ITEM 3.4TPC
The Planning Company
3601 Thurston Avenue
Anoka, MN 55303
763.231.5840
TPC@PlanningCo.com
PLANNING REPORT -Addendum
TO: Otsego Planning Commission
FROM: D. Daniel Licht, AICP
REPORT DATE: 10 July 2019
ACTION DATE: NA
RE: Otsego — Insurance Auto Auctions; Sketch plan
TPC FILE: 101.01
BACKGROUND
ITEM 3.4
Insurance Auto Auctions has submitted a concept plan for development of 100 acres located
west of Kadler Avenue south of 8011 Street. The proposed use is for an auto auction facility
involving total -loss vehicles due to accidents or theft recovery. The facility includes
construction of a 9,750 square foot building and outdoor areas for vehicle drop off, load out,
and outdoor storage that would be developed in two phases. The proposed development is to
be reviewed as a sketch plan in accordance with Section 10-5-1.13 of the Subdivision Ordinance
to provide comment to the developer as to the acceptability of the land use and public
improvements required for the proposed development.
A public hearing to consider the proposed sketch plan was noticed for the Planning Commission
meeting on 1 April 2019. The developer requested that the public hearing be continued to
allow discussion with City staff regarding the application and the opportunity to provide
additional information. The Planning Commission consider the application at their meeting on
6 May 2019 at 7:00PM. The public hearing was closed and the Planning Commission tabled
discussion of the sketch plan to allow the developer to provide additional information regarding
site operations and screening. The Planning Commission will continue discussion of the sketch
plan at their meeting on 15 July 2019.
The additional information submitted includes a video of IAA sites. The video is is available on
the City Website with the Planning Commission meeting agenda.
Exhibits:
■ Site Location Map
■ IAA narrative dated February 22, 2019
■ Tetra Tech, Inc. letter dated April 4, 2019
■ IAA Environmental Best Management Practices dated February 2017
■ IAA PowerPoint Additional Requested Information
■ IAA sites video (by reference)
■ Layout plan dated 3/8/19
ANALYSIS
Comprehensive Plan. The Comprehensive Plan guides the subject site for future industrial
uses consistent with the City's economic development goal to attract, retain, and expand
business to diversify the tax base and increase employment. The proposed auto auction site
with outdoor storage would be considered to be an industrial use.
The City's growth management plans have been established to recognize that the land uses
designated on the Future Land Use Plan are to develop overtime in a staged manner
concurrent with logical extension of infrastructure. This approach maximizes utilization of
streets, utilities and other City services before making additional expenditures in expansion.
In the interim, agricultural land uses are to be maintained until such time as the criteria for
urban development have been met. These criteria include the consideration for rezoning
outlined in Section 11-3-2.F of the Zoning Ordinance for Zoning Map amendment and
conditions defining premature subdivisions outlined in 10-6-1.13 of the Subdivision Ordinance.
Zoning. The subject site is zoned A-1, Agriculture Rural Service District consistent with the
interim land use policies of the Comprehensive Plan. The future land uses guided by the
Comprehensive Plan are to be implemented under the allowed uses and performance
standards of the 1-2, General Industrial District of the Zoning Ordinance.
The proposed auto auction use involves the wholesale resale of used damaged vehicles
determined to be total loss by an insurance company with outdoor areas for drop off, load out,
and storage. Section 11-86-2.13 of the Zoning Ordinance allows wholesale businesses within the
1-2 District as a permitted use. Open and outdoor storage is allowed as an interim use within
the 1-2 District subject to the performance standards of 11-86-3.0 of the Zoning Ordinance.
The proposed development would require application for a Zoning Map amendment to rezone
the subject site from A-1 District to 1-2 District based upon (but not limited to) the criteria
established by Section 11-3-2.F of the Zoning Ordinance. Application for an interim use permit
is required to allow the proposed outdoor storage element of the facility subject to (but not
limited to) the criteria established by Section 11-4-2.F of the Zoning Ordinance As an interim
use, the outdoor storage can be allowed conditioned upon a termination date as provided for in
Section 11-5-4 of the Zoning Ordinance:
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A. The date or event stated in the interim use permit.
B. Upon violation of conditions under which the interim use permit was issued.
C. Upon change in the City's zoning regulations that renders the use nonconforming.
D. The redevelopment of the use and property upon which it is located to a permitted or
conditional use as allowed within the respective zoning district.
The IAA narrative describes the tax and employment benefits of the proposed use. While
adding tax base and jobs to the City is positive from an economic development standpoint, the
scale of the benefits of the proposed use are not significant in context with the area of the
subject site. The proposed use should be viewed as interim from the standpoint that it is
appropriate at this point in time given the (limited) extent of industrial demand but should be
phased out overtime as such demand increases.
City staff initially recommended that approval of an interim use permit would be conditioned
on a termination date not more than 20 years from the date of approval. The recommended
20 year term of the interim use permit was based upon recognizing that IAA will be required to
invest substantially to improve Kadler Avenue that will benefit other adjacent properties guided
for industrial use that may spur additional development, providing for a limited deferment of
sewer and water availability charges, and ultimately providing for a redevelopment of the
property that will bring increase employment opportunity and generate higher property tax
revenue. IAA is requesting a longer term for the interim use permit. To this end, IAA has
suggested to pay -in -full utility availability charges for the entire site upon approval of an interim
use permit in consideration of the interim use permit term being at 35 years corresponding to
the life expectancy of Kadler Avenue that they will be paying to build.
A termination date established with approval of an interim use permit requires that the allowed
use cease upon the stated date (or event) approved by the City Council. This would require
removal of all outdoor storage. A request for another form of outdoor storage or for extension
of the vehicle storage use would be processed in the same manner as a request for the initial
interim use permit, including public hearings. Approval of an interim use permit of any length
should have provision for changes in technology. As vehicles cars are being converted to
electric (or another power source) in the both the short and long term future, this would be a
basis for a shorter IUP period as well as extended scope of environmental review. A storage
area filled with damaged and destroyed vehicles with large batteries containing various
substances is substantially different than a storage area filled with current fossil fuel powered
vehicles. This issue should be discussed by the Planning Commission and the City Council in
weighing the term of the interim use permit.
Environmental Review. The proposed development would convert 100 acres of cultivated
fields to an industrial land use. Minnesota Rules 4410.4300, Subd. 36.A requires that an
Environmental Assessment Worksheet (EAW) be prepared for any land use conversion involving
80 acres or more. IAA must prepare an EAW for review and approval by City staff, which will
include a detailed traffic study for the proposed use. The EAW is to be processed in accordance
with Minnesota Rules 4410.1500 to 4410.1700. The City will receive comments regarding the
potential for environmental effects caused by the proposed development and the City Council
will be the Responsible Government Unit (RGU) for determining if an Environmental Impact
Statement is to be required.
Surrounding Uses. The table below summarizes the existing and planned land uses
surrounding the subject site. The area surrounding the subject site is primarily rural. Industrial
development as guided by the Comprehensive Plan is occurring to the south from 701h Street to
the north. Transitioning from existing rural land uses to future industrial land uses will require
sensitivity in site design for existing residential homes. Furthermore, uses involving outdoor
storage to the extent proposed on the subject site require screening to minimize visibility of the
vehicles from public right-of-way and adjacent properties to maintain desired community
aesthetics.
Direction
Land Use Plan
Zoning Map
Existing Use
North
Industrial
A-1 District
Agriculture
Rural residential
East
Industrial
A-1 District
Agriculture
Rural residential
South
Industrial
A-1 District
1-2 District
Rural residential
Bury Industrial Park
West
Industrial
A-1 District
Agriculture
Hours. IAA has provided additional information regarding hours of operation for the facility.
Employee hours and vehicle drop -off -/load -out operations will occur between 8:OOAM and
S:OOPM. Auctions are to be held once per week during these hours.
Building Requirements. The site layout illustrates a 9,750 square foot building to be
constructed on the subject site. The submitted information does not include any additional
details regarding the proposed building. Section 11-17-4.E of the Zoning Ordinance requires
that the building consist of a minimum 75 percent masonry materials such as rock face block or
precast concrete panels. Building plans indicating compliance with the exterior material
requirements of the Zoning Ordinance will be required to be submitted with a future
development application.
Outdoor Storage. Performance standards applicable to the proposed outdoor storage area are
outlined in Section 11-86-3.0 of the Zoning Ordinance:
1. The storage area is landscaped, fenced, and screened from view of neighboring uses and
abutting residential districts.
2. Storage is landscaped and screened from view from the public right-of-way.
El
Comment: The sketch plan indicates that an 8 foot high solid fence is to be provided
along the front of the subject site parallel to Kadler Avenue (and on the three sides of
the residential exception parcel). No construction details are provided regarding this
fence, which must utilize weather resistant materials. The sketch plan also illustrates
evergreen trees planted in two staggered rows in the front yard along Kadler Avenue
(and the south, west, and north lot lines of the residential exception parcel). The height
of the proposed trees is not indicated. The trees must be at least 6 feet in height as
required by 11-19-2.B of the Zoning Ordinance or of sufficient height to provide
effective screening.
A 6 foot chain link fence will be used along the south, west, and north lot lines. The IAA
narrative includes a photo of a chain link fence with vinyl slats as a typical installation for
their facilities. Vinyl slats deteriorate over time and are not accepted for screening
purposes and a six foot height of the fence would likely not provide effective screening.
This fence should be considered as serving security purposes only. The outdoor
storage area will be visible along the side lot lines from Kadler Avenue. Fencing and/or
trees should be added to the site plan to provide screening as required by the Zoning
Ordinance.
3. The storage area is blacktopped or concrete surfaced.
Comment: The sketch plan indicates that the outdoor storage area is to be surfaced
with reclaimed asphalt millings. This surface will overtime compact and would prevent
dust issues within the site.
City staff is concerned that the proposed surface is not impervious. The IAA narrative
describes that the vehicles processed at the auction are dropped off, storage, and
loaded out in an as -is condition. The various fluids have not been removed and there is
potential for leaks from damaged vehicles while within the subject site. Fluid leaks raise
concern for potential environmental contamination. City staff and IAA have discussed
this issue further.
■ IAA has provided information regarding their operational Best Management
Practices (BMPs) that address vehicle fluid spills. The BMPs are internal
restrictions that IAA can change or choose not to enforce at any time. It would
be necessary to establish as a condition of possible approval that BMPs or
something similar are established and are ultimately enforceable by City as a
part of the interim use permit and cannot be changed by IAA.
■ IAA has provided additional information regarding the proposed recycled asphalt
surface of the outdoor storage area for review by the City Engineer to indicate
that the material is as impervious as hot mix asphalt pavement.
5
■ A stormwater containment plan will be required to be detailed as part of a
grading plan for the subject site to prevent environmental contamination of
ground water or stormwater drainage facilities.
The property owner as a condition of the interim use permit is to maintain
substantial insurance, a security acceptable to the City, and provide a hold
harmless and indemnification agreement with the City against environmental
hazards or any and all environmental claims.
4. All lighting shall be hooded and so directed that the light source shall not be visible from
the public right-of-way or from neighboring residences.
Comment: Section 11-16-6.0 of the Zoning Ordinance establishes performance
standards for exterior lighting to minimize impacts to adjacent properties and public
rights-of-way. The developer will be required to prepare photometric lighting plan
detailing the type, location, height, and intensity for all proposed exterior lighting. The
photometric lighting plan is subject to review and approval concurrent with the zoning
applications to develop the proposed use.
5. The storage area does not take up parking space or loading space as required for
conformity to this title.
Comment: The sketch plan illustrates an employee parking, drop off, and load out areas
in addition to outdoor storage areas. Further evaluation of the proposed use is required
to determine parking generation related to the number of off-street parking stalls to be
provided within the subject site in accordance with Section 11-21-8 of the Zoning
Ordinance. A site plan will be required with the development applications that must be
submitted for the proposed use detailing off-street parking areas in accordance with the
design standards established by Section 11-21-7 of the Zoning Ordinance.
Lot Requirements. Lots within the 1-2 District are subject to the following minimum lot
requirements:
Min. Lot
Min.
Setbacks
Max.
Area
Lot
Width
Bldg.
Cover
Kadler
Side
Rear
Wetland
Ave.
2.Oac.
200ft.
30ft.
20ft.
25ft.
40ft.
50%
The sketch plan complies with the lot requirements of the 1-2 District. All of the site elements
are setback 30 feet from Kadler Avenue (and the residential exception parcel) to provide for a
landscaped yard for buffering and screening. The 1-2 District does not establish a maximum for
impervious surface coverage, which will be dictated by stormwater treatment and rate control
needs.
Traffic. As noted above, the EAW required for the proposed development will include a traffic
study to estimate traffic generation for the proposed use and impacts to area roadways. IAA
has provided updated information as to traffic generation for the facility that will include the
following:
■ Car haulers and flatbed tow trucks with 3 to 4 vehicles for drop-off and load -out of an
estimated 600 vehicles per week.
■ Auctions will be held on-site once per week with an estimated 40 buyers attending.
■ Approximately 20 employees.
The subject site is accessed from Kadler Avenue. Kadler Avenue is planned as a future minor
arterial roadway by the Transportation Plan, which connects to 701h Street to the south. The
City is working with MNDoT and the City of Albertville regarding reconstruction of 70th Street to
occur in 2019. Kadler Avenue has been improved to a commercial/industrial street from 70th
Street to one-half mile north of 70th Street in conjunction with the Bury Industrial Park. Kadler
Avenue from the Bury Industrial Park to 80th Street adjacent to the subject site is a rural section
gravel roadway.
Kadler Avenue in its current condition abutting the subject site cannot accommodate traffic
generated by the proposed use. Provision of adequate access for traffic generated by the
proposed use is one of the criteria that must be met under the Zoning Ordinance for approval
of a Zoning Map amendment and interim use permit and the premature subdivision criteria of
the Subdivision Ordinance. Kadler Avenue must be improved to Standard Plate 103 of the
Engineering Manual as a 46 foot wide urban section street with asphalt pavement and concrete
curb as a condition of any approval for the proposed development. The right-of-way needs for
construction of I<adler Avenue will be determined by the City Engineer. The City does not have
improvement of this section of Kadler Avenue scheduled as part of its Capital Improvement
Plan for the next 10 years.
Advancing improvement of Kadler Avenue will make possible not only the proposed IAA
development but also open up properties on the east side of Kadler Avenue for guided
industrial development, which would advance the City's economic development goals. It has
not been the City's practice to assess the costs for the street improvements required by the
development to other potentially benefited properties and the recent court decision involving
the City of Woodbury means the City cannot agree to collect future transportation
infrastructure fees that could be rebated to the developer. To this end, IAA would be required
to undertake improvement of Kadler Avenue at their cost as a condition of developing the
subject site. Improvement of Kadler Avenue would include all costs related to land acquisition
for right-of-way and construction of the street section. This condition does not obligate the
City to use condemnation for acquisition of right-of-way for the street improvement.
7
Utilities. The subject site is within the West Sewer District established by the Comprehensive
Plan. Trunk water facilities have been placed in Kadler Avenue that would provide for water
service for the proposed use. Sewer utilities are approximately 2,700 feet to the south of the
proposed building within the subject site and would need to be extended to serve the proposed
use.
The size of the sewer line needed to serve the proposed use is significantly smaller than the
planned trunk sewer line that would serve the subject site with a more intense use and
adjacent properties. The developer is proposing to install a temporary service line that would
be sufficient for the proposed use. In consideration a termination date for the interim use
permit to allow the proposed use, such a temporary sewer line is acceptable.
Development of the subject site with industrial uses triggers payment of utility availability and
connection charges. Availability charges are based on the land area of the development and
connection charges are based upon estimated water demand for the actual use. Connection
fees for sewer and water use would be determined by the Building Official based on the plans
for the proposed building and estimated water usage.
To minimize the amount of the availability charges, IAA initially proposed to plat the subject site
as a lot that includes the building, drop off, and load out areas and an outlot encompassing the
outdoor storage area. Under this proposal, IAA would pay availability charges at the time of
final plat approval for the lot only and not the outlot; utility availability charges for the outlot
which would become due upon termination of the interim use permit based on the City fee
schedule in effect at that time.
Based on City staff's initial recommendation that the interim use permit terminate in 20 years
to trigger payment of the remaining availability charges as well as encourage a more intensive
redevelopment of the subject site, IAA is suggesting an alternative proposal. IAA would pay the
full utility availability charges for the subject site upon approval of the interim use permit. The
termination date for the interim use permit would then be determined based on balancing the
City's economic development goals and the investment by IAA in Kadler Avenue that benefits
other properties.
Stormwater Management. As noted above, stormwater management is a crucial issue for
development of the proposed use. A stormwater management plan is required that provides
not only for water quality related to the proposed use, but also for rate control such that the
rate of stormwater leaving the site is the same as exists in a predevelopment condition. The
property owner has delineated existing wetlands within subject site. Section 11-16-5.F of the
Zoning Ordinance outlines required wetland protection measures including avoidance, required
buffers, and required setbacks. In platting the subject site, the City will require that any
wetlands and wetland buffers be platted as a separate outlot(s) to be deeded to the City in
accordance with Section 10-8-10.D of the Subdivision Ordinance. The subject site is within the
Otsego Creek watershed and a stormwater impact charge based on the net developed area of
the subject site. All grading, drainage, and erosion control issues are to be subject to review
and approval of the City Engineer.
RECOMMENDATION
IAA has proposed an industrial use that if allowed on an interim basis advances the City's
economic development goals. Support for the proposed use must be conditioned on a number
of stipulations and obligations on the part of IAA to address the current lack if infrastructure
needed to support the proposed use as well as operational considerations of the proposed use.
If the Planning Commission supports the proposed use, City staff has recommended conditions
that be included in such a motion below.
POSSIBLE ACTIONS
A. Motion to support of the IAA sketch plan subject to the following conditions:
1. The proposed development shall require the following applications:
Zoning Map amendment rezoning from A-1 District to 1-2 District.
b. Interim use permit allowing outdoor storage.
Site and building plan review.
Preliminary plat.
Final plat.
2. The developer shall prepare an EAW for review and approval by City staff to be
processed in accordance with Minnesota Rules 4400.1500 to 4400.1700.
3. An interim use permit allowing the proposed outdoor storage use shall
terminate upon a date specified by the City Council in accordance with Section
11-5-4 of the Zoning Ordinance.
4. The exterior finish of all buildings shall comply with Section 11-17-4.E of the
Zoning Ordinance.
5. The outdoor storage area shall be landscaped and screened from view of the
public right-of-way.
The proposed surface of the outdoor storage area shall be subject to approval of
the City Engineer.
0J
Best Management Practices enforceable by City that cannot be unilaterally
amended by the property owner shall be adopted as a condition of the interim
use permit.
8. Off-street parking shall be provided in accordance with Chapter 21 of the Zoning
Ordinance.
9. All exterior lighting shall comply with Section 11-16-6 of the Zoning Ordinance.
10. Kadler Avenue:
a. The developer shall provide at their cost for right-of-way acquisition and
construction of Kadler Avenue between the north line of the Bury
Industrial Park and 80th Street, subject to review and approval of the City
Engineer.
b. The City shall not be obligated to utilize condemnation for right-of-way
acquisition in order for the developer to construct Kadler Avenue as a
condition of the interim use permit.
11. Utilities:
The developer shall be responsible at their cost for extension of temporary
sewer service to the subject site.
b. The developer shall pay utility availability charges for any platted lots at the
time of final plat approval in accordance with the City Code and fee
schedule in effect at that time.
Utility availability charges for any outlots for which an interim use permit is
approved to allow outdoor storage shall be paid by the developer in
consideration of the term of the interim use permit as determined by the
City Council.
d. Utility connection charges shall be paid at the time a building permit is
issued in accordance with the City Code and fee schedule in effect at that
time.
All utility issues are subject to review and approval of the City Engineer.
12. Stormwater management:
The property owner as a condition of the interim use permit shall maintain
substantial insurance, a security in the form as approved by the City, and
10
provide a hold harmless and indemnification agreement with the City
against environmental hazards or any and all environmental claims, subject
to review and approval of the City Attorney.
b. A stormwater containment plan shall be required to prevent
environmental contamination of ground water or stormwater drainage
facilities.
C. Wetlands and wetland buffers shall be platted within outlots and deeded
to the City,
d. All grading, drainage, and erosion control issues are subject to review and
approval of the City Engineer.
B. Motion to not support the IAA sketch plan based on a finding that the request is
inconsistent with growth management policies of the Comprehensive Plan.
C. Motion to table.
Adam Flaherty, City Administrator/Finance Director
Tami Loff, City Clerk
Andy MacArthur, City Attorney
Ron Wagner, City Engineer
Jay Bajgert, IAA
Jim Waters, Otsego Farms LLP
11
IAA -Site Location Map
Overview
Legend
Roads
^— CSAHCL
CTYCL
— MUNICL
— PRIVATECL
— TWPCL
Highways
— Interstate
State Hwy
- US Hwy
City/Township Limits
❑ c
❑ t
❑� Parcels
Adam Flaherty
City Administrator
City of Otsego
13400 90th Street NE
Otsego, MN 55330
February 22, 2019
Re: Insurance Auto Auctions, Inc. — Sketch Plan Narrative
WSB Project No. 013519-000
Dear Mr. Flaherty:
Attached please find an application and sketch plan for a proposed development of a 100 -acre parcel
located southwest of the intersection of Kadler Ave. NE and 801h St. NE. These documents have been
prepared by or on behalf of Insurance Auto Auctions, Inc. ("IAAI"). IAAI requests that this item be
considered at the City's March 18, 2019 planning commission meeting.
In addition to the attached, and to follow up on initial conversations with the City of Otsego staff, please find
outlined below additional information regarding the proposed development that may be of use to you in
your review.
Overview and Operations of IAAI:
IAAI works in partnership with a variety of sellers, including insurance companies, dealerships, rental car
companies and fleet lease companies to facilitate the sale by auction of total loss, theft -recovered and other
vehicles which have reached the end of their useful life. Vehicles are sold quickly and efficiently, with 50%
of IAAls business being conducted via the internet. IAAI has consistently expanded its business. In the past
10 years IAAI has added over a hundred facilities, currently employs over 1,800 people, and has
approximately 180 facilities in the United States and Canada.
After receiving vehicles from its customers, IAAI begins the process of auctioning the vehicle, by inspecting,
imaging and placing the vehicle in its inventory. Vehicles are not dismantled; no parts are removed from
the vehicles, nor is any maintenance done on the vehicles. The vehicles are sold in the same condition as
when they arrive.
IAAI follows strict regulatory compliance at federal, state and local levels, including regular environmental
audits. IAAI has best management practices for dealing with the rare spillage or leakage from a vehicle,
which is outlined in more detail below.
Economic/Tax Base Information
The proposed development will provide the city with a significant increase in tax revenues for the site
compared to the existing agricultural use. Development values of this site are summarized below:
Estimated Cost for Improvements to Property $17,000,000
Land Value $3,500,000
Total Value $20,500,000
Insurance Auto Auctions, Inc. I Two Westbrook Corporate Center,10th Floor I Westchester, IL 60154 I T708.492.7000 I F708.492.7078
IAA-Auctions.com I IAAI,com
City of Otsego
February 22, 2019 IMAPage 2 KM
Employment Benefits to the Community:
This development will consist of 20-22 dedicated employees in addition to local leadership comprised of
Branch Manager (BM), Yard Manager/Supervisor (YM/YS), Office Supervisor (OS) and sometimes
Assistant Branch Manager (ABM)
Salaries for 20-22 employees (these are averages based on location) $38.9K per employee plus
benefits
Salaries for leadership (not including bonuses or benefits)
o Branch Manager Average Salary: $96.2K (for this size branch)
o Yard Manager or Yard Supervisor average Salary: $52.8K
o Office Manager Average Salary: $51 K
Lighting and Security:
The only exterior lighting at the site is located at the building. The remainder of the site is not lit. The site
utilizes heat sensitive infrared security cameras that are effective at monitoring for security purposes in low
light or no light conditions.
Traffic:
IAAI proposes to construct two access points off Kadler Ave NE. The access points would be spaced 500 -
feet apart in accordance with City requirements. Traffic in and out of the facility will include car haulers,
flatbed tow trucks and employee vehicles. IAAI anticipates that when the site is fully developed, there would
be approximately 200-250 weekly trips to and from the site on average.
Screening:
IAAI will meet the City of Otsego's screening requirements for this development, if required. IAAI can avail
itself of a wide variety of screening options to meet such requirements. Attached is a photo of a recent
development depicting our typical chain link fence with vinyl slats.
Setbacks
IAAI will meet the City of Otsego's screening and setback requirements for this development.
Environmental Protection:
As stated above, no reclamation, repair, dismantling, or salvage of vehicles is conducted on the property.
Accordingly, leaks, spills, fumes, and odors from the site will rarely occur. In rare circumstances, a vehicle
that has been damaged may leak while it's being stored, but IAAI implements best management practices
for addressing these issues, including the following: visual inspection of vehicles upon intake and while in
inventory, proper handling and storage of vehicles, and training of personnel, preventive maintenance of
stormwater infrastructure, and regular inspections of storage areas and any other area in which hazardous
materials are present.
All IAAI facility employees receive routine training on the management of any conditions which may occur,
and IAAI has an ongoing relationship with Tetra Tech EM, Inc., a national environmental consulting and
compliance firm to assist with any significant issues, should they happen to occur. IAAI follows a specified
set of standards to ensure high quality operations, which are outlined in its Environmental Best
Management Practices Manual. In addition, IAAI carries a pollution liability policy with significant limits,
which is issued by Chubb, which covers all of its locations throughout the US and Canada.
Insurance Auto Auctions, Inc. I Two Westbrook Corporate Center, 10th Floor I Westchester, IL 60154 I T708.492.7000 I F708.492.7078
IAA-Auctions.com I IAAI.com
City of Otsego
February 22, 2019 IMAPage 3
Kadler Ave NE Road Improvements
It is understood that the City would require improvements to Kadler Ave NE in connection with this
development and the dedication of such improved road as a right of way. IAAI is amenable to discuss
providing an improved, dedicated right of way as required to facilitate this project. IAAI will work with the
City and adjacent property owners to accomplish the road improvements.
It is further understood that based on initial conversations that improvements to KadlerAve would be funded
by this development. We would be receptive to further discussions on this topic.
Thank you for your consideration of the information enclosed. We anticipate further discussion of the project
with you.
Sincerely,
Insurance Auto Auctions
Jay Bajgert
Real Estate Project Manager
Insurance Auto Auctions, Inc. I Two Westbrook Corporate Center,10th Floor I Westchester, IL 60154 i T708.492.7000 I F708.492,7078
IAA-Auctions.com I IAAI.com
OTETRATECH
April 4, 2019
Mr. Richard Hoopis
Real Estate Counsel
Insurance Auto Auctions, Inc.
Two Westbrook Corporate Center, Suite 500
Westchester, Illinois, 60154
Subject: Proposed Otsego, Minnesota Facility
Insurance Auto Auctions Inc. - Temporary Vehicle Storage
Environmental Best Management Practices
Dear 1VIr. Hoopis:
Tetra Tech, Inc. (Tetra Tech) provides Insurance Auto Auctions, Inc. (IAA) with environmental
consulting services in Minnesota and nationwide. IAA tasked Tetra Tech with describing its
operations as they relate to the temporary storage of vehicles and environmental best management
practices (BMP).
IAA OPERATIONS
The location in Otsego is planned to be used as a typical IAA auction. IAA specializes in
providing insurance companies, car rental companies, and other vehicle providers with a number
of specialized services surrounding the liquidation of vehicles acquired through the settlement of
claims. IAA picks up and stores vehicles, facilitates the transfer of sale documents, and auctions
salvage vehicles. IAA is not a salvage yard and IAA does not dismantle vehicles, sell vehicle
parts, or drain vehicle fluids. Operations at typical IAA facilities consist of four main areas:
• Drop zone/staging area: Vehicles are brought to the IAA branch after evaluation by the
insurance carrier. The drop zone/staging area at the branch is used to stage vehicles and
catalog them prior to placement in the storage yard. Fluids are not drained from vehicles.
• Storage yard: Once vehicles are cataloged, they are taken to the storage yard. Vehicles
remain in the storage yard until they are moved to the auction area.
• Auction area: The auction area is where weekly or bi-weekly auctions are held. Stored
vehicles are brought to the auction area from the storage yard.
• No industrial or environmentally sensitive operations are planned.
SPILL PREVENTION MEASURES
Good housekeeping at IAA facilities is required of all employees, work areas, and operations.
Fuel storage areas will be kept clear of combustible materials and not used as storage areas. Any
spilled material must be immediately cleaned up and debris properly disposed of. Branch
employees will ensure spill kits, fire extinguishers, and other response equipment is readily
accessible and working properly.
Tetra Tech Inc.
1100 S. McCaslin Boulevard, Suite 150, Superior, CO 80027
Tel 303.441.7900 www.tetratech.coni
OTETRA TECH
Regular inspections of all petroleum storage areas will be conducted and documented using an
existing checklist. The inspection checklist will be maintained and kept in the Branch Manager's
office. Electronic copies of the prior completed checklists are maintained.
SPILL AND LEAK COUNTERMEASURES AND RESPONSE PROCEDURES
Prompt response to a spill or leak is the best means of minimizing any impact to the environment
and, in particular, preventing a discharge from reaching the waters of the United States. In the
event of a spill, the employee first observing the physical evidence of the spill will implement
response procedures.
Upon noticing a spill or leak, the employee first observing the spill should estimate the hazard
potential by determining at least the following factors:
a. The substance spilled and its hazard potential.
b. The amount of the spill and the extent of spread.
c. The source of the leak or spill.
The employee will notify the Branch Manager of the spill and the spill will be remediated.
Responder(s) first attempt to contain the spill only if there is no threat to their safety, so as to
prevent its entry into a storm sewer, a ditch, or any conveyance that eventually discharges to the
waters of the United States. The equipment that can be used by an IAA employee to contain
spills can be found in the branch spill kit. IAA is committed to maintaining spill kits at this
branch for containing incidental spills. The spill kit may contain absorbent material, booms,
disposal bags, and personal protective equipment and will typically be located near the fuel
storage area. Once the spill or leak is contained and the source eliminated, the responder or
designee shall contact the appropriate IAA personnel.
Absorbent material and debris will be managed in a manner that fully complies with applicable
local, state, and federal laws regarding disposal of wastes. If cleanup is conducted by an outside
contractor, the contractor shall also follow all applicable local, state, and federal laws regarding
disposal of wastes.
ENVIRONMENTAL PROTECTIONS
Companywide, IAA implements a rigorous set of BMPs to ensure that any fluid leaks from
vehicles are promptly cleaned and storage yards are kept clean. Using materials prepared by
Tetra Tech, IAA employees are trained to properly respond to spills in the event any occur. At
the few IAA branches where groundwater monitoring is required by local ordinance, IAA is
complying with permit requirements. IAA employees are also trained on proper housekeeping
and material management. Implementation of the BMPs minimizes potential environmental
impacts to soil and groundwater at storage locations.
It is Tetra Tech's understanding that potential contamination from future land use is a concern
and that the proposed asphalt millings (reclaimed asphalt pavement) ground surface is being
questioned based on permeability. Asphalt millings are a long-lasting, durable material which
hardens over time. Based on a study conducted by the Colorado Department of Transportation,
OTETRA TECH
the use of reclaimed asphalt pavement as an unbound aggregate base course is an appropriate
design and construction approach for vehicle parking areas. According to the Federal Highway
Administration, the permeability of blended granular material containing reclaimed asphalt
pavement is similar to conventional granular base course material. Asphalt millings would be
expected to more readily adsorb petroleum based on their existing asphalt content. Asphalt
pavement is subject to cracking and requires frequent maintenance to prevent breaks that create
conduits to the subsurface. In addition, BMPs are valid and effective for paved and unpaved
surfaces and address large or small spills and releases alike.
Based on IAA's long history of environmentally benign operations, demonstrated operating
history, and adherence to environmental BMPs, the proposed asphalt millings surface does not
present a material risk to the environment.
Sincerely,
Bob Farnes
Manager
Insurance Auto Auctions, Inc.
Environmental Best Management Practices
/MA
AAUCTX-*'S
Insurance Auto Auctions, Inc.
Westchester, IL
Prepared by:
D]
Tetra Tech, Inc.
1100 S. McCaslin Boulevard, Suite 150
Superior, Colorado 80027
February 2017
TABLE OF CONTENTS
Section
Paqe
1.0 INTRODUCTION.................................................................................................. 1
2.0 REVIEWS AND CHANGES.................................................................................. 1
3.0 IAA OPERATIONS............................................................................................... 1
4.0 HAZARDOUS WASTE STORAGE AND DISPOSAL ........................................... 2
4.1 Conditionally Exempt Small Quantity Generator ........................................ 3
4.1.1 Disposal: ......................................................................................... 3
4.1.2 Documentation and Reporting:....................................................... 3
4.1.3 Storage: .......................................................................................... 3
4.2 Small Quantity Generator.......................................................................... 4
4.2.1 Generation and Disposal: ................................................................ 4
4.2.2 Documentation and Reporting: ....................................................... 4
4.2.3 Storage: .......................................................................................... 5
4.2.4 Labeling: ......................................................................................... 5
4.2.5 Time Limitations: ............................................................................. 5
5.0 POTENTIAL IMPACTS TO STORM WATER.......................................................5
5.1 Potential Storm Water Discharge Pollutants .............................................. 6
6.0 BEST MANAGEMENT PRACTICES....................................................................6
6.1 Good Housekeeping.................................................................................. 7
6.2 Preventive Maintenance............................................................................ 7
6.3 Inspections................................................................................................. 8
6.4 Storm Water Control Measures................................................................. 9
6.4.1 Vegetative Storm Water Controls .................................................... 9
6.4.2 Structural Control Measures.........................................................10
6.5 Release Response.................................................................................. 10
6.5.1 Procedures....................................................................................11
6.5.2 Response Team............................................................................ 12
6.6 Vehicle Washing......................................................................................13
6.7 Flood Vehicle Preparation........................................................................ 13
6.8 Specialized Equipment Service and Maintenance ................................... 14
7.0 Employee Training..............................................................................................15
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1.0 INTRODUCTION
This document presents Best Management Practices (BMP) for Insurance Auto
Auctions, Inc. (IAA) branches. It is the environmental policy of IAA to comply with all
applicable laws, regulations, permits, and orders. IAA has developed this document to
proactively conduct operations at their branches in an environmentally responsible
manner. There are various activities that take place during IAA operations that can
potentially release pollutants to the environment if the activities are not performed
properly. These environmental issues are limited to possible storm water impacts and
storage and management of materials and wastes. This document identifies potential
sources of environmental impacts from IAA branches and includes BMPs to minimize
these adverse environmental impacts. This document provides general BMPs for IAA
branches that address federal requirements. Each IAA branch will also comply with
additional regulatory requirements that address state and local regulations.
2.0 REVIEWS AND CHANGES
IAA will review the BMPs described in this document on an annual basis and make
changes as necessary. Reviews will also take place whenever there is a (1) significant
change in a branch's design, construction, operation, or maintenance that has an effect
on the potential for environmental impacts; or (2) when there is a change in applicable
laws, regulations, permits, and orders that affects operations at IAA branches.
3.0 IAA OPERATIONS
IAA is primarily engaged in securing and storing vehicles from insurance total losses,
bank repossessions, lease, and charity donations for subsequent auction to IAA
authorized buyers. Vehicles are typically transported from primary holding facilities,
such as towing companies, body shops, garages, car dealers, and residences, and then
brought to IAA branches. IAA inspects and evaluates all vehicles prior to arrival and
storage. Vehicles remain in the same condition as they arrive in and are not dismantled
or repaired. Most vehicles have been stored for approximately 15 to 20 days at a
primary holding location prior to arriving at an IAA branch. Once relocated to an IAA
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branch, vehicle storage periods average approximately 30 to 55 days while awaiting
proper paperwork for resale prior to auction.
The location of all loading, unloading, storage, sale, and access rows associated with
stored materials and vehicles varies from branch to branch. The outdoors will be
primarily used for vehicle storage and wholesale auction. Auctioning of vehicles is
primarily done outdoors one to two days per week. Access to the yard is strictly
managed through the main gate of the branch and is monitored by IAA personnel.
Buyers are issued ID badges. Loading, unloading, and movement of stored vehicles
are controlled by IAA personnel. In some cases, vehicles are loaded and unloaded
from tow trucks using a forklift. IAA activities with the potential to result in
environmental impacts are addressed in the following sections.
4.0 HAZARDOUS WASTE STORAGE AND DISPOSAL
The Resource Conservation and Recovery Act (RCRA) establishes a federal program to
manage and track hazardous wastes from cradle to grave — from the waste's initial
generation point to time of final disposal or recycling. The objective of the program is to
ensure that hazardous waste is handled in a manner that protects human health and the
environment. Under RCRA, hazardous waste is a waste that poses substantial or
potential threats to public health or the environment and generally exhibits these
characteristics - ignitable (i.e. flammable), oxidizing, corrosive, and/or toxic. For
additional details on RCRA regulations, the U.S. Environmental Protection Agency
(EPA) provides the RCRA Online Database -- http://www.epa.gov/rcraonline. State or
local regulatory agencies may also have applicable regulations regarding hazardous
waste and used oil.
Under RCRA, there are regulations for the generation, transportation, and treatment,
storage, recycling or disposal of hazardous wastes. The regulatory requirements that
apply to a branch depend upon the amount of hazardous waste that is generated by the
branch each month. There are two types of waste generation levels that apply to IAA
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branches — conditionally exempt small quantity generator (CESQG) and small quantity
generator (SQG).
4.1 Conditionally Exempt Small Quantity Generator
If a branch generates less than 220 pounds (100 kilograms) of hazardous waste or less
than 220 pounds of spill residue per month, a branch is considered a CESQG.
4.1.1 Disposal: Hazardous waste must be delivered to an offsite treatment, storage
and disposal facility (TSDF) located in the U.S. that is "permitted, licensed, or registered
by a State to manage municipal or industrial solid waste." This means the waste can go
to a local industrial or municipal solid waste landfill. However, most permitted municipal
and industrial landfills have created their own regulations that do not allow certain
wastes to be disposed, especially hazardous wastes. For this reason, make sure that
the TSDF you have selected has the necessary permits to handle hazardous waste.
4.1.2 Documentation and Reporting: There are no specific federal requirements for
keeping records of the amount of hazardous waste generated by a CESQG. However, it
is highly recommended that records be created and retained.
This documentation provides a basis for determining your generator status each
calendar month and is proof to any regulatory agency that may question your monthly
generation rates. Hazardous waste that is sent to a TSDF is generally listed on a
Uniform Hazardous Waste Manifest. The manifest provides the proper documentation
for monthly generation of hazardous waste. If at any time, the monthly generation for
the facility exceeds 220 pounds, EPA must be notified of your change of generator
status.
4.1.3 Storage: There are no specific federal requirements for storage and labeling of
accumulated hazardous waste, however, there are some basic practices that help
ensure safe management of hazardous waste. Storage containers should not be
leaking, bulging, rusted, or incompatible with the waste stored in them. While there are
no labeling requirements for CESQGs under RCRA, the Occupational Safety and
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Health Act (OSHA) requires that you have labels on all containers. As a CESQG, you
cannot accumulate onsite more than 2200 pounds of hazardous waste at any one time
prior to disposal. If this happens, you must then follow all the requirements of a small
quantity generator.
4.2 Small Quantity Generator
If a branch generates less than 2200 pounds (1000 kilograms) but more than 220
pounds (100 kilograms) of hazardous waste per calendar month, it is considered a small
quantity generator (SQG) for that month.
4.2.1 Generation and Disposal: As a SQG, you are allowed to generate less than
2200 pounds of hazardous waste in any calendar month. All hazardous waste
generated by the SQG that is not treated onsite must be manifested to an offsite TSDF
permitted to handle hazardous waste or to an approved designated facility (e.g.,
recycling facility).
4.2.2 Documentation and Reporting: SQGs are required to track, report, and
maintain documentation regarding their hazardous waste generation.
Manifests: Hazardous waste that is sent to a TSDF or an approved designated facility
must be listed on a Uniform Hazardous Waste Manifest. A manifest provides a
description of the hazards of the waste and the waste handlers. You must sign and
date the manifest and obtain the signature of the transporter on the manifest. You must
also keep a copy of the form until you receive a copy signed by the TSDF. Manifests
must be kept for at least three years from the date of shipment. If your generator status
changes, you must notify EPA or the State.
Exception Report: Once a hazardous waste manifest has been signed and dated by
you (the generator), EPA gives the disposal contractor 60 days to transport the waste to
the TSDF and return a signed copy of the manifest to you. If, after 60 days, you do not
receive the "Return to Generator" copy of the manifest signed by the TSDF, you must
send a legible photocopy of the manifest to the EPA Regional Administrator and a brief
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written statement about not receiving the signed copy. This report must be maintained
for at least three years.
Miscellaneous: Generators are also required to keep records of test results, waste
analyses, or other waste determinations for at least three years from the date of
shipment of that waste.
4.2.3 Storage: Hazardous waste must be stored in sealed tanks or containers,
provided they are not leaking, bulging, rusted, or incompatible with the waste stored in
them. Storage areas should have a means of secondary containment, an alarm, a fire
extinguisher, a "No Smoking" sign, and a means of communication (e.g., walkie-talkie,
cellular phone, or air horn) in the event of a spill or other emergency.
4.2.4 Labeling: Hazardous waste tanks and containers must be labeled with the words
"Hazardous Waste", the contents of the container, the accumulation start date, the
waste codes of the contents, and the name, address, and EPA ID number of the
generator.
4.2.5 Time Limitations: SQGs are required to dispose their hazardous waste within
180 days of placing the waste into the container.
5.0 POTENTIAL IMPACTS TO STORM WATER
Potential pollutant sources exist at IAA branches that may adversely impact storm water
runoff. Storm water may carry pollutants to storm ditches, drains, and eventually,
bodies of water, such as streams, rivers, lakes, or oceans. Potential pollutant sources
include:
• Aboveground storage tanks (AST) that contain various materials such as fuel, oil,
and waste fluids
• Drums and containers that contain fuel, oil, waste fluids, and cleaning and
maintenance chemicals
• Burned vehicles and vehicles that contain fluids within their mechanical systems
• Hydraulic equipment that contain fluids within their mechanical systems
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• Oil water separators
5.1 Potential Storm Water Discharge Pollutants
Based upon review of activities conducted at IAA branches, it is possible that significant
materials could contact storm water runoff. Potential pollutants in storm water may
include oil and grease; common gasoline compounds such as benzene, toluene,
ethylbenzene and xylenes (BTEX); diesel fuel, methyl -tertiary -butyl ether (MTBE);
metals, and suspended (non -filterable) solids. At IAA branches, potential sources of
materials that can come in contact with storm water runoff include the following:
Vehicle -related fluid from de minimis releases (a release that is too small to be
a regulatory concern) may be present in storm water discharge. The presence of
these materials may originate from drips and leaks from vehicles traveling the
road, de minimis releases from stored vehicles and vehicle transport equipment,
and precipitation contact with exposed surfaces containing vehicle related fluids.
Vehicles brought to IAA branches may contain residual amounts of fluids in the
mechanical systems that are part of the vehicles. These fluids may include
windshield -washer fluid, radiator fluid, motor oil, transmission fluid, brake fluid,
grease, hydraulic oil, battery acid, and gasoline or diesel fuel.
Material and waste storage tanks and containers can leak or spill during fluid
transfer. If these leaks and spills are not prevented or contained, they can come
in contact with storm water runoff. Materials stored and used for operations at
IAA branches include facility maintenance chemicals (such as small quantities of
cleaning supplies, paints, and fertilizers), diesel and gasoline fuel, propane,
transmission fluid, grease, heating or motor oil, and antifreeze. Some of the
used or waste materials stored at IAA branches include contaminated, used or
expired materials such as used oil, fuel contaminated with water or other vehicle
fluids, expired hydraulic oil, and contaminated soil containing spilled materials.
• Runoff from adjacent properties containing soil, organic materials, and
petroleum-based products may also contribute to storm water contamination.
Erosion of inorganic solids could result when disturbance of soil surfaces during
transport equipment operation in access aisles is combined with precipitation
events.
6.0 BEST MANAGEMENT PRACTICES
The following BMPs for IAA branches provide guidance on how to minimize adverse
environmental impacts from operations. The BMPs include general practices such as
good housekeeping, preventative maintenance and inspections to prevent
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environmental issues. Guidance is also provided for BMPs that control storm water
impacts and response to spills. Finally, operation -specific BMPs cover vehicle washing,
flood vehicle preparation and equipment service and maintenance.
6.1 Good Housekeeping
Employees at IAA branches follow good housekeeping procedures to reduce the
possibility of accidental releases and to reduce safety hazards to facility personnel. Key
elements of IAA's good housekeeping program include the following items:
• Visual inspections of vehicles brought to the branch to assess integrity of vehicle
fluid systems and identify the need for repair or remedy of vehicle
hydraulic/mechanical systems that could leak significant materials on the
property.
• Visual inspections of travel aisles in the storage yard for evidence of releases of
significant materials and identifying the cause of the release when possible.
Removal of the miscellaneous debris (i.e., loose vehicle parts that may have
inadvertently fallen off of the host vehicle), as necessary, to prevent possible
damage to site vehicles.
• Regular maintenance of site vehicles and equipment to prevent de minimis
releases.
• Careful handling of vehicles, to minimize the potential for damage to vehicle
systems, which may in turn cause a release.
• Proper handling, storage and inventory of significant materials, when necessary
in the storage yard and within the branch garage or warehouse.
• Orderly storage and inventory of stored vehicles.
• Prompt, routine removal of de minimis releases.
• Continued training of IAA personnel regarding good housekeeping practices.
6.2 Preventive Maintenance
IAA personnel are responsible for the continued inspections and preventative
maintenance. Preventive maintenance includes visual operational inspection of facility
equipment, trucks, loaders, and storm water management features to detect conditions
which may cause breakdowns or failures resulting in the potential discharge of
significant materials into storm water.
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Preventive maintenance applies to the following branch features that are considered an
integral part of facility BMPs for storm water and pollution prevention systems:
• Catch basins and culvert systems
• Drainage swales
• Vegetated areas
• Site grading
• Pavement
• Trucks and forklifts
• Fuel storage tanks; above ground and underground
6.3 Inspections
To prevent the release of materials, IAA personnel conduct routine inspections.
Inspections include fuel storage and material storage areas as well as the storage
yards. Daily routine visual inspections are conducted in the vehicle storage yard and
building areas. Inspections of vehicles are conducted prior to their arrival at an IAA
branch by the drivers before the vehicles are loaded on transports. The indoor and
outdoor vehicles are inspected daily during normal yard operations. Inspections of
vehicles, equipment, fueling equipment, and building maintenance material are done
routinely in the course of normal business operations.
Each system and major item of branch equipment is inspected at least monthly.
Inspection procedures vary depending upon the equipment or system; however, the
major elements of the inspection program include observation of equipment and
environmental conditions of the branch.
Regulations require that ASTs containing petroleum products are visually inspected
once every thirty days. If an issue is identified that requires action, the issue is
documented and subsequent remedy is recorded upon timely completion. Visual
inspections include addressing the following questions:
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• Are there any visible leaks on tanks, tank seams, connections, fittings, valves?
• Are there any visible leaks on aboveground piping, pipe seams, connections,
fittings, flanges, threaded connections, pumps or valves?
• If utilized, is overfill prevention or leak detection equipment in good operating
condition?
• If a double -walled tank is utilized, is the interstice free of liquid and is the
interstitial monitoring equipment operating properly?
• Is the secondary containment system free of tank product and other liquids or
debris, such as rainwater, snowmelt, dirt, leaves, trash, etc.?
• Are concrete surfaces and ground free of any evidence of new leaks or spills?
• Are tank supports, berms, bollards or bumpers surrounding the tank in good
condition?
• Is the tank labeled with appropriate signs identifying the material within and with
appropriate warnings?
• Do you have the appropriate supplies for cleaning up a spill and overfill? Are
these supplies appropriately marked and conveniently located?
6.4 Storm Water Control Measures
Storm water BMPs described in this section focus on controlling and reducing possible
contaminants that may discharge to storm water. Storm water devices used to reduce
contaminants that may enter storm water could include vegetative swales, hay bales,
and absorbent booms. Branches may incorporate vegetative and structural control
measures to reduce pollutants to storm water. Storm water BMPs and devices used to
control and reduce the impacts of pollutants discharged into storm water are described
in the following sections.
6.4.1 Vegetative Storm Water Controls
Vegetative controls refer to landscaping practices that provide pollutant removal
primarily by limiting sediment movement and preventing erosion. Vegetative control
may include vegetated filter strips, grassed swales, and habitat creation/preservation,
and landscaping. IAA branches may use the following vegetative storm water controls.
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Vegetative Strips: Vegetative strips may be placed perpendicular to the direction
of surface water flow across the branch.
Vegetative Swales: Vegetated drainage swales may be used to provide pollutant
removal, velocity reduction, and erosion protection.
6.4.2 Structural Control Measures
Engineered controls consist of non -natural features constructed or placed with the intent
of reducing impacts of pollutants to surface water discharge from IAA branches. The
following engineered controls may be used:
Release Containment: Release containment (metal dikes or something similar) may be
used around ASTs. Double -walled ASTs may be used where feasible.
Wood Chips: Natural, untreated wood chips may be distributed along the ground
surface to provide filtration of surface runoff flow and to provide dust suppression
through retention of moisture at ground surface.
Crushed Stone and Gravel: Stone and gravel placement in high traffic areas helps
minimize erosion and sediment additions to storm water drainage areas.
Berms: Earthen or concrete berms may be used to control and contain flow.
Oil Absorbent Boom: Oil absorbent booms may be used based on observation of
surface water conditions. An oil absorbent boom acts as a barrier against the transport
of oil and grease by removing them from surface water flow.
Plastic Covering: Vehicles received at branches with their outer body coverings intact
provide inherent covering of vehicle mechanical system surfaces. Select vehicles and
components may be shrink-wrapped with polyethylene plastic to prevent contact with
precipitation and protect valuable components.
6.5 Release Response
The following sections discuss release response procedures and the response team
that may take care of a release at an IAA branch.
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6.5.1 Procedures
IAA personnel are trained to recognize potential release situations and how to respond
appropriately in the event of a release. Emergency response kits are located at the IAA
branches adjacent to areas with spill potential.
Release response procedures are similar for each material that may be stored at an IAA
branch. If releases absorbed on the ground surface are observed during operations or
routine inspections, the affected solids on the ground surface are removed by hand or
mechanical equipment as soon as practical and disposed of properly. Materials and
equipment used in the cleanup of this material may include absorbents, rags, shovels,
backhoes, loaders, DOT -approved storage drums, etc.
Specific material handling procedures to reduce contaminated material from entering a
storm water conveyance or drainage point include covering impacted solids with
sheathing, use of absorbent material, and deployment of an absorbent boom at
drainage outfall locations. A release to the ground surface may or may not require
emergency response procedures, depending on the nature of the release. Release
response and cleanup equipment are available at all IAA branches. Employees
responding to a release have been instructed to implement containment by using
collection equipment at the location of the release and, if possible, to prevent migration
of the release off of the branch property by executing response measures.
Free product and/or impacted surface water shall be recovered to the extent
practicable, as soon as possible after a detected release. This will increase the
efficiency of the response actions and serve to minimize emulsified or dissolved phase
material which could pass through the facility storm water system and off branch
property.
If releases to surface water are observed during operations or routine inspections, the
materials (liquids or solids) are recovered by hand or with mechanical equipment.
Equipment used in the cleanup of releases to surface water may include skimmers,
pumps, adsorbents, bailers, etc., as deemed necessary.
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Pumping of liquids recovered from a release should include transfer into a secure
temporary holding tank or drum as soon as possible. Absorbent material should be
placed on the release locations and below identified sources of the release. The waste
absorbent material should be disposed of properly. Impacted soil should be excavated
and stored in appropriate containers or covered with polyethylene sheets.
Impacted material collected during the response must be removed promptly and
disposed of in accordance with Federal, State and local requirements. A licensed
emergency response contractor may be required to assist in cleanup of releases
depending on the size and location of the release, weather and ground conditions, and
the effectiveness of response actions implemented by IAA personnel. Appropriate
regulatory agencies will be notified in the event of a reportable release.
Immediately following emergency response actions, the affected drainage path and
associated possible collection points should be closely monitored to allow recovery of
as much of the release material as possible. This includes identification and collection
of released material that might be caught in stagnant zones and continues to present
potential for migration after initial removal of accumulated material.
IAA maintains records at its corporate office of all significant material releases and
response actions taken. These records are kept and periodically reviewed to reduce
the chances of release reoccurrence, to assess potential improvements that could be
made to response procedures, and to comply with applicable federal, state and local
regulations.
6.5.2 Response Team
IAA response teams are trained in release identification and response procedures,
release reporting procedures, and communications systems. The release response
team for IAA branches includes the Branch Manager and those individuals identified by
the Branch Manager to respond properly.
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6.6 Vehicle Washing
Vehicle washing does not occur at all IAA branches. However, for some branches it is a
part of normal operations. Vehicle washing has the potential to adversely affect the
quality of storm water runoff. As wash water flows over vehicles and the ground,
chemicals can be picked up including oil and grease, pesticides, metals, and other
contaminants and can discharge to storm sewers. To minimize adverse impacts, the
following practices are used:
Catch basins are maintained and kept free of debris. If no catch basin exists,
vehicles are washed over pervious surfaces such as lawns and gravel areas.
Washing activities do not occur adjacent to or on storm drains or within the
boundaries of storm water ditches, retention ponds, or other storm water
conveyances.
If possible, washing occurs without detergents. If a detergent is used, "non-
toxic", "phosphate free", or "biodegradable" detergent will be chosen.
Vehicle washing is kept to the exterior of the car.
6.7 Flood Vehicle Preparation
Flood vehicle servicing does not occur at all IAA branches. However, for some
branches it is a part of normal operations. There are four levels of flood vehicle
servicing, as described below:
1. Vacuum Water from Interior: Vacuumed water is containerized and properly
disposed of.
2. Wash Vehicle Exterior and Engine: Vehicles are washed over pervious surfaces
such as lawns and gravel areas. Wash water is prevented from entering the
storm drain or any nearby streets. The amount of detergents and other cleaners
is either eliminated (i.e. only water is used) or only those that are "non-toxic",
"phosphate free", or "biodegradable" are chosen. Engines are washed in a
contained area with no access to the sewer or storm drains. Waste water from
engine washing is collected for future treatment and disposal.
3. Change Vehicle Fluids: Vehicle fluids are changed indoors and only over
impervious surfaces where possible. If changing, adding, or draining vehicle
fluids outside, all work is conducted within areas where spills can be contained
and cleaned up immediately. Drip pans are utilized when changing fluids, when
possible. Any releases are immediately cleaned up in accordance with the
established spill response plan. Drained fluids are immediately transferred to a
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designated waste storage area, making sure not to mix different types of waste
materials together (e.g., combining used oil with used antifreeze.)
4. Shampoo and Full Detail Cleaning: Shampoo water that is collected in the
wet/dry vacuum is containerized and disposed of properly.
6.8 Specialized Equipment Service and Maintenance
Specialized equipment is used to handle and move vehicles in a proper and orderly
manner. The most commonly used specialized equipment at IAA branches is the
forklift. Routine forklift maintenance is necessary to ensure long performance life of the
machines, reduce expensive repair costs, and maintain a safe work environment.
Typical maintenance of a forklift involves fluid checks and changes (such as engine oil
or transmission fluid), tire changes, radiator flushing, battery replacement, and general
inspection of hoses, belts, gauges, and other components. The following good
housekeeping practices are implemented to ensure minimal environmental impacts
occur at IAA branches resulting from servicing and maintaining forklifts or loaders:
• Indoor floor drains that are connected to the storm drain system are plugged prior
to equipment maintenance.
• Drip pans and adequate spill prevention and cleanup materials are kept on-site
and easily available for use.
• Drip pans containing oil or other automotive fluids are not left unattended, and
the contents are disposed of properly in accordance with all applicable local,
state, and federal regulations.
• Fluids are changed indoors and only over impervious surfaces where possible. If
changing, adding, or draining vehicle fluids outside, all work is conducted within
areas where spills can be contained and cleaned up immediately.
• Batteries are stored indoors on non-reactive, curbed, and impervious surfaces
where no floor drain is present. If floor drains are present, batteries are stored
upright in a plastic tub or other appropriate container to contain any leaked
battery acid.
• Each used battery is labeled and dated.
• Used batteries are recycled by either returning them to the manufacturer for a
trade-in with the purchase of new batteries, or by arranging for a registered
waste transporter to pick them up for recycling. Used batteries are recycled prior
to accumulating 40 batteries.
Page 14 of 15 February 2017
Insurance Auto Auctions, Inc.
Environmental Best Management Practices
• Wastewater from parts cleaning, engine cleaning, undercarriage cleaning,
radiator flushing, etc. is containerized and disposed of in accordance with all
applicable local, state, and federal regulations.
• Specific areas are designated with in the facility for engine, part, or radiator
cleaning. Washing or rinsing parts outdoors only occurs when absolutely
necessary. If washing or rinsing parts outside, work is conducted within areas
where spills can be contained and cleaned up immediately.
7.0 Employee Training
Employee training is conducted to inform branch personnel of the BMPs used at IAA
branches. The training covers practices for hazardous waste management and
preventing releases and the procedures for responding properly and rapidly to releases.
Local branch personnel are trained initially, prior to work assignments, and annually
thereafter to ensure they are familiar with the elements and goals of the practices and
procedures. Training records are updated and maintained on a regular basis.
Page 15 of 15 February 2017
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