United States 

Environmental Protection 

Agency 

Office of Water 

(4203) EPA 833-R-92-002 October 1992 

Storm Water Management 

For Industrial Activities 

Developing 

Pollution Prevention Plans 

And Best Management 

Practices 

SUMMARY GUIDANCE 

*1992* 

THE YEAR OF 

CLEAN WATER 

Celebration & 

Commitment 

Printed on Recycled Paper 
FORWARD 

This booklet provides industrial facilities with summary guidance on the development of storm water 

pollution prevention plans and identification of appropriate Best Management Practices (BMPs). It 

provides technical assistance and support to all facilities subject to pollution prevention requirements 

established under National Pollutant Discharge Elimination System (NPDES) permits for storm water 

point source discharges. 

EPA’s storm water program significantly expands the scope and application of the existing NPDES 

permit system for municipal and industrial process wastewater discharges. It emphasizes pollution 

prevention and reflects a heavy reliance on BMPs to reduce pollutant loadings and improve water 

quality. This booklet provides summary guidance in both of these areas. 

The document summarized here was issued in support of EPA regulations and policy initiatives 

involving the development and implementation of a National storm water program. The document itself 

is Agency guidance only. It does not establish or affect legal rights or obligations. Agency decisions in 

any particular case will be made applying the laws and regulations on the basis of specific facts when 

permits are issued or regulations promulgated. 

The document and this booklet will be revised and expanded periodically to reflect additional pollution 

prevention information and data on treatment effectiveness of BMPs. Comments from users will be 

welcomed. Send comments to U.S. EPA, Office of Wastewater Management, 401 M Street, SW, Mail 

Code 4203, Washington, DC 20460. 
Industrial Guidance Executive Summary 

Table of Contents 

Page 

Overview of Pollution Prevention Plan Requirements . . . . . . . . . . . . . . . . . . . . . . . . . 1 

Figure -- Seven Phases for Developing and Implementing 

Industrial Storm Water Pollution Preventions Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 

Planning and Organization Phase ....................................... 3 

(A) Forming Your Pollution Prevention Team .............................. 3 

(B) Building on Existing Environmental Management Plans .................... 3 

Assessment Phase ................................................. 5 

(A) Developing a Site Map ........................................... 5 

(B) Materials Inventory ............................................. 5 

(C) Identifying Past Spills and Leaks .................................... 6 

(D) Non-Storm Water Discharges ...................................... 6 

(E) Existing Monitoring Data ......................................... 7 

(F) Site Evaluation Summary ......................................... 7 

BMP Selection and Plan Design Phase ................................... 8 

(A) Good Housekeeping ............................................ 8 

(B) Preventative Maintenance ........................................ 8 

(C) Visual Inspections .............................................. 9 

(D) Spill Prevention and Response ..................................... 9 

(E) Sediment and Erosion Control .................................... 10 

(F) Management of Runoff ......................................... 10 

Implementation Phase .............................................. 11 

(A) Implementing Appropriate Controls ................................. 11 

(B) Employee Training ............................................. 11 

Evaluation Phase ................................................. 12 

(A) Annual Site Compliance Evaluation ................................. 12 

(B) Recordkeeping and Internal Reporting ............................... 12 

(C) Plan Revisions ............................................... 12 

General Requirements .............................................. 13 

(A) Deadlines for Plan Development and Implementation ..................... 13 

(B) Required Signatures ........................................... 13 

(C) Plan Location and Public Access ................................... 14 

(D) Director-Required Plan Modifications ................................ 14 
Industrial Guidance Executive Summary 

Table of Contents (Continued) 

Page 

Special Requirements .............................................. 15 

(A) Special Requirements for Discharges Through Municipal Separate 

Storm Sewer Systems .......................................... 15 

(B) Special Requirements for EPCRA, Section 313, Reporting Facilities .......... 15 

(C) Special Requirements for Salt Storage Piles ........................... 15 

Other References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 

Worksheet #1 -- Member Roster 

Worksheet #2 -- Developing A Site Map 

Worksheet #3 -- Material Inventory 

Worksheet #3A -- Description of Exposed Significant Material 

Worksheet #4 -- List of Significant Spills and Leaks 

Worksheet #5 -- Non-Storm Water Discharge Assessment and Certification 

Worksheet #6 -- Non-Storm Water Discharge Assessment and Failure to Certify Notification 

Model Plan 
A BRIEF GUIDE TO REQUIREMENTS FOR DEVELOPING AND IMPLEMENTING 

POLLUTION PREVENTION PLANS FOR INDUSTRIAL ACTIVITIES 

Storm water runoff is part of the natural hydrologic cycle. However, human activities, particularly 

urbanization, can alter natural drainage patterns and add pollutants to the rainwater and snowmelt that run 

off the earth’s surface and enter our Nation’s rivers, lakes, streams, and coastal waters. In fact, recent 

studies have shown that storm water runoff is a major source of the pollutants that are damaging our sport 

and commercial fisheries, restricting swimming, and affecting the navigability of many of our Nation’s 

waters. 

The States and many municipalities have been taking the initiative to manage storm water discharges more 

effectively. Recognizing the importance of this problem, Congress also directed the U.S. Environmental 

Protection Agency (EPA) to develop a Federal program under the Clean Water Act to regulate certain highpriority storm water sources. The issuance of storm water discharge permits under the National Pollutant 

Discharge Elimination System (NPDES) is a major part of the Agency’s efforts to restore and maintain the 

Nation’s water quality. Discharges of storm water runoff from industrial facilities must now be covered by 

an NPDES permit. To deal with the thousands of industrial facilities which are now required to be covered 

by storm water permits, EPA strongly encourages the use of general permits. Under the NPDES program, a 

general permit authorizes discharges from a number of sources. To address storm water discharges from 

industrial facilities located in the States and territories that have not been delegated NPDES permitting 

authority, EPA issued NPDES General Permits for Storm Water Discharges Associated with industrial 

Activity in the September 9 and September 25, 1992, Federal Register. (A complete list of these States 

and territories to which EPA’s permits apply may be found on page 16 of this document.) 

Under the NPDES General Permit for Storm Water Discharges Associated with Industrial Activity, EPA 

requires the development and implementation of a pollution prevention plan - designed to reduce pollution 

at the source, before it can cause environmental problems that cost the public and private sectors in terms 

of lost resources and expensive environmental restoration activities. 

OVERVIEW OF POLLUTION PREVENTION PLAN REQUIREMENTS 

This guide provides background information on pollution prevention planning requirements for permit-tees 

under the general permit. As shown on the chart on the following page, pollution prevention plan 

requirements provide you with a step-by-step process for ensuring that pollutants are not making their way 

into the storm water discharges from your site. Specifically, the pollution prevention plan requires that you 

select and implement Best Management Practices (BMPs). BMPs include schedules of activities, 

prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce 

the pollution in runoff from your site. The five major phases of developing a pollution prevention plan are 

(1) planning and organization; (2) assessment; (3) BMP selection and plan design; (4) implementation; and 

(5) evaluation and site inspection. A set of worksheets and a model plan at the end of the document are 

provided to further clarify pollution prevention plan requirements. All permit holders under EPA’s NPDES 

General Permit for Storm Water Discharges Associated with Industrial Activity must meet a number of 

general requirements. In addition, permittees who are subject to reporting requirements under Section 313 

of the Emergency Planning and Community Right-to-Know Act (EPCRA), (also known as Title 3 of the 

Superfund Amendment and Reauthorization Act [SARA]), will have to meet special requirements under 

EPA’s general permit. These requirements are listed in boxes throughout this guide, and then elaborated 

upon in the final section. 

A more detailed manual on how to develop and implement a pollution prevention plan is available at a 

modest cost from the National Technical Information Service. The manual, titled Storm Water 

Management for Industrial Activities: Developing Pollution Prevention Plans and Best Management 

Practices, provides much more specific information than this brief guide. Instructions for ordering the 

detailed manual and a listing of other references that you may find useful can be found at the end of this 

guide. 

October 1992 Page 1 
PLANNING AND ORGANIZATION 

• Form Pollution Prevention Team 

• Review other plans 

ASSESSMENT PHASE 

• Develop a site map 

• Inventory and describe exposed materials 

• List significant spills and leaks 

• Test for non-storm water discharges 

• Evaluate monitoring data 

• Summarize pollutant sources and risks 

BMP IDENTIFICATION PHASE 

• Baseline BMPs 

• Select activity- and site-specific 

BMPs 

IMPLEMENTATION PHASE 

• Implement BMPs 

• Train employees 

EVALUATlON/MONlTORlNG 

• Conduct annual site inspection/BMP evaluation 

• Conduct recordkeeping and reporting 

• Review and revise plan 

GENERAL REQUIREMENTS SPECIAL REQUIREMENTS 

• Develop schedule 

• Obtain required signatures 

• Follow plan location and public 

access requirements 

• Modify plan 

• Plan for discharges through MS4s 

• Plan for EPCRA, Section 313 

facilities 

• Plan for salt storage piles 

SEVEN PHASES FOR DEVELOPING AND IMPLEMENTING INDUSTRIAL STORM 

WATER POLLUTION PREVENTION PLANS 

October 1992 Page 2 
PLANNING AND 

ORGANIZATION PHASE 

Before you start putting your Storm Water Pollution Prevention Plan together, there are two steps that 

will facilitate the development of your plan. These steps are designed to help you organize your staff 

and make preliminary decisions: (A) decide who will be responsible for developing and implementing 

your Storm Water Pollution Prevention Plan, and (B) look at other existing environmental facility plans 

for consistency and overlap. 

(A) Forming Your Pollution Prevention Team 

As part of developing and implementing your pollution plan, you should (1) designate a specific individual 

or team who will develop, implement, maintain, and revise your pollution prevention plan, and (2) identify 

these individuals and describe each person’s responsibilities at the site. 

Since facilities differ in size and capacity, the number of team members will also vary. Designating one 

person may be appropriate as long as that individual is qualified to design and implement the plan. The 

plan should identify those people on site who are most familiar with the facility and its operations; these 

people, in turn, should provide structure and direction to the storm water management program. In all 

cases, someone in a senior management position must have overall responsibility for the plan. 

The pollution prevention team is responsible for the following: 

l Implementing all general permit and pollution prevention plan requirements 

l Defining and agreeing upon an appropriate set of goals for the facility’s storm water management 

program 

l Being aware of any changes that are made in plant operations to determine whether any changes 

must be made to the Storm Water Pollution Prevention Plan 

l Maintaining a clear line of communication with plant management to ensure a cooperative 

partnership. 

Worksheet #1 (located at the end of this guide) is an example of an appropriate form on which to list 

the team members. To complete- this worksheet, list the pollution prevention team members by name, 

facility position (title), and phone number; include a brief description of each member’s specific 

responsibilities. This list can be directly incorporated into the Storm Water Pollution Prevention Plan, but it 

should also be displayed or posted within the facility so that other plant employees are aware of who is 

responsible for storm water management. 

(B) Building on Existing Environmental Management Plans 

The pollution prevention team also must evaluate existing environmental management plans for 

consistency and determine which, if any, provisions can be incorporated into the Storm Water Pollution 

Prevention Plan. 

Other related plans may include the Preparedness, Prevention and Contingency Plan (40 CFR Parts 264 and 

265), the Spill Control and Countermeasures requirements (40 CFR Part 112), the National Pollutant 

October 1992 Page 3 
Discharge Elimination System Toxic Organic Management Plan (40 CFR Parts 413, 433, and 469), and the 

Occupational Safety and Health Administration (OSHA) Emergency Action Plan (29 CFR Part 1910). 

Although you should build on relevant portions of other environmental plans as appropriate, it is important 

to note that your Storm Water Pollution Prevention Plan must be a comprehensive, stand-alone document, 

ADDITIONAL REQUIREMENTS FOR FACILITIES SUBJECTO REPORTING UNDER EPCRA, SECTION 313, FOR WATER 

PRIORITY CHEMICALS - EPCRA contains additional reporting requirements for designated hazardous waste 

management facilities. EPA’s Baseline General Permit contains the following specific requirements for 

such facilities: 

• The team must designate a person who will be accountable for spill prevention at the facility 

and identify this person in the plan. 

• The designated person is responsible for setting up necessary spill emergency procedures and 

reporting requirements to isolate, contain, and clean up spills and emergency releases of 

Section 313 water priority chemicals. 

October 1992 Page 4 
ASSESSMENT PHASE 

After identifying who is responsible for developing and implementing your plan and organizing your 

planning process, you should proceed to this next step-a pollutant source assessment. This is where 

you take a look at your facility and determine what materials or practices are (or may be) a source of 

contaminants to the storm water running off your site. To complete this phase, you will (A) create a 

map of the facility site to locate pollutant sources and determine storm water management 

opportunities, (B) conduct a material inventory, (C) evaluate past spills and leaks, (D) identify non-storm 

water discharges and illicit connections, (E) collect or evaluate storm water quality data, and 

(F) summarize the findings of this assessment. To select the most appropriate and effective control 

measures, consider that potential pollutant sources include areas where materials are handled or stored, 

outdoor processing areas, loading and unloading areas, and onsite waste management and disposal 

areas. 

(A) Developing a Site Map 

A site map is a complete illustration of site features. At a minimum, the site map must include information 

on the following: 

• Discharge points (“outfalls”) 

• Drainage patterns 

• Identification of the types of pollutants likely to be discharged for each drainage area 

• Direction of flow 

• Surface water bodies, including any proximate stream, river, lake, or other water body receiving 

storm water discharges from the site 

• Structural control measures (physically constructed features used to control storm water flows) 

• Locations of significant materials exposed to storm water 

• Locations of industrial activities (such as fueling stations, loading and unloading areas, vehicle or 

equipment maintenance areas, waste disposal areas, storage areas). 

Worksheet #2 (located at the end of this guide) provides guidance on completing your site map. 

(B) Materials Inventory 

Each facility must inventory the types of materials that are handled, stored, or processed onsite. 

“Significant materials’ are of particular concern and are defined as follows: 

Significant Materials: Raw materials; fuels; materials such as solvents, detergents, and plastic 

pellets; finished materials such as metallic products; raw materials used in food processing or 

production; hazardous substances designsted under section 101(14) of CERCLA; any chemical 

the facility is required to report pursuant to EPCRA, Section 313; fertilizers; pesticides; and 

waste products such as ashes, slag, and sludge that have the potential to be released with 

storm water discharges [40 CFR 122.26(b)(12)]. 

October 1992 Page 5 
To complete the materials Inventory, the facility must do two specific tasks: 

• List materials that have been exposed to storm water in the past 3 years (focus on areas where 

materials are stored, processed, transported, or transferred). 

• Provide a narrative description of methods and location of storage and disposal areas, materials 

management practices, treatment practices, and any structural/nonstructural control measures. 

• Structural practices are fixed equipment such as berms, detention ponds, or grassed swales. 

• Nonstructural practices may include regularly scheduled actions such as sweeping or 

inspections. 

Worksheet #3 (located at the end of this guide) will assist you in conducting a material inventory for 

your Storm Water Pollution Prevention Plan. If any of the significant materials on your site have been 

exposed to storm water in the 3 years prior to the effective date of your permit, complete Worksheet 

#3A and include it in your plan. 

(C) Identifying Past Spills and Leaks 

Provide a list of significant spills and leaks of toxic or hazardous that have occurred in the past 3 years. 

“Significant spills” includes releases in excess of reportable quantities, defined as follows: 

Reportable Quantity (RQ) Discharge: An RQ release occurs when a quantity of a hazardous substance 

or oil is spilled or released within a 24-hour period of time and exceeds the RQ level assigned to that 

substance under CERCLA or the Clean Water Act. These levels or quantities are defined in terms of 

gallons or pounds. Regulations listing these quantities are contained at 40 CFR 302.4, 40 CFR 

117.21 and 40 CFR 110. 

Permittees are encouraged to list spills and leaks of nonhazardous materials as well as spills of hazardous 

materials in their pollution prevention plans. 

Worksheet #4 (located at the end of this guide) can help you organize this list of leaks and spills. The 

areas on your site where significant leaks or spills have occurred are areas on which you should focus very 

closely when selecting BMPs. 

(D) Non-Storm Water Discharges 

To certify that your facility has been tested or evaluated for non-storm water discharges, you must: 

• Identify potential non-storm water discharges 

• Describe the method used and results of any test and/or evaluation for such discharges 

• Indicate the location of the onsite drainage points that were checked during the test or evaluation 

• Provide the date of the test or evaluation. (If you cannot test or evaluate potential non-storm 

water discharges, notice must still be made by certification.) 

October 1992 Page 6 
Examples of non-storm water discharges include any water used directly in the manufacturing process 

(process water), air conditioner condensate, noncontact cooling water, vehicle wash water, or sanitary 

wastes. 

To check for non-storm water discharges, you can use one of the following three common dry weather 

tests: visual inspection; plant schematic review; and/or dye testing. 

Worksheet #5 (located at the end of this guide) will assist you in conducting a non-storm water 

discharge assessment and certification for outfalls at your site. If you are unable to test and/or provide 

certification for the presence of non-storm water discharges, please refer to Worksheet #6. 

(E) Existing Monitoring Data 

Where existing storm water sampling data are available, the facility must (1) provide a summary of any 

existing storm water sampling data and (2) describe the sample collection procedures used. 

(F) Site Evaluation Summary 

This step is critical, as it will become the foundation for the rest of the Storm Water Pollution Prevention 

Plan. Facilities must fulfill the following requirements: 

l Provide a narrative description of activities with a high potential to contaminate storm water at 

your site, including those associated with materials loading and unloading, outdoor storage, 

outdoor manufacturing or processing, onsite waste disposal, and significant dust or paniculatr 

generating activities 

l Describe any pollutants of concern that may be associated with such activities. 

Once you have completed the above steps in your pollutant source assessment, you should have enough 

information to determine which areas, activities, or materials may contribute pollutants to storm water 

runoff from your site. With this information, you can select the most appropriate BMPs to prevent or 

control pollutants from these areas. 

ocrobu 1992 P*ge 7 
BMP SELECTION AND 

PLAN DESIGN PHASE 

Once you have identified and assessed potential and existing sources of storm water contamination at 

your facility, the next step is to select the proper Best Management Practices (BMPs) that will address 

these pollutant sources. To satisfy the requirements of this phase, you must provide a narrative 

description of the BMPs you have selected for your site. At a minimum, your plan must incorporate the 

following eight “baseline” BMPs: (A) good housekeeping, (B) preventive maintenance, (C) visual 

inspections, (D) spill prevention and response, (E) sediment and erosion prevention, (F) traditional storm 

water management practices, (G) other BMPs as appropriate, (H) employee training, and 

(I) recordkeeping and reporting. A number of these BMPs are discussed below. 

(A) Good Housekeeping 

Good housekeeping practices are designed to maintain a clean and orderly work environment. Often the 

most effective first step towards preventing pollution in storm water from industrial sites involves merely 

using good common sense to improve the facility’s basic housekeeping methods. The following are some 

simple procedures that a facility can consider incorporating into an effective good housekeeping program: 

• Improve operation and maintenance of industrial machinery and processes. 

• Implement careful material storage practices. 

• Maintain up-to-date material inventory. 

• Identify all chemical substances present in the workplace. 

• Label all containers showing name and type of substance, stock number, etc. 

• Schedule routine cleanup operations. 

• Maintain well-organized work areas. 

• Train employees about good housekeeping practices. 

(B) Preventive Maintenance 

Each permittee must develop a preventive maintenance program that involves inspections and maintenance 

of storm water management devices and routine inspections of facility operations to detect faulty 

equipment. Equipment (such as tanks, containers, and drums) should be checked regularly for signs of 

deterioration. 

October 1992 Page 8 
EPCRA, SECTION 313, FACILITY PREVENTIVE MAINTENANCE INSPECTION REQUIREMENTS -All areas of the 

facility must be inspected for the following at appropriate intervals as specified in the plan: 

• Leaks or conditions that would lead to discharges of Section 313 water priority chemicals 

• Conditions that could lead to direct contact of storm water with raw materials, intermediate 

materials, waste materials or products 

• Piping, pumps, storage tanks and bins, pressure vessels, process and material handling 

equipment, and material bulk storage areas for leaks, wind blowing, corrosion, support or 

foundation failure, or other deterioration or noncontainment. 

(C) Visual Inspections 

Regular visual inspections are your means to ensure that all of the elements of the plan are in place and 

working properly to prevent pollution of storm water runoff from your facility. Consider the following 

when conducting visual inspections: 

• Designate qualified, trained plant personnel to regularly inspect the facility’s equipment and areas, 

track results of inspections, make necessary changes, and maintain records of all inspections 

• Ensure that inspection records note when inspections ware done, who conducted the inspection, 

what areas ware inspected, what problems were found, and what steps were taken to correct any 

problems. 

These records should be kept with the plan. EPA’s general permit requires that records be kept until at 

least one year after coverage under the permit expires. 

(D) Spill Prevention and Response 

Areas where spills are likely to occur and their drainage points must be clearly identified in the storm water 

pollution prevention plan. You should ensure that employees are aware of response procedures, including 

material handling and storage requirements. Also ensure that there is access to appropriate spill cleanup 

equipment. 

SPILL PREVENTION PLAN CONSIDERATIONS: 

• Install leak detection devices. 

• Adopt good housekeeping practices. 

• Perform regular visual inspections to identify areas for potential leaks or spills. 

• Recycle, reduce, and reuse process materials to minimize waste onsite. 

October 1992 Page 9 
SPILL RESPONSE PIAN CONSIDERATIONS: 

l Identify a spill response team to implement the spill response plan. 

l Identify safety measures. 

l Include procedures for notifying appropriate authorities (police, fire, hospital, Publiclv Owned 

Treatment Works [POTWI, etc.) in the event of a spill. 

l Describe spill contammant, diversion, isolation, and cleanup practices. 

EPCRA, SECTION 313, FACILITY SPIU PREVENTI~ AND RESPONSE REaUatEMENTS- When a leak or spill of a 

Sectlon 313 water priority chemical has occurred, the contaminated soil, material, or debris must be 

removed promptly and disposed of in accordance with Federal, State, and local requirements and as 

described in the Storm Water Pollution Preventron Plan. These facilities are also required to designate a 

person responsible for spill prevention, response, and reponing procedures. 

(E) Sediment and Erosion Control 

The facilitv’s pollution prevention plan must identify activities that present a potential for significant soil 

erosion and measures taken to control such erosion. More information on sediment and erosion control 

BMPs can be found in the reference section of this guide. 

(F) Management of Runoff 

Perminaes must describe existing storm water controls found at the facility and any additional measures 

that can be implemented to improve the prevention and control of polluted storm water. Examples include: 

vegetative swales, reuse of collected storm water, infiltration trenches, and detention ponds. 

octobsr 1992 P8ga 70 
IMPLEMENTATION PHASE 

At this point, you have designed your Storm Water Pollution Prevention Plan and the plan has been 

approved by facility management. Under the implementation phase, you must (A) implement the 

selected storm water BMPs, and (B) train all employees to carry out the goals of the plan. 

(A) Implementing Appropriate Controls 

In implementing the plan, a facility will: 

• Develop a schedule for implementation. For example, your schedule might include a deadline for 

putting improved housekeeping measures into practice. Some controls may be immediately put 

into action; others will be phased in. 

• Assign specific individuals with responsibility for implementing aspects of the plan and/or 

monitoring implementation. 

• Ensure that management approves of your implementation schedule and strategy, and schedule 

regular times for reporting progress to management. 

(B) Employee Training 

Permittees must develop an employee training program that covers such topics as spill prevention and 

response, good housekeeping, and material management practices. 

The goals of a training program are to teach personnel, at all levels of responsibility, the components and 

goals of the storm water pollution prevention plan and to create overall sensitivity to storm water pollution 

prevention concerns. The plan must include a schedule for training programs. 

EPCRA, SECTION 313, FACILITY REQUIREMENTS-There are additional training requirements for employees 

and contractor personnel who work in areas where EPCRA, Section 313, water priority chemicals are 

used or stored. These individuals must be trained in the following areas, at least once per year: 

l Preventive measures, including spill prevention and response and preventive maintenance 

• Pollution control laws and regulations 

• The facility’s Storm Water Pollution Prevention Plan 

• Features and operations of the facility that are designed to minimize discharges of Section 313 

water priority chemicals, particularly spill prevention procedures. 

October 1992 Page 11 
EVALUATION PHASE 

Now that your Storm Water Pollution Prevention Plan has been put to action, you must keep it up-todate by regularly evaluating the information you collected in the Assessment Phase and the controls 

you selected in the Plan Design Phase. Specifically, you must (A) conduct site evaluations, (B) keep 

records of all inspections and reports, and (C) revise the plan as needed. 

(A) Annual Site Compliance Evaluation 

Qualified personnel must conduct site compliance evaluations at appropriate intervals, but at least once a 

year (at least once in 3 years for inactive mining sites). As part of your compliance evaluations, you are 

required to carry out the following: 

Inspect storm water drainage areas for evidence of pollutants entering the drainage system. 

Evaluate the effectiveness of BMPs (for example, determine if your site cleaner or gauge whether 

employees are more familiar with good housekeeping measures and spill prevention/response 

practices). 

Observe structural measures, sediment controls, and other storm water BMPs to ensure proper 

operation. 

Revise the plan as needed within 2 weeks of inspection, and implement any necessary changes 

within 12 weeks of the inspection. 

Prepare a report summarizing inspection results and followup actions, identifying the date of 

inspection and personnel who conducted the inspection. 

Sign the report and keep it with the plan. 

(B) Recordkeeping and Internal Reporting 

Your facility must record and maintain records of spills, leaks, inspections, and maintenance activities for 

at least one year after the permit expires. For spills and leaks, records should include information such as 

the date and time of the incident, weather conditions, cause, and resulting environmental problems. 

(C) Plan Revisions 

Major changes in a facility’s design, construction, operation, or maintenance will necessitate changes in 

that facility’s Storm Water Pollution Prevention Plan. 

October 1992 Page 12 
GENERAL REQUIREMENTS 

I 

This section provides guidance on some of the administrative requirements related to organizing and 

developing your Storm Water Pollution Prevention Plan. The guidance covers (A) deadlines for plan 

development and implementation, (B) required signatures, (C) requirements for plan location and 

access, and (D) Director-required plan modifications. 

(A) Deadlines for Plan Development and Implementation 

Schedule for Plan Development and Implementation 

Part IV.A. 

Deadline for Plan Deadline for Plan 

Type of Facility Development Implementation 

Facilities discharging storm water 

associated with industrial activity April 1, 1993 October 1, 1993 

on or before October 1, 1992 

Facilities beginning to discharge 60 days after 60 days after 

storm water after October 1, commencement of discharge commencement of discharge 

1992, but on or before 

December 31, 1992 

Facilities beginning to discharge 

storm water associated with 

industrial activity on or after 

January 1, 1993 

48 hours prior to 48 hours prior to 

commencement of discharge commencement of discharge 

(upon submittal of NOI) (upon submittal of NOI) 

Oil and gas exploration, 

production, processing, or 

treatment operations discharging 

a reportable quantity release in 

storm water after October 1, 

1992 

Industrial facilities rejected or 

denied from the group application 

process 

60 days after release 60 days after release 

365 days after date of 545 days after date of 

rejection or denial rejection or denial 

Note: The Director may grant a written extension for plan preparation and compliance for new 

dischargers (after October 1, 1992) upon showing of good cause. 

(B) Required Signatures 

As with the Notice of Intent (NOI), your plan must be signed by an “authorized representative,” who is a 

person at or near the top of your facility’s management chain (the president, vice president, or a 

production manager) who has been delegated the authority to sign and certify this type of document. 

October 1992 Page 13 
EPCRA, Section 313, Facility Plan Certification Requirements-The plan must be reviewed and certified 

by a Registered Professional Engineer and recertified every 3 years or after the plan is significantly 

changed. This certification that the plan was prepared in accordance with good engineering practices 

does not relieve the facility owner or operator of responsibility to prepare and implement the plan, 

however. 

(C) Plan Location and Public Access 

Although all plans are required to be maintained onsite, some NPDES storm water permits may require that 

facilities submit copies of their Storm Water Pollution Prevention Plans to the Director for review. Examine 

your permit carefully to determine what submittal requirements apply to your facility. Plans and all 

required records must also be kept at least one year after the permit expires. 

(D) Director-Required Plan Modifications 

Upon reviewing your plan, the permitting authority may find that it does not meet one or more of the 

minimum standards established by the pollution prevention plan requirements. In this case, the permitting 

authority will notify you of the changes that you must make to improve the plan. 

October 1992 Page 14 
SPECIAL REQUIREMENTS 

In addition to the minimum “baseline” BMPs discussed in previous sections, facilities may be subject to 

additional “special” requirements. Not all facilities will have to include these special requirements in 

their Storm Water Pollution Prevention Plan. Be sure to check your permit closely for these conditions. 

In particular, EPA’s general permit includes special requirements for (A) facilities that discharge storm 

water through municipal separate storm sewer systems, (B) facilities subject to EPCRA, Section 313, 

reporting requirements, and (C) facilities with salt storage piles. 

(A) Special Requirements for Discharges Through Municipal Separate Storm Sewer 

Systems 

Industrial facilities that discharge storm water through a large or medium municipal separate storm sewer 

system (serving a population of 100,000 or more) must comply with any applicable conditions established 

by the municipality’s storm water management program. These facilities will be notified by the 

municipality. Examples of conditions could include additional monitoring requirements and/or additional 

source control requirements. 

(B) Special Requirements for EPCRA, Section 313, Reporting Facilities 

In addition to the other special requirements identified in this guide, the following specific control 

requirements must be practiced in areas where Section 313 water priority chemicals are stored, handled, 

processed, or transferred: 

• Provide containment, drainage control, end/or diversionary structures (prevent or minimize runon 

by installing curbing, culverting, gutters, sewers, or other controls, and/or prevent or minimize 

exposure by covering storage piles). 

• Prevent discharges from liquid storage areas (store liquid materials in compatible storage 

containers and/or provide secondary containment designed to hold the volume of the largest 

storage tank plus precipitation). 

• Prevent discharges from material storage areas (install drainage and/or other control measures). 

• Prevent discharges from loading/unloading areas (use drip pans and/or implement a strong spill 

contingency and integrity testing plan). 

• Prevent discharges from handling/processing/transferring areas (use covers, guards, overhangs, 

door skins and/or conduct visual inspections or leak tests for overhead piping). 

• Prevent discharges from all the above areas (use manually activated valves with drainage controls 

in all areas, and/or equip the plant with a drainage system to return spilled material to the facility). 

• Introduce facility security programs to prevent spills (use fencing, lighting, traffic control, and/or 

secure equipment and buildings). 

(C) Special Requirements for Salt Storage Piles 

Salt storage piles used for deicing or other commercial purposes must be enclosed or covered to prevent 

exposure to storm water (except when salt is being added or removed from the pile). Please note that 

piles do not need to be enclosed or covered where storm water is not discharged to waters of the United 

Sates. Compliance with this requirement must be met as expeditiously as practicable, but no later than 3 

years after the NOI is submitted. 

October 1992 Page 15 
OTHER REFERENCES 

In addition to this summary, other documents are available to assist in the preparation and 

implementation of pollution prevention plans. These documents include the guidance manual Storm 

Water Management for Industrial Activities. Developing Pollution Prevention Plans and Best 

Management Practices (EPA 832-R-92-006, September 1992), which is available from the National 

Technical Information Service [NTIS Order No. PB 922 359 69] at (703) 487-4650. 

For any other information and guidance, please call EPA’s National Storm Water Hotline at 

(703) 821-4823. From the Hotline, you may obtain numerous documents, including: 

• September 9, 1992, Federal Register (57 FR 41236) - Final NPDES General Permits for Storm 

Water Discharges Associated with Industrial Activity; Notice 

- Applicability: 

For the States of Alaska, Arizona, Florida, Idaho, Louisiana, Maine, New Hampshire, New 

Mexico, Oklahoma, South Dakota and Texas; for Indian lands located in Alaska, Arizona, 

California, Colorado (including the Ute Mountain Reservation in Colorado), Florida (two tribes), 

Idaho, Maine, Massachusetts, Mississippi, Montana, New Hampshire, Nevada, North Carolina, 

North Dakota, Utah, Washington and Wyoming; for Federal facilities in Colorado and 

Washington; for Federal facilities and Indian lands in Louisiana, New Mexico, Texas, and 

Oklahoma; and for the territories of Johnston Atoll, and Midway and Wake Island. 

• September 25, 1992, Federal Register (57 FR 44438) - Final NPDES General Permits for Storm 

Water Discharges Associated with Industrial Activity; Notice 

- Applicability: 

For the States of Massachusetts and Puerto Rico; for American Samoa and Guam; for Indian 

lands located in New York; and for Federal facilities in Delaware. 

October 1992 Page 16 
POLLUTION PREVENTION TEAM Worksheet #1 

Completed by: 

Title: 

MEMBER ROSTER Date: 

Leader: Title: 

Dffico Phono: 

Responsibilities: 

Members: 

(11 Tide: 

Office phone: 

Responsibitities: 

I21 Tide: 

Office Phone: 

Responsibilities: 

(31 Title: 

Office Phone: 

Responsibilities: 

(4) Tttle: 

offko PIlana: 

Responsibilities: 
Worksheet #2 

DEVELOPING A SITE MAP 

Completed by: 

Title: 

Date: 

I Instructions: Draw a map of your sit8 including a footprint of all buildings, structures, paved areas, and 

parking lots. The information below describes additional elements required by EPA’s General 

Permit. 

EPA’s General Permit requires that you indicate the following features on your site map: 

l All ourfalls and storm water discharges 

l Drainage areas Of each Storm water Outfall 

l Structural storm water pollution control m8asures, such as: 

- Flow diversion StruCtur8s 

- Ret8nticWdet8ntiOn ponds 

- Vegetative swales 

- Sediment traps 

l Name of receiving waters (or if through a Municipal Separate Storm Sewer System1 

l Locations of 8XpOSed significant materials 

l Locations of past spills and leaks 

l Locations of high-risk, waste-generating areas and activities common on industrial sites such as: 

Fueling stations 

Vehicle/equipment washing and maintenance areas 

Area for unloading/loading materials 

Above-ground tanks for liquid storage 

Industrial waste management areas (landfills, waste piles, treatment plants, disposal areas) 

Outside storage areas for raw materials, by-products, and finished products 

Outside manufacturing areas 

Other areas of concern (specify: I 
MATERIAL INVENTORY 

Worksheet #3 

Completed by: 

Title: 

Date: _ 

- 

.-.-- -- .------ I 

Instructions: List all materials used, stored, or produced onsite. Assess and evaluate these materials for thclr potential to contrlbute pollutants to 

storm water runoff. Also complete Worksheet 3A if the material has been exposed during the last 3 years. 

I I Quantity I I Part Slgnthcant 

Material 

(unitsI Quantity Expoced in Last Likelihood of contact with ctorm water If Sprll or Leak 

Lkd Rodusd ‘8OWd 3 Yaarn ysr. deccrtbe raamon. Ye* NO 
Worksheet #3A 

Completed by: ___ _------. DESCRIPTION OF EXPOSED SIGNIFICANT MATERIAL -.-_ 

Title: 

Date: _ .- - ..-----__ ..____ __-____. -.-- - __-_ 

Instructions: Based on your material inventory, describe the signlflcant materials that were exposed to storm waler during the oust three years 

and/or are currently exposed. For the definition of “signlflcant materials’ see page 5 of this summary. 

Quantity Location Method of Storage or 

Dmcription of Expoeod Period of Erpooed lu indicated on tha aice Dupoal I. g , pal., drum, Dercnpcwn of Makrml Manayc~rmt Practice (e g . pll. 

Signiticant Mater4 EXp0.W. lunit9l m*pl tnnkl covered, drum sealed) 

- 
Worksheet #4 

LIST OF SIGNIFICANT SPILLS AND LEAKS Completed by: 

Title: 

Date: 

Directions: Record below all significant spills and significant leaks of toxic or hazardous pollutants that have occurred at the facilltv in the three 

years prior to the effective date of the permit. 

Definitions: Significant spills include, but are not limited to, releases of d or hazardoussubstances in excess ofreportable quantities. 

1st Year Pnor 

Descrlptlon Response Procudtrru 

Locatu3n 

Matmd No Preventive 

Date 

Amount of 1ong.r Expoaad 

(an indicated on l it* Measurati 

lmonrh/day/y.u) Spill Leak 

M*1*rml tu Slorm Wbtsr 

mbf.4 Typa of hImtonal QU*lltltV Sourcs. 11 Known Roaron Recowrad (Irum/f l Im4 Taken 

2nd You Prim 

Descrlptlon Response Procedure 

Location 

Matmal No 

Amount 01 1ong.r Lxpond Preventive 

DbW (aa indicatmd on rita 

lmnth/d~v/v,rl Spill Leak 

MatWlal to storm Wa1.r Measures 

m-1 Typa 01 Matmal Cb~htV INC.. II Known lhb*Oll fbcourrmd (Two/F&a) Taken 

- 

I 

3rdYOURior 

Deecrption Response Procedure 

Location 

Mbtohl No 

Preventive 

Dara 

Amount of Longer Ellpowd 

IH hdicbtd on .llm 

bnonthldavlvwrl SpiN Leak 

Mmcanol lo storm Watu Measures 

nup) Type 01 Matwial (lumtltv Soumm. U Known fbwon fbc0vw.d (TlUiFJwt Taken 
I NON-STORM WATER DISCHARGE 

ASSESSMENT AND CERTIFICATION 

Outfall Directly 

Date of Observed During the Method Used to 

Test or Test hdsntlty as md~carad on Test or Evaluate 

Evaluation Ihe cute map) Discharge 

Worksheet #5 

Completed by : -- - 

Title: 

Date: -. .~ 

I I 

Describe Results from Test for 

the Presence of Non-Storm 

Water Discharge 

Identify Potential 

Sigmficant Sources 

Name nf Person Who 

Conducted the Test or 

Evaluation 

I CERTIFICATION 

I. (responsible corporate official), 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 assure that qualified personnel properly gather and evaluate 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 fine and imprisonment for knowing violations. 

A. Name & Official Title ltype or print) B. Area Code and Telephone No. 

I C. Signature I 

D. Date Signed 
Worksheet #6 

NON-STORM WATER DISCHARGE ASSESSMENT AND 

FAILURE TO CERTIFY NOTIFICATION 

Completed by: 

Title: 

Date: 

Directions: If you cannot feasibly test or evaluate an outfall, fill in the table below with the appropriate information and sign this form to certify the 

accuracy of the included information. 

List all outfalls not tested or evaluated, describe any potential sources of non-storm water pollution from lrsted outfalls, and state the reason(s) why 

certification is not possible. Use the key from your site map to identify each outfall. 

Important Notice: A copy of this notification must be signed and submitted to tht Director within 180 days of the tfftctivt date of this permit. 

Identify Outfall Not 

Tested/Evaluated 

Description of Why Certification 

Is lnftasible 

Description of Potential Sources of NonStorm Water Pollution 

CERTIFICATION 

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 gather and evaluate 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 fine and imprisonment for knowing violations, and that such notification has been made to the Director within 180 days of 

(date permit was issued), the effective date of this permit. 

A. Name & Official Title hype or print) 8. Area Code and Telephone No. 

C. Signature D. Date Signed 
~oublo lcoop faa Cram c08pany 

40 roaha Drito 

Aaptoua, 01 1234s 

ato- mator Pollution Prmvontioa P18a 

Emergency Contact: ch0qi ai0m Work Phom: (101) 111-1231 

Title: plant mnagor Emergency Phone: (101) sss-6929 

Secondary Contact: R8chel M@pr8 Work Phone: (101) sss-2923 

Tltlo: lnginoaring l upwvi8or Emergency Phone: (101) sss-6789 

Type of Manufacturer: Iao Crou M8nufacturar 

. 1 

Operating Schedule: otoo l .8. - 11830 0.8. 

. 

Number of Employoas: The pl8at h8r 2l uplopam, facludiag put 

tira 8hff. l hiftr OvmrlrD 811 d8Y. 

Average Wastouator Dbcharqm: 1,000 g8lloar par rook 

WPBES Pannit Wumbrr: OXl~llSlf 
POLLUTION PREVENTION TEAM Workshat #I 

Complotod br: &@w/ &dn 

Tid.: / 

MEMBER ROSTER Da tr : -G-H,- 

L 
I - - 
ato- w8tOr POllUtiOB PravOnti0n ?lm 

Corp8riSOB with WCC Pl8a 

Double Scoop Xc8 Cram Plant has an SPCC plan in operation for its 

aboveground fual 8tOraga t8nk. Owrlaps at8 noted belov: 

8 Isaac Faldman is the SPCC Coordinator and reports directly 

to Cheryl Glmn. He vi11 ba the Storra Water Spill 

prevention and RSsponSe Coordinator. 

8 A complete description of potential for oil to contaminate 

storm water dischargm including qurntity of oil that could 

ba discharged. 

8 Curbing 8round 8boVagrOUnd fuel storage t8nk identified on 

8ita ID8p. 

l Expandad SPCC schedules rnd procedures to include storm 

Water Pollution Pravmtion Pl8n rquireamts. 

0 Incorporated SPCC pl8n trrfning into storm watar training 

programs on spill prevention and rasponsa. 

0 Ralwant portions of tha SPCC pl8n will be included in this 

plan. 
DEVELOPlNQ A SITE MAP 

I Instructions: Draw a map of your sits including a footprint of all buildings, structurss, prvd areas, and 

prrtcrng lots. Thr information bslow doscribos addiaonrl elemsnts rsquirsd by EPA’s G~nwai 

Permit Isee exam& maps rn Fioures 2.3 and 2.41. 

~ EPA’s Gansral Permit requires that you indicats the following featurss on your sits map: 

l All outfallr a,.d storm watsr dischrrgsr 

l Drainrgs l raa8 of rsch storfn watsr outfall 

l Structural storm wstsr pollution contrd msssufss, such as: 

- Flow divrrrion structurss 

- Rotsntion/dotsntion ponds 

- Vegststive rwaks 

- Sodimsnt traps 

l Name of rscoiving wsters (or if through a Municipal Sepsrato Stem Sswr Svstoml 

l Locations of l xposod significsnt nutsri8is (sss Sectiorr 2.2.2) 

l Locations of past spills and Is&s hs !hction 2.2.3) 

l Locations of high-risk, wssts-gonsfsting sfsss and scdvit& common on industrisl sites such as: 

Fueling stations 

Vohidr/aquipment wsshing md rnsintmsncs arus 

Ares for unlosdingllording msmriJI 

Aboveground #n&s far i&d w 

Industri4 wuta rnv arm8 WtdfMs, wuu pdu, tfumont plants, disposal areas) 

Outsida storage mu fw raw mmrials, by-product& and finishsd products 

Outsido msnufscn&tg w11 

Othw arms of concun bpscifv: I 
i 

i 

i 

i 

i 

i 

i 

i 

i . I 

i 

i 

i 

i . I I I I 

PRLBMP SITE MAP 

MARCH 1.1993 
i i 

i 

i 

I 

i 

I 

i 

I 

i 

i 

. I 

i 

i . I . I 

, 
I 

Workstteet #3 

MATERIAL INVENTORV 

I 

I Irutructions: List au mat.riJI d, wmd, or produced onute. Assess and rvaluatr these m 

storm watt rudf. NW compkto Worksheet 3A if the material has boon l xpor 

teds for theu potentml IO contrrbuto pollutants to 

J durina ~ha last three wars. I 
Worksheet 13 

MATERIAL INVENTORY 

Instructbons: List all motordo used. stotad, or produced onrite. Assess and eVdUate these matewls for the;- porenttal 10 corwlbute pollutants IO 

storm uvatar rwoff. Also complete Worksheet 3A if the material has been exposed during the last three years 
Worhheat 13A 

DESCRIPTION Of EXPOSED SIGNIFICANT MATERIAL 

krstructioms: Bwed on your matwial invntory, describe the signiftcant materbais that wue exposed to stoun water during the past three years 

ndlot are currontlv l xposod. For lhe definition of ‘signlrtcmt matertab see Appendtx B of the manual. 0 

onoqrnmc hwuu It 0. 

-. 

-.-. -.. 

- .- -- -_ -- 

NON-STORM WATER DISCHARGE 

ASSESSMENT AND CERTIFICATION 

Method Used to Describe Recults trom Test for Name al Person Who 

Conduc1ed Ih. Test or 

E VJUatlon 

CERTYKXTKbN 

(responsibk corporate othcralL cenrty under penalty of law that thrs document and al1 attachments were 

tion or aufmrvisiort in MXXM&~X with a system des@~I to assure that quaMod perrormd properly gather and evaluate the 

information submtttuf. b8od on my tnquiry of the f~sor-101 Persons who maruge the system o( thosa persons directly responsible for gathertng 

tb intorrnation, the infotmatton submittad is, to the best oi my knowledgte and b&at, true, accurate. and complete. 1 am awoke thirt there are 

sipiticant fu~Ities for submining false information, includino the possrbdity of fine and unprrsonrnent for knowing vldatrons. 

A. Name 6 Otficiat Titfo Ityfm or printl nd Telephone No. 

/ /icxEe7 55?F- /--jq-- 

C Sfiunaturs 0. Date SIunad 

Double scoop Ice crou CO8paBy 

sit. A8808880at Inspection 

Pebruary lo, 1993 

Evaluate the mite for pOllUtaBt8. 

There are five areas where material handling and storage activities 

take place. 

a The storage building contains tanks of corn syrup, liquid 

sugar, and tha granular cleansers. The tanks were examined 

for possible leaks. We found that the valve on the liquid 

sugar tank /2 was faulty and had leaked approximately 10 

gallon8 of liquid sugar. Although this leak occurred on 

l/21/92, the faulty valve was not discovered until now. 

All other tank8 are secure. Areas around the tank8 were 

swept clean to doter-mine if leaks or spills wero prevalent. 

0 The milk storage tanks were then examined for leaks or 

expo8ure. Upon closer examination, it was found that the 

number 1 tank wa8 leaking a small amount of milk to the 

drainage system. This leak may be the rea8on for the high 

concentration of biochemical oxygen demand found in the 

sample taken from the rtorm water discharge. The tank was 

temporarily fixed to l n8ure that no further contamination 

would result. A replacement tank wa8 ordered on February 

6, 1993, and was expected to arrive within 5 buriness days. 

The milk storage tank8 shall be examined on a daily basis 

to further prevent possible exposure to the storm water 

collection 8y8tea and receiving stream. 

l We inspected the fueling station to see if there were any 

leaks. Tha goneral area surrounding the fueling station 

wa8 claan butwa obrerved that garolino and motor oil falls 

during fueling. In accordance with standard operating 

conditiona, facility personnel ho88 down the area during 

vehicle wa8hing and the drain ir connected to the storm 

sovar. WI detected this connection on l/19/93 during one 

of the non-8tonn water discharge a88essment visuai 

in8pection8. Since this discharge ir not allowed under our 

gonaral p-it, we are in the procur of rubmitting a 

separate permit application specifically for the discharge 

of vehicle wa8h water. 

0 We examined the fueling station which is adjacent to the 

vehicle wa8hing area. Vehicle warhinq cleaner8 are used 

hera and any empty or open container8 were removed from the 

are8. 
l we next looked at the loading and unloading docks where rau 

materials and various cleansers are de Livered. The 

transfer of goods from ihcoming trucks to storage areas is 

a source of p0llutiOn. Although no problems were noticed, 

the pollution prevention team has developed a spill 

prevention and response plan to clean up spills quickly and 

report them if mcessary. 

a The last area we inspected was the runoff field below the 

employee parking lot. Here we noticed a significant amount 

of erosion resulting from recent construction to expand the 

parking lot. 

Dwcribo l xirtiag unaguant pr8cticu. 

Grass was lightly planted around the parking lot after recent 

construction. The fuel storage tank has curbing around it in 

accordance with our SPCC plan. Also, the maintenance crew 

regularly picks up trash and empty containers from around the 

storage tanks, loading and unloading areas, and the vehicle washing 

areas. Used oils are collected in containers and taken to a 

recycling facility. In addition, we installed two oil/water 

separators at the drains into our underground storm sewer leading 

to ths Rocky River. Those separators are indicatmd on thm site 

map. 
Dcubla -00p fco crew company 

misting Monitoring D8tr 

Although our NPDES permit for process wartWater doms not requirm 

storm wat8r sampling, VI sampled our storm water on ona occasion in 

raspon to a questionnaire ~8 rmeived from tha National 

Association of Ic8 Cream Makers. They were coll*ctinq information 

to submit as part of their comments on EPA’s proposed general 

permit. 

D8to of l mplin9 a/30/91 

owf811 l&Bpud 001 

Type of morm 1 inch light rainfall 

. 

(lastad 2 days) 

Type of lug1.s Grab samples taken 

during first hour of 

flav 

lamp10 

Puuotar Quantity Typo 1 

Boo 250 mg/l Grab 

TSS I 100 mu/l Grab 

Ba88cI upon tha high concentration of 800 in tha storm vator samples 

collacted, pollution provmtion toar is considering possible 

potential sourca8 of 800. Wa will look at storaga arms housing 

buttar f8t, milk, and vh8y solids tanks. 
Double scoop Ice Crou Cowpeny 

8-q of Pollutant 8ourcos 

March 5, 1993 

Based on the site assessment inspection conducted on 12/l/92, the 

pollution prevention team identified four potantial sources of 

pollutants: 

0 oil and grease stains on the pavement in the fueling area 

indicate oil and grease may be picked up by atom water 

draining to the storm mewar. This araa drains into the 

storm sever leading to the Rocky River. 

a Sediment and erosion potential in the field below the 

employee parking lot because of thinly planted grass. 

l Potential for spills or leaks from liquid storage tanks, 

includfng the fuel storage tank, based on a spill that 

occurred on l/21/92 and the leak that was detected in the 

ailk storage tank. Them pollutants would drain into the 

pipod outfall into the Rocky River. 

l Use 9f a toxic cleaning agmt may result in a pollution 

problem 4f handled improperly. 
Double 8coop fao Crsam compsay 

D88Oriptio8 d ltorr Istar Msasguent Yessures Talcma 

Based 01 8itm Assosuent Phase 

March I, 1993 

These measures correspond to the pollutant sources identified on 

the preceding page. 

Oil l d gre*so from fueling area. 

We installed drip pads around the fuel pumps to pick up spilled gas 

and oil during truck refueling. Those will be inspected regularly 

to make sure they are working well. 

8edimaat aad erosion in the field bolor the employoo parking lot. 

We planted grass in this area to reduce potential for erosion. 

Leaks/spills from liquid storage taakm. 

We arm in the process of installing curbing around the outdoor 

liquid storage tanks that will contain the volume of ha largest 

tank in case a spill should occur. The spill response team has 

developed procedures to clean up this area should a spill occur. 

We are incorporating spill respon88 procaduro8 from our SPCC plan. 

Todo 0lsMiag agut. 

Wo hava di8COntinWd ths use of thi8 agant and are replacing it 

with a non-toxic cl8aning agent. 
Work8hsst 17 

POLLUTANT SOlmCE IMNnFlCAnON 

(sactlon 2.2.6) 

IruUUClioru: List 88 idart- st0m1 wrtw paMutant sourc01 and dmcribm existing managumnt pramcar that address those soufcos. In thm thd 

column, h&t mw optima that cm ho kuxqoratod into the p&n to u.t&orr r- sources ot pollutants. 

I I 
Workrhe8t U78 

13MP IDENTW ICATION 

Geclion 23.1) 

Inrtructions: Lksccribe the hat Manqpmmt Practices that you have selected to inckda NI yw plan. For each 01 the baselrne RMfs. 

dtwmbo actions tM wid ba incorf3orotuf into facility opuotions. Also dmcrtbe any addmonal BMPs lactwty-specrfic 

(Chaptr 3) nd aim-specific 8MPs (Chaptu 4)) that you have selected. Attach adddonal sheets of necessary. 

Good l+oua 

Zhdimant and Erosion Control 4-tm4mem9 d-4. 

Mana~I of Runoff 
Double scoop rca c1au COmpUf 

Irployoo Training Frogru 

Line Workers 

Maintenance Crew 

Shipping and Receiving Crew 

When: 

Employee meetings held the first Monday of each month to discuss: 

l Any environmental/health and safety incidents 

0 Upcoming training sesrions 

0 Brief reminders on good housekeeping, spill prevention and 

response procedures, and material handling practices 

0 Announce any changes to the plan 

l Announce any new management practice8 

In-depth pollution provention training for new employees 

Refresher COUrS8s held every 6 months (October and March) 

addressing: 

0 Good housekeeping 

0 Spill prmvontion and response procaduras 

l Materials handling and rtoraga 

Good Houmkeaping 

. Review and demonstrate basic cleanup (rwmping 37 : 

vrcuuming) procedure8. 

l Clearly indicate proper dirpoaal loc8tion8. 

l Post sign8 in materials handling area8 rminding 8taff 

good housokerping procedures. 

l Ba sure l ployee8 know where routine clean-up 4qUipEent 

located. 
Spill Prevention and Response 

Clcariy identify potential spill areas and drainaga routes 

Familiarize employees with past spill events -- why they 

happened and the environmental impact (usa slides) 

Post warning signs in spill areas with emergency contacts 

and telephone numbers 

Introduce Isaac Feldman as the Spill Response Coordinator 

and introduce his t*taamH 

Drill on spill clean-up procedures 

Post the locations of spill clean-up equipment and the 

persons responsible for operating the equipment 

Materials Handling and Storaga 

b Be sure employees are aware which materials are hazardous 

and where those materials ara stored 

l Point out container labrls 

l Tell employees to use the oldeat materials first 

0 Explain recycling practice8 

0 Demonstrate how valves are tightly closed and hov drums 

should bo sealad 

0 Show how to fuel vehicles and avoid "topping off" 
Worksheet #8 

IMPLEMENTATION 

(Section 2.4.1) 

hstrwtiwa: b-8 whoduk for im@omonting oath BMP. Provido a brief dumption of each BMP, the steps necessary to rmpkmw\ttheBMe 

(io., any constmctlon or design), the Schedd for CompktinO thoS0 StOpS lkrt dated and the person(s) resyormbk foI 

imfdernmtatim. 

GoodHOUSdt~ 

SpiN Provontion u8d Fiufmnn 

,.. I .,, dllll hIIt: b))ttl.lflL) 

I I 
EMPLOYEE TRAININ 

(Section 2.423 

Work8haat 19 

lnstrucths: ouch IfBa empfoyu tmininQ prtapam for your facilitv Mow. The pfqyam shclukl, at a minimllm. address spill prsventloll and 

rospomm good fmumb@w, and mat- -t pruaicu. Provide a schuhb for rho uainmg prowam and list the 

eln@oyws wb l tubal traininQ wuiotu. 

Mot o#crigtlon of Tdlhg 

PNtar- hg.. fh. nowsfettu Schodde for Trhbq 

Trahbg lopks courw) lb81 deter) Attandam 

spid Preventiorr and f3u@onu 

Good HouselK~ 

Marenal Man~t Practices 

Other Topics 
~Elw 

Unibd StshPs 

EnJronmental Plowon Agency 

Washington DC 20460 

(42031 

--.~ 

Ollicii Bushes8 

Penalty For Priveta Use $300 

..-- __---