Inspecting Industrial/Commercial Facilities
For Pollutants Of Concern
During Stormwater Inspections
Kristy McCumby Hyland
City of Sunnyvale
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Presentation Overview
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Regulatory Requirements
Pollutants of Concern
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Copper
Mercury
PCBs
Inspection Forms
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Regulatory Requirements
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Stormwater Municipal Regional Permit
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Provision C.11 Mercury Controls
Provision C.12 Polychlorinated Biphenyls (PCBs)
Controls
Provision C.13 Copper Controls
BASMAA Regional Training Materials
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Guidance Manual for SW Inspectors on
SCVURPPP website
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Pollutant of Concern
(POC)
COPPER
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Copper
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POC since the late 1980s.
SF Bay listed as impaired by copper in 1989
Government agencies and businesses made significant
investment in copper source identification and copper
reduction measures
As of July 2003, all San Francisco Bay segments listed
for copper have been removed from the State’s
303(d) list of impaired water bodies and placed on the
monitoring list
Site Specific Objectives (SSOs) adopted Jan 2009
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Sources of Copper in Stormwater
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Vehicle brake pads
Copper air emissions
Architectural copper
Industrial copper use
Improper discharge of pool and spa water
Potable water discharged to storm drains
Soil erosion
Copper pesticides
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Provision C.13 Copper Control
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Identify commercial/industrial businesses likely
to use copper or have sources of copper and
include them in the inspection programs
Inspectors need to ensure that proper BMPs are
in place to minimize discharge of copper to
storm drains
Special emphasis on roof runoff that might
accumulate copper deposits from on-site
ventilation systems at industries or businesses
that use copper
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Industrial/Commercial Sources
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Electroplating
Semiconductor manufacturing
Metal finishers
Auto dismantlers
Car Washes
Automotive Services
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From BASMAA Stormwater Inspectors’
Guidance Manual:
SIC 7549 (Vehicle service shops) and SIC 7542 (Car wash facilities) can also
contribute copper to stormwater runoff if proper BMPs are not in place
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Copper in Roof Runoff
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Metal finishing, electroplating and
semiconductor manufacturing industries
Processes - copper chloride etchers,
ammonia etchers, and acid plating bath
exhaust vents
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Inspection for Copper Deposition
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Look for chemical
deposition around vents,
pipes, and other roof
surfaces to determine if
there is a potential source
of copper and if safe
access is possible
If discolorations or deposits
are seen, implement BMPs to
minimize the contamination
of roof runoff
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Inspection for Copper Deposition (cont.)
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If roof top access not
possible, check
downspout discharge
areas
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Best Management Practices
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Install vent covers and drip pans
Prevent leaks in pipe fittings and
containment vessels with routine
maintenance
Properly dispose of condensate from
ventilation
Promote condensation of ammonia etchant
vapor
Install scrubber system to treat ammonia
etchant vapors
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Pollutant of Concern
MERCURY
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MERCURY
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San Francisco Bay is considered to be
“impaired” by mercury because some types of
fish caught in the Bay contain mercury at
concentrations that may threaten the health of
humans consuming them.
TMDL adopted in SF Bay Basin Plan Feb 2008
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Provision C.11
Permittees shall promote, facilitate, and/or
participate in collection and recycling of
mercury containing devices and equipment at
the consumer level
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Industrial/Commercial Sources
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Facilities that use mercury in processes and
equipment
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metal finishing/electroplating facilities
auto dismantlers/recyclers.
Facilities that have mercury containing
products that need to be disposed properly
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From BASMAA Stormwater Inspectors’
Guidance Manual:
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Mercury Containing Products
Fluorescent Bulbs
Tubular and
Circular lamps
Compact
Fluorescent bulbs
Tanning Lamps
Germicidal Lamps
High Intensity Discharge (HID) Lights
Metal Halide
lamp
High Pressure
Sodium Lamps
Mercury Vapor
Lamps
Source: Northeast Waste Management Official’s Association (www.newmoa.org)19
Mercury Containing Products
Other Types of Lighting
Mercury Short Arc
Metal Halide Lamp
Mercury Capillary
Lamps
Mercury Xenon
Short-arc Lamps
Neon Lights
Source: Northeast Waste Management Official’s Association (www.newmoa.org)20
Mercury Containing Products
Relays and Tilt Switches
Root Switch from
Sump Pump
Mercury Wetted
Relay
Tilt Switch from
Washing Machine
Flame Sensor from
Gas Range
Mercury
Displacement Relay
Mercury Contact
Relay
Source: Northeast Waste Management Official’s Association (www.newmoa.org)21
Mercury Containing Products
Batteries – Standard Mercury Batteries, Alkaline Batteries
Zinc Air Miniature
Batteries
Mercury
Thermostat
Silver Oxide Button
Cell Batteries
Mercury Switch
inside Thermostat
Alkaline Manganese
Oxide Button-Cell
Mercury
Thermostat
Source: Northeast Waste Management Official’s Association (www.newmoa.org)22
Best Management Practices
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Proper Disposal
Spill Management
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Proper Disposal
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Regulated by recycling and disposal requirements of
the universal hazardous waste rules in the State of
California
Small business may qualify as a Conditionally Exempt
Small Quantity Universal Waste Generator
(CESQUWG)
CESQUWGs can recycle their lamps at their local
government sponsored Hazardous Waste Recycling
and Disposal Program’s sites or they can contract with
a hazardous water hauler to properly dispose of their
hazardous waste
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Spill Management
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Never touch mercury with bare hands
Never use vacuum cleaners or brooms to clean up
mercury spills
Use cardboard pieces, a squeegee, or an eyedropper
to gather and draw up the mercury
Place the mercury and the items used to clean up the
spill in a bag and dispose off as hazardous waste.
See EPA website at http://www.epa.gov/hg/spills/ for
more detailed information on cleaning up
spills/breakage of products that contain mercury
Provide facilities with EPA guidance on clean-up for
broken fluorescent lamps, CFLs, and thermometers, if
needed (See handout examples)
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Pollutant of Concern
PCBs
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PCBs
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Synthetic chemicals: Poly-chlorinated
biphenyls
Manufacture of PCBs was stopped in the
U.S. in 1977 because of evidence they build
up in the environment and can cause
harmful health effects
PCBs continued to be imported into the
U.S. until 1979, when they were banned
Regulated under the Toxic Substances
Control Act (TSCA)
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TSCA Regulations
(Toxic Substances Control Act – 1976)
Designed to ban the manufacture of
PCBs and ensure the proper disposal of
PCBs and PCB equipment, while
minimizing the risk posed by the
storage, use, and handling of the
substance.
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TSCA Regulations
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Include numerous exceptions and
authorized activities
Allowed uses of PCBs include servicing
of PCBs in various PCB-containing
equipment, such as transformers,
capacitors, natural gas pipelines, and
hydraulic systems
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TSCA Regulations
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Owners of PCB Transformers must register
transformers with EPA
There are requirements for marking, storage,
record keeping and disposal of PBC-containing
equipment
EPA Data bases can be found at
http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/
data.htm
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Provision C.12.a
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Develop training materials
Train municipal building inspectors to identify
PCBs or PCB-containing equipment
Integrate PCB inspections into existing
stormwater inspections of facilities
Reporting requirements
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Identification of PCB Containing
Equipment
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Equipment will be marked
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Identification of PCBs Containing
Equipment
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Look at Records
Recordkeeping Requirements include
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PCB weights
identification and numbers of items
storage, transfer, and disposal dates
identification of shippers and receivers
Manufacturer’s label/PCB Fluid trade names
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Aroclor, Askarel, Eucarel, Pyranol, Dykanol,
Clorphen, Clorinol, Chlorextol, Diaclor, Hyvol,
Asbestol, Inerteen, Elemex, Saf-T-Kuhl, No-Flanol,
Nepolin, EEC-18, and others
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Transformers
PCB Transformer
Source: EPA
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Where Are Transformers Found?
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Industrial and other sectors:
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Commercial Buildings:
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Inside commercial buildings (may be owned by a utility)
Neon signs (older ones manufactured prior to 1977-78)
Utilities
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Electrical substations
Inside, around, or on top of buildings
In powerhouses that generate and distribute electrical power
throughout a facility
In underground vaults
Distribution Substations
Power generating facilities
See handouts for list of registered facilities in Bay area
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Capacitors
PCB Capacitor
Source: EPA
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Where Are Capacitors Found?
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Utilities:
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Manufacturing:
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Located in distribution substations
Located in banks or individually
Found in underground pump stations
Used for power factor correction on motor control units and
part of circuitry for electric induction furnaces
Used for power correction start up of large motors (e.g.,
water pumps for air conditioning systems or lift stations)
Used for start up of any large motor associated with
manufacturing (e.g., drills, saws)
See handouts for list of facilities in Bay Area that
generate or handle PCB wastes
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Transformer and Capacitor
Manufacturers and PCB Fluid Trade
Names
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See Tables in Handouts from EPA’s PCB
Inspection Manual for manufacturer names
and fluids they contain
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Hydraulic Systems
Hydraulic Systems
Source: EPA
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Hydraulic Fluid Manufacturers and
Trade Names
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Main manufacturer was Monsanto
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Pryradraul (Many numerical versions – See table in
handouts for a listing)
Santovac
Turbinol
See handouts for list of facilities in Bay Area
that generate or handle PCB wastes
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Fluorescent Light Ballasts
Source: National Lamps and Components
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Fluorescent Light Ballasts
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PCBs are located in the light ballasts’ small capacitor
or in the potting material (the insulating material
inside the ballast)
If inspectors observe light ballasts that were
manufactured before 1978, it should be assumed they
contain PCBs
Light ballasts manufactured between 1978 and 1998
were marked with the message “No PCBs”
Ballasts manufactured after July 1, 1998 are not
required to have that message on them, which can
lead to confusion
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Other Equipment Containing PCBs
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Heat Transfer Systems
Electric Motors
Electromagnets
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Other Products/Materials
These will be unmarked and possibly found in
older facilities (before the 1979 ban):
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Carbonless copy paper
General sealants and
coatings, including
windshield sealant and silo
sealant
Investment casting wax
Lubricants, used motor oil,
hydraulic fluid, and additives
to transmission fluids
Plastics
Floor finish
Old electrical devices or
appliances with PCB
capacitors
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Paint, including marine paint
Electrical cable insulation (If
electrical cable contains
liquids or damp insulation,
PCBs should be suspected.)
Gaskets Roofing materials
Thermal insulation materials,
including fiberglass, felt,
foam, and cork
Oil-based paint
Caulking materials
Old electrical equipment such
as: voltage regulators,
switches, re-closers,
bushings, and
electromagnets
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Best Management Practices
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Employee Awareness
Spill Containment Provisions in Work Area
Proper Storage
Proper Disposal
No Leaks
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INSPECTION FORMS
Cities/Agencies should modify existing stormwater
inspection forms to include a reminder to inspect for POCs
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Sample Form from Sunnyvale
Note for
inspector to
remind them to
check for POC
sources.
“Other sources
determined to
have a potential
to contribute to
pollution of
stormwater
runoff; e.g.,
PCBs, Copper,
Mercury”
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Examples of Problems to Report
Observed in a Stormwater Inspection
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A PCB transformer that is not registered in the EPA
database (see Table 2 in handouts for list of facilities in
Bay Area);
PCB-containing equipment that does not have the
proper labeling;
Leaking PCB-containing equipment or storage drum; or
Improper storage of PCB-containing materials
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If You Observe a Problem...
The MRP requires permittees to document incidents and
“refer to appropriate regulatory agencies” as necessary.
BASMAA suggests that if stormwater inspectors find a
problem related to PCBs or PCB-containing equipment during
a stormwater inspection that the agency fax the inspection
report, or notify by e-mail or phone, the following three
agencies:
EPA Region 9: Steve Armann, Regional PCB Coordinator,
email: armann.steve@epa.gov, phone: 415-972-3352, FAX:
415-947-3530
Industrial Inspection contact for Alameda, San Mateo and
Santa Clara Counties, Cecil Felix, email:
CFelix@waterboards.ca.gov,
phone: 510-622-2343, fax: 510-622-2460
County Department of Environmental Health or local CUPA
agency
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WRAP UP
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POC inspections need to be integrated into
existing stormwater inspection programs.
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Use BASMAA Technical Memorandum and Guidance
Manual for reference
Use Outreach Material for educating business
operators
Complete Inspection Forms
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Questions?
Kristy McCumby Hyland
City of Sunnyvale
408-730-7274
kmccumby@ci.sunnyvale.ca.us
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