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
                       if I 9 9 2 if
                       THE YEAR OF
                       CxEAN WATER
                        Printed on Recycled Paper

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                                        FOREWORD
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.

EP A'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.

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                        Industrial Guidance Executive Summary

                                 Table of Contents
                                                                              Pace

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

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                       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 f 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

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        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, takes, 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 high-
priority 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 permittees
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  <8MPs).  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

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                                 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 employe
                                   EVALUATION/MONITORING
                            • Conduct annual site inspection/BMP evaluation
                            • Conduct recordkeeping and reporting
                            • Review and revise plan
                GENERAL REQUIREMENTS
               • Develop schedule
               • Obtain required signatures
               • Follow plan location and public
                access requirements
               • Modify plan
   SPECIAL REQUIREMENTS
• 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

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                                        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:

     • Implementing  all general permit and pollution prevention plan requirements

     • Defining and agreeing upon an appropriate set of goals for the facility's storm water management
       program

     • 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

     • 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. Thfs 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
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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 SUBJECT TO 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 spilt emergency procedures and
         reporting requirements to isolate, contain, and clean up spills and emergency releases of
         Section 313 water priority chemicals.
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                                      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, 
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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 IRQ) 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.)
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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:

     •  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 particular
        generating activities

     •  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.
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                                    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, ID) spill  prevention and response, (E) sediment and erosion prevention, (F) traditional storm
  water management practices,  (G) other BMPs as appropriate, 
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  EPCRA, SECTION 313. FACIUTY PREVENTIVE MAINTENANCE INSPECTION REQUIREMENTS-A II 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 were done, who conducted the inspection,
        what areas were 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.
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SPILL RESPONSE PLAN CONSIDERATIONS:

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

     •  Identify safety measures.

     •  Include procedures for notifying appropriate authorities (police, fire, hospital, Publicly Owned
        Treatment Works [POTW], etc.) in the event of a spill.

     •  Describe spill containment, diversion, isolation, and cleanup practices.
  EPCRA, SECTION 313, FACILITY Swu. PREVENTION AND RESPONSE REQUIREMENTS-When a leak or spill of a
  Section 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  Prevention Plan. These facilities are also required to designate a
  person responsible for spill prevention,  response, and reporting procedures.
(E)  Sediment and Erosion Control

The facility'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

Permittees 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.
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                                   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 
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                                      EVALUATION PHASE
  Now that your Storm Water Pollution Prevention Plan has been put to action, you must keep it up-to-
  date  by regularly evaluating the information you collected in the Assessment Phase and the controls
  you selected m 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 cfeaner 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.
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                                  GENERAL  REQUIREMENTS
  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, IB) 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.
Type of Facility
Facilities discharging storm water
associated with industrial activity
on or before October 1, 1992
Facilities beginning to discharge
storm water after October 1 ,
1992, but on or before
December 31, 1992
Facilities beginning to discharge
storm water associated with
industrial activity on or after
January 1, 1993
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
Deadline for Plan
Development
April 1 , 1 993
60 days after
commencement of discharge
48 hours prior to
commencement of discharge
(upon submittal of NOD
60 days after release
365 days after date of
rejection or denial
Deadline for Plan
Implementation
October 1 , 1 993
60 days after
commencement of discharge
48 hours prior to
commencement of discharge
(upon submittal of NOD
60 days after release
545 days after date of
rejection or denial
Note: The Director may grant a written extension for plan preparation and compliance for new
dischargers (after October 1 , 1 992) upon showing of good cause.
(B)  Required Signatures

As with the Notice of Intent (NOD, 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
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 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 alt
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.
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                                   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, and/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 (us* covers, guards, overhangs,
        door skirts and/or conduct visual inspections or leak tests for overhead piping).

     •  Prevent discharges from  all the above areas (us* 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 (us* 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). Pleas* 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.


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                                     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, 1 992, Federal Register (57 FR 412361 - Final NPOES 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)  - Rnal 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                                                                            Pag* 16

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      POLLUTION PREVENTION TEAM
              MEMBER ROSTER
Worksheet #1
Completed by:
Title: 	
Date: 	
Leader:	  Title:
                                               Office Phone:

Responsibilities:
Members:

(1) 	  Title:
                                               Office Phone:

Responsibilities:
(2) 	  Title:
                                               Office Phone:

Responsibilities:
(3> 	  Trie:
                                               Office Phone:

Responsibilities:
(4) 	  TWe:
                                               Office Phone:

Responsibilities:

-------
          DEVELOPING A SITE MAP
                                                    Date:
                                                    Worksheet #2
                                                    Completed by:
Instructions:   Draw a map of your site 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:

      •  All outfalls and storm water discharges

      •  Drainage areas of each storm water outfall

      •  Structural storm water pollution control measures, such as:

         -  Flow diversion  structures
         -  Retention/detention  ponds
         -  Vegetative swales
         -  Sediment traps

      •  Name of receiving waters (or if through a Municipal Separate Storm Sewer System!

      •  Locations of exposed significant materials

      •  Locations of past spills and leaks

      •  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:	)

-------
MATERIAL INVENTORY
Worksheet #3
Completed bv:
Title:
Date:

Instructions: List all materials used, stored, or produced onsite. Assess and evaluate these materials for their potential to contribute pollutants to
storm water runoff. Also complete Worksheet 3 A if the material has been exposed during the last 3 years.
Material














Purpose/Location














Quantity
(unit*)
UMd














PlOdUCMl














ttood














Quantity Exposed in Last
3 Year*














Likelihood of contact with dorm water If
ye*, describe reaaon.














Pa*t Significant
Spill or Leak
Ye*














No















-------
DESCRIPTION OF EXPOSED SIGNIFICANT MATERIAL
Worksheet #3A
Completed by:
Title:
Date:

Instructions: Based on your material inventory, describe the significant materials that were exposed 10 siuim water durmy th« past three years
and/or are currently exposed. For the definition of "significant materials" see page 5 of this summary
Description ol Expoeed
Significant Materiel

















Period of
Expoeure

















Quentity
Expoeed
I unit «)

















Locetion
lee indiceted on the cite
mepl

















Method of Storege or
Dwpocel (e g., pile, drum,
tenk)

















Petcription of Malecial Management Practice (eg , pile
covered, drum sealed!


















-------
LIST OF SIGNIFICANT SPILLS AND LEAKS
Directions: Record below all significant spills and significant leaks of toxic
years prior to the effective date of the permit.
Worksheet #'
Completed b)
Title:
I
r.

Date:
or hazardous pollutants that have occurred at the facility in the three
Definitions: Significant spills include, but are not limited to, releases of oM or hazardous substances in excess of reportable quantities.
1st Year Prior
Date
(month/day/year)



2nd Year Prior
Date
(month/day/year)



3rd Yeer Prior
Oat*
Imonth/day/yaar)




Spill




Spill




SpiM



Leak




Leak




Leak



Location
(at indicated on aita
map)




Location
(aa indicated on «ita
map)




Location
laa indicated on alia
map)



Description
Type of Malarial




| Quantity




Source. If Known




Raaton




Description
Typa of Malarial




Quantity


' urea. If Known




Raaaon




Description
Typa of Malarial



Quantity



Source, ff Known



Raaaon



Response Procoduro
Amount of
Material
Recovered




Material No
Longer Expoeed
to Storm Water
(True/False)




Response Procedure
Amount of
Matenel
Recovered




Matenal No
Longer Expoeed
to Sturm Water
(True/Falae)




Response Procedure
Amount of
Matenal
Recovered



Material No
Longer Expoeed
to Storm Water
(True/Fete*)



Preventive
Measures
Taken




Preventive
Measures
Taken




Preventive
Measures
Taken




-------
NON-STORM WATER DISCHARGE
ASSESSMENT AND CERTIFICATION
Date of
Test or
Evaluation






Outfall Directly
Observed During the
Test (identity at indicated on
iha site map)







Method Used to
Test or Evaluate
Discharge






Worksheet #5
Completed by:
Title:
Date:
Describe Results from Test (or
the Presence of Non-Storm
Water Discharge






CERTIFICATION
Identify Potential
Significant Sources







Name of Person Who
Conducted the Test or
Evaluation







1, (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. 1 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 (type or print)
C. Signature
0. Area Code and Telephone No.
D. Date Signed

-------
          NON-STORM WATER DISCHARGE ASSESSMENT AND
                    FAILURE TO CERTIFY NOTIFICATION
Worksheet #6
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 listed 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 the Director within 180 days of the effective date of this permit.
Identify Outfall Not
Tested/Evaluated





Description of Why Certification
Is Infeasible





Description of Potential Sources of Non-
Storm 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 (type or print)
C. Signature
B. Area Code and Telephone No.
D. Date Signed

-------
Doubla icoop lea Craaa Coapany

        40 Wonka Driva
             , OX  12341
         Dacaabar  ltt2
•ton Vatar Pollution Pravantion Plan
Emargancy contact: Chary 1 (31 ana Work Phona: (101)
Tit la: Plant Kanagar Emargancy Phona:
Sacondary Contact: taehal Kayars Work Phona: (101)
Tit la: Inginaaring fuparviaor Emargancy Phona:
55S-1234
(101) SSS-«t29
SSS-3923
(101) SS5-i7tt
Typa of Manufacturar: Xea Craaa Kanufaeturar
Oparating Schadula: tiOO a.a. - llsso p.a.
Humbar of Employ aaa: Tha plant baa 21 aaployaaa, including p*rt
tima staff. Shifts ovarlap all day.
Avaraga Waatawatar Diacharga: S,000 gallons par vaak
NPDES Pannit Nuabart OX1»34S<7

-------
      POLLUTION PREVENTION TEAM
            MEMBER ROSTER
Worksheet*!
Completed by:
Title'
Date:
Uad«r
       ** * £.  f*/s*jt* ^f*jj<+A
ID
RttponsibiHiM
Titlt:

Of«c« Phon«: S/0/
(2)
(31

-------

-------
                  Double  leoop  ice  Creaa Company

              •torm water Pollution Prevention Plan
                    Comparison with IPCC Plan


Double Scoop Ice Cream Plant hat  an SPCC plan in operation for its
aboveground fuel storage tank.   Overlaps arc notad b«low:


     •  Isaac Faldman is  the SPCC Coordinator and reports directly
        to  Cheryl Glenn.    He  will  be  the  Storm  Water  Spill
        Prevention and Response Coordinator.

     •  A complete description  of potential  for oil to contaminate
        storm water discharges  including quantity of oil that could
        be discharged.

     •  Curbing around aboveground  fuel  storage tank identified on
        site map.

     •  Expanded  SPCC schedules  and procedures  to  include  storm
        Hater Pollution Prevention Plan requirements.

     •  Incorporated SPCC plan training into storm water training
        programs on spill prevention and response.

     •  Relevant portions of the  SPCC plan will  b« included in this
        plan.

-------
          DEVELOPING A SITE MAP
Worksheet *2
Compltttd by:
TItta:
instructions:   Draw a map of your sit* including a footprint of all buildings, structures, paved anas, and
              parking lots.  The information below describes additional elements required by EPA's General
              Permit (see example maps in Figures 2.3 and 2.4).


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

      •  All outfall* a.,d storm water discharges

      •  Drainage areas of each storm water outfall

      •  Structural storm water pollution control measures, such as:

         •  Flow diversion structures
         •  Retention/detention pond*
         •  Vegetative swales
         •  Sediment traps

      •  Name of receiving waters (or if through a Municipal Separate Storm Sewer System)

      •  Locations of exposed significant materials (see Section 2.2.2)

      •  Locations of past spills and leaks (see Section 2.2.3)

      •  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 piku, treatment plants, disposal areas)
         •   Outside storage areas for raw materials, by-products, and finished products
         -   Outside manufacturing areas
         -   Other areas of concern (specify:	I

-------
IXHTBLR SCOOP ICE CREAM COMPANY

       PRE-BMP SITE MAP
         MARCH 1, 1993

-------
SCOOP ICE CREAM COMPANY

POST-BMP SITE MAP
   MARCH 1, 1993

-------
                   MATERIAL INVENTORY
                                                                 Worksheet «3
                                                                 Completed by:
                                                                 Title:  	
                                                                 Date: 	
f.kesuj
r    . i _«,
                                                                                                                     2
Instructions:   List aN materials used. stored, or produced onsite.  Assess and evaluate these materials for their potential 10 contribute pollutants to
             storm water runoff. Also complete Worksheet 3A if the material has been exposed during the last three years.
                                                                                      Ilt«tt>nn4 ot coniaci with *i
-------
                   MATERIAL INVENTORY
                                2-
Worksheet <3
Completed by:
Title:  	
Date:  	
Instructions:   List all materials used. stared. or produced onsita.  Assess and evaluate these materials lor the-' potential 10 contribute pollutants to
             storm water runoff.  Also complete Worksheet 3A if the material has been exposed during the last three

-------
     DESCRIPTION OF EXPOSED SIGNIFICANT MATERIAL
Worksheet f 3A
Completed by:
Title:
Date
Instructions:  Based on your material inventory, describe the significant inaterials that were exposed to storm water during the past three years
             and/or are currently exposed. For the definition of "significant materials" see Appendix B of the manual                '
    *»*
                                                    LocMtan
        at *!«•«• of
          . •«•. 4ruMt.
        lank)
                                                                                                   of M«l«(Ml M«o«n»m»n« Pi«cUc* I* g . pit*

-------
LIST OF SIGNIFICANT SPILLS AND LEAKS
Worksheet *<•
Completed t>j
Title:
^
r: {^flprtf/ 6/&7/1
f*/£L4t£ /W&-SI s*&£^~
Date: £&£:&*

yrj*z+~ /Zj /9S.



Location
|M maicMMl MI MU
I
Oaacr^Mion
Ty*a at MMMU!
A /
N
t w
UuwMHy
s\
u

SOUK*. M Known
A /
N
* T

t —
F_
f

Oaacriplion

Liauio SuesiA


OuvMJty
/£>ga.


SOUK*, H Known
7a*tX *2.



/rAKy vj/vtL



D^.^^n
Iyp« ol MM*ft«l
A /
A/
r Y
UucntHy
G._,

Suuic*. H Known
A /
N
t V

r—
/-
* - -
Ra»pon»a PiucauVua
Amount ol
MMMUI



MMMUI No
luoyof f •ao««il
to Sloim WMM
(liu»/fM«*|




Rasponca Plocadura
Hi
Confab*/


MMMUI No
la ^I^M WMM
^ — ~^^
Jmt,


R.H>on.a P.oc^lu,.
Amount ol
MMMUI
Hw-uvw.4



MMMUI No
lu Stan* WMM



Ptavatiiiwa
Tahan




Pravanliva
Maaauraa
Takan
/^r^^//^f



Pl*V*ftllV»
T«k*n




-------
       NON-STORM WATER DISCHARGE
      ASSESSMENT AND CERTIFICATION
                                        Worksheet *5
                                        Completed by:
                                        Title:
                                        Date:
  Date of
  Test or
Evaluation
    OutfaN Diractfy
  Observed During the
Test i
      Ih* MMHMpt
Method Used to
Test or Evaluate
   Discharge
Describe Results from Test for
 the Presence of Non- Storm
      Water Discharge
 Identify Potential
Significant Sources
 Name ol Person Who
Conducted the Test or
     Evaluation
                                                          CERTIFICATION
1.
                    (responsible corporate otliciall. certify under penally of law that this document and all attachments were
prepared offcjer 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 ol my knowledge and belief, true, accurate, and complete. 1 am awaie that there are
significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations
A. Name & Official Title (type or print)
                                                                       B. Area Code and Telephone No.
                                                      ia Code ai
                                                      2^1
C  S,gna«ure
                                                                       D  Oaie Sigiwd

-------
           .
->. j.. v

-------
                  Double Scoop Ice cr*«a Company

                    Site Assessment Inspection

                                  10, 1*93
Evaluate the sit* for pollutants.

There are five areas where material handling and storage activities
take place.


     •  The storage building contains tanks of corn syrup, liquid
        sugar,  and the 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
        gallons of liquid sugar.   Although this leak occurred on
        1/21/92,  the faulty  valve was not  discovered  until  now.
        All other tanks are  secure.   Areas around the tanks  were
        swept clean to determine  if leaks or spills were prevalent.

     •  The milk  storage  tanks  were then  examined  for  leaks or
        exposure.   Upon closer examination, it was found that the
        number 1  tank was  leaking a small  amount of  milk to the
        drainage system.  This leak may be  the reason for the high
        concentration of  biochemical oxygen demand  found  in the
        sample taken from  the storm water discharge.  The tank was
        temporarily fixed to ensure that no further contamination
        would result.  A replacement tank was ordered on February
        6, 1993, and  was expected to arrive  within 5 business days.
        The milk storage tanks shall be examined on a daily basis
        to further prevent  possible exposure to  the  storm water
        collection system and receiving stream.

     •  We inspected the fueling station to see if there were any
        leaks.   The  general  area surrounding the fueling station
        was clean  but we observed that gasoline and motor oil falls
        during  fueling.   In  accordance  with standard  operating
        conditions, facility personnel hose down the area during
        vehicle washing and  the drain is  connected  to  the storm
        sever.   We detected this connection on 1/19/93 during one
        of  the   non-storm   water  discharge  assessment  visual
        inspections. Since this discharge is not allowed under our
        general permit,  we  are  in  the  process  of  submitting  a
        separate permit application specifically for the discharge
        of vehicle wash water.

     •  We examined the fueling  station  which is adjacent to the
        vehicle washing area.   Vehicle washing  cleaners are  used
        here and any empty or open containers were removed from the
        area.

-------
     •  We next looked at the loading and unloading docks where raw
        materials  and  various  cleansers  are  delivered.    The
        transfer of goods from incoming trucks to  storage areas is
        a source of pollution.   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 necessary.

     •  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.


Describe existing management practice*.

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 sever leading
to the Rocky River.  These separators  are  indicated on  the site
map.

-------
                  Double Scoop ice Cream Company

                     Existing Monitoring Data
Although our NPDES permit for process wastewater does not require
storm water sampling,  we sampled our storm water on on* occasion in
response  to  a  questionnaire  wa  received  from  tha  National
Association of lea Cream Makers.   Thay were collecting information
to  submit  as part  of their  comments  on EPA's  proposed general
permit.
Date of tamp ling
Outfall Sampled
Type of storm
Type of Samples
8/30/91
001
1 inch light rainfall
(lasted 2 days)
Grab samples taken
during first hour of
flow
Data
Parameter
BOD
TSS
PH
Oil and
greaaa
Quantity
250 mg/1
100 mg/1
7.2 s.u.
5.0 mg/1
Sample
Type
Grab
Grab
Grab
Grab
Baaed upon tha high concentration of BOD in tha storm water samples
collected,  pollution  prevention  team  is  considering  possible
potential sources  of BOD.   He will look at storage areas housing
butter fat, milk,  and whey solids tanks.

-------
                  Double  Scoop  Ice Crea* Company

                   Summary of Pollutant Sources

                          lurch s, i»t3


Based on the site assessment inspection conducted on 12/1/92, the
pollution prevention  team  identified  four potential  sources of
pollutants:


     •  oil and grease stains on the pavement in the fueling area
        indicate  oil  and grease may be picked  up  by storm water
        draining  to the  storm  sewer.   This area  drains into the
        storm sever leading to the Rocky River.

     •  Sediment  and  erosion  potential in the field  below the
        employee parking lot because of thinly planted grass.

     •  Potential for spills or leaks  from liquid storage tanks,
        including the  fuel storage tank,  based on  a  spill that
        occurred on 1/21/92 and the leak that was detected in the
        milk storage tank.  These pollutants would drain into the
        piped outfall into the Rocky River.

     •  Use of  a  toxic  cleaning agent may result  in a pollution
        problem ** handled improperly.

-------
                  Double Scoop Zoo Crea* Company

       Description tf storm water Management Measure* Taken
                  Baaed on site Assessment Phase

                          March  5, if93


These measures  correspond to the pollutant sources identified on
the preceding page.


Oil aad grease  from fueliag area.

We installed drip pads around the fuel pumps to pick up spilled gas
and oil during truck refueling.  These  will  be  inspected regularly
to make sure they are working well.


Sediment and erosioa ia the field belov the employee parking lot.

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


Leaks/spills from liquid  storage tanks.

We are  in the  process  of installing curbing  around  the outdoor
liquid storage  tanks  that will  contain the  volume of he 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 response procedures frost our SPCC plan.


Tosie cleaaiag agent.

We have discontinued  the  use of this  agent  and are replacing it
with a non-toxic cleaning agent.

-------
                      POLLUTANT SOURCE IDENTIFICATION
                                   (Section 2.2.6)
                                      Worksheet *7
                                      Completed by
                                      Title:
                                      Data:
                                                                                                       dvA
Instructions:   List «i identified storm watf pollutant sources and describe existing management practices that address those sources.  In the thud
             column, list BMP options that can be incorporated into the plan to address remaining sources of pollutants
     Storm Water Poiutant Sources
Existing Management Practices
Description of New BMP Options
I.
                                      /rt
2.

                                                     /J
                                                                                     ₯*-1
                                                                                             - t&x if
                                                              a at**. *i f—
                                                                                                                    c£&/,w*
                                                                                                                   S      /
9.

-------
                       BMP IDENTIFICATION
                           (Section 2.3.1)
                           Worksheet *7e
                           Completed by:
                           Title:
                           Dete
Instructions:   Describe the Best Management Practices that you have selected to include m your plan. For each oi the baseline BMPs,
              describe actions that wii be incorporated into facility operations.  Also describe any additional BMPs (activity specific
              (Chapter 3) and site-specific BMPs (Chapter 4)1 that you have selected.  Attach additional sheets it necessary
                                                                 Brief Description of Activities
Good Housekeeping
Preventive Maintenance
Inspections
SpiN Prevention Response
                                                                                                                   /
                                    faej feutX tr*t
Sediment and Erosion Control
Management of Runoff
Additional BMPs •
(A« nvity i pec it ic and Situ sptsctttc)
stew- fox /c


-------
                  Double Scoop let Cream Company
                    Employee Training Program
who:
Line Workers
Maintenance Crew
Shipping and Receiving Crew
When:
Employe* meetings held the first Monday of each month to discuss:
     •  Any environmental/health and safety incidents
     •  Upcoming training sessions
     •  Brief reminders on good housekeeping,  spill prevention and
        response procedures, and material handling practices
     •  Announce any changes to the plan
     •  Announce any new management practices
In-depth pollution prevention training for new employees
Refresher  courses  held  every  6  months  (October  and  March)
addressing:
     •  Good housekeeping
     •  Spill prevention and response procedures
     •  Materials handling and storage

Employee Training Program Topicst
Good Housekeeping
     •  Review  and  demonstrate   basic   cleanup  (sweeping  a- :
        vacuuming) procedures.
     •  Clearly indicate proper disposal locations.
     •  Post signs in materials handling areas reminding staff
        good housekeeping procedures.
     •  Be sure employees know where routine clean-up equipment
        located.

-------
Spill Prevention and Response
     •  Clearly identify potential spill areas and drainage routes
     •  Familiarize employees with past spill  events — why they
        happened and the environmental  impact (use slides)
     •  Post warning signs in spill areas with emergency contacts
        and telephone numbers
     •  Introduce Isaac Feldman as the  Spill Response Coordinator
        and introduce his "team"
     •  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 Storage
     •  Be sure employees are aware which materials are hazardous
        and where those materials are stored
     •  Point out container labels
     •  Tell employees to use the oldest materials first
     •  Explain recycling practices
     •  Demonstrate how  valves  are tightly closed and  hov drums
        should be sealed
     •  Show how to fuel vehicles and avoid "topping off"

-------
IMPLEMENTATION
(Section 2.4.1)
Worksheet * 8
Completed by:
Title:
factq/t/e/ttt
Piastf * /*&+,****"
Date: ' J/&/& '
Instructions-. Develop a schedule for implementing each BMP. Provide • brief description of each BMP. the steps necessary to implement the BMP
(i.e.. any construction or design), the schedule for completing those steps (ksl dates) and the per&onU) responsible for
implementation .
BMP*
Good Housekeeping
Preventive Maintenance
Inspections
SptM Prevention and Response
Sediment and Erosion Control
Management of Runoff

• •iii • .1 llMIS
• i . . , t.t , .1.. jnj bile specific)
Description of Actktnls) Required for Implementation
1 • pttdaj? tnurr/n* /7*vqfnsrj
2- /Ja^f^/U^/- +ytf/fi/s?&
3. y
1 fa0/4ft VO/V4 £>/! £t440rfar7£ # ^
2 fas fa //*&<; sn,/A 6z*±#3-
3.
1 farf/qi/rtyXt^sK fsJtrJu/tL
2.
3
*~/Mtadat*fa*iA A**xtuJAH/f <6>np- JIM&.
' /M f ife // aria sxJtK
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                           EMPLOYEE TRAINING
                               (Section 2.4,2)
                                      Worksheet «9
                                      Completed by:
                                      Tide:
                                      Date:
Instructions:   Describe the employee training program for your facility below.  The program should, at a minimum, address sptU prevention and
              response, good housekeeping, and material management practices.  Provide a schedule for the training program and list the
              employees who attend training sessions.
            Training Topic*
     •rief Description of Training
Ptoemnrlieleriati (e.g.. fim. newsletter
              course)
Schedule for Training
     (tat dates)
Attendees
SpiN Prevention and Response
                                       tp/M ftqeansc. f**xx/*m*i
Good Housekeeping
Material Management Practices
Other Topics
                                                                                                          ft// e

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United Statet
Environmental Protection Agency
Washington DC 20460
(42QJ)	

Official Business
Penalty For Private Use $300

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