Calbag Metals Co. (Calbag) is a non-ferrous scrap metal recycling company.  Calbag purchases scrap metal for resale to the manufacturing industry.

Calbag purchases wire and other used metals from post-consumer scrap, post-industrial scrap, and building demolitions. Calbag buys new manufacturing scrap resulting from industrial processes and construction. The primary metals purchased are aluminums, coppers, brasses, and stainless steels. Calbag also purchases relatively small amounts of other materials such as zinc alloys, nickel alloys, leads, titaniums, magnesiums, ferrous metals, and copper bearing scrap such as electric motors and consumer electronics.

Metals arrive in many forms. Sheet, plate, pipe, castings, fabricated pieces, bare and insulated wires, and borings are most common. Calbag also buys remnants of metal manufacturing processes (also know in the industry as “spills”).  Calbag purchases small amounts of ferrous scrap as a service to customers who have combined ferrous/non-ferrous loads. Calbag does not buy materials that require special handling such as automobiles, mercury, "PCB" items, and waste (see Calbag Portland Material Acceptance Policy)

Calbag’s suppliers include large industrial companies, other scrap dealers and recyclers, scrap peddlers, contractors such as electricians and plumbers, and the general public.  Metals are brought in semi-trucks (Vans and flatbeds), city trucks, pickup trucks and cars.  Calbag also provides drop box delivery and retrieval services for some industrial firms.  Incoming material may be loose, in drums, in gaylords (large cardboard boxes), baled, or in drop boxes.

Calbag’s operations are indoors and outdoors.  All outdoor areas are 100% paved.  Most sorting and processing of metals takes place indoors or under cover.  Materials waiting to be sorted or packaged may be stored in piles or containers.  If not dumped when brought in, containers from industrial accounts are stored outside until packaged.  Outdoor containers are covered as necessary.  Storage of finished goods is primarily indoors.  Loading and unloading of materials takes place indoors and outdoors.

SITE DESCRIPTION

About the Site

This facility houses corporate offices and the main storage and processing warehouse.  A portion of the facility is leased from the City of Portland and is used for the truck scale, large load receiving, sorting, processing, and storage.  A 140-ft x 40-ft (0.13-ac) canopy and a variety of smaller covered structures are used to protect some significant materials from contact with stormwater.

Maps:

• Map 1--General Location

• Map DA1--Stormwater Management Features and Outdoor Operations for Drainage Area 1

• Map DA2--Stormwater Management Features and Outdoor Operations for Drainage Area 2

• Map DA3--Stormwater Management Features and Outdoor Operations for Drainage Area 3

• Map DA4--Stormwater Management Features and Outdoor Operations for Drainage Area 4

• Map DA5--Stormwater Management Features and Outdoor Operations for Drainage Area 5

This facility is associated with:

• 2495 NW Nicolai Street

• a portion of the lot located behind 2495 NW Nicolai (2615 NW Industrial Street) leased from the City of Portland

• several parcels abutting 2615 NW Industrial Street along NW 25th Place.

This facility:

• is operated under an Environmental Management System (EMS) certified by NSF-ISR under ISO 14001:2015

• is operational Monday through Friday from 7:00 AM to 2:30 PM, with the office remaining open until 4:30 PM

• has been used in whole or in part by Calbag Metals Co. since the mid-1940’s (warehouse) with the outdoor yard area added circa 1995 upon completion of the Guilds Lake Cap (ECSI Site ID 404)

• completed a Voluntary Cleanup Program (VCP; ECSI Site ID 5059) administered by the State of Oregon Department of Environmental Quality (DEQ), with NFA issued 5/30/19 and stormwater source control decision issued 3/15/19

• has 5 individual drainage areas covering 4.3-ac, all of which are 100% impervious

  • DA1 - Office and Front Warehouse Roof:  0.52-ac; composite roofing; sanitary sewer outfall

  • DA2 - Parking, Entrance Alley, and Back Warehouse Roof:  0.84-ac; composite roofing, concrete, asphalt; sanitary sewer outfall

  • DA3 - Yard:  1.85-ac; asphalt; painted metal roofing; City of Portland Basin 16 storm sewer outfall (Willamette River; 45.54843, -122.70529) under 1200-Z permit (File No. 107179)

  • DA4 - Side Yard, Exit Alley, and Back Warehouse Roof:  0.97-ac; composite roofing, concrete, asphalt; combined sewer outfall; ADCM authorization (renewed 7/28/20)

  • DA5 - Lower Lot:  0.12-ac; metal roofing, asphalt; combined sewer outfall

Activities

Indoors (enclosed):

• corporate offices

• operations offices

• storage of finished and unfinished goods

• baling of sheet, pipe, borings, cable, wire, and other metal articles

• diesel fueling of off-road material handling equipment

• movement of materials using forklifts and front-end loaders

Outdoors:

• storage of finished and unfinished goods (covered and uncovered)

• shipping and receiving

• truck scale

• covered sorting of mixed demolition scrap

• covered cutting of large scrap articles into smaller articles using plasma cutter, acetylene torch, or shear

• container storage (empty and full; covered and uncovered)

• propane fueling of forklifts

• operation of stormwater treatment facilities

• movement of materials using forklifts, front-end loaders, or material handlers

Significant Materials--Products and Supplies

The composition and disposition of significant materials at this facility are described below and corresponds to areas shown in Maps DA1-DA5.  Waste materials are listed separately.  Momentary exposure of significant materials to rainfall during consolidation or transfer between covered areas such that runoff does not occur will not be considered to be stormwater exposure.

Significant materials exposed to stormwater in open bunkers or containers during storage:

• Insulated aluminum wire

• Aluminum pieces such as extrusions or window frames

• Stainless steel, steel, iron, and aluminum solids

• Empty scrap metal storage/shipping containers with trace residues (dust, oil, dirt, etc.)

• Whole Pallets

Significant materials protected from exposure to stormwater in covered containers during storage:

• During receiving, materials destined for indoor locations may temporarily staged in covered containers

• Stainless steel, iron, and steel borings

Significant materials protected from exposure to stormwater in covered bunkers during storage:

• Electric motors

• Mixed loads for sorting

• Insulated copper wire

• Baled titanium turnings

Significant materials protected from exposure to stormwater in gaylords under tents during storage:

• During receiving, materials destined for indoor locations may be staged under tents

• Aluminum borings

• Copper solids (on occasion)

• Mixed electronics

Significant materials with no exposure to stormwater during storage:

• Radiators with copper and possible lead

• Copper solids

• Lead

• Lead-Acid batteries

• “No-PCB” ballasts and capacitors

• Brass and high-temp alloys

• Diesel

Significant Materials--Waste

Details concerning the sources and disposition of waste materials are provided in the Calbag EMS Waste Survey.  Momentary exposure of normally-covered waste materials to rainfall during consolidation or transfer between covered areas such that runoff does not occur will not be considered to be stormwater exposure.

Potential Stormwater Pollutants

The following potential pollutants could be present in stormwater discharges to surface waters from the 2495 NW Nicolai Street facility based upon activities and materials stored in that area:

• Copper

• Lead*

• Zinc

• Aluminum

• Nickel

• Chromium

• Mercury*

• Iron

• Oil/Grease*

• Sediment (TSS)

• PCBs*

• PAHs*

*incidental

The sources of these pollutants include the scrap materials themselves as well as any residual materials attached to the scrap.  While Calbag has rigorous inspection policies and handling procedures in place to avoid contact of materials such as copper and lead with stormwater, and to restrict other materials such as PCBs, PAHs, and mercury from the facility altogether, some degree of incidental contamination can be hidden in scrap loads and is therefore unavoidable.

Stormwater Monitoring

Sampling of stormwater is required for DA3 under the 1200Z permit.  Samples are collected in accordance with 1200Z permit requirements at the sampling spigot attached to the treated stormwater conveyance line, the location of which is indicated on Map DA3 and Figure 1 as "Monitoring Point 001".  In the event of bypass conditions during sampling of a permit event, Calbag shall additionally sample “...the bypass discharge at the overflow of the oil-water separator…”, the location of which is indicated on Map DA3 and Figure 1 as "Monitoring Point 002" (refer to letter from BES dated 3/10/17).

CONTROL MEASURES

Minimize Exposure:

These control measures minimize exposure of manufacturing, processing, material storage areas, including loading and unloading, disposal, cleaning, maintenance, and fixed fueling areas to rain, snow, snowmelt, and runoff to the extent technologically available and economically practicable and achievable in light of best industry practice:

• Facility-Wide

  • All scrap processing activities are conducted indoors or under cover

  • Exposed, outdoor storage is restricted to materials with minimal potential for contaminating stormwater (e.g., aluminum, stainless steel, steel)

  • Drop boxes containing potentially contaminating materials are sealed and/or covered, and lids/covers are opened as necessary and closed as necessary and at the end of each day

  • All diesel fueling activity is conducted indoors

  • With the exception of steel, stainless steel, and aluminum, all public purchases involving copper, lead, and non-standard containers are restricted to the Public Dock Canopy and DA4, the runoff from which is treated and discharged to the sewer in the event of accidental exposure

  • Baled titanium turnings may only be stored in the containment trays under the Bale Drying Tent in DA4, the runoff from which would be treated and discharged to the sanitary sewer in the event of containment failure and accidental exposure

  • Insulated copper wire may only be stored in covered containers or under the ICW Tent in DA4, the runoff from which is treated and discharged to the sanitary sewer in the event of accidental exposure due to containment system failure

• Special provisions for DA3 (drains directly to Willamette River under permit)

  • Storage or staging (for loading/unloading) of potentially contaminating materials in DA3 is restricted to the 2 Tented areas

  • Plasma/torch cutting activities and sorting of mixed loads in DA3 is restricted to the canopied workspace (0.13-ac)

  • No uncoated galvanized roofing may be used in DA3

Oil and Grease:

These control measures eliminate or minimize oil and grease contamination of stormwater discharges:

• Facility-Wide

  • See Preventive Maintenance section

  • Customers or contractors with vehicles exhibiting a significant leak should be asked to leave the premesis

• Special provisions for DA3 (drains directly to Willamette River under permit)

  • A multi-stage treatment system including a Coalescing Plate Oil/Water Separator is used to prevent floating hydrocarbons and sheen from drips and leaks from discharging into the Willamette River (Figure 1)

• Special provisions for DA4 (drains to sewer under permit)

  • A multi-stage treatment system including Separator Vault and Coalescing Plate Oil/Water Separator are used to prevent floating hydrocarbons and sheen from entering the sewer system (Figure 2)

Waste Chemicals and Material Disposal:

These control measures eliminate or minimize exposure of pollutants to stormwater:

• Facility-Wide

  • As a policy, Calbag does not purchase waste or non-scrap metal materials such as chemicals or metallic powders (see Calbag Portland Material Acceptance Policy)

  • The outdoor consolidation of non-regulated waste resulting from business operations is restricted to specified containers in DA4, the runoff from which is treated and discharged to the sewer in the event of contact with stormwater

  • Any regulated waste resulting from business operations is stored indoors

Erosion and Sediment Control:

These control measures minimize erosion of soil at the site and sedimentation:

• Facility-Wide

  • The entire site is paved, and the pavement is regularly inspected and maintained, to eliminate erosion potential

  • Pavement in DA3 is additionally inspected and maintained by the City of Portland as part of long-term management of the Guild Lake incinerator and landfill cap

Debris Control:

These control measures eliminate or minimize waste, garbage, and floatable debris in stormwater discharges and ensure that this debris is not discharged to receiving waters:

• Facility-Wide

  • As a policy, Calbag does not purchase waste or non-scrap metal materials such as municipal solid waste (see Calbag Portland Material Acceptance Policy)

  • Catch basin inserts are installed in all catch basins as the primary means of removing incidental debris from all runoff

• Special Provisions for DA3 (drains directly to Willamette River under permit)

  • A multi-stage treatment system provides additional protection from the discharge of debris into the Willamette River (Figure 1)

• Special Provisions for DA4 (drains to sewer under permit)

  • A multi-stage treatment system provides additional protection from the discharge of debris into the sewer system (Figure 2)

Dust Generation and Vehicle Tracking of Industrial Materials:

These control measures minimize the generation of dust and tracking on exposed surfaces within and between operational areas and off-site of soil, particulates, and raw, final, or waste materials:

• Facility-Wide

  • roadways, gutters, and parking areas along the boundaries of the site are swept by a contractor on a weekly basis

  • See Housekeeping section

Housekeeping:

These control measures ensure that all exposed areas that may contribute pollutants to stormwater are routinely cleaned:

• Facility-Wide

  • see Calbag EMS WI-24 (Housekeeping)

Spill Prevention and Response Procedure:

These control measures minimize the potential for leaks, spills, and other releases that may be exposed to stormwater and demonstrate planning and methodology for spill prevention, clean-up, and notification:

• Facility-Wide

  • Calbag does not purchase scrap equipment with intact tanks or reservoirs (see Material Acceptance Policy)

  • The facility is covered by a SPCC Plan in accordance with 40CFR112 (spcc.calbag.com) and should be referred to for specific details concerning spill prevention and response

  • Spill kits are available throughout indoor and outdoor areas where leaks or spills may occur (see maps)

Preventative Maintenance:

These control measures help avoid situations that may result in leaks, spills, and other releases of pollutants discharged to receiving waters through regular inspection, cleaning, maintenance, and repair of industrial equipment, systems, material handling, and material storage areas that are exposed to stormwater:

• Facility-Wide

  • All catch basins are inspected a minimum of once a month and cleaned based upon the observation of debris loading so as to avoid ponding and bypass (see Forms)

  • Source control practices, structural controls, treatment controls, and other important aspects of the SWPCP are inspected/reviewed monthly and/or as per manufacturer instructions (Appendices E-H, see Forms)

  • Lift trucks and material handling equipment is inspected each day prior to use

  • Lift trucks are maintained under an ongoing service contract with a certified local Hyster dealer

  • Other rolling stock and stationary equipment is maintained by Calbag maintenance staff on a scheduled basis

  • Employees have the authority and responsibility to decommission any piece of equipment requiring repairs that could create an environmental hazard

Employee Education:

These control measures inform personnel on the pertinent components and goals of the 1200-Z permit and the SWPCP:

• Facility-Wide

  • All employees receive initial and scheduled training on Operational Controls as documented in the Calbag Environmental Management System, which may include the following topics as applicable to their duties and responsibilities:

    • Significant Materials (also referred to as Environmental Aspects; annual; all employees)

    • Stormwater Permits (annual; all employees)

    • Spill Prevention, Control, and Countermeasures (annual; all employees)

    • Formal SWPCP (annual; all operations supervisors)

    • Formal SPCC (annual; all operations supervisors)

    • Material Acceptance

    • Battery Management

    • Trucking Operations

    • Lead Management

    • Stormwater Pollution Control (annual; all operations supervisor)

    • Copper Management

    • Waste Management

    • Housekeeping

  • Environmental Compliance Director regularly shares reminders and observations regarding stormwater issues with Warehouse and Office staff as part of regular stand-up meetings

  • Permit sampling results are shared verbally by Environmental Compliance Director with all employees as sample results are received and occasionally via email communications or electronic displays

  • New, regular employees who work in areas where stormwater is exposed to industrial activities or who conduct duties related to the implementation of the SWPCP are trained within 30 calendar days of hiring

Non-Stormwater Discharges:

These control measures eliminate any non-stormwater discharges not authorized by a NPDES permit:

• Facility-Wide

  • No non-stormwater discharge of any kind is allowed with the exception of discharges from emergency or unplanned fire-fighting activities

Inbound Recyclable and Waste Material Control Program [Sector-N]:

These control measures minimize the chance of accepting materials that could be significant sources of pollution by conducting inspections of incoming recyclables and waste materials:

• Facility-Wide

  • Calbag maintains a strict Material Acceptance Policy (MAP) that specifies the materials that Calbag does not buy and why (see Material Acceptance Policy at 14001.calbag.co), as well as who is responsible for inspection and how non-conforming materials should be handled (Calbag EMS WI-04, Material Acceptance)

  • Calbag's MAP is available to employees, customers, and the public via the 14001.calbag.co website, accessible from any internet-enabled computer, tablet, or smartphone

  • Employees are trained to inspect incoming scrap for specific scrap materials that are potentially significant sources of stormwater pollution if exposed to rainfall, such as scrap with residual fluids, lead-acid batteries, lead solids, and copper solids, and likewise trained on how to properly handle them (Calbag EMS WI-10, Battery Management; Calbag EMS WI-15, Lead Management; Calbag EMS WI-21, Copper Management).

  • Procedures for storing liquid wastes (such as water soluble cutting fluid recovered from scrap metal turnings during the packaging process) are documented in the SPCC and Calbag EMS WI-23 (Waste Management).

Scrap and Waste Material Stockpiles and Storage (Outdoor) [Sector-N]:

These control measures minimize contact of stormwater runoff with stockpiled materials, processed materials, and non-recyclable wastes:

• Facility-Wide

  • See Minimize Exposure section

• Special provisions for DA3 (drains directly to Willamette River under permit)

  • A multi-stage treatment system including three different filters and enhanced filtration media is used to reduce any stormwater pollution stemming from outdoor stockpiles in DA3 to levels that are below stormwater permit benchmarks (Figure 1)

• Special Provisions for DA4 (drains to sewer under permit)

  • A multi-stage treatment system including a sand filter with enhanced filtration media is used to reduce any stormwater pollution stemming from outdoor stockpiles in DA4 to levels that are below sewer permit benchmarks (Figure 2)

Stockpiling of Turnings Exposed to Cutting Fluids (Outdoor Storage) [Sector-N]:

These control measures minimize the contact of surface runoff with residual cutting fluids:

• Facility-Wide

  • With the exception of finished titanium bales, turnings are not stockpiled outdoors at the site but may be transported through the site during baling, shipping, or transfer and consolidation into sealed and covered containers.

  • Boxed turnings arriving on site should be immediately drained of excess fluid into wastewater storage tank then moved indoors or into sealed and covered containers.

  • Any stormwater runoff that does come into contact with turnings should be treated as industrial wastewater--discharge as stormwater runoff is not permitted.

• Special Provisions for DA4 (drains to sewer under permit)

  • Cover and grading are used to shield bales in the Titanium Bale Drying tent from precipitation and stormwater run-on, and any stormwater runoff resulting from incidental exposure is captured by the specially-designed drip tray and tank system used to capture residual cutting fluid drips.

Scrap and Waste Material Stockpiles and Storage (Covered or Indoor Storage) [Sector-N]:

These control measures minimize contact of residual liquids and particulate matter from materials stored indoors or under cover with surface runoff:

• Facility-Wide

  • Any residual liquids associated with scrap metal materials stored indoors or under cover that accumulates to the point of pooling must be managed with absorbent materials so as to minimize the potential for tracking into exposed areas--individual drips may be left alone so as to not create a larger dust issue through the use of granular absorbent

  • Any residual particulate materials associated with scrap metal materials stored indoors or under cover shall be swept up and removed as part of regular Housekeeping (see Housekeeping section) so as to minimize the potential for tracking into exposed areas

  • No indoor floor drains connect to the storm sewer system.

Scrap and Recyclable Waste Processing Areas [Sector-N]:

These control measures minimize surface runoff from coming in contact with scrap processing equipment:

• Facility-Wide

  • Scrap metal processing such as a shredding or chopping are not be performed on site

  • Scrap metal processing equipment with hydraulic reservoirs over 150 gallons in capacity are not utilized in outdoor areas exposed to surface runoff

  • Plasma Cutting, Torching, Shearing, and Sorting of scrap metals materials are the only permitted processing activities permitted at the site and shall only be conducted indoors or under cover in the area in DA3 shown on Map DA3 and subject to Housekeeping as described in the Housekeeping section.

Scrap Lead-Acid Battery Program [Sector-N]:

These control measures ensure that scrap lead-acid batteries are properly handled, stored, and recycled:

• Facility-Wide

  • Calbag only accepts whole, source-separated lead-acid batteries--lead-acid batteries are not permitted in mixed loads and broken batteries are not accepted.

  • Lead-Acid batteries are received in DA2 or DA4, and handled and stored indoors in strict accordance with Calbag EMS WI-10 (Battery Management).

Spill Prevention and Response Procedures [Sector-N]:

These control measures address spills of hydraulic fluid from outdoor stationary equipment with reservoirs exceeding 150 gallons, or of mercury from mercury-containing switches:

• Facility-Wide

  • Calbag does not employ outdoor stationary equipment with reservoirs exceeding 150 gallons

  • Calbag does not purchase elemental mercury or mercury-containing switches

Supplier Notification Program [Sector-N]:

These control measures notify major suppliers which scrap materials will not be accepted or will be accepted only under certain conditions:

• As per Calbag EMS WI-04 (Material Acceptance), Calbag Buyers are responsible for informing major suppliers of Calbag's MAP

• Major suppliers can view the Material Acceptance Policy at 14001.calbag.co

PROCEDURES AND SCHEDULES

Spill Prevention and Response:

These procedures prevent and prescribe a response to spills, including clean-up and notification procedures:

• Calbag EMS WI-09 (Spill Prevention, Control, and Countermeasures)

• Calbag Portland SPCC Plans (spcc.calbag.com)

Preventive Maintenance:

These are the procedures for conducting inspections, maintenance, and repairs to prevent leaks, spills, and other releases from drums, tanks, and containers exposed to stormwater and the scheduled regular pickup and disposal of waste materials:

• Calbag EMS WI-14 (Trucking Operations) describes inspection procedures for containers exposed to stormwater that may contain incidental waste

• Calbag Portland SPCC Plan (spcc.calbag.com) describes inspection procedures for tanks used to store fluids

• Garbage from business operations and recovered water soluble cutting fluid is picked up as necessary (highly variable; approximately twice a month) by a qualified disposal contractor as specified in Calbag EMS WI-23 (Waste Management)

Operation and Maintenance Plans:

• See Appendix

Employee Education:

• Refer to Employee Education section under Control Measures

• Refer to Calbag EMS training records

OTHER

Records

This plan, including revision history, is stored in Google Sites (account: scott.deridder@calbag.com).  All records are stored electronically in Google Drive (account:  scott.deridder@calbag.com) and can be found here.  Additionally, a "Stormwater Inspection" binder containing paper copies of the following items can be found at the Receptionist Desk for presentation to DEQ, agent or local municipality upon request:

• The current permit

• Permit assignment letter

• Inspection Reports

• Corrective actions

• DMRs

• Laboratory Reports

• Sampling notes including pH calibration records

Records will be kept a minimum of three years unless Calbag is notified otherwise by the DEQ.  Signatures may be physical or digital (i.e. S-signature).

Reporting

The following records must be reported to DEQ or agent:

• Quarterly DMRs

• Analytical reports*

• Sampling event notes (including pH)*

• Tier I (benchmark/visual observation exceedance)*

• Tier II (second year geometric mean exceedance)*

See permit for specific reporting requirements and due dates.

*when required; do not apply in the event of monitoring waiver

Review

The Storm Water Discharge Plan will be reviewed annually by the Environmental Compliance Director before the onset of the rainy season (target date is the second week of September):

• Evaluate storm water management system as a whole

• Evaluate monitoring program and test results

• Evaluate spill response procedures

• Evaluate employee awareness program

• Evaluate preventative maintenance procedures

• Evaluate record keeping procedures

• Revise the plan to incorporate amendments based on the above evaluations, or changes in legal requirements