Storm Water Environmental Compliance Audit - Port of San Francisco

Client: Port of San Francisco

Prime Contractor:: URS Corporation

Location: Pier 70 Drydock Leasehold (BAE Systems San Francisco Ship Repair)

Period of Performance: August 2008

Goals: As a subcontractor to URS Corporation, ADH conducted a storm water environmental compliance audit for the Port of San Francisco at its Drydock Leasehold at Pier 70, and provided recommendations on measures to be implemented in order to be compliant with federal, state and local regulations.

Project Description:

• Perform reviews of existing storm water-related documents for the facility
• Conduct site inspections at the facility
• Evaluate the current SWPPP and BMPs
• Complete a facility audit score sheet for pertinent state and federal regulations, with recommendations for future compliance.

Facility and Regulations Review: : Review existing Storm Water Pollution Prevention Plan (SWPPP), Best Management Practices (BMP) Program Manual for Shipyard Operations, NPDES Permit, Industrial Wastewater Permit, Annual Reports to the Regional Water Quality Control Board for Storm Water Discharges Associated with Industrial Activities, past Notices of Violation and Notices to Comply, and Hydrostatic Test Records for bilge and oil transfer hoses. Review all state and federal regulations pertinent to industrial storm water discharges (Federal Code of Regulations, California Code of Regulations, and California Water Code).

Site Inspection: Conduct a two day site visit at the drydock facility for the following tasks: introductory guided tour of the entire facility; independent walk-through inspections and photo documentation; thorough evaluations of existing BMPs; identification of additional BMPs requiring implementation. Significant activities inspected included: oil and oily bilge water storage tanks, bilge and oil transfer hoses and containment, sandblasting/painting shrouding and cleanup, paint and solvents storage, generator/mechanical equipment storage, secondary containment, spill prevention and response supplies/equipment, and storm water drainage system.

Reporting: Complete compliance audit score sheets for both state and federal regulations. Provide recommendations for revision of the existing SWPPP, and recommendations regarding existing or lacking BMPs.