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.
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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
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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
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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.
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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
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BMPs Outdoor Storage
Covered Containers
Covered storage areas
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BMP Examples
Covered Dumpsters
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BMP Examples
OR Under Roof
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BMPs Loading/Unloading
Covered Areas
Containment
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BMP Examples
Covered Loading Bays
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BMP Examples Secondary Containment – Double Walled Tanks
AND Loading Procedures
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BMPs – Waste Storage
Good Housekeeping
Covered Storage
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Waste Storage
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Waste Storage
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BMPs – Parking Areas Runoff / Bare Soil Erosion
Catch Basin and Drain Controls
End of pipe controls
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BMP Examples
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Catch Basins
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Drain Plug
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Drain Mat
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Drain Mat
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BMP Examples Gate Valve Shut-offs at all outfalls Spill containment (Stormwater and SPCC)
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BMP Examples Gate Valve Shut-offs at all outfalls
Spill containment (Stormwater and SPCC)
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Plant Roof
Don’t Forget the Out-Of-Sight Areas Before
After
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Small Changes in Equipment Can Lead to Big Changes in Pollution Prevention
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Never Assume All Is Well At the End Of The Pipe
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No Single Solution Fits Every Outfall
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Temporary Discharge Solution or Secondary Protection at End of Pipe Discharge
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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.
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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
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SPCC Plan Requirements Summary
Tier I vs. Tier II 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
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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.
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No Loading Rack
•General containment requirements (112.7(c)) •Berms, Curbing, Diversion to Ponds, Absorbents, etc. 35
Loading Rack Loading Rack
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Loading and Unloading Tanker Trucks
Per EPA Regional Inspector’s Guideline:
“Areas utilizing a single hose and connection or standpipe are not considered “racks”.”
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Integrity Testing – Bulk Storage Containers
112.8(c) requires– Visual inspection, plus Hydrostatic Radiographic
OR OR
Ultrasonic Acoustic
Regular Intervals based on type of test
$$$$ vs. Risk Small tanks, drums, totes
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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.
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Oil Filled Equipment
Oil filled electrical, operating, or manufacturing equipment
Not considered “bulk storage containers” but they are still regulated.
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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
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Wastewater Treatment (Specifically Oil / Water Separators)
Wastewater Treatment Units are exempt However, in some cases an Oil / Water Separator may be regulated
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“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.
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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
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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
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Integrate Compliance Activities
Inspections – SWPPP Contamination Sources BMPs Outfalls
Inspections – SPCC Regulated Areas Containment Units Spill Kits / Equipment
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Integrate Compliance Activities
Training – SWPPP
Training – SPCC
Personnel responsible for exposed areas or BMPs
Oil-handling personnel
Training Frequency – Annual and when assigned
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Inlet Protector
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Sediments Capture
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Sediments and Oils
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Hydrocarbon Absorbents Absorb hydrocarbons into absorbent pillows
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Hydrocarbon Absorbents
Absorbs Petroleum and Expands
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Just like conventional absorbent except – It only holds petroleum (not water) and It expands
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Used to absorb oils from transformer area
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Sediments /Oils / Organically bound Metals
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Sediments /Oils / Organically bound Metals
Various filtering media
Hydrocarbons also absorb on media
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Oil Removal
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Oil Removal
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Drain Plug
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Secondary Containment
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We see New Products every month
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Questions?
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