Orange County Coastkeeper v. Republic Services, Inc. et al

Filing 34

CONSENT DECREE by Judge Beverly Reid O'Connell. NOW THEREFORE IT IS HEREBY STIPULATED BETWEEN THE SETTLING PARTIES AND ORDERED AND DECREED BY THE COURT AS FOLLOWS: Defendants shall pay a total of $15,000.00 to Coastkeeper for fees and costs incurred by Coastkeeper in monitoring Defendants' compliance with this Consent Decree Defendants agree make a payment of $167,000.00 Payment shall be made within thirty (30) days of entry of this Consent Decree by the Court payable to the "O.C./I.E. Public Interest Green Fund" and delivered by certified mail or overnight delivery to: Orange County Community Foundation, 4041 MacArthur Boulevard, Suite 510, Newport Beach, California 92660. Defendants shall pay a total of  6;193,000.00 to Coastkeeper to partially reimburse Coastkeeper for its investigation fees, expert/consultant fees and costs, and reasonable attorneys' fees incurred as a result of investigating and preparing the lawsuit, and negotiating this Con sent Decree. This Consent Decree constitutes a full and final settlementof this matter. (MD JS-6. Case Terminated.) (Attachments: # 1 Exhibit A, # 2 Figures, # 3 Appendix B, # 4 Figures, # 5 Appendix C, # 6 Figures, # 7 Appendix B Receipt of Notice of Intent, # 8 Figures, # 9 Tables, # 10 Tables - Part 1) (jp)

Exhibit A

DRAFT STORM WATER POLLUTION
PREVENTION/MONITORING PLAN
Consolidated Volume Transport (CVT)
Material Recovery Facility and Transfer Station
1131 North Blue Gum Street
Anaheim, CA, 92806
WDID No. 8 30I000220

Prepared for:

Republic Waste Services of Southern California, L.L.C.
1131 N. Blue Gum
Anaheim, CA 92806

Prepared by:

1036 W. Taft Avenue, Suite 200
Orange, CA 92865

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 upon my inquiry of the 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.

_____________________________________________________________________________

General Manager
Republic Waste Services of Southern California, L.L.C.
Revision Date: September 30, 2013

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TABLE OF CONTENTS
SECTION A. STORM WATER POLLUTION PREVENTION PLAN REQUIREMENTS .............................. 1
A.1

BACKGROUND ............................................................................................................................................. 1

A.1.1

Regulatory Background ........................................................................................................................... 1

A.1.2

Site Information ....................................................................................................................................... 2

A.2

OBJECTIVES ................................................................................................................................................. 2

A.3

FACILITY ORGANIZATION & DESCRIPTION..................................................................................... 3

A.3.a
A.4

Pollution Prevention Team ...................................................................................................................... 3

STORM WATER DRAINAGE PATTERNS AND SAMPLING LOCATIONS ...................................... 3

A.4.1

Drainage Estimate .................................................................................................................................... 4

A.5

LIST OF SIGNIFICANT MATERIALS ...................................................................................................... 5

A.6

POTENTIAL POLLUTANT SOURCES ..................................................................................................... 5
A.6.a.i Industrial Processes ............................................................................................................................... 5
A.6.a.ii Material Handling and Storage Areas ................................................................................................... 7
A.6.a.iii Dust and Particulate Generating Activities ........................................................................................... 7
A.6.a.iv Significant Spills and Leaks .................................................................................................................. 7
A.6.a.v Non-Storm Water Discharges ................................................................................................................ 7
A.6.a.vi Soil Erosion ........................................................................................................................................... 8

A.6.b Potential Pollution Sources and Corresponding BMPs .................................................................................. 8
A.7

ASSESSMENT OF POTENTIAL POLLUTANT SOURCES ................................................................... 8

A.8

STORM WATER BEST MANAGEMENT PRACTICES ......................................................................... 9

A.8.a

STORM WATER BEST MANAGEMENT PRACTICES – NON-STRUCTURAL .............................. 9

A.8.a.i Good Housekeeping .............................................................................................................................. 9
A.8.a.ii Preventive Maintenance ...................................................................................................................... 10
A.8.a.iii Spill Response ..................................................................................................................................... 10
A.8.a.iv Material Handling and Storage ............................................................................................................ 11
A.8.a.v Employee Training .............................................................................................................................. 11
A.8.a.vi Waste Handling / Waste Recycling ..................................................................................................... 12
A.8.a.vii Recordkeeping and Internal Reporting ............................................................................................... 12
A.8.a.viii Erosion Control and Site Stabilization ............................................................................................... 12
A.8.a.ix Inspections .......................................................................................................................................... 13
A.8.a.x

Metal Roof Sampling ......................................................................................................................... 13

A.8.a.xi Quality Assurance .............................................................................................................................. 14
A.8.b

STORM WATER BEST MANAGEMENT PRACTICES – STRUCTURAL ...................................... 14

A.8.b.i Overhead Coverage ............................................................................................................................. 14
A.8.b.ii Retention Ponds .................................................................................................................................. 14
A.8.b.iii Control Devices .................................................................................................................................. 14
A.8.b.iv Secondary Containment Structures ..................................................................................................... 15
A.8.b.v Treatment ............................................................................................................................................ 15

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TABLE OF CONTENTS (continued)
A.9

ANNUAL COMPREHENSIVE SITE COMPLIANCE EVALUATION ................................................ 16

A.10

SWPPP GENERAL REQUIREMENTS .................................................................................................... 17

SECTION B. MONITORING PROGRAM AND REPORTING REQUIREMENTS ....................................... 19
B.1

SWPPP IMPLEMENTATION SCHEDULE AND RESPONSIBILITY ................................................ 19

B.2

OBJECTIVES ............................................................................................................................................... 19

B.3

NON-STORM WATER VISUAL OBSERVATIONS............................................................................... 19

B.4

STORM WATER DISCHARGE VISUAL OBSERVATION .................................................................. 20

B.5

SAMPLING AND ANALYSIS .................................................................................................................... 20

B.5.a Sampling Preparation .................................................................................................................................. 21
B.5.b Sampling Protocol ........................................................................................................................................ 21
B.5.c Sampling Methods and Parameters .............................................................................................................. 21
B.6

SAMPLE STORM WATER DISCHARGE LOCATIONS ...................................................................... 22

B.6.a Representative Drainage Areas ................................................................................................................... 22
B.6.b Comingled Storm Water.............................................................................................................................. 22
B.6.c Sample Locations That Are Difficult to Observe and Sample..................................................................... 23
B.6.d Substantially Identical Drainage Areas ....................................................................................................... 23
B.7

VISUAL OBSERVATION AND SAMPLE COLLECTION EXCEPTIONS ......................................... 23

B.7.a Exceptions ................................................................................................................................................... 23
B.7.b Non-Qualifying Observation and Sampling Exceptions ............................................................................. 23
B.8

ALTERNATIVE MONITORING PROCEDURES .................................................................................. 23

B.9

MONITORING METHODS ....................................................................................................................... 24

B.9.a Rationale for CVT Monitoring Program ..................................................................................................... 24
B.9.a.i Visual Observations .............................................................................................................................. 24
B.9.a.ii Sampling Location................................................................................................................................ 24
B.9.a.iii Analytical Methods and Detection Limits ............................................................................................ 24
B.9.b Sampling and Sample Preservation ............................................................................................................. 25
B.10

INACTIVE MINING OPERATIONS ........................................................................................................ 26

B.11

SAMPLING AND ANALYSIS EXEMPTIONS AND REDUCTIONS ................................................... 26

B.12

RECORDS .................................................................................................................................................... 26

B.13

ANNUAL REPORT ..................................................................................................................................... 26

B.14

GROUP MONITORING ............................................................................................................................. 27

B.15

WATERSHED MONITORING OPTION ................................................................................................. 27 

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TABLE OF CONTENTS (continued)
Figure 1 – Site Vicinity Map
Figure 2 – SWPPP Site Plan
Figure 3A – Preliminary BMP Site Map
Figure 3B – Preliminary Bioretention Area 1
Figure 3C – Preliminary BMP Area 3
Figure 3D – Preliminary BMP Area 5
Figure 3E – Preliminary Storm Chamber Underground Infiltration Area

Table 1 – CVT Storm Water Pollution Prevention Team
Table 2 – List of Significant Materials at CVT
Table 3 – Potential Pollution Sources and Corresponding BMPs

Appendix A – Copy of General Storm Water Permit
Appendix B – Receipt of Notice of Intent
Appendix C – Example of Annual Report Forms
Appendix D – Example of Visual Observation Forms
Appendix E – Example of Chain of Custody Form

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SECTION A. STORM WATER POLLUTION PREVENTION PLAN REQUIREMENTS
A.1

BACKGROUND

This storm water pollution prevention plan (SWPPP) has been created by Environ Strategy
Consultants, Inc. (Environ Strategy) for Consolidated Volume Transport (CVT) owned and
operated by Republic Waste Services of Southern California, L.L.C. (Republic). The contents of
this SWPPP are consistent with the guidelines of the California State Water Resources Control
Board (SWRCB) and include facility runoff locations and descriptions, narratives of both facility
processes and storm water prevention techniques, and a monitoring program with reporting
requirements. The objectives of this SWPPP are: (1) to identify and evaluate sources of
pollutants associated with industrial activities that may affect the quality of storm water
discharges and authorized non-storm water discharges from the site; and (2) to identify and
implement site-specific Best Management Practices (BMPs) to reduce or prevent pollutants
associated with industrial activities in storm water discharges and authorized non-storm water
discharges. The results of this SWPPP are based upon a facility audit and documentation
provided by Environ Strategy. CVT is fully aware of the significance of pollution on the
immediate and larger environment and is adamant about maintaining and exceeding regulatory
compliance.
A.1.1 Regulatory Background
Storm water at CVT is managed in accordance with appropriate federal and state regulations
including the Environmental Protection Agency, National Pollutant Discharge Elimination
System (NPDES) requirements. In response to federal regulations promulgated in 1972 by the
Water Pollution Control Act (also known as Clean Water Act or CWA), as amended in 1989 and
codified as final regulations in 1990 in Title 40 of the Code of Federal Regulations, Part 122
(40 CFR 122), SWRCB elected to issue a statewide General Permit that would apply to all
discharges covered under the new regulations, except municipal storm drain systems and storm
water discharges from construction activities covered under separate statewide permits. The
General Permit was initially issued in November 1991 under Water Quality Order
No. 91-13-DWQ. The monitoring requirements of the General Permit were amended in
September 1992 by Order No. 92-12-DWQ.
SWRCB issued a revised General Permit under Order No. 97-03-DWQ in April 1997 (revised
General Permit) to replace the existing General Permit issued under Order No. 91-13-DWQ (as
amended by Order No. 92-12-DWQ). This revised General Permit was issued to amend some of
the provisions of the expired permit in accordance with federal regulations. The revised General
Permit is described in the following section.
The revised General Permit issued under SWRCB Order No. 97-03-DWQ had waste discharge
requirements (WDRs) for discharges of storm water associated with industrial activities.

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Industrial sites covered under the former and revised permits must comply with the following
requirements:





Submit an abbreviated Notice of Intent (NOI) form.
Prepare a revised SWPPP to comply with the appropriate requirements of the revised
General Permit.
Develop and implement a revised storm water monitoring program.
Report storm water testing results and perform a comprehensive site compliance evaluation
annually.

A copy of the revised General Permit for Order No. 97-03-DWQ is enclosed in Appendix A.
CVT originally applied for the Regional Water Quality Control Board General Storm Water
Permit on March 2, 1992. A copy of the NOI is included in Appendix B.
A.1.2 Site Information
This facility provides commercial and residential solid waste pick up within Anaheim and
outlying areas. CVT provides a valuable service to the surrounding community through waste
and recyclable material pickup, processing, and handling (see Figure 1). The facility is a whollyowned subsidiary of Republic.
Name/Address:

Republic Waste Services of Southern California, L.L.C.
dba Consolidated Volume Transport (CVT)
1131 North Blue Gum Street
Anaheim, CA 92806

Site Contact:
Facility SIC Codes:
WDID #:

Robin Murbach (Telephone [phone])
4953 (Transfer Station), 5093 (Recycling), 4214 (Hauling)
8 30I000220

A.2

OBJECTIVES

The objectives of this SWPPP are: (1) to identify and evaluate sources of pollutants associated
with industrial activities that may affect the quality of storm water discharges and authorized
non-storm water discharges from the site; and (2) to identify and implement site-specific best
management practices (BMPs) to reduce or prevent pollutants associated with industrial
activities in storm water discharges and authorized non-storm water discharges. The results of
this SWPPP are based upon a facility audit and documentation provided to Environ Strategy.
CVT is fully aware of the significance of pollution on the immediate and larger environment and
is adamant about maintaining and exceeding regulatory compliance.

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FACILITY ORGANIZATION & DESCRIPTION

This site houses the Orange County operations of Republic doing business as the CVT Material
Recovery Facility (MRF) and Transfer Station, Anaheim Disposal, etc. Republic is an integrated
solid waste management company. CVT was organized primarily to conduct recycling, transfer,
and solid waste hauling operations. Site facilities include maintenance facilities, administrative
offices, recycling facilities, solid waste transfer, a public drop-off area and the MRF (see
Figure 2).
The CVT site is approximately 17 acres in size. Approximately 94% of the site is surfaced in
impervious materials. Structures account for approximately 39% of the site, while 55% is
comprised of paved areas. The remaining 6% pervious surface consists of landscaped areas.
Site operations include activities associated with the recovery of recyclable materials and transfer
of solid waste and the maintenance of solid waste off-road vehicles. With the exception of public
disposal and wood-waste, inert material and baled recyclable storage, all solid waste sorting,
recovery and transfer operations are assigned to covered, enclosed areas. The most prominent
structures on the site are the MRF and the Green-waste building.
A.3.a Pollution Prevention Team
The members of the CVT Pollution Prevention Team (PPT) are listed in Table 1. The PPT has
the authority and responsibility for coordinating and implementing the SWPPP. The PPT
includes personnel knowledgeable in spill control, health and safety, materials management, and
waste management. The General Manager of the facility oversees the SWPPP and delegates
responsibility to site staff to act as the PPT. The ongoing training and implementation of this
SWPPP and monitoring program is the responsibility of the General Manager, who may be
supported in these responsibilities by Republic’s Maintenance Managers, Operations Managers,
and/or Environmental Managers.

A.4

STORM WATER DRAINAGE PATTERNS AND SAMPLING LOCATIONS

The three primary drainage directions at the site are northwest towards Coronado Street, east
towards Blue Gum Street, and southwest towards the corner of the site adjacent to the
intersection of La Palma Avenue and Highway 57. The flow directions are illustrated on
Figure 2.
There are concrete curbs and/or block walls around much of the site perimeter that prevent storm
water discharge. Republic is in the process of permitting and constructing infiltration areas and
permeable paving that is expected to be completed by December 31, 2013. The main volume of
storm water discharge will be directed to two (2) StormChamber® subsurface infiltration devices
located along Coronado Street, a StormChamber® subsurface infiltration device in the southwest
corner of the site, and a bioretention area located north of the Post Collection Building (Figure
3A). After the completion of these storm water structural improvements, the storm water surface

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discharge offsite will be limited to discharge from the MRF roof drain to the Caltrans property in
the southwest corner of the site, the MRF roof drain on the northeast corner to the Human
Resources parking lot, and minor sheet flow onto Blue Gum Street from Gretta Lane and
employee parking areas near Gretta Lane and the corporate office. Gretta Lane does not receive
storm water runoff from the adjacent building roofs or any industrial areas. The Post Collection
Building, Human Resources Office, and Off-Road Maintenance roofs drain to landscaped areas.
The Green Waste and Employee Break Building roofs drain to the proposed bioretention area.
The StormChamber® and bioretention areas will be inspected during rain events that occur
during scheduled facility operating hours. Republic anticipates that only former monitoring point
MP-1 will have a sufficient volume of storm water discharge offsite to allow a sample to be
collected. The bioretention area located upstream of MP-1 and the StormChamber® infiltration
areas are designed to capture runoff from an 85th percentile storm. Therefore, a storm event
greater than the 85th percentile, may be required to produce enough storm water discharge to
enable sample collection. Overflow will be sampled if it occurs. If the overflow is due to a storm
event greater than the 85th percentile, the sampling will be for informational purposes only.
There are storm drains located along Blue Gum Street, Coronado Street, the 57 freeway, and La
Palma Avenue that are not the responsibility of CVT.
A.4.1 Drainage Estimate
An estimate of the drainage areas, in relation to total facility square footage is presented below.
A site plan identifying the drainage areas, discharge locations, and monitoring points is identified
in Figure 2.
Drainage
Area
Section I
Section II
Section III
Section IV

Section V

Section VI

Runoff Source Area
Paved areas around the Green Waste Building, (flows to
Monitoring Point 1 at Blue Gum Street)
Corporate Office and employee parking areas (minimal sheet
flow onto Blue Gum Street)
Employee parking lot, guard shack, scale, shipping & storage
area, and south side of MRF (flows to SW corner of site)
Scales, tarping station and a portion of the solid waste storage
buildings along the west side of the site (flows to the Coronado
cul-de-sac)
Paved areas around the Bale Storage Building, which includes
e-waste and hazardous waste storage areas (flows to Coronado
Street)
Paved area between the MRF, Off-Road Maintenance, and
Green Waste Buildings including diesel AST (flows to clarifier
in the MRF)

(Approx.
Sq. Feet)

% of Total
Facility

173,700

28%

41,700

7%

215,100

34%

124,700

20%

52,200

8%

24,100

4%

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LIST OF SIGNIFICANT MATERIALS

Raw materials reported to the local Hazardous Material Business Plan program and used either
currently or within the last two to three years by CVT are listed in Table 2. A complete listing of
raw materials is also contained in the CVT Hazard Communication MSDS binder. See Figure 2
for the approximate locations of material storage areas.

A.6

POTENTIAL POLLUTANT SOURCES

This section identifies the process and material handling areas and lists the significant materials
that are handled and stored in each area at CVT.
A.6.a.i Industrial Processes
Industrial process areas identified as potential source contributors to pollutants in storm water
runoff include: the Material Recovery Facility (MRF), the off-road vehicle maintenance area;
diesel refueling area; recycled materials shipping/storage area; the Green Waste Building and
adjacent paved areas; the scales and tarping station; the Bale Storage building; and vehicle
parking areas. Pollutants inadvertently coming in contact with rainwater may increase levels of
oil and grease (O&G), total suspended solids (TSS), metals, and chemical oxygen demand
(COD). The potential pollutants present in each area are described below.
Material Recovery Facility (MRF)
Municipal solid waste and recyclable materials are deposited, sorted, and loaded into transfer
trucks or sea-containers for transport offsite. The recyclable materials are also baled within the
MRF. Potential pollutants include municipal solid waste, recyclables, minor amounts of
household hazardous waste, and spills or leaks from equipment and vehicles. Southwest of the
MRF, a StormChamber® with SedimenTrap™ will be installed (Figure 3C).
Off-Road Vehicle Maintenance Area
The off-road vehicle maintenance facility is where most of the chemicals used at CVT are stored.
Chemicals are ordered on an as-needed basis so there is no build-up of materials in stock. All
chemicals are stored in appropriate cabinets and/or containment devices. Any materials spilled
are immediately treated with absorbent materials and cleaned up to avoid tracking off site.
Diesel Refueling Area
The red dye diesel fuel tank is filled on an as-needed basis. Tanker trucks from a certified fueling
contractor enter the site and pump fluids directly into the 20,000 gallon aboveground storage
tank (AST). The AST is used for the fueling of bulldozers and loaders operating in the
compaction pit and throughout the facility. The equipment is fueled by trained operators on a
daily basis. The diesel fuel dispensing area will be surrounded by a berm and covered with a

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metal canopy by February 1, 2014, subject to receiving the necessary permits from the City of
Anaheim and fabrication (Figure 3A).
Recycled Materials Shipping/Storage Areas
The recycled materials shipping/storage area was upgraded in 2011. The lot located southeast of
the MRF was repaved and new loading docks were installed. Trucks with sea-containers back up
to the loading docks and bales are loaded directly into the trucks (Figure 2). Bales of recycled
materials awaiting removal from the site can be stored inside the MRF. The baled and
temporarily stored materials are non-chemical in nature, but may result in debris such as metal
filings and/or minor dripping of liquids such as laundry detergent, soda, etc. The bale staging
areas are inspected and cleaned regularly by maintenance staff. Containers are inspected for
leaks and the contents are checked to make sure they are not creating a hazard. Exposed
materials are covered with tarps during rain events to prevent storm water contact.
The Green-Waste Building and Adjacent Area
Most green and wood waste is stored on paved surfaces under the Green Waste Building roof.
However, some public disposal, wood waste, and inert materials are temporarily stored outside
on paved surfaces adjacent to the Green Waste building. These items may be partially enclosed
by K-rails or push walls. Some of the public disposal items and construction and demolition
debris may be temporarily stored in roll-off bins outside.
Scales and Tarping Station
Inbound trucks cue near the Coronado Street cul-de-sac before proceeding to the scales for
weighing. Transfer trailers also stop at the tarping station to secure the tarps over their loads
before proceeding to the exit at Coronado Street. Loose litter, debris, and oily drips can be left
by the trucks passing through the northwest area of the site.
A new scale was also installed south of the MRF near the recyclable material shipping & storage
area. Loose litter, debris, and oily drips can be left by the trucks passing through the south area
of the site.
Vehicle Parking Areas
Parked vehicles and equipment are potential sources for storm water pollution from leaks of
coolant, oils, etc. The CVT vehicle parking areas include the employee parking lot and parking
area near the corporate office, along Blue Gum Street. The employee parking spots will be paved
with permeable pavement per the TGD BMP Fact Sheet INF-6 by December 31, 2013 (Figure
3A). Sometimes dozers, loaders, and/or other heavy equipment are left parked on impermeable
surfaces near the Green Waste building or await repairs parked outside the Off-road maintenance
building. However, as much as practical, the heavy equipment is kept under cover. Maintenance
staff inspects the parking lots and paved areas and clean up minor spillage, oily drips, etc.
Equipment and trucks are maintained and checked for leaks on a regular basis.

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A.6.a.ii Material Handling and Storage Areas
The significant materials and their storage locations at the site are listed in Table 2 - List of
Significant Materials at CVT. Municipal solid waste and recyclable materials are mainly handled
in the MRF. Bales of recyclable materials are stored on the south side of the MFR near the
loading docks where they are loaded into sea-containers. Green and wood waste are handled in
the Green Waste Building. Construction and demolition debris, public dumping, and temporary
staging of other miscellaneous (non-hazardous) wastes are handled northwest and west of the
Green Waste Building. E-waste, small amounts of household hazardous waste, and bales of
recyclable materials are temporarily stored at the Bale Storage Building. Lubricating and other
maintenance fluids are stored at the Off-Road Maintenance Shop. Hazardous wastes generated
by servicing and maintenance of heavy equipment are limited to waste motor oil, gear oil,
hydraulic oil, brake fluid, waste antifreeze, used oil filters, batteries, soiled rags, and absorbent
materials. These wastes are accumulated in appropriately labeled containers having secondary
containment. All hazardous wastes at the site are transported off site under manifest for recycling
and/or disposal by qualified hazardous waste subcontractors that are certified to handle the waste.
A.6.a.iii Dust and Particulate Generating Activities
The unloading, sorting, loading and other processing and transfer activities of MSW, green waste,
and recyclable materials can generate dust and particulates. Much of the dust and particulates are
contained within the MRF and Green Waste Buildings, where they may collect along walls or in
corners. To prevent airborne dust and particulates, CVT performs these activities inside
buildings or under cover as much as possible. Misting systems operate within the MRF and the
loading pit, along the perimeter openings of the MRF and Green Waste Building, and along the
west perimeter of the site by the MRF tunnel. These misters operate during active site hours.
A.6.a.iv Significant Spills and Leaks
There have been no identified, significant spills from the facility for materials listed in 40 CFR
Part 372, extremely hazardous materials, or other on-site raw materials onto the facility grounds
at CVT.
A.6.a.v Non-Storm Water Discharges
The CVT has installed engineering controls to prevent any non-storm water discharges
(irrigation water, air conditioner and misting system runoff, etc.) from leaving the site. These are
discussed later in Section 8 – Best Management Practices. Domestic wastewater is piped directly
to municipal sanitary sewer lines. Republic does not anticipate unauthorized non-storm water
discharges or infiltration at this site. Spill kits and spill response procedures are in place to
ensure that no unauthorized non-storm water discharge will reach any infiltration areas.

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A.6.a.vi Soil Erosion
Only 6% of CVT has permeable surfaces with potential to erode during heavy rain events. These
consist of landscaped areas which have established plants and grass to prevent erosion. Some
soil may come onto the site from the landscaped freeway embankment located along the western
property boundary. These slopes are maintained by Cal Trans, so when there are erosion issues,
CVT contacts Cal Trans. The pavement at the north side of the Locker Rooms and near the OffRoad Maintenance area will be repaired by December 31, 2013.
A.6.b Potential Pollution Sources and Corresponding BMPs
CVT has identified potential areas of impact to storm water runoff and has implemented the best
management practices listed in Table 3 – Assessment of Potential Pollutant Sources and
Corresponding Best Management Practices. The non-structural and structural BMPs are also
discussed in more detail in the following sections.
Run-on from Blue Gum Street into Drainage Area 3 at CVT will be prevented by a planned
cross-gutter (Figure 3A). This cross-gutter will be installed as soon as possible after acquiring
the necessary permits from the City of Anaheim and fabrication. Other storm water run-on at
CVT may occur from the Cal Trans slopes in the northwest corner of the site. Gretta Lane does
not receive run-on from Blue Gum Street.

A.7

ASSESSMENT OF POTENTIAL POLLUTANT SOURCES

Certain materials used or stored on the site contain potential pollutants. The following table lists
the pollutants identified as having a potential to be present in storm water discharge.
Potential Pollutant

Source

Location

Ammonia (as N)

Solid waste and green waste

MRF & Green Waste Building

Chemical Oxygen Demand
(COD)

Organic material from solid waste and green
waste

MRF & Green Waste Building

Cyanide

Household hazardous waste

Oil &Grease

Fuels, hydraulic fluid, & lubricants

Total Suspended Solids (TSS)

Dirt and dust

Metals

Recyclable materials, C&D, solid waste,
metal roofs, and equipment, bins, & trucks

Bale Storage Building Hazardous
Waste area
Off-Road Maintenance Area, diesel
AST, and vehicle traffic areas
Unpaved areas, truck traffic areas,
waste transfer areas
MRF, Green Waste Building, and
C&D staging east of scales

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A.8 STORM WATER BEST MANAGEMENT PRACTICES
Table 3 contains an assessment of potential pollutant sources and the corresponding best
management practices utilized at the CVT. The BMPs are also separated in to non-structural and
structural categories and described below.
A.8.a STORM WATER BEST MANAGEMENT PRACTICES – NON-STRUCTURAL
CVT has developed the following storm water management controls based on the requirements
of the revised General Permit, facility process knowledge, and observed runoff gradients. These
storm water controls utilize existing personnel and established preventive maintenance routines,
including spill prevention and spill response techniques.
A.8.a.i Good Housekeeping
The following procedures are routinely employed to maintain CVT as a clean and orderly facility:


Regenerative street sweepers operate on site and along the access roads adjacent to the
facility;



The track-out grid and proposed “cattle grid”, which will be installed by December 31, 2013,
near the guard shack (Figure 3A) will be inspected and cleaned regularly;



Hydrocarbon spots left by company/personnel vehicles are removed on a regular basis using
absorbent and/or a water-based, biodegradable solvent;



Parking lots are kept clean and clear of debris using dry sweeping methods or the street
sweepers;



Process drains, clarifiers, and cleanouts are inspected and periodically cleaned as necessary
to avoid excess pooling of industrial water and/or rainwater;



Rainwater drainage trenches, gutters, and downspouts are periodically cleaned to remove
excessive debris, vegetation, and silt so that storm flow is not obstructed;



Access roads and perimeter fences/walls are inspected frequently, and refuse is picked up and
disposed of properly;



All objects with raw material or finished product residues are kept covered and indoors, and
are periodically wiped clean;



Absorbent material and pans are used to contain leaks, spills, or small discharges;



Vehicles/equipment cleaning is performed in designated areas with collection drains using
minimal amounts of water;

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

Hazardous wastes generated at the site are kept in clearly labeled and dated containers
awaiting transport off site in accordance with applicable handling regulations;



Liquids from the baling area inside the MRF are contained by absorbent materials to prevent
discharge flowing out of the southwest corner of the MRF;



Dedicated litter collection personnel inspect the facility daily and pick up any litter found;
and



Litter collection, tarp applications and inspections, and BMP inspections and maintenance
will be logged through the use of the activity logs and observation forms enclosed in
Appendix D.

A.8.a.ii Preventive Maintenance
The following preventative maintenance procedures are routinely practiced at CVT:


Site vehicles and equipment receive regular maintenance in accordance with manufacturers’
recommendations to prevent leaks;



Absorbent material is readily available in areas where leaks may routinely occur (i.e.,
refueling, parking, and off-road maintenance area);



Only trained site employees are allowed to fuel facility vehicles and equipment within
designated areas. They are instructed to report leaking fuel dispensers immediately to the
appropriate manager;



Individuals fueling vehicles are instructed not to “top off” or overfill fuel tanks;



Vehicle and equipment maintenance is performed in a designated area on impermeable
surfaces; and



The bioretention and pretreatment areas will be inspected and cleaned as necessary before
and during the rainy season, which will be documented.

A.8.a.iii Spill Response
Spills of hazardous materials greater than 55 gallons will be handled appropriately. If required, a
HAZMAT contractor will be contracted. In the event of a significant spill the appropriate
supervisor or manager will be immediately notified and the following activities will be
conducted:
1. Identify product and secure the area (if necessary).
2. Obtain personal protective equipment and maintain safety of employees.
3. Contain spilled material with portable dikes, absorbent socks, and/or other absorbent
materials.

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4. Cover floor and storm drains.
5. Remove soiled absorbent, clean up material, and package it for disposal in accordance
with environmental regulations.
6. Clean area to the approval of the appropriate manager.
7. Log the time, place, volume, reason for, and type of spill release (raw material usage,
vehicle and tank fueling, or other vehicle fluids) in an incident report.
8. Replace or clean any spill control equipment so that it will be ready for the next event.
9. The incident shall be reported to the General Manager and/or Site Manager. The
appropriate manager(s) shall determine the need for reporting to local enforcement
agencies in accordance with federal, state, and local regulatory requirements.
A.8.a.iv Material Handling and Storage
The following material handling and storage procedures are employed at CVT to minimize spills
and prevent exposure of storm water to pollutants:


If possible, MSW and green waste is unloaded, temporarily stored, and loaded within
enclosed or covered areas.



Public disposal and inert materials are temporarily stored outside on a paved surface,
partially enclosed with K-rails or push walls.



Baled recyclable materials are stored on paved surfaces within the MRF or immediately
adjacent in the loading dock area and are loaded into sea containers as soon as possible.



Heavy materials are loaded and unloaded by a trained forklift operator.



During unloading, the responsible employee accepting the delivery inspects for spills,
leaks, and debris before the delivery vehicle leaves. Minor spills are cleaned up promptly.



All containers storing significant materials are kept closed except when adding or
removing material.



All hazardous materials will be stored in containers with legible labels identifying the
material and the date stored.

A.8.a.v Employee Training
Responsibilities of the SWPPP Manager include implementation of annual training schedules for
employees handling hazardous materials and having spill prevention/response responsibilities
through the Hazard Communication Training Program. This program includes training
designated employees in implementing facility controls, spill response, good housekeeping, tarp
applications and inspections, appropriate hazardous material handling and storage, and other
required training. In addition to emergency response procedures identified in the Emergency
Response Plan, CVT has designated key employees to perform storm water management roles.
These employees are trained to identify conditions at the various work areas at the site that may
potentially cause pollution of storm water. Each new employee whose work in the course of their

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job might impact storm water, shall complete the Republic SWPPP and Spill Prevention Control
and Countermeasures (SPCC) Training Program. This training is designed to maintain employee
awareness regarding storm water pollution prevention practices. Drivers/operators receive
additional training in proper fueling, fuel station inspections, and spill prevention procedures.
A.8.a.vi Waste Handling / Waste Recycling
The following waste handling and recycling procedures are implemented at CVT to minimize
and prevent exposure of storm water to pollutants:


Waste products from vehicle/equipment maintenance such as motor oil, antifreeze, brake
fluid, hydraulic fluid, gear oil, and batteries are collected, temporarily stored in
appropriately labeled containers, and disposed/recycled under manifest by a qualified
subcontractor.



Drip pans are emptied into the used oil tank.



Dry shop waste (rags, absorbent materials, etc.) is stored in a covered container located
indoors in the Off-Road Maintenance Shop.



Used oil filters are drained and then recycled by an approved vendor. Used oily parts are
cleaned prior to disposal or recycling.

A.8.a.vii Recordkeeping and Internal Reporting
CVT will keep all storm water and non-storm water discharge observation forms, chain of
custody, analytical data, and records documenting employee training, litter collection, tarp
application, and storm water BMP inspections and maintenance readily available on site. All
elements of SWPPP observations will be retained as part of the plan. The time, place, volume,
reason for, and type of release (raw material usage, vehicle and tank fueling, or other vehicle
fluids) for any spills will be recorded on an incident report. All compliance reporting will be
carried out in accordance with federal, state, and local regulations.
A.8.a.viii Erosion Control and Site Stabilization
Impermeable surfaces at CVT are maintained with landscape vegetation to prevent erosion.
Landscaped areas are irrigated at intervals consistent with County or City Water Conservation
Resolutions. Excess runoff from hoses, irrigation lines, air conditioners, or other domestic water
sources are directed away from site areas where pollutants are likely to accumulate. The planned
storm water infiltration areas will prevent any soil erosion from discharging offsite. During the
storm season sandbags, silt screens, straw bales and/or other additional sediment control devices
may be utilized.

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A.8.a.ix Inspections
Monthly, quarterly, and annual SWPPP inspections are conducted in accordance with the
General Permit requirements. These inspections are described in Section B.
Designated CVT employees perform routine site inspection duties. Inspecting employees may
recommend any additional spill prevention controls. Vehicles and equipment are regularly
inspected to check for leaks. Vehicle parking and transit areas are inspected regularly for drips,
debris, etc. A designated litter control person will inspect the perimeter of the facility daily and
pick up litter, which will be recorded on the Litter Control Logs in Appendix D. If tarps are
applied to cover materials during rain events, their application and inspections will be recorded
on the Tarp Application and Inspection Form in Appendix D.
Storm water infiltration and pre-treatment areas will be inspected before the rainy season and
during rain events that occur during scheduled facility operating hours during the rainy season.
An example of the Bioretention Area and StormChamber Visual Observation Form for
documenting the BMP inspections is enclosed in Appendix D.
A.8.a.x Metal Roof Sampling
During the first hour of the second and third qualifying storm water discharges of the 2013-2014
season (a qualifying storm water discharge is one that occurs during scheduled facility operating
hours on a day preceded by at least three (3) working days without storm water discharge), the
following metal roof storm water discharge samples will be taken:
 Material Recovery Facility – 2 samples (from different locations)
 Green Waste Building – 1 sample
 Off-Road Maintenance Building – 1 sample
These are the only buildings on the site that have metal roofs. The four (4) samples listed above
will be analyzed for Aluminum, Copper, Iron, Lead, and Zinc to determine the need for roof
coating. Two (2) rounds of sampling will be conducted at these four (4) locations. If both rounds
of sampling produce samples that do not exceed benchmarks, the metal roofs will not require
coating. If the samples exceed the following USEPA Storm Water Benchmarks, the metal roof(s)
exceeding the benchmark values will be coated within 60 days of receiving the second round of
laboratory results.
Parameter
Aluminum
Copper
Iron
Lead
Zinc

Units
mg/L
mg/L
mg/L
mg/L
mg/L

Federal Benchmark Value
<0.75
<0.0636
<1
<0.0816
<0.117

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A.8.a.xi Quality Assurance
The ongoing training and implementation of this SWPPP program is the responsibility of the
General Manager, who is supported in these responsibilities by the PPT. The General Manager
may designate a qualified environmental consultant for review and updating the SWPPP on an
“as needed” basis.
A.8.b STORM WATER BEST MANAGEMENT PRACTICES – STRUCTURAL
CVT utilizes structural control measures to minimize rainfall runoff and impact from on-site
operations. The structural control measures include overhead coverage, control devices to
channel storm water away from pollution sources, secondary containment, and treatment devices.
Structural control measures are discussed in the following sections.
A.8.b.i Overhead Coverage
Most waste transfer operations are conducted within the enclosed MRF (which contains the
transfer tunnel), under canopies adjacent to the MRF, or under the covered/partially enclosed
Green Waste building. Most maintenance is conducted within the Off-Road Maintenance
building and liquid raw material drums are stored within the Off-Road Maintenance building.
Hazardous waste is stored under an awning at the Bale Storage Building. E-waste and recyclable
material bales are also stored within the Bale Storage Building. The glass piles in Drainage Area
3 will be covered in a permanent method to be determined, designed, fabricated and installed by
February 1, 2014, subject to receiving the necessary permits from the City of Anaheim. A
canopy to cover the diesel fuel AST and dispensing area will be installed by February 1, 2014,
subject to receiving the necessary permits from the City of Anaheim and fabrication (Figure 3A).
A.8.b.ii Retention Ponds
This site does not have retention ponds.
A.8.b.iii Control Devices
The MRF and Green Waste Building have a series of gutters and downspouts to collect storm
water runoff and direct it to areas where it will not come into contact with pollutants. The runoff
from the southwest portion of the MRF building roof will be directed via an overhead pipe to the
Cal Trans drainage ditch offsite.
A concrete curb runs along the west side of CVT to prevent storm water from leaving the site
and to prevent sediment from the slopes alongside the 57 freeway from washing down into the
site. A concrete ribbon gutter and a grade break in Drainage Area 1 directs discharge towards a
storm water settling clarifier, which will be replaced by a bioretention area. A cross-gutter to
prevent run-on from the southernmost entrance at Blue Gum Street will be installed as soon as
possible after acquiring the necessary permits from the City of Anaheim.

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Track-out grids have been placed near the Guard Shack to knock litter and debris off trucks and
vehicles exiting the site onto Blue Gum Street. A cattle grid will be installed by December 31,
2013 between the track-out grids and the exit, with a cement lining underneath the grid for ease
of clean out.
A berm around the diesel fuel dispensing area to prevent spilled fuels from leaving the area will
be installed by February 1, 2014, subject to receiving the necessary permits from the City of
Anaheim and fabrication of the canopy (Figure 3A).
Permeable pavement will be installed in the employee and visitor parking stalls located at the
Corporate Office, the Human Resources Office, and the Post Collection Building.
A.8.b.iv Secondary Containment Structures
Some maintenance fluids and liquid wastes are stored within a block wall enclosure with
secondary containment at the Off-Road Maintenance Shop. Other maintenance materials and
liquid wastes are properly stored in drums on spill containment pallets. Hazardous Wastes are
stored in labelled drums on spill containment pallets at the Bale Storage Building. The red dye
diesel AST is double-walled and has a secondary containment concrete berm around it.
A.8.b.v Treatment
A bioretention area with pretreatment will be installed north of the Post Collection Building by
December 31, 2013 (Figure 3B). The pretreatment will consist of concrete chevrons providing
energy dissipation, as well as a basket of approximately 4 to 6 inch diameter rocks, which will
provide energy dissipation and sediment removal.
A StormChamber® with SedimenTrap™ will be installed north of Coronado Street in the
Operations & Maintenance Facility (Figures 3A and 3E). Drainage from Area 4 at CVT will be
discharged via subsurface piping over to this device for treatment. A StormChamber® with
SedimenTrap™ will also be installed north of the Bale Storage Building along Coronado Street.
(Figure 3D). The StormChamber® installation in areas 4 and 5 is expected to be completed by
December 31, 2013.
A StormChamber® with SedimenTrap™ will also be installed in Area 3 in the southwest corner
of the site (Figure 3C). It was discovered that a portion of the property inside the fence line in
this corner is not owned by the site, so Republic is working on purchasing this property. Since
the property acquisition will take more time, it is anticipated that the StormChamber® in Area 3
may not be installed by December 31, 2013. Therefore, Republic will be prepared to install a
temporary sump and use temporary tanks to collect and hold the storm water discharge from
Area 3, starting December 31, 2013. The collected storm water will be tested for the parameters
listed in Section B.5.c. If the storm water sample results are below the benchmarks, the storm
water will be discharged directly to the CalTrans property. If the storm water results are above
the benchmarks, the collected storm water may be discharged to another infiltration basin on site

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(weather permitting) or discharged to the MRF clarifiers, which are connected to the sanitary
sewer.
Pretreatment to avoid clogging in all the StormChamber® subsurface infiltration devices will
consist of inlet protection in the form of fiber rolls and drop inlet filters.
The above mentioned StormChamber® and bioretention areas have been designed for the 85th
percentile storm, which is 0.9 inches of precipitation in a 24-hour period. These areas will be
monitored during rain events that occur during routine scheduled facility operating hours using
the forms in Appendix D. Storm water discharge due to overflow from a StormChamber®
infiltration area or the bioretention area will be sampled. If a storm event greater than the 85th
percentile storm occurs, leading to overflow of the infiltration devices, this overflow will be
sampled for informational purposes only.

A.9

ANNUAL COMPREHENSIVE SITE COMPLIANCE EVALUATION

The General Manager or their qualified designee shall conduct an Annual Comprehensive Site
Compliance Evaluation. These annual compliance evaluations will be conducted at CVT to
evaluate site compliance with the elements contained in this SWPPP. The annual evaluations will
cover annual reporting period from July 1st of each year to June 30th of the following year and
will be conducted within 8-16 months of each other.
The following activities will be conducted during each annual evaluation:


Review of inspection records and storm water sampling data collected during the
reporting period.



Visual inspection of all potential pollutant sources identified at the site for evidence of, or
the potential for, pollutants entering storm water discharge.



Review and evaluation of the non-structural and structural BMPs to determine if they are
adequate, properly implemented and maintained, or whether additional BMPs are needed.



Visual inspection of equipment needed to implement the SWPPP (such as spill response
kits) shall be performed.



Preparation of an annual evaluation report.

The annual evaluation report will be retained on site and submitted to the Regional Water
Quality Control Board (RWQCB) with the annual report. The annual evaluation will include the
following information:


Personnel conducting the evaluation.

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

Dates of the evaluation.



A schedule to implement the appropriate SWPPP revisions, if needed.



Any incidents of non-compliance and corrective actions taken.



A certification that the facility operator is in compliance with the revised General Permit.

A sample copy of SWRCB Annual Report Forms is enclosed in Appendix C.

A.10 SWPPP GENERAL REQUIREMENTS
a. The SWPPP shall be kept on-site and made available upon request of a representative of
the Regional Water Board and/or local storm water management agency which receives
the storm water discharges.
b. The Regional Water Board and/or local agency may notify the facility operator when the
SWPPP does not meet one or more of the minimum requirements of this Section. As
requested by the Regional Water Board and/or local agency, the facility operator shall
submit an SWPPP revision and implementation schedule that meets the minimum
requirements of this section to the Regional Water Board and/or local agency that
requested the SWPPP revisions, the facility operator shall provide written certification to
the Regional Water Board and/or local agency that the revisions have been implemented.
c. The SWPPP shall be revised, as appropriate, and implemented prior to changes in
industrial activities which (i) may significantly increase the quantities of pollutants in
storm water discharge, (ii) cause a new area of industrial activity at the facility to be
exposed to storm water, or (iii) begin an industrial activity which would introduce a new
pollutant source at the facility.
d. Other than as provided in Provisions B.11, B.12, and E.2 of the General Permit, the
SWPPP shall be revised and implemented in a timely manner, but in no case more than
90 days after a facility operator determines that the SWPPP is in violation of any
requirements(s) of this General Permit.
e. When any part of the SWPPP is infeasible to implement by the deadlines specified in
Provision E.2 or Sections A.1, A.9, A.10c, and A.10.d of this General Permit due to
proposed significant structural changes, the facility operator shall submit a report to the
Regional Water Board prior to the applicable deadline that (i) describes the portion of the
SWPPP that is infeasible to implement by the deadline, (ii) provides justification for a
time extension, (iii) provides a schedule for completing and implementing that portion of
the SWPPP, and (iv) describes the BMPs that will be implemented in the interim period
to reduce or prevent pollutants in storm water discharges and authorized non-storm water
discharges. Such reports are subject to Regional Water Board approval and/or

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modifications. Facility operators shall provide written notification to the Regional Water
Board within 14 days after the SWPPP revisions are implemented.
f. The SWPPP shall be provided, upon request, to the Regional Water Board. The SWPPP
is considered a report that shall be available to the public by the Regional Water Board
under Section 308(b) of the Clean Water Act.

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SECTION B. MONITORING PROGRAM AND REPORTING REQUIREMENTS
B.1

SWPPP IMPLEMENTATION SCHEDULE AND RESPONSIBILITY

In order to meet the requirements of this SWPPP for CVT, Republic has dedicated significant
time and expense. The anticipated result is to minimize the impact of facility processes on
natural rainfall runoff.
The General Manager of the facility will oversee the SWPPP program and has delegated
responsibility to the PPT for the implementation of the program. The ongoing training and
implementation of this SWPPP and its monitoring program is the responsibility of the General
Manager, who may be supported in these responsibilities by the PPT or other Republic managers.
The General Manager may designate a qualified environmental consultant for the review and
updating of the SWPPP on an “as needed” basis.

B.2

OBJECTIVES

The objectives of the monitoring program are to:


Ensure that storm water discharges are in compliance with the Discharge Prohibitions,
Effluent Limitations, and Receiving Water Limitations specified in the General Permit.



Ensure practices at the facility to reduce or prevent pollutants in storm water discharges
and authorized non-storm water discharges are evaluated and revised to meet changing
conditions



Aid in the implementation and revision of the SWPPP required by Section A of the
General Permit.



Measure the effectiveness of best management practices (BMPs) to prevent or reduce
pollutants in storm water discharges, and prevent authorized and unauthorized non-storm
water discharges.

VISUAL OBSERVATIONS (INSPECTIONS)
Designated CVT personnel will perform visual inspections using the forms enclosed in
Appendix D of this SWPPP. The forms include quarterly dry (non-storm water) observations,
monthly wet season observations of the site discharge locations, and bioretention and
StormChamber® area observations as described below.

B.3

NON-STORM WATER VISUAL OBSERVATIONS

Quarterly a designated CVT employee shall visually observe all drainage areas within the facility.
Visual observations shall occur in daylight hours during scheduled facility operating hours on
days with no storm water discharges. Quarterly observations should be conducted within 6 to 18

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weeks of each other during the following periods: January-March, April-June, July-September,
and October-December. The CVT employee will document the presence of any observed
authorized and/or unauthorized non-storm water discharges, discolorations, stains, odors,
floating materials, etc. Authorized non-storm water discharges include fire hydrant flushing,
potable water discharge from the operation, maintenance or testing of potable water sources,
drinking fountains, irrigation drainage, landscape watering, and atmospheric condensates from
refrigeration, air conditioning, and compressors. Clean non-storm water discharge is only
authorized if quarterly visual observations are performed. BMPs to reduce contact with
significant materials or equipment must also be utilized to prevent significant quantities of
pollutants in the discharge.
The proposed storm water infiltration areas and permeable paving should eliminate authorized
non-storm water discharges. If non-storm water discharge is observed leaving the site, the source
will be identified and additional BMPs used to eliminate the flow of non-storm water discharges.
Spill kits and spill prevention controls will be used to prevent any unauthorized non-storm water
discharge from reaching the infiltration areas. Quarterly observations will include a description
of corrective measures taken to eliminate the discharge. The BMPs may be revised and
implemented if necessary.

B.4

STORM WATER DISCHARGE VISUAL OBSERVATION

Monthly during the wet season (October 1 to May 30) a designated CVT employee shall visually
observe storm water discharges from at least one storm event. These observations will occur
during the first hour of discharge at all monitoring locations. Visual observations will be
conducted in daylight hours, during scheduled facility operating hours, on a day preceded by at
least three “working days” without storm water discharge. The presence of any floating and
suspended material, O&G, discolorations, turbidity, odor, source of any pollutants, and any
corrective measures taken to prevent pollutants shall be documented. The BMPs shall be revised
and implemented as necessary.
The proposed StormChamber® and bioretention areas and their pretreatment BMPs will be
monitored during rain events that occur during routine scheduled facility operating hours using
the forms in Appendix D.

B.5

SAMPLING AND ANALYSIS

Republic has prepared a site-specific storm water monitoring program for CVT which includes
the following components: rationale and locations for sampling, analytical methods, QA/QC
program, pollutant reduction tracking, and record keeping. The intent of this program is to
monitor the facility progress in minimizing discharge of potential facility pollutants, assist in
implementing the SWPPP, and measure the effectiveness of existing and proposed BMPs, such
as those previously implemented and planned. CVT has trained designated employees in proper
storm water sampling and sample handling techniques. An off-site California-certified analytical
laboratory performs analyses of samples collected by CVT personnel.

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The proposed StormChamber® and bioretention areas have been designed for the 85th percentile
storm, which is 0.9 inches of precipitation in a 24-hour period. If storm water discharge occurs
due to overflow from a StormChamber® infiltration area or the bioretention area, it will be
sampled and submitted for laboratory analysis. If a storm event greater than the 85th percentile
storm occurs, leading to overflow of the infiltration devices, this overflow will be sampled for
informational purposes only.
B.5.a Sampling Preparation
CVT will be prepared to sample the first rainfall of the “wet” season during scheduled facility
operating hours starting in October. Per the revised General Permit, samples will be collected
within the first hour of storm water discharge, on a day preceded by at least three “working” days
without storm water discharge. Storm water samples will be collected from the designated site
monitoring location in accordance with the General Permit.
B.5.b Sampling Protocol
Samples of storm water discharge will be collected during scheduled facility operating hours on
a day preceded by at least three (3) working days without storm water discharge. The infiltration
areas are designed to capture runoff from an 85th percentile storm. Therefore, it is expected that a
storm event greater than the 85th percentile will be required to produce storm water discharge
offsite. Overflow will be sampled if it occurs. If the overflow is due to a storm event greater than
the 85th percentile, the sampling will be for informational purposes only.
B.5.c Sampling Methods and Parameters
Samples will be collected directly in clean laboratory-provided sample bottles, or if necessary in
clean unused high density polyethylene quart bottles from water pooled, or flowing into the
sample area. This water will then be immediately transferred into the laboratory-provided sample
bottles. Bottle size and type and laboratory method may vary slightly depending on the
laboratory, but the general sampling parameters are identified herein:

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Parameters

EPA Method1

Sample Bottle

pH

150.1, A4500HB, or grab

500 mili-liter HDPE unpreserved

120.1 or A2510B

500 mili-liter HDPE unpreserved

413.2 or 1664A HEM

1 liter amber glass with H2SO4

Total Suspended Solids (TSS)

160.2 or 2540D

1 liter HDPE unpreserved

Total Metals

200.7, 200.8, or 6010B

500 mili-liter HDPE with HNO3

Chemical Oxygen Demand (COD)

410.4, 5220B, or 5220D

500 mili-liter glass with H2SO4

Ammonia (as N)

SM 4500-NH3 B+ C or E

1 liter amber glass with H2SO4

Cyanide, Total

3135.2I

1 liter HDPE with NaOH

Mercury (Hg)

245.1

500 mili-liter HDPE with HNO3

SM9221B/E

120 mili-liter HDPE with Na2S2O3

SM9230B

120 mili-liter HDPE with Na2S2O3

Specific Conductivity (EC)
Oil & grease (O&G)

2

3

Fecal Coliform
3

Enterococci

HNO3 = nitric acid
H2SO4 = sulfuric acid NaOH = sodium hydroxide HDPE = high density polyethylene
Na2S2O3 = sodium thiosulfate
Metals includes: Aluminum (Al), Arsenic (As), Cadmium (Cd), Copper (Cu), Iron (Fe), Lead (Pb), Magnesium
(Mg), Selenium (Se), Silver (Ag), and Zinc (Zn)
1
Or Equivalent Approved Method
2
O&G can be substituted for total organic carbon (TOC) as allowed in the General Permit.
3
These are being analyzed in accordance with a Settlement Agreement.

B.6

SAMPLE STORM WATER DISCHARGE LOCATIONS

B.6.a Representative Drainage Areas
Based on the general site contours, and the proposed storm water infiltration areas, Republic has
identified one representative storm water discharge location for monitoring/sampling, as
illustrated on Figure 2. Monitoring point (MP-1) is located at the northeast corner of the site at a
drain by Blue Gum Street.
The StormChamber® subsurface infiltration devices and their pre-treatment BMPs will be
monitored, when rain events occur during scheduled facility operating hours. This monitoring
will be recorded on the observation forms in Appendix D. If discharge or overflow is observed,
storm water samples will be collected and submitted for laboratory analysis. If the overflow or
discharge is due to a storm event greater than the 85th percentile design storm, then the sampling
will be for informational purposes only.
B.6.b Comingled Storm Water
CVT receives run-on from Blue Gum Street and La Palma Avenue that can flow into Area 3 at
the site’s southernmost entrance. A cross-gutter will be installed across the entrance from Blue
Gum Street to eliminate any run-on at that location, pending receiving the necessary permits
from the City of Anaheim (see Figure 3A). CVT may also receive some run-on from the
landscaped freeway embankments that run along the northwest perimeter of the site during heavy

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precipitation events. A concrete curb helps prevent any run-on from the adjacent property. The
selected storm water sampling locations will be carefully sampled to avoid collecting a
comingled storm water sample.
B.6.c Sample Locations That Are Difficult to Observe and Sample
The current sample locations at CVT are not difficult to observe or sample.
B.6.d Substantially Identical Drainage Areas
Though not currently applicable, CVT will document in the annual report if the industrial
activities and BMPs within two or more drainage areas are substantially identical, such that a
combined sample or a reduced number of storm water samples are collected.

B.7

VISUAL OBSERVATION AND SAMPLE COLLECTION EXCEPTIONS

B.7.a Exceptions
If CVT is not able to conduct required visual observations or collect storm water samples due to
dangerous weather conditions, storm water discharge beginning after scheduled facility operating
hours, or because storm water discharges are not preceded by three working days without
discharge, these exceptions shall be explained in the annual report.
B.7.b Non-Qualifying Observation and Sampling Exceptions
CVT will attempt to perform visual observations and sample collection within the first hour of
storm water discharge from the site drainage locations. However, CVT may choose to collect a
storm water sample after the first hour of storm water discharge, if the “wet” season is almost
over, and there have been no previous storm events in which storm water could be sampled
within the first hour of discharge. If the storm water samples are not collected within the first
hour of discharge, an explanation will be included in the annual report.

B.8

ALTERNATIVE MONITORING PROCEDURES

This site does not have any alternative monitoring procedures.

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B.9

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MONITORING METHODS

B.9.a Rationale for CVT Monitoring Program
B.9.a.i Visual Observations
CVT will perform monthly visual observations of storm water discharge from October to May
during the “wet” season. The monitoring location MP-1 has been selected based upon the
topography, site configuration and drainage, storm water infiltration areas, and industrial
activities at CVT.
The bioretention area and StormChamber® infiltration Areas 3, 4, and 5 (Figure 3A) will be
observed during rain events that occur during scheduled facility operating hours. These
observations will be recorded on the Bioretention Area & StormChamber Visual Observation
Form in Appendix D.
Authorized non-storm water discharge is not anticipated due to the proposed installation of
infiltration areas and permeable pavement. Spill kits and spill prevention controls will be used to
prevent any unauthorized non-storm water discharge from reaching the infiltration areas. In
accordance with the General Permit, quarterly visual observations will be performed to detect the
presence of authorized and unauthorized non-storm water discharges from July 1st to June 30th.
The observations will be performed by a trained, designated employee in the PPT.
B.9.a.ii Sampling Location
CVT personnel will be prepared to sample the first rainfall of the “wet” season starting in
October. Per the SWRCB, samples will be collected within the first hour of storm water
discharge, on a day preceded by at least three (3) “working” days without storm water discharge.
Storm water samples will be collected from sampling location MP-1, which has been selected as
the most representative sampling locations for storm water at the site based on storm water
conveyance and runoff, infiltration areas, and the location of industrial activities. Since storm
water discharge from CVT will be mostly eliminated once the proposed infiltration areas and
permeable pavement is installed, monitoring point MP-1 will be representative of runoff in
accordance with the guidelines provided by the RWQCB.
If storm water discharge due to overflow from the bioretention area or from a StormChamber®
infiltration area occurs during scheduled facility operating hours, it will be sampled. The
bioretention area and StormChamber® infiltration Areas 3, 4, and 5 have been designed for the
85th percentile storm, which is 0.9 inches of precipitation in a 24-hour period. If a storm event
greater than the 85th percentile storm occurs, leading to overflow of the infiltration devices, this
overflow will be sampled for informational purposes only.
B.9.a.iii Analytical Methods and Detection Limits
All storm water samples shall be analyzed at a laboratory certified for such analyses in
accordance with State Regulations. The analytical methods and method detection limits may

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vary slightly depending on the laboratory, but the sampling parameters, methods, and method
detection limits are presented in the following table.
Parameters

EPA Method1

Method Detection Limit

pH

Calibrated portable meter or
litmus paper

0.01 pH Units

Specific Conductivity (SC)

120.1 or A2510B

Oil & grease (O&G)2

EPA 1664A HEM

1.0 micro ohms per centimeter
(umhos/cm)
1.0 milligrams per liter (mg/L)

Total Suspended Solids (TSS)

SM2540D

1.0 milligrams per liter (mg/L)

Chemical Oxygen Demand (COD)

SM5220C

1.0 milligrams per liter (mg/L)

Ammonia (as N)

SM 4500-NH3 B+C or E

0.1 milligrams per liter (mg/L)

Iron (Fe)

200.7

0.005 milligrams per liter (mg/L)

Metals: Al, As, Cu, Pb, Mg, Se, & Zn

200.7, 200.8 or 6010B

0.0005 milligrams per liter (mg/L)

Metals: Cadmium (Cd) and Silver (Ag)

200.8

0.0002 milligrams per liter (mg/L)

Cyanide, Total

3135.2I

0.003 milligrams per liter (mg/L)

Mercury (Hg)

245.1

0.0001 milligrams per liter (mg/L)

SM9221B/E

1.0 colony forming units per 100 mL

SM9230B

1.0 colony forming units per 100 mL

3

Fecal Coliform
3

Enterococci
1

Analyses must be conducted per 40 CFR Part 136 or an equivalent method approved by the RWQCB.
O&G can be substituted for total organic carbon (TOC) as allowed in the General Permit.
3
These are being analyzed in accordance with a Settlement Agreement.
2

The Method Detection Limit can vary based on the analysis method, laboratory equipment,
laboratory Quality Assurance/Quality Control protocols, and the storm water sample itself. The
method detection limits are carefully determined by the analytical laboratory to meet State and
Federal regulations. The method detection limits are well below the Federal Benchmark Levels
(FBLs), which are the pollutant concentrations above which EPA determined represent a level of
concern at which a storm water discharge could potentially impair, or contribute to impairing,
water quality or affect human health from ingestion of contaminated fish.
B.9.b Sampling and Sample Preservation
All sampling and sample preservation shall be in accordance with the current edition of
"Standard Methods for the Examination of Water and Wastewater". All analyses will be
conducted at a laboratory certified for such analyses by the State Department of Health Services.
Consolidated, or their designated consultant, will select the analytical laboratory and arrange the
handling and transfer of the sample bottles. Storm water samples will be placed in a cooler with
ice and will be transported to the lab with a completed chain of custody.
The chain of custody shall include:
1)
2)
3)
4)

Site Name;
Project Manager and contact information (can be a consultant);
Sample location name(s);
Date and time of sample collection;

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5)
6)
7)
8)
9)

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September 30, 2013

Requested analysis;
Requested turnaround time;
Total number of containers;
Name of individual performing sampling; and
Signatures of persons relinquishing and receiving the samples.

An example of the COC form is included in Appendix E.
All monitoring instruments and equipment shall be calibrated and maintained in accordance with
manufacturers’ specifications to ensure accurate measurements.

B.10

INACTIVE MINING OPERATIONS

There are no inactive mining operations at this site.

B.11

SAMPLING AND ANALYSIS EXEMPTIONS AND REDUCTIONS

There are no exemptions or reductions designated for this site.

B.12

RECORDS

A binder/folder will be maintained at CVT and will include this SWPPP, inspection forms,
recommended actions, corrective actions, and results of laboratory analyses. The binder will be
available to regulatory agencies upon request.
Records of storm water monitoring information shall include:
1. Date, place, time of site sampling and measurements (including site inspections and visual
wet weather observations).
2. Name of individual(s) performing sampling and monitoring.
3. Chain of Custody (COC) form and laboratory analytical report.
An example of the required COC form is included in Appendix E.

B.13

ANNUAL REPORT

All required information will be submitted in an annual report by the required due date of July 1st
to either the Executive Officer of the Regional Water Quality Control Board (RWQCB) or via
the SWRCB’s online Storm Water Multiple Application and Report Tracking System (SMARTS)
database.