Storm Water and SPCC Plan Best Management Practices Presented To: 2015 IMAA Winter Workshops February 2, 3 & 4, 2015

Transcription

1 Storm Water and SPCC Plan Best Management Practices Presented To: 2015 IMAA Winter Workshops February 2, 3 & 4, 2015 Mack Overton, VP Industrial Services KERAMIDA, Inc.

2 Stormwater Rule Purpose is to limit both excessive flow and pollutants from entering surface water. Regulates construction sites greater than 1 acre in size. Regulates industrial facilities within specific SIC Codes and exposure of potential pollutants sources to stormwater. 2

3 Storm Water Rule Requirements Notice of Intent Submission Develop Storm Water Pollution Prevention Plan Identify Potential Pollutant Sources Complete Periodic Sampling; Report Results Conduct Training Perform Inspections Determine Best Management Practices Submit Annual Report 3

4 Storm Water Rule Requirements USEPA MSGP USEPA s MultiSector General Permit Provides guidance for all industry sectors covered by the stormwater regulations. Stipulates sampling parameters and numeric discharge limits for those specific sectors. Identifies recommended Best Management Practices for potential pollutant sources 4

5 Storm Water Rule Requirements State Implementation Tennessee Numeric Effluent Limitations Kentucky Numeric Effluent Limitations Ohio Numeric Effluent Limitations Illinois Quarterly Visual Inspections Michigan Sampling & Effluent Limitations in Certain Industries 5

6 IDEM Draft Storm Water Rule IDEM in process of modifying the existing Storm Water Rule Proposed rule anticipated to be published in 2014, with final rule implemented by the end of the year The proposed rule will be very similar to the MSGP. 6

7 Best Management Practices (BMPs) This is the heart of your Stormwater Pollution Prevention Plan (SWPPP) Must have BMPs that address all sources of stormwater contamination Outdoor Storage Loading/Unloading Waste Storage Parking Area Runoff / Bare Soil Erosion Air Emissions / Rooftop Stacks Outdoor Washing 7

8 BMPs Outdoor Storage Covered Containers Covered storage areas 8

9 BMP Examples Covered Dumpsters 9

10 BMP Examples OR Under Roof 10

11 BMPs Loading/Unloading Covered Areas Containment 11

12 BMP Examples Covered Loading Bays 12

13 BMP Examples Secondary Containment Double Walled Tanks AND Loading Procedures 13

14 BMPs Waste Storage Good Housekeeping Covered Storage 14

15 Waste Storage 15

16 Waste Storage 16

17 BMPs Parking Areas Runoff / Bare Soil Erosion Catch Basin and Drain Controls End of pipe controls 17

18 BMP Examples 18

19 Catch Basins 19

20 Drain Plug 20

21 Drain Mat 21

22 Drain Mat 22

23 BMP Examples Gate Valve Shut-offs at all outfalls Spill containment (Stormwater and SPCC) 23

24 BMP Examples Gate Valve Shut-offs at all outfalls Spill containment (Stormwater and SPCC) 24

25 Plant Roof Don t Forget the Out-Of-Sight Areas Before After 25

26 Small Changes in Equipment Can Lead to Big Changes in Pollution Prevention 26

27 Never Assume All Is Well At the End Of The Pipe 27

28 No Single Solution Fits Every Outfall 28

29 Temporary Discharge Solution or Secondary Protection at End of Pipe Discharge 29

30 Oil Spill Prevention, Control and Countermeasures Plan (SPCC) Goal: To prevent oils spills from impacting navigable waters. Focus is upon aboveground containers of oil or oil products 55 gallons in volume or greater. 30

31 The Evolution of SPCC Beginning in 2002, a series of rule revisions were instituted, bringing SPCC interpretation and enforcement to a new level. As of May 10, 2013, all SPCC Plan are to be prepared and implemented. As with all EPA rules, there is a large layer of interpretation and guidance that was not present ~ 5 years ago. Rule provides the framework. However, applying guidance documents is critical. 31

32 SPCC Plan Areas of Focus Security Fencing Lighting Loading Areas Integrity Testing Operating Equipment 32

33 SPCC Plan Requirements Tier I vs. Tier II Summary Tier I can be used if less than 10,000 gallons total storage, and no spills exceeding 1,000 gallons have been reported. Requires that the SPCC Plan be generated in compliance with USEPA requirements. Does not require PE signature Tier II the standard approach to the SPCC Plan is to be used in other instances 33

34 Loading and Unloading Tanker Trucks Is containment required for loading areas? Loading Rack Containment Required No Loading Rack General containment requirements need to be met Berms, Curbing, Diversion to Ponds, Absorbents, Etc. 34

35 No Loading Rack General containment requirements (112.7(c)) Berms, Curbing, Diversion to Ponds, Absorbents, etc. 35

36 Loading Rack Loading Rack 36

37 Loading and Unloading Tanker Trucks Per EPA Regional Inspector s Guideline: Areas utilizing a single hose and connection or standpipe are not considered racks. 37

38 Integrity Testing Bulk Storage Containers 112.8(c) requires Visual inspection, plus Hydrostatic OR Ultrasonic Radiographic OR Acoustic Regular Intervals based on type of test $$$$ vs. Risk Small tanks, drums, totes 38

39 Integrity Testing Bulk Containers EPA Letter <30,000 gallon shop-built containers Visual inspection + Elevated + All sides visible Visual inspection + Barrier to ground + immediately detect leaks Totes and drums Single-use Frequent visual inspections for leaks, deterioration, etc. 39

40 Oil Filled Equipment Oil filled electrical, operating, or manufacturing equipment Not considered bulk storage containers but they are still regulated. 40

41 Oil Filled Equipment Meet general secondary containment standards (112.7(c)) Berms, Curbing, Ponds, Absorbents, Route to Retention pond, etc. Alternative (112.7 (k)) - If you have a good spill history Implement an inspection and monitoring program (written) Written contingency plan for response to spills 41

42 Wastewater Treatment (Specifically Oil / Water Separators) Wastewater Treatment Units are exempt However, in some cases an Oil / Water Separator may be regulated 42

43 Bulk Storage Container in O/W Separator Stores oil until pumping into a tanker truck = Regulated Bulk Storage Container Oil / Water Separator 43

44 Integration of SPCC and SWPPP Combine certain aspects of both plans Inspections Plan Reviews Training Complete Integrated Plan to address compliance with both requirements. 44

45 Plan Integration Considerations Advantages Most areas are regulated by both rules Many preventive measures are the same Contingency and response measures are the same for both rules Combine Training of personnel into one session Combine inspections into one walk-around and document 45

46 Plan Integration Considerations Disadvantages Can be difficult for inspectors and auditors to assess compliance with specific rule requirements. Hard to balance meeting the rule requirements with providing a document that is useful in practice. Records Management 46

47 Integrate Compliance Activities Inspections SWPPP Contamination Sources BMPs Outfalls Inspections SPCC Regulated Areas Containment Units Spill Kits / Equipment 47

48 Integrate Compliance Activities Training SWPPP Personnel responsible for exposed areas or BMPs Training SPCC Oil-handling personnel Training Frequency Annual and when assigned 48

49 Inlet Protector 49

50 Sediments Capture 50

51 Sediments and Oils 51

52 Hydrocarbon Absorbents Absorb hydrocarbons into absorbent pillows 52

53 Hydrocarbon Absorbents Absorbs Petroleum and Expands 53

54 Just like conventional absorbent except It only holds petroleum (not water) and It expands 54

55 Used to absorb oils from transformer area 55

56 Sediments /Oils / Organically bound Metals 56

57 Various filtering media Sediments /Oils / Organically bound Metals Hydrocarbons also absorb on media 57

58 Oil Removal 58

59 Oil Removal 59

60 Drain Plug 60

61 Secondary Containment 61

62 We see New Products every month 62

63 Questions? 63