Good Housekeeping and Spill Response

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1 Good Housekeeping and Spill Response Presented By: Michele Loudenback, R.P.E.S Carrie J. Evenson, Ph.D., P.E. Industrial Wastewater Enforcement Section Water Quality Division Department of Environmental Quality

2 Pollution Prevention and You Presented By: Michele Loudenback, R.P.E.S Industrial Wastewater Enforcement Section Water Quality Division Department of Environmental Quality

3 Outline Structural vs. Non-structural Controls Permit Requirements Good Housekeeping Exposure Minimization Preventive Maintenance Spill Prevention and Response Other Controls Salt Storage Hazardous Materials Sector Specific Requirements

4 Structural vs. Non-structural Controls Structural control measures focus on installation of engineered or constructed structures to control discharges. Detention/Retention Ponds Temporary or Permanent Coverings Catch Basin Inserts Stormwater Conveyances

5 Structural vs. Non-structural Controls Non-structural control measures are intended to prevent or reduce the amount of pollutants getting into stormwater using practices that focus on facility operations and procedures. Preventive Maintenance Employee Training Spill Response Procedures Facility Inspections

6 Permit Requirements Section of the OKR05 Requires consideration of several types of BMPs, both structural and nonstructural If you determine that the listed BMPs are not appropriate, you have to explain why in your SWP3

7 Permit Requirements Non-structural BMPs that must be considered: Good Housekeeping Exposure Minimization Preventive Maintenance Spill Prevention and Response Procedures Routine Facility Inspections Employee Training

8 Good Housekeeping

9 Good Housekeeping All exposed areas of the facility must be kept in a clean, orderly manner Practical and cost-effective Can improve operation efficiency Enhances safety and improves work environment

10 Good Housekeeping Must have: Regular schedule for pickup and disposal of garbage and waste materials Routine inspections for the condition of drums, tanks, and containers

11 Good Housekeeping Things to consider (document use in SWP3): Maintaining clean work spaces Labeling storm drains and BMPs Practicing good inventory management

12 Good Housekeeping Things to consider (document use in SWP3): Labeling and storing industrial materials properly Regularly sweeping paved surfaces Utilizing procedures and training personnel for emptying drip pans under leaking items

13 Good Housekeeping Common problem areas include: Trash container proximity and adjacent areas Material storage and handling areas

14 Good Housekeeping Common problem areas include: Vehicle and equipment maintenance areas Loading and unloading areas

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19 Exposure Minimization

20 Exposure Minimization Minimize the exposure of manufacturing, processing, and material storage areas to rain, snow, snowmelt, and runoff by exploring and seizing opportunities to relocate activities/materials to covered or contained areas.

21 Exposure Minimization The areas in question include: Loading/unloading docks or areas Storage areas Disposal containers Vehicle/equipment maintenance areas Fueling operations Vehicle/equipment cleaning areas

22 Exposure Minimization Things to consider (document use in SWP3): Using grading, berming, or curbing to contain runoff and divert run-on Using spill/overflow protection equipment Using dry methods (absorbents) to clean up spills and leaks promptly

23 Exposure Minimization Things to consider (document use in SWP3): Using drip pans and absorbents under/around leaky vehicles Putting materials, equipment, and activities in areas where containment and diversions systems can contain leaks

24 Exposure Minimization Things to consider (document use in SWP3): Draining fluids from equipment and vehicles before storing or disposing on site Performing cleaning operations indoors, under cover, or in bermed areas that prevent runoff /run-on and capture overspray

25 Exposure Minimization Things to consider (document use in SWP3): Ensuring wash water drains to a collection system NOTE: Discharge of vehicle and equipment wash water is NOT authorized by OKR05 need a separate OPDES permit for this

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30 Preventive Maintenance

31 Preventive Maintenance Maintenance program procedures should ensure that control measures and industrial equipment are kept in good operating condition to prevent or minimize leaks or other pollutant discharges and should be described with schedules in the SWP3

32 Preventive Maintenance Things to consider (document use in SWP3): Regularly inspecting, testing, maintaining, and repairing all industrial equipment and systems that have the potential for exposure to stormwater Maintaining all equipment in effective operating condition

33 Preventive Maintenance Things to consider (document use in SWP3): Maintaining all control measures in effective operating condition. Making sure all non-structural control measures are maintained (spill kit resupply, employee training, etc.)

34 Preventive Maintenance Things to consider (document use in SWP3): If control measures are not operating correctly, maintenance must be performed before the next anticipated storm event

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36 Pictures Preventive Maintenance

37 Spill Prevention and Response

38 Spill Prevention and Response Minimize the potential for leaks, spills, and other releases that may be exposed to stormwater Develop plans for timely and effective cleanup of spills if/when they occur SPCC plan should be referenced in SWP3 Spill prevention and response checklist available at: ibit%207%20spill%20prevention%20and%20response%20proced ures%20checklist_august2011.pdf

39 Spill Prevention and Response Things to consider (document use in SWP3) Ensuring material handling procedures are effective, material storage is appropriate, and equipment, like diversion valves, is in use Labeling containers that are often spilled or leaked properly ( Used Oil, Spent Solvents, Fertilizers and Pesticides, etc.) encouraging careful handling and rapid response

40 Spill Prevention and Response Things to consider (document use in SWP3) Using measures such as barriers between storage and traffic areas and secondary containment Having effective and timely procedures for cleanup of spills/leaks Keeping and maintaining equipment on site for cleanup

41 Spill Prevention and Response Things to consider (document use in SWP3) Training employees on procedures and equipment for cleanup NOTE: Procedures for hazardous material cleanup must meet RCRA regulations (40 CFR Parts 264 and 265) Keeping and maintaining notification procedures and information for reporting spills/leaks (ie, appropriate facility personnel, emergency response entities, regulatory agencies)

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44 Other Controls Attention should be given to other controls to help with pollution prevention. Things to consider (document use in SWP3): Minimizing off-site tracking of raw, final, or waste materials Minimizing dust generation

45 Other Controls Things to consider (document use in SWP3): Keeping exposed areas free of waste, garbage and floatable debris or intercepting them before discharge Using velocity dissipation at each discharge location and along the length of any outfall channel

46 Salt Storage Locations must be documented in the SWP3 Must be enclosed or covered Exception: there is no discharge or the discharge is covered by a separate OPDES permit Should use BMPs that minimize exposure when adding to or removing salt from piles

47 Salt Storage

48 Hazardous Substances or Oil Prevent or minimize the discharge of hazardous substances or oil in your discharge If a spill or release is in an amount equal to or greater than the reportable quantity amount established in 40 CFR 110, 40 CFR 117, or 40 CFR 302, you must report it within 24 hours of discovery or knowledge of it NRC: DEQ:

49 Hazardous Substances or Oil Procedures for hazardous material cleanup must meet RCRA regulations (40 CFR Parts 264 and 265) SWP3 must be reviewed and measures must be identified and implemented to prevent recurrence and strengthen response Describe release, circumstances leading to it, and date release occurred Modify the SWP3

50 Sector Specific BMPs Each sector has specific requirements with respect to the SWP3 and control measures used Be sure to check in Part 12 of OKR05 for your sector Examples: Increased requirements for good housekeeping measures like sweeping Increased requirements for dust suppression Increased inspection frequency

51 DEQ Stormwater Contacts Permitting Michael Moe (405) Karen Milford (405) Ismat Esrar (405) Permit Administration Loree Boyanton- (405) Anamari Holcomb- (405) Sandra Purvis- (405) Compliance/Enforcement Wayne T. Craney - (405) Michele Loudenback (North) - (405) Michelle Chao (West) - (405) Lorinda Mollenkamp (South) - (405)

52 Questions, Comments, Discussion