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.
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
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
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
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
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
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
BMPs Outdoor Storage Covered Containers Covered storage areas 8
BMP Examples Covered Dumpsters 9
BMP Examples OR Under Roof 10
BMPs Loading/Unloading Covered Areas Containment 11
BMP Examples Covered Loading Bays 12
BMP Examples Secondary Containment Double Walled Tanks AND Loading Procedures 13
BMPs Waste Storage Good Housekeeping Covered Storage 14
Waste Storage 15
Waste Storage 16
BMPs Parking Areas Runoff / Bare Soil Erosion Catch Basin and Drain Controls End of pipe controls 17
BMP Examples 18
Catch Basins 19
Drain Plug 20
Drain Mat 21
Drain Mat 22
BMP Examples Gate Valve Shut-offs at all outfalls Spill containment (Stormwater and SPCC) 23
BMP Examples Gate Valve Shut-offs at all outfalls Spill containment (Stormwater and SPCC) 24
Plant Roof Don t Forget the Out-Of-Sight Areas Before After 25
Small Changes in Equipment Can Lead to Big Changes in Pollution Prevention 26
Never Assume All Is Well At the End Of The Pipe 27
No Single Solution Fits Every Outfall 28
Temporary Discharge Solution or Secondary Protection at End of Pipe Discharge 29
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
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
SPCC Plan Areas of Focus Security Fencing Lighting Loading Areas Integrity Testing Operating Equipment 32
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
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
No Loading Rack General containment requirements (112.7(c)) Berms, Curbing, Diversion to Ponds, Absorbents, etc. 35
Loading Rack Loading Rack 36
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
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
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
Oil Filled Equipment Oil filled electrical, operating, or manufacturing equipment Not considered bulk storage containers but they are still regulated. 40
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
Wastewater Treatment (Specifically Oil / Water Separators) Wastewater Treatment Units are exempt However, in some cases an Oil / Water Separator may be regulated 42
Bulk Storage Container in O/W Separator Stores oil until pumping into a tanker truck = Regulated Bulk Storage Container Oil / Water Separator 43
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
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
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
Integrate Compliance Activities Inspections SWPPP Contamination Sources BMPs Outfalls Inspections SPCC Regulated Areas Containment Units Spill Kits / Equipment 47
Integrate Compliance Activities Training SWPPP Personnel responsible for exposed areas or BMPs Training SPCC Oil-handling personnel Training Frequency Annual and when assigned 48
Inlet Protector 49
Sediments Capture 50
Sediments and Oils 51
Hydrocarbon Absorbents Absorb hydrocarbons into absorbent pillows 52
Hydrocarbon Absorbents Absorbs Petroleum and Expands 53
Just like conventional absorbent except It only holds petroleum (not water) and It expands 54
Used to absorb oils from transformer area 55
Sediments /Oils / Organically bound Metals 56
Various filtering media Sediments /Oils / Organically bound Metals Hydrocarbons also absorb on media 57
Oil Removal 58
Oil Removal 59
Drain Plug 60
Secondary Containment 61
We see New Products every month 62
Questions? 63