stormwater pollution prevention plan and spill prevention ......swppp section 2.5.2 and 6.3 •...

Stormwater Pollution Prevention Plan and Spill Prevention Annual Training

Lafayette Airport Commission2020

Permitting BackgroundSWPPP Section 2.2

• Louisiana Department of Environmental Quality (LDEQ) permits:

— LDEQ Multi Section General Permit for the Discharge of Stormwater Associated with Industrial Activities (MSGP) (LAR05M152);

— LDEQ Municipal Separate Stormwater Sewer System Permit (MS4) (LAR0401025);

— LDEQ Exterior Vehicle Wash Wastewater Discharge Permit (Wash Permit) (LAG7550655).

• Require Storm Water Management Program (SWMP) Plan and Storm Water Pollution Prevention Plan (SWPPP)

MSGP Section 1.7.10Failure to comply with any of the permit requirements constitutes a violation of the Louisiana Environmental Quality Act (LEQA).

MSGP Section 3.1.1The discharge of wash water, including tank cleaning operations, is not authorized by this permit. These wastewaters must be covered under a separate LPDES permit, discharged to a sanitary sewer in accordance with applicable industrial pretreatment requirements, or disposed of otherwise in accordance with applicable law.

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Training Requirement

• All personnel (both LFT personneland tenants) who work in areaswhere significant materials areexposed to storm water, or whohave SWPPP implementationresponsibilities must be trainedannually.

• It is the responsibility of tenants andoperators to train their employees

MSGP Section 3.1.8 and 1.7.10All employees who work in areas where industrial materials or activities are exposed to storm water or who are responsible for implementing activities necessary to meet conditions of this permit must be trained.

– Such as Inspectors, maintenance personnel, all members of the Pollution Prevention Team.

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Training SWPPP Section 5.2

• Training will address each component of the SWPPP.

• Topics include the following:– Stormwater pollution prevention plan

applicability, goals, objectives, and requirements;

– Monitoring, documentation, inspections, and reporting requirements;

– Best Management Practices.– Spill prevention and response;– Exterior Vehicle and Equipment Wash

Water Discharge Permit Requirements

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Co-Located ActivitiesSWPPP Chapter 2

• Airport Tenant Facilities are Co-permiteesunder LAC’s Permit and SWPPP. – Appendix B.1 of the SWPPP contains a

listing and evaluation of tenants located on LAC property to determine SWPPP Applicability.

• Tenants are responsible for meeting the permit requirements and implementing the SWPPP for their operations.

MSGP Permit Section 1.6 and 6.S.3A single comprehensive SWPPP, developed collaboratively by the airport authority and tenants, must be developed for all storm water discharges associated with industrial activity at the airport. The SWPPPs developed by any operator for storm water discharges from its own area of the airport must be integrated and coordinated. Each operator is responsible for implementing their assigned portion of this comprehensive SWPPP

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Purpose and NeedSWPPP Section 2.1

• Identifies Industrial facilities on LAC property – Facilities identified as industrial are provided in Appendix B.1

• The LAC’s permit coverage excludes tenants with their own permit coverage

• The purpose of the SWPPP– document the management practices and stormwater

pollution prevention.

• Airport tenants without their own permit coverage are to comply with LAC’s Permit and SWPPP.

• Management practices and pollution prevention measures are implemented to prevent or minimize the contamination of stormwater discharges.

• As participants each facility has an equal duty to:– Comply with the MSGP and SWPPP – Responsibility to ensure their facility is in compliance

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Compatibility with Other DocumentsSWPPP Section 2.2

• Plan will be compatible with other LFT plans– Spill Prevention Control and Countermeasures

(SPCC) Plan – MS4 SWMP Plan

• Periodically evaluate internal documents and other work practices for consistency

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Stormwater Pollution Prevention TeamSWPPP Section 2.3

• Stormwater Pollution Prevention Team – responsible for development and implementation

of the SWPPP. – Made up of representatives of LAC and Tenants – LAC manages the stormwater pollution prevention

• Administrator and Team member

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• The Team Members and Responsibilities -Appendix C.1

MSGP Section 4.3.1The SWPPP must identify the name or title and individual responsibilities of each of the facility’s storm water pollution prevention team staff member(s).

This team is responsible for assisting in developing and revising the SWPPP, maintaining control measures, and taking corrective actions where required.

Each team member must have ready access to either an electronic or paper copy of the applicable portions of this permit and the SWPPP

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• Each facility must identify at least one employee to serve as a Team member.

• The Team member should: – Have knowledge and experience of the facility

relevant to the SWPPP;– Possess knowledge and skills to assess conditions and

activities that could impact stormwater quality and evaluate the effectiveness and

– Implement and maintain BMPs and take corrective actions, as necessary.

• The list of Team members and responsibilities -Appendix C.1.

• Tenant Facility Team Member Designation Form -Appendix C.3.

• Electronic Version of SWPPP and Permit -http://lftairport.com/environmental-management/

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http://lftairport.com/environmental-management/


• LAC’s primary responsibility: – Administer the stormwater compliance – Maintain and update the SWPPP.

• Team members are expected to: – Notify LAC of any changes within 30 calendar days of that

change;– Maintain and operate BMPs;– Perform repairs and maintenance of BMPs as required;– Maintain access to copy of the SWPPP;– Maintain facility-specific documentation;– Implement corrective actions and provide documentation; and– Review and Certify their Compliance with the SWPPP Annually.

• Lease agreements required tenants to comply with all applicable environmental rules and regulations.

– Each industrial facility operator has an equal duty to comply– Operators have the responsibility to ensure their facility

operations are in compliance.

• Appendix C.2 list activities performed by LAC on behalf of Team members and how results are communicated

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Drainage and OutfallsSWPPP Section 2.5

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Bayou Vermillion and Bayou Tortue Water QualitySWPPP Section 2.5.2 and 6.3

• Listed in Integrated Report of Water Quality– Water body uses designated as fishing, swimming,

boating, wildlife propagation and agriculture– River found to be impaired associated with activities such

as swimming and propagation of wildlife• Impairments:

– Nitrate/nitrite with an unknown source; – Dissolved oxygen with suspected sources of agriculture and the

natural environment; and – Fecal coliform with suspected sources of: Agriculture, On-site

treatment systems, and Package plants

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Bayou Vermillion and Bayou TortueWater Quality

• No specific requirements set by LDEQ for LFT

• Best Practices:– All sewage generated should be confined

to the sanitary sewer.– LAV Cart waste should be properly

disposed. • Lav Cart wastewater cannot enter sanitary

sewer without approval from LUS

– Fertilizers should be applied according to manufacturers’ recommendations.

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WARNINGNo Chemicals or Paints

Can be drained into thesesinks. It is against LafayetteUtilities System Regulations

Potential Pollutant SourcesSWPPP Section 3.1

• Inventory of Exposed Materials – SWPPP Appendix B.2– All Materials that are stored outside, used outside or could be

washed down a storm drain must be documented in this inventory.

• Examples of items that may be stored inside and used outside are: – Soaps, – Aircraft Lavatory Cart Sanitizers– Cleaners, – Deicing fluid, – Hydraulic fluid, – Antifreeze, – Paints and – Herbicides.

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• Tenants and operators must routinely provide information to LAC– Monthly Deicing Use Record Form– SDS documentation for deicing chemicals in use– Tenant Facility Team Member Designation Form– Quarterly Wash Rack Usage and Information Form– Spill Report Forms– Maintain facility-specific documentation– Review Inventory of Exposed Materials annually– Annual Tenant and Operator SWPPP Compliance Certification and

Update Report Form– Maintain SDSs for the soaps used and provide review prior to use– Issues noted during these inspections should be resolved and

documentation provided to LAC

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• Potential pollutant sources include:– Aircraft, Ground Vehicle, and Equipment

Maintenance Areas– Aircraft, Ground Vehicle, and Equipment Cleaning

Areas– Aircraft Deicing/Anti-icing Operations– Material Storage Areas– Generators– Pesticides, Herbicides, and Fertilizer Application– Tank Storage Areas– Fueling Areas

MSGP Section 1.7.5The permittee must select, install, implement and maintain control measures at the facility that minimize pollutants in the discharge as necessary to meet applicable water quality standards. In general, except in the situations explained below, the SWPPP developed, implemented, and updated consistent with Permit is considered as stringent as necessary to ensure that the discharges do not cause or contribute to an excursion above any applicable water quality standard.

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• Significant Spills and Leaks – A releases of hazardous substances in excess

of reportable quantities

• The responsible party is responsible for determining if a release triggers an RQ based on state regulations and federal regulations – Additional info on determining if a release is

reportable can be found on the LFT Environmental Management Website under Informational Brochures

• The List of Significant Spill and Leaks -Appendix G.3

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• Spill response procedures - LAC’s SPCC Plan

• LAC assist by taking the appropriate reasonable steps to minimize adverse effects from spills.

• If responsible party will not take action, LAC will contact the LDEQ for assistance.

• LAC has procedures for discharge detection and elimination in SWMP Plan– (https://lftairport.com/environmental-management/).

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Non-Storm Water Discharges • A discharge from the stormwater drainage system that is

not from a rain event.

• Exampleso Wash watero Paintso Sanitary waste watero Oilso Concrete washout

MSGP Section 1.7Discharges of non-storm water, other than those specifically authorized in Part 1.5.2, are not authorized by this MSGP and must either be eliminated or covered under another LPDES permit.

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• The following discharges are allowable under the LDEQ Discharge Permit:

– Discharges from firefighting activities, – fire hydrant flushings, or testing if discharges consist of

water– Uncontaminated condensate;– Landscape watering– Water from the routine washing of pavement conducted

without the use of detergents where spills or leaks not occurred unless removed

– Water from the routine external washing of buildings without the use of detergents;

– Potable water;– Incidental windblown mist from cooling towers but not

intentional discharges– Water from foundation or footing drains– Wet weather discharges of deicing fluid or anti-icing

fluid.• Any non-stormwater discharges not covered a permit must

either to be eliminated or permitted. • The LPDES MSGP does not authorize dry weather discharges

of deicing/anti-icing chemicals

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• Activities washing outside of a Wash Rack such as:– building wash down, – pressure washing, – stationary equipment washing

• Only water can be utilized. • Otherwise prior notification to LAC

required.– All storm drains discharge directly to

Bayou Vermillon or Tortue.• Including hangar floor drains

– Any discharge other than only water must be permitted with the LDEQ.

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Measures and Controls SWPPP Chapter 4

MSGP Section 3.1 • All facilities must comply with BMPs. • The permittee must regularly inspect, test, maintain, and repair all industrial equipment

and systems to avoid situations that may result in leaks, spills, and other releases of pollutants.

• The permittee must maintain all control measures required by this permit in effective operating condition.

• Non-structural control measures must also be diligently maintained – Spill response supplies available, personnel appropriately trained, etc.

• If the permittee finds that control measures need to be replaced or repaired, the permittee must make the necessary repairs or modifications as expeditiously as practicable

• All facilities at LFT are expected to implement the entire list of BMPs as applicable to their operations (Appendix E).

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Measures and Controls SWPPP Chapter 4

• Deicing and Anti-Icing Chemical Use

• Monthly Deicing/Anti-Icing Chemical Use Record Form (Appendix F.4) – Starting in January 2021 the must

me completed and submitted monthly

MSGP Section 6.S.2Facilities which conduct deicing operations shall maintain a record of the types of chemicals (including the Safety Data Sheets (SDS) used and the monthly quantities, either as measured or, in the absence of metering, using best estimates.

– This includes all deicing chemicals, not just glycols and urea (e.g., potassium acetate), because large quantities of these other chemicals can still have an adverse impact on receiving waters.

– Deicing operators must provide the above information to the airport authority

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Deicing Fluid• Dry weather discharges prohibited

by LDEQ Industrial Stormwater Discharge Permit

• Issues with discharges to waterways– Oxygen removal which leads to fish

kills and bacterial growth – Additives in deicing fluid

• Corrosion inhibitors, wetting agents, flame retardants, pH buffers, and dispersing agents

• Produce toxic byproducts that harmful to fish

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Discharge Permit Requirements• Stormwater Permit/Stormwater Pollution

Prevention Plan Requirements:

– Not enter drains during dry weather

– Conduct activities away from inlets

– Unusable fluid should be recycled

– Change in deicing fluid type provide SDS.

– Activities must be conducted in designated deicing area

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Designated Deicing Area

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Designated Deicing Area

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Discharge Permit Requirements

• Runoff control measures should be implemented where feasible:– plug-and-pump; – using vacuum/collection

trucks; – recycling collected deicing

fluid; and– directing runoff into vegetative

areas for infiltration.

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Discharge Permit Requirements

• Provide annual summary with type, dilution and quantity utilized monthly.

– Annual Tenant Deicing/Anti-icing Chemicals Usage and Storage Form

• Due 1/31

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Measures and Controls SWPPP Chapter 4.2.1

• Good Housekeeping– Using drip pans or absorbents to catch fluid

leaks– Storing equipment and materials under cover

in centralized areas to the extent practicable – Performing maintenance activities under cover– Promptly cleaning spills and leaks using dry

methods– Keeping culverts, drains, dikes, and trenches

clear of debris– Training Employees

MSGP Section 3.1.2The permittee must keep clean all exposed areas that are potential sources of pollutants, using such measures as sweeping at regular intervals, keeping materials orderly and labeled, and storing materials in appropriate containers. Measures must also include a schedule for regular pickup and disposal of garbage and waste materials and routine inspections for leaks and conditions of drums, inks, and containers. Common problem areas include loading docks, the area around trash containers and storage areas.

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Measures and ControlsMSGP Section 3.1.6There shall be no discharge of floating solids or visible foam except in trace amounts, oil or oily materials, nor toxic materials in quantities that are toxic to aquatic organisms. There shall be no visible sheen or stains attributable to this discharge.

MSGP Section 3.1.10The permittee must intercept or keep exposed areas free of waste, garbage, and floatable debris to ensure that these materials are not discharged to receiving waters.

MSGP Section 3.1.11Minimization of dust generation and off-site tracking of raw, final, or waste materials or sediments, including tracking or blowing of these materials from no exposure areas to exposed areas, is required.

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• Preventative Maintenance– Examples of equipment needing preventive maintenance:

• Tank valves or gauges;• Oil Water Separators;• Seals and valves on mobile fueling equipment; and• Secondary containment around fuel storage areas.

• Preventive maintenance program Includes: – Identify equipment that may have a spill or release; – Adjust, repair, or replace equipment in a timely manner; and – Keep secondary containment areas free of oil or other contaminants.

MSGP Section 3.1.3The permittee must regularly inspect, test, maintain, and repair all industrial equipment and systems to avoid situations that may result in leaks, spills, and other releases of pollutants in storm water discharged to receiving waters. The permittee must maintain all control measures that are used to achieve the effluent limits required by this permit in effective operating condition. Non-structural control measures must also be diligently maintained (e.g., spill response supplies available, personnel appropriately trained). If the permittee finds that control measures need to be replaced or repaired, the permittee must make the necessary repairs or modifications as expeditiously as practicable.

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• Spill Prevention and Response– Identifying areas for potential leaks or

spills;– Developing and conducting training;– Containing and cleaning up leaks and

spills as soon as possible. – Installing secondary containment;– Properly disposing of any spilled

product or wastes– Properly labeling containers; and– Containers should be stored under a

covered area where feasible.

MSGP Section 3.1.4The permittee must minimize the potential for leaks, spills and other releases that may be exposed to storm water and develop plans for effective response to such spills if or when they occur. At a minimum, the permittee must implement the following Procedures for plainly labeling containers, Preventative measures and release response and notification procedures.

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Best Management PracticesSpill Prevention and Response

LDEQ Industrial MSGP Permit Section 3.1.4

• The permittee must minimize the potential for leaks, spills and other releases that may be exposed to storm water and develop plans for effective response to such spills if or when they occur.

• At a minimum, the permittee must implement the following:– Procedures for expeditiously stopping, containing, and cleaning up

leaks, spills, and other releases. – Employees who may cause, detect, or respond to a spill or leak must be

trained in these procedures and have necessary spill response equipment available.

– Procedures for notification of appropriate facility personnel, emergency response agencies, and regulatory agencies. Where a leak, spill, or other release containing a hazardous substance or oil in an amount equal to or in excess of a RQ established

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• The following BMPs have been implemented. – Developing and conducting training on proper spill

clean-up– Providing proper personal protective equipment

(PPE);– Containing and cleaning up leaks and spills as soon as

possible. – Installing secondary containment;– Disposing of any wastes according to applicable

regulations– Properly label containers; and– Drums containing liquids are stored under cover

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Best Management PracticesSPCC Requirements Review

Federal Regs• Facilities where the aboveground storage capacity of oil is equal to or

greater than 1,320 gallons• oils in any kind or any form, including:

– Petroleum based oils, greases, fuels– Vegetable/seed oils, animal fats– Synthetic oils, mineral oils– Other greases & oils

State Regs• Facilities where the aboveground storage capacity of regulated

substances (e.g. MEK, acetone, toluene, and ethylene glycol) is equal to or greater than 1,320 gallons for two or more containers in a common storage area or equal to or greater than 660 gallons for an individual container

Tenants that meet the volume applicability requirements must developand maintain their own SPCC Plan.

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Oil Storage• Bulk Storage – Any container used to

store oil. These containers are used for storage of oil prior to use, while being used, or prior to further distribution– Examples: Fuel ASTs, emergency

generator belly tank, 55-gallon drums, Used Oil ASTs

• Oil-filled operational equipment – Any equipment that includes an oil storage container (or multiple containers) in which the oil is present of the apparatus or the equipment.

– Examples: elevators, transformers

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• All oil-handling personnel must receive training as perthe SPCC plan annually

• LFT provides this annual training to tenant andoperator representatives. It is the responsibility of thetenants and operators with SPCC Plans to train theiroil-handling personnel that have SPCC implementationresponsibilities.

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SPCC Plan Amendments and ReviewSPCC Plan Section 1.5 and 1.6

• The SPCC Plan must be amended for the site when there is a change in the site design, construction, operation, or maintenance that affects the potential for a discharge.

– Some examples include: adding containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; altering secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures.

• The SPCC Plan must be amended when the facility has a discharge of more than 1,000 gallons of oil in a single discharge or has discharged more than 42 gallons of oil each in two discharges occurring within any twelve-month period

• Needed amendments shall be implemented prior to or concurrent with the facility modification.

• At a minimum, a review and evaluation shall be conducted once every five years from the date of the last five year review.

• All reviews and evaluations conducted must be documented, and a statement must be signed

• After the review and evaluation, if needed, the SPCC Plan must be amended within 90 days and implemented as soon as possible and within six months

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Discharge Prevention MeasuresSPCC Plan Section 2.1.5

• Perform preventive maintenance of equipment, secondary containment systems, and discharge prevention systems as needed to keep them in proper operating conditions.

• Maintenance activities are performed indoors or undercover to the greatest extent practicable;

• Recovery of any solvents, waste fuels and oils, and other potential pollutant sources (fuel filters, oil filters, etc.) is performed by containing and storing the materials in dedicated drums and/or tanks for off-site removal;

• Inspections are conducted to detect and prevent potential spills; and

• Annual personnel training programs

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Procedures for Routine Products Handling SPCC Plan Section 2.1.6 and 2.1.5

• Spill response equipment (absorbent materials, booms, shovels, etc.) should be quickly deployed once a spill or leak is detected;

• Containment areas should be inspected prior to discharge of any accumulated rainwater;

• Personnel should utilize equipment with care during loading, unloading, and transfer operations.

• Ensure that vendors understand the site layout, know the protocol for entering the facility and unloading product, and have the necessary equipment to respond to a discharge.

• All transfers take place only in the designated areas.

• Personnel remain with the vehicle at all times while fuel is being transferred and actively monitor liquid level.

• Positioning and/or backing of trucks are directed

• Loading and unloading operations procedures should be followed

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Procedures for Routine Products Handling SPCC Plan Section 2.1.6 and App D

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Discharge CountermeasuresSPCC Plan Section 2.1.8 and 3.3.10

• State and federal laws prohibit the uncontrolled discharge of oil to groundwater, surface water, or soil.

• It is the responsibility of each person to assist in spill prevention by being observant for signs of potential spills.

• All visible discharges should be cleaned up promptly.

• If any issues exist that are causing the discharge, it should be corrected in a timely manner to prevent further releases of oil.

• Accumulations of oil should be promptly removed from diked areas.

• Personnel may reduce or eliminate the risk of spills by taking direct action to correct the situation

• Daily as part of normal site operations be observant for signs of deterioration or leaks.

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Disposal MethodsSPCC Plan Section 2.1.9

• Discharge material and discharge cleanup material shall be disposed of off-site in accordance with all applicable regulations.

– Exact means of disposal will depend upon the nature and volume of the contaminated material.

• Soils and other solids should be placed in drums or roll-off boxes, as appropriate.

• Any liquids should be placed in drums or collected with a vacuum tank truck and placed in a tank, if needed.

• Collected materials will be labeled, characterized, and disposed/recycled.

• Tenants and Contractors are responsible for cleaning up of spills that they cause and for the proper disposal of used spill cleanup materials that they generate.

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LAC’s SPCC Plan Section 2.1.5• Discharge Prevention Measures

– It is the responsibility of each person to assist in spill prevention by being observant for signs of potential spills.

– If any issues exist that are causing the discharge, it should be corrected in a timely manner to prevent further releases of oil.

– Spill response equipment should be kept on hand at all times and quickly deployed once a spill or leak is detected.

– All visible discharges should be cleaned up promptly. – Perform preventive maintenance of equipment, secondary

containment systems, and discharge prevention systems as needed to keep them in proper operating conditions.

– Utilize equipment with care during loading, unloading, and transfer operations.

– Remain with the vehicle at all times while fuel is being transferred and actively monitor liquid level.

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Spill Reporting and ResponseSPCC Plan Section 2.1.11, 2.1.12 and App D

• Types of spills– Emergency Condition

• any condition which could reasonably be expected to endanger the health and safety of the public, cause significant adverse impact to the land, water or air environment, or cause severe damage to property.

– Non Emergency • All other spills

• Spill Response Steps– Step 1 Assess Risk

• Determine the risks and respond accordingly. If the situation is an emergency or is not safe for personnel to contain or stop the spill proceed directly to step 4.

• Since each spill scenario is different personnel should use judgment to determine whether to first contain the spill, stop the source, or notify Emergency Coordinators

• If needed the container label or the Safety Data Sheet (SDS) should be consulted for primary dangers posed to responders and the environment.

– Step 2 Contain Spill• Limit the spill area to prevent the spill from spreading• Spill should be stopped before it impacts a water source (sheen on water is reportable) by

minimizing the spill area and protecting drains in area.– Blocking, diverting, or confining the spill through placement of booms or pads or other

absorbent material, digging a diversion ditch, or building soil berm.– If the spill reaches surface water, booms and pads should be placed in the water to

contain the release 13


• Spill Response Steps (continued)– Step 3 Stop Source

• Determine the source of the discharge, and if safe to do so, immediately stop the source

– Ex. If fueling equipment or hoses are found to be causing a spill the emergency fuel shutoff should be operated immediately.

– Ex. Simply righting a container or plugging a leak from a damaged container

– Step 4 Assess Incident and Verbal Notifications• Notify your Emergency Coordinator and LAC

– Emergency Coordinator will determine the type and quantity of material spilled and if the incident was considered an emergency as defined above. They will also determine if the spill exceeded a reportable quantity.

– LAC 24hr contact number AVCOM 337-266-4461 (on back of airport badge)

– Step 5 Cleanup• Once the spill is confined and the leak has been stopped, the situation

should be reassess and a plan of action developed for implementing the spill cleanup.

• Spilled materials should be recovered and wastes appropriately containerized.

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– Step 6 Decontamination• The site, personnel, and equipment should be decontaminated by removing or neutralizing the

hazardous materials that have accumulated during the spill. This may involve removing and disposing of contaminated media, such as soil, that was exposed during the spill incident

• Regulatory Reporting Requirements– Emergency Condition

• Report immediately to Louisiana State Police (LSP) at (225) 925-6595 and Lafayette Parish Local Emergency Planning Committee at (337) 291-5075

• Notify the National Response Center (NRC) at (800) 424- 8802as soon as you acquire knowledge of the release.

• Notify LDEQ Office of Environmental Compliance Single Point of Contact (SPOC) within 1 hr at (225) 765-0634 or (225) 342-1324

– Nonemergency Condition and Exceed a Reportable Quantity• Notify the NRC as soon as you acquire knowledge of the release.• Report immediately to LSP and Lafayette Parish Local Emergency Planning Committee

– If the release meets or exceeds the RQ and escapes the facility or – If it is a release of flammable liquids in excess of 13.5 gallons which leaves the site

• Notify LDEQ Office of Environmental Compliance within 24hours after learning of the release

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• Regulatory Written Notifications– LSP Written Notice

• Facilities must also submit follow-up written reports for reportable releases within five business days after the release or incident occurs

– LDEQ Written Notice• Written reports for any unauthorized discharge that requires notification

shall be submitted by the discharger within seven calendar days• For information required for submittal that is unknown at the time of

written notification, an update must be provided every 60 days until completion.

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• Regular inspections are required – Formal visual external inspections of tanks

monthly and annually – For tanks >5,000 gallons, inspection by

certified tank inspector is required every 20 years

– Water from containment dikes must be inspected prior to release

• Water not suitable for discharge must be collected for off-site disposal.

• Documentation must be maintained.

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Record Retention SPCC Plan App B

• All records should be maintained for at least three (3) years. – A summary of required records is included within

Appendix B.• Completed Inspection Forms• Annual Training Sign in Sheets• Corrective Action Documentation• Spill Reports• Maintenance

– All testing as well as other work on the tanks and equipment cover by plan

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• Sediment and Erosion Control– Keep storm drain inlets free of debris– Address Soil erosion issues– When construction activities occur:

• Follow requirements in SWMP Plan for construction

• Follow LDEQ Construction General Permit

MSGP Section 3.1.5The permittee must stabilize exposed areas and contain runoff using structural and/or non-structural control measures to minimize on-site erosion and sedimentation and the resulting discharge of pollutants. Flow velocity dissipation devices must be placed at discharge locations and within outfall channels where necessary to reduce erosion and/or settlement of pollutants.

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• Material Storage Areas– Comply with applicable state and

federal laws;– Train employees;– Gauges or visual inspection to

monitor fill levels;– Use secondary containment with

sufficient freeboard; and– Use impervious diked area.

MSGP Section 6.S.4.4Maintain the vessels of stored materials in good condition, to prevent or minimize contamination of storm water. Plainly label the vessels (e.g., “used oil,” “Contaminated Jet A,” etc.). To minimize contamination of precipitation/runoff from these areas, implement control measures

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Measures and Controls SWPPP Chapter 4.3.2 and 4.3.3

• Fueling Areas– Discourage topping off fuel tanks;– Use dry clean-up methods for fuel stations;– Use proper spill control; and– Require that on-site personnel remain with

the vehicle during fueling.

• Loading and Unloading Areas– LAC’s SPCC Plan contains detailed

discussions on loading and unloading operations

MSGP Section 6.S.4.7Minimize the discharge of pollutants in storm water from airport fuel system and fueling areas through implementation of control measures. If the permittee implemented a SPCC plan the permittee may cite the relevant aspects from the facility’s SPCC plan

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• Vehicle and Equipment Maintenance Areas– Recycle or properly dispose of used oil;– Recover of solvents, waste fuels, etc. for off-site removal.– Perform maintenance activities under cover where feasible – Use drip pans/buckets– Use dry clean-up methods;– Check equipment for leaks; and– Separate and label wastes.

MSGP Section 6.S.4.2Store all aircraft, ground vehicles and equipment awaiting maintenance in designated areas only. Implement control measures to minimize the discharge of pollutants in storm water from these storage areas

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• Vehicle and Equipment Storage Areas– Designate areas for storage of vehicles and

equipment;– Use drip pans;– Store vehicles and equipment on an impervious

surface;– Use absorbents; and– Clean pavement routinely to remove oil and

grease.

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Measures and Controls SWPPP Chapter 4.3.6 and Section 5.8

• Vehicle and Equipment Washing

• Quarterly Wash Rack Usage Information Form Appendix F.7– Tenants and users of LAC’s permitted

wash racks are required to submit the Quarterly to LAC

– The Soap SDS review table details the soaps reviewed f and if they meet the permit requirements - Appendix H.2

– Soaps utilized at LAC wash racks -Appendix H.2

MSGP Section 3.1.1The discharge of wash water, including tank cleaning operations, is not authorized by this permit. These wastewaters must be covered under a separate LPDES permit, discharged to a sanitary sewer in accordance with applicable industrial pretreatment requirements, or disposed of otherwise in accordance with applicable law.

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Permitting BackgroundSWPPP Section 2.2

• Louisiana Department of Environmental Quality (LDEQ) permits:—Storm water associated with

industrial activity (LAR05M152);—Exterior vehicle wash waters

(LAG7550655).

• Require Storm Water Pollution Prevention Plan (SWPPP)

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Training RequirementLDEQ Industrial SW Permit Section 3.1.8 and 1.7.10

• All employees who are responsible for implementing activities necessary to meet conditions of this permit must be trained. – Such as Inspectors, maintenance personnel, all members of the

Pollution Prevention Team. – The EPA recommends training be conducted at least annually

• All personnel (both LFT personnel and tenants) who have SWPPPimplementation responsibilities must be trained.

• It is the responsibility of tenants and operators to train theiremployees, sublessee, contractors, etc.

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Wash Rack LocationsLDEQ Wash Permit Part 1.A

• Allows Airport tenants and the LAC to wash only in certain areas.

• Wash Racks discharge directly to the Bayou Vermillion

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Prohibited Wash Rack ActivitiesLDEQ Wash Permit Part 1.A

The following activities are prohibited at the wash racks:• Using detergents that are not non-toxic, biodegradable, low-

phosphate, and low-surfactant;• Use of potentially hazardous chemicals and solvents• Washing tanks or cargo compartments used for hauling or

dispensing of pesticides, hazardous waste, or any other chemicals

• Internal tank truck washing • External washing of tank trucks with product on the outside• Steam cleaning or pressure washing • The use of detergents, emulsifiers, or dispersants to clean up

spilled contaminants

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Compliance with Permit RequirementsLDEQ Wash Permit

LAC will be responsible for the following:• Permit updates • Labeling wash areas• Posting instruction signs• Sampling quarterly as per permit• Observing weekly for any visual sheen and

completing Sheen Log • Submitting Discharge Monitoring Reports to

LDEQ Quarterly• Providing training annually on requirements of

permit• Review of Soap Safety Data sheets for permit

compliance

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Compliance with Permit RequirementsLDEQ Wash Permit Part I Outfall 001

Wash rack users will be responsible for the following concerning both their employees, sublessees and contractors:• Send at least one representative to LAC training• Provide training to employees, sublessees and contractors

prior to their use of the wash rack• Notifying LAC of changes in wash water discharged• Submit soap SDSs• Provide SDSs to LAC for review prior to changing soap or

beginning washing• Tracking soap usage• Track average number of aircraft/vehicles washed per week• Track average time that the hose runs • Provide average quantity of soap stored• Clean any dirt, spills, drips of fluids, or other contamination

through dry clean-up methods in wash area after or prior to washing

• Follow washing BMPs found in LAC’s SWPPP

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Best Management PracticesLDEQ Wash Permit Part I Outfall 001 and Part II.D

The following BMPs have been enacted by LAC to meet permit requirements:• Only washing with nontoxic, biodegradable, low-phosphate, and

low-surfactant soaps in minimal amounts• Any spills, drips of fluids, etc in the washing area must be removed

by dry means prior to washing• Any vehicle or equipment in a state of disrepair shall not be washed• Wash only vehicles and equipment that do not have leaks of fluids,

oils, or other substances• No washing activities shall be conducted that cause discharge of oil

or visible solids such as dirt, debris, grass, etc. • Stop washing immediately if discharges of oil sheen, debris, foam,

or staining are observed• No steam cleaning, pressure washing or blasting is allowed• Exterior washing only• No vehicles, containers, cargo compartments for pesticides,

hazardous waste, or any other chemical shall be washed• No washing of the inside of tank trucks or • No exterior washing if visible accumulation of product• Do not dump the bucket of soapy water or anything else into the

wash rack • Conduct no maintenance in or around the wash areas• Wash only in approved wash rack areas

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Inspection and Testing RequirementsLDEQ Wash Permit Part I Outfall 001

• Sheen Log/Weekly Wash Rack Inspection– Each wash rack must be inspected weekly during

normal working hours by Permit Holder.

– LAC wash racks are inspected for the following: • Condition of the label, • Condition of washing instruction sign, • Hose change, • New users,• Sheen in the drain and • Any any dirt, spills, drips of fluids, or other contamination in

the area of the wash rack.

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Reporting and Records RequirementsLDEQ Wash Permit Part I.C and Part I Outfall 001

• Collect samples quarterly and report results tothe LDEQ.

• Maintain a weekly sheen log for each wash rack.• Track soap usage, storage and types

• Users should provide the SDS for the soap used• Users should track the amount of soap utilized• Users should provide the quantities of soaps stored

– Track the amount of water discharged.• Users should track the average number of

aircraft/vehicles washed

– This information should be provided to LAC quarterly

Prior to using a soap to wash submit the SDSs for the soap to LAC for review

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Stormwater Management PlanSWPPP Section 4.4

• LDEQ small municipal separate storm sewer systems (MS4) discharge permit– Develop, implement, and enforce

• Storm Water Management Program (SWMP) Plan• Identify Best Management Practices (BMPs) and

measurable goals to implement and evaluate performance

• Annual report submittal to LDEQ identify progress

• The SWMP Plan covers all LAC Tenants and all airport-related operations

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Stormwater Management PlanSWPPP Section 4.4

• Six minimum control measures:– Public education and outreach– Public involvement and participation;– Illicit discharge detection and elimination;– Construction site runoff control;– Post-construction storm water management; – Pollution prevention and good housekeeping

LDEQ MS4 Permit Part IV.C.2The Permittee shall exert enforcement authority as required by this permit for its facilities, employees, contractors and other entities within its jurisdiction.

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Stormwater Management PlanSWPPP Section 4.4 and 4.2.4

• Illicit Discharge Detection

• Non-Stormwater Discharge Assessment and Certification

Louisiana Administrative Code Title 33:IX.2511.B.2 An Illicit discharge is any discharge to a municipal separate storm sewer that is not composed entirely of stormwater except discharges pursuant to a LPDES permit (other than the LPDES permit for discharges from the municipal separate storm sewer) and discharges resulting from firefighting activities. The firefighting exclusion does not include predictable and controllable discharges from firefighting training facilities.

MS4 Permit Part IV.D.3.ivPermittees must develop and implement a plan to detect and address illicit discharges to its system.

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Identify•Complaint received, employee reported incident, or issue identified during inspections

Investigate

•Inspect outfall or suspect area•Collect supporting information•Identify source

Notify

•Assemble documentation•Complete findings report•Generate correspondence with responsible party

Resolve

•Onsite - Follow Enforcement Program•Offsite - Deliver findings report to LCG, also LDEQ if appropriate, and maintain record of completed action


• Illicit Discharge Elimination and Enforcement– Through lease agreement language– Enforcement process overview flow chart

MS4 Permit Part IV.D.3.a.ivTo the extent allowable under state, tribal, or local law, effectively prohibit, through ordinance or other regulatory mechanism, non-storm water discharges into your storm sewer system and implement enforcement procedures and actions.

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• Construction Site Runoff Control– Develop program to prevent

construction projects from negatively impacting waterways

– Specific requirement summaries for construction projects of various sizes

• Applicable to construction projects conducted on LAC property

– Construction Site Inspections and enforcement

MS4 Permit Part IV.D.4.a.iDevelop, implement, and enforce a program to reduce pollutants in any storm water runoff to your small MS4 from construction activities

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• As per the LDEQ Construction General Permit for Discharges of Construction sites the following discharges are prohibited:– Discharge of stucco, paint

or other construction materials

– Washout of concrete into a storm drain

– Direct pumping of sediment laden water into a storm drain

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• Post-Construction Stormwater Management– development, implementation, and

enforcement of a program • Two forms of substantial impacts

– Increase in the pollutants in stormwater runoff

– Increasing the quantity of water discharged

• Post construction controls include – detention ponds, – grassy swales, – landscaping

MS4 Permit Part IV.D.5.aDevelop, implement, and enforce a program to address storm water runoff.Ensure adequate long-term operation and maintenance (O&M) of BMPs

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Monitoring, Record Keeping and Reporting RequirementsSWPPP Section 5.1

• Inspections required:– Quarterly Routine Site Inspections – Annual Comprehensive Site Evaluation and Compliance Report– Quarterly outfall visual inspections– Monthly dry weather screening - deicing areas– Weekly Wash Rack Inspections and Sheen Log– Quarterly Wash Rack Discharge Monitoring Reports

• Any deficiencies observed during an inspection must be corrected as soon as practicable.

These inspections require that LAC visit your operations to evaluate whether BMPs are being followed and are effective.

LDEQ Permit Section 3.1.3The permittee must maintain all control measures that are used to achieve the effluent limits required by this permit in effective operating condition. Non-structural control measures must also be diligently maintained (e.g., spill response supplies available, personnel appropriately trained). If the permittee finds that control measures need to be replaced or repaired, the permittee must make the necessary repairs or modifications as expeditiously as practicable

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• Routine Site Inspections – Routine Site Inspection Form - Appendix F

• Reviews areas where industrial materials or activities are exposed to stormwater and Stormwater control measures or BMPs

• Prevention Team Members should routinely look for evidence of spills and leaks throughout the airport.

LDEQ Permit Section 5.1The permittee must routinely inspect all facility areas where industrial materials or activities are exposed to storm water and all storm water control measures used to comply with the effluent limits contained in this permit. Routine facility inspections must be conducted at least quarterly.

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• Annual Comprehensive Site Evaluation– Overall assessment of SWPPP Compliance each year– Annual Tenant and Operator SWPPP Compliance Certification and Update Report Form - Appendix

G.2. – Annual SWPPP Facility Inspection Form/Report - Appendix F.1.

• Inspectors are required to:– Inspect industrial activities exposed to stormwater;– Inspect areas where significant spills or leaks have occurred;– Inspect BMPs including the maintenance and effectiveness;– Inspect discharge locations; and– Inspect for off-site tracking or blowing of materials.– Verify Training records, maintenance logs, material inventories, etc required

LDEQ Pemit Section 5.2The permittee must conduct annual comprehensive site inspections while covered under this permit. Annual, as defined in thisPart, means once during each calendar year.

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• Comprehensive Annual Site Certification report – Comprehensive Annual Site Evaluation and

Certification report -Appendix G• summary describing the implementation and

efficacy of the SWPPP program over year • Summarizes inspection results, follow-up

actions and compliance with the SWPPP

• Incidents of noncompliance will be documented. – Must be brought into compliance no later

than 12 weeks after the evaluation – The SWPPP will be revised, as necessary,

within 14 days

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• Quarterly discharge Outfall Monitoring– Form is provided in Appendix F – Inspection conducted during daylight hours– Samples examined in a well-lit area– Observations made for:

• color, • clarity, • floating solids, • settled solids, • suspended solids, • foam, • oil sheen, • odors, and • other obvious indicators

LDEQ Permit Section 3.2.5The permittee must collect and conduct a visual assessment of a storm water sample from each outfall once per quarter for the entire permit term.

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Monitoring, Record Keeping and Reporting RequirementsSWPPP Section 5.5 and LDEQ Permit Section 3.2.5

• Stormwater Discharge Visual Monitoring Requirements– Minimum of 72 hours from previous storm with discharge – Sample taken during the first 30 minutes of discharge

• No storm during quarter, excused from monitoring for that quarter

– Documentation must be included in records.– Sampling from missed quarter will be distributed to

other quarters

• Monitoring may be suspended due to adverse weather – Adverse conditions must be documented– Sample will be collected during the next qualifying event

• LPDES MSGP contains a condition that any runoff must meet limits for TOC daily maximum level of 50 milligrams per liter (mg/L) and/or 15 mg/L of O&G is considered to be a violation of the permit.

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• Monthly Deicing Monitoring Requirements– The Deicing Area Inspection and Deicing Outfall Visual Monitoring Form - Appendix F.5– December to February or when deicing is occurring– Inspections includes

• Review of deicing area Outfalls 009 and 011 and • Designated deicing areas BMPs

• Observed incidences of noncompliance are documented, addressed, and brought into compliance as soon as practicable, but no later than 14 days after the inspection.

LDEQ Permit Section 6.S.6At a minimum conduct facility inspections at least monthly when deicing occurs during the deicing season. If the facility needs to deice before or after this period, expand the monthly inspections to include all months during which deicing chemicals may be used.

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Monitoring, Record Keeping and Reporting RequirementsSWPPP Section 5.7 and LDEQ Permit Section 5.4

Recordkeeping and Reporting

• Forms associated with the SWPPP to be retained and or updated:

– Industrial Facilities Listing (Appendix B.1) – Material Inventory (Appendix B.2);– Tenant Facility Team Member Designation Form (Appendix

C.3)• To be completed and updated as needed by Tenants and Operators and

submitted to LAC;

– Non-Storm Water Discharge Assessment & Certification (Appendix D);

– Stormwater BMP Inventory (Appendix E)– Annual Site Inspection Form (Appendix F.1);– Quarterly Routine Site Inspections (Appendix F.1);– Outfall Quarterly Visual Monitoring (Appendix F.2);– Annual Deicing Usage Summary (Appendix F.3)– Monthly Deicing/Anti-Icing Use Records (Appendix F.4)

• To be completed monthly by deicing/Anti-icing chemical users and submitted to LAC;

– Deicing Area Inspection and Outfall Visual Monitoring Form (Appendix F.5)

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Monitoring, Record Keeping and Reporting RequirementsSWPPP Section 5.7 and LDEQ Permit Section 5.4

– Wash Area Inspection Form and Sheen Log (Appendix F.6)

– Quarterly Wash Rack Usage Information Form (Appendix F.7)

• To be completed Quarterly by wash rack users and submitted to LAC;

– Comprehensive Annual Site Evaluation and Report Template (Appendix G.1)

– Annual Tenant and Operator SWPPP Compliance Certification and Update Report Form (Appendix G.2)

• To be completed annually by Tenants and Operators and submitted to LAC;

– List of Significant Spills and Leaks (Appendix G.3);• Spill Report Form to be submitted to LAC for each

reportable spill by responsible party– Deicing SDS Documentation (Appendix H.1)

• To be kept up to date by Deicing/Anti-icing Chemical Users. Updates should be provided to LAC prior to use of new chemicals;

– Soap SDS Documentation (Appendix H.2)• To be kept up to date by Wash Rack Users. Updates must

be provided to LAC prior to use of new soaps.

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Monitoring, Record Keeping and Reporting RequirementsSWPPP Section 5.7.2 and 5.7.4 and LDEQ Permit Section 5.4

• Spills and Leaks– Operators are responsible for:

• Spill response and reporting • Completing Spill Report Form for each RQ spill and

submitting to LAC– LAC’s SPCC Plan Appendix C - Form 2

• Maintenance records include:– Facility name and location, date, and time of

maintenance;– Name(s) of the person(s) performing

maintenance activity;– Equipment or machinery requiring

maintenance;– Reason and type of maintenance; and– Any spills or issues of note that occurred during

maintenance activities

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• LDEQ Wash Water Discharge Permit – Requirements for inspection, monitoring, and record keeping

• Samples must be collected quarterly and analyzed• If exceeds standard then sampling must be conducted monthly• Discharge Monitoring Reports submitted to the LDEQ quarterly• Wash Area Inspection Form and Visible Sheen Log in Appendix F.6.• Records of the following must be kept for at least 3 years:

– Water discharged from each wash rack – Soaps used with SDSs – Quantity soap utilized each quarter – Amount of soap stored

• Wash rack users must submit to LAC– Quarterly Wash Rack Usage Information Form - Appendix F.7

• Document the usage of wash racks as required by the permit.

– SDSs for soap utilized prior to their use• SDSs for Soaps utilized at wash racks - Appendix H.2 • Soap SDS review summary table - Appendix H.2

– Details the soaps reviewed and if they meet the permit requirements

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• Corrective Action – Defined as any action taken or required to be taken to:

• Repair, modify, or replace any storm water control used at the site;• Clean-up and dispose of spills, releases, and other deposits found at the site; and• Remedy a permit violation.

• Within 24 hours of discovery discharges are documented in the List of Significant Spills and Leaks with other corrective action documentation as needed in the Annual Compliance Evaluation Report

• Within 14 days the following information must be documented: – Summary of corrective action taken or to be taken or the basis for determining that

corrective action is not necessary;– Notice of whether SWPPP modifications are required;– Date corrective action initiated; and– Date corrective action completed or expected to be completed.

MSGP Section 3.3Failure to take any required corrective actions constitutes a violation of this permit, the Clean Water Act (CWA) and the Louisiana Environmental Quality Act and is grounds for enforcement action.

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Plan Review and ModificationSWPPP Section 6.4 and LDEQ Permit Section 4.5 and 4.6

• The SWPPP will be reviewed and amended with the following:– An unauthorized release or discharge;– Control measures are not stringent enough for the discharge to meet

water quality standards; – Exceedance of an water quality standard or requirement stipulated in

Part 3 of the permit– LDEQ official determines that modifications are necessary

• Discovery must be documented within 24 hours– Document the following information:

• identification of the condition triggering corrective action review; • description of the problem identified; • and date the problem was identified.

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Plan Review and ModificationLDEQ Permit Section 4.7 and 4.8

• Within 14 days, document any corrective action(s) as follows

– Summary of corrective action taken or to be taken – Basis for determination that corrective action is not

necessary– Notice of whether SWPPP modifications are required– Date corrective action initiated; and– Date corrective action completed or is expected to be

completed.

• Other conditions requiring the review are:– Construction or a change in design, operation, or

maintenance; – A routine facility inspection, quarterly visual outfall

monitoring event, or annual comprehensive site inspection reveals control measures are not being properly operated and maintained

• If changes are necessary, any modifications to the control measures will be made before the next storm event if possible, or as soon as practicable following that storm event.

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SWPPP AvailabilitySWPPP Section 6.6

• SWPPP is available at the time of an on-site inspection or upon request.

• LAC posts the SWPPP on its website – https://lftairport.com/environmental-

management

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https://lftairport.com/environmental-management

Questions?

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• Contact:Ashley SimonEnvironmental Compliance OfficerLafayette Airport [email protected]

mailto:[email protected]