Storm Water Pollution Prevention Training

For Industrial FacilitiesIn the City of Memphis

What is Storm Water?Storm water is water flowing over the land during and immediately after a rain storm.

Storm water does not flow into a wastewater treatment system, it flows into our surface watersIn the Memphis area, our storm water system consists of our gutters, storm drains, underground pipes, open channels, culverts, and creeks. Our storm water system discharges into the Wolf, Nonconnah, Loosahatchie and Mississippi Rivers.

What we do on the land affects the water quality and the habitat of our creeks and rivers. It also affects our quality of life, our fisheries, and our recreation.

Why do we have to do something to improve our storm water discharges?In 1972, Congress passed the Clean Water Act and focused on point source pollution discharges to surface waters. Most point sources have been eliminated, others are permitted.

In 1990, the EPA began the National Pollutant Discharge Elimination System (NPDES) Permitting process to address non-point sources of pollution.

Industries have to have an NPDES Permit for their storm water discharges. The permit requires that industrial facilities have a Storm Water Pollution Prevention Plan (SWPPP), observe their discharges (some also have to sample) and work to implement Best Management Practices (BMPs) to minimize pollutants from leaving their facility.

City of Memphis Storm Water ProgramAs a result of an NPDES permit issued to the City of Memphis, the City is responsible for enforcing storm water pollution prevention requirements.The City of Memphis is committed to an active role in the reduction of pollution and the protection of human health and the environment.City facilities with industrial activities will be required to comply with the NPDES industrial permit regulations for their applicable sector beginning March 2003.

How do you achieve compliance with the NPDES permit?Each facility needs its own SWPPP that addresses all potential pollutant sources and measures and controls needed to prevent pollution.The facility must implement a quarterly facility inspection and document the inspections in an annual comprehensive site evaluation report and update SWPPP with new BMPs etc.The facility must visually, and in some cases chemically, analyze its storm water runoff for signs of pollution. BMPs must be implemented and, sometimes, engineering controls must be installed in order to prevent pollution from your facility.Employees must be trained.

What is the goal of training employees about storm water?

To stress the importance of being AWARE of and ALERT to conditions that could result in the dischargeof pollutants to storm water!

To improve communicationemployees and supervisors.

Employee training and improved communication could have helped here:

Why is this a storm water problem?

Whats wrong here?

and here

What needs to happen here?and what has already happened?

TRAINING TOPICSVehicle Washing and FuelingFuel and Chemical Storage ActivitiesSand/Soil PilesVehicle Parking LotsWaste Containers and Drum ManagementOutdoor StorageGood HousekeepingPreventive MaintenanceSpill Prevention and ResponseIllicit Discharge Detection and Reporting

Non-storm water discharges must go to sanitary sewerThis means no washing vehicles outside!!!

This means no washing vehicles outside!

Fuel and Chemical Storage Activites

Fuel and Chemical Transfer ActivitiesConsider how fuels and chemicals are transferred day to day to the fleet.Evaluate and institute transfer procedures for fuels and chemicals from tank trucks to the ASTs and USTs at our facilities. Implement Engineering ControlsReport SpillsClean Up Spills

What BMPs would have helped prevent the pollution leaving this site?

Cover sand and soil piles to prevent pollution!!

Drums must be sealed with covers and bungs And preferably inside a secondary containment area!!

Waste products must be stored in covered drums and staged in an assigned area with secondary containment.

Outdoor Storage Areas

ANYTHING STORED OUTSIDE MUST BE CLEANED OF CHEMICAL RESIDUES, PROPERLY CONTAINED, AND WE NEED TO CONSIDER WHY WE ARE KEEPING IT, AND FIGURE OUT HOW TO GET RID OF IT OR STORE IT INSIDE EACH FACILITYS OUTDOOR STORAGE MUST BE ADDRESSED

Good Housekeeping Prevents PollutionMinimize exposure, inspect and report, cleanup spills and leaks promptly

Absorbent material placed on a spill

will end up at the outfall if not swept up!!!

Good Housekeeping Inside Buildings to Prevent PollutionMake sure that there are no discharges from the building to storm water through doorways or other pathways Make sure that spill response equipment is readily available throughout building to contain leaks and spillsClean the floors and do not allow the wash water to discharge outsideHave a comprehensive chemical storage and management plan, specify co-located areas and accumulation amounts for vendor pick-ups

Vehicle Storage Areas Must Be Cleaned To Prevent Pollution

What needs to happen here?

Preventative MaintenanceDaily inspections of equipment and storageRegular maintenance of equipmentRoutine sediment/debris removal and surface cleaning of storm water management devices such as:oil-water separators, ponds, inlets, ditches, & secondary containment of fuel farm

All types of outfallsall need maintenance and cleaning

Leaking vehicles/equipment stored outside should be drained, absorbent material placed to capture releases

Spill ResponseClean all small fuel spills and leaks, and to report significant fuel spills or leaks to management immediately!Always document spills in the SWPPP and SPCC plan in order to learn from mistakesREMEMBER SPILLS ARE CAUSED, THEY DO NOT JUST HAPPEN!!

Spill Prevention and Response1.Contain2.Locate and Stop the Source3.Clean Up4.Dispose of Properly5.Notify Pollution Prevention Team Members6.Document Release and/or Report if over the applicable threshold7.Follow Up: - Evaluate changes needed and modify SWPPP - Implement changes - Replace spill response equipment used

Again, sweep up the spill absorbent materials!

Review of NPDES Permit Requirements for Industrial FacilitiesDevelop a Storm Water Pollution Prevention PlanConduct Quarterly Facility InspectionsConduct Quarterly Visual (Sometimes Chemical) Examination of Storm Water Conduct Annual Comprehensive Site Compliance EvaluationConduct Annual Pollution Prevention Training

Annual Comprehensive Site Compliance EvaluationEvaluate areas contributing storm water discharge associated with industrial activity for evidence of, or the potential for, pollutants entering the drainage system. Measures to reduce pollutant loadings shall be evaluated to determine whether they are adequate and properly implemented in accordance with the terms of the permit or whether additional control measures are needed. Structural storm water management measures, and other structural pollution prevention measures identified in the plan shall be observed to ensure that they are operating correctly.

Storm Water HotlineCall 576-6721 to report information about illicit discharges or other problems that you detect

Visualize cleaner industrial facilities in MemphisWe can do it!!!

City of Memphis Public Works- Storm Water ProgramPrepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramAsk the class to define the difference between point and non-point sources of pollution and give examples.Discuss Love Canal 1978, Lake Eerie.

Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramPrepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water Program

Tell story about purchasing and lack of communication causing environmental problems. This example: oil for a garbage compactor motor was ordered in the same quantity each year, regardless of the amount needed. The result: years of purchasing resulted in a unneeded stockpile of leaking drums.Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramStorm water comes in contact with the leaking drums and the petroleum contaminated soils in the area. This pollution then travels offsite in the storm water system.Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramThis is a fill port for a Used Oil Underground Storage Tank. The fill port is not adequate for pouring 55-gallon drums of used oil into. Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramThis is the outside of the building where the previous picture of the fill port is located. The spills that occur inside the building are able to release to the storm water.Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramThe used oil fill port drains through this pipe to the underground storage tank below. The pipe is located in an area that may be driven over, in fact that is what had already happened.

At this point, state that these are examples of why we are here today. While we talk today, I want you to think of your facility and what potential pollutant sources there are.Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramSTORY: There was an industrial facility that was required to perform analytical monitoring of its storm water discharges. It eliminated all outdoor storage and could not figure out why it was still exceeding its pollutant parameter cut off concentrations. It turned out that they had relocated a piece of equipment too close to the mop water discharge point to an oil water separator which discharged to the sanitary sewer. They did not know how much room was needed and didnt find out. The woman that was working at night to wash floors at the facility began to unload the sweepers discharges into the storm drain outside. She didnt know it was a big deal and didnt communicate about it.

Lessons: training and communication with those performing the work when doing the decision making.Ask the trainees if they understand the difference between the storm and sanitary sewer systems?

Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramThis picture is at a garbage truck transfer facility that is now closed. What do you think they were washing here? Is it possible that they were washing out the garbage trucksPrepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramThese were Above Ground Storage Tanks containing oil and antifreeze for fleet maintenance. The vehicles were also fueled at this location. Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramIt is our responsibility to make sure that our vendors do not cause spills on our properties. It is ultimately our responsibility and not theirs to respond to those spills; therefore, we must make sure that we prevent them!!!Is your facility required to have a Spill Prevention, Control and Countermeasures (SPCC) Plan? If so who is on your SPCC Team and who is trained to respond to spills?

Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramSecondary containment for tanks and piping; automatic cutoff controls (overfill protection); training; spill response equipment (not only used but also swept up) etc.

Also ask the trainees if they see another pollution source leaving the site in this picture: it is the non-storm water discharge running from the right side of the picture. In this case it was a hose where people cleaned out trucks/washed vehicles.Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramIt is required by the NPDES permitPrepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramWhat will happen when rainwater fills up this open topped container?Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramFollow up with next slide after the trainees discuss the need for preventative maintenance.Prepared by Hess Environmental Services, Inc.City of Memphis Public Works- Storm Water ProgramPrepared by Hess Environmental Services, Inc.