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 assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.  I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

/s/ Melody M McPharlin

Melody M. McPharlin

Director of Administration

B.S. Environmental Science & Resources Mgmt

3 - Best Management Practices (BMPs)

Operational Source Control BMPs are defined by Ecology as a schedule of activities, prohibition of practices, maintenance procedures, employee training, good housekeeping, and other managerial practices to prevent or reduce the “pollution of waters of the state.” Not included in this definition are BMPs that require construction of pollution control devices.

3.1 - Operational Source Control BMP

3.1A - Good Housekeeping BMPs

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

• see Calbag EMS WI-24 (Housekeeping)

• All dumpsters will be kept under cover or fit with a storm resistant lid that must remain closed when not in use.

3.1B - Preventive Maintenance

• Equipment: Inspect all equipment and vehicles during monthly site inspection for leaking fluids such as oil, antifreeze, etc. Take leaking equipment and vehicles out of service or prevent leaks from spilling on the ground until repaired.

• Storm Drain System:

  • Clean catch basins when the depth of debris reaches 60% of the sump depth. In addition, the debris surface must be kept at least 6 inches below the outlet pipe.

  • Catch basin grates should be free of trash and debris. Trash or debris that is located immediately in front of the catch basin opening, or is blocking inlet capacity of the unit by more than 10%, will be removed.

  • System will be cleaned at least once per permit cycle.

  • Straw bales, wattles and oil-absorbent booms used around the three main catch basins will be replaced as needed.

  • Installation of the catch basin inserts (CBIs) is described in the manufacturer’s literature. CBI maintenance will be as follows:

    • Catch basins will be inspected monthly during the rainy season for clogging or other flow problems (ie improper installation).

    • CBIs will be removed and emptied of debris and solids, as necessary.

• Oil/water Separator: The Environmental Manager is responsible for inspecting the oil/water separator and for making arrangements with an outside service for cleaning. The CMC separator is a coalescing plate separator, Utility Vault model 712-S.

  • The separator will be inspected monthly during the wet season (October 1 through April 30) to ensure proper operation.

  • Tank will be cleaned annually

  • Designated employees will be trained on appropriate separator operation, inspection, recordkeeping and maintenance procedures.

• Pump Station: The Environmental Manager is responsible for inspecting the pump station and for making arrangements with an outside service for cleaning, maintenance and repairs. The pump station, which is the 72”Ø manhole located next to the Aquip unit, will be inspected and cleaned following the pertinent procedures specified above for the storm drain system. Additionally, the pump station will be inspected monthly for:

  • normal pump operation;

  • Floating debris (which may interfere with the float switches);

  • Normal float switch operation (float switches are not tangled or hung up).

The submersible pump is a Goulds Model No. WS5034D3 and operates at 280 gpm. The pump will be maintained in accordance with the manufacturer’s recommendations.  CMC has a backup pump and flexible hose on site that can be used, in the event of a pump failure at the pump station, to transfer stormwater between the pump station and Tank A until the pump station pump is operable. Tank A has a connection port for a portable pump. A portable pump and flexible hose also are available for rent.

• Intermediate Pump: The intermediate pump (variable-speed, Goulds Model No. 3656) will be maintained in accordance with the manufacturer’s recommendations. A backup variable-speed pump is not kept on site; alternatively, if the pump fails, the manual valve located between Tank B and this pump will be turned to route the stormwater (via gravity flow) directly to the Aquip unit during pump troubleshooting.

• Stormwater Storage Tanks A, B, C, D, E, F, G, Overflow Tank, and Associated Float Switches The Environmental Manager or his designee is responsible for inspecting the tanks and for making arrangements with an outside service for cleaning and repairs.

  • Connections and fittings will be inspected for wear/leakage during the monthly site inspection.

  • Annually, the tanks will be drained and flushed out to remove accumulated solids.

  • During (dry) summer months, the tanks should be drained of stormwater so as to reduce the potential for biological growth in the water. Biological growth may clog the Aquip unit.

  • The float switches in Tank B will be inspected weekly during the rainy season (October 1 - April 30) by observing the water levels in the Tank A, B and C sight glasses. For example, if Tank B is more than 1⁄2 full but the intermediate pump is not on, this would indicate the float switch (75%) is not operating properly. The float switches in the Overflow Tank will be inspected during the monthly site inspection for normal float switch operation (float switches are not tangled or hung up).

• Aquip Unit and Flow Meter: The Environmental Manager or his designee is responsible for inspecting the Aquip unit and flow meter and for making arrangements with an outside service as necessary for cleaning, maintenance and repairs. Monthly inspections will be performed to make sure there is enough media to filter out contaminants. Detailed maintenance and troubleshooting procedures are described in the Stormwater Treatment System Operation & Maintenance (O&M) Manual, including maintenance frequency (DCLLC, 2013)

• Overflow Pump: The overflow pump (Homa Model No. TP50M54L/2/3c) will be maintained in accordance with the manufacturer’s recommendations. CMC has a backup pump on site that will be used in the event of a pump failure at the Overflow Tank.

• Service Checklists/Maintenance Logs: Checklists and/or maintenance logs will be maintained by CMC personnel for the equipment/systems listed above. Service vendors will maintain logs for their maintenance activities and provide copies to CMC.

3.1C - Spill Prevention & Emergency Cleanup

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. Work Instruction 09 in Calbag Metals ISO 14001 program also should be looked at concerning spill response.

All spills and leaks must be cleaned up promptly (using absorbents, vacuuming, etc.) to prevent the discharge of pollutants in stormwater runoff. The Environmental Manager is the Spill Coordinator for the facility

Prevention: Employees will prevent spills from occurring by:

• keeping the spill kits stocked and in their designated locations;

• servicing equipment on a regular schedule;

• emptying drip pans;

• adhering to the BMPs for fuels, oils, spent liquids, and liquids received in drums and containers.

Storage of Liquid Chemicals and Petroleum Products. Liquid chemicals and petroleum products must be stored on an impervious surface and provided with containment (e.g., double-walled tank, berm, dike, secondary containment tray/bin). The containment structure must be sized to contain 10% of the total enclosed tank volume or 110% of the volume contained in the largest container, whichever is greater.

A 1,000-gallon, double-walled, diesel fuel storage tank is located outside on the south side of the building (see site map). A 100-gallon mobile fuel tank, which is set inside a secondary containment box, is stationed near the permanent (1,000-gallon) tank. New and spent antifreeze, oils and fuels are stored in 55-gallon drums or smaller containers inside the CMC building; containers are provided with secondary containment.

Containment Areas. Unless this is impractical, precipitation must be prevented from accumulating in secondary containment areas using a roof or equivalent cover. At the CMC facility, the outdoor coolant storage tank has secondary containment. The tank is located in

a shed, which prevents rainwater from accumulating in the containment structure. The mobile fuel tank is set in a secondary containment box; this box has a lid, which prevents rainwater from accumulating in the box.

Spill Kits: Spill kits are located within 25 feet of all stationary fueling stations, fuel transfer stations, mobile fueling units, and used oil storage/transfer stations.

The permit specifies that spill kits shall include the following items:

• Oil absorbent material capable of absorbing 15 gallons of fuel;

• A catch basin cover;

• At least 10 feet of a non-water containment boom with 12-gallon absorbent capacity;

• A non-metallic shovel; and

• Two, five-gallon buckets with lids.

Use of Fueling Nozzles. Do not lock shut-off fueling nozzles in the open position. Do not “top-off” tanks being refueled.

Storm Drains. Block, plug or cover storm drains that receive runoff from areas where fueling, during fueling.

Drip Pans. Use drip pans or equivalent containment measures during all petroleum transfer operations.

Additional Spill-related BMPs. The mandatory spill-related BMPs of the permit include a requirement to “locate materials, equipment, and activities so that leaks are contained in existing containment and diversion systems (confine the storage of leaky or leak-prone vehicles and equipment awaiting maintenance to protected areas).” A leaky forklift or loader can be moved into the building (a protected area) while awaiting repair. Larger equipment, such as the dump truck or a crane, will not fit into the building. If leaking, CMC will respond by using drip pans and/or absorbent materials until the leak is repaired.

Spill Log. A spill log must be maintained, and must include the following information related to spills of chemicals or petroleum products: date and time of spill, name/type of product, location and reason for spill, date and time cleanup was completed, notifications made, and staff involved.

Employee Training: SWPPP training will be provided to all employees who have duties in areas of industrial activity subject to the permit and this SWPPP. The electronic training is located at stormwater.calbag.com as well as the annual training records which include dates the employee received training.  At a minimum, training will be done once per year and include the following content:

• Overview of what is in this SWPPP;

• How employees make a difference in complying with the SWPPP and preventing stormwater contamination;

• Spill response procedures (see WI-09), good housekeeping (see WI-24), maintenance requirement, and material management practices

3.1D - Inspections, Reporting & Recordkeeping

Inspections: Inspections required by the permit must be documented and recordkeeping procedures as follows:

• Facility personnel responsible for inspecting designated equipment/systems/areas are noted in section 5 (Inspections)

• The electronic inspection form can be found:

  • For equipment

• Tracking and follow-up procedures, to ensure a report is prepared and appropriate response actions are taken in response to visual inspections can be seen in section 5.2 (results and recordkeeping)

• Compliance with the signature requirements of the permit are discussed in sections 10 and 13

• The records retention requirements of permit condition S9 is located in section 5.2b

• The monthly inspection statement required by permit condition S7.C.1.c is addressed in section 10 and the statement is included on the monthly inspection form

• This SWPPP will include all inspection reports completed by CMC

3.1E - Illicit Discharges

During each monthly site inspection, look for signs of illicit discharges, especially during dry weather when stormwater isn’t discharging from the site. Monthly site inspections will include:

• Observations made at the location where stormwater is discharged off site;

• Observations for the presence of floating materials, visible oil sheen, discoloration, turbidity, odor, etc. in the stormwater discharge(s); and

• Observations for the presence of illicit discharges such as domestic wastewater, non-contact cooling water, or process wastewater (including leachate).

  • This excludes pavement wastewater to the storm drain system

• If an illicit discharge is discovered, the Permittee shall notify Ecology within seven days. The Permittee shall eliminate the illicit discharge within 30 days.

Permit condition S5.D identifies categories and sources of non-stormwater discharges that are conditionally authorized for discharge. These include discharges from fire fighting activities, uncontaminated air conditioning or compressor condensate, and discharges of uncontaminated groundwater. Refer to the permit for the conditions under which water from these non-stormwater sources may be discharged.

3.1F - BMPs for Vehicle Recyclers*

CMC accepts pre-processed (dismantled and drained) scrap vehicles for recycling. This means fluids, including gasoline, motor oil, antifreeze, brake fluid, and Freon have been removed and batteries and mercury switches have been removed. Fluids in sealed units (such as Spicer axle assemblies, shock absorbers and bumper shocks) do not require removal. Engine blocks and transmissions are accepted, if oil pans and oil filters are removed or if there are large holes in the pans and no standing liquids. Drained radiators and batteries also are accepted for recycling.

CMC may occasionally arrange to receive vehicles that have not been preprocessed, in which case the vehicles will be moved into the building for fluid removal and dismantling. No fluids removal or dismantling will be performed outdoors at the CMC facility.

*Please note that additional structural BMP’s can be found in section 3.2B

• Unloading. Scrap vehicles are inspected on arrival at the facility to confirm they have been pre-processed.

• Vehicle Storage Areas. Employees must continually watch for residual fluid leaks and notify the Spill Coordinator of significant leakage. Drip pans may be used to collect residual fluid. The shred pile/storage area must be inspected at least monthly for pavement staining or similar contamination from residual fluid.

• Storage of Solid Wastes Contaminated with Fluids. These solid wastes (e.g., oily rags, booms and other used absorbent material) must be stored in a suitable, non- leaking container with a solid cover or lid. All containers will be clearly labeled as to contents.

• Drip Pans. Drip pans will be used as needed to collect oil drippage from trucks, equipment, and residual liquids drippage from scrap vehicles, scrap storage boxes, containers and bins, until such time that the leak can be repaired or remedied. Pans must be checked daily and emptied routinely to prevent overtopping. The use of drip pans is preferred over the use of “floor dry” or similar absorbent material, as the drip pan will keep the liquid off the pavement. Repairing the leaking item is the preferred BMP.

• Fluid draining. Drain and transfer fluids from vehicles and other equipment only in a designated area with a waste collection system or over drip pans.

3.1G - SWMM BMPs

Dust Control at Manufacturing Areas. Consistent with the SWMM’s applicable BMPs for “manufacturing areas”, accumulated dust/residue is removed from around the (indoor) baler after baler runs, using the vacuum sweeper.

Fueling at Dedicated Stations. Stationary fueling is done at the diesel fuel storage tank located on the pavement on the south side of the building. The following procedures will be followed:

• The operator must stay at the vehicle or with the equipment at all times during fueling.

• The hose and nozzle will be handled so as to prevent drippage. If drippage occurs, the CMC employee will wipe this up promptly.

• The spill kit located next to the tank will be properly stocked.

• A trained employee will be designated as responsible for spill cleanup.

Loading and Unloading Areas for Liquid or Solid Material. Debris can accumulate outside at uncovered loading/unloading areas, such as the customer unloading bins area next to the dock. These surfaces must be swept frequently to remove material that could otherwise be washed off by stormwater. Outside areas that are covered for a period of time (e.g., by bins) should be swept after the areas are cleared. Drip pans, or other appropriate temporary containment devices, must be placed at locations where leaks or spills may occur such as hose connections and filler nozzles (for example, at the diesel fuel tank). Drip pans shall always be used when making and breaking connections. Loading/unloading equipment such as valves, pumps, flanges, and connections, must be checked regularly for leaks and repaired as needed.

Transfer of Diesel from Bulk Truck to Aboveground Diesel Fuel Storage Tank. The SWMM’s operational BMPs for transferring liquids include the transfer of diesel from a tanker truck to an aboveground storage tank, such as CMC’s stationary diesel fuel tank. The mandated “Operations Plan” is not included in this SWPPP; instead, the spill cleanup procedures referenced in Section 3.1C are provided. The vendor truck driver must remain at the nozzle during unloading and the driver must be trained in spill containment/cleanup; as such, the requirement to have a CMC employee stationed at the tank during vendor unloading is not included here. A spill kit is maintained for use at the diesel tank should a spill occur during tank filling. Spills will be cleaned up promptly. The vendor will wipe up any diesel that is dripped onto the tank during fuel transfer.

Maintenance and Repair of Vehicles and Equipment. CMC must inspect for leaks all incoming vehicles, parts, and equipment stored temporarily outside. Drip pans or containers must be placed under parts or vehicles that drip or that are likely to drip liquids. Batteries and liquids removed from CMC vehicles and equipment must be removed in designated areas and cracked batteries must be stored in a covered non- leaking secondary containment system or in a lidded non-leaking container. Oil and fuel filters must be drained before disposal and waste oil and fuel managed properly.

The CMC forklifts, hostlers, loader and sweepers are maintained by CMC inside the building. The leased forklifts (and sometimes the sweepers) are serviced by a vendor in a dedicated area next to the scale shack. This is an elevated area distant from any catch basin. The cranes, mobile shear and dump truck are too large to service under cover; alternatively, temporary spill containment equipment (e.g., booms, pads, bales) will be placed by CMC or the service vendor when servicing this large equipment. This also will be done during maintenance of the portable shear. Because all stormwater runoff is routed to treatment systems, these BMPs are equally effective to performing all maintenance under cover. Preventive maintenance procedures are described in Section 3.1B, above. Maintenance and repair of the transport truck will be performed off site.

Maintenance of Stormwater Drainage and Treatment Systems. SWPPP- specified maintenance BMPs for drainage and treatment systems are included in the requirements described for these systems in Section 3.1B.

Mobile Fueling of Heavy Equipment. The following operational BMPs will be followed during mobile refueling:

• Ensure that all mobile fueling operations are approved by the local fire department and comply with local and Washington State fire codes.

• Mobile fueling will be done only during daylight hours with adequate light at the filling point.

• Mobile fueling by CMC will be done only with the constant observation of a CMC employee (the employee will not walk away during fueling). Mobile fueling by a vendor will be done only with the constant observation/monitoring of the vendor/driver (the driver will not walk away during fueling).

• The mobile fueling location will be at least 25 feet from any catch basin, or the catch basin will be covered to ensure no spilled or leaked fuel can drain to the storm drain system.

• The surface where fueling takes place must be impervious and in good repair.

• A drip pan of at least five-gallon capacity, or an absorbent pad capable of absorbing five gallons, will be placed under each fueling location prior to and during fuel dispensing. A drip pan will be kept in the mobile fuel tank box for this purpose.

• The mobile fuel tank nozzle has automatic shut-off capability.

• The fuel transfer hose, nozzle, and drip pan/absorbent pad will be handled so as to prevent spills/leaks of fuel. The fuel hose will not be extended across a traffic path.

• The person doing the fueling will not lock the nozzle in the open position. No “topping off” is allowed.

• The CMC employee doing the fueling will be trained annually in spill prevention and cleanup measures and emergency procedures.

• The hose and nozzle will be maintained and replaced when necessary to prevent failures.

• A spill kit will be readily available.

Roof/Building Drains. The SWMM’s pollutant control approach for roofs and building drains at manufacturing and commercial buildings is to evaluate potential sources of stormwater pollutants and apply source control BMPs where feasible. Applicable operational BMPs for manufacturing and commercial buildings are to sample and analyze the roof runoff and implement appropriate source control measures such as operational changes.

CMC’s building roof runoff was sampled in 2007 and 2008 as part of a Level Three investigation. Based on the sampling results and other considerations (DCLLC and RH2 Engineering, Inc., 2008) roof runoff has been routed to the stormwater treatment system. The operational BMPs associated with roof runoff are as follows:

• To reduce tracking and the emission of particulate, accumulated dust/residue is removed from around the (indoor) baler after baler runs, using the vacuum sweeper;

• Annually during the summer months, the area of the roof surrounding the roof vents is mopped or wiped down with wet rags;

• Until a different schedule is identified, filter fabric installed on the exhaust vents will be checked monthly and the fabric replaced as necessary.

Storage of Liquids in Containers/Drums. All liquids in containers or drums (55-gallon drums and smaller), including new and spent oils, fuels and antifreeze, are stored inside the building.

Coolant (Cutting Oil) Collection Trays and Outdoor Coolant Storage Tank. When in use, trays will be inspected daily to monitor the need for emptying and to prevent overtopping. The customer/vendor will be notified promptly that the box is not liquid tight and requires sealing. The 359-gallon-capacity coolant storage tank is located in a shed next to the (outside) west wall

of the building. It will be inspected monthly to identify problems with the drain valve (e.g., leaks, corrosion, etc.) and to monitor liquid level. The tank must be labeled as to contents.

Storage of Liquids in Permanent Aboveground Tanks. As noted above, the facility has a 1,000-gallon diesel fuel tank and a 359-gallon coolant storage tank. The aboveground storage tank areas will comply with the Uniform Fire Code and National Electric Code, as applicable. The tank areas will be cleaned regularly and inspected monthly. Fittings, hose connections and valves will be checked for leaks, cracks or corrosion and repaired or replaced as necessary. The area will be checked for fluid spills or leaks, and to make sure the tank labels are still legible and accurate. Tanks will be clearly labeled as to contents. The secondary containment structure beneath the coolant tank will be checked for liquid and pumped out as necessary. A drip pan (minimum five-gallon capacity) will be used during diesel tank filling and during fueling from the tank.

Vehicle/Equipment Washing or Steam Cleaning. The Industrial Stormwater General Permit prohibits the discharge of process wastewater (e.g., vehicle washing wastewater) to surface water and stormwater that commingles with process wastewater is considered process wastewater. CMC will not wash or steam clean vehicles or equipment outdoors unless wash water can be contained and collected and taken off site for disposal, the wash water is treated and reused in a closed-loop, zero discharge system, or the wash water is collected and discharged to sewer with appropriate City approvals.

Cleaning Exterior Building Surfaces. The SWMM allows building wash water (without soaps/detergents) to be drained to soil for infiltration. This option is not available to CMC. Alternatively, building wash water may be discharged to the sewer with appropriate City approvals.

Spill Kits. Please see the site map for locations.

3.1H - Additional Operational BMPs Employed by CMC

In-bound Materials Inspection

• For inspection process, see Work Instruction 04 - Material Acceptance

• See Material Acceptance Policy for items that have restrictions

Unloading Practices. Bins are provided at the dock for individual customers to off- load their scrap material. Customers are not allowed to break down their scrap items on site.

Indoor Storage of Specific Scrap Materials. The following materials are stored inside the building, in part to reduce the potential impact on stormwater runoff:

• Aluminum, steel and brass turnings

• Brass slag and other brass scrap

• Lead scrap (except lead weights still housed inside wheels)

• Electric motors

• Copper scrap (including copper wire)

• Bullet shells, lead and copper bullet jackets

• Transmissions

Cutting Areas. All torch cutting and saw cutting in the nonferrous yard is performed in the covered area on the west side of the building. To prevent metal particles from tracking or blowing outside the covered area, the cutting area will be swept (manually or with the mechanical sweeper) or vacuumed, when needed. Cutting in the ferrous yard will be limited to the designated areas, which will be swept at the end of each shift (manually or with the vacuum sweeper).

Titanium Turnings Storage Area. Boxed titanium turnings are stored in a 30-foot by 30-foot covered area located near the northwestern corner of the site. Residual turnings fluid (coolant) may drip from the boxes and onto the steel plate-covered pavement in the storage area. The storage area will be inspected on a weekly basis and residual coolant will be removed from the storage area on a weekly basis. Boxed (loose) titanium turnings may be stored outdoors before they are moved inside the building for baling. While stored outdoors, these boxes will be covered with tarps (or other cover).

Access Buffer. CMC maintains a buffer between the ferrous yard operations and the perimeter ecology blocks to prevent material encroachment toward the southern perimeter and to provide access for the sweeper and maintenance vehicles.

3.2 - Structural Source Control BMPs

“Structural source control BMPs” are defined by the permit as physical, structural or mechanical devices or facilities that are intended to prevent pollutants from entering stormwater. These BMPs typically include enclosing or covering the pollutant source (e.g., with a building, enclosure, roofed area, tarps) and/or segregating the pollutant source to prevent run-on of uncontaminated stormwater (e.g., berming a container storage area).

3.2A - Mandatory Structural BMPs Specified in the Permit

The permit requires that structural BMPs be included that minimize the exposure of processing and material storage areas to rain, snow, snowmelt and runoff by either “locating these industrial materials and activities inside or protecting them with storm resistant coverings (S3.B.4.b.ii.). Industrial materials on site include various different types of metals that have been purchased for resale (ie stainless steel, aluminum, steel).

Permittees shall:

• Use grading, berming or curbing to prevent runoff of contaminated flows. At CMC, grading, berming and the stormwater drainage system route all stormwater through treatment processes.

• Use grading, berming or curbing to divert run-on away from processing and material storage areas. Scrap metal recycling operations occur across the yard areas and it is not feasible to divert run-on around these large areas. The berm around the facility serves to prevent run-on onto the facility.

• Perform all cleaning operations indoors, under cover, or in bermed areas that prevent stormwater runoff and run-on and also that capture any overspray.

• Ensure that all wash water drains to a collection system that directs the wash water to further treatment or storage and not to the stormwater drainage system. CMC currently is not equipped for outdoor washing or steam cleaning and thus it is not allowed to be performed. It may be performed by an outside service, only if the service is capable of collecting the wash water and transporting it off site for proper disposal.

3.2B - BMPs for Vehicle Recyclers

Vehicle Storage in the Ferrous Yard. Only preprocessed (dismantled and drained) vehicles will be stored in the ferrous yard. Employees will be on the lookout for residual fluids dripping from preprocessed vehicles and notify the Spill Coordinator of significant spills or releases. Drip pans may be used to collect residual fluid.

Storage of Vehicle Components. The following materials are stored inside the building: batteries, mercury switches that are discovered after vehicle acceptance and removed from vehicles, and drained transmissions.  Batteries must be stored on the ground in a leak proof container.

Scrap Metal Storage Piles. All stormwater from outdoor scrap metal storage piles/areas, including areas that may store scrap vehicle parts, is routed to the on-site stormwater treatment system.

3.2C - SWMM BMPs

Loading and Unloading Areas for Liquid Material and Solid Material. Consistent with the SWMM structural BMPs, containerized liquid materials are loaded and unloaded at docks that provide for unloading fully inside the building or at a covered platform. The dock areas are paved and sloped to prevent the ponding of water and catch basins are not covered by material, containers or equipment.

Spent coolant is transferred from the storage shed tank to a vendor (tank) truck when shipped off site for recycling. Structural BMPs for this transfer include a sloped and paved surface and routing all stormwater to on-site treatment systems.

Solid materials (scrap metal) are unloaded at the CMC docks, into bins provided for customers and located on pavement adjacent to the docks, and onto the pavement in the nonferrous and ferrous yard areas to the west and south of the building, respectively. It is not practical to conduct all unloading in the building or under a roof or other cover, due to the nature of site operations (including the type and volume of material handled). Alternatively, site stormwater is collected and conveyed to on-site treatment systems. The collection system includes a berm around the facility that prevents stormwater from running off site and routes it to the storage/treatment systems.

Transfer of Diesel from Bulk Tank Truck to Aboveground Diesel Storage Tanks. Consistent with the SWMM BMPs, transfers take place on a paved surface and spill cleanup kits are provided on site.

Maintenance and Repair of Vehicles and Equipment. The CMC forklifts, hostlers, loader and sweepers are maintained by CMC inside the building. The leased forklifts (and sometimes the sweepers) are serviced by a vendor in a dedicated area next to the scale shack. This is an elevated area distant from any catch basin. The cranes, mobile shear and dump truck are too large to service under cover; alternatively, temporary spill containment equipment (e.g., booms, pads, bales) will be placed by CMC or the service vendor when servicing this large equipment. This also will be done during maintenance of the portable shear. Because all stormwater runoff is routed to treatment systems, these BMPs are equally as effective to perform all maintenance under cover.

Mobile Fueling of Heavy Equipment. The structural BMPs applicable to this activity are the use of an automatic shutoff nozzle on the mobile tank and adequate lighting at the refueling location.

Storage of Liquids in Drums and Containers. Containers must be stored inside the building (unless impractical due to fire code constraints), or in an outside area that is covered, paved, and provides secondary containment (bermed or diked). If containerized liquids are temporarily stored outside, an alternative containment unit may be used (see SWMM, Figure 2.2.8).

Storage of Liquids in Permanent Aboveground Tanks. The facility has two permanent tanks located outside the building: the 1,000-gallon diesel fuel tank and the 359-gallon coolant storage tank. Both tanks are located on an impervious surface. The diesel fuel tank is UL-approved; it is double-walled and thus has secondary containment. It is fitted with a “Fill-rite” meter (an overfill protection system) to minimize spillage during filling by the fuel vendor. The coolant tank is hard-plumbed to receive coolant via piping from inside the building, is located in a shed, and is set in a secondary containment tank that provides containment for 110 percent of the coolant tank volume. For overfill protection, the pipe valve is kept closed. When it is necessary to drain coolant to the tank, the operator opens the valve and monitors the draining to prevent overfilling.

Turnings Storage. Turnings containing residual cutting oils or coolants must be stored in a covered area or in lidded or tarped dumpsters or bins.

Roof/Building Drains. The SWMM’s pollutant control approach for roofs and building drains at manufacturing and commercial buildings is to evaluate potential sources of stormwater pollutants and apply source control BMPs where feasible. Applicable operational BMPs are specified in the SWMM, but some are actually structural source control measures “such as air pollution control equipment...”

CMC has implemented an air pollution control structural BMP at the four building exhaust vents (with fans) located on the building roof. Screens are attached to the vent shroud and filter fabric is installed on the screens. The filter fabric removes particulate exhaust from the building, identified by CMC as particulate coming primarily from the indoor baling of radiators.

The 2012 SWMM added an applicable structural BMP: “Paint/coat the galvanized surfaces as described in Ecology Publication #08-10-025” (Ecology, 2008). This BMP is omitted from this SWPPP as it is unnecessary and infeasible for the CMC facility for the following reasons.

The building roof is approximately 2 acres in size (the CMC facility, including the building, is approximately 8.75 acres). The roof is galvanized and uncoated. Ecology Publication #08-10-025 reports that painting galvanized surfaces may reduce their 30-year, maintenance-free life, require painting at frequent intervals, and may invalidate a roof warrantee. Further, painting the roof would not address zinc generated from the downspouts nor would it prevent ongoing area atmospheric deposition that contributes copper, zinc and other pollutants onto the roof and facility (Brandenberger, et al, 2010).

Alternatively, CMC re-routed the roof runoff to the facility stormwater treatment system. This way zinc generated from the roof and from the downspouts is provided treatment, as well as [area] air contaminants that continue to deposit onto the roof. Routing the roof runoff to the treatment system is a more protective option than painting the galvanized roof.

3.2D - Additional Structural BMPs Employed by CMC

Catch Basin Perimeter Controls. In addition to catch basin inserts, a system of oil- absorbent booms, straw wattles, and straw bales is installed around the three main catch basins in the yard. This system serves to block and filter out coarse sediment (solids) and also removes oil from the stormwater.

3.3 - Treatment BMPs

3.3A - General

Treatment BMPs are intended to address residual pollutants when operational and source control BMPs are not adequate to reduce pollutants by a significant amount. Permit condition S3.B.4.b.iii. includes the following mandatory treatment BMPs:

• Use treatment BMPs consistent with the SWMM (or other Ecology-approved document per condition S3.A.3.);

• Employ oil/water separators, booms, skimmers or other methods to eliminate or minimize oil and grease contamination of stormwater discharges;

• Obtain Ecology approval before construction/installation of all treatment BMPs that include the addition of chemicals to provide treatment.

The SWPPP also must include BMPs necessary to comply with applicable federal technology-based treatment requirements under 40 CFR 125.3. The federal treatment requirements of 40 CFR Part 125.3 apply to facilities with technology-based effluent limitations. As CMC has no technology-based effluent limitations in its NPDES stormwater discharge permit, these federal technology-based treatment requirements are not applicable to the facility.

As discussed in this SWPPP, operational and structural BMPs are in place at the site and their effectiveness is monitored through inspections and stormwater sampling. Based on the nature of the site’s metal recycling operations, visual observations, and sampling results, treatment BMPs are necessary for additional control of turbidity, metals, and petroleum hydrocarbons in stormwater. Treatment BMPs have been implemented, including filtration at the catch basins, oil/water separation, detention/settling in tanks, and multimedia filtration in an end-of-pipe treatment system. The treatment structures/processes are consistent with the SWMM, which identifies treatment options employed by CMC for oil control (coalescing plate oil/water separator, catch basin inserts), for total suspended solids (TSS) control (catch basin inserts, settling tanks, multimedia filtration), and for metals reduction (catch basin inserts, multimedia filtration). Detention in the storage tanks also reduces metals through solids settling. As previously noted and consistent with the SWMM, roof runoff is routed to the treatment system.

No chemical additives are used to provide treatment.

3.3B - Catch Basin Filtration

Catch basin inserts are used as a filtration method for total suspended solids (TSS) and particulate metals.  There is also a system of oil-absorbent booms, straw wattles, and straw bales installed around the catch basin perimeter of the three main catch basins in the yard and serves to block and filter out coarse sediment (solids) and remove oil from the stormwater. Catch basin filters also are a SWMM-recommended treatment BMP for dust control; i.e., removal of TSS in stormwater

3.3C - Oil/water Separation

All runoff from the yard areas and loading/unloading dock areas is routed to the oil/water separator located in the western corner of the facility. The separator is a coalescing plate oil/water separator, Utility Vault 712-S. The separator was designed to treat the flow from a 6-month/24-hour storm event (Barghausen, 2000).

An oil-removal module is installed in the pretreatment chamber of the Aquip® Enhanced Filtration System. Attached to the existing pretreatment outlet pipe, the module is intended to act as a combination boom and baffle. As stormwater flows from the pretreatment chamber to the filtration bed, the water surface contacts the module’s oil- absorbent boom. It is designed to assist with oil sheen removal; it is not meant to replace existing upstream oil removal measures but is intended as an additional oil removal step. The boom is visible from the Aquip inspection ladder and can readily be replaced when necessary.

3.3D - Detention/Settling

Stormwater settling is provided by the use of seven, aboveground tanks. Horizontal Tanks A and B have a capacity of 40,000 gallons each; each steel tank is 13 feet in diameter (Ø) and 40 feet long. Tanks C, D and E are vertical, fiberglass tanks; each are 20,000-gallon capacity, dish/cone bottomed, and approximately 12.5’Ø by 25’ in height.

Tanks F and G also are vertical, fiberglass tanks; each are 30,000-gallon capacity, flat- bottomed, and approximately 14.5’Ø by 28’ in height. The seven tanks are plumbed in series, with a pump located between Tanks B and C. Together the tanks provide a total of 153,140 gallons of live storage and associated settling.

Settling reduces turbidity and TSS, as well as metals. Procedures for tank operation are described in the O&M Manual.

3.3E - Multimedia Filtration

In 2010, CMC installed an Aquip® Enhanced Filtration System Model 210SBE (Aquip unit) to treat site stormwater. The Aquip unit is approximately 8 feet wide by 32 feet long. It is located next to the storage tanks and is plumbed to receive stormwater from the common header that connects Tanks C through G. The unit is a passive filter designed to remove TSS and metals. The system provides an initial pH buffering step (buffering chamber), followed by layered filtration media understood to be two grades of washed sand, activated aluminum oxide, and granular activated carbon (GAC). The system is designed for passive hydraulic flow and allows stormwater within the unit to drain out between storm events. Pollutant removal in the first (pre-treatment) chamber occurs by gravity settling and removal in the filtration chamber occurs through sorption, filtration and co-precipitation (StormwateRx, 2010).

A detailed system description and procedures for system operation and maintenance are provided in the O&M Manual, of which a copy is located toward the bottom of this webpage. O&M Manual procedures include:

• An inspection program capable of detecting Aquip malfunctions and the discharge of stormwater not treated through the Aquip (see O&M Manual Section 3 System Operation, Section 4 Monitoring and Testing Procedures, which include bypass monitoring, and Section 5 Maintenance and Trouble- shooting);

• How the duration and the volume of stormwater not treated through the Aquip will be estimated (see O&M Manual Section 4.7 Bypass Monitoring and Sampling)1; bypass sampling details are include in Section 9 of this SWPPP; and

• How solids loading in stormwater influent to the Aquip is reduced and controlled (see O&M Manual Section 4.1 Monitoring Influent Solids Loading).

1 Volume-estimating procedures will be followed once they have been approved by Ecology.

3.4 - Stormwater Peak Runoff and Volume Control BMPs

The permit requires that stormwater runoff from new development or redevelopment be evaluated to determine if flow control is necessary. CMC is not a new development and no redevelopment is planned at this time.

3.5 - Erosion and Sediment Control BMPs

Permit condition S3.B.4.b.iv. includes mandatory erosion and sediment control BMPs where necessary to prevent the erosion of soils and other earthen materials.

As previously noted, 100 percent of the CMC facility is covered with pavement or structures. There are no potential areas of soil erosion. The facility’s pavement is monitored to determine whether/when repairs are needed and damaged pavement is repaired on a periodic basis.

5 - Inspections

5.1 Site Inspection Frequency and Personnel

Visual inspections of the site must be performed on a monthly basis and the inspections must be documented. Inspections must be performed by qualified personnel; that is, “personnel who possess the knowledge and skills to assess conditions and activities that could impact stormwater quality at the facility, and evaluate the effectiveness of the BMPs required by the permit.”

5.2 Inspection Components, Results and Recordkeeping

Each monthly inspection shall include the components listed below. The inspector shall record the results of each monthly inspection in an inspection checklist (or other report) and keep this record on site as part of the SWPPP for Ecology review. A monthly inspection checklist prepared by Ecology may be used; a copy is provided here.

5.2a Inspection Components

• Observations made at the sampling point and where stormwater discharges from the site, including observations for the presence of floating materials, visible oil sheen, discoloration, turbidity, odor, etc.

• Observations for the presence of illicit discharges such as domestic wastewater, noncontact cooling water, or process wastewater (including leachate).

  • If an unauthorized, non-stormwater discharge is discovered the permittee must notify Ecology within seven days and eliminate the discharge within 30 days.

• Verify that the description of potential pollutant sources in Sections 2.2b are still accurate.

• Verify that the site map reflects current conditions.

• Visually assess media levels to insure that there is adequate media for filtration in the Aquip.

• Assess all BMPs that have been implemented, noting all of the following:

  • Effectiveness of the BMP inspected;

  • Location(s) of BMPs that need maintenance, the reason maintenance is needed, and a schedule for maintenance;

  • Location(s) where additional or different BMPs are needed and the rationale for the additional/different BMP.

5.2b Results and Recordkeeping

The results of each inspection will be recorded in an inspection checklist, which will be available for Ecology review. The following will be included in the checklist:

• Time and date of inspection.

• Locations inspected.

• Include a statement by the inspector and the Responsible Corporate Officer that the site is either in compliance or out of compliance with the terms and conditions of the SWPPP and the permit.

• If the inspection indicates the site is out of compliance, prepare a summary report and implementation schedule for the remedial actions CMC plans to take.

• Include the name, title, and signature of the person conducting the inspection, and the following statement: “I certify that this report is true, accurate, and complete, to the best of my knowledge and belief.”

• Include a certification and signature of the Responsible Corporate Officer or a Duly Authorized Representative of the facility per G2.B. and D. (see permit condition G2., Signatory Requirements, for details of personnel authorized to sign and the certification statement).

5.3 Non-Compliance Reports

If non-compliance is identified during an inspection, CMC must prepare a summary report per the requirements of permit condition S7.C.1.d. and S7.D. Review Section 6.6 of this SWPPP and permit condition S9.E. for details.

7- Corrective Actions

7.1 General

As discussed in Section 4, sampling results are compared to benchmark values specified in the permit (listed in the Section 4.6 table of this SWPPP). Benchmark values are not water quality standards and are not permit or discharge limits- they are indicator values. Ecology considers a stormwater pollutant concentration below the benchmark value as unlikely to cause a water quality violation, and above which it may. When stormwater pollutant concentrations exceed benchmarks, corrective action requirements are triggered.

Permit condition S8. details the steps a permittee must take if stormwater sampling results are above benchmark values. Three levels of corrective action are detailed (Level One, Two, and Three) and are triggered based on the number of times a benchmark is exceeded (for a single parameter) during a calendar year. The levels reflect escalating requirements to review this SWPPP, make revisions to the SWPPP to implement additional operational and structural BMPs, as necessary, and to implement additional treatment BMPs, as necessary. Each level of corrective action has a specified deadline.

7.2 Implementation Deadlines and Reporting

Implementation deadlines specified for each level of corrective action are provided in Section S8. of the permit. Corrective actions taken will be summarized in the Annual Report (S9.B).

7.3 Schedule Extensions and Waivers

Under certain circumstances, a schedule extension for Level Two and Three corrective actions may be obtained; e.g., if the construction of a structural BMP will take longer than the time allotted by the permit. The permit also provides a waiver provision. Under certain circumstances, the implementation of additional structural and/or treatment BMPs may be waived by Ecology. The permittee must provide a technical basis in its application for a schedule extension or a waiver and receive a Modification of Permit Coverage. Applications must be submitted by the permit-specified deadline. See permit condition S8. for details.