LAKE CHARLES HARBOR & TERMINAL DISTRICT BULK TERMINAL NO. 1 SULPHUR, LOUISIANA STORM WATER POLLUTION PREVENTION PLAN LPDES PERMIT NO. LA0091812 March 2013 Prepared by: C-K Associates, LLC 17170 Perkins Road Baton Rouge, Louisiana 70810 (225) 755-1000 C-K Associates Project No. 8587
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 REVISION RECORD REVISION DATE REASON FOR REVISION NAME NUMBER Original April 27, 2005 None Scott Auterson 1 February 2008 Update inventory of significant materials, outfalls. 2 November 2010 Update Pollution Prevention Team, inventory of significant materials, general formatting. 3 March 2013 Update inventory of significant materials, new permit requirements. Scott Auterson Scott Auterson Scott Auterson i C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 TABLE OF CONTENTS REVISION RECORD...i Section Page 1.0 INTRODUCTION...1 1.1 Purpose and Need...1 1.2 Pollution Prevention Team...1 1.3 Site Description...2 1.4 Storm Water Outfalls...2 1.5 Site Map...2 1.6 Prediction of Direction, Rate of Flows, and Quantity...2 2.0 SUMMARY OF POTENTIAL POLLUTANT SOURCES...3 2.1 Significant Materials and Activities...4 2.2 Potential Pollutant Sources...4 2.3 Spills and Leaks...4 3.0 MEASURES AND CONTROLS...4 3.1 Good Housekeeping...4 3.2 Minimizing Exposure...4 3.3 Preventive Maintenance...5 3.4 Spill Prevention and Response...5 3.5 Visual Inspections...5 3.6 Employee Training...6 3.7 Sediment and Erosion Controls...6 3.8 Storm Water Management...6 4.0 MONITORING REQUIREMENTS...7 4.1 Annual Site Inspection and Summary Report...7 4.2 Recordkeeping and Reporting...7 4.3 Plan Review and Changes...8 ii C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 TABLE OF CONTENTS CONTINUED LIST OF FIGURES Table 1 List of Oil and Hazardous Materials 2 Regulatory Cross- reference Figure 1 Site Location Map 2 Site Diagram Appendix LIST OF APPENDICES A B C D LPDES Permit Spills and Leaks Log Employee Training Log Annual Site Inspection and Summary Report iii C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 1.0 INTRODUCTION 1.1 Purpose and Need This document is intended to serve as the Storm Water Pollution Prevention Plan (SWPPP) for the Lake Charles Harbor & Terminal District (LCH&TD) Bulk Terminal No. 1 (BT-1) facility, located in Sulphur, Calcasieu Parish, Louisiana. It was prepared to meet the requirements of Louisiana Pollutant Discharge Elimination System (LPDES) Permit No. LA0091812, which was issued by the Louisiana Department of Environmental Quality (LDEQ) on December 4, 2012 and became effective on January 1, 2013. This SWPPP has been prepared in accordance with the narrative requirements and conditions (as spelled out in Condition Nos. T-8 through T-20) of the LPDES permit. A copy of the LPDES permit is included in Appendix A. The purpose of the SWPPP is to prevent and/or minimize the contamination of storm water discharges by potential pollutant sources at the site. This SWPPP was prepared in accordance with good engineering practices. The SWPPP will be reviewed and updated, if necessary, within six months of the effective date of the permit. The SWPPP will apply to all storm water discharges from the facility, either through permitted outfalls or through outfalls which are not listed in the permit or which exist as sheet flow. 1.2 Pollution Prevention Team The following positions have been assigned to the facility s Pollution Prevention Team. Included are the specific responsibilities. Director of Operations Todd Henderson 337-493-3579 Oversees implementation of SWPPP. Signs all certifications of SWPPP. Delegates or assigns specific responsibilities to other team members. Bulk Terminal Manager Clark Hayes 337-493-3606 Ensures development and implementation of SWPPP. Performs annual site inspection and documents findings in SWPPP. Oversees implementation of Best Management Practices (BMPs). Oversees collection of storm water samples. General Staff Philip Bradley Lewis 337-493-3581 Prepares Discharge Monitoring Reports (DMRs). Performs routine facility inspections. Ensures installation and maintenance of structural BMPs. Provides employee/contractor training. Collects storm water samples. 1 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 1.3 Site Description BT-1 is located on approximately 74 acres at 3501 Bayou d Inde Road, Sulphur, Louisiana. Figure 1 is a Site Location Map. BT-1 is a marine bulk terminal engaged in the handling and storage of petroleum coke, calcined coke, wood chips, barites, aluminum trihydrate, anode butts, magnetite, rutile, fly ash, ilmenite, and coal [Standard Industrial Classification (SIC) Code 4491]. The facility consists of several large open bulk storage areas. Bulk materials are brought in via railcar and tractor trailer, off-loaded, stored, and/or transported via an extensive system of conveyors, machinery, and silos to docked vessels, tractor trailers, or railcars for transportation off-site. 1.4 Storm Water Outfalls BT-1 is currently authorized to discharge storm water form two outfalls (002 and 003). Outfall 002 consists of the intermittent discharge of vehicle rinse water, dust suppression water, and industrial storm water from the wood chip, anode butt, petroleum coke, and coal storage area. Storm water drains to a concrete-lined pit (Pit 2) which acts as a settling basin prior to storm water discharge. Outfall 003 consists of the intermittent discharge of vehicle rinse water, dust suppression water, and industrial storm water from the wood chip, anode butt, petroleum coke, and coal storage area. Storm water drains to a concrete-lined pit (Pit 1) which acts as a settling basin prior to storm water discharge. Outfalls 002 and 003 discharge to the Calcasieu River in Segment No. 030301 of the Calcasieu Water Quality Management Basin. Additional portions of the property discharge storm water associated with industrial activity via sheet flow or discharge storm water that is not associated with industrial activity. 1.5 Site Map Figure 2 (Site Diagram) serves as a site map which shows each storm water drainage area, outfalls, structural control measures, name of receiving waters, and location of significant materials and/or industrial activities. 1.6 Prediction of Direction, Rate of Flow, and Quantity BT-1 does not anticipate equipment failure to a degree that would cause a discharge of significant amounts of pollutants from the facility. BT-1 is designed whereby most significant materials are located within the drainage areas for Outfalls 002 and 003, both of which drain to concrete-lined pits which act as settling basins prior to storm water discharge. Each pit has a gate valve to prevent the discharge of spills or leaks. 2 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 However, should a major failure occur, adequate containment is provided for individual storage tanks or by the concrete-lined pits. Therefore, there is little risk of a spill causing significant amounts of pollutants to reach surface waters. The direction of flow is typically to the southeast. The rate of flow is a function of the type of failure and the worst case scenario is based on the release of the entire capacity of a tank over an hour. The total quantity of pollutants is included in Table 1 (List of Oil and Hazardous Materials). 2.0 SUMMARY OF POTENTIAL POLLUTANT SOURCES 2.1 Significant Materials and Activities Significant materials at BT-1 include bulk materials which are stored in outdoor storage piles. These include petroleum coke, calcined coke, wood chips, barites, aluminum trihydrate, anode butts, magnetite, rutile, fly ash, ilmenite, and coal. Also, a list of oil and hazardous materials is included in Table 1. These significant materials have the potential to be spilled or released to the ground during transport or filling of equipment. The following outdoor storage of significant materials and outdoor activities constitute the potential pollutant sources to storm water at BT-1. Bulk Materials Storage Areas Bulk materials are stored in designated outdoor storage piles. Drainage from these areas is routed to concrete-lined pits which act as settling basins. Loading/Unloading Areas Bulk materials are transferred from railcars and tractor trailers; stored; and transferred again via an extensive system of conveyors, machinery, and silos to docked vessels, railcars, and tractor trailers. The potential for exposure exists if solid materials spill onto the ground during transportation. Truck Wash Area Trucks are washed in a designated area which is located in the northeast corner of the facility. Maintenance Shop and Used Oil Storage Area A maintenance shop and used oil storage area are located in the southwest corner of the facility. Gear oil and hydraulic oil are used for maintenance of equipment. The potential for exposure exists if oil is spilled or leaked during transfer and/or storage. 3 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 Diesel Fuel and Unleaded Gasoline Area Diesel fuel and unleaded gasoline are stored in 2,000-gallon and 1,000-gallon storage tanks, respectively, which are located near the water tower and at the woodchip facility. There is also a portable diesel fuel storage tank located at the woodchip facility which is used for supplying diesel fuel to the equipment to load the conveyor system. The potential for exposure exists if diesel or gasoline is spilled or leaked during transfer and/or storage. Vehicles and Heavy Equipment Vehicles and heavy equipment are commonly used throughout the facility and there is the potential for leaks of hydraulic oil, lube oil, etc. In addition, minor repairs and maintenance of vehicles occurs throughout the facility. Transformers There are seven transformers at BT-1. The potential for exposure of dielectric fluids, lubricants, or other oils to storm water exists by leak or release due to failure. 2.2 Potential Pollutants The majority of significant materials stored or used at the facility are bulk materials associated with marine bulk terminals as discussed in Section 2.1. These materials may contact storm water as a result of rainfall. Other pollutants may contact storm water as a result of a spill or leak. In addition, other potential pollutants that may occur in storm water are suspended sediments attributed to the general deterioration of paved materials (i.e., limestone, asphalt, and clamshell) and equipment. 2.3 Spills and Leaks There have been no reportable quantity spills or leaks at the facility during the last three years. Any future spills or leaks will be documented in Appendix B. 3.0 MEASURES AND CONTROLS 3.1 Good Housekeeping BT-1 will utilize all reasonable methods including BMPs to minimize any adverse impact on the drainage system including but not limited to: maintaining adequate roads and driveway surfaces; removing debris and accumulated solids from the drainage system; and cleaning up immediately any spill by sweeping, absorbent pads, or other appropriate methods. 4 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 All equipment, parts, dumpsters, trash bins, petroleum products, chemical solvents, detergents, or other materials exposed to storm water will be maintained in a manner which prevents contamination of storm water by pollutants. All waste fuel, lubricants, coolants, solvents, or other fluids used in the repair or maintenance of vehicles or equipment will be recycled or contained for proper disposal. Spills of these materials will be cleaned up by dry means whenever possible. 3.2 Minimizing Exposure Industrial materials and activities will be protected to prevent contamination of storm water, whenever possible. Any materials that are stored outside which may contribute to storm water contamination will be moved, or stored under roof, or provided with a site-specific BMP which may include the following: Use grading, berming, or curbing to prevent runoff of contaminated flows; Locate materials, equipment, and activities so that potential leaks are contained in existing containment or diversion systems; Clean up spills and leaks promptly using dry methods whenever possible; Use drip pans and absorbents under or around leaking vehicles and equipment and store under roof where possible; Use spill/overflow equipment; Drain fluids from equipment and vehicles prior to on-site storage or disposal; and Ensure that all wash water drains to a proper collection system. 3.3 Preventive Maintenance All diked areas surrounding storage tanks or storm water collection basins will be free of residual oil or other contaminants so as to prevent the accidental discharge of these materials in the event of flooding, dike failure, or improper draining of the diked area. All drains from diked areas will be equipped with valves which will be kept in the closed position except during periods of supervised discharge. 3.4 Spill Prevention and Response All spilled product and other spilled wastes will be immediately cleaned up and disposed of according to all applicable regulations and BT-1 s Spill Prevention, Control, and Countermeasure Plan (SPCC). Use of detergents, emulsifiers, or dispersants to clean up spilled product is prohibited except where necessary and where the cleanup practice does not result in a discharge and does not leave residues exposed to future storm events. In all such cases, initial cleanup will be done by physical removal and chemical usage will be minimized. 5 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 In the event of a spill, the individual who discovers the spill will take any appropriate action to contain or minimize the spill and then notify the Bulk Terminal Manager. All responses to significant spill incidents requiring notification of regulatory agencies will be conducted in accordance with local, state, and federal regulations. 3.5 Visual Inspections All valves, tanks, drains, or other potential sources of pollutant releases will be inspected and maintained by operating personnel on a regular basis to ensure the proper operation and to prevent the discharge of pollutants. In addition, a member of the Pollution Prevention Team will perform an annual site inspection as discussed in Section 4.1 of the plan. This inspection will include a review of past discharges, equipment, control measures, outfalls, and any potential spills and leaks in all areas where industrial materials or activities are exposed to storm water. 3.6 Employee Training All operations and environmental personnel who work in areas where significant materials are exposed to storm water and/or who have responsibilities for implementing portions of this plan are trained and qualified. Training on good housekeeping, preventive maintenance, discharge prevention measures, drainage controls, and spill prevention and response is conducted routinely for these personnel. Environmental awareness, SWPPP, and SPCC training are provided on an annual basis. Employee training will be documented in Appendix C. 3.7 Sediment and Erosion Control Areas prone to sediment erosion will be inspected and addressed using erosion controls. These controls may include dirt maintenance and stabilization of soils with ground cover to minimize erosion. Vegetative practices include the maintenance of vegetated buffer strips along the perimeter of the property. All storm water conveyances will be kept clear of obstruction. 3.8 Storm Water Management The management of storm water at BT-1 is achieved through existing structural controls, non-structural controls, and BMPs. These include the use of concrete curbing and containment dikes, drainage systems, concrete-lined pits, and gate valves. 6 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 BT-1 will comply with all applicable regulations under the Louisiana Solid Waste and Resource Recovery Law and the Hazardous Waste Management Law. BT-1 will obtain all necessary permits and/or approvals authorized by these statutory requirements. BT-1 will employ the following BMPs as far as they apply to preventing the exposure of pollutants to storm water discharges: Waste Materials/Trash Waste materials will be collected and temporarily stored in designated areas prior to off-site disposal; Dumpsters will be covered; and Construction debris will not be buried. Sanitary Waste Sanitary waste from portable toilets or other sources will not be allowed to commingle with storm water. 4.0 MONITORING REQUIREMENTS 4.1 Annual Site Inspection and Summary Report BT-1 will conduct a thorough site inspection once per year. A member of the Pollution Prevention Team will conduct an inspection of the storm water drainage areas for evidence of pollutants entering or having the potential to enter a drainage system. The purpose of this inspection is to evaluate whether measures to reduce pollutant loadings identified in the SWPPP are adequate and have been properly implemented in accordance with the terms of the LPDES permit or whether additional control measures are needed. Appendix D contains the Annual Site Inspection and Summary Report which must be completed by the inspector and signed by a responsible corporate officer or a duly authorized representative. 4.2 Recordkeeping and Reporting The following records are maintained by BT-1: Spills and leaks (Appendix B); Employee training records (Appendix C); Documentation of inspections (Appendix D); and Monitoring data and DMRs (Main Office). 7 C-K Associates, LLC
Lake Charles Harbor & Terminal District Bulk Terminal No.1 Storm Water Pollution Prevention Plan March 2013 4.3 Plan Review and Changes The SWPPP will be reviewed and amended whenever there is a change in design, construction, operation, or maintenance which has a significant effect on the potential for the discharge of pollutants in storm water. The SWPPP will be amended if a determination is made that the plan has proven to be ineffective in preventing or minimizing the discharge of pollutants in storm water from the sources identified herein. In the event of a discharge of a hazardous substance or oil in excess of a reportable quantity, the appropriate corrective action will be implemented and the plan will be amended to address the situation, if applicable. In addition, the SWPPP will be reviewed to identify measures to prevent the recurrence of such releases and to respond to such releases, and the plan will be amended, if applicable. A regulatory cross-reference (Table 2) has been included to facilitate review of this plan s conformance with the permit. 8 C-K Associates, LLC
TABLES
TABLE 1 LIST OF OIL AND HAZARDOUS MATERIALS
TABLE 1 LIST OF OIL AND HAZARDOUS MATERIAL MATERIAL QUANTITY SIZE (GALLONS) Motor Oil, Transmission Oil 4 550 Portable Used Oil 2 300 Anti-Freeze 3 55 Used Oil 3 55 Transformer Oil 1 325 Emergency Generator Diesel 1 409 Unleaded Gasoline 1 1,000 Diesel Fuel 1 2,000 Gear Oil 1 325 Transformer Oil 1 532 Used Oil 1 500 Used Oil 20-25 55 Hydraulic Oil 18-20 55 Transformer (Oil) 1 325 Transformer (Oil) 1 190 Transformer (Oil) 1 347 Transformer (Oil) 1 433 Transformer (Oil) 1 175 Rollo Oil Filled Equipment 1 110 Mineral Oil 2 55 Portable Diesel Fuel 1 250
TABLE 2 REGULATORY CROSS-REFERENCE
TABLE 2 REGULATORY CROSS-REFERENCE CONDITION PLAN SECTION SECTION TITLE T-8 1.1 Purpose and Need T-9(A) 4.1 Annual Site Inspection and Summary Report T-9(B) 1.6 Prediction of Direction, Rate of Flow, and Quantity T-9(C) 4.1 Annual Site Inspection and Summary Report T-9(D) 1.5 Site Map T-9(after D) 2.3 Spills and Leaks T-9(after D) 2.1, 2.2 Significant Materials and Activities, Potential Pollutants T-10(A) 3.1 Good Housekeeping T-10(B) 3.1 Good Housekeeping T-10(C) 3.1 Good Housekeeping T-11 3.4 Spill Prevention and Response T-12 3.4 Spill Prevention and Response T-13 3.1 Good Housekeeping T-14 3.1 Good Housekeeping T-15 3.3 Preventive Maintenance T-16 3.3 Preventive Maintenance T-17 3.5 Visual Inspections T-18 3.8 Storm Water Management T-19 4.3 Plan Review and Changes T-20 4.3 Plan Review and Changes
FIGURES
FIGURE 1 SITE LOCATION MAP
FIGURE 2 SITE DIAGRAM
APPENDICES
APPENDIX A LPDES PERMIT
APPENDIX B SPILLS AND LEAKS LOG
APPENDIX B Spills and Leaks Log Date/Time Quantity/Material Circumstance
APPENDIX C EMPLOYEE TRAINING LOG
APPENDIX C Employee Training Log Date Name of Employee Name of Instructor Topics
APPENDIX D ANNUAL SITE INSPECTION AND SUMMARY REPORT
APPENDIX D ANNUAL SITE INSPECTION AND SUMMARY REPORT An annual site inspection is required to be conducted of all areas where significant materials or activities are exposed to storm water. This checklist is designed for personnel to function as a standardized procedure for conducting the evaluation. Bulk Materials Storage Areas Are there any leaks or spills? No Yes (If yes, where and what corrective action?) Loading/Unloading Areas Are there any leaks or spills? No Yes (If yes, where and what corrective action?) Truck Wash Area Are there any leaks or spills? No Yes (If yes, where and what corrective action?) Maintenance Shop and Used Oil Storage Area Are there any leaks or spills? No Yes (If yes, where and what corrective action?) Diesel Fuel and Unloaded Gasoline Area Are there any leaks or spills? No Yes (If yes, where and what corrective action?) Heavy Equipment and Vehicles Are there any leaks or spills? No Yes (If yes, where and what corrective action?) Transformers Are there any leaks or spills? No Yes (If yes, where and what corrective action?)
Outfall 002 Is there a visible sheen? No Yes (If yes, where and what corrective action?) Outfall 003 Is there a visible sheen? No Yes (If yes, where and what corrective action?) Comments/Corrective Action Evaluate the effectiveness of measures to reduce pollutant loadings and whether additional measures are needed. Are they properly operated and maintained? Is the SWPPP up to date and are any changes required? Complete the summary report (comments/ corrective actions). Person Conducting Inspection: Date/Time:
CERTIFCATION STATEMENT 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 gather and evaluate 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 fine and imprisonment for knowing violations. Name and Title Date