sidewalk in the eastern portion of the site will flow into a drainage ditch located immediately north of the facility, will empty into a grated inlet located in the northeast corner of the site, or will flow through the north entry gate. Storm water run-off that flows into the drainage ditch will flow east into a 15-in storm sewer pipe located just outside the northeast corner of the site. Storm water run-off that makes its way into the grated inlet will drain into a 15-in storm drain which is connected to the same 15-in storm sewer pipe which the drainage ditch discharges. The storm drain crosses beneath the access road and discharges into a drop inlet. The run-off then drained into an 18-in storm drain where it will be directed north toward Campus Road. Run-off leaving the site through the north entry gate will flow across the access road into the drainage ditch located on the east side of the road. The run-off will then flow into the drop inlet where it is intermingled with the run-off being discharged from the 15-in storm sewer drain and then flow north through the 18-in storm drain. The 18-in storm drain will discharge the run-off into a drop inlet at the northeast corner of the intersection of the access road and Campus Road. The run-off will then drain into a 24-in storm sewer pipe and cross beneath Campus Road. The run-off will then be directed east toward Grogans Mill Road where it will eventually outfall to another tributary of Panther Branch.


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Existing Curb & Gutter

Existing Tree LineExisting Chain Link

FenceExisting Concrete Sidewalk Grate Inlet

Concrete Sidewalk

12” Storm Sewer

Concrete Sidewalk

Type “B-B” Inlet

Storm Sewer

Manhole

Existing 30” Storm Sewer

Proposed Swale Ditch

Existing Concrete Pavement

Existing Sanitary Sewer Manhole Manhole

18” RCP Storm Sewer

8” Sanitary Sewer

Maintenance Building and

Offices

Processing Building

Painting Building

Sawmill Road

(northboundlanes)

Gate

Limits of Clearing

Type “C” Inlet

Limits of Clearing Existing Tree Line

Existing Grate InletExisting 24” R.C.P.

Existing Grate InletExisting Swale Ditch

6” Sanitary Sewer

Wash Area (Water Hose)

18” CMP Storm Sewer

Concrete

Covered Parking

ConcretePavement

Black Steel Storage

CoveredChemical Tanks

Finished Galvanized Products


Inventory of Significant Materials

Table C.2 list the significant materials found at the Verona Galvanizing facility.

Table C.2 - Significant Materials on SiteSignificant Materials Storage Container Storage AreaLubricating Oils Weathertight CoveredGrease Weathertight CoveredCleaning Solvents Weathertight CoveredDetergent Weathertight CoveredSpray Paint Weathertight CoveredBlack Steel Outside on pallets ExposedSodium Hydroxide Weathertight CoveredHydrochloric Acid Weathertight CoveredAmmonium Chloride Weathertight CoveredZinc Weathertight CoveredLead Weathertight CoveredDry Kettle Skims Weathertight CoveredZinc Bottom Dross Weathertight CoveredGalvanized Steel Outside on pallets Outside on pallets

Black steel (uncoated steel) is stored outside on wooded pallets on asphalt.

Sodium Hydroxide, Hydrochloric Acid, and Ammonium Chloride are stored inside the facility in 12,000 gallon baths. Each chemical is also stored in 12,000 gallon storage tanks outside the facility next to the maintenance building. These storage tanks are kept covered with a metal awning. The waste chemicals is eventually pumped into a truck and delivered to a recycling facility.

Zinc and lead are by-products of the galvanizing kettle. These are stored inside the processing facility. Zinc is also stored inside in slabs weighing about 1 metric ton.

Kettle skims and zinc bottom dross are also by-products of the galvanizing kettle. Once they are extracted from the kettle they are stored in 55 gallon drums until they are hauled to a recycling facility. They are also kept under a metal awning.

The finished galvanized product is stored outside on wooden pallets.

Solvents, cleaners, lubricants and detergents are stored inside the maintenance building.

Materials management procedures

Several practices are used at the site to minimize contact between significant materials and precipitation or storm water run-off. These are examples of this contact minimization:

1. Indoor maintenance: All maintenance and touch-ups are done inside the maintenance building to prevent contact between storm water run-off or precipitation and any significant materials.

American Galvanizers Association 1996- rev 2015

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2. Covered parking: Vehicles are parked so that the vehicle is covered by a metal awning. This practice helps prevent precipitation from coming into contact with any fluids or fuels that may have leaked from the vehicle’s engine compartment.

3. Cleanup of spills: Fluids leaked from vehicles and equipment are cleaned up immediately to prevent contact with storm water run-off and precipitation.

4. Vehicle maintenance: Any noticeable leaks from vehicles and equipment are repaired as soon as possible.

5. Covered storage: Chemicals, solvents, lubrications oils and cleaners are stored inside the maintenance building or covered to prevent exposure to storm water run-off and precipitation.

6. Wash water: Washing of equipment and parts are done in the maintenance building. The wash water drains directly into the sanitary sewer. This procedure eliminates the possibility of contaminants in wash water mixing with storm water run-off.

7. Compressors: Compressors are located inside the maintenance building to prevent contact with precipitation and storm water run-off.

Existing Structural and Non-Structural Pollution Controls

The existing structural and non-structural controls used to reduce pollutants in storm water run-off include:

1. Covered parking area

2. A fully enclosed maintenance building in which all lubricants, solvents, and cleaners are stored

3. A fully enclosed washing area

4. A fully enclosed painting building

5. Good housekeeping measures, including sweeping and immediate cleanup of spills and leaks.

Existing Storm Water Treatment Methods

The only treatment that the run-off receives prior to discharge from the site occurs in a vegetated strip located along the east boundary of the site (see Figure C.2). This strip provides partial vegetative filtration which filters some suspended solids from the storm run-off before the run-off is discharged from the site.

Significant Spills and Leaks

No significant spills or leaks of toxic materials have occurred at the facility within the past 3 years. Special measures have been adopted to prevent spills and leaks at the facility:


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1. Drip pans: Drip pans are placed beneath all hose connections during transfer of fuels and chemicals from delivery trucks to the tanks.

2. Chemical delivery: Transfers from delivery trucks to the chemical tanks are continuously monitored.

3. Maintenance: Leaking or dripping fluids from vehicles, equipment, or piping are collected in drip pans or containers. All leaks are repaired as soon as possible.

4. Used fluids: Used fluids are promptly transferred to the proper waste recycling drums. Full drip pans or other containers are not left lying around.

5. Daily inspections: Storage tanks, equipment, and piping are inspected daily to ensure that no leaks have developed.

Non-Storm Water Discharges

Outfalls identified on the site layout map were evaluated for the presence of non-storm water discharges. The methods used to conduct the evaluation included:

1. Onsite investigation of storm water management systems

2. Examinations of site layout maps, drainage maps, etc.

3. Interviews with plant personnel concerning onsite drainage patterns

Sources of non-storm water at the site include wastewater from the sinks and toilets, vehicle and equipment wash water, floor wash waters, and steel wash waters. These may not be discharged into surface waters under the EPA baseline and multi-sector permits. Very small amounts of compressor and air-conditioning may also be discharged under certain circumstances. These may be discharges with storm water from the site, if they are referenced in the SWPPP and if appropriate pollution prevention measures are taken, as described later in this plan.

Wastewater from sinks and toilets drains directly into a sanitary sewer. Therefore, these flows are not discharged into surface waters.

Most vehicle and equipment washing takes place in the western end of the building (see Figure C.2). The wash water is discharged through a floor drain which is connected to a 4-in sanitary sewer line. The 4-in sewer line is connected to a manhole located in the north-central part of the site which in turn is connected to an 8-in sanitary sewer line. This 8-in sewer line runs west beneath the pavement, eventually connecting to another sanitary sewer line on the west side of Sawmill Road. Therefore the vehicle and equipment wash water is not discharged into surface waters.

A sediment trap and an oil-water separator will be installed in the sanitary sewer line just off the edge of the concrete pavement at the west end of the facility. Greases, oils and fluids washed into the floor drains during vehicle and equipment operations will be filtered out before the sewer discharge reached the main system.


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Storm Water Pollution Prevention Manual Appendix C - Sample SWPPPSome equipment washing also occurs in the northeast corner of the facility. A water hose, brush, and a 5 gallon bucket filled with soapy water are also used to clean the equipment in this area. Run-off from this operation drains into the swale located immediately north of the property line.

The wash waster from the shop floor cleaning operations drains to either the north or south side of the site in the eastern portion of the facility, depending on the direction the wash water is sprayed and the direction it is swept out of the building. The wash water either makes its way into the drainage ditch located on the east side of the access road (if enough water is discharged from the shop area) or saturates the concrete pavement (which begins just outside the shop doors) and eventually evaporated. Any wash water that happens to discharge into the drainage ditch will eventually outfall into a tributary of Panther Branch.

Part cleaning operations take place outside on the south side of the facility. A high-pressure sprayer is used to clean the parts. Run-off from this activity drains into the grated inlet located in the south east corner of the site, where it crosses beneath the access road via a 12-in storm sewer pipe and discharges into a drainage ditch. Any wash water that does not evaporate or percolate into the ground is eventually discharged into a tributary of Panther Branch.

Some of the non-storm water discharges listed above (Vehicle and equipment wash water, shop cleaning wash water, and part cleaning wash water) are not allowable under the EPA baseline and multi-sector storm water discharge permit and must be eliminated before this SWPPP becomes effective. The vehicle and equipment wash water and part cleaning wash water will be eliminated by moving these operations into the maintenance part of the building , so the wash water is discharged into the floor drains leading to the sanitary sewer system,. The certification form shown in Figure C.3 must be completed by the date required for implementation of this SWPPP. The certification must be signed by the person designed as having authority by the owner.


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This certification is to be completed by an authorized signatory only when all the measures

stated in this SWPPP for eliminating non-storm water discharges have been fully carried out. This

certification is required before the effective date of the plan.

Signed: _______________________________________________________________________

Name: _______________________________________________________________________

Title: _______________________________________________________________________

Company: _______________________________________________________________________

Address: _______________________________________________________________________

Telephone: _______________________________________________________________________

Date: _______________________________________________________________________

Figure C.3 - Certification form for the elimination of non-storm water discharges


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CERTIFICATION THAT NON-STORM WATER DISCHARGES HAVE BEEN ELIMINATED







violations.


Sampling Data

No storm water sampling has been performed on the site, and no sampling data are available from other sources. (Note once sampling data is available for the site it will be place in an Appendix of the facility plan and be retained onsite and available for at least 5 years.) EPA's Industrial Stormwater Monitoring and Sampling Guide provides information on how to collect, document and analyze samples 4 times per year. The data must then be compared to the monitoring requirements.

Risk Identification and Summary of Potential Pollutant Sources

The most immediate potential pollutant source at the facility is wash water from vehicle, equipment, part washing, and shop cleaning. With the completion of the certification relating to non-storm water discharges earlier in this plan, however, this potential pollutant source should be eliminated.

A number of processes, activities, and materials have a reasonable potential to contribute significant amounts of pollutants to storm water run-off, unless proper procedures and precautions are taken. Potential contributors include:

Maintenance facility: Many vehicle and equipment maintenance operations use materials or create wastes that have the potential to pollute storm water run-off. Activities that can pollute storm water run-off include parts cleaning; shop cleaning; spilled fuel, oil, chemicals, or other materials; and replacement of fluids.

Rooftops: Buildings having ventilation systems with discharge vents located on the roof can contribute particular matter to storm water run-off. These ventilation systems pull dust from inside the building and discharge it onto the roof area around the vent. A storm event would wash the dust from the rooftops onto the ground where the dust would mix with storm water run-off.

Chemical storage areas: Storage, leaks, drips, and spills of chemicals in areas exposed to precipitation may increase concentrations of chemicals in storm water run-off.

Parking areas: Drips or leaks of oil, transmission fluid, antifreeze, etc., from vehicles could potentially have an adverse impact of storm water quality by contributing chemicals such as ethylene glycol to the run-off and by raising the oil and grease levels.

Vehicle and equipment wash areas: Washing removes particulate matter from vehicle and equipment, thus increasing the suspended-solids levels. There is also a potential for small amounts of oil and grease or metal fragments to be washed away by high pressure sprayers at these facilities. Some detergents also contain phosphates, which can cause excessive growth of nuisance plants in water when the phosphates enter lakes or streams in wash water.

Loading and unloading operations: Materials spilled, leaked, or lost during loading and unloading may collect in the soil or on other surfaces and be carried away by storm water run-off or when the area is cleaned. Rainfall may wash off pollutants from machinery used to unload or load materials.

Product washing: Oil, grease, dirt, and metal fragments can be washed from the finished product during pressure spraying. These materials could potentially elevate oil and grease levels and suspended-solids levels.


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http://www.epa.gov/npdes/pubs/msgp_monitoring_guide.pdf

http://www.epa.gov/npdes/pubs/msgp_monitoring_guide.pdf


CONSISTENCY WITH OTHER REGULATIONS

This site will be operated and maintained in accordance with all applicable laws and regulations of Montgomery County, the state of Texas, and any other agency having jurisdiction over the site.

POLLUTION PREVENTION MEASURES AND CONTROLS

This section describes the measures to be taken to reduce the discharge of pollutants in storm water. Three types of measures are included:

Pollutant source reduction measures

Pollutant source control measures

Storm water recycling and treatment measures

Pollutant Source Reduction Measures

The most important measure implemented to improve storm run-off will pertain to source reductions which have been addressed previously in the SWPPP. These measures will eliminate or reduce the amount of pollutants generated on the site. Source reductions include:

1. Good housekeeping

2. Preventive maintenance

3. Spill prevention

4. Training

5. Material management practices

Good Housekeeping

The following good housekeeping measures are to be conducted at the facility to help keep contaminants out of storm water discharge.

Sweeping: All areas covered with concrete, cement, or asphalt surfaces will be swept regularly. This includes areas located both inside and outside the buildings. All dirt and sediment should be removed from all paved areas on the site. Dust that is allowed to accumulate on the floors on the building can be tracked outside by vehicle tires or customer and personnel footwear. All matter that is swept from these areas should be disposed of in an area of the site which allows no storm water run-off or should be trucked off site for disposal.

Leaks and spills: Immediately clean up all leaks and spills.


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Vehicle parking: Limit vehicle parking to specific areas of the site. Park vehicles under covered areas as much as possible.

Pavement washing: Avoid hosing down work areas which could possible contain storm water pollutants. Use brooms, shovels, mops, etc., to collect waste and dispose of it properly.

Drip pans: Keep a drip pan and tarpaulin under areas while disconnecting hoses, unscrewing filters, or removing other parts. Use drip pans under any area that might leak, to keep splatters or drips off the floor or ground.

Used fluids: Promptly transfer fluids to the proper waste or recycling drums. Do not leave full drip pans or other open containers lying around.

Used filters: Crush and recycle used filters. Under Texas state law, used filters may not be disposed of in sanitary landfills.

Waste disposal: Dispose of trash and debris by putting them into the dumpster or hauling them directly to a landfill or recycling facility. Keep the dumpster lid closed to prevent rainfall from entering the dumpster and washing pollutants out through the drain holes located in the bottom of the container.

Employee information: Post good housekeeping procedures and reminders in appropriate locations around the workplace.

Materials Management

The following materials management practices will be used at the facility to protect the quality of storm water discharges.

Parts-cleaning agents: Use non caustic detergents instead of caustic cleaning agents for cleaning parts cleaning.

Organic solvents: Use detergent-based or water-based cleaning systems in place of organic solvent degreasers.

Chlorinated organic solvents: Replace chlorinated organic solvents (1,1,1-trichloroethane, methylene chlorides, etc.) with nonchlorinated solvents. Nonchlorinated solvents such as kerosene or mineral spirits are less toxic and less expensive to dispose of but are by no means harmless themselves. Check the list of active ingredients in each solvent to see whether it contains chlorinated solvents.

Recycling cleaning agents: Choose cleaning agents that can be recycled.

Solvents: Reuse “dirty” solvents. Presoak dirty parts in used solvent before cleaning the parts in fresh solvents.

Detergents: Use phosphate-free biodegradable detergents for vehicle and equipment washing.

Recycling waste oil: Collect waste oil for recycling.


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Drum storage: Locate waste and recycling drums in properly controlled areas of the site, preferably in covered areas with concrete slab and secondary containment.

Parts-cleaning procedures: Clean parts without using liquid cleaners whenever possible to reduce waste. Scrape parts with a wire brush, or use a bake oven if one is available. Do all liquid cleaning at a centralized station so the solvents and residues stay in one area. If parts are dipped in liquid solvents, remove them slowly to avoid spills. Locate drip pans, drain boards, and drying racks so that drips are directed into a sink of fluid holding tank for reuse.

Recycling procedures: Collect used oil, fluids, cleaning solutions, and degreasers for transport to a commercial recycling facility. This requires that wastes be separated and stored until they are picked up by the recycling company.

Employee information: Use signs, labels, and color coding to identify problem areas or hazardous materials at the facility. Accurate labeling can help site personnel to quickly identify the type of material released so that they can respond to the spill correctly. Color coding is easily recognized by facility personnel and simply involves painting/coating or applying an adhesive label to the container. Color codes will be consistent throughout the facility, and signs explaining the color codes will be posted.

Materials management: Improve material tracking and inventory practices so that wastes resulting from overstocking and the disposal of outdated materials can be reduced or eliminated.

Liquid wastes: Eliminate intentional disposal of liquid wastes into floor drains, sinks, outdoor storm drain inlets, or other storm drains. Signs will be posted at sinks to remind employees, and stencils will be used at drains to tell employees and other not to pour wastes down the drains.

Preventive Maintenance

A preventive maintenance program which involves regular inspections of storm water management devices and other equipment and systems will be carried out. Systems and equipment to be regularly inspected include:

Gutters: Roof gutters will be inspected quarterly or at the first sign of clogging. Any debris or dust that has collected inside the gutter will be removed and disposed of properly.

Pumps: The pumps will be visually inspected daily. Areas to be inspected include the pump foundation and connections. The pumps will be checked for corrosion, leaks, cracks in hoses, or other physical damage to the system. Should a leak or other threatening condition be found, corrective action will be taken immediately, or else the pump will be shut down until the problem is solved. The pumps will be cleaned with a wet rag or a sponge mop. A water hose will not be used to clean the pumps, in order to avoid washing potential contaminants onto the surrounding pavement or drainage areas where they could potentially enter into storm water run-off.

Chemical storage areas: Chemical storage barrels and tanks will be inspected daily for leaks. Should a leak or other threatening condition occur, corrective action will be taken immediately.

Record keeping and reporting: Records and reports of all inspections and maintenance activities will be maintained, as described later in this plan.


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Spill Prevention and Response Procedures

Spill prevention and response procedures are a vital part of the SWPPP. Employees should be well trained in material handling procedures, storage requirements, and cleanup procedures that minimize the potential for spills, and, in the case of a spill, how to respond. Containment and diversion equipment also plays an important part in preventing pollutants from entering into storm water run-off. Spill prevention and response procedures that will be implemented at the facility include:

Plug floor drains: The floor drain located inside the chemical storage area will be plugged to prevent spills from entering into the sanitary sewer.

Containment areas: All chemicals, petroleum products, solvents and cleaners will be stored inside a contained area so that all spills or leaks can be controlled.

Storage locations: Containers and drums will be stored away from direct traffic routes to prevent accidental spills.

Bulk chemical delivery: Transfer of chemicals from delivery vehicles to the storage tanks will be monitored closely to prevent overfilling and spilling.

Spill response: Mops, rags, or sorbent materials (cat litter, straw, sawdust, etc.) will be used to clean up and contain petroleum or chemical spills. Petroleum or chemical spills will not be washed into the storm drain or sanitary sewer.

Overflow protection: Existing overflow protection devices on tank systems will be maintained to warn the operator or to automatically shut down transfer pumps when the tank reaches full capacity.

Valve labeling: Valves will be clearly tagged or labeled to reduce the potential for human error.

Inspections: Visual inspections of the pumps and tanks will be conducted on a daily basis. Areas to be inspected include pump foundations and hose connections.

Cleaning: Vacuum and pump systems will be used at the facility to collect both wet and dry materials in material handling areas and work areas.

Employee Training- Annual

Employee Annual training programs will inform personnel at all levels of responsibility of the components and goals of the SWPPP. Training will address each component of the SWPPP, including how and why tasks are to be implemented. Topics will include:

Spill prevention and response

Good housekeeping

Material management practices


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Spill prevention and response procedures will be discussed in the training program in order to ensure that all plant employees, not just those on the spill response teams, know what to do if a spill occurs. The following measures will be addressed:

Identifying potential spill areas and drainage routes, including information on past spills and causes

Posting warring signs in spill areas with emergency contacts and telephone numbers

Specifying material handling procedures and storage requirements

Introducing the Spill Response Coordinator and her or his team

Drilling on spill cleanup procedures

Posting the locations of spill cleanup equipment and the persons responsible for operating the equipment

On-site contractors and temporary personnel will also be informed of the plant operations and design features in order to help prevent accidental discharges or spills.

Facility personnel will also be taught how to maintain a clean, orderly work environment. These points will be emphasized in the good housekeeping portion of the training program:

Require regular sweeping.

Promptly clean up spilled materials to prevent polluted run-off.

Identify places where brooms, vacuums, sorbents, foams, neutralizing agents, and other good housekeeping and spill response equipment are located.

Display signs reminding employees of the importance and procedures of good housekeeping.

Discuss updated procedures, and report on the progress of practicing good housekeeping at every meeting.

Provide instruction on securing drums and containers and frequently checking for leaks and spills.

Outline a regular schedule for housekeeping activities to verify that the job is being done.

Personnel will also be trained to handle and organize materials stored on site. This training will help prevent spills and injury to employees as well as reduce wastes due to overstocking. These points will be emphasized in the material management practices portion of the training program:

Neatly organize materials for storage.

Identify all toxic and hazardous substances stored, handled, and produced on site.

Discuss handling procedures for these materials.


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Tell employees to use the oldest materials first.

Explain recycling practices.

Demonstrate how valves are tightly closed and how drum storage should be sealed.

Training materials to be included in the facilities training program include the following:

Employee handbooks

Films and slide presentations

Drills

Routine employee meetings

Bulletin boards

Suggestion boxes

Newsletters

Environmental excellence awards or other employee incentive programs

Employees at the facility will attend a storm water pollution prevention training annually based on the effective date of this SWPPP. Employees hired after the annual storm water pollution prevention training will receive complete training before they begin their new duties at the facility.

Pollutant Source Control Measures

Erosion Control

The facility is almost completely paved, with small vegetated areas. Erosion is not expected to be a problem.

Containment and Diversion

Containment and diversion measure will be implemented at the facility to reduce the amount of pollutants generated. These practices will include:

Covering activities: Used chemicals, petroleum products or solvents containers, or any other potential pollutant sources will be stored in covered areas while they wait to be transported off site to recycling facilities or disposal areas.

Dust control: Paved areas of the site will be swept regularly to remove particulate matter that could potentially elevate suspended solids levels in storm water run-off.


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Diversion measures: Part cleaning operations will take place inside the so that greases, oils, fluids, and metal fragments will be drained into the sanitary sewer system and then through the oil-water separator and sediment trap before the sewer discharge reaches the main system.

Storm Water Recycling and Treatment

Due to the containment and diversion and exposure minimization practices being implemented at the facility, no storm water treatment practices will be implemented at this time. If future site inspections indicate that additional practices or measures need be implemented to reduce pollutant loads in storm water run-off, storm water treatment measures may be implemented.

Record Keeping and Internal Reporting

Keeping records of and reporting events that occur on site are an effective way of tracking the progress of pollution prevention efforts and waste minimization. Analyzing records of past spills, e.g., can provide information useful for developing improved best management practices to prevent future spills of the same kind. Record keeping and internal reporting represent good operation practices because they can increase the efficiency of the facility and the effectiveness of BMPs.

All records will be kept up to date with respect to the following:

The correct name and address of the facility

The correct name and location of receiving waters

The number and location of discharge points

Any operations performed at the site

When storm water sampling is performed, sampling records will be retained for 6 years after the date of sampling.

Public Access

Despite the fact that the SWPPP and associated reports are not necessarily required to be submitted with the NOI, these documents are considered to be reports according to Section 308(b) of the Clean Water Act, and therefore they are available to the public. The permittee, however, may claim certain parts of the SWPPP as confidential according to regulations in 40 CFR part 2. These regulations state that records which contain trade secrets may be claimed as confidential.

Spills, Leaks, and Other Discharges

A record keeping system will be established for documentation spills leaks and other discharges, including discharges of hazardous substances in reportable quantities. Reports of incidents and follow-up information on the results of inspections and reported spills, leaks, or other discharges will be recorded and maintained.


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Records will include the following, as appropriate:

The date and time of the incident

Volume spilled

Weather conditions

Duration of the incident

Cause of the incident

Environmental problems

Response procedures

Parties notified

Recommended revisions of the BMPs program

Operating procedures

Equipment needed to prevent recurrence

Formal written reports (and documentation of all reports called in to the National Response Center in the event of a reportable quantity discharge)

A list of the procedures for notifying the appropriate plant personnel and the names and telephone numbers of responsible employees

Inspections and Maintenance Activities

A log of all inspections and maintenance activities, such as the cleaning of oil-water separators or filter systems, will be maintained to allow evaluation of the effectiveness of the program, equipment, and operation. Inspection records will note:

When inspections were done

Who conducted the inspection

What areas were inspected

What problems were found

Steps taken to correct any problems, including who has been notified


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Changes to the Plan

This plan will be amended whenever there is a change in design, construction, operation, or maintenance which may impact the potential for pollutants to be discharged or if the SWPPP proves to be ineffective in controlling the discharge of pollutants. The amended plan will be kept at the site with the original.

Implementation Schedule for Pollution Measures and Controls

All controls or practices identified in this plan will be implemented no later than the effective date of this plan.

Comprehensive Site Compliance Evaluation

A comprehensive site inspection will be conducted annually. The following steps will be completed in connection with the annual inspection:

SWPPP review: Review the SWPPP and draw up a list of those items which are part of material handling, storage, and transfer areas covered by the plan.

Materials review: Verify the list of equipment and materials in these areas covered in the plan

Operations review: Review facility operations for the past year to determine if any more areas should be included in the original plan or any existing areas were modified so as to require plan modification. Change the plan as appropriate.

Drainage area inspection: Inspect storm water drainage areas for evidence of pollutants entering the drainage system.

Source reduction measures: Evaluate the effectiveness of measures to reduce pollutant loadings, and decide whether additional measures are needed.

Source control measures: Observe structural measures, sediment controls, and other storm water BMPs to ensure proper operation.

Equipment review: Inspect any equipment needed to implement the plan, such as spill response equipment.

Plan revision: Revise the plan as needed within 2 weeks of inspection (potential pollutant source description and description measures and controls).

Plan implementation: Implement any necessary changes in a timely manner, but within 12 weeks of the inspection.

Inspection report: Prepare a report summarizing inspection results and follow-up actions, the date of inspection, and personnel who conducted the inspection.

Record keeping: Sign the report and keep it with the plan.


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Certification: Document all incidents of noncompliance in the inspection report. Where there are no incidents of non compliance, the inspection report must contain a certification that the facility is in compliance with the plan. Figure C.4 contains a certification for this purpose.

This certification is completed by an authorized signatory after each annual site compliance

evaluation. It indicates that the Storm Water Pollution Prevention Plan was evaluated as part of an

inspection, is adequate for control of facility storm water discharges, and that the facility is in compliance

with the SWPPP. If changes to the SWPPP or the site are necessary as a result of the inspection, these

changes should be performed before this certification is completed.

Signed: _______________________________________________________________________

Name: _______________________________________________________________________

Title: _______________________________________________________________________

Company: _______________________________________________________________________

Address: _______________________________________________________________________

Telephone: _______________________________________________________________________

Date: _______________________________________________________________________

Figure C.4 - Certification of comprehensive site compliance evaluation


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Annual Certification of Compliance







violations.


The inspection supervisor and inspection conductor will be responsible for the comprehensive site inspections.

A copy of the Annual Comprehensive Site Compliance Evaluation worksheet will be completed and filed on site. The worksheet will be signed by an authorized signatory authority.

EPCRA Section 313 Water Priority Chemicals

The EPA general permit has special requirements concerning the storage and handling of water priority chemicals identified under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986.

EPCRA Section 313 Water Priority Chemicals on Site

EPCRA section 313 water priority chemicals found on site are located in the maintenance shop, in the processing facility, and in the storage tanks on the east side of facility. EPCRA section 313 water priority chemicals can be found in the following:

Unleaded gasoline Spray lubricants Hydrochloric acid bathCaustic bath Spray paints Floor adhesivesFuel additives Welding rods

Table C.3 lists each EPCRA section 313 water priority chemical, along with the CAS reference number, the substances which contain the chemicals, the container used to store each substance, and the reportable quantity (RQ) amount of each chemical.

All substance containing water priority pollutants are stored and used in covered areas, which prevents the substances from being exposed to precipitation and storm water run-off.

TABLE C.3 - EPCRA Section 313 Water Priority Chemicals on SiteCommon Name CAS Ingredient of: Container Reportable Quantity, lbHydrochloric Acid 7647-01-0 Acid bath 12,000 gal bath 5000Lead 7439-92-1 Galvanizing bath

Zinc ashBottom dross

Galvanizing kettle55 gal drums55 gal drums

10

Zinc 7440-66-6 Galvanizing bathZinc ashBottom dross


1000

Xylene 1330-20-7 Krylon spray paint Aerosol cans 1000Toluene 108-88-3 Krylon spray paint Aerosol cans 1000Ammonia 7664-41-7 Ammonia 1/2 gal cans 100Cadmium 7440-43-9 Galvanizing bath

Zinc ashBottom dross


10

Chromic acid 1115745 Cleaning solution 1/2 gal cans 10Lead chloride 7758954 Flux 55 gal drums 100Zinc chloride 34868359 Zinc ash 55 gal drums 1000


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Special Requirements for EPCRA Section 313 Water Priority Chemicals

Employees and contractor personnel who work in areas where EPCRA section 313 water priority chemicals are used or stored will be trained in the following areas at least once per year:

Identification of water priority chemicals used at the site

Preventive measures, including spill prevention and response techniques

Pollution control laws and regulations

The facility’s SWPPP

Features and operations of the facility which are designed to minimize discharges of section 313 water priority chemicals, particularly spill prevention procedures.

Spray painting will be done indoors in a paint booth to prevent overspray from potential polluting storm water run-off.


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USEPA Multi-sector General Permit requires a SWPPP and has provided extensive guidance for implementing this requirement. An entire web page is devoted to Developing SWPPPs, Reporting Monitoring Data and Annual Reports. http://cfpub.epa.gov/npdes/stormwater/msgp.cfm#msgp2008_swppp

Industrial SWPPP Guidance (PDF) (44 pp, 3.2MB) - [Final Formatted Version! (3/13/09)] Guidance on how to develop a SWPPP that meets the requirements of the 2008 MSGP.

Sample MSGP SWPPP Template (WORD) (29 pp, 148K) - Industrial facilities can now use EPA’s "Industrial SWPPP Template" to create their own SWPPPs. The Template provides step-by-step instructions for developing a SWPPP for your site, based on the requirements in the 2008 MSGP. As a reminder, all facilities must have a SWPPP completed prior to submitting their NOIs for coverage under the 2015 MSGP.

Sample Recordkeeping Templates (WORD) (22 pp, 100K) - Use the sample templates and forms in the "Additional Documentation Template" to keep records of your monitoring, inspection, maintenance, visual evaluation, and corrective action activities.

Industrial Stormwater Monitoring and Sampling Guide (PDF) (51 pp, 1.1MB) - This guide is a how-to primer for industrial operators on how to conduct visual and analytical monitoring of stormwater discharges. The guide is written to help facilities understand and comply with the 2015 MSGP monitoring requirements, but can also be used by facilities subject to different state permits.

MSGP Industrial Discharge Monitoring Report (MDMR) Form (PDF) (8 pp, 269K) – Part 7.1 requires permittees to use the electronic Net DMR system to prepare and submit your Discharge Monitoring Report (DMR) form. However, if you are given approval by the EPA Regional Office to use a paper DMR form, and you elect to use it, you must complete and submit the following form.

Annual Reporting Form (PDF) (6 pp, 234K) or (WORD) (6 pp, 240K) - Permittees are now required to submit to EPA annual reports summarizing their annual comprehensive site inspection and corrective actions taken during the year for the MSGP. EPA has developed this Annual Reporting Form, which can be used by permittees to submit this information to EPA.

Region 10 Questions and Answers about the MSGP (PDF) (26 pp, 239K) - This document provides answers to many of the commonly asked questions in Region 10 about the MSGP.


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http://water.epa.gov/polwaste/npdes/stormwater/upload/msgp_Q-A_aug2009.pdf

http://www.epa.gov/npdes/pubs/msgp2008_appendixi.doc

http://water.epa.gov/polwaste/npdes/stormwater/upload/msgp2015_appendixi.pdf

http://water.epa.gov/polwaste/npdes/stormwater/upload/msgp2015_appendixm.pdf

http://water.epa.gov/polwaste/npdes/stormwater/upload/msgp_monitoring_guide.pdf

hhttp://water.epa.gov/polwaste/npdes/stormwater/upload/msgp2015_recordkeepingtemplate.docx

http://water.epa.gov/polwaste/npdes/stormwater/upload/msgp2015_swppptemplate.docx

http://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf

http://cfpub.epa.gov/npdes/stormwater/msgp.cfm#msgp2008_swppp

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