Storm Water Pollution Prevention · Stormwater Pollution Prevention Plan 2 SWPPP AMENDMENTS This Storm Water Pollution Prevention Plan (SWPPP) shall be amended: • Whenever there

Stanford Linear A ccelerator Center

SLAC-I-750-0A16M-002-R002

Storm Water Pollution Prevention Plan

ES&H Division EP Department

May 2007

This document, the SLAC Stormwater Pollution Prevention Plan (SLAC-I-750-0A16M-002-R002)has been reviewed, accepted, and approved for implementation by:

John Cornuelle, Associate Director, Operations Division Date

_____________________________________________________________ Sayed Rokni, Associate Director, ES&H Division Date

John Weisend, Associate Director, Date Conventional and Experimental Facilities

This document was designed and published by the ES&H Division.

Original Publication Date: July 1998

Revision Date: December 2005

Original Source: Environment, Safety, and Health Division

Reference Document Number: SLAC-I-750-0A16M-002-R002

Work supported by Department of Energy contract DE-AC03-76SF00515

Stormwater Pollution Prevention Plan


Table of Contents

List of Abbreviations and Acronyms ................................................................................................ iv 1 SWPPP Certifications ................................................................................................................1 2 SWPPP Amendments ................................................................................................................2 3 Introduction and Background .....................................................................................................3

3.1 Regulatory Background ...................................................................................................3 3.2 Purpose and Elements of the SWPPP ............................................................................4 3.3 Area and Site Description................................................................................................5

3.3.1 Location ..............................................................................................................5 3.3.2 Setting.................................................................................................................6 3.3.3 Climate and Regional Rainfall ............................................................................7 3.3.4 Land Use and Development on the SLAC site...................................................7 3.3.5 Impervious and Pervious Surface Areas and Drainage Patterns.......................9 3.3.6 Non-Storm Water Discharges...........................................................................12

3.4 Stormwater Pollution Prevention Team and Contact Information .................................14 4 Existing Facility Plans and References....................................................................................16

4.1 Air Permits –Dust and Particulates................................................................................16 4.2 Chemical Management System and Hazardous Materials Business Plan ...................16 4.3 ES&H Manual ................................................................................................................16 4.4 Emergency Response ...................................................................................................16 4.5 Integrated Safety and Environmental Management Systems .......................................16 4.6 Long Term Development Plan.......................................................................................17 4.7 On Site Hazardous Materials Transportation ................................................................17 4.8 Radiation Safety ............................................................................................................17 4.9 Training..........................................................................................................................17 4.10 Other Plans and References .........................................................................................17

5 Stormwater Pollution Prevention Plan .....................................................................................18 5.1 Facility Map....................................................................................................................18 5.2 Stormwater Pollution Source Assessment ....................................................................18

5.2.1 Methodology .....................................................................................................18 5.2.2 List of Significant Materials...............................................................................19 5.2.3 Description and Assessment of Potential Pollutant Sources ...........................22 5.2.4 Estimate of Potential Pollutants in Stormwater Run-off....................................36

5.3 Stormwater Best Management Practices ......................................................................36 5.3.1 Non-Structural Source Controls and Management Practices ..........................36 5.3.2 Stormwater Structural Source Controls............................................................39 5.3.3 Annual Comprehensive Site Compliance Evaluation and Inspection Program40 5.3.4 Recordkeeping and Reporting..........................................................................41

Page - i SLAC-I-750-0A16M-002-R002


List of Figures

Figure 1: Site Location Map............................................................................................................. 6

Figure 2: Schematic of Linac and Rings.......................................................................................... 8

Figure 3: IR-6 and IR-8 Channels.................................................................................................. 11

Figure 4: Assessment Decision Process Diagram ........................................................................ 19

List of Tables

Table 1: Record of Revisions .......................................................................................................... 2

Table 2: SWPPP Requirements ...................................................................................................... 5

Table 3: Potential Pollutants: Radioactivity ..................................... Error! Bookmark not defined.

Table 4: Chemicals found in Aqueous Wastes and Rinsewater ................................................... 23

Table 5: MFPF Treatment Chemicals............................................................................................ 23

Table 6: Compressed Gas and Cryogenic Tanks ........................... Error! Bookmark not defined.

Table 7: Petroleum Storage Tanks................................................................................................ 26

Table 8: Chemicals used to service utilities .................................................................................. 28

Table 9: Chemicals used at the Crafts Shop and Transportation ................................................. 28

Table 10: Potential Pollutants: Machining, Assembly and Welding .............................................. 29

Table 11: Waste Accumulation Areas (WAA)................................................................................ 31

Table 12: Outdoor Storage Areas.................................................................................................. 32

Table 13: Dust and Particulate Generating Activities .................................................................... 33

Table 14: Housekeeping Schedule for Outdoor Areas near Buildings.......................................... 38

SWPPP Appendices Appendix A. Notice of Intent

Appendix B. Responsibilities

Appendix C. BAAQMD Permitted and Exempt Sources

Appendix D. SWPPP Map

Appendix E. List of Significant Materials

Appendix F. SWPPP Monitoring Program

Appendix G. Table B: Industrial Activity Areas, Potential Pollutants and Applicable BMPs

Page - ii SLAC-I-750-0A16M-002-R002


Appendix H. Significant Spills since April 17, 1994

Appendix I. SWPPP Best Management Practices

Appendix J. Computation Sheet for Determining Runoff Coefficients

Appendix K. Inspection Lists and Forms

Page - iii SLAC-I-750-0A16M-002-R002


List of Abbreviations and Acronyms

BMP Best Management Practice BSY Beam Switchyard CERCLA Comprehensive Environmental Response, Compensation and Liability Act CMP Corrugated Metal Piping CWA Clean Water Act CEF Conventional and Experimental Facilities Department DOE (United States) Department of Energy DOT (United States) Department of Transportation EP Environmental Protection (Department) EPA (United States) Environmental Protection Agency ES&H Environment, Safety, and Health (Division) HMBP Hazardous Material Business Plan HWSA Hazardous Waste Storage Area IR Interaction Region ISEMS Integrated Safety and Environmental Management System JRBP Jasper Ridge Biological Preserve LCLS Linac Coherent Light Source LCW Low Conductivity Water Linac Linear Accelerator LRDP Long Range Development Plan MCC Main Control Center MFPF Metal Fabrication Pretreatment Facility NPDES National Pollutant Discharge Elimination System PCB polychlorinated biphenyl PEP Positron-Electron Project PVTC Portola Valley Training Center RCRA Resource Conservation and Recovery Act RP Radiation Protection (Department) RWQCB (San Francisco Bay) Regional Water Quality Control Board SARA Superfund Amendments and Reauthorization Act SBSA South Bayside System Authority SLAC Stanford Linear Accelerator Center

Page - iv SLAC-I-750-0A16M-002-R002


SLC Stanford Linear Collider SLD SLAC Large Detector SOP Standard Operating Procedure SPCC Spill Prevention, Countermeasure, and Control (Plan) SPEAR Stanford Positron-Electron Asymmetrical Ring STA SLAC Training Assessment SSRL Stanford Synchrotron Radiation Laboratory SWRCB (California) State Water Resources Control Board SWPPP Stormwater Pollution Prevention Plan WAA Waste Accumulation Area WM Waste Management (Group)

Page - v SLAC-I-750-0A16M-002-R002


1 SWPPP CERTIFICATIONS

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons or persons 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 fines and imprisonment for knowing violations.

______________________________________________________________________ John Cornuelle Date Associate Director, Operations Division

January 31, 2007 SLAC-I-750-0A16M-002-R002 1


2 SWPPP AMENDMENTS

This Storm Water Pollution Prevention Plan (SWPPP) shall be amended: • Whenever there is a change in operations which may affect the discharge of

pollutants to surface waters; or • If any condition of the General Industrial Permit is violated or the general objective of

reducing or eliminating pollutants in stormwater discharges has not been achieved. If the Regional Water Quality Control Board (RWQCB) determines that a permit violation has occurred, the SWPPP shall be amended and implemented within 90-calendar days after notification by the RWQCB;

• And when deemed necessary by Stanford Linear Accelerator Center (SLAC) to maintain or improve accuracy of its content or effectiveness.

The following items will be included in each amendment: • Who requested the amendment • The location of proposed change • The reason for change

The amendments for this SWPPP are listed in the Table 1: Record of Revisions.

Table 1: Record of Revisions Revision Number

Description Section(s) Requestor /Reason Date of Revision

Rev. 0 Original Issue All 1992 Rev. 1 Update All Program Manager/ To reflect

program changes 1996

Rev.1 Update All Program Manager/ To reflect program changes

7/1998

Rev. 1 Update Appendix C Program Manager/ To reflect program changes

12/2001

Rev. 2 Reorganized/ Update

All Program Manager/ Change in SLAC organizational structure, document reorganized to reflect permit

1/2007

6/22/07 SLAC-I-750-0A16M-002 2


3 INTRODUCTION AND BACKGROUND

Stanford Linear Accelerator Center (SLAC) is one of the world’s leading research laboratories. Established in 1962, it is located in Menlo Park, California. SLAC’s mission it to make discoveries in photon science and particle and astro particle physics and to operate a safe laboratory. SLAC is a federal facility operated by Stanford University under contract with the United States Department of Energy (DOE). Experimental research started in 1966 with the completion of the two-mile linear accelerator (Linac). Since 1966, other major research facilities have been built. SLAC continues to grow and has an exciting array of new science programs and facilities planned for the future. The Long Range Development Plan (LRDP)1 has been developed to guide this effort. Parts of the campus are always open to the public and the public is frequently invited to events hosted by SLAC or to participate in Public Tours of the facility. Though primarily for visiting scientists (referred to as facility users), housing is available on-site for visitors and guests at the Stanford Guest House. Up to 500 facility users from other institutions may be involved in conducting experiments at SLAC at any given time. The day-to-day operation is managed under four directorates: Operations; Linac Coherent

Light Source (LCLS) Construction; Particle and Particle Astrophysics; and Photon Science. All facility users (who generally have supplementary outside funding) are under the jurisdiction of SLAC with respect to the control of hazardous material or activities. No products for commercial markets are manufactured at SLAC. Equipment, from minute electronic parts to large detector assemblies, is constructed on site for use in SLAC

research programs. The energy demand for operation of the Linac and experimental equipment is substantial. All electrical energy is supplied to SLAC from the local utility. SLAC’s mission includes maintaining environmental excellence. This effort is implemented through the use of an Integrated Safety and Environmental Management System (ISEMS). All environmental aspects, including stormwater pollution, are mitigated through a system of PLAN-DO-CHECK-IMPROVE, which supports effective organizational communication and resource allotment resulting in constant improvement. The facility’s corporate ownership, street address, and other industrial information appear in the Notice of Intent, originally filed on March 27, 1992, and resubmitted July 2, 1997 (WID # 2 41I002417). A copy is attached to this document as Appendix A.

3.1 Regulatory Background The 1987 amendments to the Federal Water Pollution Control Act (also referred to as the Clean Water Act [CWA]) added Section 402(p) establishing a framework for regulating municipal and industrial stormwater discharges under the National Pollutant Discharge Elimination System (NPDES) Program. The U.S. Environmental Protection Agency (EPA) published Phase I regulations on November 16, 1990, that establish application

1 URL link: http://www-group.slac.stanford.edu/bsd/SLAC_LRDP_final.pdf

6/22/2007 SLAC-I-750-0A16M-002 3


requirements for stormwater permits. The regulations require that stormwater associated with industrial activity must be regulated by an NPDES permit. The State of California has been authorized to issue individual or General Industrial Permits to regulate stormwater discharges. The California State Water Resources Control Board (SWRCB) issued a statewide General Industrial Permit (Permit) on November 19, 1991 that applied to all industrial activity stormwater discharges requiring a permit except construction activity. The permit requirements pertaining to SLAC are implemented and enforced by the San Francisco Bay Regional Water Quality Control Board (RWQCB). The permit’s monitoring requirements were amended on September 17, 1992 to conform more closely to the new EPA nationwide stormwater permit and related guidance. On April 17, 1997, the SWRCB adopted a new five-year permit that contained many SWPPP and Monitoring Program modifications and improvements relative to the initial General Industrial Permit. On December 8, 1999, EPA issued Phase II stormwater regulations that modify industrial, construction, and municipal permitting requirements. A draft state permit is currently going through public review to meet the new Phase II stormwater regulations. SLAC is currently regulated under Industrial Stormwater General Industrial Permit Order 97-03-DWQ. The permit requires SLAC to: 1. Develop and implement a SWPPP to reduce or prevent industrial pollutants in stormwater discharges; 2. Eliminate unauthorized non-stormwater discharges; and 3. Conduct visual and analytical stormwater discharge monitoring to indicate the effectiveness of the SWPPP in reducing or preventing pollutants in storm discharges.

3.2 Purpose and Elements of the SWPPP The main objectives of the SWPPP are: • to help identify the sources of pollution that affect the quality of industrial stormwater

discharges, and • to describe and ensure the implementation of practices to reduce pollutants in those

discharges. Table 2 shows the required elements of the SWPPP and Monitoring Plan as outlined in the permit and the corresponding sections of this document that fulfill those requirements. A more comprehensive check sheet is attached as Appendix A.

6/22/07 SLAC-I-750-0A16M-002 4


Table 2: SWPPP Requirements SWPPP Requirement (General Permit Section) SWPPP Section Signed Certification (Section C.9. and C.10) Section 1 Stormwater Pollution Prevention Team (A.3.a) Section 3.4 Existing Facility Plans (A.3.b) Section 4 Facility Site Map(s) (A.4.a -e) Section 5.1 List of Significant Materials (A.5) Section 5.2.2 Description of Potential Pollution Sources (A.6) Section 5.2.3 Assessment of Potential Pollutant Sources- Table B (A.7) Section 5.2.3 Stormwater Best Management Practices (A.8) Section 5.3 Annual Comprehensive Site Compliance Evaluation (A.9) Section 5.3.3 Filed Notice of Intent Appendix A Monitoring Program Requirements Appendix F Quarterly Non-Stormwater Discharge Visual Observations (B.3) Appendix F

Stormwater Discharge Visual Observations (B.4) Appendix F Sampling and Analysis (B.5-7,10, 13-14) Appendix F

3.3 Area and Site Description SLAC is unique in its mission and operation. As a research facility it differs from more typical manufacturing or industrial sites due to its decentralized and dynamic organization. Processes and structures are research driven and are changed based on the needs of the users and their research objectives. Environmental safeguards are defined through a contractual relationship between the DOE and Stanford University and managed through an ISEMS. The following describes the site location, surrounding land use, and types of development on site.

3.3.1 LOCATION SLAC is in an unincorporated area of San Mateo County, adjacent to the City of Menlo Park (Figure 1). SLAC is bordered to the north by Sand Hill Road. The commercial and residential developments of Sharon Heights lie north of SLAC across Sand Hill Road. Stanford Hills, a residential development, and agricultural grazing land lie to the east. Agricultural and equestrian facilities lie to the south. Undeveloped areas, particularly the Jasper Ridge Biological Preserve (JRBP) lies alongside the SLAC southern boundary for approximately 1 mile starting at the western end of the Linac. San Francisquito Creek flows from west to east roughly parallel to the SLAC southern border. Adjacent leaseholders separate SLAC property from the creek along SLAC’s entire boundary. At no place does SLAC discharge directly to the creek. The Linac is situated on a parcel roughly 975 feet (ft) wide and 10,000 ft long, and is oriented in an east-west direction. Near the east end of the Linac, the parcel widens to approximately 3,000 ft. The total length of the site, including the Linac, Research Yard, and experimental facilities, is approximately 3 miles. Interstate Highway 280 passes over the eastern portion of the Linac. The main entrance to the site, at 2575 Sand Hill Road, includes a security guard station. The perimeter of the site is fenced and there are several locked gates within the perimeter fence. Access and movement within the SLAC campus area is unrestricted. Typically, this area is used by SLAC personnel, vendors and visitors. The Linac, Research Yard, and many experimental facilities are within a controlled area called the Accelerator Area.

6/22/2007 SLAC-I-750-0A16M-002 5

jfulton

Complete this


Access to this area is restricted to employees and contracted vendors holding SLAC badges. All personnel entering this area must pass through a controlled gate.

Figure 1: Site Location Map

3.3.2 SETTING The SLAC site is in a belt of low rolling foothills, lying between the alluvial plain bordering San Francisco Bay on the east and the Santa Cruz Mountains on the west. The entire site is underlain by sandstone and claystone, which represent a shallow marine environment. In general, the bedrock on which the western half of the site rests is the Whiskey Hill Formation of Eocene age (over 50 million years old), and under the eastern half of the site is Ladera Sandstone of Miocene age (over 10 million years old). On top of this bedrock at various places are found alluvial deposits of sand and gravel of the Santa Clara Formation – generally of Pleistocene age (1 million years old). At the surface is a soil overburden of unconsolidated earth materials averaging one to two ft in depth. A basalt stratum approximately 30 ft thick occurs at the eastern end of the site above Alpine Road. The terrain includes numerous small hills and gullies, many of which were the result of earth-moving activities from SLAC construction. The SLAC site varies in elevation from 174 to 350 ft (ft) above sea level, whereas the alluvial plain to the east around the Bay lies less than 151 ft above sea level; the mountains to the west rise abruptly to over 2,000 ft. Surface waters within ¼ mile of the SLAC site are: San Francisquito Creek (<200 ft south), Bear Creek (approximately 400 ft. west), Searsville Lake (approximately 1500 ft

6/22/07 SLAC-I-750-0A16M-002 6


south), and Bear Creek (approximately 400 ft west). Other surface waters located farther from the site include Lake Lagunita (approximately 4500 ft east), Bear Gulch Reservoir (approximately 6000 ft north), and Felt Lake (approximately 8000 ft southeast). Bear Creek, Los Trancos and San Francisquito Creek are the main drainage systems in the area. Bear Creek joins with San Francisquito Creek south-west of SLAC. Los Trancos Creek joins San Francisquito Creek south-east of the site. San Francisquito Creek discharges into San Francisco Bay. San Francisquito Creek begins at the northern end of Searsville Lake, approximately ¼ mile southwest of SLAC in the northwest corner of JRBP. Stormwater run-off from SLAC ultimately discharges into San Francisquito Creek, either through run-off from natural drainages, or through the stormwater conveyance systems. Three seasonally ephemeral tributary streams of San Francisquito Creek flow through SLAC. Two of these streams drain the western portion of the site. The other receives run-off primarily from the campus and leaves the site just south of the Interaction Region 8 (IR-8) along the SLAC southern border.

3.3.3 CLIMATE AND REGIONAL RAINFALL The climate in the SLAC area is Mediterranean. Winters are cool and moist, and summers are mostly warm and dry. Long-term weather data describing conditions in the area have been assembled from official and unofficial weather records at Palo Alto Fire Station Number 3, 3 miles east of SLAC. The SLAC site is 197 to 394 ft higher than the station and is free of the moderating influences of the city; temperatures therefore average about two degrees lower than those in Palo Alto. Daily mean temperatures are seldom below 32 degrees Fahrenheit or above 86 degrees Fahrenheit. Rainfall averages about 22 inches per year. The distribution of precipitation is highly seasonal. About 75 percent of the precipitation, including most of the major storms, occurs during the four-month period from December through March. Most winter storm periods are from two days to a week in duration. The storm centers are usually characterized by relatively heavy rainfall and high winds. The combination of topography and air movement produces substantial fluctuations in intensity, which can best be characterized as a series of storm cells following one another that produce heavy precipitation for periods of five to 15 minutes with lulls in between bursts.

3.3.4 LAND USE AND DEVELOPMENT ON THE SLAC SITE There are more than 230 buildings, and over 100 trailers, sheds, and other roofed structures on-site. For the purposes of this plan the facilities, areas, and structures at SLAC are grouped as follows: • Research Facilities: includes structures and areas such as the Linac, interaction and

detector halls, and tunnel rings; • Support Areas: includes areas typically categorized as industrial such as the

fabrication, maintenance and craft shops, cooling towers, utility, instrumentation and electrical power structures, loading docks, as well as the Hazardous Waste Storage Area (HWSA).

• Non-Industrial Activity Areas: includes office buildings and associated employee and visitor parking lots, public areas such as the visitor’s center, auditorium and cafeteria, guest house, campus lawn areas and naturally vegetated undeveloped areas.

6/22/2007 SLAC-I-750-0A16M-002 7


The permit only covers the industrial activity portions of the site which include most of the Support Structure Areas and Research Facilities. Though non-industrial activity areas are not captured under the permit, SLAC has chosen to include activities in these areas that may pollute stormwater in this SWPPP. However, construction activities that fall under the Construction General Permit2 are not addressed here. Once the construction is completed the SWPPP will be updated to include the new structures if applicable.

3.3.4.1 Research Facilities Research facilities are located both above and below grade and are the core of the research activities at SLAC. The Linac and rings shown in Figure 2 are the primary structures. The Linac consists of the two-mile long tunnel housing the Accelerator Beam and the above grade Klystron Gallery. The Linac tunnel is located approximately 40 ft below grade along the western two thirds of the SLAC site. The Klystron Gallery and other support facilities are located directly above the tunnel on the ground surface. The high-energy beam moves through the tunnel and enters the Beam Switch Yard (BSY) near the Research Yard area, where it is split and directed to various experimental areas including the Positron Electron Project (PEP) tunnel and the Stanford Linear Collider (SLC) tunnel.

Figure 2: Schematic of Linac and Rings

The Stanford Synchrotron Radiation Laboratory (SSRL) is located north of the Research Yard in the eastern part of the site. It is a national user facility that provides synchrotron radiation, a name given to x-rays or light produced by electrons circulating in a storage ring at nearly the speed of light. The Stanford Positron Electron Asymmetric Ring (SPEAR) provides the source of radiation for experiments at SSRL. While SPEAR was originally designed as a high-energy physics colliding beam facility, it has been an 2 Dischargers whose projects disturb 1 or more acres of soil or whose projects disturb less than 1 acre but are part of a larger common

plan of development that in total disturbs 1 or more acres, are required to obtain coverage under the General Permit for Discharges of

Storm Water Associated with Construction Activity (Construction General Permit, 99-08-DWQ). Construction activity subject to this

permit includes clearing, grading and disturbances to the ground such as stockpiling, or excavation, but does not include regular

maintenance activities performed to restore the original line, grade, or capacity of the facility.

6/22/07 SLAC-I-750-0A16M-002 8


important and effective source for synchrotron radiation experiments for all of its 30-year history. Since 1990, SPEAR has been totally dedicated to synchrotron radiation experiments, operated under the stewardship of the DOE Office of Basic Energy Sciences. The newest addition to SLAC will be the Linac Coherent Light Source (LCLS). It will be the world's first x-ray free electron laser when it becomes operational in 2009. Construction on the LCLS began in 2006.

3.3.4.2 Support Areas There are many activities and structures that support the research done at SLAC. Many of these can be categorized as typical industrial activities such as metal fabrication, metal plating, vacuum assembly, and various (chemical, metallurgy and photographic) laboratories. However, SLAC also provides support more typical of community services such as salvage and recycling, craft shops, transportation and fleet maintenance, utilities (low conductivity water, deionized water, cooling and heating, natural gas), materials storage areas, and hazardous waste management facilities. Support areas are interspersed through-out the site with many concentrated in areas just west or within the Research Yard. Many if not most of these activities occur inside buildings and therefore, are not subject to the permit. Specific areas and activities that pose a potential threat to stormwater are discussed in Section 5 and Appendix G.

3.3.4.3 Non-Industrial Activity Areas Much of SLAC can be categorized as a non-industrial activity area. Office buildings, parking lots, cafeteria, visitor’s center, Guest House, and the fire station are located in the central area of the campus. Large undeveloped areas, which are naturally vegetated, envelope most of the built-up areas on site. The cafeteria, fire station, and areas where significant erosion may occur, though not considered industrial activities, are managed using best management practices described in this SWPPP.

3.3.5 IMPERVIOUS AND PERVIOUS SURFACE AREAS AND DRAINAGE PATTERNS Impervious surfaces make up a relatively small portion of SLAC. The total area of paved surfaces and roofed structures is approximately 151 acres; or 35% of the site. On the other hand, pervious areas such as landscaped and undeveloped areas cover 275 acres or 65% of the site. 3 SLAC has an extensive storm drain system consisting of both overland channels and below grade corrugated metal piping (CMP). There are over 400 stormwater catch basins and 25 surface water discharge points at SLAC. Section 5 of SWPPP Monitoring Program (Appendix F) discusses each drainage area, discharge point and final disposition of stormwater flow from the SLAC site. In general, discharges from the storm drain system percolate into the ground, evaporate, or are carried into San Francisquito Creek. Drainage to the storm drain is generally

3 From Toxic Reporting Inventory calculations for surface run-off: 89 acres of paved streets, parking lots, 54 acres of buildings and roofs, 261 acres of unimproved land, and 14 acres of landscaped areas. Numbers confirmed through Mechanical Design group. Computation Sheets are in Appendix K.

6/22/2007 SLAC-I-750-0A16M-002 9


divided along topographic lines, with most slopes going south toward the creek. However, the storm drain system has been routed through hillsides, so that storm drain boundaries are not identical to topographical watershed boundaries. The drainage west of Highway 280 is dominated by the Linac. When the Linac was constructed in the 1960s, it was built across four major natural drainage channels that drained south across the site to San Francisquito Creek. Large, open-ended, CMP culverts were placed under the Linac to convey the natural drainage toward the creek. The Linac is divided into 31 sectors (numbers 0 to 30, west to east) of approximately 330 ft each. From west to east, these culverts are located at Sectors 6, 10, 14, and 18. The culverts at Sectors 6, 14, and 18 daylight on the SLAC site south of the Linac, while the culvert at Sector 10 daylights on the adjacent JRBP, before flowing overland to San Francisquito Creek. The area that drains into the culvert at Sector 18 includes areas both east and west of Highway 280 and run-on from the adjacent properties. Localized surface drainage along the Klystron Gallery is channeled by curbs and ditches. In the Campus/Support Area, stormwater drainage is carried by paved curb and gutter flow to grate-covered catch basins and a below-grade storm drain system. The majority of this area drains to the IR-8 channel. A small portion of the Campus Area drains north, towards Sand Hill Road and is discharged to the Menlo Park storm drain system ultimately discharging to San Francisquito Creek near the intersection of Sand Hill Road and Santa Cruz Avenue. In the Research Yard, catch basins located approximately every 100 ft collect stormwater into closed underground culverts which discharge through the IR-6 channel. The majority of water that comes into contact with industrial activities leaves the site through the IR-6 and IR-8 channels. The IR-6 drainage area encompasses approximately 30 acres; this area is primarily paved or covered by buildings, and includes the Research Yard. The IR-8 drainage area encompasses approximately 65 acres; this area is also substantially paved and occupied by buildings, including the SLAC campus area. The IR-6 and IR-8 channels are described below and depicted in Figure 3.

• IR-6 Channel – The storm drain system from the Research Yard daylights at the IR-6 Channel. The SLAC portion of the channel is lined with concrete and is 100 ft long and ends at the property fence line. There is an additional 330 ft of unlined channel off SLAC property. This portion is part of an on-going restoration effort to eliminate low levels of PCB and lead found in sediment.4

• IR-8 Channel – The storm drain system that services several areas within the developed portion of SLAC including the Magnet Yard, Upper/Lower Salvage Yards, and fabrication areas, daylights upstream of the IR-8 channel. The channel is concrete lined for approximately 400 ft. The channel is lined with rock for approximately 100 ft up to the property fence line.

4 RWQCB Order No. R2-2005-0022

6/22/07 SLAC-I-750-0A16M-002 10


Figure 3: IR-6 and IR-8 Channels

IR-8 channel converges with a channel that drains Buildings 15 and 18 parking lots outside the southern border of SLAC before it converges with the IR-6 channel. The combined flow is conveyed by two culverts underneath a horse track before entering a detention pond prior to discharging to San Francisquito Creek.

3.3.5.1 Sub-Drain Systems Portions of the tunnels at SLAC are located below the groundwater table. Sub-drains and moisture barriers are installed to eliminate hydrostatic pressure and seepage. However, groundwater cannot be completely prevented from entering these below grade structures. All the water which infiltrates the tunnels, is collected in sumps, analyzed for radiation as necessary, and discharged to the sanitary sewer. Groundwater is also collected in sub-drains placed below the Linac, the PEP Ring, and the SLC tunnel. The SLC sub-drain system is plumbed to vaults located within the tunnel where the groundwater co-mingles with tunnel seepage before being discharged to the sanitary sewer. Sub-drain groundwater from the Linac and PEP ring is not exposed to any industrial processes or potential pollutants and is discharged to the storm drain system. The sub-drain system below the Linac consists of a parallel set of perforated collection pipes sloped to drain from west to east through four connected vaults on the south side of the structure at Sectors 8, 15, 20 and 30. Each vault was designed to discharge to a surface drainage channel with excess water draining to the next vault. The vault at Sector 8 discharges to an area that supports year-round cattails and percolates into the soil. The

6/22/2007 SLAC-I-750-0A16M-002 11


vault at Sector 15 doesn’t appear to collect any water.5 The drainage culvert from the vault at Sector 20 has been crushed, resulting in the majority of the groundwater flowing to the final vault at Sector 30. The groundwater from the Sector 30 vault daylights at the concrete lined channel at IR-8 before leaving the site. The PEP tunnel is designed with five structures known as the Interaction (IR) Halls placed at regular intervals in a clockwise configuration. The IR Halls are designated as IR-2, IR-4, IR-6, IR-8, and IR-12. Outside each of the IR Halls is a storm water catch basin. IR-2, IR-6, IR-8, and IR-12 are in depressions and use lift stations to pump the collected water automatically to the storm drain system. Groundwater that is collected by the tunnel sub-drain system enters leach fields near each IR Hall where some re-percolates into the soil. The leach fields are plumbed to the IR Hall catch basins to capture excess drainage. Drainage from IR-2 enters the IR-2 North Channel and drainage from IR-12 enters the North Adit East Channel, both ultimately enter the Menlo Park storm drain system. Drainage from IR-8 enters the IR-8 channel. Drainage from IR-4 enters the Alpine Gate East Channel. Drainage from IR-6 enters the Alpine Gate West Channel. The drains below the Linac and PEP divert between 4,000 and 8,000 gallons of groundwater to the storm drain system daily.6

3.3.6 NON-STORM WATER DISCHARGES 3.3.6.1 Authorized Non-Storm Water Discharges

3.3.6.1.1 Secondary Containment and Utility Vaults Outdoor secondary containments fill with rain and must be emptied to maintain containment capacity. Utility vaults can contain both groundwater and stormwater and must be emptied prior to repair work. SLAC utilizes a 2,200 gallon vacuum truck to pump this water for re-use as cooling tower basin make-up water. (See sections 5.2.3.4, 5.2.3.5 and 5.2.3.6). Contained stormwater can only be discharged to the storm drain if it is clean and the discharge is documented. Visual inspections and/or chemical tests may be conducted for suspected contaminants.

3.3.6.1.2 Eyewashes and Emergency Showers Eyewash and emergency shower stations are located in chemical use areas throughout SLAC. Each eyewash and emergency shower is flushed periodically to ensure proper operation. The amount of domestic water used for flushing is approximately 2 gallons. Indoor eyewashes and emergency showers are connected to the sanitary sewer system. Water from eyewashes and showers in the HWSA drains into a blind sump, and is either disposed of in the sanitary sewer or as a hazardous waste, depending upon analytical results. The eyewash at the Metal Fabrication Pretreatment Facility (MFPF) (B38) empties onto the concrete floor of the secondary containment that surrounds the plant. The spent water is pumped into the plant for treatment and disposal to the sanitary sewer. Outdoor eyewashes and emergency showers are flushed to the pavement. In most cases the water evaporates before reaching a storm drain. There is potential that material can be mobilized by the flushed water. Operators are instructed to keep these areas swept and to minimize the amount of flush water.

5 The sub-drain in this area drains a section of the linac that is above the groundwater table. 6 Flow estimates were derived from findings of the Underdrain Study (1999 – 2000). Transducers were placed in selected vaults and catch basin for a 24 hour period, every three months over two years to estimate seasonal flow volumes.

6/22/07 SLAC-I-750-0A16M-002 12


3.3.6.1.3 Water Line and Low Conductivity Cooling Water System Breaks Occasional breaks occur in the SLAC domestic and hot water supply lines. The design of the system allows such leaks to be isolated as soon as discovered. Flow from line breaks may enter the storm drain system, but upon discovery they are isolated and pumped to the sanitary sewer if necessary. The Deionized Water Plant (located next to B460) provides low conductivity water (LCW) for closed–loop industrial cooling and for the Plating Shop. In this process, domestic water is converted to LCW using vendor-supplied cylinders of cation/anion mixed beds and an organic resin bed. This system is maintained by CEF who contract U.S. Filters for cylinder exchange and filter change out. The water does not contain chemicals and is neutral until exposed to air at which point it produces carbonic acid and can drop to a pH of 3. Any LCW line break or leak is detected by monitoring the quantity of make-up water required to maintain pressure in the system.

3.3.6.1.4 Groundwater Groundwater from sub-drain systems is discharged to the storm drain (See section 3.3.5.1). Additional groundwater may enter through hillside and spring seepage into drainage channels directly.

3.3.6.1.5 Irrigation Water Landscaped areas are irrigated and excess water may run-off entering the storm drain system. There are approximately 14 acres of lawn areas with scattered trees and 7.6 acres of ground cover with scattered trees and shrubbery. The contract for landscaping services includes the monitoring of all irrigation systems to achieve water usage efficiency, and to inspect and adjust the irrigation controllers and the sprinkler system regularly to maintain delivery of the right amount of water.

3.3.6.1.6 Fire System Flushing and Drills The National Fire Protection Code (NFPC) requires that fire hydrants and sprinkler systems be flushed every eight weeks for 30 seconds. The General Permit authorizes this discharge provided it is uncontaminated. Procedures call for the use of thiosulfate tablets to minimize any contamination by chloramines to the extent possible. Discolored or rusty discharge must be filtered and discharged to the sanitary sewer when possible.

3.3.6.1.7 Fire Suppression Runoff In an emergency, water from fire hydrants or tankers used to suppress fire could enter the storm drain system. If it is determined by the emergency incident command that the fire suppression water could be contaminated with pollutants, the runoff will be contained to the extent allowed given the emergency conditions.

3.3.6.1.8 Condensate Minor amounts of water from liquid nitrogen condensation, air conditioner condensation, and air compressor condensation may be discharged to the storm drain. In most cases the quantity is so slight as to evaporate before discharge.

3.3.6.2 Non-Authorized Non-Storm Water Discharges 3.3.6.2.1 Sanitary Sewer Back-up or Line Breaks

The sanitary sewer system has no known cross-connections to the storm drain, however due to roots, breaks and in some cases, aging infrastructure, occasionally a pipe may back-up. Any back-ups that occur near a storm drain pose a risk if the drain is not adequately protected. Such a break would be managed as an emergency condition and

6/22/2007 SLAC-I-750-0A16M-002 13


SLAC would apply aggressive containment measures to prevent its entering a storm drain.

3.3.6.2.2 Cooling Tower Water Releases A small amount of cooling tower basin water is deposited on the paved and undeveloped areas surrounding each cooling tower as mist or drift. In addition, cooling tower recirculation water piping may leak or break releasing basin water. Related is the release of basin water if a power outage results in failure of both primary and back-up basin pumps. In that case, all the water in the recirculation piping drains back into and exceeds the basin’s holding capacity. Historical spills that have occurred at the cooling towers are included in Appendix I. Cooling towers 101 and 1701 have configurations that could result in a basin water release in the event that both pumps fail. Measures have been taken to protect the storm drain in both areas, including staging supplies near by to block the local storm drains if required.

3.3.6.2.3 Small Maintenance and Repair Work Cleanup Cleanup from small facility and grounds maintenance and repair work by SLAC laborers may include rinsing of containers and hand tools. Laborers are typically engaged in activities such as saw-cutting, trenching, digging, and small building and grounds surface repairs. Rinse water is typically limited to a few gallons which is discharged to the ground surface in a manner to prevent discharge into the storm drain.

3.3.6.2.4 Vehicle and Equipment Washing Vehicle and equipment washing is prohibited except in designated areas at the steam cleaning pads at B025 and B081. Discharges from these pads are treated and discharged to the sanitary sewer. Currently the Fire Department washes its engine with limited amounts of domestic water at the fire station. Efforts are being made to construct an oil/ water separator connected to the sanitary sewer to support the requirements of fire engine maintenance.

3.3.6.2.5 DIRC Emergency Water In the event that the Detection of Internally Reflected Cherenkov Light (DIRC) Stand-off Box (SOB) dumps 7 during heavy rains, SLAC will need to protect the experimental equipment and prevent flooding. This may result in ultra pure water being released to the storm drain. In any other case, the water will be contained at the lift station at IR-2 and pumped out for release at the top of the hill into a grassy undeveloped area where it can percolate and/or evaporate without entering the storm drain system.

3.4 Stormwater Pollution Prevention Team and Contact Information

The ES&H Stormwater Program Manager is the point of contact (POC) for the SWPPP program and is responsible for maintaining the SLAC SWPPP. The SWPPP will be reviewed periodically to ensure that it represents current information regarding SLAC facilities and activities. The responsibility for implementing SLAC policies is delegated to individual Associate Directors, who appoint individuals to be responsible for environmental and safety

7 http://www.slac.stanford.edu/BFROOT/www/Detector/DIRC/shifts/AfterDumpProcedure.html

6/22/07 SLAC-I-750-0A16M-002 14


matters, including stormwater pollution prevention and implementation of BMPs. Appendix B identifies those individuals responsible for implementing the SWPPP.

6/22/2007 SLAC-I-750-0A16M-002 15


4 EXISTING FACILITY PLANS AND REFERENCES

The following are existing facility plans included in the SWPPP by reference.

4.1 Air Permits –Dust and Particulates A list of all Bay Area Air Quality permitted and exempt sources at SLAC are provided in Appendix C. Air permits for specific sources are available through the ES&H Air Program Manager. Locations of sources with dust and particulate emissions are identified on the SWPPP Map (ID 581-020-00-C3) provided in Appendix D.

4.2 Chemical Management System and Hazardous Materials Business Plan

SLAC uses a third party chemical service provider to encourage minimal hazardous materials storage on site by providing reliable product sources and fast delivery options. The centralized nature of chemical ordering and defined delivery locations is a key element of the safe delivery, storage and handling of chemicals on site. The Hazardous Materials Business Plan includes an inventory by building of chemicals and hazardous waste stored on site. The Hazardous Materials Inventory statement is included in Appendix E - List of Significant Materials. Details of the chemical management system, including maps of delivery points can be found at http://www-group.slac.stanford.edu/esh/groups/cgs/cms/.

4.3 ES&H Manual The ES&H Manual8 outlines policy. Chapter 26 describes the SLAC policy on stormwater pollution prevention and creek protection.

4.4 Emergency Response The following emergency response plans are used to ensure that stormwater is protected from spills of chemicals, hazardous waste and oil products. • ES&H Manual Chapter 37: Emergencies9 • Facility Emergency Plans10 • Consolidated Chemical Contingency Plan11 • Spill Prevention, Control, and Countermeasures Plan (SLAC-I-750-0A16M-R001) 12

4.5 Integrated Safety and Environmental Management System This program is described at http://www-group.slac.stanford.edu/esh/general/isems/. It is a systems approach to determine environmental and safety goals and facilitate continuous improvement and communication between different organizational groups.

8 http://www-group.slac.stanford.edu/esh/eshmanual/ 9 http://www-group.slac.stanford.edu/esh/emergency/chapter/policies.htm 10 https://www-internal.slac.stanford.edu/esh/emergency/fep/ 11 http://www-group.slac.stanford.edu/esh/documents/CCCP.pdf 12 https://www-internal.slac.stanford.edu/esh/documents_internal/SPCC.pdf

6/22/07 SLAC-I-750-0A16M-002 16


4.6 Long Term Development Plan This plan describes the development goals of the SLAC lease holding over the next decade. It discusses land use, architectural considerations, open space and parking strategies and can be found at: http://www-group.slac.stanford.edu/bsd/SLAC_LRDP_final.pdf

4.7 On Site Hazardous Materials Transportation The “Stanford Linear Accelerator On Site Hazardous Materials Transportation Safety Document” (SLAC-I-720-0A86Z-002-R000)13 describes how SLAC implements the safe transportation of hazardous materials while on SLAC roadways.

4.8 Radiation Safety The nature of research at SLAC requires that special precautions and procedures be followed to minimize risk from radiation. These procedures can be found in the following documents. • Radiological Control Manual (SLAC-I-720-0A05Z-001-R002)14 • Radioactive Waste Manual (SLAC-I-720-2A08Z-001-R001)15

4.9 Training An individual’s training requirements are assessed by their supervisors based on requirements of the position. ES&H requirements are determined using the ES&H SLAC Training Assessment, a web-based tool that helps determine what training is required to meet our environmental and safety objectives. Stormwater Awareness training is a required course for SLAC employees who conduct or manage activities that may impact stormwater runoff.

4.10 Other Plans and References • SLAC University Technical Representative Guide (SLAC-11-01-07-01)16

13 http://www-group.slac.stanford.edu/esh/documents/hazmatTransportSafety.pdf 14 http://www-group.slac.stanford.edu/esh/documents/RCM.pdf 15 http://www-group.slac.stanford.edu/esh/documents/RWM.pdf 16 https://www-internal.slac.stanford.edu/operations/manuals/UTRManual.pdf

6/22/2007 SLAC-I-750-0A16M-002 17


5 STORMWATER POLLUTION PREVENTION PLAN

The stormwater pollution prevention plan works within the framework of the SLAC ISEMS. It includes an assessment of potential sources and mitigations of stormwater pollution and a process both to evaluate program performance and make the necessary corrections for continuous improvement. The SWPPP program adapts and improves based on inspection findings, monitoring results and changes in pollution prevention technology and operations. The SWPPP document will be updated to reflect these changes.

5.1 Facility Map The Environmental Compliance SWPPP Map consists of additional layers on the SLAC Site Plan base map. The base map documents buildings, roads, stormwater and sanitary sewer connections. The SWPPP Map (Appendix D) documents site topography, erosion/sediment control locations, waste accumulation and storage areas, drainage areas, vehicle service areas, large unroofed transformers, above ground storage tanks, Bay Area Air Quality Management District (BAAQMD) permitted air sources, unroofed storage/salvage areas, fueling areas, industrial activity areas, stormwater discharge points, and stormwater sampling locations.

5.2 Stormwater Pollution Source Assessment

5.2.1 METHODOLOGY In conducting the stormwater pollution source assessment, the Environmental Protection Department (EP) reviewed Hazardous Materials Business Plan (HMBP) chemical inventories, BAAQMD permits, conducted visual inspections of storage, industrial activity and drainage areas, interviewed SLAC personnel regarding operations and procedures and reviewed documents including historical spill reports, monitoring results and academic and professional stormwater literature. The current chemical inventory can be found in Appendix E. A list of current BAAQMD permits is in Appendix C. Historical stormwater monitoring results can be found in Appendix F within the Stormwater Monitoring Program and is updated annually in the Stormwater Monitoring Annual Summary Report. The information in the listed appendices will be reviewed annually and updated as needed. The criteria used to assess the potential pollutant sources follow the decision process diagram in Figure 5. Those areas requiring the implementation of best management practices are tabulated in Table B: Industrial Activity Areas, Potential Pollutants and Applicable Best Management Practices (BMPs) (Appendix G). SLAC sampling parameters are selected from Table 5.3 of the SWPPP Monitoring Program (Appendix F) based on one or more of the following rationale:

• It is required by the General Permit • It is a potential pollutant as a result of industrial activities and operations • It is listed as an additional Table D parameter • It has been found present in samples from other related studies

6/22/07 SLAC-I-750-0A16M-002 18


Figure 4: Assessment Decision Process Diagram

5.2.2 LIST OF SIGNIFICANT MATERIALS The following sections discuss materials that may potentially pollute stormwater. Significant materials handled or stored at the facility are listed with their typical quantities and handling frequency in Appendix E. Locations where each material is stored, received, shipped, and handled are described below and are tabulated in Table B, Appendix G. Materials included are raw materials, intermediate products, recycled materials, and waste. As defined in the permit, "Significant Materials" includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production; hazardous substances designated under Section 101(14) of Comprehensive Environmental Response, Compensation, and Liability Act (CERLCA); any chemical the facility is required to report pursuant to Section 313 of Title III of Superfund Amendments and Reauthorization Act (SARA); fertilizers; pesticides; and waste products

6/22/07 SLAC-I-750-0A16M-002 19


such as ashes, slag, and sludge that have the potential to be released with storm water discharges.

5.2.2.1 Hazardous Material and Class I Waste SLAC has contracted with Haas TCM to provide and manage a chemical management service (CMS). In a CMS, a customer engages with a service provider in a strategic, long-term contract to supply and manage the customer's chemicals and related services. The CMS centralizes information on all chemical purchases, delivery points, storage areas and responsible people, Material Safety Data Sheets, and usage rates. This chemical information is used for HMBP reporting (SARA, Title III Section 312) in addition to other environmental reports. The HMBP reports on all chemicals stored in quantities exceeding 55 gallons for liquids, 500 pounds for solids, and 200 cubic ft for gases on a building-by-building basis. It is generated annually and submitted to the San Mateo County Department of Health Services, the local implementing agency for the SARA program. Haas TCM has established delivery locations to meet the needs of SLAC operations. Bulk chemicals are delivered directly to storage tanks. Smaller quantities of chemical are delivered to personnel responsible for storage at localized chemical storage sheds, stockrooms, laboratories and process area chemical cabinets. Hazardous materials storage areas are in the process of being documented in the CMS chemical use-maps17 as well as each operation’s Area Hazard Analysis and Facility Emergency Response Plan.18 These maps and plans are the basis for identifying areas of potential stormwater pollution from hazardous materials. Hazardous waste is generated through various processes on site and is tracked by the Environmental Protection Department’s Waste Management Group (WM). In accordance with SLAC policy, a container can be used for accumulation of hazardous waste for approximately 45 calendar days. Each container of waste will be picked up by WM when the 45-day limit is reached, even if the container is not full. Operational waste generators arrange for containers that are tracked by a computerized system and managed by WM to ensure this time limit is enforced. Waste is collected by trained WM staff for preparation and final off-site shipping. Outdoor storage of hazardous waste occurs on a limited basis. Staff is trained on proper management of containers to prevent exposure to stormwater. All hazardous waste accumulation areas (WAA) are secured and equipped with the required secondary containment and signage. They are inspected weekly.

5.2.2.2 Class II Landfill Waste Class II landfill waste is non-hazardous as defined under the Resource Conservation and Recovery Act (RCRA) and State regulation, but is more regulated than Class III (municipal) landfill waste. It typically consists of non-hazardous solids that are contaminated with regulated levels of petroleum hydrocarbons and low levels of PCB or metals. Other waste streams that may fall under this category include non-friable asbestos and treated wood. Disposal schedules vary from month to month depending on a number of factors such as quantity of waste generated and project size. All Class II waste containers (bins, drums, etc.) are maintained in good condition and kept closed except

17 http://www-group.slac.stanford.edu/esh/departments_groups/chemical_general_safety/cms/ 18 Area Hazard Analysis and Facility Emergency Response Plans can be found through the ES&H web site at https://www-internal.slac.stanford.edu/esh/general/hazanalysis/ahalibrary.htm.

6/22/07 SLAC-I-750-0A16M-002 20


when adding or removing waste. Staff is trained on proper management of soil piles to prevent exposure to stormwater.

5.2.2.3 Class III Landfill Waste and “Green Bin” Recycled Material SLAC contracts with a local disposal firm for Class III waste disposal and recycling of cardboard, paper, beverage containers, wood, and green waste. Recyclable paper and beverage containers are segregated and collected in green bins. Covered collection dumpsters are used for garbage and cardboard. Collection bins and dumpsters are placed in various locations for easy access and are

picked up weekly. Wood and green waste bins are located in a secured area off the PEP ring road between the access roads to IR-12 and North Adit Entrance.

5.2.2.4 Radioactive Material and Waste Radioactive material and waste is managed through the ES&H Radiation Protection Department (RP). This is a highly controlled material that must be surveyed, documented and stored in secured areas. RP performs radiological surveys on suspected radioactive items before they leave radiologically controlled areas. Once an item is identified as radioactive waste, it is entered in an electronic inventory system, which tracks the waste item from the time it is accepted by RP through the ultimate disposal or recycling of the item. This helps prevent the inadvertent disposal or improper handling of radioactive waste. When radioactive wastes are at SLAC, they are handled only by trained personnel and are stored so that exposure to people and to the environment is minimized. SLAC stores radioactive waste for only the time needed to prepare the waste for treatment or disposal. The Radioactive Material Storage Yard (RAMSY) and the Radioactive Waste Storage Area (RWSA) are the RP Waste Storage Areas at SLAC. Waste produced by generators is transferred to these storage areas to be prepared for shipment to final treatment or disposal. The RP radioactive waste storage areas are locked when RP personnel are not present. Weekly radiological surveys and area inspections are performed to ensure that storage conditions are sufficient. Some LCW systems are more likely than others to become activated, especially those used to cool components that either interact directly with the beam or with secondary radiation produced by the beam. RP has a well defined process for controlling potentially radioactive water through collection, testing, documenting and final disposal. In most cases the activity of this water is low enough to allow discharge to the sanitary sewer. Resin bottles used to maintain the purity of this water may also become activated and

6/22/07 SLAC-I-750-0A16M-002 21


must be handled in a manner outlined in the LCW Resin Bottle Servicing Procedure (SLAC-I- 760-2A30C-007-R001).

5.2.2.5 Metal Recycling, Moratorium Metals, and Salvage Operations SLAC Property Control salvage operations conduct a robust metal recycling program for aluminum, copper and steel fines and scrap. Metal is collected in bins and drums located near the generators. Scrap can also be generated from the dismantling of experimental equipment and buildings. The material is then brought to the salvage yard for additional sorting and consolidated into bins for off-site transport. Equipment, including e-waste, is also brought to the salvage yards for redistribution or disposal. Typical salvage material consists of office furniture and equipment, experimental or facility equipment, forklifts, magnets, and cabinets. However, it can include almost anything that had previously been used on site that may be used elsewhere or has value as scrap. Property Control salvage operations does not handle wood, garbage or recycled paper or beverage containers (green bin recyclables). There are two salvage yards on site identified on the SWPPP map as the upper and lower salvage yards. A DOE moratorium, initiated July 13, 2000, prevents the unrestricted release or recycling of scrap metal that came from radiological areas. A radiological area, as defined in 10 CFR 835 includes radiation areas, high radiation areas, very high radiation areas, contamination areas, high contamination areas, and airborne radioactivity areas. Non-radioactive metal materials in this category are stored in secured holding areas managed by Property Control salvage operations. Material that is friable or can be mobilized by rain is contained, roofed or covered. There currently are three secure holding areas for moratorium material that is further described in section 5.2.3.10.5 Outdoor Storage Areas.

5.2.2.6 Other Materials SLAC stores other non-radioactive materials such as shielding blocks, and sheet and block metals. Facility maintenance materials such as plumbing supplies, pipes, rock, sand, electrical and communication cables, cable trays, and fencing materials are also stored on site. These materials are controlled by the operational groups that use them and are usually stored in proximity of their use.

5.2.3 DESCRIPTION AND ASSESSMENT OF POTENTIAL POLLUTANT SOURCES This section describes activities that could generate stormwater contaminants. Activities described include industrial, material handling and storage, dust and particulate generating, non-storm water discharges and sediment and erosion.

5.2.3.1 MFD Metal Finishing Shop and Metal Fabrication Pretreatment Facility The Metal Finishing shop consists of the plating shop, degreasers and laboratories in the Light Fabrication Building (B025), an outdoor steam cleaning pad, a chemical storage building (B036) and shed (B499), the MFPF (B38) and WAA #3. The Metal Finishing Shop is a job shop providing unique cleaning and plating services to the SLAC user and operations community.

6/22/07 SLAC-I-750-0A16M-002 22


Table 3: Chemicals found in Aqueous Wastes and Rinsewater • Actane

• Alkaline cleaner and etch • Alodine dip • Aluminum anodizing bath • Chromic acid dip • Copper cyanide plate • Copper cyanide strike • Copper plate • Hydrochloric Acid • Acid Copper Bath • Ammonium Persulfate • Chemdize-740 • Copper Bright Dips • Enbond (Q-527) • Enprep (Q-527) • Etchant-33 • MC-200

• Nickel Plate • Nickel Strike • Nitric acid • Oxyban-60 • Phosphoric and nitric acid dip • Sulfuric and nitric acid dip • Sodium bicarbonate solution • Metex-629Nickel • Sulfamate bath • Nitric Acid 50% • Nitric Acid, stripper 50% • SST Pickle Acid • SST Cleaner (109-P) • Sulfuric Acid, Anodic and Cathodic • Sulfuric Acid 30% • Everite 50% • All Bright

The Metal Finishing Operation generates waste rinse waters and other aqueous waste from the various plating baths and other associated plating shop operations. These wastes are plumbed directly into the MFPF for treatment. The MFPF also treats wastes streams from other operations that have similar characteristics. See Table 3 for a listing of chemicals commonly found in the waste water treated at the MFPF. These waste streams are brought in tanks and pumped into the treatment holding tanks. Metals and cyanide are removed from the rinse water prior to discharge to the sanitary sewer. SLAC has obtained a permit to treat low levels of hazardous waste on-site under the California Tiered Permit program (Permit-By-Rule). The pH is neutralized, the cyanide destroyed, and the metals are removed through precipitation and flocculation producing a filter cake as a hazardous waste stream. The filter cake is collected in boxes and managed by WM.

Table 4: MFPF Treatment Chemicals

• Sodium hydroxide solution• Calcium chloride • Defoamer agent • Ferric chloride solution

• Sodium hypochlorite solution • Ferrous Sulfate • Polyelectrolyte coagulant • Sulfuric acid

Acid and bases are used in the treatment process at the MFPF (Table 4). Solutions are purchased in bulk and stored in containment areas within the facility. The MFPF facility is roofed and has adequate secondary containment. The facility’s walls are approximately 3-ft high; the containment area has a “blind” sump for collection of rainwater or chemical spills. Any spills are collected and returned to the treatment process. There is no connection between the sumps or containment areas and the storm drain or sanitary sewer.

6/22/07 SLAC-I-750-0A16M-002 23


An outdoor steam cleaning pad located near the Metal Finishing shop is also plumbed to the MFPF. The pad is surrounded by a grated drain which collects the wash water. After each job the drain is cleaned and all the water is drained to the MFPF. The valve is then closed to prevent rain water from entering the MFPF.

5.2.3.1.1 Assessment of the MFD Metal Finishing Shop and Metal Fabrication Pretreatment Facility

The plating and degreasing operations occur inside B025. The pretreatment of waste and rinse water occur in a contained and bermed structure (B038) which has no connections to the storm drain system. The piping from the plating shop to the MFPF is double contained. The storage areas are enclosed or roofed and bermed. Chemicals are transferred from storage to the plating operation within secondary containment. Other than a catastrophic event or spill, there are only two areas that may present an exposure to stormwater. Both have engineered and administrative controls as detailed below:

1. MFPF sludge collection: Spills during collection or transfer could be exposed to storm water. This area is roofed and precautions have been made to contain the dried sludge. An operator monitors the drying and collection process and responds quickly to any spills. The sludge is collected in bags that are closed before pick-up by WM. Spill response equipment is readily available and maintained.

2. B025 Steam Cleaning Pad: The steam cleaning pad is exposed to stormwater. It is cleaned regularly and is not used to store or stage material or items. Only water and detergent are used for cleaning and this material is collected and piped directly to the MFPF. The area and collection gutters are cleaned after each job and before the gutter valves to the MFPF are closed.

5.2.3.2 Remediation Treatment Facilities There are two remediation treatment facilities at SLAC that are mitigating past releases to the soil and groundwater. 19 The first system installed was the Former Solvent Underground Storage Tank system or FSUST. The newest system is the Former Hazardous Waste Storage Area Dual Phase Extraction System or FHWSA DPE. The treated effluent from both systems is discharged to the sanitary sewer. The FSUST was installed in the fall of 2001 to extract and treat groundwater contaminated with volatile organic compounds (VOCs) and semi-volatile organic compounds. An underground storage tank, which was removed in 1983, was the source of the solvents. The FSUST consists of extraction wells and a granular-activated carbon vessel. The treatment vessel is in a roofed structure with secondary containment. The system is alarmed in the event there are leaks from the well heads, conveyance piping or from the carbon vessel. If the alarm is triggered the pumps automatically shut down. Solid sodium hypochlorite is used to prevent bio-fouling and is added to the influent. The FHWSA DPE has been operating as an interim system since 2003. The final system was installed in early 2006. This system was installed to extract both groundwater and soil vapors from an area contaminated with VOCs. The source was an unlined hazardous materials and waste storage area used from the early 1970’s to the early 1980’s.

19 Remediation efforts are conducted under California Regional Water Quality Control Board San Francisco Bay Region Order No. R2-2005-0022.

6/22/07 SLAC-I-750-0A16M-002 24


The FHWSA DPE groundwater extraction and treatment system consists of 23 extraction wells and an air stripper treatment unit. The air stripper is roofed and installed within a secondary containment structure. The system has an alarm for leaks from the well heads, double-contained untreated groundwater conveyance piping, or air stripper. If the alarm is triggered the groundwater pumps and all treatment equipment are automatically shut down. Anti-scalant is added to the influent within the secondary containment structure.

5.2.3.2.1 Assessment of Remediation Treatment Facilities Both systems are roofed and bermed and have alarm systems. Spill response equipment is accessible. The facilities are routinely monitored and maintained and do not pose a threat to stormwater.

5.2.3.3 Master Substation and Transformers SLAC has approximately 100 transformers, more than 30 are large transformers (>660 gallons each). Most are located along the Linac, at the Master Substation, and at Building 750. The primary dielectric fluid is mineral oil. Many of these transformers contained PCB in the past, but most have now been retrofilled, significantly reducing the PCB concentrations. The Master Substation is a fenced area south of Sector 30 that contains buildings and transformers to handle the incoming electric power for the entire site. Past storage and handling practices resulted in soil contamination. This location was remediated and the stormwater rerouted around the substation in the fall of 1998. Other transformer sites have been remediated as part of a site-wide remediation program. Starting in 2005, these remediation activities are conducted under RWQCB Order No. R2-2005-0022. Spill procedures for transformers are described in the Spill Prevention, Countermeasure, and Control (SPCC) plan. All active transformers are surrounded by concrete berms with adequate containment for 110% or more of the transformer volume. Some have been fitted with roofs and/or tarps to reduce the accumulation of rainwater. Transformer containments are inspected on a regular basis. Any release of oil is captured in the secondary containment.

5.2.3.3.1 Assessment of Transformers All active transformers have secondary containment. Incidental leaks and/or spills during maintenance activities are contained. The main risk posed by transformers is the release of oil-contaminated rainwater overflowing the secondary containment. Accumulated rainwater from the containments is routinely collected and treated before being used as make-up water in Cooling Tower 1701.

5.2.3.4 Above Ground Tanks Table 5 lists all the above ground petroleum storage tanks regulated under the SPCC plan. Unless indicated, each tank has adequate secondary containment. There are no below ground tanks at SLAC.

6/22/07 SLAC-I-750-0A16M-002 25


Table 5: Petroleum Storage Tanks Location Contains Capacity (in gal.)

B016 Mobile Mineral Oil 1000 B018 Mobile Biodiesel 20 200 B756 SLC Area Biodiesel 20 500 B023 Central Utility Biodiesel 20 10,000 B037 Biodiesel 20 3900 B007 BSY Substation Biodiesel 20 500 B104 Substation 505A*

Biodiesel 20 500

B082 Fire Station Biodiesel 20 500 B035 Fuel Station Biodiesel 20

/Gasoline 2000

B111 Master Substation

Biodiesel 20 2000

B020 Damping Ring Shelter

Castor Oil 516

B021 Damping Ring RF Shelter

Mineral Oil 260

B044 Test Lab Mineral Oil 4200 *Secondary containment is currently inadequate. Upgrade is planned.

5.2.3.4.1 Assessment of Above Ground Storage Tanks The compressed gas and cryogenic tanks do not present a threat to storm water other than maintenance issues shared with any outdoor structure. The fuel tanks pose a risk when product is removed for fueling vehicles and equipment or during filling. Engineered measures have been taken at the B035 Fuel Station. Administrative measures are taken at B082 Fire Station fuel tank and at B111 Master Substation fuel tank. The nine above-ground diesel tanks on site are refilled from small mobile refueling trucks that use industry standard spill precautions. The tanks at B020 and B021 are only used for temporary storage of mineral and castor oil while performing maintenance work on the modulators and are monitored to ensure secondary containment capacity is maintained.

5.2.3.5 Cooling Towers and Containment Water Treatment Unit SLAC has seven induced-draft cooling towers: four east of Interstate 280 (CT-101, CT-1701, CT-404, and CT-015) and three distributed along the Linac west of I-280, (CT-1200, CT-1201, CT-1202). All the cooling tower systems at SLAC are open re-circulating loop types. LCW circulates through the cooling water system drawing heat from various processes (i.e. air conditioning units, experimental equipment) and expelling it at the cooling towers. The LCW remains contained in pipes and is cooled with circulated domestic water via counter-current heat exchangers. Water is lost at the cooling towers through evaporation, mist, drift and blow-down. Make-up domestic water must be added to the system. In addition to domestic water, CT-1701 make-up water includes rain water pumped from secondary containments and sumps. A 2,200 gallon vacuum tanker truck is used to remove accumulated water from outdoor transformer and fuel tank secondary containments after storm events, and as needed from utility vaults. The collected water is pumped to an uncovered 13,000 gallon concrete storage tank next to Cooling Tower 1701. This water is filtered and treated with activated carbon before use as make-up water in the cooling tower recirculation basin.

6/22/07 SLAC-I-750-0A16M-002 26


Up to 99% of the cooling tower bulk water leaves the system by evaporation into the atmosphere. The remaining amount discharges to the sanitary sewer as blow-down with a small amount drifting to the nearby landscape as mist. Chemicals used at the cooling towers include biocides, dispersants, and acids and are delivered in bulk to storage tanks at each tower. Department of Transportation (DOT)-approved storage tanks are located in small free-standing chemical storage buildings adjacent to each tower. Each tower has an automatic chemical addition system that is inspected regularly to ensure that the system is operating properly.

5.2.3.5.1 Assessment of the Cooling Towers and Containment Water Treatment System

There are five potential sources of stormwater pollution from the cooling towers: 1. Bulk chemical delivery or handling

Cooling tower bulk chemicals are delivered by a vendor and pumped into tanks with secondary containment located in chemical sheds. The vendor delivering the bulk chemicals ensures that the tanker is intact and follows established spill prevention procedures. SLAC personnel are present during tank filling activities to monitor dispensing operations. Spill response equipment is readily available.

2. Drift to the surrounding pavement A preliminary site assessment20was conducted at the cooling towers to determine if they are a potential source of contamination to the surrounding soil. Only cadmium was detected at concentrations greater than both the RWQCB Risk Based Screening Levels (RBSL) and SLAC background levels (CEW, 1992). Run-off from some cooling tower areas flows to IR-8 (CT-101 and CT-1701) and IR-6 (CT-404) drainage channels. In stormwater samples collected at these locations cadmium has not been detected within 50% of the benchmark values.

3. Cooling tower basin water spills and pipe ruptures Cooling tower basin water spills and pipe ruptures have occurred and are documented in Appendix H- Significant Spills. Measures have been taken to protect storm drains and contain overflow in the event of future spills.

4. Oil and grease from pumps and motors Oil and grease accumulate on the pumps and motors used at the cooling towers. Many of the motors and pumps are covered to prevent stormwater from contacting the pumps. Others are within contained areas. Preventive maintenance is conducted regularly to minimize exposure from this source.

5. Basin sludge removal and filter replacement Sludge is removed from the basins and water filters are replaced as needed. Metals and PCB have been detected in the sludge and filters and they are characterized as Class I or II waste for disposal. Wet sludge and filters are placed in drums for disposal. Any spills are cleaned up immediately.

20 Preliminary Site Assessment of Cooling Towers 101, 1200, 1201, 1202, and 1701; SLAC-I-750-0A33H-012, September 2002

6/22/07 SLAC-I-750-0A16M-002 27


5.2.3.6 Cooling System Pipe Flushing LCW is used for cooling at SLAC and is transported through copper and aluminum pipes. Periodically these pipes, which can be of very narrow diameter, become clogged and need to be flushed or cleaned out. The CEF Department is responsible for this operation. The copper pipes are flushed with a diluted phosphoric acid solution (MC 200) at a pH of 1. The pH of the LCW itself usually runs between 4 and 5, but can be as low as 3.21

5.2.3.6.1 Assessment of the Cooling System Pipe Flushing Procedures for this operation include testing the pipes for leaks before introducing the acid. Small spills (a few gallons) can occur when the hoses are disconnected from the storage tanks that hold the spent solution before it is treated and released to the sanitary sewer. Measures are taken to contain or clean up any spilled material resulting from this operation. Neutral pH LCW used for flushing the pipes after the acid treatment is collected for discharge to the sanitary sewer.

5.2.3.7 Utilities22 Table 6: Chemicals used to service utilities

The Central Utility Building (B023) houses the campus boilers and chillers. The CEF Department also services and maintains heating, air conditioning, ventilation, and water (chilled water, LCW, High Conductivity water (HCW), hot water) systems throughout the site.

Chemicals used to service these utilities are listed in Table 6.

• Corrosion treatments • Degreasing solvents • Cleaning solutions • Lube oils

5.2.3.7.1 Assessment of Utilities

Releases of treated water or cooling fluids from pipe or valve breaks are the most common threats to stormwater. Many of these systems service mission critical activities and are closely monitored. Pressure or temperature deviations result in immediate investigation for cause.

5.2.3.8 Transportation and Craft Shops Table 7: Chemicals used at the Crafts Shop and Transportation

Routine vehicle maintenance activities including steam cleaning, refueling, fluid replacement, and vehicle repair are conducted at SLAC Transportation (B081). Spent oil and other spent fluids such as transmission oil, anti-freeze, brake fluid, and oily rags are stored in WAA # 1, which is a secured chemical shed with built-in secondary containment. Steam cleaning effluent is collected, treated in an oil-water seperator, and discharged to the sanitary sewer. Chemicals used in the transportation department are listed in Table 7.

Crafts Shop (B35) Transportation Department (B81)

Oil and water based paintsLacquer thinners Adhesives

Gasoline New and spent motor oil Hydraulic Fluids Solvents Anti-freeze

21 Information was from interviews with maintenance crews and vendor that supplies water treatment cartridges. 22 More information on utilities can be found at http://www.slac.stanford.edu/grp/ad/op/aso2_manual/utilities/Utilities.htm#II

6/22/07 SLAC-I-750-0A16M-002 28


The fueling station is outdoors. The fueling area is sloped to a gutter drain where run-off is collected in a sump, treated and discharged to the sanitary sewer. The tank is described and assessed above in Section 5.2.3.4 Above Ground Storage Tanks. Painting and carpentry shop activities occur primarily within Building 35. The carpentry shop has an air abatement device that collects saw dust and particulates that is located outside the building. Chemicals used in Building 35 are listed in Table 7.

5.2.3.8.1 Assessment of Transportation and Craft Shops The Transportation group stages vehicles outdoors in the parking lot which may result in higher oil and grease in the run-off. This is minimized by inspection of incoming vehicles for leaks prior to accepting them. All repairs are conducted inside the garage. Effluent resulting from the cleaning of equipment and vehicles is collected and treated in an oil and grease separator prior to discharge to the sanitary sewer. This is one of the two authorized locations for vehicle and equipment washing. Waste is containerized and stored in a chemical shed (WAA #1). Most of the craft shop activities occur within Building 35. The air abatement device is checked and cleaned regularly to minimize sawdust and wood particles.

5.2.3.9 Assembly and Machining Activities Much of the experimental and support equipment is designed and built at SLAC.

Table 8: Potential Pollutants: Machining, Assembly and Welding

a Wastes generated include spent cleaning solutions, waste machining oils and coolants, and metal shavings contaminated with oils.

SLAC Buildings Potential Chemicals and Wastes a Solid Metals Used

Light Fabrication Building (B25) Heavy Fabrication Building (B26) Light Assembly Building (B30)

Cutting, hydraulic, and motor oils Lube greases Epoxy adhesives 1,1,1-trichloroethane perchloroethylene isopropanol petroleum distillates

Copper Brass Steel Stainless Steel Titanium Aluminum

Welding, sheet metal work, vacuum assembly, precision machining and assembly, electromagnet fabrication, leak testing and bake out services are provided to support the research at the facility. Most of these activities occur in the support areas of the site within Buildings 25, 26, 31, and 40. Occasionally there are outdoor fabrication activities. Table 8 lists potential stormwater pollutants associated with these activities.

5.2.3.9.1 Assessment of Machining and Assembly Activities The potential impact to stormwater is primarily from the outdoor collection and storage of metal scrap and fines. Metal fines are collected in a baghouse at Building 29 and scrap metal is collected outdoors in covered drums between Building 25 and 29 before being sent to salvage operations for recycling. Areas are swept frequently and precautions are taken to protect near by stormdrains. Equipment staged outdoors is kept under overhangs or roofs to minimize oil and grease contamination. Guidance has been developed to ensure that machine shop mop water is properly disposed.

6/22/07 SLAC-I-750-0A16M-002 29


5.2.3.10 Material Handling and Storage Materials are handled and stored site wide. The General Permit defines “material handling activities” as storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste product. The following descriptions cover specific and general material handling operations at SLAC.

5.2.3.10.1 Stores and Shipping and Receiving Area SLAC has General and Metal Stores that keep inventories of new materials and products on site. General Stores, located in Building 81, keeps an inventory of non-chemical materials including stormwater protection supplies, spill response equipment, signs, personal protective equipment, bottles, hardware, and replacement parts. It does not include any chemicals because SLAC has made it a policy that all chemical purchases must come through the CMS. Metals Stores (B029) maintains an inventory of selected raw and intermediate metal material to support the metal fabrication services at SLAC. The Metal Stores has both an indoor and outdoor area for storage. SLAC’s Shipping and Receiving Area is located at Building 81. It includes a loading and unloading dock that receives and ships materials and equipment. Material may be temporarily staged outdoors in the parking lot before pick-up or distribution. Forklifts are commonly used in this area. Any chemicals that are received are stored indoors in original manufacturer containers awaiting distribution.

5.2.3.10.2 Hazardous Waste Storage Area and Waste Accumulation Areas Hazardous waste is accumulated for up to 90 days at the HWSA, before being shipped off-site. The HWSA has controlled access and is fenced, locked, and surrounded by a 10-inch berm. In addition, the HWSA is roofed to reduce rainwater intrusion. The HWSA contains several bays, separated by berms, which slope into blind sumps. This prevents mixing of spills from incompatible wastes. No water is released from the sumps until the HWSA has been inspected for spills or leaks and the water has been analyzed. Following analysis, uncontaminated water is typically disposed of in the sanitary sewer. A small quantity of chemicals is stored in a shed outside of the HWSA. Personnel from the Waste Management (WM) Department inspect the area at least four times per week. In addition, SLAC Security patrols the area on a routine basis.

6/22/07 SLAC-I-750-0A16M-002 30


Table9: Waste Accumulation Areas (WAA) 23

There are nine WAA at SLAC (Table 9). These areas are located near chemical-use areas and are for temporary accumulation of waste until transfer to the HWSA. Most are chemical sheds with built in secondary containment. WAA #10 is a fenced area with a berm and overhang. All WAAs

are protected from stormwater.

W.A.A.# Building # Building Name Map Grid Location

1 81 General Services 26E

2 35 Plant Maintenance Shop/Paint Shop

27E

3 4001,4002, 4003

Plating Shop 29E

4 4029 Light Fab. Bldg./Machine Shop 29E

5 38 MFDF (Plating) 29E

8 44 Test Lab 30D

10 CT-1701 Cooling Tower (N.E.) 33F

13 81 Casting Pad Maintenance Shelter

26E

16 40 Central Lab (MFD)/ CL-157

31D

5.2.3.10.3 Radioactive Material Storage Yard (RAMSY) and the Radioactive Waste Storage Area (RWSA)

SLAC stores radioactive waste for the time needed to prepare the waste for treatment or disposal. Waste produced by generators is transferred to these storage areas to be prepared for shipment and final treatment or disposal. An electronic inventory system tracks the storage time. Newly generated radioactive waste may be stored for up to 18 months. The RAMSY is an outdoor, bermed area that contains a partially enclosed building (B450), and an area that is secured by a perimeter fence. Excess material may be stored in the area adjacent to the RAMSY. Items that have rusted or may be mobilized by rain or wind are covered. The RWSA (B478) is an enclosed building with large roll-up doors to allow easy movement of large items. Procedures for handling and storing this material are detailed in the Radioactive Waste Manual (SLAC-1-780-2A087-001-R001). 24

5.2.3.10.4 Chemical Receiving and Storage Areas All hazardous material shipments are managed through a CMS provider. Delivery locations and storage areas are documented and on the CMS web site.25 Outdoor storage of chemicals, other than in above ground tanks (discussed earlier), is limited to chemical cabinets containing small quantities that would be contained if spilled. Chemicals are delivered in their original DOT-approved containers.

5.2.3.10.5 Outdoor Storage Areas Outdoor storage areas, not discussed specifically above, are listed in Table 10. They include raw materials, salvage operations, metals moratorium holding areas, staging areas

23 Note: WAA #s 6, 7, 9, 11, 12, 14, and 15 have been closed.24 http://www-group.slac.stanford.edu/esh/documents/RWM.pdf 25 http://www-group.slac.stanford.edu/esh/departments_groups/chemical_general_safety/cms/

6/22/07 SLAC-I-750-0A16M-002 31


for non-hazardous waste and recyclables, and storage of reusable or excess equipment and materials.

Table 10: Outdoor Storage Areas

Outside Storage Areas Category Type of Materials Surface Cover

Upper Salvage Yard Salvage Scrap metal, salvaged equipment Paved Partial – sheds

Lower Salvage Yard Salvage Scrap metal, salvaged equipment Paved Partial- shed/ building some covered bins

Sec. 0 - south Moratorium Metals Holding Moratorium Metal Gravel bed None

B081/B035 parking lot Equipment Staging Forklifts, government vehicles Paved None

B029 Metal Stores Raw Materials Piping, metal Paved None

Research Yard Equipment Staging Forklifts, cranes and rigging equipment Paved Partial- some overhangs

SSRL storage Yard -Beam Line and B120

Waste, Excess and Reusable

Scrap metal collection, equipment, building materials Paved Partial- some overhangs

B750 parking lot Staging Class II waste, excess equipment Paved None

B630 parking lot Moratorium Metals Holding Moratorium Metal Paved Partial- shed, storage

boxes

South Adit Entrance Area

Moratorium Metals Holding Moratorium Metal Paved None

North Adit Entrance Area Reusable Shielding Paved None

Recycling Yard Trash, Recyclables Wood, cardboard, trash, Misc. Gravel Covered bins

IR-4 parking lot Reusable, Stockpiled Shielding, equipment Paved none

IR-2 parking lot Raw Material Piping Paved None

IR-12 parking lot Raw Material, Final Products

Piping, metal(bricks, sheet), experimental equipment Paved None

IR-8 parking lot and dock Reusable Shielding , experimental equipment Paved Partial- Tarps

Bone Yard Stockpiled Concrete blocks, shielding Unpaved none

Under 280 overpass Raw Materials Cables, pipes, trays Partially paved Roofed (by overpass)

BSY Raw Material Building material Partially paved none

Magnet Yard Waste, Excess and Reusable

Concrete blocks, shielding, building material Paved Partial - Tarps

Sand Box Raw, Reusable and Building Materials

Excess building materials and equipment Unpaved None

Along south side of Linac Excess and Reusable Concrete blocks, shielding Partially

paved None

Sector 16 Excess and Reusable Pipes, corrugated metal sheeting, fiberglass, excess equipment Paved None

5.2.3.10.6 Assessment of Material Handling and Storage Practices

SLAC historically has staged and stored excess material in an informal manner that has led to storage areas without defined owners. Although most of this material is not a threat to stormwater, SLAC has developed a policy that includes criteria for what types of materials should be kept. In addition, management is assigning ownership to all areas at SLAC with responsibilities for managing outdoor storage consistent with BMPs.

6/22/07 SLAC-I-750-0A16M-002 32


Potential stormwater pollutants are materials that can be mobilized or dissolved by rain or wind. Small particles such as paint chips, rust, lead wool, pencil lead, or small activated materials are the primary stormwater management focus. Soil and debris piles from maintenance or construction activities are covered to minimize mobilization while being staged for disposal. Mercury switches or oil must be removed from excess or salvage material before staged outdoors. Copper piping is covered and any metal fines, especially when contaminated with cutting fluids, are managed in covered containers. Tarps themselves can be sources of debris as they degrade due to UV light exposure. Tarps used to cover material are UV resistant and replaced if deterioration is noted.

5.2.3.11 Dust and Particulate Generating Activities Dust and particulate generating activities at SLAC include wood and metal cutting and grinding, plasma-arc welding, sandblasting, and diesel generator operations. These activities are listed in Table 11 and identified on the SWPPP Map. Other potential particulate and dust air emission sources at SLAC include ovens, furnaces, plating operations, sludge drying, and laboratory fume hoods.

5.2.3.11.1 Assessment of Dust and Particulate Generating Activities Air emissions from dust and particulate generating activities are captured in abatement devices including filters and bag houses. The areas around the abatement devices are inspected and cleaned regularly to prevent stormwater contamination. Deposits from laboratory hoods, plating operations, and sludge drying have not been detected to date and are not a significant source of storm water pollution. The ovens and furnaces are used for drying and off-gassing and do not generate particulate or dust emissions.

Table 11: Dust and Particulate Generating Activities Activity Quantity Buildings

/Locations Descriptions

Laboratory and Bake-out Ovens

27 26, 25, 44, 40, 34, 233, 4081, 112, 31, 24

Thirteen are located in B044. Used for off-gassing, drying and heating. Range from small low heat (180 deg C) to larger higher heating units up to 1000 deg C.

Furnaces 40 25,44, 120, 123,62,107, SSRL complex

Fourteen are located within the SSRL complex. Twelve are located in B040. They range from bench top laboratory furnaces to a large electrically heated, retort-type pit furnace.26 They are used for a range of applications including brazing, annealing, scattering, and tempering metal parts as well as more typical laboratory applications.

Air Scrubbers 4 25, 38 Three scrubbers servicing the plating operation, one for the sludge dryer at the MFPF

Air Emissions Filter and Bag Houses

4 29, 24, 35, 25, 26

Bag houses collect metal fines and sawdust. Filter and collection drum is used for plasma arc cutting torch operation.

26 http://www.slac.stanford.edu/cgi-wrap/getdoc/slac-pub-0110.pdf

6/22/07 SLAC-I-750-0A16M-002 33


Activity Quantity Buildings /Locations

Descriptions

Laboratory Fume Hoods

24 6,24, 25, 26, 33, 40, 44, 107, 120, 131, 137

Eleven fume hoods are located in the SSRL complex (B120, B130, and B137). Hoods are used for laboratory applications.

Diesel Generators

10 18, 756, 505, 7, 686, 23, 706

Used for back-up emergency power.

5.2.3.12 Construction Activities There are numerous construction activities and projects both large and small that occur at SLAC. Projects equal to or larger than one acre must have a project specific SWPPP detailing how BMPs will be implemented. Smaller projects must use BMPs outlined in this plan. Construction projects have many aspects that must be managed to protect stormwater including: power washing, paint removal and application, demolition, excavation, equipment and vehicle management, metal cutting and welding, removal of asbestos-containing material, concrete management and use, dust control, and materials storage.

5.2.3.12.1 Assessment of Construction Activities Construction projects vary as does the risk they pose to stormwater. In addition to storage and materials management construction projects may need to manage:

1. Concrete pouring operations: Run-off from concrete-pouring operations as well as tool and equipment wash-water from concrete pouring and slurry from concrete-cutting operations are not discharged to the storm drain system.

2. Grading activities: Soil erosion from grading activities and debris from construction activities are controlled and minimized to prevent particulates and other contaminants from entering the storm drain system.

3. Excavation: Rainwater that is collected in excavations is managed to minimize sediment entering the storm drain.

4. Soil piles: Piles are covered.

5.2.3.13 Fertilizers, Pesticide or Herbicide Application Pesticides and herbicides are occasionally used on-site by contracted certified landscaping firms. Application practices are designed to ensure that chemicals are not mobilized by stormwater run-off. Efforts have been made to explore landscaping with native plants to further minimize the need to use fertilizers, pesticides and herbicides.

5.2.3.13.1 Assessment of Fertilizers, Pesticide or Herbicide Applications These materials are not present in significant quantities in stormwater run-off.

5.2.3.14 Traffic, Parking and Roadways Employee and visitor parking lots are not industrial activities; however, run-off from these areas can commingle with stormwater run-off from areas of industrial activities. The parking lots may be a source of pollutants in the stormwater discharged from SLAC due to minor leaks of fluids associated with normal vehicle operation. Potential pollutants in parking lot stormwater run-off are:

6/22/07 SLAC-I-750-0A16M-002 34


• Motor oil • Lube grease • Trace heavy metals • Organic compounds from anti-freeze and brake fluid • Asphalt leachate

Asphalt and concrete curbs are used in parking areas and roads where drainage control is necessary. For parking areas and roads without curbs, roadside ditches are used for drain-age control. Highway 280 passes over the Linac at Sector 25. This structure is owned by the State of California and operated by CalTrans. Some run-off from the overpass drains into SLAC. Potential contaminants in stormwater run-off coming from the highway are similar to those described above for on site parking lots, with the addition of silt and sediment.

5.2.3.14.1 Assessment of Traffic, Parking and Roadways Sediment sampled from parking lots and roadways has been found to contain trace PCBs and lead in addition to more typical contaminants listed above. Streetsweeping activities occur frequently in selected areas. Site wide streetsweeping occurs at least annually prior to each wet season.

5.2.3.15 Soil Erosion and Sediment Much of the topography of SLAC is the result of cut and fill construction methods. This has resulted in many steep slopes that are prone to erosion. Mud slides and hillside slumping, channel erosion and bank destabilization occur during the wet season and are monitored. SLAC uses plantings, hydro-seeding, retaining walls, and geotextiles to reduce erosion. Contract hydrologists and engineers are employed to manage the more complicated projects and work closely with neighbors and regulatory agencies to generate solutions that protect the environment and SLAC property. Sediment management is required for soil that is washed onto roadways and paved areas. Low levels of PCB and lead are found in the sediment from a variety of areas on site and cannot be correlated with current activities or specific areas. All excavated material and sediment and debris collected during street sweeping is profiled and disposed at an appropriate facility. Remediation activities are conducted under RWQCB Order No. R2-2005-0022.

5.2.3.15.1 Assessment of Soil Erosion and Sediment Sources The sediment sources at SLAC are similar to other undeveloped areas in the region. The additional risk comes from low levels of PCB and metals that may become mobilized with the sediment.

5.2.3.16 List of Significant Spills Appendix H lists significant spills that have occurred at SLAC since April 17, 1994. Information presented includes the date of the spill, the type and quantity of material spilled, the location of the spill, and corrective actions taken. The spills are of two main types: spills of water with low levels of stormwater contaminants such as overflows of cooling tower water, sanitary sewage, LCW; and spills of more concentrated chemicals such as small releases of fuels from portable containers and vehicles, leaks of transformer oil, and other chemical spills.

6/22/07 SLAC-I-750-0A16M-002 35


No spills have exceeded SARA reportable quantities. No significant impacts to surface or ground water have resulted from any spill since April 1994.

5.2.4 ESTIMATE OF POTENTIAL POLLUTANTS IN STORMWATER RUN-OFF As described above, SLAC maintains a list of the chemicals found on site. SLAC implements best management practices designed to eliminate and minimize pollutants to minimize the quantities of pollutants found in stormwater. Management and operating practices at SLAC minimize possible contact between pollutants and stormwater run-off. Most buildings are entirely enclosed and, where warranted by chemical-use operations, are designed with effective waste handling systems. These factors, coupled with management practices (including clean-shop policies and well defined spill prevention and response procedures), isolate the potential pollutants associated with these areas from stormwater runoff. No significant quantities of potential pollutants from these areas are likely to be present in stormwater run-off. Pollutants which have the potential to be present in stormwater because of outdoor use and outdoor storage are: • Trace metals and metal particulates • Motor oil and asphalt leachate • Antifreeze • Hydraulic oil/brake fluid • PCB • Transformer insulating oil • Cooling tower chemicals

Sampling to-date has shown a few constituents are consistently above EPA benchmark values. Specific conductivity is elevated in areas because of groundwater discharged to the stormwater system via tunnel subdrains (discussed in section 3.3.6). A natural source of metals has been detected at the Linac underdrain sump at Sector 20 from the low pH of the groundwater as a result of the geology in that area. The acidic groundwater in this area leaches naturally occurring metals from the surrounding clays before being captured in the underdrain system. This is managed by periodic pumping of these sumps after IR-8 sampling results indicate that metal, especially aluminum, concentrations are rising. Zinc concentrations are frequently elevated. The source may be the presence of zinc in building materials, storm drain piping and naturally occurring in the soils. Elevated zinc concentrations have also been detected in background samples of the receiving water within San Francisquito and Bear Creeks.

5.3 Stormwater Best Management Practices

5.3.1 NON-STRUCTURAL SOURCE CONTROLS AND MANAGEMENT PRACTICES The purpose of this section is to identify administrative and non-structural best management practices (BMP) to minimize exposure of pollutants to stormwater. SLAC BMPs are listed under activity headings in Appendix I. The industrial activity areas, potential pollutants, and applicable BMPs or other controls are described in Table B, included in this document as Appendix G. These practices are summarized below.

6/22/07 SLAC-I-750-0A16M-002 36


5.3.1.1 Equipment Maintenance and Cleaning Procedures are in place to ensure that equipment is working properly to minimize potential contact between stormwater run-off and materials and wastes associated with maintenance and cleaning activities. These procedures are available as part of individual department SOPs, which are incorporated by reference into this SWPPP.

5.3.1.2 Waste Collection, Recycling, and Disposal Practices Waste handling practices used to minimize potential contact between wastes and stormwater run-off, and methods of storing waste prior to removal for off-site disposal or recycling, are described in the individual department SOPs, and the BMP document.

5.3.1.3 Spill Prevention and Response Activities Specific information on preventing and responding to spills is provided in the ES&H Manual (Chapter 16, Spills), Consolidated Chemical Contingency Plan, SPCC Plan, and SOPs for individual departments. Chemical handling, specifically liquids and bulk dry chemicals, is performed in a manner that minimizes the potential for spills and leaks. Consequently, the potential for contact between pollutants and stormwater is minimized. Spill procedures are summarized below. Loading and unloading of liquids and dry bulk materials are overseen by SLAC per-sonnel or subcontractors. This provides detection of accidental spills, ruptures, or leaks in vendor packaging or chemical containers, or in SLAC containers into which bulk chemi-cals are being transferred (generally tanks). In the case of a spill, SLAC and subcontractor personnel isolate the spill immediately if it is safe to do so. The spill is bermed by loose absorbent materials or absorbent pads to prevent contact with nearby storm drains or trenches. Pathways to storm drains and storm drain inlets are closed or diverted, using such materials as gel-filled plastic mats, plastic sheeting, and sandbags. All spills are reported and documented, according to Chapter 16. This includes recording the spill information in the Basic Incident Information Database27 and reporting to regulatory agencies when necessary. Spill-prevention procedures involve proper handling of raw material and waste. Spills are cleaned-up promptly and are not allowed to dry or evaporate in place. Response procedures for minor, indoor spills follow dry clean-up procedures. Small spills are wiped up using a dry shop rag. Used shop rags are disposed of appropriately, either as non-hazardous or hazardous waste, depending on the chemical involved. Spills too large to wipe up are contained as soon as possible. Liquids are soaked up with a dry absorbent such as loose bentonite clay granules or an absorbent sock. The used absorbent is swept up and properly disposed. If the spill is not secondarily contained and has the possibility to flow to a storm drain, storm drain inlets are temporarily plugged, as described above, and the spill bermed.

5.3.1.4 Preventive Maintenance and Good Housekeeping SOPs for individual departments include maintenance procedures. Records of maintenance activities are completed and maintained by the responsible department. BMPs include maintenance activities.

27 V:\ESH\CGS\Basic Incident Information (BII) Database\BII_v1_2.mdb

6/22/07 SLAC-I-750-0A16M-002 37


5.3.1.4.1 Storm Drain System Maintenance The storm drain system is inspected and maintained as needed. Significant obstructions or debris observed during inspections are removed by the area manager or the CEF Department. Spilled or leaked materials that could be transported by stormwater are also removed and the leak source is repaired. Accumulated sediment, leaves, and other debris are removed from trenches and culverts annually during the dry season to ensure the system is in proper working order before the rainy season begins.

5.3.1.4.2 Equipment Maintenance Equipment maintenance schedules ensure that equipment operates correctly to minimize spills and leaks. Schedules for maintaining equipment are set according to equipment manufacturer specifications. Additional maintenance is conducted as needed. Maintenance of outdoor equipment includes maintenance of the surface beneath the equipment, usually a concrete pad. A drip pan or catchment is used whenever maintenance procedures may result in leaks or spills. Equipment prone to small, on-going leaks (such as vacuum pumps and other oil-lubricated machinery) has permanently mounted pans or absorbent material spread beneath the unit to contain the leaks. This equipment is routinely checked for accumulation of leaks.

5.3.1.4.3 Vehicle Maintenance Regularly scheduled vehicle maintenance is performed at the transportation area in B081. Drips and spills in this area are collected and disposed of in accordance with the procedures described in Section 5.2.1. Vehicles are regularly cleaned at the steam-cleaning areas. Wash water from the steam-cleaning process is collected and discharged to the sanitary sewer system, after passing through an oil/water separator. Vehicle motors are steam-cleaned as necessary. Motor oil and other lubrication and coolant fluids are collected in pans and transferred into waste accumulation drums in the transportation area (WAA # 2).

5.3.1.4.4 Landscape Maintenance Landscape maintenance is performed weekly. Fertilizers and pesticides are used as necessary. When chemicals are used, manufacturers' instructions are followed and the minimum quantity needed is used. Table 12: Housekeeping Schedule for Outdoor Areas near Buildings

General housekeeping and cleaning activities are performed daily. Floors are swept and solid wastes collected, separated,

and disposed of properly, or stored in a designated area for pickup by a recycler. Outdoor paved areas are swept clear of debris and dirt on a regular basis (See Table 12). Hosing with water is not used as a substitute for sweeping. Construction and remediation project sites are cleaned and tools are stored at the end of each day. Steps to reduce sediment and pollutant transport are taken if rain is forecast.

Task # Description Frequency1 Empty Trash Within 15 Ft of Entrances 5 x Week

31 Sweep / Blow Within 15 Ft of Entrances 1 x Week

32 Sweep / Blow Within 15 Ft of Dumpsters 1 x Week

33 Sweep / Blow Exterior Stairwells 1 x Month

34 Sweep / Blow Stairs, Landing, Porches 2 x Month

35 Sweep / Blow Main Quad Arcades 1 x Week

5.3.1.5 Sediment and Erosion Control Most slopes are sufficiently stabilized with natural vegetation such that no significant erosion is occurring. SLAC has identified areas with significant erosion potential and

6/22/07 SLAC-I-750-0A16M-002 38


stabilized these areas where practicable (See Appendix D SWPPP Map). Hillsides are monitored for signs of erosion. SLAC has implemented an annual street sweeping program to remove sediment from the roadways before the start of the rainy season. Sediment is removed during the rainy season when necessary.

5.3.1.6 Employee Training Training is required for personnel responsible for implementing the SWPPP to address spill response, good housekeeping, and material management practices. The ES&H Division is responsible for training personnel in proper management of hazardous material and waste. The SLAC Training Assessment (STA) is used to identify personnel who, because of job class or work function, require Stormwater Awareness Training and annual hazardous waste and material management training.

5.3.2 STORMWATER STRUCTURAL SOURCE CONTROLS This section describes structural source control information and facility management practices. Structural controls refer to the permanent structures used for potential pollutant containment and isolation. The structures are described below. Structural modifications planned or under construction are also described.

5.3.2.1 Isolation of Storm Drain from Sanitary Sewer The SLAC storm drain and sanitary sewer exist as two separate systems. Since implementation of the SWPPP in 1992, SLAC has identified illicit connections, rerouted non-authorized discharges, and achieved isolation of the storm drain from the sanitary sewer system. This work is ongoing as new illicit connections are discovered.

5.3.2.2 Reduced Exposure of Potential Pollutants Materials or areas are roofed or bermed, as feasible, to minimize exposure to potential pollutants. Specific areas are described below.

5.3.2.2.1 Transformers Most outdoor liquid-filled transformers with capacities greater than 100 gallons are surrounded by containment berms or basins, typically constructed of concrete. The containment basins have adequate containment for 110% or more of the transformer liquid volume. Some of these transformers are covered by roofs or other shelters to keep rainwater from accumulating in the containment structures.

5.3.2.2.2 Chemical Storage Areas Containerized wastes are stored in the fenced HWSA. This area is surrounded by a 10-inch-high berm, and has a roof to prevent rainwater from entering the area. The entire area is sloped so that liquid contacting the floor runs into “blind” sumps (each sump is not connected to the storm drain or sanitary sewer, so liquid in the sump must be manually pumped-out for testing and disposal). Most WAAs are chemical sheds with secondary containment. Bulk chemicals for the Plating Shop are stored inside the Chemical Storage Building (B36), which is surrounded by a berm, or B499 which is a roofed, three walled structure which is bermed at the entrance. Bulk chemical storage at the Cooling Towers is within chemical sheds with built-in secondary containment.

6/22/07 SLAC-I-750-0A16M-002 39


5.3.2.2.3 Treatment Facilities The MFPF, LCW plant, and groundwater treatment facilities are roofed and surrounded by berms. They also have leak detection alarms.

5.3.2.3 Separation and Structural Isolation of Wastes This section identifies structures used to separate and isolate wastes in each area of the site, including sumps and tanks used to collect or store wastes prior to recycling or disposal.

5.3.2.3.1 Sump Pumps and Lift Stations Sump pumps are located in structures below grade (such as the Linac, PEP, and SLC tunnels). The sumps are designed to collect groundwater and small amounts of rainwater which have seeped into the tunnels. They have been covered, bermed, and hard-plumbed to the sanitary sewer. Most of the sumps pump water to holding tanks, where the water is checked for radioactivity before discharge to the sanitary sewer.

5.3.2.3.2 Master Substation The drainage area around the Mater Substation has been designed to divert all run-on to minimize potential exposure to pollutants. Rainwater within the substation collects in a blind sump where it evaporates or is pumped, treated and used as make-up water in CT 1701.

5.3.2.4 Sediment Traps Numerous sediment traps have been incorporated into the storm drain system. These traps slow down the velocity of the run-off allowing sediment and particulates to drop-out of suspension. The traps are cleaned at least annually during the dry season. Traps are located near Sector 30, at the Oak Swale in the CEF storage yard, near the building materials storage area of the CEF storage yard, and downstream of IR-2 near B736.

5.3.3 ANNUAL COMPREHENSIVE SITE COMPLIANCE EVALUATION AND INSPECTION PROGRAM

An annual site-wide compliance evaluation program for stormwater discharge issues was instituted in 1992 as part of the SWPPP Monitoring Plan. The program involves an annual inspection, assessment of the effectiveness of BMPs, review of potential pollutant sources, and review of stormwater analytical and visual monitoring data. The monitoring program is described in Appendix F. As required by the permit, SLAC visually inspects all significant non-stormwater discharge locations on a quarterly basis for the presence of any discoloration, stains, odors, or floating material. Non-stormwater discharges include fire hydrant flushing, air conditioner and compressor condensate, irrigation drainage, testing of potable water sources and emergency showers, groundwater, and foundation and footing drainage. Stormwater discharges are visually observed for the same indica-tors during one storm event each month during the rainy season (October 1 - May 30) at locations where the discharges leave the SLAC site. New construction is inspected to identify areas where run-off and sediments may create a problem. Containment and equipment locations are also reviewed in the design phase. Buildings and storage areas are inspected periodically for proper storage procedures. Maintenance procedures and records are also inspected periodically. Training is provided to employees identified through the SLAC Training Assessment (STA). Included in the training curriculum are elements of self-inspection and audits to ensure proper management practices and compliance.

6/22/07 SLAC-I-750-0A16M-002 40


5.3.4 RECORDKEEPING AND REPORTING Recordkeeping for the stormwater program is maintained by the Stormwater Program Manager in EP and consists of storm water monitoring analytical results, logs of visual observations, and logs of annual inspections and evaluations. The annual stormwater report is submitted to the Regional Water Quality Control Board each July 1st. The annual stormwater report is described in the SWPPP Monitoring Plan in Appendix F. All records pertaining to the Storm Water Monitoring Program will be kept for a period of at least five years from the date of the sample observation, measurement, evaluation, or report. The SWPPP will be readily available for review by SLAC employees and Regional Water Quality Inspectors. It will be available to the public on request.

6/22/07 SLAC-I-750-0A16M-002 41

Documents

Storm Water Pollution Prevention · Stormwater Pollution Prevention Plan 2 SWPPP AMENDMENTS This Storm Water Pollution Prevention Plan (SWPPP) shall be amended: • Whenever there