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Workshop R
Storm Water Pollution Plans (SWP3), Spill Prevention, Control, and Countermeasure (SPCC) and
Hazardous Waste Contingency Plans … How do They Interact?
Tuesday, March 22, 2016 3:30 p.m. to 4:45 p.m.
Biographical Information
Gregory A. Hemker, President EHS Technology Group, LLC
P.O. Box 0187, Miamisburg, Ohio 45343-0187 Office 937.865.3818 or 800.356.9039 Fax: 937.865.3611
[email protected] Mr. Hemker is one of the founders of EHS Technology Group, LLC located in Miamisburg, Ohio. He has over 40 years of experience in environmental engineering and management. Mr. Hemker obtained a Master’s Degree in Environmental Engineering from the University of Cincinnati and is a Certified Hazardous Materials Manager (CHMM). His principle fields of expertise are air pollution, hazardous waste, and hazardous chemical management. He has conducted numerous environmental management training seminars throughout the U.S. and China. In recent years Mr. Hemker has focused on consulting with manufacturing industries to solve problems associated with air pollution, water pollution, hazardous waste, oil and chemical spill prevention, chemical safety, and industrial hygiene. Has lead the development and implementation of Energy management Systems at manufacturing facilities in Ohio and Kentucky. Mr. Hemker is a RAB trained lead auditor and has been developing and implementing ISO 14001, 9001, 50001 and OHSAS 18001 management systems since the adoption of the Standards.
Matthew R. Scroggins, Manager, Environmental Health & Safety StandardAero, 11550 Mosteller Rd., Sharonville, OH 45241
Cell: 513.370.1838 Office:513.618.9588 Fax: 513.587.6600 [email protected]
Mr. Scroggins is currently Manager-Environmental, Health, and Safety at StandardAero- Component Services, LLC, a world class Maintenance, Repair, and Overhaul facility for aircraft engine components, located in Sharonville, Ohio. He has over 8 years of experience in the implementation and management of EHS functions and programs in a manufacturing setting; specifically focusing on hazardous waste management, air pollution, and occupational safety and health. Also, he has lead the effort to implement and become 3rd party registered for both ISO 14001-Environmental Management and OHSAS 18001-Occupational Health and Safety Management Systems at his sites of responsibility. Mr. Scroggins obtained a Master’s Degree in Safety, Security, and Emergency Management from Eastern Kentucky University and is a Certified Safety Professional (CSP).
PRESENTED BY:
GREG HEMKER, CHMMEHS TECHNOLOGY GROUP
&MATTHEW SCROGGINS, CSP
STANDARD AERO
FOR:
MEC 25TH ANNUAL SUSTAINABILITY & EHS SYMPOSIUM
MARCH , 2016
SPCC, SWP3 and Hazardous Waste Contingency Plans‐How do they interact?
40 CFR Part 112‐ SPCC for Oil
40 CFR Part 265 Subpart D‐ Hazardous Waste Contingency‐ note also include 40 CFR Part 265 Subpart C‐Emergency Preparedness
SWP3‐• OEPA – Industrial GP OHR 000005‐Part 5 : SWP3 references USEPA document EPA 833‐B‐09‐002
• IDEM – 327 IAC 15‐6‐7 : known as “Rule 6” for Industrial Storm Water Discharges‐ SWP3
• Kentucky‐ Industrial GP KYR00; USEPA Guidance above
Regulatory Requirements
General Requirements:
SPCC required when the facility has
• 1,320 gallons or more on‐site at any given time in
• 55 gallon or larger containers
• Reviewed and approved by P.E.
Qualified facilities can use a simplified template and no P.E. signature
Qualified facility‐Tier I and II
• Limited releases in last three years
• No individual container > 5,000 gallons
Oil Spill Prevention Countermeasures & Control SPCC
Specific Requirements:
Approved by top management
Cross reference table from requirements to your pages of the SPCC Plan
Discussion of compliance with requirements
Describe the facility layout and plan drawing• Topo, buildings, pavements, drains,
• oil storage, loading/unloading, type and size of containers
Oil Spill Prevention Countermeasures & Control SPCC
Specific Requirements:
Describe the facility layout and plan drawing• Topo, buildings, pavements, drains,
• oil storage, loading/unloading, type and size of containers and oil
• Containment, pipes, valves, etc.
• Preventive measures
• Countermeasures, etc.
Oil Spill Prevention Countermeasures & Control SPCC
Specific Requirements:
Inspections, Tests & Records‐ in plan for last 3 years
Identify responsible personnel
Perform training of responsible personnel
Appoint designated personnel for discharge prevention
Establish security measures
Oil Spill Prevention Countermeasures & Control SPCC
General Requirements:
LQGs‐must be written plan
If have SPCC, can be combined as consolidated plan
SQGs‐Must be understood by personnel
CESQGs‐ Not required
Hazardous Waste Contingency Plan
Specific Requirements for LQG:
Written Plan
Describe actions to be taken by personnel to respond to fires, spills and explosions
Describe arrangements with local authorities and contractors; police, fire, hospitals, etc.
List names of emergency coordinators with addresses and phones; one coordinator named as primary coordinator.
Hazardous Waste Contingency Plan
Specific Requirements for LQG:
List of all emergency equipment; e.g. fire extinguishers, alarms, communication, decontamination, the location and description of each item on the list
Evacuation Plan‐ description, routes and drawings of the facility
List of copies to local authorities
Hazardous Waste Contingency Plan
Specific Requirements for LQG:
A description of actions that will be taken to correct an emergency; spill clean‐up, disposal of wastes, restore emergency equipment, etc.
Revision plan in the event of rule changes, failure of the prevention plan,
EC‐ after emergency‐must assure compatible of wastes, proper remediation, prevention measures of incident in future
Hazardous Waste Contingency Plan
Recommended Requirements for LQG:
Drawings of the entire property and buildings that include:
• Locations of waste management
• Types and amounts of wastes
• Number of containers
• Drainage pathways
• Location of emergency equipment
Hazardous Waste Contingency Plan
General Requirements:
Must be developed and implemented within 365 days of the effective date of your permit
Must file Rule 6 SWP3 checklist to IDEM
Must be certified by a qualified professional
Qualified professional‐ PE, CHMM, other certified environmental professional, trained and experienced in storm water treatment techniques
SWP3‐ IDEM
Specific Requirements:
Identifies individuals and responsibilities for SW Pollution Prevention Team
Copy of the NOI
Soil Maps with boundaries of property outlined
Area Maps‐ topography, building, receiving waters, wells, etc.
SWP3 Plan‐All States
Specific Requirements:
Graphic representation‐ on‐site drainage, adjacent properties, water bodies, drainage areas, property lines, directions of flow, wells, structures, USTs (historic & current), snow piles, outdoor processing areas, dusty areas, outdoor waste storage, pesticide/herbicide areas, vehicular traffic areas
SWP3 Plan‐All States
Specific Requirements:
Narrative description of potential pollutants source areas, storage methods, type and quantity of materials, remedial actions taken, spill history, chemical exposures, etc.
SWP3 Plan‐All States
Specific Requirements:
Narrative description of existing and planned management practices;
• Description of existing and historical exposure areas
• Specific control measures
• Written preventive maintenance plan
• Written spill response plan
• Written non‐storm assessment
• Copies of all analytical results
• References to other related plans; e.g SPCC, Contingency
SWP3 Plan‐All States
Page 18
A World Leading MRO ProviderStandardAero is one of the world’s largest independent providers of MRO services, engine and airframe repair and overhaul, engine component repair, engineering services, interior completions and paint applications. We employ nearly 4,000 team members around the world and generate $1.6B in annual sales.
We serve a diverse array of customers in the business/general aviation, airline, military, helicopter, components, energy, and VIP completions markets.
StandardAero provides a global service network of 13 primary facilities in the U.S., Canada, Europe, Singapore and Australia, plus over 50 sales and field service locations.
Page 19
StandardAero Component Services’ facility, in Sharonville, covers approximately 240,000 sq ft, employs approximately 475 people, and has numerous process capabilities, including:
StandardAero Component Services Overview
NDT•Fluorescent Penetrant•Magnetic Particle•Ultrasonic•Robotic and Manual Eddy Current•Radiography
Special Processes•Heat Treating•Shot Peening•Furnace Brazing•Automated Waterjet and Wet Blast•Composite and Bonding Repairs•Balancing
Thermal Spray•Plasma•HVOF•Wire-Arc•Flame Spray
Machining•Conventional Mills/Lathes•CNC Mills and Lathes•Vertical Turret Lathes
• Up to 200 inches•Horizontal Boring Machines•ID/OD Grinding
Welding•Gas Tungsten Arc•Automated Dabber•Electron Beam
Page 21
MAIN OIL USES THROUGHOUT THE FACILITY
Fluorescent Penetrant Inspection
Machine Oils/Coolants• Storage• Reservoirs
Oily wastewater collected in bulk above ground storage tanks for 3rd party disposal.
Page 22
StandardAero Component Services - Site Layout
MACHINE OIL/COOLANT STORAGE AREA
FLUORESCENT PENETRANT INSPECTION
OILY WASTE STORAGE AREA (TANKS)
Page 23• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIALSeptember 19 2013 | QRM2/2013 SNECMA | Company Confidential• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIAL Page 23
Hazardous Waste Contingency Plan-List of Emergency Equipment
EQUIPMENT LOCATION CAPABILITY VerificationFirst aid supplies Employee Meeting
RoomGeneral first aid, minor burns, eye wash, bandages
Stocking vendor
First aid supplies Maintenance Door access
General first aid, minor burns, eye wash, bandages
Stocking vendor
First aid supplies QC Lab aisle way General first aid, minor burns, eye wash, bandages
Stocking vendor
First aid supplies Employee break room General first aid, minor burns, eye wash, bandages
Stocking vendor
First aid Grab-N-Go Center N-S aisle AED, first aid supplies EHS Monthly Inspection tag on AED
Portable fire extinguishers Strategically located throughout the facility
Classes ABC, BC, & D placement determined by fire load
Monthly PM maintenance
Silent Knight Fire Alarm Phone room Building evacuation, automatic notification to 911
Building owner annually – rpt to SFD
ESFR sprinkler system 12 fire zones in the building
Static pressure 80+ psi, coverage extended to all structures within the building. Linked to fire alarm system
Building owner annually – rpt to SFD
Telephone system IT server room Phone and intercom Daily useSafety Shower/eye wash Paint booth, Large NDE
line, Rotating Cell, Main NDE, Clean Line, Chemical Storage room, Honeywell, Dabber, Honeycomb
Thorough drenching for chemical exposure, eye flush
Monthly PM maintenance
Eye wash station Met Lab, shipping Eye flush for chemical exposure Monthly PM maintenance
PPE-aprons, gloves, face shields, respirators
Central Stores Chemical exposure Supply chain inventory
5.4.4 Emergency Response ResourcesIn order to respond to various emergency situations at the facility, StandardAero is equipped with the following emergency response equipment:
Tamper Tags for quick verification
Page 24• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIALSeptember 19 2013 | QRM2/2013 SNECMA | Company Confidential• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIAL Page 24
Hazardous Waste Contingency Plan-Evacuation Plan
•Headcount completed at accountability areas
•Accountability areas are determined by facility Org Chart
•Employee rosters are stored at accountability area and updated monthly.
•Emergency Coordinators are identified/trained for all shifts
Page 25• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIALSeptember 19 2013 | QRM2/2013 SNECMA | Company Confidential• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIAL Page 25
Hazardous Waste Contingency Plan-Implemented due to Process Fire 8/29/2014
• Fire occurred on 2nd shift between 12:45 and 1 a.m. in our Nitric Acid stripping process.
• No injuries occurred as a result of this incident.
• 3 attempts were made by trained employees to extinguish the fire.
• Building evacuation was initiated and Contingency Plan was implemented.
• Main areas of focus were:
• Employee/life safety• Spill/Run off control due to the poly tank breeching and facility fire suppression system activating.• Clean-up• Business Recovery
Page 26• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIALSeptember 19 2013 | QRM2/2013 SNECMA | Company Confidential• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIAL Page 26
Page 27• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIALSeptember 19 2013 | QRM2/2013 SNECMA | Company Confidential• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIAL Page 27
Resulting Business Implications
•2nd shift on 8/29 lost about 35% of their shift productivity
•Weekend shift lost a significant amount of productivity
•The Nitric Process was destroyed requiring replacement. Also, in the meantime, the parts had to be sourced to outside vendors, which impacted customer and delivery dates.
•Approximately 7,500 of wastewater was managed and shipped offsite on 8/29.
•Hazardous Waste was generated
•Significant Costs associated Emergency Response by 3rd
party contractor
States Web sites:• www.in.gov/idem , www.water.ky.gov, www.epa.ohio.gov/dsw• Look at “Compliance”, “Hazardous waste”, Storm Water & “Guidance”
USEPA Web site:• www.epa.gov• Look at “Hazardous Waste”, “SPCC“, “SWP3”
Public Resources