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
October 1992 P»ff* 3
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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.
October 1992 Ptg* 4
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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 stepa 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.)
October 1992 P»g* 6
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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.
October 1992 P*ff* 7
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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.
October 1992 P»9f 9
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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.
October 1992 P»g* 10
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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.
October 1992 Ptg* 12
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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
13
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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.
October 1992 Ptg* 14
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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.
October 1992 P»99 15
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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:
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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: )
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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
3 Det*J»0//n*v&-*6eM/' 5/ntt Pr*ise*ttoA/
r r 0+^c*»x*i l-mtn/ny
1 f/^ntatmSS *+*>t*it/ AC£S&j>r& *WA
2. '
3.
1 J&Mfa illwady jn /P/trce
2. ' '
3.
*-$Hhttifa.fc fl£M foxiS-f/rAWVtaqert
2. J '
:\
Scheduled
Completion
Date(s) for
Req'd. Action
*/m/4*
L/i/ii
*>/tfa
i/irfa*
4/1/1*
tt/*°/1*
H/l'/l*
l/i Sit -A^**toX
4///»* - /T«*A/
V/^firA.3
k- 2/2 */<(-*,
Person
Responsible
tor Action
^-feH*
tr/4*u
fc(jit/i~tM
fv/^rp^tl
6/*rtiSl
tfeyh*
fzkf*1l£3.+1
fZl^J-t-i^H-i
fc/
-------
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
-------
United Statet
Environmental Protection Agency
Washington DC 20460
(42QJ)
Official Business
Penalty For Private Use $300
------- |