Basic essential training for compliance withStorm Water Pollution Prevention Plans

Storm water Pollution Prevention Plans are written and provided by Corporate Environmental.

Those plans are generic then have been made site specific by each terminal location.

Most of the plans are basic in scope only, with outfalls as marked.

Our purpose is to go over best management practices (BMPs) for truck terminals

What is it and why should we be concerned with something as simple as rain water?

1948 Water Pollution Control Act

1956 Federal Water Pollution Control Act

1965 Water Quality Act

1972 Amendments to the FWPCA establishes the Clean Water Act

The 1972 Clean Water Act leads to the establishment of the National Pollutant Discharge Elimination System (NPDES)

1983 the EPA establishes the Nationwide Urban Runoff Program (NURP) and we are on our way to a program of storm water pollution prevention programs.

1987 Amendments to the CWA directed the EPA to regulate storm water discharges.

Remember, for most of our purposes good best management practices will be sufficient to achieve compliance

For example:

As a trucking company, the number one priority is to REMAIN WITH YOUR TRUCK WHILE FUELING!

Besides a common sense BMP, remaining with your unit is company policy and required procedure at most truck stops.

One of the most expensive incidents of 2010 was a situation in which a fuel line “jumped” out of the tank, and our driver was on his cell phone, not noticing it at the time. The cost to TLG exceeded $14,000!

More BMPs include:

Inventory your truck’s fuel spill kit when checked in, and periodically check the contents and the expiration date on the putty.

Keep your work area tidy. Neatness pays!

Never use storm drains to wash away wastes, clean parts, or clean paint brushes.

Try and store all chemical containers indoors, but if they must be stored outdoors, keep them under secondary containment or under a tarp.

For vehicles with a slow leak, use a temporary drip pan. Never allow fluids to drip on the ground.

Try and load trucks indoors, or outdoors when there is not a current or pending storm event. If that is not possible, be careful not to spill anything that can be washed down and into the storm sewer.

NEVER hose down any area for cleaning. Pick up wastes and spills and sweep clean.

Prompt clean up is important. Don’t put it off until later. You might forget or a storm might come up in the meantime.

If mechanics must perform equipment maintenance outdoors, be sure and use a drop cloth to catch any leakage resulting from the activity.

Metal scraps, trash, any residues of chemicals, etc. need to be removed, covered or cleaned promptly.

All dumpsters with lids must remain with the lids down when not in use.

Open top dumpsters must be covered with a tarp when not in use or during a storm event.

Every terminal’s vaulted diesel tanks must be visually inspected daily to check for leaks or minor spills around the fuel island.

Any spills or leaks that are discovered must be promptly cleaned up with the requisite dry absorbtion method and material properly disposed of.

The smaller above ground tanks we use for storage of oils or small quantities of gasoline are inside a 125% containment wall.

That containment will collect rain water after an event and over time.

On schedule or as needed those containment walls must be emptied of rain water.

That water must be checked for any sheen or other contamination and noted if there is anything that looks or smells of contamination.

Anything that appears “not right” or any sheen, etc. must be reported to Corporate Environmental before proceeding.

If all is well and nothing out of the ordinary is recorded, the water may be emptied (drained) in accordance with company environmental policy.

There is not much more to do. Compliance with the NPDES storm water pollution prevention plan is easy!

Our Corporate Environmental Department handles all the federal reporting and filing of notice of intent (NOI) documents.

As an industrial location all our terminals are eligible for the multi-sector general permits and our Corporate Environmental people handle most of that.

We don’t handle much in the way of hazardous materials, and our trucks do not transport hazardous cargo.

Our outfalls have been mapped so every terminal manager and shop manager should know “where the water runs.”

Our final step is simple…

Just get samples of water runoff during a storm event. Nothing to it…

The essentials of getting that sample are as follows:

► One time per quarter (every 3-months) the terminal manager and location shop manager will need to take an actual sample of storm water runoff during the event.

► A qualifying event is one in which the rain is coming down at an approximate rate of one-half inch per hour.

► Then, it must have been raining for no more than 15-minutes. (In other words, you can’t wait for the rain to come down for an hour – thus cleaning everything off.)

► Next, take your clear glass cups and go to each of the outfalls as marked on your map, and take a sample of the runoff.

This location has 4 outfall areas that have been mapped as locations at which storm water leaves the property.

► Mark each cup as to the specific outfall on that property, then collect all outfall samples and take all the samples inside for observation.

► The observation needs only to be visual and includes smelling the sample and looking for such things as a visible oil sheen etc.

► Check each sample for:1. Color2. Odor3. Clarity4. Floating solids5. Settled solids6. Suspended solids7. Oil sheen8. Foam9. Other indicators of contamination

Make all appropriate notes on your form provided by Corporate Environmental.

As long as there is no obvious visual oil sheen or odor that would indicate contamination, you are essentially done.

Sign, date and file the form and maintain those records in case of an inspection or audit.

What if there is an oil sheen, or obvious odor of contamination?

What do you do next?

What if it has not rained, or not rained while you were able to get the required sample?

If it doesn’t rain, or if it rains when you are not on duty in order to collect the sample, simply make the proper notation on your form as that quarter comes to a close.

Some locations may have several quarters in which there is no qualifying event.

If there is any problem with a sample, contact the fleet safety office and we will review any situation that might have caused the problem.

We will then notify Corporate Environmental Department personnel and go over the details of the sample.

This will likely precipitate further inspection and communication with Corporate Environmental personnel and eventual notification to the EPA as required by our permit.

If the exact source or contaminant is unknown the sample will be sent to a laboratory for testing and evaluation.

Problems very rarely occur, and the rare occasion that they have, our environmental people have made the proper notifications and the source of the problem was promptly corrected (in each case even before the notification was made).

Problems can happen, but any observations that are necessary can correct small problems before they become big problems.

•Storm water pollution prevention is simple and does not require significant changes in any normal work activities.

•Just follow basic BMPs, and clean up leaks and spills with dry pickup methods.

Anderson, D. (2011, February). Clean Water Act. Presented at a SMGT 528.01 W lecture at University of Texas A&M-Commerce.

Excal Visual, LLP, (2011). Storm water pollution prevention. Best management practices guidebook (SW:SWPP-guidebook, 0603). [Brochure]. Boulder, CO: Author. (Produced by Excal Visual for use with their video: Storm Water Pollution Prevention: Storm Warnings, and Everyday BMPs. For J.J. Keller & Associates.)

 J.J. Keller & Associates, Inc. (2011, n.d.). EPA administered programs: The national pollutant

discharge elimination system. Retrieved information and research data various dates in March and April,2011 from http://www.kelleronline.com/Topics/TopicInfo.aspx?TopicKey=9877&DocType=2&Linktype=1&linkdata=30619. (Inside, J.J. Keller.com and password protected subscription to Keller Online®.)

Sullivan, T.P.F. (Ed.). (2009). Environmental law handbook (20th ed.). Lanham, MD: Government Institutes (An Imprint of The Scarecrow Press, Inc.).

United States Environmental Protection Agency (n.d.). Storm water discharges from industrial facilities. Retrieved various dates in March and April, 2011 from http://cfpub.epa.gov/npdes/stormwater/indust.cfm, and Developing your storm water pollution prevention plan, a guide for industrial operators from http://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf.

United States Environmental Protection Agency (n.d.). Miscellaneous information and research. Retrieved various dates in March and April 2011 from http://www.epa.gov and http://www.epa.gov/npdes/pubs/idde_chapter-1.pdf and http://cfpub.epa.gov/npdes/glossary.cfm?program_id=0 and http://water.epa.gov/scitech/swguidance/standards/history.cfm; original photographs are from the EPA websites and internal links unless labeled otherwise.