STORM WATER POLLUTION PREVENTION PLAN CITY OF DAYTON OTTAWA YARDS

Transcription

1 STORM WATER POLLUTION PREVENTION PLAN CITY OF DAYTON OTTAWA YARDS

2 II of III Table of Contents 1.0 OVERVIEW About This Plan Distribution List Document Revision History Certification Pollution Prevention Team SITE DESCRIPTION/MAP General Outfalls and Drainage Areas INVENTORY OF EXPOSED MATERIALS SIGNIFICANT SPILLS AND LEAKS NON-STORM WATER DISCHARGES SAMPLING DATA RISK IDENTIFICATION AND SUMMARY OF POTENTIAL POLLUTANT SOURCES EMERGENCY RESPONSE Bulk Loading and Unloading of Storage Tanks Vehicle Fueling Vehicle Maintenance Pavement Deicing Vehicle Washing Waste Removal Vehicle Parking BEST MANAGEMENT PRACTICES Good Housekeeping Measures and Controls Preventive Maintenance Inspections Spill Prevention and Response Procedures Employee Training Sediment and Erosion Control Management of Runoff and Activity-Specific BMPs SITE COMPLIANCE AND PLAN EVALUATION RECORD KEEPING AND REPORTING SPECIAL REQUIREMENTS Section 313 Special Requirements Salt Piles Discharge to Large or Medium Separate Storm Sewer Systems Coal Piles APPENDIX A COPY OF NPDES PERMIT APPENDIX B LIST OF INVENTORY APPENDIX C LIST OF 313 WATER PRIORITY CHEMICALS APPENDIX D OTTAWA YARDS SITE PLAN APPENDIX E LIST OF SIGNIFICANT SPILLS AND LEAKS... 34

3 III of III APPENDIX F DRY WEATHER OBSERVATION FORM APPENDIX G INSPECTION WORKSHEETS APPENDIX H SPILL / RELEASE REPORTING REQUIREMENTS - OTTAWA YARDS SPILL SIGN... 37

4 1 of OVERVIEW 1.1 About This Plan In accordance with Ohio EPAs Guidance for MS4 Operated Industrial Facilities (June 2009),Municipal Separate Storm Sewer Systems (MS4) that operate vehicle maintenance facilities must develop and implement a Storm Water Pollution Prevention Plan (SWP3). The fourth renewal of the industrial general permit (Permit No.OHR000005), mirrors OEPA s current Multi-Sector General Permit (MSGP). There were no sector specific requirements for SIC 3700 (vehicle maintenance). On January 31, 2012, a Termination of coverage under Ohio EPA NPDES General Permit for OHR was issued by Ohio EPA. A copy can be found in Appendix A. The SWP3 was developed as a comprehensive approach to site-wide management of storm water. The City understands that it has responsibility for coordinating site-wide storm water protection and complying with this plan is a part of its responsibility in the normal course of use of the facility's storm water system. The SWP3 is intended to prevent or control the discharge of pollutants in storm water runoff from the facility. This pollution prevention approach focuses on two major objectives: (1) to identify sources of pollution potentially associated with industrial activity that can affect the quality of storm water discharges from the facility; and (2) to describe and outline the implementation of practices to minimize and control pollutants in storm water discharges from the facility. Thus, the plan provides a mechanism for compliance with the terms and conditions of the permit. Several key points are considered when reviewing this plan: 1. The Environmental Manager has completed and signed the Certification of this plan. 2. Section 3.0 of this plan lists the materials at Ottawa Yards that are exposed to storm water and, thus, may be sources of pollutants in runoff. This list is kept current. 3. A review is made of any water priority chemicals listed under the Emergency Planning and Community Right-to-Know Act (EPCRA), Section 313, which are used, produced, or stored at Ottawa Yards in reportable quantities. 4. Section 4.0 of this plan lists significant spills and leaks that occurred after August 9, Section 9.0 of this plan details the site compliance evaluation and SWP3 review that is completed and kept on file as part of the SWP3. The Ottawa Yards NPDES Permit requires that the BMP Plan be amended when a change in design, construction, operation, or maintenance has a significant effect on the potential for discharge of pollutants in storm water. The plan must also be amended if the procedures of controls prove to be ineffective in eliminating or significantly minimizing pollutants from potential sources. Amendments to the BMP Plan will be included in the SWP3, and kept on file. When the plan is amended or updated, the date of the latest revision will be indicated. If worksheets are updated, the revision number and the date of revision will be noted in the upper right hand corner. Worksheets that are replaced will be kept on file as reference. This plan will be revised as necessary, with copy of this document located in a three-ring binder to facilitate amendments and updates. Each plan has a distribution page listing the number and the holder of each copy. Contact the Division of Environmental Management, when revisions to this plan are needed.

5 2 of Distribution List Copy Plan Holder Title 1 Michele Simmons Manager, Environmental Management 2 Felicia Graham Environmental Compliance Coordinator 3 Leslie Tipton Environmental Scientist 4 Chris Holmes Chief Engineer, Water Engineering 5 Matt Newton Manager, Fleet Management 6 Anthony Wade Sewer Maintenance Operations Administrator 7 Fred Stovall Manager, Street Maintenance 8 Tom Ritchie, Jr Manager, Waste Collection 9 Phil Van Atta Manager, Water Supply & Treatment 10 Romona Carver Assistant Director, Public Works 11 David Shade WUFO Operations Coordinator

6 3 of Document Revision History Preliminary Plan Date: April 1, 1994 By: Donna Gorby Lee Revision 1 Date: November 1995 By: Tammi Clements Revision 2 Date: July, 2000 By: Dan Smith Revision 3 Date: October, 2001 By: Michele Jones Revision 4 Date: June 2004 By: Felicia Graham Revision 5 Date: October 2006 By: Felicia Graham Revision 6 Date: January 2007 By: Felicia Graham Revision 7 Date: January 2009 By: Felicia Graham Revision 8 Date: February 2012 By: Felicia Graham Revision 9 Date: March 2014 By: Leslie Tipton Revision 10 Date: May 2015 By: Leslie Tipton

7 4 of Certification 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 assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly 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. Signature: Title: Certification Date:

8 5 of Pollution Prevention Team Name, Title, Phone No. M. Simmons, Manager X3796 L. Tipton, Environmental Scientist X3782 F. Graham, Environmental Compliance Coordinator X8598 All Ottawa Yards Tenants Responsibility Responsible for Ottawa yards, and will certify the information contained in the BMP Plan. Ensuring that storm water pollution prevention is included in Ottawa Yards Task Force training classes. Communication with regulatory agencies as needed. Development, review, and implementation of BMPs, including both facility and procedural changes. Oversee records keeping. Spill response. Routine inspections for adherence to BMP Plan. Communication with regulatory agencies as needed. Oversee records keeping. Spill response. Routine inspections for adherence to BMP Plan. Environmental compliance. Review and implementation of BMPs. Ensure that storm water pollution prevention is incorporated in employee training classes for City of Dayton onsite employees. Maintain records for training and inspection activities and any spill events at Ottawa Yards Facility. Spill response. Routine inspections for adherence to BMP Plan. In the event of an emergency during non-business hours, contact Ottawa Yards Security at X4941.

9 6 of SITE DESCRIPTION/MAP 2.1 General Ottawa Yards is owned by the City of Dayton. It is located at 1010 Ottawa Street at East Monument Avenue. Ottawa Yards contains the following City operations: Fleet Maintenance and vehicle storage, garage, fueling station, drinking water supply and treatment facilities (including lime kiln), Sewer Maintenance, Street Maintenance, Water Distribution and Waste Collection. 2.2 Outfalls and Drainage Areas A site map of Ottawa Yards delineating the drainage areas is located in Appendix D. Ottawa Yards is located within the #2 Mad River Left (MRL-02) drainage area, and is 2,609, square feet (59.89 acres) in size. The following thirteen (13) outfalls are identified on the site map: Outfall 001: This outfall is 21 in diameter and drains to the Monument Avenue. The drainage area includes: A portion of the main roadway that runs through the facility; the truck wash station; the north portion of the water treatment plant buildings and two enclosed tanks; and waste collection truck parking area. Outfall 002: This outfall is 21 in diameter and drains to Monument Avenue. It has a 98% impervious area which includes: vehicle maintenance and parking; vacant land management garage and office building; water electrician s office; Street maintenance office building and shop; heavy truck parking area; Street Maintenance garage storage bays; and chemical materials storage area. Outfall 003: This outfall is 12 in diameter and drains to Keowee Street. The drainage area includes an employee parking lot,.the Sewer Maintenance office building, inside equipment storage area and several bays of the Street Maintenance storage garage Outfall 004: This outfall is 18 in diameter and drains to Keowee Street. The Drainage area includes the Sewer Maintenance office building, Outfall 005: This outfall is 24 in diameter and drains to Keowee Street. The drainage area includes a parking lot, a pump station, Water Distribution building and storage area, and the underground water reservoir. Outfall 006: This site drains to a 10 outfall discharging to the Mad River (MRL-04). The area is 0% impervious with no buildings. The drainage area includes a portion of the east underground reservoir; an unpaved dirt area; locations to the west and north of the water treatment settling basin building; and a portion of the water treatment plant building. Outfall 007: This outfall is 48 in diameter and drains directly to the Mad River (MRL-05). The drainage area includes the east portion of the water treatment settling building; the lime kiln; associated buildings and tanks. Outfall 008: This is a process water outfall which is permitted through a separate NPDES permit Number 1IW00030*DD (MRL-06).

10 7 of 42 Outfall 009: This outfall is 15 in diameter and drains directly to the Mad River (MRL-07). The drainage area includes a paved area north of the slab for the old salt barn. Outfall 010: This outfall is 12 in diameter and drains to Monument Avenue. The drainage area includes a paved area north of the new salt storage building. Outfall 011: This outfall is a 21 diameter pipe that drains the City Fueling Facility on the south side of Monument Avenue. This Area drains to Monument Avenue. Appendix D shows the storm water sewers, the outfalls, and their approximate locations and drainage areas on the site. It also shows general drainage on the site. All of the drain/storm sewer systems and their outfalls are potentially affected by the site activities.

11 8 of INVENTORY OF EXPOSED MATERIALS An inventory was completed of materials used, stored, or produced onsite that could be potentially exposed to storm water. Appendix B contains a list of data gathered during the inventory including purpose, quantities used, quantity stored, and location. Section 313 of the Emergency Planning and Community Right-to Know-Act (EPCRA) lists substances that have been identified by EPA as especially toxic to water ecosystems ("313 water priority chemicals"). EPA has reporting requirements for facilities handling these toxic chemicals. A list of the "313 water priority chemicals" is included in Appendix C. Table 3-1 presents a list of the "Section 313 water priority chemicals" that are "used, stored or produced" at Ottawa yards. All of these chemicals are stored and used inside. There appears to be no significant risk of exposure of the "313 water priority chemicals" to storm water.

12 9 of 42 Table Water Priority Chemicals Inventory Facility Material CAS No. 1 Quantity Location WS&T Chlorine one ton cylinders South of Water Treatment Plant, inside of the chlorine building, on concrete floor 1. CAS No. = Chemical Abstract Service classification number.

13 10 of SIGNIFICANT SPILLS AND LEAKS The EPA defines significant spills as: 1. Releases of oil or hazardous substances in excess of reportable quantities under Section 311 of the Clean Water Act or Section 102 of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). 2. A release, as used in the above paragraph, is defined to include any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment. All spills are presently reported through the respective Division Managers, then to the Division of Environmental Management. Major spills are reported immediately to the Fire Department and the Dayton Regional Hazardous Materials Team (HAZMAT). All reportable spills are reported to the appropriate regulatory agencies. The Division of Environmental Management maintains a record of spills at Ottawa Yards. Appendix E lists the recorded outdoor spills at Ottawa Yards and Appendix H displays a copy of a copy of spill signs posted.

14 11 of NON-STORM WATER DISCHARGES Visual inspections of all outfalls were performed to identify any serious non-storm water discharges in the storm sewer system at Ottawa yards. City of Dayton staff performed outfall inspections. All inspections were made after at least 72 hours had passed since the most recent storm event. Observations are recorded on the Dry Weather Observation Form included in Appendix F. Data for Outfalls MRL-02 MRL-07 is also included in Appendix F.

15 12 of SAMPLING DATA Storm water discharge from Ottawa Yards is monitored periodically. See Appendix F for screening data.

16 13 of RISK IDENTIFICATION AND SUMMARY OF POTENTIAL POLLUTANT SOURCES EMERGENCY RESPONSE Table 7-1 presents potential pollutant sources identified during site visits and tenant interviews. Appendix D shows the location of these potential pollutant sources. Potential pollutant sources include bulk loading and unloading of storage tanks, vehicles and equipment, minimal pavement deicing, and minimal vehicle washing. Table 7-2 presents a summary of specific pollutants from potential sources. These materials may present both aesthetic (oil sheen, surfactant foam) and functional (reduced oxygen transfer, increased oxygen demand, aquatic toxicity) issues in the receiving streams. 7.1 Bulk Loading and Unloading of Storage Tanks Loading and unloading operations at bulk storage tanks have the potential for spills from the truck hose connections or from leakage from the truck. Bulk materials stored outside in above ground and underground storage tanks include waste anti-freeze, unleaded and diesel fuel, and waste oil. The primary risk for bulk loading and unloading would be due to the potential for major leakage or from rupture of delivery truck hoses. Loading and unloading operations of waste oil at the Centralized Garage have the potential for spills from truck hose connections to the waste oil underground storage tank. Flow to surface waters would be by over land flow across the asphalt surfaces. Minimal risk to surface waters would be associated with the waste oil underground storage tank Fuels and Petroleum Products The fuel farm unloading areas are covered with asphalt. Drainage from the Monument Avenue fuel farm drains through an oil/water separator prior to discharge to the storm sewer. The pavement on which the trucks load and unload from the tanks are sloped so that the area drains through an oil/water separator prior to entering the storm sewer. Minimal risk to surface water would be associated with these fuel farms and fuel oil storage because small pollutant quantities could be collected in the oil/water separator The fuel farms are equipped with the Veeder Root electronic monitoring system, which is connected via modem to a computer monitor at Fleet Maintenance. The fuel system is also equipped with Auto shut off, during filling and unloading procedures.

17 14 of 42 Table 7-1 Potential Pollutant Sources 1 Location Number Facility Activity 1 OTTAWA YARDS Maintenance Facility 2 OTTAWA YARDS Maintenance Fuel Farm Maintenance Fueling 3 Deicing Material Storage Roadway/ Sidewalk Deicing 4 Truck/ Vehicle Wash Vehicle Washing 5 Vehicle Parking Oils, Antifreeze, Debris 6 Drum Storage Facility Temporary Drum storage Table 7-1 is to be used in conjunction with Appendix D.

18 15 of 42 Table 7-2 Specific Pollutants from Potential Sources Source Bulk loading and unloading of storage tanks Vehicle fueling Vehicle and equipment maintenance Pavement deicing Vehicle washing Waste removal Deicing roads and sidewalks Vehicle and equipment parking Pollutant Gasoline, Diesel Fuel, Motor Oil, Hydraulic Fluid, Transmission Fluid, Waste Oil, Spent Antifreeze Gasoline, Diesel Fuel Antifreeze, Motor Oil, Hydraulic Fluid, Transmission Fluid Salt Detergents, debris Waste Oils, Waste Antifreeze, Solvent Wash Fluid Salt Oil, antifreeze, debris Deicing Chemicals Storage of deicing salt presents a risk of exposure when storage piles are not covered. Salt is now stored in a dome structure. 7.2 Vehicle Fueling The Ottawa gasoline dispensing facility is used for fueling automobiles and other service equipment. Gasoline and diesel fuel are stored in underground storage tanks. The potential risk would be from drips or minor fuel expansion during vehicle fueling. The facility has been equipped with breakaway hoses and auto shut off. 7.3 Vehicle Maintenance Loading and unloading operations of waste oil at Fleet Maintenance have the potential for spills from truck hose connections to the waste oil underground storage tank. Small spills are absorbed with absorbent material. There is a potential for spills when changing the oil or other fluids. Minimal risk to surface water would be associated with these. Primary risk would be due to potential for rupture of delivery trucks, or during maintenance. Regular vehicle maintenance is conducted by Fleet Management in the centralized garage. This maintenance requires the use of oils, lubricants, antifreeze, and other chemicals.

19 16 of 42 Vehicle and other equipment maintenance is generally conducted inside, with areas draining to the sanitary sewer system 7.4 Pavement Deicing Roadway deicing occurs as required by safety considerations to remove accumulations of snow and ice from traffic surfaces. Potential risk would be due to the pavement deicing materials entering the storm sewer. 7.5 Vehicle Washing There is one outdoor vehicle/equipment wash area that is designed to drain to the sanitary sewers. Although the wash station drains to the sanitary system, overspray of wash water outside of designated wash area could potentially enter the storm sewer system. Potential risk would be if cleaning materials were spilled in close proximity to the wash area and the material spilled out to areas draining to the storm sewer system. 7.6 Waste Removal Waste oil and antifreeze generated during vehicle and equipment maintenance are stored both inside and outside in drums and in USTs and ASTs until contract removal. Waste oil is also burned to heat the building. Potential risk would be from damage to drums stored outside or from leaking pumps or hoses during contract removal. 7.7 Vehicle Parking Vehicles are parked in various locations at Ottawa Yards. See Appendix D for various locations. The salvaged vehicles are drained of fluids. If a vehicle awaiting maintenance begins to leak, the leak is captured and contained to prevent discharge to the storm sewer system. Waste Collection vehicles are parked in a lot in which controls are employed to reduce the impact of runoff on the storm sewer system. Employees also use absorbent material to contain leaks from vehicles.

20 17 of BEST MANAGEMENT PRACTICES Best management practices (BMPs) are measures taken at the facility to prevent or mitigate water pollution from sources other than the manufacturing or treatment process. BMPs are broad ranging and may include processes, procedures, human actions, or construction. BMPs are aimed at preventing spills and similar environmental incidents by stressing the importance of management and employee awareness of potential spill situations. The following subsections will describe BMPs that will be included in Ottawa Yards BMP Plan. They are primarily baseline BMPs, general practice appropriate to pollution prevention in a wide range of activities. Ottawa Yards will focus on effective control of storm water pollution using the institutional and operational controls described in the baseline BMPs. If future site compliance evaluation inspections indicate specific problems, advanced, activity-specific BMPs may be incorporated in future revisions of the plan. A summary of these more advanced, activityspecific BMPs are listed in the USEPA's Guidance Document "Developing Pollution Prevention Plans and Best Management Practices." 8.1 Good Housekeeping Measures and Controls Good housekeeping practices are designed to maintain a clean and orderly work environment. The following types of good housekeeping measures are to be implemented at Ottawa Yards in an effort to prevent pollutants from entering storm water discharges Operation and Maintenance Floors and ground surfaces are kept dry by using brooms, shovels, vacuum cleaners, or cleaning machines Garbage and waste materials are regularly picked up and properly disposed Spillage is contained in the immediate area. All spillage is promptly removed Equipment is routinely inspected to make sure it is in working order. Departments and Divisions at Ottawa Yards shall document and keep records of equipment inspections at their facilities The importance of spill cleanup procedures is communicated to employees during regular meetings Material Storage Practices All containers are labeled with the name of the material, expiration date, and health hazards All drums are stored inside Adequate aisle space is provided to facilitate material transfer Containers, drums, and bags of materials are stored away from direct traffic routes to prevent accidental spills Each division/ department shall annually update the chemicals inventory section of the BMP Plan and submit to the Ottawa Yards Environmental Manager.

21 18 of Each division / department will submit annual reports to the Ottawa Yards Environmental Manager on the use, storage, or production of any "313 water priority chemicals" at their facility Employee Participation Information on good housekeeping practices and pollution prevention concepts is transmitted and discussed during employee training sessions Pollution prevention concepts are made readily available to employees Employees will annually conduct a review of spill response procedures Spill response procedures will be included as part of new employee training Pollution prevention concepts are discussed at monthly Ottawa Yards Task Force Meetings with Pollution Prevention Team Members. (See Appendix D for sign in sheet.) Oil/Water Separator Maintenance Oil/water separators are checked quarterly by Ottawa Yards maintenance, and more often when needed Each unit is cleaned on an "as needed" basis by Ottawa Yards maintenance, approximately two or three times per year, or if an oil layer is detected Outfall Maintenance/ Release The typical cleaning procedure is to place absorbent pads on the material to be removed. Materials removed are placed in 55-gallon containers, sealed, and stored inside until contract disposal is completed Disposal of absorbent pads and other material involved in the cleaning process is by EPA approved methods Vehicle and Equipment Washing Outdoor washing is restricted to the wash station located on the southeast corner of Ottawa Yards, parallel to Monument Avenue. This vehicle/equipment wash area is designed to drain to the sanitary sewer. Wash area is regularly swept. Sanitary line is regularly flushed to prevent clogging and overflows Materials Loading/Unloading Operations The following practices have been developed to minimize contamination during the loading/unloading of bulk materials into storage tanks and trucks: Equipment is routinely checked for leaks Spill response kits for minor spills are kept in close proximity to the loading/unloading areas Employees are annually updated on spill response procedures Street Sweeping

22 19 of Streets are swept by Ottawa Yards maintenance approximately once per week unless needed more frequently. Water is sprayed on pavement for dust control Street Sweeping equipment is routinely inspected by Fleet Maintenance to make sure it is working order Catch Basin Clean-Outs Ottawa Yards has a limited number of catch basins due to the general lack of curbing. These basins are checked approximately every 24 months by Sewer Maintenance Litter Control Trash and litter are picked up by waste collection two times per week. Litter is also picked up on an "as needed" basis after windstorms, vandalism, etc SNOUT Maintenance The snout is checked quarterly by Ottawa Yards maintenance, and more often when needed The unit is cleaned on an "as needed" basis by Ottawa Yards maintenance, approximately two or three times per year, or if an oil layer is detected. 8.2 Preventive Maintenance Inspections The preventative maintenance and inspection program at Ottawa Yards includes the following: Timely inspections and maintenance of storm water drains and sewers Regular inspection and testing as appropriate of tanks, fuel trucks, and fuel handling equipment and systems to uncover conditions that could cause breakdowns or failures resulting in discharges of pollutants to surface waters Proper maintenance of facility equipment and tank systems. Some of the components of the program are described in the following paragraphs Visual Inspections Inspections of outfall drains and storm sewers are conducted quarterly. Outfalls are visually inspected by sewer maintenance and environmental management staff during field screening. The following areas are routinely observed by operating staff for damage, leakage, or corrosion: Fuel farm, fuel trucks, and areas around all fuel handling equipment and tanks exposed to storm water Parking lots where fleet vehicles are parked while not in service Storm Sewer Maintenance Gratings on the storm sewer drains are cleaned of debris by Sewer Maintenance staff as needed as a result of visual inspection. The equipment owners maintain mechanical equipment in accordance with supplier recommendations.

23 20 of Equipment and Vehicle Maintenance Maintenance and repair facilities practice the following: Vehicles and equipment are routinely checked for leaking oils and fluids Defective equipment found during inspection and testing is promptly repaired or replaced Records are kept of waste oil and battery recycling Liquid wastes are not poured down drains Records of inspection and testing of equipment are kept at the facility Oil filters are drained prior to disposal or recycling Wastes are segregated and labeled Drip pans are placed under wrecked vehicles or damaged equipment Absorbent material boxes are placed in convenient locations; areas are to be swept after use Salvaged vehicles are drained of fluids Storage Tanks All AST's and UST's are to be maintained and operated in compliance with State and Federal laws. Employees are properly trained on loading/unloading and spill response procedures. Tanks and equipment are routinely inspected. USTs are monitored with electronic Veeder Root System Materials Transport Trucks Materials transport trucks are routinely inspected for drips or leaks, to minimize contamination of the storm sewer system. 8.3 Spill Prevention and Response Procedures This section outlines the tasks required to identify and characterize potential spills, how to eliminate or reduce spill potential, and how to respond if a spill should occur. It is not intended to suffice for/or replace spill plans required by other regulations. See Appendix H for a copy of the Spill Sign to be posted at Ottawa Yards Identification of Potential Spill Areas An inventory of materials handled, used, and disposed of is provided in Section 3.0 and Appendix B. Drainage areas for the facility are identified in Appendix D. From this information, it can be concluded that the areas at the facility that drain to storm water outfalls where spills are most likely to occur include: Bulk materials storage areas Vehicle storage facilities and fueling stations The major spill/release prevention measures include proper maintenance of equipment, constant attendance of the person responsible for the operation during fueling or tank filling, inspection of outdoor chemical storage, and annual employee training on spill response procedures and storm water pollution prevention awareness Identification of Spill Response Procedures and Equipment In the event that spill prevention measures fail, Ottawa yards personnel shall immediately contact the Division of Environmental Management to respond to the spill to minimize contamination of storm water. When appropriate, the Division of

24 21 of Employee Training Environmental Management will contact the Dayton Hazardous Materials (HAZMAT) Response Team. Ottawa Yards personnel are responsible for complying with all Federal, State, and local spill response and reporting requirements. Supervisors will discuss the SWP3 with employees to assure understanding. Employee training programs are instituted for all Ottawa Yards employees. Employee training is conducted annually. The intent is to inform employees of the components, goals, and requirements of the plan. New employees review the plan during the first week of their employment. The training program for existing employees, as well as new employees, will address spill prevention and response procedures, good housekeeping, and material management practices. A brief description of each is outlined below Spill Prevention and Response Procedures Employees involved in the storm water pollution prevention program review potential spill areas and drainage routes at Ottawa Yards Employees review instructions on how to report spills and the appropriate individuals to contact Proper material handling procedures and storage requirements are discussed Employees responsible for spill response activities are taught how to quickly and safely implement spill response procedures Good Housekeeping Employees are instructed to promptly clean up spilled materials to prevent storm water pollution Locations of housekeeping and spill response materials are provided to all employees Materials Management, Wash down, and Fueling Practices Employees are instructed to maintain materials in an organized manner Outdoor vehicle washing is prohibited at Ottawa Yards except the wash area where drainage is connected to the sanitary line. An approved washing plan is in place, which collects all significant pollutants before entering the storm water conveyance system Pans are used to collect waste oil during engine maintenance. Pans are promptly emptied into waste oil receptacles Fuel truck operators will remain present during all fueling operations. 8.5 Sediment and Erosion Control Activity at Ottawa Yards (typically construction projects) that have the potential to affect the quality of storm water shall comply with the following: Projects involving earth-disturbing activities of one (1) acre or more require an OEPA NPDES General Permit for Construction, including the development of an SWP3. The SWP3 must conform to the specifications of Rain Water and land Development, Ohio s Standards for Storm Water Management Land Development and Urban Stream Protection.

25 22 of In addition, all projects involving earth-disturbing activities of one (1) acre or more must comply with the City of Dayton Revised Code of General Ordinances, Chapter 54, Storm Water Management. The rules and standards require the submittal of an approved Storm Water Management Plan to the City of Dayton Water Engineering Department. 8.6 Management of Runoff and Activity-Specific BMPs Storm water runoff at Ottawa Yards is managed by storm sewers. Locations of storm sewers are shown in Appendix D.

26 23 of SITE COMPLIANCE AND PLAN EVALUATION The Environmental Manager or named designate will conduct an annual review to: Confirm the accuracy of the description of potential pollutant sources contained in the BMP Plan. Determine the effectiveness of the plan. Assess compliance with the terms and conditions of the storm water permit. The Environmental Manager conducts the comprehensive site compliance evaluation. During the evaluation, material handling and storage areas and other potential sources of pollution will be visually inspected for evidence of actual or potential pollutant discharges to the drainage system. Erosion controls and structural storm water management devices will also be inspected to ensure that each is operating correctly. Worksheets are provided to assist in the inspection. See Appendix G for inspection forms. The results of each inspection will be documented and filed by the Environmental Manager. Based on the results of each inspection, the Plan, including the description of potential pollutant sources and implementation of measures and controls, will be revised (if appropriate). If the inspection report lists changes at the site that have a significant effect on the potential for the discharge of pollutants to surface waters, the BMP Plan will be amended to describe the changes.

27 24 of 42 RECORD KEEPING AND REPORTING A record keeping system has been set up by City of Dayton, Ottawa Yards Facility for documenting spills, leaks, and other discharges, including discharges of hazardous substances in reportable quantities. Typically, the records contain the following information: Date and time of the incident Weather conditions Duration of the spill/leak/discharge Cause of the spill/leak/discharge Response procedures implemented Persons notified Environmental concerns associated with the spill/leak/discharge Division of Environmental Management (DEM) retains records of inspections, maintenance, and training. Records of spills and other discharges exposed to storm water, training records, inspections, and maintenance activities are retained in the BMP Plan for at least 1 year after the expiration of the Ottawa Yards Facility NPDES Permit. Monitoring records are presently required by the permit for this facility, and will be filed and available upon request at the Division of Environmental Management Office.

28 25 of SPECIAL REQUIREMENTS 11.1 Section 313 Special Requirements Section 313 of the Emergency Planning and Community-Right-to-Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act (SARA), requires operators of manufacturing facilities that handle toxic chemicals in amounts exceeding threshold levels to report to the government on an annual basis. The EPA established specific control requirements in its general permits for specific "water priority chemicals." If these chemicals are used or stored, a material handling/control plan must be developed for the facility and certified by a registered engineer. A complete Chlorine Risk Management Plan (RMP) is kept on file Salt Piles The location of the salt barn is indicated on facility drawing Attachment D Discharge to Large or Medium Separate Storm Sewer Systems The facility is located in the City of Dayton and therefore is part of the municipal separate storm water system Coal Piles The facility does not have a coal pile.

29 26 of 42 APPENDIX A NOTICE OF TERMINATION GUIDANCE FOR MS4 OPERATED INDUSTRIAL FACILITIES

30 27 of 42 APPENDIX B LIST OF INVENTORY

31 28 of 42 Potentially Exposed Materials Facility/ Use Material CAS No. 1 Quantity Used Quantity Stored Location Fleet Mgmt / Vehicle Fueling Diesel Fuel Tank 457,940 gal/year 2/20,000 gallon UST UST located on Monument Avenue at the Centralized Fueling Station south east of Ottawa Yard Fleet Mgmt/ Vehicle Fueling Unleaded 87 Octane 580,974 gal/year 2/20,000 gallon UST UST located on Monument Avenue at the Centralized Fueling Station south east of Ottawa Yards Fleet Mgmt/ Vehicle Fueling Motor Oil 10,000 gal/year 2/1,000 gallon UST UST located on Monument Avenue at the Centralized Fueling Station south east of Ottawa Yards Fleet Mgmt / Vehicle Maintenance Fleet Mgmt / Vehicle Maintenance Fleet Mgmt / Vehicle Maintenance Motor Oil 15W40 Hydraulic Oil AW32 Hydraulic Oil AW40 8,500 gal/year 9,200 gal/year 8,500 gal/year 8,000 gallon UST 8,000 gallon UST 8,000 gallon UST UST is located under a concrete pad on the west side of the Fleet Maintenance building in a tank farm area between the garage doors UST is located under a concrete pad on the west side of the Fleet Maintenance building in a tank farm area between the garage doors UST is located under a concrete pad on the west side of the Fleet Maintenance building in a tank farm area between the garage doors Fleet Mgmt / Vehicle Maintenance Transmission fluid 1,800 gal/year 2,500 gallon UST UST is located under a concrete pad on the west side of the Fleet Maintenance building in a tank farm area between the garage doors Fleet Mgmt / Vehicle Maintenance Waste Oil Tank (Motor oil 15W40, Hydraulic Fluid, Transmissio n fluid, Tractor Oil, Gear Oil) 7,200 gal/year 8,000 gallon UST UST is located under a concrete pad on the west side of the Fleet Maintenance building in a tank farm area between the garage doors

32 29 of 42 Facility/ Use Material CAS No. 1 Quantity Used Quantity Stored Location Fleet Mgmt / Vehicle Maintenance Antifreeze and Coolant 1300 to 1400 gal/year 55 gallon drum/50 to 55 gallon shipment Drum is stored inside the building in a room located in the center of the garage east end Fleet Mgmt / Vehicle Maintenance Antifreeze (waste) 1000 gal/year 2,500 gallon UST UST is located under a concrete pad on the west side of the Fleet Maintenance building in a tank farm that is located between two garage doors Fleet /Parts Washers WS&T/ Recalcinated lime used in water treatment process Tekusolve Variable 8-30 gal, 5-16 gal, 2-14 gal Lime Variable ½ million tons (two basins) Stored in various locations around the building The Lime Kiln is located at the far east end of Ottawa Yards, northeast of the Ottawa Water Treatment Plant, the Lime retention basins are located on the far eat end of the Water Treatment building WS&T/Compon ent of water treatment process Hydrofluoric Acid Variable 6,000 gallon AST Located on the west side of the Water Treatment building between the road and the parking lot, there is a small grassy area (walkway) around the tank WS&T/Used in water treatment process Chlorine Variable one ton cylinders South of Water Treatment Plant, inside of the chlorine building, on concrete floor WS&T/Waste drums WS&T/Mainten ance Building Waste Petroleum Products Petroleum Acids Variable Variable Two story drum cabinet located just inside security gate. Variable Variable Inside Maintenance Building. Street Main/. Painting Street Lines Fast Dry Paint 4,620 gal/year gal drums, gal drums Stored inside maintenance storage building/garage on the west end of the Truck Station

33 30 of 42 Facility/ Use Material CAS No. 1 Quantity Used Quantity Stored Location Street Main/To manage ice and snow covered roadways Salt Variable 7.5K tons (inside) The salt dome is located center of the east side of Ottawa Yards inside of the building on a paved surface Street Main/To manage ice and snow covered roadways Calcium chloride Variable Two 5,500 gallon ASTs ASTs located west of the salt dome. Waste Collection/Colle ction of solid waste Solid Waste/ Waste Collection Trucks Trucks are parked in a paved parking lot area at the southeast end of Ottawa Yards, located just north of the DP&L transformers Cleaning trucks Debris, leaves, grass, dirt, etc. Variable Variable The truck wash station is located on the southeast side of the Ottawa Yards, slightly surrounded by grassy and soil area on the west sand southern portion of the truck wash pad Drum storage area (Temporary storage of misc. items collected during abandoned drum/ emergency response activities) Variable Variable Variable The Drum storage area is located east of Waste Collection and south of Fleet Management. Drums stored inside and under cover. Oil/Water Separator For waste oil and vehicle fluid runoff Variable Variable At the end of the storm line that drains the parking lot where the garbage trucks park. Trash containers Mulch and Soil Piles Variable Variable Variable Outside of the Waste Collection building near Fleet Management. Variable Variable Variable North of the Salt Barn south of the fence.

34 31 of 42 Salvage vehicles Variable Variable Variable East of the Salt Barn, west of the guard station. Vehicles for Maintenance Variable Variable Variable West of the Fleet Management building.

35 32 of 42 APPENDIX C LIST OF 313 WATER PRIORITY CHEMICALS

36 33 of 42 APPENDIX D OTTAWA YARDS SITE PLAN

37 34 of 42 APPENDIX E LIST OF SIGNIFICANT SPILLS AND LEAKS

38 35 of 42 APPENDIX F DRY WEATHER OBSERVATION FORM

39 36 of 42 APPENDIX G INSPECTION WORKSHEETS

40 37 of 42 APPENDIX H SPILL / RELEASE REPORTING REQUIREMENTS - OTTAWA YARDS SPILL SIGN