Timothy Carvana MARTA Environmental Safety Engineer August 2007

1. A&WMA Southern Section 2007 ConferenceDevelopment and Implementation of Storm Water Pollution Prevention and SPCC Programs Timothy Carvana MARTA Environmental Safety Engineer August 2007

2. OVERVIEW • Regulatory programs • MARTA facilities affected • Storm Water Pollution Prevention and Emergency Response (SWPP&ER) Program Development • SWPP&ER Program Documents • SWPP&ER Program Implementation • SWPP&ER Program Results

3. REGULATORY PROGRAMS • National Pollutant Discharge Elimination System (NPDES) General Permit • Oil Storage and Hazardous Waste [40 Code of Federal Regulations (CFR) 112, 40 CFR 265 Subpart D, Georgia Environmental Protection Division (GEPD) Rule 391-3-11]

4. MARTA FACILITIES AFFECTED • Maintenance facilities that discharge storm water associated with industrial activity • 5 Bus Maintenance Facilities • 3 Rail Maintenance Facilities • Processes causing facilities to meet regulatory requirements • Light and heavy maintenance of trains and buses • Storage of petroleums, oils, and lubricants (POLs) greater than 1,320 gallons

5. SWPP&ER PROGRAM DEVELOPMENT • Kickoff meeting with stakeholders • Site visits • Document preparation

6. SWPP&ER Program Development: Kickoff Meetings and Site Visits • Kickoff meeting with stakeholders • Discuss documents • Identify Pollution Prevention Team (PPT) • Determine submittal and review schedule • Obstacles • Logistics for getting various departments together • Site visit • Brief walkthrough same day as site visit • Follow-up as needed for specific information and figure markups • Scheduled different times with different departments so only attended part pertinent to each department (attend multiple if responsibilities overlap)

7. SWPP&ER Program Development: Document Preparation • Draft • Set of all documents submitted to stakeholders • Review • Meeting to discuss draft contents with stakeholders • Final • Binder with all finalized documents

8. SWPP&ER PROGRAM DOCUMENTS • OnePlan • Spill Prevention, Control, and Countermeasures (SPCC) Plan • Storm Water Pollution Prevention Plan (SWP3) • Storm Water Monitoring Plan • Spill Equipment Memo • Training • Spill Posters

9. SWPP&ER Program Documents: OnePlan • Lists necessary steps for personnel to use in case of environmental emergencies at any MARTA maintenance facility. • Contains specific information for each MARTA maintenance facility subject to state and federal requirements. • Provides needed contact information in time of emergencies for all types of spills.

10. SWPP&ER Program Documents: SPCC Plan • Addresses the storage and management of petroleum products within MARTA maintenance facilities • Fulfills the requirements of 40 CFR Part 112 • SPCC Plan required if aboveground oil storage volume exceeds 1,320 gallons for all containers that hold 55-gallons or more in volume • Identifies and evaluates potential spill sources of oil and hazardous material • Outlines procedures designed to prevent the discharge of oil or hazardous substances into the environment and to respond to releases that do occur

11. SWPP&ER Program Documents: SWP3 • Identifies potential sources of storm water pollution • Establishes and implements practices and structural controls (when necessary) to eliminate, minimize, and/or control the potential for contamination of storm water • Establishes a PPT, which is responsible for implementation, maintenance, and revision of the SWP3

12. SWPP&ER Program Documents: Storm Water Monitoring Plan • Follows requirements of NPDES General Permit • Identifies outfalls requiring monitoring • Describes inspection procedures to follow during monitoring events

13. SWPP&ER Program Documents: Spill Equipment Memo • Summarizes evaluation of spill response equipment at each facility • Identifies potential spill sources • Recommends locations for storing spill response equipment

14. SWPP&ER Program Documents: Training • Modules for Safety Meetings • Spill Response (OnePlan) • Spill Prevention and Response • Storm Water Pollution Prevention • Hazardous Waste Awareness • Industrial Wastewater Treatment and Recycling • Enhanced (hands-on) training and spill drills

15. SWPP&ER Program Documents: Spill Response Posters Contact information and elements of a spill response for fast reference in event of a spill

16. SWPP&ER PROGRAM IMPLEMENTATION • Plan Requirements • Training • Program Review and Updates

17. SWPP&ER Program Implementation: Plan Requirements • Storm Water Monitoring • Annual Inspections • Non-Storm Water Discharge Evaluation • Storm Water Inspection from Containment Areas • Integrity Testing

18. SWPP&ER Program Implementation: Training • Basic training for all employees • Spill prevention and spill response information • Stormwater best management practices (BMPs) • Hazardous waste awareness • Enhanced spill response training for employees who may respond to a spill • Spill drills to ensure employees have basic understanding of SWPP&ER program

19. SWPP&ER Program Implementation: Program Review and Updates • Reviews • Annually • Change in facility operations • Updates • SWP3 - Issuance of new General Permit • SPCC - Every 5 years

20. SWPP&ER PROGRAM STATUS • Accomplishments • Implementation at all maintenance facilities • Current progress • Beginning process of updating everything on 5 year cycle • Future goals • Continued awareness with all facility personnel

21. Questions ?