Storm Water Pollution Prevention Training For Industrial Facilities In the City of Memphis.

Storm Water Pollution Prevention Training

For Industrial FacilitiesIn the City of Memphis

What is Storm Water?

Storm water is water flowing over the land during and immediately after a rain storm.

Storm water does not flow into a wastewater treatment system, it flows into our surface watersIn the Memphis area, our storm water system consists of our gutters, storm drains, underground pipes, open channels, culverts, and creeks. Our storm water system discharges into the Wolf, Nonconnah, Loosahatchie and Mississippi Rivers.

What we do on the land affects the water quality and the habitat of our creeks and rivers. It also affects our quality of life, our fisheries, and our recreation.

Why do we have to do something to improve our storm water discharges?

In 1972, Congress passed the Clean Water Act and focused on point source pollution discharges to surface waters. Most point sources have been eliminated, others are permitted.

In 1990, the EPA began the National Pollutant Discharge Elimination System (NPDES) Permitting process to address non-point sources of pollution.

Industries have to have an NPDES Permit for their storm water discharges. The permit requires that industrial facilities have a Storm Water Pollution Prevention Plan (SWPPP), observe their discharges (some also have to sample) and work to implement Best Management Practices (BMPs) to minimize pollutants from leaving their facility.

City of Memphis’ Storm Water Program

As a result of an NPDES permit issued to the City of Memphis, the City is responsible for enforcing storm water pollution prevention requirements.The City of Memphis is committed to an active role in the reduction of pollution and the protection of human health and the environment.City facilities with industrial activities will be required to comply with the NPDES industrial permit regulations for their applicable sector beginning March 2003.

How do you achieve compliance with the NPDES permit?

Each facility needs its own SWPPP that addresses all potential pollutant sources and measures and controls needed to prevent pollution.The facility must implement a quarterly facility inspection and document the inspections in an annual comprehensive site evaluation report and update SWPPP with new BMPs etc.The facility must visually, and in some cases chemically, analyze its storm water runoff for signs of pollution. BMPs must be implemented and, sometimes, engineering controls must be installed in order to prevent pollution from your facility.Employees must be trained.

What is the goal of training employees about storm water?

To stress the importance of being AWARE of and ALERT to conditions that could result in the dischargeof pollutants to storm water!

To improve communicationemployees and supervisors.

Employee training and improved communication could have helped here:

Why is this a storm water problem?

What’s wrong here?

…and here…

What needs to happen here?

…and what has already happened?

TRAINING TOPICSVehicle Washing and FuelingFuel and Chemical Storage ActivitiesSand/Soil PilesVehicle Parking LotsWaste Containers and Drum ManagementOutdoor StorageGood HousekeepingPreventive MaintenanceSpill Prevention and ResponseIllicit Discharge Detection and Reporting

Non-storm water discharges must go to sanitary sewer

This means no washing vehicles outside!!!

This means no washing vehicles outside!

Fuel and Chemical Storage Activites

Fuel and Chemical Transfer ActivitiesConsider how fuels and chemicals are transferred day to day to the fleet.Evaluate and institute transfer procedures for fuels and chemicals from tank trucks to the ASTs and USTs at our facilities. Implement Engineering ControlsReport SpillsClean Up Spills

What BMPs would have helped prevent the pollution leaving this site?

Cover sand and soil piles to prevent pollution!!

Drums must be sealed with covers and

bungs

And preferably inside a secondary containment area!!

Waste products must be stored in covered drums and staged in an assigned area with secondary containment.

Outdoor Storage Areas

ANYTHING STORED OUTSIDE MUST BE CLEANED OF CHEMICAL RESIDUES, PROPERLY CONTAINED, AND WE NEED TO CONSIDER WHY WE ARE KEEPING IT, AND FIGURE OUT HOW TO GET RID OF IT OR STORE IT INSIDE EACH FACILITY’S OUTDOOR STORAGE MUST BE ADDRESSED…

Good Housekeeping Prevents Pollution

Minimize exposure, inspect and report, cleanup spills and leaks promptly

Absorbent material placed on a spill…

…will end up at the outfall if not swept up!!!

Good Housekeeping Inside Buildings to Prevent Pollution

Make sure that there are no discharges from the building to storm water through doorways or other pathways Make sure that spill response equipment is readily available throughout building to contain leaks and spillsClean the floors and do not allow the wash water to discharge outsideHave a comprehensive chemical storage and management plan, specify co-located areas and accumulation amounts for vendor pick-ups

Vehicle Storage Areas Must Be Cleaned To Prevent Pollution

What needs to happen here?

Preventative Maintenance

Daily inspections of equipment and storageRegular maintenance of equipmentRoutine sediment/debris removal and surface cleaning of storm water management devices such as:oil-water separators, ponds, inlets, ditches, & secondary containment of fuel farm

All types of outfalls…

…all need maintenance and cleaning

Leaking vehicles/equipment stored outside should be drained, absorbent material placed to capture releases

Spill Response

Clean all small fuel spills and leaks, and to report significant fuel spills or leaks to management immediately!Always document spills in the SWPPP and SPCC plan in order to learn from mistakesREMEMBER SPILLS ARE CAUSED, THEY DO NOT JUST HAPPEN!!

Spill Prevention and Response

1. Contain2. Locate and Stop the Source3. Clean Up4. Dispose of Properly5. Notify Pollution Prevention Team Members6. Document Release and/or Report if over the

applicable threshold7. Follow Up:

- Evaluate changes needed and modify SWPPP

- Implement changes - Replace spill response equipment used

Again, sweep up the spill absorbent materials!

Review of NPDES Permit Requirements for Industrial

Facilities

Develop a Storm Water Pollution Prevention PlanConduct Quarterly Facility InspectionsConduct Quarterly Visual (Sometimes Chemical) Examination of Storm Water Conduct Annual Comprehensive Site Compliance EvaluationConduct Annual Pollution Prevention Training

Annual Comprehensive Site Compliance Evaluation

Evaluate areas contributing storm water discharge associated with industrial activity for evidence of, or the potential for, pollutants entering the drainage system. Measures to reduce pollutant loadings shall be evaluated to determine whether they are adequate and properly implemented in accordance with the terms of the permit or whether additional control measures are needed. Structural storm water management measures, and other structural pollution prevention measures identified in the plan shall be observed to ensure that they are operating correctly.

Storm Water Hotline

Call 576-6721 to report information about illicit

discharges or other problems that you detect

Visualize cleaner industrial facilities in Memphis…

We can do it!!!