good housekeeping and spill...
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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
Pictures
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
Pictures
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
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