pollution prevention and good housekeeping activities for municipal operations developing the storm...

Pollution Prevention and Pollution Prevention and Good Housekeeping Activities forGood Housekeeping Activities for

Municipal OperationsMunicipal Operations

Developing the Storm Water Pollution Developing the Storm Water Pollution Prevention Plan Prevention Plan

Presenter: Keith Noble, Saginaw Bay District OfficePresenter: Keith Noble, Saginaw Bay District Office

How to develop a How to develop a Storm Water Pollution Prevention Plan Storm Water Pollution Prevention Plan

Who needs to develop the Who needs to develop the Storm Water Pollution Storm Water Pollution

Prevention PlanPrevention Plan

Including the following municipal operations:Including the following municipal operations:AirportsAirportsWastewater Treatment Plants (1MGD+)Wastewater Treatment Plants (1MGD+)Maintenance facilities for bus and waste Maintenance facilities for bus and waste

Hauling vehiclesHauling vehiclesLand fillsLand fillsLand Applications sitesLand Applications sites

Facilities regulated by theFacilities regulated by theindustrial storm water regulationsindustrial storm water regulations

Municipal owned or operated Municipal owned or operated facilities that are not designated facilities that are not designated

by the Industrial Storm Water by the Industrial Storm Water regulations, which meet any of regulations, which meet any of

the following criteria, must the following criteria, must develop and implement a develop and implement a

SWPPP.SWPPP.

There are storm water There are storm water discharges to surface discharges to surface

waters of the statewaters of the state

Facilities will need to develop a Facilities will need to develop a SWPPP if:SWPPP if:

They meet the definition of a storage yardThey meet the definition of a storage yard

There is a fleet and maintenance There is a fleet and maintenance activities for the fleet are conducted activities for the fleet are conducted

outsideoutside

Maintenance is performed outsideMaintenance is performed outside

There is evidence of poor There is evidence of poor housekeepinghousekeeping

Information on who needs to Information on who needs to develop the SWPPP is in the develop the SWPPP is in the

Pollution Prevention and Good Pollution Prevention and Good Housekeeping Activities for Housekeeping Activities for

Municipal Operations Municipal Operations compliance assistance compliance assistance

document available on the document available on the

DNRE storm water web siteDNRE storm water web site

http://www.michigan.gov/deqstormwater

The industrial storm water certified The industrial storm water certified operator training provides instruction for operator training provides instruction for the development and implementation of the development and implementation of the SWPPP the SWPPP

Contact District Water Bureau Staff to Contact District Water Bureau Staff to schedule trainingschedule training

Certified Operator TrainingCertified Operator Training

The Industrial Storm Water Certified The Industrial Storm Water Certified Operator Training Manual is located @ Operator Training Manual is located @ http://http://www.michigan.gov/deqstormwaterwww.michigan.gov/deqstormwater on the Industrial Program page.on the Industrial Program page.

Certified Operator TrainingCertified Operator Training

The SWPPP needs to be The SWPPP needs to be developed and implemented by the developed and implemented by the due date for the SWPPI or SWMPdue date for the SWPPI or SWMP

For municipalities that are permitted under For municipalities that are permitted under the watershed general permit they must the watershed general permit they must have a industrial storm water certified have a industrial storm water certified operator unless the SWPPP is submitted operator unless the SWPPP is submitted as part of the SWPPI.as part of the SWPPI.

Storm Water Pollution Prevention Plan Storm Water Pollution Prevention Plan (SWPPP)(SWPPP)

A lengthy plan is not necessarily an A lengthy plan is not necessarily an effective plan.effective plan.

Pollution Incident Prevention Plan Pollution Incident Prevention Plan (PIPP) (Part 5 Rules)(PIPP) (Part 5 Rules)

Liquid Polluting MaterialsLiquid Polluting Materials

Solid Polluting MaterialsSolid Polluting Materials

Spill Prevention Countermeasures and Spill Prevention Countermeasures and Control Plan (SPCC) (40 CFR 112) Control Plan (SPCC) (40 CFR 112)

Oil Pollution PreventionOil Pollution Prevention

Ethanol PlantsEthanol Plants

Asphalt PlantsAsphalt Plants

Integrated Contingency PlansIntegrated Contingency Plans

Typically include all environmental, health, Typically include all environmental, health, and safety plans including SWPPP, PIPP, and safety plans including SWPPP, PIPP, and SPCCand SPCC

Sample plans can be obtained from the Sample plans can be obtained from the DNRE district offices.DNRE district offices.

SWPPP RequirementsSWPPP Requirements

SWPPP must identify Significant SWPPP must identify Significant Materials both outside…Materials both outside…

and inside the facilityand inside the facility

GoalGoal Prevent the contamination of Prevent the contamination of the surface waters of the statethe surface waters of the state

SedimentSediment

Remember…preventing pollution is the Remember…preventing pollution is the BEST SOLUTIONBEST SOLUTION

Developing a SWPPPDeveloping a SWPPP

Storm Water Pollution Prevention PlanStorm Water Pollution Prevention Plan

• Source IdentificationSource Identification• Non-Structural ControlsNon-Structural Controls• Structural ControlsStructural Controls

Site Map DevelopmentSite Map Development

Source Identification

Clean palletsPlastic Pellet Hopper in secondary containment

Material Handling & Loading / Unloading Area

Material Handling & Loading / Unloading Area

Double Walled Diesel and Gasoline Tanks

Fuel Island with curbing

2 Covered 20 yrd roll-off dumpsters

Cry

stal

Cle

ar C

reek

Cry

stal

Cle

ar C

reek

Vegetation

Building

Asphalt

Property Boundary

Exposed / Erodible Soils

Contaminated Soil listed under Part 201

Trench Drain

Roof Drains

Storm Water Catch Basins

Detention Pond

Outfall 003

Ou

tfal

l 00

2

Roof Drainage

Asphalt Drainage

Municipal Storm Water Discharge

NPDES Non-Contact Cooling Water Discharge

Ou

tfal

l 00

1C

ryst

al C

lear

Cre

ek

Municipal Storm Sewer System

Site map must show everything Site map must show everything relevant to storm waterrelevant to storm water


Identifying Significant MaterialsIdentifying Significant Materials


SoilsSoils


SaltSalt


Raw MaterialsRaw Materials


Fuels andFuels and

LubricantsLubricants


Solvents and DetergentsSolvents and Detergents


Fertilizers and PesticidesFertilizers and Pesticides


Waste ProductsWaste Products


Polluting MaterialsPolluting Materials


WastewaterWastewater


Building MaterialsBuilding Materials


All sources of contamination need to be All sources of contamination need to be identifiedidentified


Remember Remember The outside and inside The outside and inside of the facility must be evaluatedof the facility must be evaluated


Significant Material InventorySignificant Material Inventory


Pollutant SourcesPollutant Sources


Loading, unloading, and other Loading, unloading, and other material handling operationsmaterial handling operations


Outdoor storage including Outdoor storage including secondary containment structuressecondary containment structures


On-site waste disposal practicesOn-site waste disposal practices


Maintenance and cleaning of Maintenance and cleaning of vehicles, machines, and equipmentvehicles, machines, and equipment


Areas of exposed and / or erodible Areas of exposed and / or erodible soilssoils


Sites of Environmental Sites of Environmental Contamination, under Part 201Contamination, under Part 201


Other areas where storm water Other areas where storm water may contact significant materialsmay contact significant materials


Inventory exposed materials and Inventory exposed materials and evaluate method of exposureevaluate method of exposure

Source IdentificationSource Identification

Listing of Significant SpillsListing of Significant Spills


Spill Report shall include:Spill Report shall include:

DateDate

Volume Volume

Location of releaseLocation of release

Actions taken to clean up materialActions taken to clean up material


If a release occurs…If a release occurs…

It shall be managed in accordance with the It shall be managed in accordance with the SWPPPSWPPP

The SWPPP shall be updated to include The SWPPP shall be updated to include corrective actions within 14 calendar dayscorrective actions within 14 calendar days


Storm Water samplingStorm Water sampling IS NOTIS NOT a a requirement at most municipal requirement at most municipal

facilities that develop a SWPPPfacilities that develop a SWPPP


Developing a SWPPPDeveloping a SWPPP

Storm Water Pollution Prevention PlanStorm Water Pollution Prevention Plan• Source IdentificationSource Identification

• Non-Structural ControlsNon-Structural Controls• Structural ControlsStructural Controls

Non-Structural ControlsNon-Structural Controls

Non-Structural Controls

8 Non Structural Controls8 Non Structural Controls

1.1. Preventative Maintenance / Preventative Maintenance / Routine InspectionsRoutine Inspections

2.2. Comprehensive InspectionsComprehensive Inspections

3.3. Good HousekeepingGood Housekeeping

4.4. Material Handling & Spill Material Handling & Spill Prevention / ResponsePrevention / Response


5.5. Sedimentation & Erosion Sedimentation & Erosion ControlControl

6.6. Employee TrainingEmployee Training

7.7. TMDL requirementsTMDL requirements

8.8. Significant Materials Significant Materials PresentPresent


1.1. Preventative MaintenancePreventative Maintenance


Identifying and Preventing BreakdownsIdentifying and Preventing Breakdowns


Preventative Maintenance Program Preventative Maintenance Program DescriptionDescription

EquipmentEquipment TasksTasks FrequencyFrequency

Silt SacksSilt Sacks Clean and Replace if Clean and Replace if neededneeded

After significant rain After significant rain eventsevents

Detention PondDetention Pond Inspect outfall and Inspect outfall and remove collected debris remove collected debris if neededif needed

Every other monthEvery other month

Fleet VehiclesFleet Vehicles Oil change and check Oil change and check overover

Every 3000 milesEvery 3000 miles


Routine InspectionsRoutine Inspections

Responsibility of the Certified Responsibility of the Certified Operator or Storm Water Program Operator or Storm Water Program ManagerManager

Recommended every two weeksRecommended every two weeks

Must be documentedMust be documented


Focus on areas that have a greater potential Focus on areas that have a greater potential to contaminate storm waterto contaminate storm water


Inspections should include:Inspections should include:


Housekeeping activity areas Housekeeping activity areas

Preventative maintenance Preventative maintenance itemsitems

Material handling areas Material handling areas

Fueling areas Fueling areas

Etc.Etc.

2.2. Comprehensive Site InspectionsComprehensive Site Inspections


COMPREHENSIVECOMPREHENSIVE site inspection must be site inspection must be conducted quarterly or on an alternative conducted quarterly or on an alternative schedule approved by the Departmentschedule approved by the Department


All controls should be evaluatedAll controls should be evaluated


Document Document comprehensive site comprehensive site inspectionsinspections

Responsible of the Responsible of the Certified Operator Certified Operator or smpor smp


A schedule for COMPREHENSIVE site A schedule for COMPREHENSIVE site inspections must be identified in the SWPPPinspections must be identified in the SWPPP


3.3. Good Housekeeping PracticesGood Housekeeping Practices


Operation and Maintenance ProceduresOperation and Maintenance Procedures


Material Storage Practices and Inventory Material Storage Practices and Inventory ProceduresProcedures


Employee ParticipationEmployee Participation


Housekeeping Procedures and Housekeeping Procedures and ScheduleSchedule

Area/TaskArea/Task TasksTasks FrequencyFrequency

Chip & Refuse Dumpster Chip & Refuse Dumpster Storage AreaStorage Area

Inspect the area for Inspect the area for spillage or leakagespillage or leakage

At the end of each shiftAt the end of each shift

Loading DockLoading Dock Sweep collected materialSweep collected material At the end of each shiftAt the end of each shift

Pallet Storage AreaPallet Storage Area Inspect for cleanlinessInspect for cleanliness Every FridayEvery Friday

Rack Storage AreaRack Storage Area Inspect for cleanlinessInspect for cleanliness Every FridayEvery Friday


4.4. Material Handling and Storage Material Handling and Storage ProceduresProcedures


Tracking spilled Tracking spilled materials outsidematerials outside


Loading and Unloading ProceduresLoading and Unloading Procedures


Poor material storage locationPoor material storage location


Material storage proceduresMaterial storage procedures


Avoid storing liquids near drainsAvoid storing liquids near drains


Avoid storing leaky items near drainsAvoid storing leaky items near drains


Avoid storing flammable materials near heatAvoid storing flammable materials near heat


Avoid storing acids and bases near each otherAvoid storing acids and bases near each other

BOOM!!!


Avoid stacking materials too highAvoid stacking materials too high

Barrier posts in high risk areasBarrier posts in high risk areas


Proper labeling of containersProper labeling of containers


Barrels Barrels and Drums and Drums stored stored outside outside must be must be kept kept off off the groundthe ground


Critical Materials in secondary containmentCritical Materials in secondary containment


Spill Prevention & ResponseSpill Prevention & Response


Identify Spilled Material

Contact Supervisor Protect Storm Drain

Big Spill

Contain Spill

Hire Contractor

Write Report

Small Spill

Clean Spill

Dispose of Material Appropriately


Avoiding spills is economically preferredAvoiding spills is economically preferred


Identifying Potential Spill AreasIdentifying Potential Spill Areas


Material Handling & Storage ProceduresMaterial Handling & Storage Procedures


Detailed clean-up proceduresDetailed clean-up procedures

Spill kit locations Spill kit locations

Clean-up equipmentClean-up equipment

Clean-up personalClean-up personal

Phone numbersPhone numbers


AreaArea Materials Materials PresentPresent

Response Plan Response Plan LocationLocation

Fuel BayFuel Bay Absorbent Material, Absorbent Material, Absorbent Pads, Absorbent Pads, Absorbent BoomsAbsorbent Booms

Shift Supervisor’s OfficeShift Supervisor’s Office

Loading DockLoading Dock Absorbent Material, Absorbent Material, Absorbent Pads, Absorbent Pads, Absorbent BoomsAbsorbent Booms


Chemical Storage AreaChemical Storage Area Absorbent Material, Absorbent Material, Absorbent Pads, Absorbent Pads, Absorbent BoomsAbsorbent Booms



In the event of a spillIn the event of a spill


DNRE Pollution Emergency Alert DNRE Pollution Emergency Alert System (PEAS)System (PEAS)

1-800-292-47061-800-292-4706• Non-business hoursNon-business hours

Call the District OfficeCall the District Office• During business hoursDuring business hours

• Make sure a message is left with a Make sure a message is left with a person not an answering machine.person not an answering machine.


Spill report form is available on the Spill report form is available on the DNRE websiteDNRE website


5.5. Soil Erosion and Sedimentation ControlSoil Erosion and Sedimentation Control


Erosion and Sedimentation Control Erosion and Sedimentation Control MeasuresMeasures

Area Of ConcernArea Of Concern Control MeasuresControl Measures

Gravel Parking LotGravel Parking Lot Catch Basin InsertsCatch Basin Inserts

Detention Pond OutfallDetention Pond Outfall Rip Rap around the culvert and in the Rip Rap around the culvert and in the spill wayspill way

Access Road Over Roadside DitchAccess Road Over Roadside Ditch Stone Filter BermStone Filter Berm


Outlet pipes Outlet pipes to ditches and to ditches and streamsstreams


Culverts and Culverts and Stream CrossingsStream Crossings


Areas with exposed soilsAreas with exposed soils


Gravel / Dirt lotsGravel / Dirt lots


DNRE Construction Storm Water DNRE Construction Storm Water Manual Manual


The The Construction Site Certified Operator and SESC Training Manual is available to is available to download on the DNRE Storm Water download on the DNRE Storm Water Website on the Construction Site Program Website on the Construction Site Program page.page.

6.6. Employee TrainingEmployee Training


Preventative Maintenance and Preventative Maintenance and Good HousekeepingGood Housekeeping


Spill prevention and responseSpill prevention and response


Internal spill reporting proceduresInternal spill reporting procedures


Employee Training ScheduleEmployee Training Schedule

TopicTopic Employees Employees IncludedIncluded

FrequencyFrequency

Good Housekeeping Good Housekeeping PracticesPractices

All EmployeesAll Employees Time of Hire & AnnuallyTime of Hire & Annually

Spill Prevention & Spill Prevention & ResponseResponse

1) All Employees1) All Employees

2) Response Team2) Response Team

1) Time of Hire & Annually1) Time of Hire & Annually

2) 6 Months2) 6 Months

Internal Spill Reporting Internal Spill Reporting ProceduresProcedures

All EmployeesAll Employees Time of Hire & AnnuallyTime of Hire & Annually


Training Training events need to events need to

be be documenteddocumented


7.7. Total Maximum Daily Loads Total Maximum Daily Loads (TMDLs)(TMDLs)


TMDL is the process used to determine how much TMDL is the process used to determine how much pollutant load a lake or stream can handle from pollutant load a lake or stream can handle from

point and nonpoint sources. point and nonpoint sources.


Contact your district staff for specific Contact your district staff for specific TMDL informationTMDL information

If the TMDL is listed in the Certificate of If the TMDL is listed in the Certificate of Coverage issued to the MunicipalityCoverage issued to the Municipality

If a TMDL applies to your receiving waters, If a TMDL applies to your receiving waters, controls to meet the TMDL are required in controls to meet the TMDL are required in your SWPPPyour SWPPP


8. Significant Materials still present8. Significant Materials still present


Unnatural turbidityUnnatural turbidity


Sediment depositSediment deposit

Unnatural oil filmUnnatural oil film


Unnatural foamUnnatural foam


If pollutants still remain after non-structural If pollutants still remain after non-structural controls, structural controls will have to be controls, structural controls will have to be installed.installed.


Industrial Storm Water Industrial Storm Water Certified Operator ClassCertified Operator Class

Provides Training Provides Training OnOn

Specific Pollution Prevention MeasuresSpecific Pollution Prevention Measures

Fueling StationsFueling Stations

Activity Specific Controls

Vehicle and Equipment MaintenanceVehicle and Equipment Maintenance


Controls for Painting OperationsControls for Painting OperationsActivity Specific Controls

Controls for washing:Controls for washing:

Equipment Equipment

VehiclesVehicles


Equipment and vehicle wash water is Equipment and vehicle wash water is not authorized not authorized

Storm sewer inletVehicle wash water

Controls for Loading andControls for Loading andUnloading OperationsUnloading Operations


Controls for liquid Controls for liquid storage in above storage in above

ground tanksground tanks

Controls for outside Controls for outside storage of materialsstorage of materials

Controls For Outside Waste Controls For Outside Waste Disposal AreasDisposal Areas


Controls For DewateringControls For DewateringActivity Specific Controls

Cease the dischargeCease the discharge

For dewatering on emergency repair jobsFor dewatering on emergency repair jobs

Do not discharge directly into: Do not discharge directly into:

Storm SewersStorm Sewers

Surface WatersSurface Waters

Discharge into:Discharge into:

Stone Stone

Dense growth of vegetationDense growth of vegetation

Catch Basin ProtectionCatch Basin Protection

Catch Basin Insert


Straw bales are Straw bales are notnot effective effective

pollution prevention and good housekeeping activities for municipal operations developing the storm...

Documents

spcc slide

facility slide

oil pollution prevention

state sediment slide

best solution slide

storage yard slide

storm water discharges

swppp requirements