Good Housekeeping and Spill...

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

Pollution Prevention and You

Presented By: Michele Loudenback, R.P.E.S

Industrial Wastewater Enforcement Section

Water Quality Division

Department of Environmental Quality

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

Outline

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

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

Structural vs. Non-structural Controls

Section 4.2.8 of the OKR05 Requires consideration of several types of BMPs, both structural and non-structural

If you determine that the listed BMPs are not appropriate, you have to explain why in your SWP3

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

Permit Requirements

Good Housekeeping

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

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

Good Housekeeping

Things to consider (document use in SWP3):

Maintaining clean work spaces

Labeling storm drains and BMPs

Practicing good inventory management

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

Good Housekeeping

Common problem areas include:

Trash container proximity and adjacent areas

Material storage and handling areas

Good Housekeeping

Common problem areas include:

Vehicle and equipment maintenance areas

Loading and unloading areas

Pictures

Exposure Minimization

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.

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

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

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

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

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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Preventive Maintenance

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

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

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.)

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

Preventive Maintenance

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Spill Prevention and Response

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:

https://www.deq.state.ok.us/wqdnew/forms/stormwater/Exhibit%207%20Spill%20Prevention%20and%20Response%20Procedures%20Checklist_August2011.pdf

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

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

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)

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

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

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

Salt Storage

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: 1-800-424-8802

DEQ: 1-800-522-0206

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

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

Sector Specific BMPs

Permitting

Michael Moe– (405) 702-8184

Karen Milford – (405) 702-8191

Ismat Esrar – (405) 702-8193

Permit Administration

Loree Boyanton- (405) 702-6177

Anamari Holcomb- (405) 702-6178

Sandra Purvis- (405) 702-6182

Compliance/Enforcement

Wayne T. Craney - (405) 702-8139

Michele Loudenback (North) - (405) 702-8116

Michelle Chao (West) - (405) 702-8112

Lorinda Mollenkamp (South) - (405) 702-8156

DEQ Stormwater Contacts

Questions, Comments, Discussion