SWPP and SPCC Plans Best Practices

1. SWPP and SPCC Plans & Best Practices Ground Water and Surface Water Training Session June 24, 2009 Fairfax County I-95 Landfill Presented By Jim Johnston, PE

2. 2 SWP3 Topics to be Covered Background and Purpose of SWP3 Storm Water Pollution Prevention Team Potential Pollutant Sources Measures and Controls Good Housekeeping Preventative Maintenance Spill Prevention and Response Employee Training Best Management Practices (BMPs) Site Inspections and Monitoring Requirements

3. 3 I. Background and Purpose of SWP3 Ensures compliance with permit and state regulations (VPDES general permit) Establishes best management practices and controls for the specific facility Identifies potential pollutant sources Minimizes potential for release of harmful materials to storm water Ensures specified controls are implemented Ensures management buy-in

4. 4 II. Storm Water Prevention Team To avoid continuously update plan, use position titles instead of names. Make sure the individuals have the knowledge and experience to qualify to oversee Best Mgt Practices.

5. 5 III. Potential Pollutant Sources Inventory of exposed materials Potential Pollutant areas/sources Record of significant spills and leaks Site drainage map Outfall identification Updated regularly to accurately reflect site conditions

6. 6 IV. Measures and Controls Best Management Practices Good Housekeeping � includes but not limited to: Maintaining clean and orderly work environment Education of employees on housekeeping practices Conduct repairs and maintenance indoors if possible Washing of aircraft/vehicles within designated wash areas Regular disposal of waste materials Up-to-date inventory of materials Use and inspection of drip pans under leaking equipment

7. 7 IV. Measures and Controls (cont.) Best Management Practices (cont.) Material Storage Practices Identify chemicals present and label containers Storing containers, drums and bags out of traffic routes and walkways Storing containers indoors on pallets to prevent corrosion Provide adequate space for material transfer and access for inspections Discuss good housekeeping at employee meetings Spilled materials cost everyone money and time!

8. 8 IV. Measures and Controls (cont.) Best Management Practices (cont.) Preventative Maintenance Inspecting outside equipment and containers for leaks Regular inspections and maintenance of outside equipment, fuel farm containment, and parking lots Maintaining storm water management devices (catch basins, ditches, etc.) Check for signs of erosion

9. 9 IV. Measures and Controls (cont.) Best Management Practices (BMPs) Designated and evaluated by SWP3 team Updated as needed based on inspections General grounds inspection (monthly) Inspect loading and unloading facilities Inspect outfalls Good housekeeping

10. 10 VIII. Implementing an Effective Program Identify SWP3 Team Everyone�s Responsibility Store material indoors where practical Practice good housekeeping Maintain awareness of storm drains and potential pollutant sources Clean facility = safe facility Conduct timely inspections

11. 11 Summary Keep SWP3 current with updates SWP3 Team should meet regularly Timely Inspections Training annually and as required Documentation! �If it�s not recorded it must not have happened� � Your Inspector File reports and inspections in SWP3

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16. 16 What is a SPCC Plan? Spill Prevention, Control, and Countermeasures Purpose is to prevent oil* spills from polluting our nation�s navigable waterways* which are defined under the Clean Water Act and Oil Pollution Act (*see definitions on next slide) Spilled materials pose a threat to soil, ground water, fresh water, marine habitats, and human & animal life Most updated SPCC Plans must be certified by a registered P.E.

17. 17 Definitions �Navigable Waterways� = includes lakes, rivers, streams, wetlands, wet meadows, playa lakes, and ponds Basically covers almost all natural surface water in the U.S. �Oil� = petroleum, fuel oil, sludge, oil refuse & oil mixed with wastes, non-petroleum oils, synthetic oils, animal fats, oil & greases, and vegetable oils (biodiesel)

18. 18 Regulatory History Rule was originally promulgated on December 11, 1973 by EPA Over 100 pages of amendments published in 2002 (40 CFR Part 112) EPA announced additional amendments in December 2006 Compliance deadline extensions granted six times, most recently in March 2009

19. 19 Do I Need a SPCC Plan? Preparation and implementation of SPCC requirements apply to facilities that have a total aboveground oil storage capacity of 1,320 gallons or underground storage capacity > 42,000 gallons Heating oil AST for your scalehouse? Diesel AST for your on-site heavy equipment? Gasoline AST for your on-site vehicles? Waste Oil AST from on-site maintenance or citizen convenience center? 55 Gallon drums of grease/lubricant for equipment? Transformers and other oil filled electrical equipment?

20. 20 SPCC Plan Requirements Identification & location of all storage media, capacity, function, and actual inventory Control measures to prevent a spill Descriptions of any past spills detailing corrective actions taken and prevention of a reoccurrence Prediction of direction, flow rate, & quantity of oil that could be spilled (based on potential equipment failures) Description of any containment or diversionary structures and available equipment

21. 21 SPCC Plan Requirements (con�t) Detailed discussion of the spill prevention measures that apply to the specific facility Operating procedures that have been implemented to prevent future spills from occurring Control measures in force to prevent future oil spills Implemented procedures & countermeasures to contain, clean-up, and lessen the damage of any spill

22. 22 Highlights of the Amendments Clarification of the criteria used to determine who must prepare and SPCC Plan Expansion & clarification of requirements regarding both the content & format of SPCC Plans New requirement that ASTs and underground piping must be periodically tested for integrity Expansion & clarification of design, performance, & PE certification requirements for secondary containment systems For example, EPA has clarified that secondary containment is required not just for the storage tanks, but also for the loading & unloading areas New requirements for corrosion protection of underground piping

23. 23 Highlights of the Amendments (con�t) Modification of the stormwater management & recordkeeping requirements Clarification & expansion of requirements for routine facility inspections & associated recordkeeping Modification of the training requirements for employees that handle petroleum products Modification of requirements for periodic SPCC Plan reviews & updates Clarification & expansion of requirements for Professional Engineer�s role in SPCC Plan preparation & certification Clarification of the owner�s responsibility for implementation of the SPCC Plan

24. 24 Tiered Approach � Tier 1 <10,000 gallons of aboveground oil storage Have not had a single discharge of 1,000 gallons or two discharges of 42 gallons to waterways NO individual containers >5,000 gallons Self-certified SPCC Plan with SOME aspects of 40 CFR 112.7 (eliminating some provisions that do not apply to facilities that store small volumes of oil [e.g., loading racks])

25. 25 Tiered Approach � Tier 2 Same as Tier 1, except you DO have individual containers >5,000 gallons Self-certified SPCC Plan with ALL aspects of 40 CFR 112.7

26. 26 Tiered Approach � All Other Facilities >10,000 gallons of aboveground oil storage PE-certified SPCC Plan with ALL aspects of 40 CFR 112.7

27. 27 Compliance Deadlines Modified plans for existing facilities (EPA must review SPCCs): by January 14, 2010 Plan implementation, including facility modifications and upgrades: by January 14, 2010 Previous deadline was July 1, 2009 These reflect the 6th extension granted on March 30, 2009

28. 28 Penalties EPA can make announced or unannounced inspections Failure to comply with these regulations can result in fines up to $25,000 per day per violation Some specific violations subject to penalties are: Using untrained personnel Failure to report a spill that enters a waterway Lack of an adequate SPCC plan

29. 29 The End Questions? Don�t hesitate to e-mail me at jjohnston@scsengineers.com Thanks!