Sampling FAQ’s

pH Test Procedure

What do I do with this strip booklet?
The pH strip booklet you received as a part of your sampling kit is used to measure the pH of your stormwater. Rip out one strip from the booklet and dip it in the stormwater for 3 seconds. The color of the strip will change. Compare this color to the colors on the inside cover of the booklet and write down the matching color’s number, which is the pH of the water on your Chain of Custody. The pH limit is 6-9 pH units.

What do I do with pH strips that were in an envelope?
If you also have a booklet, discard the strips in the envelope and use instructions on the booklet or found in the question above. If you only have the envelope pH strips, take one pH strip and dip into discharge water for 3 seconds, so all color zones are immersed. Compare the indicator zone (middle unprinted area) to the color scale and find which printed number value it most closely matches. Write down the matching color’s number on your Chain of Custody. The pH limit for the Water Board is 6-9 pH units.

Which bottle do I test the pH from?
The pH test should be performed in the flowing water on the ground by the Discharge Point where the storm water lab sample is collected. If you did not test for pH when you filled the bottles and water is no longer flowing, you can test for pH from any of the sample kit bottles.

Sampling Requirements

I sampled last week/month, do I need to sample again?
If you are a part of a Brash compliance group, you are required to sample once between July and December, and once more between January and June. If you are not a part of a Brash compliance group, you are required to sample twice during July and December, and an additional two times during January and June.

Do I need to sample if the rain started last night or over the weekend?
Yes. If rain began overnight or during the weekend, you have 4 hours from the time you open your facility to collect a sample if there is still a stormwater discharge from your site. If it rained overnight or over the weekend and there is no stormwater discharge from your site when you open, then you do not need to collect a sample. Please make a note of this in your workbook’s calendar and/or inspection tables.

I’m in Level 1 and/or 2, do I need to sample?
Yes. Level 1 and/or 2 status does not affect the number of samples required each storm season.

I didn’t collect a sample when it rained because there was no discharge, is this ok?
If there was no stormwater discharge during operating hours, please make a note of this in your workbook and let us know. We will include this information on your annual report.

Sampling Procedures

Where do I collect the sample?
Your chain of custody should have your sampling location listed under “Sample Description”. You can also find the location on your site map which is labeled “Discharge Point”. The discharge point should be where the stormwater is leaving your site. If this is different from what your Chain of Custody or map shows, please contact us so we can make the appropriate changes.

Do I need to fill out the Chain of Custody?
Yes. Please fill out the following items which should be highlighted or circled on your Chain of Custody:

• Date Sampled
• Time Sampled
• Sampled by: Name of person who collected the sample
• pH: Circle “Field” and write down the pH reading you obtained from the pH strip
• Customer and Address (if not already filled in)
• Sample Description/Discharge Point Location (if not already filled in): This is the location where you collected your sample from (i.e. front gate, back fence, etc.)

Do I need to fill up all the bottles?
Yes. Start by filling up the biggest bottles and then move on to the smaller bottles. Make sure you fill them up.

What if I don’t have enough water to fill up all the bottles?
If you don’t have enough water to fill up all the bottles, then do not collect a sample and wait until there is enough discharge to collect a sample on the same day. If you still cannot collect a sample due to no discharge, write this down in your workbook and let us know so we may include this information in your annual report if needed.
If there is a lot of water running off but it’s taking too long to collect a sample or there is sheet flow, use a clean new plastic folder sleeve or zip lock bag to collect the sample. Set the plastic sleeve/bag flat on the ground just low enough to allow water to get in, open the sleeve/bag to allow flow of water and then use this to transfer it to the bottles. Please note that this is not an approved sample collection method by the Regional Water Boards.

My neighbor’s stormwater is flowing onto my yard/driveway where I sample, do I still need to sample the stormwater?
Yes, you are to collect a sample even if you have run-on water commingling with yours. You can use a boom to deflect your neighbor’s stormwater away from your stormwater discharge. Please contact us so we can make a note of the run-on water on your SWPPP and Site Map.

Sample Pick Up

I collected a sample, when can you pick it up?
Brash does not pick up your stormwater samples. Instead, our subcontracted lab has a designated team of couriers to ensure your samples get picked up. Please call (818) 639-5307 to schedule a pick-up. If you have a bacteria sample, please mention this to the person on the sample pick-up hotline to ensure you sample gets picked up within 8 hrs.

Who do I call for pick up?
Please call the laboratory’s sample pick-up hotline at (818) 639-5307 to schedule a pick up.

What do I need to do with my sample in the meantime?
Ensure your Chain of Custody is filled out, bottles are labeled with your business name and any other information as listed on the sample instructions in your workbook, and keep the bottles in the refrigerator (DO NOT FREEZE).

What do I do once the courier arrives to pick up the samples?
Sign the box at the bottom of the Chain of Custody that says, “Relinquished By” and the courier will sign “Received By”. Have the courier give you the yellow copy of the Chain of Custody for your records and place it in your Workbook Binder provided by Brash.

My samples have not been picked up, what should I do?
If you scheduled a sample pick-up with the laboratory, please allow 2-3 days for the lab to pick up your samples. If they do not pick them up after 3 days, please contact us as soon as possible so we may assist you.

Uncategorized

Comments to the Industrial General Permit Amendment

Brash Industries (BI) represents more than 250 auto recyclers (SIC Code 5015) and 100 scrap recyclers (SIC Code 5093) and is the Compliance Group Leader for Compliance Groups for the afore mentioned SIC Codes. BI serves the needs of small to mid-size Permittees. BI works closely with the 5015 Permittees and represents their trade associations; California Auto Dismantling and Recyclers Alliance (CADRA), Automotive Dismantlers Association of Southern California, (ADASC), Inland Automotive Dismantlers Association (IADA), San Diego County Auto Recyclers Association (SDCARA), and Valley Auto Dismantlers Association (VADA). With the State issuing approximately 13,000 Industrial Permits of which approximately 1,000 Permits are issued to auto recycling facilities, Brash submitted comments in February, 2018 on the proposed amendment to represent the concerns and perspectives of a significant number of the Permittees.

Uncategorized

Industrial General Permit TMDL Amendment

The Industrial General Permit was written with a clause that enabled the Permit to be modified when the new Federal Law addressing the TMDL (Total Maximum Daily Load) requirements became effective.  The major concern is copper. If it is not in your inventory list, it is not an issue. However, if copper is on your site, then make certain that it is stored in a sealable barrel that is stored inside where it is not exposed to rain or run off.

This notice from the Waterboard is the first step in modifying the existing Permit.  Brash Industries will respond to modifications when appropriate.  Otherwise, there is nothing for you to do and we will keep you updated.

Uncategorized

Monthly Non-Storm-Water Visual Inspections

The new Permit requires monthly non-storm-water visual inspections. Inspections have been required since September, 2015. Municipal and Regional Water Board inspectors are verifying that these reports are being completed by requesting to see them.

Failure to complete these monthly inspection report forms is a Permit violation. The report form is Table 2, Monthly Non-storm Observation Log in the BI Workbook. Conduct the inspection once a month on days when it is not raining, and record the observations on the correct monthly report form.

When a storm water sample is collected, a Storm Discharge Visual Observation is to be completed. This form is Table 3, Storm Discharge Visual Observation Log Sheet in the BI Workbook.

The Table 3 Storm Discharge Visual Observation Log Sheet is used to record visual observations of the storm water being discharged from the site when a sample is collected. It needs to be completed only when a storm event sample is collected.

The absence of either of these reports could lead to the issuance of a Notice Of Violation, and a fine. It is imperative that these forms are completed and available when an inspector requests them.

 

Uncategorized