SPCC and Stormwater Update October 23, 2013 0
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SPCC and Stormwater UpdateOctober 23, 2013
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Contents
• Spill Prevention Control and Countermeasure (SPCC) Regulations
• Construction Stormwater Permitting
• Developing Stormwater Pollution Prevention Plans (SWPPPs)
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SPCC – What Will be Covered
• Who Needs an SPCC Plan• Summary of SPCC Plan Requirements • Amendments/Deadlines• Revised Guidance• Bulk Storage Container Inspection Fact Sheet• Tips to Make Compliance Easier• Common Audit Findings• Resources
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Who Needs an SPCC Plan
1) Non-Transportation-Related Facility engaged
in drilling, producing, gathering, storing,
processing, refining, transferring, distributing, using,
or consuming…
2) More than 1,320 gallons (in 55 gallon or larger
containers) of Oil…
3) And can discharge to a Navigable Waterway…
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Who Needs an SPCC Plan (cont.)
Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil (§112.2)
But… different regulatory programs may define it differently.
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Who Needs an SPCC Plan (cont.)
What is a navigable waterway?“Navigable waters" as defined in section 502(7) of the FWPCA, and includes: (1) all navigable waters of the United States, as defined in judicial decisions prior to the passage of the 1972 Amendments of the Federal Water Pollution Control Act, (FWPCA) (Pub. L. 92-500) also known as the Clean Water Act (CWA), and tributaries of such waters as; (2) interstate waters; (3) intrastate lakes, rivers, and streams which are utilized by interstate travelers for recreational or other purposes; and (4) intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in interstate commerce.
Due to court decisions, EPA and USACE have struggled with providing guidance.
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Summary of SPCC Requirements
•Professional Engineer Certification•Plan Amendments – Owner/EPA•Preparation and Implementation•Inspections, Tests, and Records•Personnel and Training Requirements
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Summary of SPCC Requirements
•Security Requirements•Brittle Fracture Evaluation•Bulk Storage Tanks Requirements•Transfer Operations, Piping & Pumping
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Amendments/Deadlines
ALL DEADLINES HAVE PASSED!!!
Major revisions in ‘02, ‘06, ‘08, and ‘09
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Updated Guidance
Chapter 1 - Introduction
• Describes the rule and regulatory framework
• Summary of amendments along with specific discussions (table format in Appendix C)
• Includes summary of deadlines
• Much more detailed and easier to understand the various changes to the rule
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Updated Guidance
Chapter 2 – SPCC Applicability
• Clarifies the facilities, equipment, and activities subject to the rule
• Greatly expanded to include scenarios and examples
• Breaks out additional types of oils – synthetic, AFVO, oil and water, biodiesel, etc.
• New section regarding the definition of “facility”, examples of aggregation/separation
• Expanded discussion of EPA/DOT jurisdiction, including tank and railcars, vessels, and marine terminals to demonstrate where jurisdiction is divided/overlaps
• Incorporates discussions of all of the exemptions included in the revised regulation
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Updated Guidance
Chapter 3 – Env. Equivalence
• Discusses the flexibility to develop site-specific methods of compliance as long as they provide equivalent protection and are approved by the PE
• Most significant change is that the USEPA specifically indicates that cost CAN be a factor in selecting an environmentally equivalent option
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Updated Guidance
Chapter 4 – Secondary Containment
• Discusses secondary containment and use of impracticability determinations
• Much more complete discussion of the options available in the regulations (passive vs. active, alternative measures)
• Clarifies some areas of confusion (difference between contingency plans and active containment measures)
•Additional issues discussed such as general secondary containment for piping
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Updated Guidance
Chapter 5 – Oil-Water Separators
• Discusses various scenarios on how to characterize oil-water separators•Added additional clarification for oil-water separators at oil production facilities and oil recovery and/or recycling facilities
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Updated Guidance
Chapter 6 – Facility Diagrams
•Discusses what needs to be included on facility diagrams
•Biggest change is the addition of a completely new section regarding what needs to be included in the General Facility Description section of a SPCC Plan
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Updated Guidance
Chapter 7 – Inspect/Evaluate/Test
• Provides a summary of inspection, evaluation, and testing requirements for containers and piping
•Adds specific guidance for developing a hybrid program
• Expands summary of16 industry standards
• Discusses removal of oil accumulations in bulk storage diked areas
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Updated Guidance
Appendices
• Updated to include a summary of revised rule provisions• Sample plans• Inspection checklists – Revised!• Policy documents
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Bulk Storage Container
Inspection Fact Sheet• Integrity testing only applies to bulk containers, not
OFOE
• Rule requires you to 1) test or inspect each
container, 2) Frequently inspect the outside of each
container, and 3) Identify the type and frequency of
testing for each container in your SPCC Plan
•Use industry standards to establish schedule and
document it in your SPCC Plan
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Bulk Storage Container
Inspection Fact Sheet (cont.)• If you have not yet inspected certain containers, it is
acceptable to include a discussion of the details of
the program to be implemented, including a schedule
• Change in understanding for environmental
equivalence for certain shop-built containers, STI
SP001 was revised to allow for visual inspection on
certain types of containers
• Includes guidance on what elements to include in a
hybrid inspection program
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Tips for Making Compliance
Easier• If applicable, use the qualified facilities option
• Consider alternative methods of defining your facility boundaries – if portions of your property are distinctly different then it might make sense to define separately
• Work closely with your PE to identify ways to comply that fit with how your organization works
• Take advantage of the regulatory relief offered in many of the amendments to the regulations –environmental equivalence, impracticability, etc.
• Make sure you are accurately applying the definitions to identify the appropriate requirements
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Common Audit Findings• Not having a plan at all
• Failing to include ALL required elements of an SPCC
• Failure to identify “non-traditional” oils
• Not identifying all drainage pathways
• Not including transformers, hydraulic systems,
elevators, emergency generators
• Failure to conduct inspections as required
• Not adequate protecting containers from vandalism
• Plan not certified by PE or signed by management
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Common Audit Findings•Not including containment calculations where required
•Missing tank inspections/testing
•Missing substantial harm criteria/signature
•Not reviewing/updating plan every five years
•Plan not current (i.e., new tanks added without PE
certification)
•Not identifying deviations or environmental equivalence
•Failure to identify “active” containment
•Not using appropriate industry standard
•Improperly characterizing oil-water separators
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Resources
Definition of Navigable Waters:
◦ http://www.usace.army.mil/Portals/2/docs/civilwor
ks/regulatory/cwa_guide/cwa_juris_2dec08.pdf
SPCC Inspector’s Guidance Manual
◦ http://www.epa.gov/emergencies/docs/oil/spcc/gui
dance/SPCC_Guidance_fulltext.pdf
Bulk Storage Container Inspection Fact
Sheet
◦ http://www.epa.gov/emergencies/docs/oil/spcc/int
egrity-testing-factsheet.pdf
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Construction Stormwater Permit
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Construction Stormwater
What Will be Covered
• New Illinois General Permit• Implementation• Notice of Intent• Non-Stormwater Discharges• SWPPP• Miscellaneous Changes• Definitions• Resources
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New Illinois General Permit
On July 30, 2013, the IEPA issued General NPDES
Permit No. ILR10 for Storm Water Discharges
from Construction Site Activities
• Effective August 1, 2013, expires July 31, 2018
• Implements Federal 2012 Construction
General Permit
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Implementation
• Ongoing construction projects are automatically
covered under the new permit; however,
•A Notice of Termination must be submitted
by July 31, 2014, OR
• Revise SWPPP to comply with new permit
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Notice of Intent
• NOIs/NOTs and SWPPPs are to be submitted
electronically
• Projects operating under approved local plans or
active MS4 permit holders have to submit a copy of
the NOI as well
• Minor modifications to the contents of NOTs
(dates of completion and stabilization)
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Non-Stormwater Discharges• Allowed if identified in the SWPPP with appropriate controls:
• Fire-fighting activities, fire hydrant flushing, vehicle wash water (no detergent), water from dust control, potable water sources, landscape irrigation, building wash water (no detergent), pavement wash water (no spills), air conditioning condensate, uncontaminated ground water, foundation drains
• Not allowed:
•Concrete/washout, wash water from construction materials (drywall compound, stucco, paint, etc.), fuels, oils, soaps, solvents, detergents, spills
• Dewatering of trenches and excavation is allowed if appropriately managed
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SWPPPs
• Major revisions to SWPPP requirements to comply
with 40 CFR 450
•A copy of the permit Approval Letter and the
permit must be posted at the construction site
• Description needs to include locations of on or off-
site soil stockpiling/material storage
• Detailed information about post-construction
runoff coefficients, drainage patterns
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SWPPPs
Controls
• Erosion and sediment controls to match 40 CFR
450
• Stabilization has to be initiated within 1 working day
of cessation of earth-moving activities and completed
within 14 days
•Added design requirements for sediment basins
•Added pollution prevention measures and control of
other waste provisions
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SWPPPs
Controls (cont.)
• Post-Construction storm water management must
be included in the SWPPP
•What controls will be installed during construction
to reduce storm water runoff post-construction?
•Velocity dissipation devices shall be placed as
necessary to protect water courses
• Plan for 25-year, 24-hour storm event
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SWPPPs
Inspections
• Inspections must be made once every 7 days and
within 24 hours after a large storm
• Inspections can be performed by a Certified
Professional in Erosion and Sediment Control and a
Certified Erosion Sediment and Storm Water
Inspector, Professional Engineer or “other
knowledgeable person”
• 24-hour and 5-day reporting and immediate
corrective actions in the event of an incident of non-
compliance
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Miscellaneous Changes
•Added Bypass/Upset provisions to Standard
Conditions
•Added definition of construction activity and work
day
•Changed “Facility” to “Construction Activity”
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Definitions
Construction Activity
Earth disturbing activities, such as clearing, grading
and excavation of land. For purposes of this permit,
construction activities also means construction site,
construction site activities, or site. Construction
activities also include any demolition activities at a
site.
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Definitions
Disturbance
Disturbance is defined as exposed soil from clearing,
grading, and excavation, although not limited to these
activities. The total acreage disturbed includes not
only the actual area being excavated but also the area
where materials/soils are stored and equipment
staging areas which may alter the land surface, even if
for a temporary period of time and even if site
restoration is planned.
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Definitions
Common Plan of Development?A "larger common plan of development or sale" is a contiguous area where multiple separate and distinct construction activities may be taking place at different times on different schedules under one plan. For example, if a developer buys a 20-acre lot and builds roads, installs pipes, and runs electricity with the intention of constructing homes or other structures sometime in the future, this would be considered a larger common plan of development or sale. If the land is parceled off or sold, and construction occurs on plots that are less than one acre by separate, independent builders, this activity still would be subject to stormwater permitting requirements if the smaller plots were included on the original site plan. The larger common plan of development or sale also applies to other types of land development such as industrial parks or well fields. A permit is required if one or more acres of land will be disturbed, regardless of the size of any of the individually-owned or developed sites. (http://cfpub.epa.gov/npdes/faqs.cfm?program_id=6#303)
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Resources
Illinois General Permit
◦ http://www.epa.state.il.us/water/permits/stor
m-water/general-construction-permit.pdf
Illinois Urban Manual
◦ http://aiswcd.org/IUM/index.html
USEPA Guidance/Templates
◦ http://cfpub.epa.gov/npdes/stormwater/swppp.
cfm
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Developing Stormwater Pollution
Prevention Plans
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SWPPPs –
What Will be Covered
• Summary of SWPPP Requirements
• Developing a SWPPP
• Common Issues
• Resources
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SWPPP Requirements
The Basics- Topographic and Site Maps
- Narrative describing the site, operations,
types of materials, structural and non-
structural control measures, storage and
disposal methods
- Types of pollutants likely to be present
- Estimate of impervious areas
- Sampling data, if any
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SWPPP Requirements
The Basics (cont.)
- Storm Water Management Controls include:
1) SWPPP Personnel
2) Preventative Maintenance
3) Good Housekeeping
4) Spill Prevention and Response
5) Storm Water Management Practices (containment, oil and grease separation, debris and sediment control, waste chemical disposal, storm water diversion, covered areas, mercury switch removal, storm water reduction)
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SWPPP Requirements
The Basics (cont.)
- Storm Water Management Controls include:
6) Sediment and Erosion Prevention
7) Employee Training
8) Inspection Procedures
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SWPPP Requirements
The Basics (cont.)
- Non-storm water discharge certification
- Quarterly visual observations of discharges
- Annual facility inspection
- Certification
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Developing the SWPPP
Step 1 – Establishing SWPPP Team
- Identify your SWPPP Team
- Responsible for implementing the SWPPP, including
corrective actions
-There is no set size on the number of people that
have to be on the SWPPP team
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Developing the SWPPP
Step 2 – Assessment/Planning
- Conduct an assessment of the activities at your
facility to identify potential sources of pollution
- Evaluate previous sampling data for potential issues
- Prepare maps of the facility to include industrial
activities, pollutant sources, control measures, and the
direction of stormwater flow
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Developing the SWPPP
Step 3 – Select Control Measures
- In general, control measures fall into pollution
prevention, minimizing exposure, combining measures
where necessary, understanding your site’s sources of
pollution, maximizing infiltration, using vegetated
areas, buffering from natural drainage areas, and using
structural practices as necessary
- Selecting your control measures can be difficult!
-The USEPA has identified 12 technology-based
discharge requirements (and don’t forget sector
notebooks)53
Developing the SWPPP
Step 4 – Monitoring/Inspections
Routine Facility Inspections
- How often will you inspect/maintain storm water
conveyance systems such as oil-water separators,
etc.?
- How often will you inspect/maintain plant systems
whose failure could result in storm water pollution?
- Inspections and maintenance records need to be
maintained
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Developing the SWPPP
Step 4 (cont.)Quarterly Visual Sampling
Your visual observation must be made on samples collected as soon as practical, but not to exceed 1 hour of when the runoff or snowmelt begins discharging from your facility. All samples must be collected from a storm event discharge that is greater than 0.1 inch in magnitude and that occurs at least 72 hours from the previously measurable (greater than 0.1 inch rainfall) storm event. The observation must document: color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, and other obvious indicators of storm water pollution. If visual observations indicate any unnatural color, odor, turbidity, floatable material, oil sheen or other indicators of storm water pollution, the permittee shall obtain a sample and conduct additional analysis.
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Developing the SWPPP
Step 4Annual Facility Inspections
- Illinois has a specific form that needs to be
completed and submitted
- Identify any activity such as a spill which may have
led to a discharge of pollutants
- Identify any changes that needed to be made to the
SWPPP
- Include information regarding quarterly visual
observations of discharges
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Common Issues
• No SWPPP developed
• Control measures not used
• No SWPPP on site
• SWPPP not signed
• SWPPP team not up to date
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Common Issues (cont.)
• Staff not aware they have a SWPPP
• Improper collection of visual samples
• Uncovered dumpsters
• Poor or no training (contractors too)
• Records not included with the SWPPP
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Resources
Developing a SWPPP:http://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf
SWPPP Template: http://www.epa.gov/npdes/pubs/msgp2008_swppptemplate.doc
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Questions?
Jennifer Gould, CHMM, CPEA
Senior Environmental Specialist
Exelon Nuclear
(630) 657-3210
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