KANSAS CITY, MO INDUSTRIAL FACILITY INSPECTION FOR MS4 PROGRAM

Transcription

1 KANSAS CITY, MO INDUSTRIAL FACILITY INSPECTION FOR MS4 PROGRAM Storm Water Pollution Prevention, Control, Reduction and Minimization In Compliance with Kansas City, MO Municipal Separate Storm Sewer System (MS4) Permit Date: May 31, 2005 Prepared by: Water Services Department Kansas City, MO DRAFT

2 I. Introduction Storm water runoff is part of the natural hydrologic cycle. However, human activities, particularly urbanization, can alter natural drainage patterns and add pollutants to the rainwater and snowmelt that runoff the earth s surface and enter our Nation s rivers, lakes, streams, and coastal waters. In an effort to reduce the pollution of the Waters of the United States, the Environmental Protection Agency (EPA), as directed by Congress, has established phased National Pollutant Discharge Elimination System (NPDES) requirements for storm water discharges. To implement these requirements, EPA published the initial permit application requirements for certain categories of storm water discharges associated with industrial activity and for discharges from municipal separate storm sewer systems (MS4) located in municipalities with a population of 100,000 or more (Phase I sources). Pursuant to the Federal requirement, under the authority granted to the State of Missouri and in compliance with the Missouri Clean Water Law, Missouri Department of Natural Resources (MDNR) issued Kansas City, MO State Operating Permit to discharge from Kansas City Municipal Separate Storm Sewer System on September 3, In Kansas City, MO s MS4 permit, Part III.A.5. states the following: The permittee will implement a program to monitor and control pollutants in storm water discharges to the MS4 from hazardous waste treatment, disposal, and recovery facilities; industrial facilities that are subject to SARA Title III section 313 and other industrial or commercial facilities that the permittee determines are contributing or have the potential to contribute a substantial pollutant loading to the MS4, by a. [ ]. b. [ ]. c. Developing an inspection or self-auditing program to assess these facilities. This inspection program can be combined with other existing inspection program (i.e., pretreatment) where applicable. d. [ ]. e. [ ]. Recognizing that industrial facilities have a potential to impair the quality of storm water discharges from the MS4, and to ensure the City s compliance with its permit, the STOMP-IT team working for KCMO MS4 permit has developed a set of inspection procedures (see Attachment) to evaluate industrial facilities and to determine their contribution to the MS4 and potential impacts to the receiving waters. DRAFT 2

3 This document is designed to assist inspectors in understanding the purpose and scope of the industrial facility inspection with regard to storm water pollution, and use of the inspection procedures developed for the MS4 permit. It is not intended to replace any necessary relevant training. Be advised that inspectors shall take all appropriate training as specified by their supervisors prior to performing any official inspections. II. The Purpose of Inspection To promote and enhance the industrial awareness to the potential of storm water pollution to receiving streams and lakes; To identify industrial facilities and their activities that significantly contribute or have the potential to contribute pollutants to the MS4, and to take appropriate actions, including, but not limited to, requiring control methods (Best Management Practices) implementation, and enforcement actions; To evaluate industrial facilities for their runoff management practices and to determine their contribution to the MS4 and potential impacts to the receiving waters. The ultimate goal is to prevent, control, and minimize pollutant runoff from industrial operations. III. The Frequency of Inspection There are a total of 138 industrial facilities listed in the Industrial Facility Inventory for Kansas City, MO MS4 program as of April, It is anticipated that the list will be modified with the appropriate justification in subsequent permit years. Thus, for each coming permit year (e.g., May, 2006 April, 2007) during the first permit term, approximately 35 facilities shall be inspected by two full-time employees, following the procedures as specified in this manual. DRAFT 3

4 IV. The Scope of Inspection The inspector(s) shall request (and review later) from the facility copies of any existing pollution prevention plans, any existing environmental permits, any existing storm water sampling data, and any enforcement actions related to environmental issues that the facility has received within the last three years. The inspector(s) and facility representative(s) shall walk through all indoor and outdoor areas, and observe activities: (1) where the activities might impact storm water quality, and (2) where it is safe to do so. Examples of activity areas that might pose pollution potential to storm water are material storage area, loading/unloading areas, and refuse sites. When inspecting he site, the inspector shall request to be informed of the locations of spills and leaks within the last three years. The inspector shall attempt to understand how runoff leaves the site and gets into the MS4 system by observing site grading and all portions of the storm water conveyance system, where accessible and safe. This might include swales, enclosed systems, inlets, outfalls, open channels, etc. The inspector shall observe the condition of storm water structures (e.g., junction boxes, inlets, outfalls, open channels, etc.), where accessible and safe. The inspector shall observe the condition of all runoff pollution prevention structures, such as detention basins, swales, and erosion and sedimentation control features. The inspector shall identify the potential pollution sources, evaluate the runoff management practices, attempt to assess the facility s actual and potential impacts on storm water quality, and communicate with the facility representative when appropriate. The inspector shall use a standard site map (as described in V. Site Map Preparation) and inspection form (see attachment), take notes of what is observed, and take photos as appropriate. The inspector may collect samples of suspicious flow that are non- permitted, nor storm water by itself, and that are present either in the facility s storm water drainage system, or in its discharge to the City s MS4. DRAFT 4

5 IV. Inspection Procedures Inspection Procedure Flow Chart Decide the Facility to be Inspected 1 Contact Site Map Preparation (See section V.) Existing File/Database Review Site Inspection 2,3 Opening conference Identify potential pollutant sources - Outdoor walk through - Indoor walk through - Suspicious flow collection Evaluate potential pollution impact Examine pollution prevention measures Assess Best Management Practices Document inspection activities Closing conference Inspection Report and Follow-up Complete inspection documentation Complete report Update the database Identify Corrective Actions 4 DRAFT 5

6 Note: 1. There are several reasons that an inspector may decide to perform an inspection: Annual inspection of the facilities that are listed in the Inventory; Emergency response; Complaint driven-by; Others. 2. The inspection areas for a facility shall cover, but not be limited to, the following: Industrial plant yards; Immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-products used or created by the facility; Material handling sites, including storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product, by-product or waste product; Refuse sites; Sites used for the application or disposal of process waste waters; Sites used for the storage and maintenance of material handling equipment; Sites used for residual treatment, storage, or disposal; Shipping and receiving areas; Manufacturing buildings; Storage areas (including tank farms) for raw materials, and intermediate and final products; Areas where industrial activity has taken place in the past and significant materials remain and are exposed to storm water; and Other areas from where storm water will drain into MS4. 3. Significant materials, of concern if exposed to precipitation, may include: Raw materials, fuels, solvents, detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production; hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required to report pursuant to section 313 of title III of SARA; fertilizers; pesticides; and waste products such as ashes, slag and sludge that have the potential to be released with storm water discharges. 4. Corrective Actions: The staff is working on setting up the Corrective Actions and adding this content to the City Ordinance. Please refer to City Ordinance Chapter 63 for potential details. DRAFT 6

7 V. Site Map Preparation A site map to be prepared for this inspection purpose shall, at a minimum, include the following information: An aerial photo or a planimetric map showing: - Building/structure footprints; - Streams/lakes/ponds; - Roadways, sidewalks, and parking lots. Sewer systems, denoting: - Combined Sewer System and/or Separate Storm Sewer System; - System elements, such as outfalls, catch basins, inlets, junction boxes, and etc.; Contour lines Facility legal name / Basic legend / Scale / North direction DRAFT 7

8 INSTRUCTIONS INDUSTRIAL FACILITY INSPECTION FORM FOR MS4 PROGRAM Section A: GENERAL INFORMATION Site #: Look up the Inventory for Site #; Inspection Reference: (Year-Month-Date-Hour) Map #: The same as Site #; Facility Name: Provide the complete legal name of the facility to be inspected; Site Address: Provide the detailed address of the facility primary activities; Mailing Address: Provide the detailed mailing address of the facility s major contact person; Contact Person: Provide the name of the facility s major contact person; Facility Representative: Provide the name of the facility s representative (s) on site for inspection; Date and Time: Provide the exact time and date that the inspection is conducted; Weather: Record the weather condition when the inspection is conducted. Watershed: Provide the name of the watershed where the facility s primary activities are located; Combined or Separate System: Check whether the facility s primary activities are located within the Combined Sewer System area (North-South: Missouri River-85th Street; East-West: Blue River- State Line), or within Separate Storm Sewer System area. TRI TSD SIU Tier II LQG: Check which of the following list (s) the facility belongs to; TRI: Missouri Toxic Release Inventory; TSD: Missouri Hazardous Waste Facility List; SIU: Kansas City, MO Significant Industrial User List; Tier II: Missouri Emergency and Hazardous Chemical Inventory LQG: Missouri Hazardous Waste Large Quantity Generator List. Environmental Permits: Any type of existing Missouri permits that are related to environmental issues. Examples: Air Emission Permit, Storm Water Permit, Hazardous Waste Management Facility Permit, etc. DRAFT 8

9 Section A: GENERAL INFORMATION (CONT D) Exp. Date: The expiration dates of the above-listed permits. Prior Sampling Data: Indicate whether the facility has any previous storm water monitoring data. Spill in last 3 yrs-date: Check whether there is (are) any leak (s) or spill (s) that occurred at the site during the past three yeas, and if any, list the date (s). Major Operation: Specify the primary industrial activities at the site. SIC Code: Standard Industrial Classification Code; Inspectors: List the full names of the inspector (s). Section B. SITE MANAGEMENT PRACTICES Note: this section might be filled after Section D on the second page of this checklist. P2 (Pollution Prevention) Measures Material handling training: - Check if the employees receive regular material handling training; Preventive maintenace: - Check if there is a preventive maintenance program that involves inspections and maintenance of storm water management devices and routine inspection of facility operations to detect faulty equipment (e.g., tanks, containers, and drums); Or - Check if equipments (such as tanks, containers, and drums) are checked regularly for signs of deterioration. Fleet washing: hauled / sewered: - Check if the on-site vehicle washing is collected and disposed off-site, or disposal on-site with permit; DRAFT 9

10 Section B. SITE MANAGEMENT PRACTICES (CONT D) Good housekeeping: - Check if the facility, in general, maintains a clean and orderly work environment; Some practices include improving operation and maintenance of industrial machinery and processes; implementing careful material storage practices, maintaining up-to-date material inventory, scheduling routine cleanup operations, maintaining well-organized work areas, and providing employees good housekeeping practice training; Trained in good housekeeping: - Check if employees receive good housekeeping training; Storm drain (s) cleaning: - Check if the storm drainage system are cleaned on a regular base; Spill plan: - Check if the facility has a spill plan for the site and request a copy; Response training: - Check if employees receive Spill Response training; Previous inspection record: - Check if the facility has previous compliance record (past 3 yrs), and if yes, request a copy. Storm P2 Plan-Date: - Check if the facility has a Storm Water Pollution Prevention Plan (SWPPP), and if yes, request a copy, and record the last update date. CONTROL MEASURES Sump around fueling area: - Check if there is sump around fueling area; Spill kit: - Check if the spill kit is kept in an appropriate position and is in good condition; Retention/Detention: - Check if there is any retention/detention device; DRAFT 10

11 Section B. SITE MANAGEMENT PRACTICES (CONT D) Vegetated swales: - Check if there is vegetated swales; Flow diversion structure: - Check if there is any flow diversion structures. Erosion control: - Check if there is any erosion control devices; Stormwater treatment: - Check if there is any structure or device that treat storm water before it runs off the site; Sediment trap: - Check if there is any sediment trap to control sediment washed off the site; Other: - Check if there is any other structural or non-structural measures that control storm water pollution. Section C. ADDITIONAL COMMENT It might include: Description of changes of operational activities, schedule, and major personnel, if any; Description of any additional details about the potential pollutant sources that have been recorded earlier; Description of any other potential pollutant sources of concern that are not covered in the form; Description of the facility s Best Management Practices, i.e., stormwater pollution prevention measures and pollution control measures; And Other pertinent information. DRAFT 11

12 Section D. POTENTIAL POLLUTANT SOURCES Loading Area: Fill in the block under Loading Area if the inspected area is for loading/unloading function Total Number of Loading Areas: Specify the total number of loading areas at the site; Area #: Specify Area # as marked on the site map; Truck Dock Rail Spur Other: Check the transportation types used for loading/unloading; Containment Type: Specify the containment type; Covered Impervious Surface Drain : Check the area if it s covered, or if its ground is impervious surface; and specify where the ground drains, to sanitary sewer, separate storm sewer, or to natural streams, swales, etc. Comments: Describe any activities or material (including waste) handling practices that have potential to cause storm water pollution as observed, and any other pertinent information. Storage Area: Fill in the block under Storage Area if the inspected area is for storage function Total Number of Storage Areas: Specify the total number of storage areas at the site; Container Type: Describe container type; Stored Material: List major chemicals stored at site; Covered Containment Impervious Surface: Check whether material is correctly covered, or contained, and whether the ground is impervious surface. Comments: Describe any activities, material (including waste) handling practices, or container condition that have potential to cause storm water pollution as observed, and any other pertinent information. Other Areas of Interest: Fill in the block under Other Areas of Interest if the inspected area is for any activity areas that may have potential to cause storm water pollution. Total Number of Other Areas: Specify the total number of other areas at the site; DRAFT 12

13 Section D. POTENTIAL POLLUTANT SOURCES (CONT D) Area #: Specify Area # as marked on the site map; Runoff Direction: Indicate the direction of surface runoff, e.g., NW (northwest). Also check if the runoff enters any of the following systems: MS4 (Separate Storm Sewer System), CSS (Combined Sewer System), SSS (Sanitary Sewer System), or Environment. Idle Equipment: Check if there is (are) idle equipment at site; Trash Dumpster: Check if there is (are) trash dumpster (s) at site; Roof Drains: Check if there is (are) roof drain (s) at site; Floor Drains not to Sanitary: Check if the floor does not drain to a Sanitary sewer system; Exposure to Stormwater: Check if there is any significant material or activity, that is (1) of concern with regard to storm water pollution; and (2) exposed to precipitation; Illicit Discharge: Check if there is any discharge to a municipal separate storm sewer that is not composed entirely of storm water except discharges pursuant to a NPDES permit and discharges resulting from fire fighting activities; Other: Check if there is any other items of concern to storm water quality; Drainage System: Type: List major storm water control structure types. Comments: Describe any activities, material (including waste) handling practices, or container condition that have potential to cause storm water pollution as observed, and any other pertinent information. DRAFT 13