NPDES
Best Management Practices
Workshop
Office of Water Enforcement
The Environmental Protection Agency
Washington, D.C.
November 23-25, 1980
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833R80002
NPDES
Best Management Practices (BMP)
Workshop
^
^
/
Conference Manager, Harry M. Thron, ]T.
Office of Water Enforcement
Permits Division
Conference Coordinator, Eric R. Olson
Office of Water Enforcement
Permits Division
U.S. EPA Region III
Regional Center for Environmental
Information
1650 Arch Street (3PM52)
Philadelphia, PA 1910S
November 23-25, 1980
Dulles Marriott Hotel
Chantilly, Virginia
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Agenda
Sunday Evening
November 23, 1980
8:00 p.m. REGISTRATION
Salon C
8:30 Welcome
ADMINISTRATIVE ANNOUNCEMENTS
Harry Thron
Permits Division
Office of Water Enforcement
8:45 Introduction to BMPs
Chronology of BMP Regulations
Harry Thron
9:15
NPDES BMP Guidance Document
Eric Olson
Permits Division
Office of Water Enforcement
9:30 Summary of Public Comments on BMPs
10:00 Preview of Monday Session
Open Discussion
RECEPTION
Harry Thron
Eric Olson
Harry Thron
Salon B
Monday
November 24, 1980
8:00 a.m. REGISTRATION
8:45 Convene
ADMINISTRATIVE ANNOUNCEMENTS
9:00 Introductory Remarks
Overview of BMPs
9:30 BMP Practical Exercise
Reagent Chemical, Inc.
10:00 BMPs in Second Round (BAT) Permits
Atlas Powder Company
10:30 COFFEE BREAK
Salon C
Harry Thron
J. William Jordan, Chief
Industrial Permits Branch
Harry Thron
Eric Olson
James Vincent
National Enforcement
Investigations Center
in
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Monday
November 24, 1980 (continued)
10:45 BMP Program Development
Rollins Environmental Services
11:15 BMP Case History—Part I
New Jersey Zinc Company
12:00 p.m. LUNCH
Keynote Address
1:30 BMP Case History—Part 2
New Jersey Zinc Company
2:00 Compliance with BMP Requirements
2:30 BMP Practical Exercise
Kalama Chemical Incorporated
3:00 Enforcement of BMP Requirements
3:30 BREAK
3:45 BMPs for Municipal Treatment Systems
4:00 BMPs and the Resource Conservation and
Recovery Act
4:15 What Is a BMP Plan?
5:30 Preview of Tuesday Session
RECREATIONAL ANNOUNCEMENT
7:00 DINNER
Michael Polito
Emergency Response
Branch Region II
Richard Warner
National Enforcement
Investigations Center
Salon A and B
R. Sarah .Compton, Esq.
Deputy Assistant Administrator
for Water Enforcement
Joseph Davis, Chief
Pennsylvania Section
Enforcement Branch Region III
Gary Polvi, P.E.
Enforcement Division
Office of Water Enforcement
Eric Olson
Robert Bragar, Esq.
Enforcement Division
Office of Water Enforcement
Michael Boswell
Washington Suburban
Sanitary Commission
Kay Holub
Permits Division
Office of Water Enforcement
Harry Thron
Eric Olson
Harry Thron
Salon A and B
IV
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Tuesday Morning
November 25, 1980
8:45 a.m. Convene
AWARDS CEREMONY
9:00
Chemical Industry's Perspective of BMPs
Harry Thron
Robert Romano, Ph.D.
Manager of Water Programs
Chemical Manufactures
Association
9:30
State Perspective of BMPs
10:00
10:30
10:45
Open Discussion
COFFEE BREAK
Panel Discussion
Chemical Industry Representatives
EPA Representatives
State Representative
Larry Kane
Indiana
Larry Lawson
Virginia
Steven Williams
Iowa
Robert Fawcett, P.E.
Allied Chemical Company
Jack Schauer, P.E.
Shell Chemical Company
Howard Schwartzman, P.E.
Procter & Gamble Company
Thomas Kremer
Region IX
Mary McGhee
Region VII
Larry Lawson
Virginia
11:45 SUMMARY and WRAPUP
12:00 p.m. Adjourn
Harry Thron
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CONTENTS
AGENDA iii
INTRODUCTION 1
I. HISTORICAL BACKGROUND
Legislative Authorities 1-1
Chronology of Events 1-3
Chronology of Federal Register Notices 1-7
Federal Register Notices 1-9
II. SUMMARY OF PUBLIC COMMENTS
Issues II-l
Summary of Issues II-3
Responses to Public Comments II-9
III. BMP REGULATION (40 CFR Part 125 Subpart K)
Proposed Rule III-l
Final Rule III-5
Reproposed Rule III-ll
IV. NPDES BEST MANAGEMENT PRACTICES GUIDANCE DOCUMENT IV-1
V. CASE HISTORIES
Reagent Chemical V-l
Atlas Powder V-5
Rollins Environmental Services V-19
New Jersey Zinc V-53
Kalama Chemical V-67
Sanitary District of Rockford V-73
VI. LITERATURE ARTICLES
How One Chemical Company is Attacking the Spill Problem VI-1
A New Pair of Eyes VI-15
Guidelines for Chemical Plants in the Prevention, Control,
and Reporting of Spills VI-23
Prevention and Control of Chemical Spill Incidents VI-45
Best Management Practices for Control of Toxic and
Hazardous Materials VI-51
WORKSHOP SPEAKERS and PARTICIPANTS
NOTES
VII
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INTRODUCTION
Best Management Practices or BMPs are expected to be an important part of
the NPDES permitting strategy for the 1980's. The first round of NPDES permits
issued in the mid-1970's emphasized the control of conventional pollutants,
such as BCD, TSS and pH. As we enter the second phase of permits issuance,
the control of toxic pollutants will be a high priority and permits will
contain effluent limitations based on the application of the Best Available
Technology or BAT. BMPs will complement BAT-based effluent limitations to
achieve total plant site control of the discharge of toxic pollutants and
hazardous substances.
Several characteristics of BMPs are noteworthy. First, they frequently
are procedural and suggest methods or practices to accomplish certain goals.
Second, they often are qualitative and are normally used in conjunction with
quantitative controls, such as effluent limitations. Finally, BMPs are
flexible and allow alternative methods to be used to achieve equivalent
results.
The NPDES Best Management Practices Workshop is designed to provide
regulatory authorities with an understanding of the scope and utility of BMPs
for pollution control. The workshop uses a combination of lectures, case
histories, practical exercises and panel discussions. Although the emphasis
of the workshop is on the technical or engineering aspects of BMPs, attendees
will gain an understanding of the legal aspects from the sessions on compliance
and enforcement. Industry and State perspectives on BMPs complete the program.
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I. HISTORICAL BACKGROUND
Legislative Authorities
Chronology of Events
Chronology of Federal Register Notices
Federal Register Notices
-------
Legislative Authorities
CLEAN WATER ACT
SECTION 304(e)
(e,) The Administrator, after consultation with appropriate Federal
and State agencies and other interested persons, may publisli, regula-
tions, supplemental to any effluent limitations specified under subsec-
tions (b) and (c) of this section for a class or category of point
sources, for any specific pollutant which the Administrator -is charged
with a, duty to regulate as a toxic or hazardous pollutant under sec-
tion 307 (a) (!) or 311 of this Act, to control plant site runoff, spillage
or leaks, sludge or waste disposal, and drainage from raw material
storage which the Administrator determine* are associated with or
ancillary to the industrial manufacfitri-ny or treatment proccxs within
such, class or category of point sources and mat/ contribute xigiiiff/nit
amounts of such pollutants to nnrigable wafers. Any licable en-n-
trols established under this subsection shall be ineludcd- as a, require-
ment for the purposes of section 301, 302, 30C. 307. or Jt03, as the r/ixe
may be. in any permit issued to a point source '/mrsuant to section Jt02
of this Act.
CLEAN WATER ACT
SECTION 402(a)(1)
SEC. 402. (a) (1) Except as provided in sections 318 and 404 of this
Act, the Administrator may, after opportunity for public hearing,
issue a permit for the discharge of any pollutant, or combination of
pollutants, notwithstanding section 301 (a), upon condition that such
discharge will meet either all applicable requirements under sections
301, 302, 306, 307, 308, and 403 of this Act, or prior to the taking of
necessary implementing actions relating to all such requirements, such
conditions as the Administrator determines are necessary to carry out
the provisions of this Act.
1-1
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July 20, 1978-
August, 1978-
August 9, 1978-
Chronology of Events
BMP Development in the NPDES Program
Orientation meeting for industry in Washington, D.C
attended by major chemical companies and trade associ-
ations (CMA, AFPA, API).
Hydroscience begins data gathering activities.
EPA and Hydroscience met with Procter and Gamble
technical staff, Cincinnati, Ohio*
August 23, 1978- Site visit to Hooker Chemical, Buffalo, N.Y.
September 1, 1978-
November, 1978-
EPA proposes rule establishing control on toxic and
hazardous pollutants by imposing BMPs for ancillary
industrial activities in NPDES permits (43 FR 39282),
October 25, 1978- Site visit to Allied Chemical, Hopewell, Virginia.
Phone interviews with Allied Chemical, Union Carbide,
Shell Chemical and Stauffer Chemical.
December, 1978-
January 24, 1979-
February, 1979-
Phone interviews with Celanese Fiber Co. and E.I.
Dupont, Inc.
Remarks to Allied Chemical Environmental Workshop,
Morristown, N.J., by H. Thron.
Hydroscience completes data gathering.
1-3
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April, 1979-
Hydroscience completes rough draft of Technical Guidance
Document.
May 9, 1979-
At Purdue Industrial Waste Conference, Lafayette,
Indiana,.H. Thron presents paper "BMPs for the Control
of Toxic and Hazardous Pollutants" based on Hydroscience's
study.
June 7, 1979-
EPA promulgates rule establishing the use of BMPs and
development of BMP Programs in the NPDES program (44 FR
32954).
July 18, 1979-
CMA files complaint for declaratory judgment and
injunctive relief in U.S. District Court (Roanoke, Va.)
challenging the EPA final NPDES regulation. Count
seven of the complaint addressed BMPs.
August 10, 1979-
EPA publishes FR notice deferring effective date of the
BMP portion of the regulations (44 FR 47063) until 60
days after the "NPDES Best Management Practices Guidance
Document" becomes available.
September, 1979-
Hydroscience submits draft BMP Technical Guidance
Document to EPA for review and printing.
March 20, 1980-
April 2, 1980-
EPA publishes FR notice making available to the public
the draft NPDES Best Management Practices Guidance
Document and provides comment period of 45 days from
the date of publication of the notice.
EPA publishes FR notice correcting the
comments closing date announced in the
March 20, 1980 FR issue to read "May 5,
1980" instead of "45 days from the date of
publication of this notice".
1-4
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May 5, 1980- EPA publishes PR notice extending the initial comment
period of the draft NPDES BMP Guidance Document by 45
days through June 19, 1980 making the total comment
period 90 days.
May 29, 1980- Chemical Manufacturers Association provides verbal
comments concerning draft NPDES BMP Guidance Document
during technical meetings at EPA.
May 30, 1980- CMA provided comments on BMP "policy" to EPA in a
follow-up meeting to the May 29 meeting.
June 19, 1980- EPA published FR notice extending the public comment
period an additional 30 days to a total of 120 days and
announces its intention to repropose the BMP regulation
(40 CFR Part 125, Subpart K).
July 14, 1980- CMA provided comments on the Guidance Document and
other BMP-related issues in a follow-up technical
meeting (see also May 29, 1980).
July 21, 1980- Formal comment period on draft Guidance Document
closes.
November 23-25, 1980- Office of Water Enforcement sponsors NPDES Best Manage-
ment Practices Workshop at Dulles Marriott Hotel.
1-5
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Chronology of BMP Federal Register Notices
Date
9/1/78
Volume No.,
FR Page No.
43 FR 39282
Action
Proposed rule: Criteria and
Standards for Imposing Best
Management Practices for
Ancillary Industrial Activities.
6/7/79
44 FR 32943
Final rule: (40 CFR Part 125,
Subpart K) Criteria and
Standards for Best Management
Practices Authorized under
Section 304(e) of the Act.
8/10/79
44 FR 47063
Deferral of Effective Date of
Subpart K until 60 days after
EPA publishes in the FR
notice of the availability of
the final NPDES Best Management
Practices Guidance Document.
3/20/80
45 FR 17997
Continuation of Deferral of
Effective Date and Notice of
Availability of Technical
Information in the draft
report entitled "NPDES Best
Management Practices Guidance
Document".
1-7
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4/2/80
45 FR 21635
Correction to 45 FR 17997 of
3/20/80: Comments closing
date should read "May 5,
1980".
5/5/80
45 FR 29589
5/19/80
45 FR 33537
Continuation of deferral of
effective date for Subpart K
and extension of comment
period on the draft Guidance
Document by 45 days.
Omit requirement for submission
of BMP program with permit
application Form 2c at this
time.
6/19/80
45 FR 41418
//80
45 FR
Continuation of deferral of
effective date for Subpart K
and further extension of
comment period on the draft
Guidance Document by 30 days.
Reproposed rule: Criteria and
Standards for Best Management
Practices Authorized under
Section 304(e) and 402(a)(1)
of the Act.
//81
46 FR
Final rule and notice of
the availability of the final
Guidance Document. Effective
date of Subpart K becomes / /81
1-8
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Federal Register Notices
The following Federal Register notices pertain to the BMP regulations,
Both BMP regulations (the September 1, 1978, proposed rule and the
June 7, 1979, regulation) can be found on pages III-l — 111-10 of this
Workbook.
1-9
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Federal Register / Vol. 44. No. 156 / Friday. August 10, 1979 / Rules and Regulations 47063-47064
40 CFR Parts 122 and 125
[FRL 1294-3]
National Pollutant Discharge
Elimination System; Deferral of
Effective Date for Best Management
Practice Requirements
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Deferral of Effective Date.
SUMMARY: EPA recently revised its
regulations for the National Pollutant
Discharge Elimination System (NPDES)
under the Clean Water Act. Certain new
requirements relating to best
management practices (BMP's) were
scheduled to become effective August
13,1979. Because EPA has not yet .
published relevant technical
information, EPA is today deferring the
effectiveness of the BMP requirements.
DATES: The BMP requirements will
become effective 60 days after EPA
publishes notice in the Federal Register
that the BMP technical information is
available.
FOR FURTHER INFORMATION CONTACT
Edward A. Kramer IEN-336), Office of
Water Enforcement, EPA, 401 M Street
SW., Washington, D.C. 20460, (202) 755-
0750.
SUPPLEMENTARY INFORMATION: EPA
PUBLISHED MAJOR REVISIONS TO ITS
NPDES REGULATIONS ON JUNE 7, 1079. 44
FR 32854-32956. IN THE JUNE 7 Federal
Register, EPA announced that most
provisions of the new regulations would
become effective on August 13,1979. 44
FR 32854, 32856.
One of the requirements scheduled to
become effective on August 13 was
Subpart K of 40 CFR Part 125—"Criteria
and Standards for Best Management
Practices Authorized Under Section
304{e) of the Act'' Subpart K requires
that applications for NPDES permits
include a "BMP program" for the control
of certain toxic and hazardous
pollutants. EPA stated that information
on the development of BMP programs
was contained in a publication entitled
"NPDES Best Management Practices
Guidance Document." 44 FR 32955,
comment following 40 CFR 125.104(b).
Publication of the Guidance Document
has, however, been unavoidably
delayed. EPA does not expect that it will
be available until a month or two after
the August 13 effective date.
EPA accordingly feels compelled to
defer applicability of the BMP portions
of the NPDES regulations until 60 days
after EPA has published Federal
Register notice of the availability of the
BMP program Guidance Document. The
following provisions are hereby
deferred: (1) The parenthetical reference
to BMP programs in 40 CFR 122.10(a);
and (2) all of Subpart K of 40 CFR Part
125 (40 CFR 125.100-104).
Dated: August 7,1970.
Douglas M. Costle,
Administrator.
JFR Doc. 79-24765 Filed B-S-Tft 8:45)
BILLING CODE C960-OI-M
1-10
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Federal Register / Vol. 45. No. 56 / Thv.r.sdsy. Morrh 20, 1930 / Ru!rs anil R«.-gula!ions 17997
40 CFR Parts 122 and 125
[FRL1440-8]
National Pollutant Discharge
Elimination System (NPDES); NPDES
Best Management Practices Guidance
Document and Regulations
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Continuation of Deferral of
Effective Date and Notice of Availability
of Technical Information.
SUMMARY: This notice announces the
availability of the draft NPDES Best
Management Practices (BMP) Guidance
Document. At this same time EPA is
providing a review and comment period
on the Guidance Document and is
continuing the deferral of the effective
date of the BMP requirements.
DATES: Comments on the draft NPDES
Best Management Practices Guidance
Document must be received on or before
[45 days from the date of publication of
this notice].
The effective date of the BMP
requirements continues to be deferred
until EPA completes the review of
comments submitted in response to this
notice and announces the new effective
datejn the Federal Register^
ADDRESSES: Interested persons may
obtain copies of the draft Guidance
Document by written request addressed
to the contact person listed below.
Comments on the Document should be
submitted to the same address.
FOR FURTHER INFORMATION CONTACT:
Harry M. Thron, Office of Water
Enforcement (EN-338), Environmental
Protection Agency, 401M Street S.W.,
Washington. D.C. 20460. (202) 426-7010.
SUPPLEMENTARY INFORMATION: EPA
published major revisions to its NPDES
regulations on June 7,1979.44 FR 32854-
32956. In the June 7 Federal Register,
EPA announced that most provisions of
the new regulations would become
effective on August 13,1979.44 FR
32854,32856. One of the requirements
scheduled to become effective on
August 12 was Subpart K of 40 CFR Part
125—"Criteria and Standards for Best
Management Practices Authorized
Under Section 304(e) of the Act."
Subpart K requires that applications for
NPDES permits include a "BMP
program" for the control of certain toxic
and hazardous pollutants.
EPA stated in the June 7 regulations
that technical guidance on the
development of BMP programs would be
provided in a publication entitled
"NPDES Best Management Practices
Guidance Document." See comment
following 40 CFR 125.104 (b) (44 FR
32955). However, publication of the
Guidance Document was delayed
beyond the August 13 effective date.
Therefore, on August 10,1979. EPA
deferred applicability of the BMP
portions of the NPDES regulations until
60 days after publication in the Federal
Register of a notice of availability of the
BMP Guidance Document. 44 FR 47063.
EPA today announces the availability of
the draft report "NPDES Best
Management Practices Guidance
Document" (EPA-600/9-79-045,
December 1979), and provides a 45-day
comment period on the Guidance
Document. Comments should address
only the technical aspects of the
Guidance Document since EPA
previously has solicited and received
comments on the BMP regulation itself.
After reviewing comments, EPA will
finalize the Guidance Document and .
publish a notice in the Federal Register
announcing the effective date of the
BMP regulations, 40 CFR Part 125
Subpart K.
Dated: March 12. I960.
Jeffrey G. Miller,
Acting Assistant Administrator for
Enforcement.
[FR Doc. 80-8577 Filed 3-1MO: 8:43 am)
BILLINQ CODE 6560-01-M
1-11
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Federal Register / Vol. 45, No. 65 /Wednesday, April 2, 1980 / Rules and Regulations 21635
40 CFR Parts 122 and 125
FRL 1440-8]
National Pollutant Discharge
Elimination System (NPDES); NPDES
Best Management Practices Guidance
Document and Regulations
Correction
In FR Doc. 80-8577, appearing on page
17997, in the issue for Thursday, March
20,1980, in the "DATES" paragraph, the
comments closing date should read
"May 5.1980".
BILLING CODE 1505-01-M
1-12
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Federal Register / Vol. 45. No. 88 / Monday. May 5.1980 / Rules and Kegulations 29589
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Parts 122 and 125
[FRL 1462-2]
National Pollutant Discharge
Elimination System (NPDES); NPDES
Best Management Practices Guidance
Document and Regulations
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Continuation of deferral of
effective date and extension of comment
period.
SUMMARY: This notice announces that
EPA is extending the review and
comment period on the National
Pollutant Discharge Elimination System
(NPDES) Best Management Practices
(BMP) Guidance Document and is
continuing the deferral of the effective
date of the BMP requirements.
DATES: Comments on the draft NPDES
Best Management Practices Guidance
Document must be received on or before
June 19,1980.
The effective date of the BMP
requirements continues to be deferred
until EPA completes the review of the
comments submitted in response to this
notice and announces the new effective
date in the Federal Register.
ADDRESSES: Interested persons may
obtain copies of the draft Guidance
Document by written request addressed
to the contact person listed below.
Comments on the Document should be
submitted to the same address.
POR FURTHER INFORMATION CONTACT:
Harry M. Thron, Office of Water
Enforcement (EN-336), Environmental
Protection Agency, 401M Street, SW,
Washington, DC 20460, (202) 426-7010.
SUPPLEMENTARY INFORMATION: EPA
stated in the June 7,1979 Federal
Register that technical guidance on the
development of BMP programs would be
provided in a publication entitled
"NPDES Best Management Practices
Guidance Document." See comment
following 40 CFR 125.104(b) (44 FR
32955). However, publication of the
Guidance Document was delayed
beyond the August 13 effective date.
Therefore, on August 10,1979, EPA
deferred applicability of the BMP
portions of the NPDES regulations until
60 days after publication in the Federal
Register of a notice of availability of the
BMP Guidance Document. 44 FR 47063.
EPA later announced on March 20,1980
the availability of the draft report
"NPDES Best Management Practices
Guidance Document" (EPA-600/9-79-
045, December 1979), and provided a 45-
day comment period on the Guidance
Document. 45 FR 17997. EPA today
announces that the comment period on
the BMP Guidance Document is
extended by 45 days to a total of 90
days. The comment period is being
extended in response to public
comments that the initial comment
period of 45 days is insufficient due to
the technical nature and length of the
Document and to mail delays.
Comments should address only the
technical aspects of the Guidance
Document since EPA previously has
solicited and received comments on the
BMP regulation itself.
After reviewing comments, EPA will
finalize the Guidance Document and
publish a notice in the Federal Register
announcing the effective date of the
BMP regulations, 40 CFR Part 125
Subpart K. 40 CFR Part 122 is unaffected
by this action.
Dated: April 23,1980.
Jeffrey G. Miller,
Acting Assistant Administrator for
Enforcement.
(FR Doc. 8O-13835 Filed 5-2-S& 9:17am]
BILLING CODE 6560-01-M
1-13
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Federal Register /Vol. 45, No. 98 / Monday,' May 19, 1980 / Rules and Regulations
c. Ancillary Activities Which may
Result in Discharges of Toxic Pollutants
or Hazardous Substances—Best
Management Practices Programs.
Proposed §§ 122.64(d) (11) and (13) and
draft items III-B and II1-C of Form 2c
required each applicant to describe any
actual or potential discharges of toxic
pollutants or hazardous substances from
ancillary activities and to attach a copy
of its Best Management Practices (BMP)
program for controlling these discharges.
The requirement to develop a BMP
program was contained in Part 125,
Subpart K of the final NPDES
regulations published on June 7,1979 (44
FR 32854, 32954). The effective date of
Part 125, Subpart K was deferred on
August 10,1979 (44 FR 47063) pending
the availability of a BMP guidance
document. On March 20,1980 (45 FR
17997) the guidance document was made
available for a 45-day public comment
ending May 5,1980 (see 45 FR 21635;
April 2,1980). Therefore, at this time 40
CFR Part 125, Subpart K is not yet
effective.
In light of this timing problem, EPA
decided to omit the requirement to
submit a BMP program from Form 2c at
this time. When Part 125, Subpart K
becomes effective Form 2c will be
amended as appropriate. This will allov
EPA to make any adjustments tc the
requirements necessary to respond to
public comments on the BMP manual a;
well as those previously submitted on
proposed §§ 122.64(d) (11) and (13) and
draft items III-B and III-C. In particular,
EPA is considering comments submitted
on the draft form which suggested that a
summary of the BMP program, rather
than the entire program, be included
with the application, and that the
description of actual and potential
discharges (draft item III-B) be
combined with this summary.
1-14
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Federal Register / Vol. 45, No. 120 / Thursday, June 19, 1980 / Rules and Regulations 41418-41419
40 CFR Parts 122 and 125
[FRL 1519-2]
National Pollutant Discharge
Elimination System (NPDES); NPDES
Best Management Practices Guidance
Document and Regulations
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Continuation of deferral of
effective date and further extension of
comment period.
SUMMARY: This notice announces that
EPA is further extending the review and
comment period on the NPDES Best
Management Practices (BMP) Guidance
Document and is continuing the deferral
of the effective date of the BMP
requirements.
DATES: Comments on the draft NPDES
Best Management Practices Guidance
document must be received on or before
July 21,1980.
The effective date on the BMP
requirements continues to be deferred
until EPA completes the review of
comments submitted in response to this
notice and announces the new effective
date in the Federal Register.
ADDRESSES: Interested persons may
obtain copies of the draft Guidance
Document by written request addressed
to the contact person listed below.
Comments on the document should be
submitted to the same address.
FOR FURTHER INFORMATION CONTACT:
Harry M. Thron, Office of Water
Enforcement (EN-336), Environmental
Protection Agency, 401M Street, SW.,
Washington, D.C. 20460 (202) 428-7010.
SUPPLEMENTARY INFORMATION: EPA
stated in the June 7,1979 Federal
Register that technical guidance on the
development of BMP programs would be
provided in a publication entitled
"NPDES Best Management Practices
Guidance Document". See comment
following 40 CFR 125.104(b) (44 FR
32955). However, publication of the
Guidance Document was delayed
beyond the August 13 effective date.
Therefore, on August 10,1979, EPA
deferred applicability of the BMP
portions of the NPDES regulations until
60 days after publication in the Federal
Register of a notice of availability of the
Guidance Document 44 FR 47063. EPA
later announced on March 20,19BO the
availability of the draft report "NPDES
Best Management Practices Guidance
Document" (EPA-600/9-79-045,
December 1979), and provided a 45-day
comment period on the Guidance
Document, 45 FR 17997. EPA then
announced on May 5,1980 that the
comment period on the BMP Guidance
Document was extended by 45 days to a
total of 90 days, 45 FR 29589. EPA today
announces that the comment period on
the BMP Guidance Document is further
extended by 30 days to a new total of
120 days. The comment period has been
extended in response to public
comments that a comment period of 90
days is insufficient due to mail delays.
Thesejlelays are due, in part, to the
great number of requests for the
document which the EPA unexpectedly
has received. This large public response
resulted in the need to print additional
copies of the original draft document to
afford all interested parties the
opportunity to comment. Comments
should address only the technical
aspects of the Guidance Document. EPA
intends to propose changes in the near
future to the BMP regulations, 40 CFR
Part 125, Subpart K. Public comments on
the regulations themselves will be
solicited at that time.
After reviewing comments, EPA will
make available the final Guidance
Document and publish a notice in the
Federal Register announcing the
effective date of the BMP regulations, 40
CFR Part 125, Subpart K.
Dated: June 16.1980.
Jeffrey G. Miller,
Acting Assistant Administrator for
Enforcement
|FK Doc. 80-18500 Filed 6-15-BO; 8:45 am)
BILLING CODE 6580-01-M
1-15
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II. SUMMARY OF PUBLIC COMMENTS
Issues
Summary of Issues
Responses to Public Comments
-------
Issues
Federal Register Notice
Comment Period
Authority/Jurisdiction
CWA - Scope (SPCC)
NPDES Subpart K Part 125 (6/7/79)
Interrelationship of Other Regulations
Effective Date—BMPs
Second Round Permits
BMPs and Point Sources
Need for BMP Plan and Content
Impact on Industry
Impact on States/Regions
Third Party Abuse
Incomplete Review of Industries
Use of Document as a Guide
Lack of EPA Staff/Experience
Baseline vs. Advanced
Baseline BMPs—General
Advanced BMPs—General
BMPs and Major Construction
Proprietary Data
Runoff
Certification/New Provisions
Submission of Plan
Concurrence
II-l
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Summary of Issues
ISSUE 1 - FEDERAL REGISTER NOTICES (3/20/80, 6/19/80)
• FR stated that comments should not address BMP regulations - cannot
comment on BMPGD in absence of regulatory framework.
• Cannot comment on document if the regulations it is to support have
not been issued in their entirety.
ISSUE 2 - COMMENT PERIOD
• Want extension because more data on industries needs to be collected
and because of the delays in receiving copies of the document.
• 45-day comment period conflicts with Executive Order 12044 since
they consider the BMPGD to be a significant regulation
• Comment period should be extended until final RCRA and UIC regulations
are promulgated.
ISSUE 3 - AUTHORITY (GENERAL)
• Question EPA's statutory authority to require a BMP, as outlined in
this document, on a case-by-case basis at every facility with a
NPDES Permit.
• Question authority to impose advanced BMPs (including receiving
water quality impact) without a detailed cost and regulatory analysis.
• Question broad definition of ancillary sources (as outlined in
guidance document infringes on rights of industry to conduct
operations and manufacturing processes)
• Question that EPA has authority to require spill reporting and other
base-line BMPs, except as intended and required by CWA.
ISSUE 4 - CLEAN WATER ACT-SCOPE (SPCC)
• Various base-line BMPs are outside intent/scope of CWA Section 304(e)
and Section 402. .
• EPA has gone beyond BMP objective of providing guidance on spillage
around ancillary activities and has confused SPCC requirements
(CWA 311) with BMPs.
ISSUE 5 - NPDES PART 125 SUBPART K (6/7/79)
• Although 6/7/79 regulations indicate that only base-line BMPs would be
included in 2nd round permits, the BMPGD addresses advanced BMPs.
II-3
-------
• Although EPA has indicated that a state could exercise discretion in
applying BMPs, Part 125 states that a BMP program is to be submitted
with a permit application and would therefore be subject to EPA review
for non-waived categories.
• Disagree with EPA's determination in 6/7/79 regulations that the BMPs
do not require an economic impact statement.
• No need for BMP Guidance Document - requirements should be incorpor-
ated into 125 Subpart K regulations.
• See CMA (Letter 46) proposed amendments to Part 125.
ISSUE 6 - INTERRELATIONSHIP/OVERLAP WITH OTHER REGULATIONS
• BMP regulations and the BMPGD overlapping with TSCA, RCRA, OSHA, CAA,
UIC, SDWA
ISSUE 7 - EFFECTIVE DATE OF BMP REGULATIONS
• Question as to whether BMP regulations are effective 60 days after
availability of BMP Manual in final form or after availability of this
draft.
• No BMPs should be established as part of an NPDES permit until regula-
tions have been finalized.
ISSUE 8 - SECOND ROUND PERMITS
• Will only base-line BMPs be included in Second Round permits ?-
• Facilities are now submitting second round permit applications and
although EPA has indefinitely deferred the effective date of the BMP
regulations, regulations state, that a permit application not contain-
ing a BMP program will be considered incomplete.
ISSUE 9 - BMPs AND POINT SOURCES
• BMPGD neither deals with point source categorization nor defines
significant amounts of toxics/hazardous pollutants contrary to CWA
Section 304 (b) and (e).
• BMPs are not applicable to non-point source runoff.
ISSUE 10 - NEED FOR BMP PLAN (CONTENT?)
• Question that each NPDES permittee who uses, produces or discharges
substances on the toxic or hazardous pollutants lists needs to prepare
a BMP plan - how does a permittee determine if a plan is required given
the generic classifications used and considering that the guideline of
significant amount is not defined.
II-4
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• Industry already practicing the management actions outlined in BMPGD.
• Allow permit writers or enforcement agency to waive submission and
inclusion of a BMP plan with permit application.
• A SPCC plan should not be required as part of BMP plan.
• What level of detail and what format is required for a BMP.plan?
ISSUE - 11 IMPACT ON INDUSTRY
• BMP plans will have a severe cost impact (equipment and manpower) on
industry.
• BMP program would be an administrative burden (paperwork).
• Legal implications of BMP program is that a permittee is required to
draft a BMP plan which is incorporated in his permit and later could
be enforced on him.
• BMP concepts prepared at meetings of 5/29 and 30 would help to alleviate
level of manpower required to implement the plan.
ISSUE 12 - IMPACT STATES/REGIONS
• The procedure to be used by the permit : writer to review a BMP plan will
be a drain on state and regional manpowert
• If third parties request evidentiary hearings to tie up the permit
process, as is expected, this will create another burden for states
and regions.
• The timing and scope of EPA review of BMP plans will effect the manpower
impact on EPA region and states.
• Analogous state programs should be acceptable in lieu of BMPs.
• Who will train the permitting authority?
ISSUE 13 - THIRD PARTY ABUSE
• It is feared that third parties, such1 as environmental groups and unions,
will request evidentiary hearings for delay and harassment purposes.
• The BMP plan would be open to public review and thus disclose confi-
dential information.
ISSUE 14 -INADEQUATE INDUSTRIAL REVIEW
• The concentration of review on major chemical companies ignored others
such as the steam electric power, mining, and petroleum industries.
II-5
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ISSUE 15 - USING THE BMPGD AS A GUIDE
• BMPGD appears to be an inflexible set of requirements and checklists
and does not provide the flexibility that a guidance document should.
ISSUE 16 - PERMIT WRITER QUALIFICATIONS
• Permit writers do not have the level of engineering experience or
familiarity with an individual facility to effectively evaluate a
BMP plan.
• The discretionary judgement experienced by permit writers should be
limited so that they will not arbitrarily impose stringent require-
ments .
• -Permit writers should not use the BMPGD as an inflexible cookbook or a
checklist.
ISSUE 17 - BASELINE VS. ADVANCED BMPs
• What is the rationale for distinguishing between baseline and advanced
BMPs?
ISSUE 18 - BASELINE BMPs: GENERAL
• Only baseline BMPs should be included and should be objectives, not
rigid requirements.
• BMPGD baseline overlap with other statutory requirements.
ISSUE 19 - ADVANCED BMPs: GENERAL
i
• Advanced BMPs are not authorized by CWA 304 (e) or Part 125 Subpart K.
• Advanced BMPs should not be included in the BMPGD or required as part
of a BMP plan.
• Advanced BMPs interfere with plant operation and would cause expensive
costs.
• Advanced BMPs overlap with other statutory requirements (particularly
SPCC plans under CWA Section 311).
ISSUE 20 - BMPs AND MAJOR CONSTRUCTION
• BMPs requiring major construction are not authorized under existing
regulations.
TSSUE 21 - PROPRIETARY INFORMATION
o Since the BMP plan would be part of the permit, it would be open to
public review, thus releasing confidential information.
II-6
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• The materials inventory and security requirements involve disclosure
of proprietary data.
ISSUE 22 - RUNOFF
• EPA is not authorized under the BMP regulations to regulate non-point
source runoff.
• Not all plant site runoff is a problem (such as drainage from coal
piles, runoff from a fertilized lawn etc.)
ISSUE 23 - CERTIFICATION (5/29/80 MEETING PROPOSED REVISIONS)
• Support the proposed procedures of 5/29/80 meeting concerning
certification, development and implementation of plan.
ISSUE 24 - SUBMISSION OF PLAN WITH PERMIT APPLICATION
* According to 5/29/80 meeting the BMP plan does not need to be sub-
mitted with a permit application, but must develop a plan within six
months from submission and implement it within 18 months.
• Request that development of BMP plans be delayed until BMPGD is
finalized.
• Oppose submission of BMP plan with permit application (comments sub-
mitted prior to 5/29 meeting).
ISSUE 25 - CONCURRENCE
• Concurred with CMA comments: Kaiser Aluminum, Shell, DuPont, National
Food Processors.
• Concurred with Texas Chemical Councils comments: DOW Chemical,
Diamond Shamrock.
• Concurred with American Petroleum Institute comments: Shell.
• Concurred with Chlorine Institute comments: Diamond Shamrock.
• Concurred with UWAG comments: PP&L, RG&E.
II-7
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Responses to Public Comments
ISSUE 3
Comment A: Many commenters questioned the statutory authority for imposing
BMP plans. They stated that Section 304(e) of the Act authorizes the
Administrator to establish BMPs by regulation only for a class or category
of point sources supplemental to effluent limitations.
Response: Section 304(e) provides EPA the authority for requiring BMPs on
the basis of industrial categories, supplemental to effluent limitations
guidelines. The authority for imposing BMP plans is derived from Section
402(a)(1) of the Act. Under the authority of Section 402(a)(1), the
Administrator, where determined necessary, may prescribe conditions in
NPDES permits to carry out the provisions of the Act.
One of the provisions of the Act [contained in Section 304(e)] allows
the Administrator to prevent or minimize the discharge of toxic pollutants
and hazardous substances from activities identified in Section 304(e) by
publishing regulations for a class or category of point sources. These
"class or category" regulations, supplemental to effluent limitations, have
not yet been published. In the absence of Section 304(e) BMPs, the Office
of Water Enforcement, under the authority of Section 402(a)(1), has proposed
that NPDES permittees prepare and implement BMP plans in accordance with 40
CFR Part 125 Subpart K.
Comment B: Many commenters questioned the authority to impose advanced
BMPs (site-specific or pollutant-specific requirements) without a detailed
cost analysis.
II-9
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Response: The authority for imposing advanced BMPs is derived from Section
402(a)(1). Advanced BMPs, as well as baseline BMPs (the 9 specific require-
ments) , may be imposed, where determined necessary, on a case-by-case
basis, if a BMP is needed to control the discharge of toxic pollutants or
hazardous substances for a specific case, the most cost effective BMP
should be chosen. To determine if a BMP, whether advanced or baseline, is
required, factors such as the toxicity of chemicals, opportunity for
release to surface waters and spill history of the facility must be considered.
In addition to any case-by-case BMPs required, all NPDES permittees or
applicants who use, handle, manufacture or discharge any toxic pollutant or
hazardous substance must prepare and implement a BMP plan.
Comment C: Many commenters questioned EPA's broad definition of ancillary
sources. Specifically, the commenters felt that in-plant transfer, process
and material handling areas as well as loading and unloading areas were
beyond the scope of Section 304(e).
Response: The scope of Section 304(e) covers activities associated ,
with or ancillary to the industrial manufacturing or treatment process.
BMPs for these activities should prevent or minimize the following types of
discharges: plant site runoff; spillage or leaks; drainage from raw
material storage; and sludge and waste disposal. In-plant transfer,
process and material handling areas, and loading and unloading areas
involve activities which are associated with the industrial manufacturing
or treatment process and these activities could result in spillage or
leaks. Consequently, these activities are covered by Section 304(e).
ISSUE 6
Comment A: BMP regulations and the BMP Guidance Document overlap
with TSCA, RCRA, OSHA, CAA, UIC, and SDWA.
Response: The intent of BMP plan requirements is different from other
-egulatory requirements. Consequently, the requirements for BMP plans will
increase concern for preventing or minimizing discharges of toxic pollutants
11-10
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or hazardous substances whereas similar requirements under OSHA, for example,
may not focus on prevention or minimization of these discharges. The Agency
has no intent to impose redundant requirements which serve the same purposes.
If a requirement of a BMP plan (i.e., preventive maintenance) is also required
by a previous regulation, then the existing preventive maintenance (PM)
program should be reviewed and modified, where necessary, to incorporate BMP
plan objectives. A second or separate PM program need not, and should not,
be implemented. If the PM program documentation is kept separate from the
BMP plan, the PM program and its location should be referenced in the BMP
plan. In this manner, requirements in a BMP plan will complement requirements
under TSCA, RCRA, OSHA, CAA, and SDWA.
ISSUE 8
Comment A: Will only baseline BMPs (the 9 specific requirements) be
included in second round permits?
Response: On a case-by-case basis, the Administrator, where determined
necessary, may impose conditions in a permit to carry out the provisions of
the Act. In the second round of permit issuance, the control of toxic
pollutants and hazardous substances is a high priority. If it is determined
that baseline BMPs are not able to fully control the discharges of these
chemicals for a facility, then advanced BMPs (site-specific or pollutant-specific
requirements) may be imposed for that facility. Secondly, when hazardous
substances SPCC regulations are promulgated, advanced BMPs, primarily in the
form of secondary containment or drainage control, will be imposed for
certain facilities.
Comment B: BMP regulations state that a permit application not containing
a BMP program (BMP plan) will be considered incomplete.
Response: Since the effective date of Subpart K has been deferred, the
regulation is not now applicable. Therefore, a permit application need
not specifically address BMPs until the regulation becomes effective.
li-ll
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ISSUE 10
Comment A: Need to define significant amount to determine which facilities
must develop and implement a BMP plan.
Response: All NPDES applicants and permittees who use, produce, manufacture
or discharge toxic pollutants or hazardous substances must develop and
implement a BMP plan. It is anticipated that the length, content, and
detail of a BMP plan will be commensurate with the quantity of toxic or
hazardous chemicals on site and their opportunity for discharge. Consequently,
the determination of "significant amount" is left, principally, to the
facility's judgment. For example, if a facility determines that small
quantities of toxic chemical X stored onsite have a low potential for
reaching navigable waters, then minimal procedures and practices are
necessary for BMP incident control. On the other hand, if a high potential
exists for large quantities of toxic chemical X to reach receiving waters,
then appropriate BMPs would be necessary.
ISSUE 11
Comment A: BMP plans impose severe costs on industry.
Response: Since requirements under BMP plans are flexible and primarily
involve procedures, the costs will depend upon site specific situations.
The flexibility of a BMP plan lessens the cost impact to a facility by
allowing the most cost-effective elements of each specific requirement to
be used. The procedural nature of BMP plans imposes negligible equipment
cost on a facility. Most facilities are already using elements of specific
requirements to satisfy requirements of other regulations. Consequently,
the costs for implementing a BMP plan is less than might be anticipated.
Comment B: BMP plans would be an administrative burden.
11-12
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Response: Naturally paperwork is involved, but the BMP plan is not meant
to be a paper intensive exercise. Once a BMP plan is developed, the
paperwork involved in keeping records of preventive maintenance, employee
training, inspections, and BMP incidents should be kept to a minimum. The
record-keeping process should be used to increase awareness and concern
toward preventing BMP incidents, and not to increase paperwork or bureaucracy.
The Agency believes that the flexible, self-regulatory BMP approach with a
de-emphasis on paperwork is in the spirit of regulatory reform.
ISSUE 12
Comment A: The procedure to be used by the permit writer to review a BMP
plan will be a drain on state and regional manpower.
Response: The review of a BMP plan is a potential burden on the resources
of the states and regions. Consequently, extensive review by permitting
authorities is not anticipated. The BMP plan will be kept onsite and be
subject to review during compliance inspection or at the request of the
Director.
Comment B: Analogous state programs should be acceptable in lieu of BMP
plans.
Response: All facilities subject to Subpart K must develop BMP plans.
These facilities should review state programs which are analogous to the
BMP plans. Requirements under existing state programs which satisfy BMP
plan requirements need only be referenced in the BMP plan. Redundant
practices need not and should not be developed or implemented.
ISSUE 15
Comment A: Draft BMP Guidance Document appears to be an inflexible
set of requirements and checklists and does not provide the flexibility
that a guidance document should.
11-13
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Response: The draft NPDES BMP Guidance Document has been revised. By
rewording sentences, deleting checklists and incorporating cornmenters
suggestions, the Agency anticipates the final guidance document to be
extremely flexible.
ISSUES 17 and 19
Comment A: What is the rationale for distinguishing between baseline BMPs
(the 9 specific requirements) and advanced BMPs (site-specific and pollutant-
specific requirements)?
\
Response: In a BMP plan, baseline BMPs are mandatory whereas advanced
BMPs are optional. Baseline BMPs usually are low in cost in comparison
with advanced BMPs. A facility may decide efficiently and cost-effectively
upon the elements of each baseline BMP which best fit the needs of the
facility. After each baseline BMP is addressed in the BMP plan, the
facility, if it chooses to do so, may incorporate advanced BMPs into its
BMP plan.
Comment B: Advanced BMPs should not be included in the BMP Guidance
Document or required as part of a BMP plan.
Response: EPA intends to delete the advanced BMPs in the final guidance
document. Advanced BMPs are an optional part of a BMP plan, and are not
mandatory.
Comment C: Advanced BMPs overlap with other statutory requirements
(particularly SPCC plans under CWA Section 311).
Response: BMP plans cover both toxic pollutants and hazardous substances
while SPCC plans cover only hazardous substances. Therefore, no overlap
exists concerning requirements for toxic chemicals.
Advanced BMPs typically involve capital expenditures for items such as
instrumentation or construction. These same types of measures may be taken
11-14
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to comply with requirments for SPCC plans for hazardous substances, once
the SPCC regulations are promulgated. The requirement to prepare a BMP
plan or SPCC plan is triggered by a permit application. Therefore one or
the other is required, but not both. If a permittee has both toxic pollutants
and hazardous substances, these may be addressed by a combination SPCC-BMP
plan. Actions taken to satisfy SPCC requirements will satisfy BMP require-
ments. In this manner, overlap is avoided.
ISSUE 21
Comment A: Since the BMP plan would be part of the permit, it would be
open to public review, thus releasing confidential information such as the
materials inventory and security system.
Response: Though EPA intends to have the BMP plan remain onsite, a
certification statement in the permit application would tie the BMP plan to
the permit. To prevent disclosure of confidential information, facilities
are allowed to separately file the sections of their BMP plans which they
deem confidential. The location of the files must be referred to in the BMP
plan and shall be made available to the Director upon request.
ISSUES 23 and 24
Comment A: Some commenters support the proposed procedures concerning
certification, development and implementation of the plan.
Response: At the present time, the Agency is considering requiring a
statement in the permit application which certifies that the BMP plan will
be developed within 6 months and implemented within 18 months of the date
of the permit application.
Comment B: Some commenters request that development of BMP plans be
delayed until the draft BMP Guidance Document is put in final form.
11-15
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Response: The Agency intends to make the final BMP Guidance Document
available before the effective date of the BMP regulation, 40 CFR Part 125
Subpart K.
11-16
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III. BMP REGULATION
(40 CFR Part 125 Subpart K)
Proposed Rule
Final Rule
Reproposed Rule
-------
FRIDAY, SEPTEMBER 1, 1978
PART VI
ENVIRONMENTAL
PROTECTION
AGENCY
NATIONAL POLLUTANT
DISCHARGE
ELIMINATION SYSTEM
Criteria and Standards for
Imposing Best Management
Practices for Ancillary Industrial
Activities
iii-i
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39282
PROPOSED RULES
[6560-01]
ENVIRONMENTAL PROTECTION
AGENCY
[40 CFR Port 125]
IFRL 912-3A]
NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM
Criteria end Standards for Imposing Best Men-
ogomonf Practices for Ancillary Induilrial
AcflwHIoa
AGENCY: Environmental Protection
Agency.
ACTION: Proposed rule.
SUMMARY: This proposed rule would
revise the existing regulations govern-
ing the National Pollutant Discharge
Elimination System (NPDES) program
In order to reflect new controls on
toxic and hazardous pollutants under
the 1977 amendments to the 'Clean
Water Act. The proposed rule indi-
cates how "best management prac-
tices" for onsite industrial activities
(such as materials storage and waste
disposal) may be Imposed in NPDES
permits to prevent the release of toxic
and hazardous pollutants to surface
waters. It should be read in conjunc-
tion with regulations recently pro-
posed (43 FR 37078. Aug. 21, 1978) to
amend the NPDES program as a
whole (new parts 122-125) and with
regulations proposed today in separate
part V for spill prevention control and
countermeasure plans (new part 151).
DATES FOR COMMENTS: Com-
ments must be received on or before
October 31, 1978. A notice was pub-
lished In the FEDERAL REGISTER con-
cerning two meetings open to the
public. for discussing and receiving
comments on the proposed NPDES
regulations. These meetings are sched-
uled for September 19, 1978 (in Wash-
tr:5d/>n, D.C.) and September 21, 1978
( Sf.n Francisco, Calif.).
BESSES: Interested persons may
r I •>••'.<; in this proposed rulemak-
by submitting comments to
i >ard A. Kramer, Permits Division
( ?•?*>), Office of Water Enforce-
ment, Environmental Protection
Agency. 401 M Street SW., Washing-
ton, D.C. 20460. A copy of all public
comments, will be available for inspec-
tion and copying at EPA Public Infor-
mation Reference Unit, Room 2922
(EPA Library), 401 M Street SW.,
Washington, D.C. 20460. The EPA In-
formation regulation (40 CFR Part 2)
provides that a reasonable fee may be
charged for copying. Two open meet-
Ings to discuss and receive comments
on the prfosed regulations, are to be
held at the following addresses:
September 19. 1978, 1 to 5 p.m. and 7
to 10 p.m.. GSA Auditorium, 18th and
F Streets NW., Washington, D.C.
20450. (For information concerning
the Washington, D.C. meeting contact
Edward A. Kramer at address shown
below.)
September 21, 1978, 1 to 5 p.m. and 7
to 10 p.m., EPA, Region IX, 6th Floor
Conference ROom, 215 Fremont
Street, San Francisco, Calif. 94104.
(For further information concerning
the San Francisco meeting contact
Rick Hoffman, EPA, Region IX,
Office of External Relations, 215 Fre-
mont Street, San Francisco, Calif.
94105, telephone 415-556-6695.)
FOR FURTHER INFORMATION
CONTACT:
Edward A. Kramer (EN-336), Office
of Water Enforcement, Environmen-
tal Protection Agency, Washington,
D.C. 20460. 202-755-0750.
SUPPLEMENTARY INFORMATION:
Under section 304(e) of the 1977
amendments to the Clean Water Act
(Pub. L. 95-217), Congress established
new authority to protect surface
waters from toxic and hazardous pol-
lutants through "best management
practices" (BMP's) imposed in NPDES
permits. Best management practices
must be imposed to control "plant site
runoff, spillage or leaks, sludge or
waste disposal, and drainage from raw
material storage" which are associated
with or ancillary to the industrial
manufacturing or treatment process.
This proposed rule describes how
BMP's for onsite industrial activities
under section 304(e) shall be reflected
in permits for dischargers who use,
manufacture,' store, handle, or dis-
charge significant amounts of toxic or
hazardous pollutants into waters of
the United States. Two methods of
control are required.
First, best management practices
may be incorporated into permits as
express requirements, either as re-
quired by a promulgated effluent limi-
tations guideline for that industry or
as determined to be necessary on a
case-by-case basis under section
402(a)(l)of the act.
In addition, unless applicable stand-
ards and limitations are adequate to
control toxic and hazardous pollut-
ants, all such dischargers must develop
and implement a "BMP plan" to pre-
vent or minimize the potential for re-
lease of toxic and hazardous pollut-
ants. The BMP plan must establish
specific control objectives, established
specific practices to meet those objec-
tives, and be certified by a registered
professional engineer. The plan would
be incorporated by reference into the
permit, with its adequacy determined
by its effectiveness in preventing the
release of toxic and hazardous pollut-
ants. The failure to develop and imple-
ment an adequate BMP plan, as well
as the discharge of pollutants In con-
travention of an adequate BMP plan,
will constitute a permit violation and
subject the permittee to enforcement
action. The BMP plan approach would
be Implemented under section
402(a)(l) of the act; its individualized
focus would provide flexibility and en-
courage innovation in establishing
best management practices.
These regulations are being pro-
posed in conjunction with regulations
under section 31KJX1XC) of the act
(40 CFR Part 151). Under the section
311 regulations, permittees would be
required to develop spill prevention
control and countermeasure (SPCC)
plans to prevent discharges of hazard-
ous substances to surface waters. To
Insure regulatory consistency, SPCC
plan requirements would constitute
minimum requirements for BMP
plans. The purpose of publishing the
two regulations concurrently is to
allow the owner or operator of a per-
mitted facility to develop BMP and
SPCC plans concurrently, and thereby
avoid duplication of environmental
controls. SPCC plans, as required by
proposed regulations, could be incor-
porated into BMP plans by reference.
Based upon the experience of the oil
SPCC program, EPA believes that the
flexible, self-regulatory approach of
the BMP plan is the least costly alter-
native available under section 304(e).
However, to insure that this is in fact
the case, comments are solicited on:
(1) The cost breakdowns for BMP
plans for particular industries; and
(2) Whether any less costly alterna-
tives (that are environmentally and le-
gally acceptable) exist.
For further assistance in this regard,
EPA has prepared a cost analysis
which is available upon request from
Edward Kramer, the contact person
noted above.
NOTE.—The Environmental Protection
' Agency has determined that this document
does not constitute a major regulation re-
quiring preparation of an economic Impact
statement under Executive Order 12044.
Dated: August 24, 1978.
DOUGLAS M. COSTLE,
Administrator.
•PART 125—CRITERIA AND STANDARDS FOR
THE NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM
Subport L—Crlterfo ond Standard* for Imposing Best
Management Practices Under Section 304(e) of the
Art
Sec.
125.60 Purpose and scope.
125.61 Definitions.
125.62 Applicability of best management
practices.
125.63 Permit terms and conditions.
125.64 Best management practices plan.
1. 40 CFR Part 125 is proposed to be
amended by adding a new subpart L,
as follows:
FEDERAL REGISTER, VOL 43, NO. 171—FRIDAY, SEPTEMBER 1, 1978
III-2
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PROPOSED RULES
39283
Subpart I—Criteria and Standard! for Impos-
ing Boat Management Practices (BMP) Under
Section 304(e) of the Act
§ 125.60 Purpose and scope.
This subpart describes how best
management practices for ancillary in-
dustrial activities under section 304(e)
of the Act shall be reflected in per-
mits, including best management prac-
tices promulgated In effluent limita-
tions under section 304 and estab-
lished on a case-by-case basis in per-
mits under section 402(a)(l) of the
Act. Best management practices au-
thorized by section 304(e) are included
in permits as requirements for the
purposes of sections 301, 302, 306, 307,
or 403, as the case may be.
§ 125.61 Definitions.
For purposes of this subpart:
(a) "Best management practices"
(BMP) means methods, measures, or
practices to prevent or reduce the con-
tribution of pollutants to waters of the
United States. BMP's Include but are
not limited to treatment requirements,
operating and maintenance proce-
dures, schedules of activities, prohibi-
tions of activities, and other manage-
ment practices to control plant site
runoff, spillage or leaks, sludge or
waste disposal, and drainage from raw
material storage. They may be im-
posed in addition to or In the absence
of effluent limitations, standards, or
prohibitions.
(b) "Manufacture" means to produce
as an intermediate or final product, or
byproduct.
g 125.62 Applicability of Best Management
Practices.
Dischargers who use, manufacture,
store, handle or discharge any pollut-
ant listed as toxic under section
307(a)(l) of the Act or any pollutant
listed as hazardous under section 311
of the Act are subject to the require-
ments of this subpart for all activities
which may result In significant
amounts of those pollutants reaching
waters of the United States. These an-
cillary activities include but are not
limited to: Manufacturing operations;
materials storage; materials handling,
housekeeping, or waste treatment and
' disposal; and preventive maintenance.
§ 125.63 Permit terms and conditions.
(a) Best management practices shall
be expressly Incorporated into a
permit where required by an applica-
ble EPA promulgated effluent limita-
tions guideline under section 304(e);
(b) Best management practices may
be expressly incorporated into a
permit on a case-by-case basis where
determined necessary to carry out the
provisions of the Act under section
402(a)(l). In issuing a permit, consid-
eration shall be given to the following
factors:
(1) Toxlcity of the pollutant(s);
(2) Quantity of the poUutant(s)
used, produced or discharged; •
(3) History of NPDES violations;
(4) History of significant leaks or
spills of toxic or hazardous pollutants;
(5) Potential for adverse impact on
public health (i.e., proximity to a
public water supply) or the environ-
ment (i.e., proximity to a sport or com-
mercial fishery); and
(6) Any other factors determined to
be relevant to the control of toxic or
hazardous pollutants.
Best management practices may be es-
tablished in permits under paragraph
(b) alone or in combination with those
required under paragraph (a) of this
section.
(c) In addition to the requirements
of paragraphs (a) and (b) of this sec-
tion, dischargers covered under
§ 125.62 shall develop and implement a
best management practices plan (BMP
plan) in accordance with § 125.64
which prevents or minimizes the po-
tential for the release of toxic or haz-
ardous pollutants from ancillary activ-
ities to waters of the United States. A
BMP plan does not have to be pre-
pared if the discharger can demon-
strate that the discharges Involved are
adequately controlled by applicable
standards and limitations in the
permit.
§ 125.64 Best management practices plans.
(a) BMP plans shall be prepared in
accordance with good engineering
practices and with the provisions of
this subpart. No BMP plan shall be ef-
fective to satisfy the requirements of
this subpart unless it has been re-
viewed and certified by a registered
professional engineer. In this certifica-
tion, the engineer shall attest to the
fact that:
(1) He/she has examined the facili-
ty;
(2) He/she is familiar with the provi-
sions of this subpart; and
(3) The BMP plan has incorporated,
in accordance with good engineering
practices, procedures which will pre-
vent or minimize the potential for the
release of toxic or hazardous pollut-
ants from ancillary activities to waters
of the United States.
This certification shall in no way re-
lieve the owner or operator of the per-
mitted facility of the duty to prepare
and Implement the BMP plan in ac-
cordance with the provisions of this
subpart.
(b) The BMP plan shall: (1) Be in
narrative form, but shall include any
necessary plot plans, drawings or
maps;
(2) Establish specific objectives for
the control of toxic and hazardous pol-
lutants;
(1) Each facility component or sys-
tems shall be examined for its poten-
tial for causing a release of significant
amounts of toxic or hazardous pollut-
ants to waters of the United States
due to equipment failure. Improper op-
eration, natural phenomena such as
rain or snowfall, et cetera.
(ii) Where experience indicates a
reasonable potential for equipment
failure (such as a tank overflow, rup-
ture or leakage) or natural conditions
(such as a rainfall event) to result in
significant amounts of toxic or hazard-
ous pollutants reaching surface
waters, the plan should Include a
predication of the direction, rate of
flow and total quantity of toxic or haz-
ardous pollutants which could be dis-
charged from the facility as a result of
each major type of failure or condi-
tion.
(3) .Establish specific best manage-
ment practices to meet the objectives
identified under paragraph (b)(2) of
this section, addressing each compo-
nent or system capable of causing a re-
lease of significant amounts of toxic or
hazardous pollutants to the waters of
the United States.
(4) At a minimum, the BMP plan
shall: (1) Reflect requirements for spill
prevention control and countermeas-
ure (SPCC) plans under section 311 of
the Act and 40 CFR Part 151, and
shall incorporate any such plans into
the BMP plan by reference;
(11) Assure the proper management
of solid and hazardous waste in ac-
cordance with regulations promulgat-
ed under the Solid Waste Disposal
Act, as amended by the Resource Con-
servation and Recovery Act of 1976 (40
U.S.C. 6901 et 3eq.) Management prac-
tices required under these regulations
shall be expressly incorporated into
the BMP plan; and
(ill) address the following points:
(A) Liquid and raw material storage
areas.
(B) Plantsite runoff.
(C) Truck and rallcar loading and
unloading areas.
(D) Inplant transfer, process and
materials handling areas.
(E) Preventive maintenance and
housekeeping.
(F) Release of rainwater from diked
or other drainage areas.
(O) management of solid and haz-
ardous waste.
(H) Materials handling.
(I) BMP-related employee training.
(c) The BMP plan shall be Incorpo-
rated by reference into the permit. It
shall be prepared within 6 months of
the modification or issuance of the
NPDES permit for the facility, and
shall be fully Implemented as soon as
possible, but not later than 1 year
FEDERAL REGISTER. VOL 43, NO. 171—FRIDAY, SEPTEMBER 1, 1978
• III-3
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39284
PROPOSED RULES
after the date of modification or issu-
ance unless the Enforcement Division
Director or, where appropriate, the Di-
rector specifies a later date in the
permit. A later date may be specified
in the permit in order to enable co-
ordinated preparation of the BMP
plan required under these regulations
and the SPCC plan required under
section 311.
(d) The discharger shall maintain a
complete copy of the BMP plan at the
facility and shall make the plan avail-
able to the Enforcement Division Di-
rector or the Director upon demand.
(e) Owner or operators of faculties
subject to this subpart shall amend
the BMP plan for the facility in ac-
cordance with the provisions of this
subpart whenever there is a change in
facility design, construction, operation
or maintenance which materially
affect the faculty's potential for dis-
charge of significant amounts of haz-
ardous or toxic pollutants into the
waters of the United States. No
amendment to a BMP plan shall satis-
fy the requirements of this paragraph
unless it is certified by a registered
professional engineer in accordance
with paragraph (a) of this section.
(f) Any release of toxic or hazardous
pollutants from ancillary industrial ac-
tivities to waters of the United States
not in accordance with an applicable
BMP plan shall be a violation of the
permit. If the BMP plan proves to be
Ineffective in achieving the general ob-
jectives of preventing the release of
toxic or hazardous pollutants to those
waters and the specific objectives and
requirements under paragraph (b) of
this section, the permit and/or the
BMP plan shall be subject to modifica-
tion to incorporate revised BMP re-
quirements.
[FR Doc. 78-24661 Filed 8-31-78; 8:45 am]
FEDERAL REGISTER, VOL. 43, NO. 171—FRIDAY, SEPTEMBER 1, 1978
III-4
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Thursday
June 7, 1979
Part II
Environmental
Protection Agency
National Pollutant Discharge Elimination
System; Revision of Regulations
III-5
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32896 Federal Register / Vol. 44, No. Ill / Thursday. June 7, 1979 / Rules and Regulations
Subpart K—Criteria and Standards for
Imposing Best Management Practice
Under Section 304(e) of the Act
Proposed Subpart L (now Subpart K)
was reserved for the criteria and
standards for imposing best
management practices under section
?04(e) of the Act. On September 1.1978,
'•',PA published proposed regulations
establishing these criteria and standards
(43 FR 39282). Section 304(e) of the Act
authorizes the Administrator to publish
regulations to control plant site runoff,
spillage or leaks, sludge or waste
disposal, and drainage from raw .
material storage which may contribute
significant amounts of toxic and
hazardous pollutants to navigable
waters. The purpose of Subpart K is to
prevent discharges of toxic and
hazr-dous substances from facilities
which are subject to the NPDES. In
NRDC v. Costle (Runoff Point Sources)
the court recognized EPA's authority
under section 402(a)(l) of the Act to
include BMPs in permits where numeric
effluent limitations are infeasible or
where reasonably necessary to achieve
effluent limitations and standards (see
|122.15(g) (2) and (3) and preamble
discussion to §122.15(g)). Subpart K,
however, addresses EPA's authority to
require BMPs under section 304(e) of the
Act.
On September 1,1978, EPA also
proposed Spill Prevention Control and
Countermeasure (SPCC) regulations
under the authority of section
311(j)(l)(C) of the Act. Section
311(j)(l)(C) authorizes the issuance of
regulations establishing procedures,
methods and equipment to prevent
discharges of oil and hazardous
-substances from vessels and from on-
shore and off-shore facilities and to
contain such discharges. The purpose of
proposed 40 CFR Part 151 was to
prevent discharges of hazardous
substances from facilities subject to
section 402 permitting requirements.
The approach used in both proposed
regulations was similar to the one
developed and used in EPA's oil
pollution prevention regulation, 40 CFR
Part 112. This was the concept of a plan
developed by the owner or operator of a
facility or by his/her engineer, in
accordance with guidelines contained in
the respective regulations. The proposal
required that the plans be certified by a
registered professional engineer and
subsequently implemented by the owner
or operator.
The requirements of the two proposed
regulations (40 CFR Parts 125 and 151)
were coordinated and the proposals
stated that compliance by a facility with
the provisions of the SPCC plan
requirements set put in 40 CFR Part 151
would be established as a minimum
level of control for the BMP plan
required by 40 CFR Part 125. The
purpose of publishing the two
regulations concurrently was to allow
the owner or operator of a permitted
facility to develop BMP and SPCC plans
concurrently and thereby avoid
duplication of environmental controls.
The proposal stated that SPCC plans
could be incorporated into BMP Plans
by reference.
A thirty-day comment period was
provided which was extended twenty
days (43 FR 47213. October 31,1978).
The Agency received 75 comments and
EPA's response to the significant
comments is described below.
Several comments were received
suggesting that BMP Plans and SPCC
Plans are duplicative and should be
developed together. Other comments
requested a clarification of the
relationship between the two. Finally,
some comments argued that since BMPs
and SPCC Plans are authorized by
different sections of the Act, they are
therefore designed for different purposes
and should not be linked. In response to
the first comment, EPA wishes to point
out that BMP Programs and SPCC Plans
are being developed together. This first
step in this development is Subpart K,
i.e., BMPs which involve minor new
construction or modifications to existing
facilities. The second step will be SPCC
Plans (and perhaps another BMP
regulation) which will emphasize
secondary containment to control spills
and may require major construction for
drainage control, sewering and diking.
EPA believes that a requirement for
BMP programs is a necessary step at
this time, for a number of reasons. Many
industrial permits were issued during
1974 and 1975 and will be due for
renewal before the SPCC requirements
under section 311 become effective.
Since the timing for preparation of SPCC
plans by NPDES-permitted facilities will
be tied to permit reissuance, many
facilities would be subject to no spill
prevention controls at all until 1984 or
1985. The development of a BMP
program by such facilities will focus
attention on the potential for spills and
other unplanned discharges and help to
prevent such occurrences until the time
SPCC requirements become effective.
BMP programs will be compatible with
later requirements for SPCC plans, and
steps taken in implementing a BMP
program will satisfy some of the SPCC
requirements. Additionally, EPA
believes that prevention of unplanned
releases of toxic materials requires
actions by facilities not yet subject to
SPCC requirements, and that the BMP
program is an effective and relatively
inexpensive way to achieve such
prevention.
EPA also agrees with some
commenters that, while both BMPs and
SPCC Plans have many common
features, their emphasis is different.
Facilities subject to the NPDES Program
normally have continuous discharges of
wastewater and the capability to treat
that wastewater. SPCC Plans, on the
other hand, focus on classic spill events
and may require containment. Thus,
there is some overlap between BMPs
and SPCC Plans (BMPs are normally a
subpart of SPCC Plans) and therefore a
need exists for a regulatory link. It
should be noted that BMPs are broader
than SPCC Plans in one sense because
BMPs control both section 307 and 311
pollutants whereas SPCC Plans control
only section 311 pollutants.
Many commenters argued that the
economic impact of the proposed
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Federal Register / Vol. 44, No. Ill / Thursday. June 7. 1979 / Rules and Regulations 32897
regulations would be excessive and that
the benefits to the environment would
not justify the expense of employing the
BMPs contemplated by the regulation.
Although EPA explicitly requested
information in the preamble to the
proposed regulation (43 FR 39282)
concerning the costs of BMPs and
preparation of BMP plans for particular
industries, few commenters directly
addressed costs. It appears that the
major categories of expense in the
proposal were for SPCC related
requirements. Because of this economic
impact, EPA has revised today's
regulations to make inclusion of SPCC
plans in BMP programs discretionary
rather than mandatory as was proposed.
(See § 125.104(b)(4)(i).) Thus, Subpart K
emphasizes BMPs of a procedural nature
(especially preventive maintenance and
housekeeping) and BMPs requiring only
minor construction.
Based on a recent EPA survey of
representative plants in the chemical
industry, it appears that many of these
type of BMPs are currently in use by
facilities. Good housekeeping or
preventive maintenance procedures.
material recovery programs, safety
procedures, training programs, etc. are
common and thus the costs of complying
with Subpart K will not be great.
Facilities are encouraged, nevertheless,
to begin planning for BMP-related major
construction (drainage control, waste
stream segregation, and secondary
containment) to coincide with
construction related to the installation
of best available technology (BAT) and
of the implementation of (SPCC) plans.
BMP regulations requiring major
construction taay be published in the
future.
Under authority of section 402(a)(l) of
the Act, permitting authorities may
impose BMPs on a case-by-case basis
using best engineering judgment. These
case-specific BMPs may be more costly
than those contemplated by Subpart K
which requires only procedural BMPs or
minor construction. Guidance to
permitting authorities will emphasize
procedural BMPs and will encourage
equivalency for potentially costly BMPs,
such as secondary containment. Where
permitting authorities have knowledge
of a specific facility or receive
information through the permit
application indicating the opportunity
for discharges of toxic or hazardous
pollutants which could be prevented by
a BMP, the permitting authority-may
impose a BMP based on best
engineering judgment. Such BMPs,
which may involve construction, are
expected to be limited to facilities with
spill histories or other indications of an
Inadequate program to control
discharges from ancillary industrial
activities. v
Several commenters argued that
dictating manufacturing process changes
or operational procedures and activities
went beyond the intent of Congress.
EPA does not intend to use BMPs to
dictate how plants are operated or to
otherwise infringe, on plant
management's prerogatives. However,
section 304(e) does give EPA the
authority to prescribe certain "in-plant"
procedures or practices which would be
useful to prevent the discharge of toxic
or hazardous pollutants where
traditional effluent limitations
guidelines are impractical or ineffective.
To further explain EPA's intent,
changes have been made to proposed
§ 125.62 and § 125.64(b)(4)(iii), now
§ 125.102 and § 125.104(iii), to clearly
distinguish between ancillary
manufacturing operations (sources of
pollutants] and BMPs (methods to
prevent or minimize pollution). For
example, preventive maintenance and
housekeeping are BMPs, not ancillary
operations. Material storage and
loading/unloading operations are
ancillary manufacturing operations, not
BMPs.
To allow due process and public
notice of BMP programs, permittees are
now required to submit a description of
their program with their NPDES permit
application, (§ 125.104(c)). Some
commenters thought one year for the
implementation of BMP plans, proposed
§ 125.64(c), was too short. EPA feels that
the one year after permit issuance is
realistic and reasonable, particularly for
the BMPs of a procedural nature or
minor construction required by this
Subpart. However, a discharger could be
. given more than one year under special
circumstances such as coordinating a
BMP plan with an SPCC plan required
under 40 CFR Part 151.
Many commenters suggested that the
term "significant amount" should be
defined or that a minimum amount of a
particular chemical should be specified
to require the preparation of a BMP
plan. EPA has not defined this term but
wishes to clarify its meaning. In the case
of section 311 pollutants EPA has
proposed reportable quantities of
hazardous substances (44 FR 10271, Feb
16,1979) and considers these quantities
potentially significant for the purpose of
this Subpart. For section 307 pollutants,
the fact that a chemical is on the section
307 toxic pollutant list indicates
potentially toxic effects of its discharge.
As guidance to facilities developing
BMP programs, two examples are given
. to demonstrate the definition of
"significant amount" in terms of the
BMPs applicable to a particular
chemical:
1. A facility uses laboratory quantities of
toxic chemical X in an analytical chemistry
laboratory adjacent to its manufacturing
facility. Chemical X is used for no other
purpose at the facility. No more than five
pounds of the chemical are on hand at any
given time. An appropriate BMP could be to
label all containers of chemical X with
instructions such as "Do not dispose of this
material in laboratory sinks. Refer to
Laboratory Procedures Manual for Disposal
Instructions." The Laboratory Procedures
Manual might further provide thai chemical X
and other compatible chemicals be disposed
of in an appropriately labelled 55 gallon drum
to be periodically picked up and treated by a
responsible hazardous waste contractor in
accordance with RCRA regulations.
2. A facility uses thousands of gallons daily
of a hazardous chemical Y (a section 311
Category "A" pollutant) as a raw material in
a batch chemical manufacturing process and
is located next to a small stream. Chemical Y
is stored outside in a single 10,000 gallon tank
and is periodically pumped to the reactor
vessel. An appropriate BMP would be to
provide secondary containment around the
storage tank in the form of a dike to contain
the maximum volume of chemical Y stored in
the tank plus a reasonable allowance for
rainfall. In the alternate, a facility might
choose to use a combination of measures
instead of secondary containment to attempt
to achieve equivalency to secondary
containment. For example, a liquid level
alarm, frequent non-destructive testing and
daily visual inspections might be employed
rather than constructing a dike around the
storage tank. However, this latter approach
may not satisfy proposed SPCC requirements
which require the former approach, i.e.,
secondary containment wherever reasonable
probability of a discharge to navigable
waters exists. Thus, provision of secondary
containment would satisfy both BMP and
proposed SPCC requirements simultaneously.
Numerous commenters stated that the
proposed regulations went beyond the
intent of Congress because the
development of BMPs is discretionary
and can ony be on the basis of point
source categories supplemental to
effluent guidelines. EPA disagrees and
believes that BMP programs and case-
by-case determination of BMPs are
appropriate based on the legislative
history to section 304(e) (see CWA
Legis. Hist, at 453 which specifically
discusses case-by-case determinations
of BMPs). BMPs supplemental to effluent
limitations guidelines have not yet been
promulgated by EPA. However, the
potential for confusion and duplication
of effort by the permittee between BMPs
and SPCC plans has led us to delete the
requirement for a BMP plan in favor of a
BMP program. The BMP program
approach provides a self-regulatory,
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32S98 Federal Register / Vol. 44. No. Ill / Thursday, June 7, 1979 / Rules and Regulations
flexible mechanism to control toxic and
hazardous pollutant discharges from
ancillary sources and will allow
permittees to develop BMPs tailored to
their particular circumstances with
attendant cost savings.
Many comments were received
concerning the relationship of BMPs to
the requirements of the Resource
Conservation and Recovery Act
(RCRA), arguing that RCRA
requirements should not be imposed by
the Clean Water Act. EPA disagrees and
wishes to point out that section 304(e)
specifically includes the phrase "sludge
or waste disposal" as one of four
general activities subject to BMPs. Thus
g 125.104(b)(4)(ii) has not been changed
and continues to' require management
practices developed by companies to
comply with RCRA to simultaneously
satisfy the BMP requirements of the
Clean Water Act by expressly
incorporating the practices into the BMP
. program.
Many commenters felt that the
requirement for a professional engineer
(PE) to certify the BMP plan was
unnecessary and should be eliminated
or made optional Since Subp&rt K no
longer requires BMP plans, PE
certification is no longer required.
However, EPA continues to believe that
PE certification would assure a
minimum level of quality in both BMPs
and SPCC plans. Since today's
requlations are the first step in a two
step process, and the second step (SPCC
regulations 40 CFR Part 151) may require
PE certification of SPCC plans, EPA
encourages facilities to develop their
programs in accordance with sound
engineering practices. These facilities
would then have BMP-related
procedures and construction which
could satisfy, in part, future SPCC
requirements.
Economic Impact ofSubpart K
Since Subpart K now requires only
BVPs of a procedural nature or th .;se
rp' airing minor construction, the costs
o! jompliance with these regulations
should be minimal. Permittees are
encouraged to use innovative,
inexpensive techniques to achieve the
basic goal of preventing the discharge of
toxic or hazardous pollutants from
ancillary industrial activities to surface
waters. Because BMP requirements will
vary among facilities, guidance will be
provided to the permit writers on what
requirements are sufficient. This
guidai i will reflect the conclusion of e
BMP cost analysis which is being
undertaken by the Agency. The
guidance will consider reasonableness
of cost. Most facilities have many of
these generic BMPs in place and Subpart
K only requires documentation of the
existing practices or, hi some cases,
upgrading and documentation of the
BMP program. Although BMPs requiring
major construction (e.g., grading, paving,
sewering, waste stream segregation,
covering, and secondary containment)
may be included in the BMP program
description, the implementation of these
BMPs is not mandated by these
regulations. Therefore, EPA has
determined that Subpart K does not
constitute a major regulation requiring
the preparation of an economic impact
statement under Excecutive Order
12044.
Because there is much flexibility in
how the individual facility complies
with BMP procedural requirements,
there is also flexibility in compliance
costs. The cost of developing and
implementing BMP procedures is .
estimated to be within the range of
$10,000 to $30,000 per facility for the
costs of a materials inventory, some
engineering modifications, training,
maintenance, housekeeping, and some
minor construction for items such as the
installation of liquid level.alarms. To
develop these costs the assumption was
made that 50% of the BMP procedural
requirements would already be in place
in order to meet normal safety, fire, and
other occupational or operational
standards. Clearly, a facility with minor
problems will require a less elaborate
program.
Because the requirements may be less
flexible under the SPCC program for
which these BMP requirements are the
first stage and we have so little cost
data now on the BMP procedures
because of their flexibility, further cost
estimates for BMPs will be acquired
when we prepare a detailed analysis of
the SPCC cost requirements. These
estimates will be necessary for the
Agency to adequately assess the cost
and usefulness of specific aspects of the
SPCC program.
Based on existing predictions of
NPDES permit issuance, industrial
facilities will be required to develop and
implement BMP programs on the
following schedule:
Number of Permits
FY1979 _ ....2.600
FY1980 3,000
FY 1981....... 1,700
FY1982 1.000
Using an average cost of $20,000 per
facility, the total costs of BMPs, thru FY
1982 are expected to be no greater than
the following:
FY 1979 $52,000,000
FY 1980 — $60.000.000 .
FY 1981 „ $34,000,000
FY i9a2 „ $20,000,000
This does not include the cost of
BMPs established under authority of
section 402(a)(l) using best engineering
judgment.
The Agency may propose a new form
of BMP guidelines in the future which
will describe BMPs which are broadly
applicable to industrial facilities and
relatively independent of the chemical
under consideration. In addition, these
BMP guidelines would address more
specific or advanced BMPs for certain
chemicals or ancillary industrial
activities and would include an
economic impact analysis. Major
construction would probably be
required to comply with these future
BMPs and likely will be required to
comply with the SPCC regulations.
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Federal Register / Vol. 44. No. Ill / Thursday. June 7, 1979 / Rules and Regulations 32954-32955
Subpart K—Criteria and Standards for
Best Management Practices
Authorized Under Section 304(e) of the
Act
§ 125.100 Purpose and scope.
This Subpart describes how best
management practices (BMPs) for
ancillary industrial activities under
section 304(e] of the Act shall be
reflected in permits, including best
management practices promulgated in
effluent limitations under section 304
and established on a case-by-case basis
in permits under section 402(a)(l) of the
Act. Best management practices
authorized by section 304(e) are
included in permits as requirements for
the purposes of sections 301,302, 306,
307, or 403 of the Act as the case may
be.
§125.101 Definition.
"Manufacture" means to produce as
an intermediate or final product, or by-
product.
S 125.102 Applicability of best
management practices.
Dischargers who use, manufacture,
store, handle or discharge any pollutant
listed as toxic under section 307(a)(l) of
the Act or any pollutant listed as
hazardous under section 311 of the Act
are subject to the requirements of this
Subpart for all activities which may
result in significant amounts of those
pollutants reaching waters of the United
States. These activities are ancillary
manufacturing operations including:
materials storage areas; in-plant
transfer, process and material handling
areas; loading and unloading operations;
plant site runoff; and sludge and waste
disposal areas.
§125.103 Permit terms and conditions.
(a) Best management practices shall
be expressly incorporated into a permit
where required by an applicable EPA
promulgated effluent limitations
guideline under section 304(e);
(b) Best management practices may be
expressly incorporated into a permit on
a case-by-case basis where determined
necessary to carry out the provisions of
the Act under section 402(a)(l). In
issuing a permit containing BMP
requirements, the Director shall consider
the following factors:
(1) Toxicity of the pollutant(s);
(2) Quantity of the pollutant(s) used,
produced, or discharged;
(3) History of NPDES permit
violations;
(4) History of significant leaks or
spills of toxic or hazardous pollutants;
(5) Potential for adverse impact on
public health (e.g., proximity to a public
water supply) or the environment (e.g.,
proximity to a sport or commerical
fishery); and
(6) Any other factors determined to be
relevant to the control of toxic or
hazardous pollutants.
(c) Best management practices may be
established in permits under paragraph
(b) of this section alone or in
combination with those required under
paragraph (a) of this section.
(d) In addition to the requirements of
paragraphs (a) and (b) of this section,
dischargers covered under § 125.102
shall develop and implement a best
management practices program in
accordance with § 125.104 which
prevents, or minimizes the potential for,
the release of toxic or hazardous
pollutants from ancillary activities to
waters of the United States.
§ 125.104 Best management practices
programs.
(a) BMP programs shall be developed
in accordance with good engineering
practices and with the provisions of this
Subpart.
(b) The BMP program shall:
(1) Be documented in narrative form,
and shall include any necessary plot
plans, drawings or maps;
(2) Establish specific objectives for the
control of toxic and hazardous
pollutants.
(i) Each facility component or system
shall be examined for its potential for
causing a release of significant amounts •
of toxic or hazardous pollutants to
waters of the United States due to
equipment failure, improper operation,
natural phenomena such as rain or
snowfall, etc.
(ii) Where experience indicates a
reasonable potential for equipment
failure (e.g., a tank overflow or leakage),
natural condition (e.g., precipitation), or
other circumstances to result in
significant amounts of toxic or
hazardous pollutants reaching surface
waters, the program should include a
prediction of the direction, rate of flow
and total quantity of toxic or hazardous
pollutants which could be discharged
from the facility as a result of each
condition or circumstance;
III-9
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Federal Register / Vol. 44. No. Ill / Thursday. June 7. 1979 / Rules and Regulations 32955
(3) Establish specific best
management practices to meet the
objectives identified under paragraph
[b)(2] of this section, addressing each
component or system capable of causing
a release of significant amounts of toxic
or hazardous pollutants to the waters of
the United States;
(4) The BMP program:
(i) May reflect requirements for Spill
. Prevention Control and Countermeasure
(SPCC) plans under section 311 of the
Act and 40 CFR Part 151, and may
incorporate any part of such plans into
the BMP program by reference;
[Comment: EPA has proposed section
311(j)(l)(c) regulations (43 FR 39276) which
require facilities subject to NPDES to develop
and implement SPCC plans to prevent
discharges of reportable quantities of
designated hazardous substances. While
Subpart K requires only procedural activities
and minor construction, the proposed 40 CFR
151 (SPCC regulations) are more stringent
and comprehensive with respect to their
requirements for spill prevention. In
developing BMP programs in accordance with
Subpart K, owners or operators should also
consider the requirements of proposed 40
CFR 151 which may address many of the
same areas of the facility covered by this
Subpart.]
(ii) Shall assure the proper
management of solid and hazardous
waste in accordance with regulations
promulgated under the Solid Waste
Disposal Act, as amended by the
Resource Conservation and Recovery
Act of 1976 (RCRA) (40 U.S.C. 6901 et
seqj. Management practices required
under RCRA regulations shall be
expressly incorporated into the BMP
program; and
(iii) Shall address the following points
for the ancillary activities in § 125.102:
(A) Statement of Policy;
(B) Spill Control Committee;
(C) Material Inventory;
(D) Material Compatibility;
(E) Employee Training:
(F) Reporting and Notification
Procedures;
(G) Visual Inspections;
(H) Preventive Maintenance;
(I) Housekeeping; and
(J) Security.
[Comment: Additional technical information
on BMPs and the elements of a BMP program
is contained in a publication entitled "NPDES
Best Management Practices Guidance
Document." Copies may be obtained'by
written request to Edward A. Kramer (EN-
33G), Office of Water Enforcement.
Environmental Protection Agency,
Washington, D.C. 20460.)
(c)(l) The BMP program must be
clearly described and submitted as part
of the permit application. An application
which does not contain a BMP program
shall be considered incomplete. Upon
receipt of the application, the Director
shall approve or modify the program in
accordance with the requirements of
this Subpart. The BMP program as
approved or modified shall be included
in the draft permit (§ 124.31). The BMP
program shall be subject to the
applicable permit issuance requirements
of Part 124, resulting in the incorporation
of the program (including any
modifications of the program resulting
from the permit issuance procedures)
into the final permit.
(2) Proposed modifications to the BMP
program which affect the discharger's
permit obligations shall be submitted to
the Director for approval. If the Director
approves the proposed BMP program
modification, the permit shall be
modified in accordance with § 122.31,
provided that the Director may waive
the requirements for public notice and
opportunity for hearing on such
modification if he or she determines that
the modification is not significant. The
BMP program, or modification thereof,
shall be fully implemented as soon as
possible but not later than one year after
permit issuance, modification, or
revocation and reissuance unless the
Director specifies a later .date in the
permit,
[Comment: A later date may be specified in
the permit, for example, to enable
coordinated preparation of the BMP program
required under these regulations and the
SPCC plan required under 40 CFR 151 or to
allow for the completion of construction
projects related to the facility's BMP or SPCC
program.)
(d) The discharger shall maintain a
description of the BMP program at the
facility and shall make the description
available to the Director upon request.
(e) The owner or operator of a facility
subject to this Subpart shall amend the
BMP program in accordance with the
provisions of this Subpart whenever
there is a change in facility design,
construction, operation, or maintenance
which materially affects the facility's
potential for discharge of significant
amounts of hazardous or toxic
pollutants into the waters of the United
States.
(f) If the BMP program proves to be
ineffective in achieving the general
objective of preventing the release of
significant amounts of toxic or
hazardous pollutants to those waters
and the specific objectives and
requirements under paragraph (b) of this
section, the permit and/or the BMP
program shall be subject to modification
to incorporate revised BMP
requirements.
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Reproposed Rule
Highlights
Certification Statement submitted with the
NPDES permit application
BMP Plan developed within 6 months of the
application
• BMP Plan implemented within 18 months of the
application
BMP Plan kept on site and made available to
compliance inspectors or Director upon request
• BMP Plan reviewed at least every three years
by permittee and amended as necessary
BMP Plan becomes part of permit terms once
permit is issued.
NOTE: These highlights are being considered by
the Agency and are subject to change before
the reproposed rule is published in the
Federal Register.
III-ll
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IV. NPDES
Best Management Practices
Guidance Document
-------
NPDES
Best Management Practices
GUIDANCE DOCUMENT
Environmental Protection Agency
Office of Enforcement
Office of Water Enforcement
Permits Division
August 1980
-------
Disclaimer
The information contained herein is based on work performed by
Hydroscience, Inc. under contract to the U.S. Environmental Protection Agency
(Contract No. 68-03-2568). The document is guidance to NPDES permitting
authorities and does not necessarily reflect official EPA policy. Mention of
trade names, techniques or procedures does not constitute endorsement by EPA.
-------
Preface
During the period June 13, 1978, to February 26, 1979, Hydroscience,
Inc., under Contract No. 68-03-2568 to the Environmental Protection Agency
(EPA), gathered information leading to the identification of best management
practices (BMPs) currently used by industry. The result of the data gathering
and analysis by Hydroscience, Inc. was a draft report entitled "NPDES Best
Management Practices Guidance Document" EPA 600/9-79-045. In response to
keen public interest in the draft report, EPA made the report available to
the public and provided a 45-day comment period, which subsequently was
extended twice, resulting in a 120-day comment period on the report. After
evaluating the comments received, EPA revised the draft report, and published
this final document. This final document supersedes the draft report.
In the interest of clarity and brevity, the Hydroscience, Inc. draft
report shall be hereinafter referred to as either the "draft report" or
"report". The EPA revised document (this document), which has the same
title as the draft report, shall be hereinafter referred to as either the
"final document" or "document".
IV-i
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Abstract
I
The purpose of this document is to assist National Pollutant Discharge
Elimination System (NPDES) permitting authorities, compliance officers and
permit applicants in developing Best Management Practices (BMP) plans for
industry. BMPs are authorized under the 1977 Clean Water Act for the control
of discharges to receiving waters of significant amounts of any pollutant
listed as hazardous under Section 311 of the Act or toxic under Section 307
of the Act from activities which are associated with or ancillary to industrial
manufacturing or treatment processes. The types of discharges to be controlled
by BMPs are plant site runoff, spillage and leaks, sludge and waste disposal,
and drainage from raw material storage areas.
This document provides a basis for developing BMP plans. The use of the
document requires engineering experience with industrial manufacturing and
treatment processes and knowledge of current laws and regulations applicable
to NPDES permits, BMP plans, and Spill, Prevention, Control and Countermeasure
(SPCC) plans.
The guidance in this document is based on a review by Hydroscience, Inc.
of current practices used by industry to control the non-routine discharge of
toxic pollutants and hazardous substances. Included in the review are published
articles and reports, technical bulletins on specific compounds, and discussions
with industry through telephone contacts, written questionnaires, and site
visits.
IV-ii
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Contents
Page No.
Preface iv-i
Abstract * iv-ii
1. Introduction IV-1
Background iv-1
Statutory Authority IV-2
BMP Regulatory History IV-2
Final BMP Regulation IV-3
Final Document IV-4
2. Use IV-5
3. BMP Plan IV~7
Scope IV-7
Minimum Requirements Iv~8
General Requirements IV-10
Specific Requirements IV-10
Appendices
Appendix A. References IV-29
Appendix B. Example Summary IV-31
IV-iii
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SECTION 1
INTRODUCTION
Background
The Federal Water Pollution Control Act Amendments of 1972 established
the objective of restoring and maintaining the chemical, physical, and
biological integrity of the Nation's waters. This objective has remained
unchanged in the 1977 amendments to the Act, commonly referred to as the
Clean Water Act of 1977, hereinafter "the Act". To achieve this end, the
Act sets forth a series of goals, including the goal of eliminating the
discharge of pollutants into navigable waters by 1985. The principal
mechanism for reducing the discharge of pollutants from point sources is
through implementation of the National Pollutant Discharge Elimination
System (NPDES) established by section 402 of the Act.
At the time of first round NPDES permit issuance, conventional pollutants
(BOD, pH, fecal coliforms, etc.) were considered the parameters which most
urgently needed controls. In second round permitting, however, Agency
emphasis is shifting from the conventional pollutants to the control of
toxic and hazardous pollutants.
Traditionally, NPDES permits have contained chemical-specific numerical
effluent limits. Effluent guidelines are not always available to prescribe
these effluent limits nor to guarantee water quality sufficient for the
protection of indigenous aquatic life. To improve water quality, the Act
provides for water pollution controls supplemental to effluent limitations
guidelines. Best Management Practices (BMPs) are one such supplemental
control. Pursuant to sections 304 and 402 of the Act, BMPs may be incor-
porated as permit conditions. BMPs in the context of the NPDES program are
IV-1
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actions or procedures to prevent or minimize the potential for the release
of toxic or hazardous pollutants in significant amounts to surface waters.
BMPs, although normally qualitative, are expected to be most effective when
used in conjunction with numerical effluent limits in NPDES permits.
Statutory Authority
Section 304(e) of the Act authorizes the Administrator to publish
regulations to control discharges of significant amounts of toxic pollutants
under Section 307 or hazardous substances under Section 311 from activities
which the Administrator determines are associated with or ancillary to
industrial manufacturing or treatment processes. The discharges to be
controlled by BMPs are plant site runoff, spillage or leaks, sludge or waste
disposal and drainage from raw material storage.
Section 402(a)(1) of the Act allows the Administrator to prescribe
conditions in a permit determined necesssary to carry out the provisions of
the Act. BMPs are one such condition.
BMPs are intended to complement other regulatory requirements imposed
by RCRA, OSHA, the Clean Air Act, and SPCC plans for hazardous substances
under the Clean Water Act. Pursuant to Section 311 of the Act, the EPA has
proposed (40 CFR Part 151) requirements for SPCC plans to prevent discharges
of hazardous substances from facilities subject to NPDES permitting require-
ments. The guidelines proposed for hazardous substances SPCC plans are very
similar to those required for oil SPCC plans in the Oil Pollution Prevention
Regulations, 40 CFR, Part 112. Since the Agency has received many favorable
comments about the Oil Pollution Prevention Regulations, the NPDES BMP
regulation has been structured to be similar to the oil SPCC regulations.
BMP Regulatory History
On September 1, 1978, EPA proposed regulations (43 FR 39282) addressing
t^e use of procedures to control discharges from activities associated with
or ancillary to industrial manufacturing or treatment processes. The
proposed rule indicated how best management practices would be imposed in
IV-2
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NPDES permits to prevent the release of toxic and hazardous pollutants to
surface waters. The proposed regulation was incorporated as "40 CFR Part
125, Subpart L - Criteria and Standards for Best Management Practices
Authorized Under Section 304(e) of the Act" in the August 21, 1978 proposed
NPDES regulations (43 FR 37078). A 60-day comment period on proposed
Subpart L was provided.
After evaluating the comments received on the proposed regulation, EPA
revised Subpart L and promulgated the regulation as Subpart K (44 FR 32954-5)
on June 7, 1979. Industries regulated by Subpart K were to develop a BMP
program and submit the program with their permit application. Subpart K
stated that information on the development of BMP programs was contained in
a publication entitled "NPDES Best Management Practices Guidance Document."
Subpart K was to become effective on August 13, 1979. However, publication
of the report was unavoidably delayed beyond August 13, 1979. Therefore,
on August 10, 1979, EPA deferred applicablity of the BMP portions of the
NPDES regulations until 60 days after publication in the Federal Register of
a notice of availablity of the final document (44 FR 47063). EPA announced
on March 20, 1980 the availability of the draft report and provided a 45-day
comment period (45 FR 17997), which subsequently was extended twice, resulting
in a 120-day comment period on the report.
Based on public comments on the draft report and further discussion
with industry, the Agency reproposed Subpart K on , and provided
a 60-day comment period on the reproposed regulation. After evaluating the
comments received on both the draft report and reproposed Subpart K, EPA.
made appropriate revisions and published the final document and final BMP
regulation.
Final BMP Regulation
The final BMP regulation (revised Subpart K) describes how BMPs shall
be reflected in certain NPDES permits. An applicant for an NPDES permit
must submit as part of the application a signed statement certifying that a
BMP plan will be developed within 6 months and implemented within 18 months
IV-3
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of the date of application. The regulation describes certain general
requirements and specific requirements for BMP plans and prescribes other
conditions pertaining to the use of BMPs in the NPDES program.
Final Document
The preamble to the BMP regulation directs readers to the final "NPDES
Best Management Practices Guidance Document11 for additional technical
information on the specific requirements and elements of a BMP plan. The
final document is designed to provide guidance to the National Pollutant
Discharge Elimination System (NPDES) permitting authorities, compliance
officers, and permittees for developing BMP plans. The document addresses
the 9 specific requirements listed in Subpart K but does not address site
specific or pollutant specific BMPs since these BMPs are an optional part of
a BMP plan. Consequently, both the subsection entitled "Advanced Best
Management Practices" of Section 3 (Best Management Practices) and the
entirety of Section 4 (Classification of Toxic and Hazardous Substances) of
the draft report are not contained in the final document. Furthermore, the
draft report provides sufficient assitance for developing a BMP plan without
requiring the inclusion of an evaluation process. Therefore, Section 5
(Methods for Evaluating BMP Programs and Prescribing BMP Alternatives)
of the report is not contained in this document.
IV-4
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SECTION 2
USE
This document should be used for guidance in developing BMP plans.
However, the document's limitations with respect to site-specific conditions
should be recognized and considered. As its name suggests, the NPDES Best
Management Practices Guidance Document is to be considered by NPDES permitting
authorities, compliance officers, permit applicants and permittees as
guidance to be used in a flexible manner in the formulation of BMP plans as
required by 40 CFR Part 125, Subpart K of the NPDES regulations. Consequently,
the document identifies elements of each specific requirement that should be
considered in the development of the BMP plan, but does not require that
each element be included in every facility1s BMP plan.
In utilizing this document to develop a BMP plan, the applicant/permittee
is encouraged to use the most oost-effective and innovative techniques to
fit the particular facility or circumstances. A BMP plan may vary from site
to site and industry to industry, depending upon the site-specific situation.
In addition, an applicant/permittee may delete, modify, or add to the
elements of the specific requirements presented in the document where
equivalent results can be obtained.
If an applicant/permittee needs assistance to develop a BMP plan under
the Subpart K regulations, he/she may contact the appropriate permit issuing
authority for advice.
IV-5
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SECTION 3
BMP PLANS
Scope
The activities which are associated with or ancillary to the industrial
manufacturing or treatment process are subject to the BMP regulations. For
brevity, all such activities are referred to as "ancillary sources". The
ancillary sources at the plant should be examined to determine if there is a
reasonable potential for equipment failure (e.g., spillage or leakage),
natural conditions (e.g., plant site runoff or drainage from raw material
storage), or other circumstances (e.g., sludge or waste disposal) which
could result in the discharge of a significant amount of toxic or hazardous
pollutants to receiving waters. The ancillary sources are divided for
discussion in this document into five categories: material storage areas;
loading and unloading areas; plant site runoff; in-plant transfer, process,
and material handling areas; and sludge and hazardous waste disposal areas.
Material storage areas include storage areas for toxic and hazardous
chemicals as raw materials, intermediates, final products or by-products.
Included are: liquid storage vessels that range in size from large tanks
located at a tank farm to 55-gallon drums; dry storage in bags, piles, bins,
silos, and boxes; and gas storage in tanks and vessels.
Loading and unloading operations involve the transfer of materials to
and from trucks or railcars but not in-plant transfers. These operations
include pumping of liquids or gases from truck or railcar to a storage
facility or vice versa, pneumatic transfer of dry chemicals to or from the
loading or unloading vehicle, transfer by mechanical conveyor systems, and
transfer of bags, boxes, drums, or other containers from vehicles by fork-lift
trucks or other materials handling equipment.
IV-7
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Plant runoff is generated principally frcm rainfall on a plant site.
Runoff frcm material storage areas, in-plant transfer areas, loading and
unloading areas, and sludge disposal sites potentially could becone contam-
inated with toxic and hazardous substances. Heavy metal pollutants frcm
sludge disposal sites are of special concern. Bailout, attributable to the
plant air emissions which settle on the plant site, may also beccme a
source of contaminated runoff. Contaminated runoff may reach a receiving
body of water through overland flow, drainage ditches, storm or clean
cooling water sewers, or overflows frcm combined sewer systems.
In-plant transfer areas, process areas, and material handling areas
encompass all in-plant transfer operations frcm raw material to final
product. Various operations could include transfer of liquids or gases by
pipelines with appurtenances such as pumps, valves and fittings, movement of
bulk materials by mechanical conveyor-belt systems, and fork-lift truck
transport of bags, drums, and bins. All transfer operations within the
process area with a potential for release of toxic and hazardous substances
to other than the process waste water system are addressed in this grouping.
Sludge and hazardous-waste disposal areas are sources of potential
contamination of receiving waters. The operations include land-fills, pits,
ponds, lagoons, and deep-^well injection sites. Depending on the construction
and operation of these sites there may be a potential for leachate containing
toxic or hazardous materials to seep into the ground water, eventually
reaching surface waters, or for liquids to overflow to surface waters frcm
these disposal operations. BMP requirements are not intended to duplicate
the requirements of RCRA. Actions taken for compliance with RCRA may be
referenced in the BMP plan.
Minimum Requirements
BMPs may include some of the same practices used by industry for
pollution control, for SPCC plans for oil and hazardous materials, for
safety programs, for fire protection, for protection against loss of valuable
raw materials or products, for insurance policy requirements or for public
IV-8
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relations. The NPDES regulations provide instructions for development of
BMP plans (see 40 CFR Part 125, Subpart K, "Criteria and Standards for BMPs
Authorized Under Section 304(e) and 402(a)(1) of the Act"). The minimum
requirements of a BMP Plan are prescribed by the BMP regulation and are
listed in Table 1. They are divided into two categories: general require-
ments and specific requirements.
TABLE 1
Minimum Requirements of a BMP Plan
A. General Requirements
1. Name and location of facility
2. Statement of BMP policy and
objectives
3. Review by plant manager
B. Specific Requirements
1. BMP Committee
2. Risk Identification and
Assessment
3. Reporting of BMP Incidents
4. Materials Compatibility
5. Good Housekeeping
6. Preventive Maintenance
7. Inspections and Records
8. Security
9. Employee Training
IV-9
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General Requirements
The BMP plan shall be organized and described in an orderly narrative
document format and shall be reviewed by the plant engineering staff and
plant manager. A description of the facility, including the plant name, the
type of plant, major processes used, and the products manufactured, shall be
included in the BMP plan, and a map shall be provided showing the location
of the facility and the adjacent receiving waters. The BMP plan will
include specific objectives for the control of toxic and hazardous substances
as part of the statement of corporate policy.
Specific Requirements
Each of the 9 specific requirements listed in Table 1 must be addressed
in the BMP plan. The size and complexity of the BMP plan will vary with the
corporate environmental policy, size, complexity, and location of the
facility, among other factors. It is anticipated that the length and detail
of the BMP plan will be commensurate with the quantity of toxic and hazardous
chemicals onsite and their opportunity for discharge. Therefore, a fundamental
part of the BMP plan in determining the potential for toxic and hazardous
chemicals to reach receiving waters is "Risk Identification and Assessment".
Discussions of the specific requirements are presented on the following
pages. Each specific requirement contains important elements that should be
considered in developing a BMP plan. For convenience, the elements are
listed below each discussion of the specific requirements. It is recognized
that all elements may not be applicable to all facilities. Elements should
be added, deleted or modified to fit the needs of a particular facility.
Permittees are encouraged to use innovative techniques to achieve equivalent
results.
1. BMP Committee
The BMP Committee is that group of individuals within the plant
organization which is responsible for developing the BMP plan and assisting
the plant management in its implementation, maintenance and updating. Thus,
IV-10
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the Committee's functions are similar to those of a plant fire prevention or
safety committee.
The scope of activities and responsibilities of the "BMP Committee"
should include all aspects of the facility's KIP plan, such as identification
of toxic and hazardous materials handled in the plant; identification of
potential spill sources; establishment of incident reporting procedures;
development of BMP inspection and records procedures; review of environmental
incidents to determine and implement necessary changes to 'the BMP plan;
coordination of plant incident response, cleanup and notification of authorities;
establishment of BMP training for plant personnel; and aiding interdepartmental
coordination in carrying out the BMP plan.
Other Committee duties could include review of new construction and
changes in processes and procedures at the facility relative to spill
prevention and control. The Committee can also periodically evaluate the
effectiveness of the overall BMP plan and make recommendations to management
in support of corporate policy on BMP-related matters.
Plant management has overall responsibility for the BMP plan. The plan
should contain a clear statement of the management's policies and responsi-
bilities with respect to BMP-related matters. Authority and responsibility
for immediate action in the event of a spill should be clearly established
and documented in the BMP plan, with the Committee indirectly involved in
that responsibility. The Committee should advise management on the technical
aspects of environmental incident control, but should not impede the
decision-making process for preventing or mitagating spills and incidents.
The size and makeup of the BMP Committee should be appropriate to the
size and complexity of the plant and the specific toxic and hazardous
chemicals handled at the plant. Facility personnel knowledgeable in spill
control and waste treatment such as environmental specialists, production
foreman, and treatment plant supervisor should be included. In some
plants, the Committee might consist of the one manager or engineer assigned
IV-11
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responsibility for environmental control. For very small facilities, the
Committee function might even have to be fulfilled by competent engineers or
managers from the corporate staff or the nearest large plant.
A list of personnel on the BMP Committee should be included in the BMP
plan. The list should have the office and home telephone numbers of the
Committee members and the names and phone numbers of backup or alternate
people.
Elements of the "BMP Committee", listed below, should be considered in
developing a BMP plan;
o Inclusion of facility personnel knowledgeable in spill control and
waste treatment such as environmental specialists, production foreman,
and treatment plant supervisor.
© Responsibility for
providing assistance to plant management for developing a BMP
plan,
providing assistance to plant management in implementing, maintaining,
and updating the BMP plan,
identifying toxic and hazardous substances,
identifying potential spill sources,
establishing BMP incident reporting procedures,
developing BMP inspections and records procedures,
reviewing environmental incidents,
coordinating plant incident response, cleanup and notification
procedures,
establishing BMP training for plant personnel,
providing assistance for interdepartmental coordination in carrying
out the BMP plan,
reviewing new construction and changes in processes and procedures,
evaluating the effectiveness of the BMP plan,
making recommendations to management in support of corporate policy
on BMP-related matters.
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2. Risk Identification and Assessment
The areas of the plant subject to BMP requirements should be identified
by the BMP Committee, plant engineering group, environmental engineer, or
others in the plant. Each such area should be examined for the potential
risks of discharges to receiving waters of significant amounts of toxic
pollutants or hazardous substances from ancillary sources. Any existing
physical means (dikes, diversion ditches, etc.) of controlling such discharges
also should be identified.
The areas described above should be clearly indicated on a plant plot
plan or drawing. A simplified materials flowsheet showing major process
operations can be used to indicate the direction and quantity of flow of
materials from one area to another. The direction of flow to navigable
waters of potential major spills and surface runoff subject to BMP regulations
could also be estimated based on site topography and indicated on the
plant site drawings. Dry chemicals which are on the toxic or hazardous
lists need to be evaluated if they have the potential to reach navigable
waters in significant quantities via rainfall runoff, for example.
A hazardous substance and toxic chemical (materials) inventory should
be developed as a part of the "Risk Identification and Assessment" process.
The detail of the materials inventory should be proportionate to the quantity
of toxic pollutants and hazardous substances on site and the potential for
them to reach the receiving waters. For example:
(1) The plant has determined that materials stored in bulk quantities
at a tank farm have a high potential for reaching the receiving waters in
the event of structural failure or overfills. Therefore, the materials
inventory for the tank farm should be detailed, and should provide the
identity, quantities, and locations of each material.
(2) The plant has determined that materials stored in small quantities
at the research laboratory have a low potential for reaching the receiving
waters. Therefore, the materials inventory for the laboratory should be
IV-13
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minimally detailed, and might not include the identity, quantity, or location
of each material but may include an estimate of the total quantity of toxic
and hazardous materials stored and would provide the location of the laboratory.
The rationale for the "low risk" nature of the laboratory should be provided
in this part of the BMP plan.
(3) The plant has determined that materials used in a batch operation
in the manufacturing process have a high potential for reaching the receiving
water. The plant supplies a variety of products through the batch operation
process to acconmodate fluctuations in public demand. Consequently, the
materials used for the batch process vary from week to week, oftentimes
unexpectedly. Therefore, the materials inventory for the batch operation
should be detailed but remain flexible. The inventory might include the
identification of each material expected for use, and the maximum quantity
of material that the batch process can handle. The materials inventory
could be updated to include any material substitutions unanticipated at the
time of the original inventory.
The examples above illustrate the flexibility of the materials inventory.
A materials inventory should be part of the "Risk Identification and Assessment"
of every BMP plan but the detail of the inventory will vary with the size
and complexity of the plant, the quantities of toxic and hazardous chemicals
on site and the potential for those materials to reach surface waters.
Determining the potential for incidents reaching receiving waters as well as
the detail needed for the materials inventory requires sound engineering
judgment.
The materials inventory and other useful technical information should
be made available to the BMP Gcmmittee but may require separate filing from
the BMP plan documents to protect confidentiality or trade secrets. This
data may include physical, chemical, toxicological and health information
(e.g., technical bulletins or safety data sheets) on the toxic and hazardous
substances handled; the quantities involved in various operations or ancillary
sources; and the prevention, containment, mitigation, and cleanup techniques
that are used or would be used in the event of a discharge.
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Materials planned for future use in the plant should be evaluated for
their potential to be discharged in significant amounts to receiving waters.
Where the potential is high, the same type of technical data described above
should be obtained.
Elements of "Risk Identification and Assessment", listed below, should
be considered in developing a BMP plan:
• Identification of areas of the plant subject to BMP requirements.
• Examination of identified areas for potential risks of BMP incidents
reaching receiving waters.
• Identification of existing site-specific or pollutant-specific
containment measures.
• Plant plot plans or drawings that clearly label the identified
areas.
• Simplified flowsheet(s) of the major process operations.
• Estimation of the direction of flow of potential discharges towards
navigable waters.
• Evaluation of the potential for materials planned for future use to
be discharged to receiving waters in significant amounts.
• Materials inventory system tailored to the need of the particular
facility.
• Physical, chemical, toxicological, and health information on the
toxic and hazardous chemicals on-site.
3. Reporting of BMP Incidents
A BMP incident is a discharge of a significant amount of a toxic
pollutant or hazardous substance from the ancillary sources subject to BMP
regulations.
A BMP incident reporting system is used to keep records of incidents
such as spills, leaks, runoff and other improper discharges for the purpose
of minimizing recurrence, expediting mitigation or cleanup activities, and
complying with legal requirements. Reporting procedures defined by the BMP
IV-15
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Committee should include: notification of a discharge to appropriate
plant personnel to initiate immediate action; formal written reports for
review and evaluation of the BMP incident and revisions to the BMP plan; and
notification as required by law to governmental and environmental agencies
in the event that a spill or other reportable discharge reaches the surface
waters.
The reporting system should designate the avenues of reporting and the
responsible company and government officials to whom the incidents would be
reported. A list of names, office telephone extensions, and residence
telephone numbers of key employees in the order of responsibility should be
utilized when necessary for immediate reporting of spill and incidents to
plant management for implementation of emergency response plans.
A communications system should be designated and available for
notification of an impending or actual BMP incident. Reliable communications
with the person or persons directly responsible would expedite immediate
action and countermeasures to prevent incidents or to contain and mitigate
discharged chemicals. Such a communication system could include telephone
or radio contact between transfer operations, and alarm systems that would
signal the location of an incident. Provisions to maintain communications
in the event of a power failure should be addressed.
Written reports on all BMP incidents should be submitted to the plant's
BMP Committee and plant management for review. Written reports should
include the date and time of the discharge, weather conditions, nature of
che materials involved, duration, volume, cause, environmental problems,
countermeasures taken, people and agencies notified, and recommended revisions,
as appropriate, to the BMP plan, operating procedures and/or equipment
to prevent recurrence.
Procedures and key data should be outlined for necessary reporting of
BMP incidents to federal, state, and local regulatory authorities. In some
circumstances, voluntary reporting to authorities such as municipal sewage
treatment works, drinking water treatment plants, and fish and wildlife
IV-16
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commissions may be desirable. The plant individuals responsible for notifi-
cation should be listed. Pertinent telephone numbers should be listed
for those individuals in the plant and those in the agencies to be notified.
The phone numbers should be reviewed periodically for accuracy and might
actually be used in the course of a "spill drill".
Elements of "Reporting of BMP Incidents", listed below, should be
considered in developing a BMP plan:
• Maintenance of records of incidents through formal reports for
internal review.
• Notification as required by law to governmental and environmental
agencies should an incident occur.
• Procedures for notifying the appropriate plant personnel, and taking
preventive or mitigating actions.
• Identification of responsible company and government officials.
• A list of names, office telephone extensions, and residence telephone
numbers of key personnel.
• A communications system for reporting incidents in-plant (i.e.,
telephone, alarms, radio, etc.).
4. Materials Compatibility
Incompatibility of materials can cause equipment failure resulting from
corrosion, fire or explosion. Equipment failure can be prevented by ensuring
that the materials of construction for containers handling hazardous substances
and toxic pollutants are compatible with the containers' contents and
surrounding environment.
Materials compatibility encompasses three aspects: compatibility of
the chemicals being handled with the materials of construction of the
container, compatibiity of different chemicals upon mixing in a container,
and compatibility of the container with its environment. The specific
requirement of "Materials Compatibility" in the BMP plan should provide
procedures to address these three aspects in the design and operation of the
equipment on site handling toxic and hazardous materials.
IV-17
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The BMP documentation on materials compatibility should recognize the
engineering practices already used in the plant, and should summarize these
existing practices with regard to corrosion and other aspects of material
compatibility. Specific consideration should be given to procedures and
practices delineating the mixing of chemicals and the prohibition of mixing
of incompatible chemicals which might result in fire, explosion or unusual
corrosion. Thorough cleaning of storage vessels and equipment before being
used for another chemical should be standard practice to ensure that there
is no residual of a chemical that is incompatible with the second, or later,
chemical to be used. Coatings or cathodic protection should be considered
for protecting a buried pipeline or storage tank fron corrosion.
Where applicable, material testing procedures should be described.
Proposed substitutions for currently used toxic or hazardous chemicals
should be studied to determine whether the construction materials of the
existing containers are compatible with the proposed new conditions. The
procedures utilized by the plant or an outside contractor to perform the
materials compatibility study should be documented. Materials compatibility
aspects of waste disposal which are covered by the RCRA hazardous waste
regulations should be referenced in the BMP plan.
Elements of "Materials Oorrpatibility", listed below, should be considered
in developing a BMP plan:
• Evaluation of process changes or revisions for materials compatibility.
® Incorporation of existing engineering practices with regard to
materials of construction, corrosion, and other aspects of materials
compatibility.
® Evaluation of procedures for mixing of chemicals and of possible
incompatibility with other chemicals present.
® Cleansing of vessels and transfer lines before they are used for
another chemical.
• Use of proper coatings and cathodic protection on buried pipelines if
required to prevent failure due to external corrosion.
IV-18
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5. Good Housekeeping
Good housekeeping is essentially the maintenance of a clean, orderly
work environment and contributes to the overall facility pollution control
effort. Periodic training of employees on housekeeping techniques for those
plant areas where the potential exists for BMP incidents reduces the possi-
bility of accidental incidents caused by mishandling of chemicals or
equipment.
Examples of good housekeeping include neat and orderly storage of bags,
drums and piles of chemicals; prompt cleanup of spilled liquids to prevent
significant run-off to navigable waters; sweeping, vacuuming or other
cleanup of accumulations of dry chemicals as necessary to prevent them from
reaching receiving waters; and provisions for storage of containers or
drums to keep them from protruding into open walkways or pathways.
Maintaining employee interest in good housekeeping is a vital part of
the BMP plan. Methods for maintaining good housekeeping goals could include
regular housekeeping inspections by supervisors and higher management;
discussions of housekeeping at meetings; and publicity through posters,
suggestion boxes, bulletin boards, slogans, incentive programs and employee
publications.
/•
Elements of "Good Housekeeping", listed below, should be considered in
developing a BMP plan:
• Neat and orderly storage of chemicals.
• Prompt removal of spillage.
• Maintenance of dry and clean floors by use of brooms, vacuum cleaners,
etc.
• Proper pathways and walkways and no containers and drums that protrude
onto walkways.
• Minimum accumulation of liquid and solid chemicals on the ground or
floor.
• Stimulation of employee interest in good housekeeping.
IV-19
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6. Preventive Maintenance
An effective preventive maintenance (PM) program is important to
prevent BMP incidents, A PM program involves inspection and testing of
plant equipment and systems to uncover conditions which could cause breakdowns
or failures with resultant significant discharges of chemicals to receiving
waters. The program should prevent breakdowns and failures by adjustment,
repair or replacement of items. A PM program should include a suitable
records system for scheduling tests and inspections, recording test results,
and facilitating corrective action. Most plants have existing PM programs
which provide a degree of environmental protection. It is not the intent of
the BMP plan to require development of a redundant PM program. Instead, the
objective is to have qualified plant personnel (e.g., BMP Committee, mainten-
ance foreman, environmental engineer) evaluate the existing plant PM
program and recommend to management those changes, if any, needed to address
BMP requirements.
A good PM program should include the following: (1) identification of
equipment or systems to which the PM program should apply (2) periodic inspec-
tions or tests of identified equipment and systems; (3) appropriate adjustment,
repair, or replacement of items; and (4) maintenance of complete PM records on
the applicable equipment and systems.
The BMP plan documentation on PM may include a list of procedures,
examples of recordkeeping, a list of the principal systems to which the PM
program is applicable, and directions for obtaining the records for any
articular system included or referenced in the BMP plan. In general, it. will
oe adequate to reference in the BMP plan the scope and location of existing PM
procedures and records applicable to the PM specific requirement.
Elements of "Preventive Maintenance", listed below, should be considered
in developing a BMP plan:
• Identification of equipment and systems to which the PM program
should apply.
IV-20
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• Periodic inspections of identified equipment and systems.
• Periodic testing of such equipment and systems.
• Appropriate adjustment, repair, or replacement of parts.
• Maintenance of complete PM records on the applicable equipment and
systems.
7. Inspections and Records
The purpose of the inspection and records system is to detect actual or
potential BMP incidents. The BMP plan should include written inspection
procedures and optimum time intervals between inspections. Records to show
the completion date and results of each inspection should be signed by the
appropriate supervisor and maintained for a period of three years. A
tracking (follow-up) procedure should be instituted to assure that adequate
rdsponse and corrective action have been taken. The record-keeping portion
of this system can be combined with the existing spill reporting system in
the plant.
While plant security and other personnel may frequently and routinely
inspect the plant for BMP incidents, these people are not necessarily
capable of assessing the potential for such incidents. Thus certain inspec-
tions should be assigned to designated qualified individuals, such as
maintenance personnel or environmental engineering staff.
The inspection and records system should include those equipment and
plant areas identified in the "Risk Identification and Assessment" portion
of the BMP plan as having the potential for significant discharges. To
determine the inspection frequency and inspection procedures, competent
environmental personnel should evaluate the causes of previous incidents,
and assess the probable risks for incident occurrence. Rorthermore, the
nature of chemicals handled, materials of construction, and site-specific
factors including age, inspection techniques and cost effectiveness should
be considered.
Qualified plant personnel should be identified to inspect designated
equipment and plant areas. Typical inspections should include examination of
IV-21
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pipes, pumps, tanks, supports, foundations, dikes, and drainage ditches.
Records should be kept to determine if changes in preventive maintenance or
good, housekeeping procedures are necessary. Each of the ancillary sources
should have "Inspection and Records" programs designed to meet the needs of
the particular facility.
Material storage areas for dry chemicals should be inspected for
evidence of, or the potential for, windblowing which might result in signi-
ficant discharges. Liquid storage areas should be inspected for leaks in
tanks, for corrosion of tanks, for deterioration of foundations or supports,
and for closure of drain valves in containment facilities. Inspections
could include the examination of seams, rivets, nozzle connections, valves,
and connecting pipelines. Storage tanks should be inspected for evidence of
corrosion, pitting, cracks, abnormalities, and deformation and such evidence
should then be evaluated-
For in-plant transfer and materials handling of liquids, inspections
should include visual examination for evidence of deterioration of pipelines,
pumps, valves, seals and fittings. The general condition of items such as
flange and expansion joints, pipeline supports, locking valves, catch or
drip pans, and metal surfaces also should be assessed.
For loading and unloading operations, inspections during transfer of
materials would permit immediate response if an incident occurred. The
conditions of pipelines, pumps, valves, and fittings for liquid transfer
r/stems and pneumatic conveying systems used for transferring dry chemicals
dtould be inspected. Inspections (together with monitoring) should be used
to ensure that the transfer of material is complete before flexible or
fixed transfer lines are disconnected prior to vehicular departure.
Before any tank car or tank truck is filled, the lower-most drain valve and
all outlets of such vehicles should be closely examined for evidence of
leakage and, if necessary, tightened, adjusted, or replaced. Before departure,
all tank cars or tank trucks should be closely examined to ensure that all
t insfer lines are disconnected and that there is no evidence of leakage
from any outlet.
IV-22
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For plant runoff, inspections should be used for examining the integrity
of the stormwater collection system and the overflow diversion structures, and
for ensuring the drain valves and pumps for diked areas are properly closed.
The plant sewer and storm sewer system should be periodically surveyed to
ensure that toxic and hazardous pollutants are not discharged in significant
amounts. Additionally, inspections should include diked areas to ensure
that hazardous and toxic chemicals are not discharged fron inside diked
areas to waterways. Any liquid, including rainwater, should be examined,
and where necessary, analyzed, before being released frcm the diked areas
to a receiving water.
For sludge and hazardous waste disposal sites, visual inspections
should include examinations for leaks, seepage, and overflows frcm land
disposal sites such as pits, ponds, lagoons, and landfills. Other procedures
and inspection techniques should be considered on a site-specific basis.
Any inspections made or records kept to comply with RCRA may be included in
the BMP plan by reference.
Elements of "Inspection and Records", listed below, should be considered
in developing a BMP plan:
• Inspection of
storage facilities,
transfer pipelines,
loading and unloading areas,
pipes, pumps, valves, and fittings,
tank corrosion (internal and external),
windblcwing of dry chemicals,
tank support or foundation deterioration,
seams along drainage ditches and old tanks,
deterioration of primary or secondary containment,
housekeeping,
drain valves on tanks,
damage to shipping containers,
conveying systems for dry chemicals,
IV-2 3
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integrity of stormwater collection system,
leaks, seepage, and overflows from sludge and various waste
disposal sites.
• Records of all inspections
• Tracking procedures to assure adequate response and corrective action
have been taken when inspections reveal deficiencies.
8. Security
A security system is needed to prevent accidental or intentional entry
to a plant which might result in vandalism, theft, sabotage or other improper
or illegal use of plant facilities that could possibly cause a BMP incident.
Most plants have security systems to prevent unauthorized entry leading to
theft, vandalism, sabotage and the like. The BMP plan should describe those
portions of the existing security system which ensure that the pertinent
chemicals are not discharged to receiving waters in significant quantities.
Documentation of the security system may require separate filing from the
BMP plan documents to prevent undesirables from gaining access to confidential
information.
The BMP Committee, plant security manager, plant engineer or other
qualified plant personnel should evaluate the coverage of the existing
security system for those areas of the plant and the equipment identified by
the "Risk Identification and Assessment" specific requirement as having the
potential for significant discharges. They should recommend to plant
management any changes necessary to improve the security system.
Examples of security measures include: routine patrol of the plant by
security guards in vehicles or on foot; fencing to prevent intruders from
entering the plant site; good lighting; vehicular traffic control; a guardhouse
or main entrance gate, where all visitors are required to sign in and obtain
a visitor's pass; secure or locked entrances to the plant; locks on certain
valves or pump starters; and television surveillance of appropriate plant
si-9S, such as plant entrance, and loading and unloading areas.
IV-24
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Whenever possible, security personnel should be instructed to observe
leaks from tanks, valves, or pipelines while patrolling the plant and also
be informed of the procedures to follow when a spill or other discharge is
detected. Many plants use contractor or plant security personnel who nay
not be qualified or nay not have time to carry out such surveillance. In
such cases, the surveillance can be incorporated in the "Inspection
and Records" specific requirement and should be conducted by production or
environmental staff.
Elements of "Security", listed below, should be considered in developing
a BMP plan:
• Routine patrols of plant by security personnel.
• Fencing.
• Good lighting.
• Vehicular traffic control.
• Controlled access at guardhouse or main entrance gate.
• Visitor passes.
• Locked entrances.
• Locks on certain drain valves and pump starters.
• Television monitoring.
9. Employee Training
Employee training programs should instill in personnel, at all levels
of responsibility, a complete understanding of the BMP plan, the processes
and materials with which they are working, the safety hazards, the practices
for preventing discharges, and the procedures for responding properly and
rapidly to toxic and hazardous materials incidents. Employee training
meetings should be carried out at least annually to assure adequate under-
standing of the objectives of the BMP plan and the individual responsiblities
of each employee. Typically, these meetings could be a part of routine
employee meetings for safety or fire protection. Such meetings should
highlight previous spill events or failures, malfunctioning equipment
IV-25
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components, and recently developed BMP precautionary measures. Training
sessions should review the BMP plan and associated procedures. Just as fire
drills are used to improve an employee's reaction to a fire emergency, spill
or environmental incident drills may serve to improve the employee's reactions
to BMP incidents. Plants are encouraged to conduct spill drillson a quarterly
or semi-annual basis. Spill drills serve to evaluate the employees' knowledge
of BMP-related procedures and are a fundamental part of employee training.
Of particular importance is the strong commitment and periodic input
from top management to the employee training program to create the necessary
climate of concern for a successful program. A plant manager might accomplish
more in a brief, face-to-face, appearance than an elaborate, impersonal
training program would accomplish.
Adequate training in a particular job and process operation is essential
for understanding potential discharge problems. Knowledge of specific
manufacturing operations and how discharges could occur, or have occurred in
the past, is important in reducing human error that can lead to BMP incidents.
The training program should also be aimed at making employees aware of
the protocol used to report discharges and notifying the people responsible
for response so that immediate countermeasures can be initiated. In addition,
personnel involved in BMP-incident response would be trained to use cleanup
materials such as sorbents, gelling agents, foams, and neutralizing agents.
As appropriate, they should be educated in safety precautions, in the side
effects of the chemicals they are working with, and in possible chemical
reactions. Operating manuals and standard procedures for process operations
should include appropriate sections on the BMP plan and the spill control
program and would be readily available for reference. Spill response
drills, suggestion boxes, posters, and incentive programs can be used to
motivate employees to be alert to the potential for discharges and to their
prevention.
The employee training program should include records of the frequency,
and names and position of the employees trained as well as the lesson plans,
IV-26
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subject material covered, and instructors' names and positions. BMP-related
training may be combined with other forms of training, such as safety and
fire prevention at the discretion of the plant.
In addition to permanent personnel, contractors or temporary personnel
should be trained procedures for preventing BMP incidents since these
individuals may be unfamiliar with the normal operating procedures or
location of equipment (pipelines, tanks etc.) at the facility. Adequate
supervision of contractor maintenance personnel should be provided to
minimize the possibility of BMP incidents resulting from damaging equipment
such as buried pipelines.
Elements of "Employee Training", listed below, should be considered in
developing the BMP plan:
• Meetings held at least annually to assure adequate understanding of
program goals and objectives.
• Environmental Incident (Spill) drills used at least semiannually.
• Periodic input from management.
• Adequate training in particular job and process operation and the
effect on other operations.
• Transmission of knowledge of past incidents and causes.
• Making employees aware of BMP plan and incident reporting procedures.
• Training in the use of sorbents, gelling agents, foams, and neutralizing
agents for cleanup or mitigation of incidents.
• Operating manuals and standard procedures.
• Making employees aware of health risks of chemicals handled through
both the plant's BMP plan and safety program.
• Motivating employees concerning incident prevention and control.
• Records of the personnel who were trained, and of the dates, instructors,
subject matter, and lesson plans of the training sessions.
• Training and supervision of contractors and temporary personnel.
IV-2 7
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APPENDIX A
References
1. Hydroscience, Inc., "NPDES Best Management Practices Guidance Document,"
EPA 600/9-79-045 (December 1979).
2. 54 comments on "NPDES Best Management Practices Guidance Document,"
EPA 600/9-79-045 (December 1979).
Commenters
Hunton & Williams
Gulf Mineral Resources Co.
Shell Oil Co.
Allied Chemical Co.
Kennecott Minerals Co.
Chemical Manufacturers Association
Los Alamos Scientific Laboratory
Envirologic Systems Inc.
The Fertilizer Institute
The Gulf Companies
Conoco Inc.
Illinois Power Co.
The Chlorine Institute Inc.
Tennessee Valley Authority
J. R. Simplot Co.
State of Wisconsin
Ohio EPA
Texas Chemical Council
Department of Natural Resources
iv-29
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Commenters Continued
National Food Processors Association
Kaiser Aluminum
Huntington Alloys, Inc.
Monsanto Co.
General Motors Corp.
American Textile Manufacturers Institute
E.I. DuPont De Nemours & Co.
Diamond Shamrock Corp.
Environmental Engineering and Pollution Control/3M Company
Dow Chemical
Texaco Inc.
Tennessee Valley Authority
Pennsylvania Department of Environmental Resources
EPA, Spill Prevention and Control Branch
American Cyanimid Co.
Bethlehem Steel Corp.
01in Chemicals Group
The Standard Oil Co.
Utility Water Act Group
American Paper Institute/National Forest Products Association
International Paper Co.
American Petroleum Institute
The Upjohn Company
Uniroyal Chemical
Pennsylvana Power and Light Co.
State of Washington: Department of Ecology
Rochester Gas & Electric Corp.
Amax Environmental Services Inc.
Star-Kist Foods Inc.
IV-30
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APPENDIX B
Example Summary
Eighteen months after the date of permit application, NPDES permittees
subject to Subpart K must submit to the permitting authority written summaries
of each specific requirement implemented in accordance with their BMP plans.
The following example summary of "Security" is provided to assist permitees
in writing summaries of the BMP specific requirements.
This example is illustrative and may not be appropriate for all facilities.
The content, length and format of the summary will vary according to site-specific
circumstances.
Security
The security system for Responsible Chemical Company is designed to
prevent accidental or intentional entry to the facility that could possibly
cause a chemical release. Protection measures against vandalism, theft,
sabotage, or other improper and illegal use of plant facilities include
routine foot patrols by the plant security guards; fencing at all points
surrounding the plant excluding the guardhouse entrance area; good lighting
surrounding the plant buildings and parking lots; vehicular traffic control
at both major intersections during workshift changes and normal business
hours; a guardhouse at the main entrance along with a gate at the rear
entrance where all visitors at either entrance are required to sign in and
obtain a visitor's pass; secure or locked entrances; and locks on drain
valves and pumps for chemical storage tanks and loading and unloading facilities.
The security personnel are trained to look for leaks from tanks,
valves, or pipelines while patrolling the plant and are trained in the
IV-31
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procedures to follow when a spill is detected. Due to the small size of the
plant, patrols are made only by foot. Security personnel are notified by
plant operating personnel of any non-routine activities which are expected
that day. This increases awareness of the increased possibility of security
infringement associated with non-routine activities. Outdoor lighting is
provided by flood lights. During normal working hours and workshift changes,
a traffic officer is stationed at each traffic intersection. Color coded
traffic signs are also posted to direct visitors to their destinations. The
main entrace guardhouse contains a minimum of two guards. The rear entrance
gate is kept locked from 12:00 a.m to 6:00 a.m. unless an authorized non-
routine delivery arrives between these hours. No television monitoring is
deemed necessary since the plant is small, the chemicals involved are stored
in small quantities with low potentials for discharge into navigable waters,
and the entire exterior of the plant can be observed by the security guards
at all times.
IV-3 2
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V. CASE HISTORIES
Reagent Chemical
Atlas Powder
Rollins Environmental Services
New Jersey Zinc
Kalama Chemical
Sanitary District of Rockford
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BMP CASE HISTORY
Reagent Chemical and Research Company, Incorporated
Port Arthur, Texas
Reagent Chemical and Research Company (RCRC), is located near the
intersection of the Sabine River and Neches River. RCRC is used as a storage
facility for bulk quantities of liquids. RCRC does not continuously discharge
into navigable waters of the United States, and consequently, is not permitted
under NPDES.
Spill Event:
At 10:45 a.m. on July 27, 1980, a large gas cloud was noticed at the
Sabine-Neches River Intersection, a navigable waterway of the United States.
The gas cloud emanated from an area adjacent to two stroage tanks at RCRC, and
extended across a small mooring slip and into the river intersection.
The gas cloud was due to a discharge of a 32 percent solution of
hydrochloric acid from one of the two storage tanks. The discharge was caused '
by the deterioration of the rubber lining inside the storage tank and an
adjoining sump pipeline. The rubber deteriorated at a flange fitting, ultimately
allowing the acid to eat through the flange. Oftentimes rubber lining is
used in containers to prevent corrosion by acid solutions of approximately 33
percent or less. According to RCRC, the tank had been visually inspected by
an outside contractor 8 months before the incident, but inspection records
were not provided.
The hydrochloric acid spilled from the deteriorated flange into a bed of
clam shells approximately two feet deep. The clam shell bed surrounded the
storage tank and had a permeable bottom. The storage tank was not diked, and
the clam shell bed was instantly overwhelmed by the discharged acid.
v-i
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The spilled acid flowed from the clam shell bed into two ditches which
led towards the river intersection. The two ditches merged, forming a single
ditch, at a culvert adjacent to the mooring slip. This ditch continued
towards the water, and the acid entered the mooring slip from a partially
submerged ten inch pipe. This location was designated as the number one
discharge point. The acid also ran underground from the tanks to a third
ditch, and entered the mooring slip at a second discharge point.
EPA identifies a discharge of hydrochloric acid in excess of 5000 pounds
as a quantity which may be harmful if discharged within a 24 hour period.
Approximately 73,100 gallons of hydrochloric acid spilled during the 5 hours
of discharge. Of this/it is estimated that one-third, or 24,123 gallons of
acid, entered the water. Since the weight of the acid was 9.68 pounds per
gallon, the amount discharged is approximately 233,510 pounds. This figure
indicates that a violation of Section 311 of the Act has occurred.
Spill Clean-up Procedure:
At 12:00 p.m., the Port Arthur Fire Department was observed washing acid
from an inland ditch to the culvert adjacent to the river intersection. The
hydrochloric acid reacted with the wash water and plant life in the ditch.
Upon entering the mooring slip, the acid created a bubbling action and a brown
foam.
The U.S. Coast Guard did not conduct a clean-up because of the solubility
of the hydrochloric acid in the water. Mitigation actions were taken by
damming the number one discharge point and neutralizing the acid on the shore
with clam shell. All water wash downs were ordered ceased.
Note; The preceding case history was extracted from a report submitted by
Investigating Officer M. J. Foley of the USCG.
Requirement;
1) What legal remedies or penalties are appropriate in this case?
V-2
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2) Assume RCRC has an NPDES permit. What BMPs should be placed in the permit
to prevent recurrence of this incident?
V-3
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WORKSHEET
V-4
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ATLAS POWDER COMPANY
Joplin, Missouri
Note:
The following material has been
extracted from a draft NPDES permit.
The permit conditions herein are for
instructional purposes and do not
necessarily reflect EPA policy or the
form of the actual draft or final
permit for this facility.
vV-5
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ATLAS PLANT EFFLUENTS
North
Grove
Atlas Pond
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PART IV
1
PART IV Permit No. MO-0002453
(DRAFT PROPOSAL)
(REVISED 9/1/80)
STANDARD BEST MANAGEMENT- PRACTICES CONDITIONS
FOR NPDES PERMITS
SECTION A. GENERAL CONDITIONS
1. Applicability
These conditions apply to all permittees who use, manufacture,
store, handle or discharge any pollutant listed as toxic under Section
307(a)(l) of the Clean Water Act or any pollutant listed as hazardous
under Section 311 of the Act and who have ancillary manufacturing operations
which could result in significant amounts of these pollutants reaching
waters of the United States. These operations include material storage
areas; plant site runoff; in-plant transfer, process and material handling
areas; loading and unloading operations, and sludge and waste disposal
areas.
2. BMP Plan
The permittee shall develop and implement a Best Management Practices
(BMP) plan which prevents, or minimizes the potential for, the release
of toxic substances from ancillary activities to the waters of the
United States through plant site runoff; spillage or leaks; sludge or
waste disposal; or drainage from raw material storage.
3. Implementation
The plan shall be developed within six months of the permit applica-
tion and shall be implemented as soon as practicable but not later than
one year after the effective date of the permit or 18 months after the
permit application, whichever is sooner, unless a later date is specified
by the Director.
4. General Requirements
The BMP plan shall:
a. Be documented in narrative form, and shall include any necessary
plot plans, drawings or maps.
b. Establish specific objectives for the control of toxic and
hazardous pollutants.
(1) Each facility component or system shall be examined for
its potential for causing a release of significant amounts
of toxic or hazardous pollutants to waters of the United
States due to equipment failure, improper operation, nat-
ural phenomena such as rain or snowfall, etc.
v-7
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PART IV
2
Permit No. MO-0002453
(2) Where experience indicates a reasonable potential for
equipment failure (e.g., a tank overflow or leakage),
natural condition (e.g., precipitation), or other circum-
stances to result in significant amounts of toxic or haz-
ardous pollutants reaching surface waters, the plan should
include a prediction of the direction, rate of flow and
total quantity of toxic or hazardous pollutants which could
be discharged from the facility as a result of each condition
or circumstance.
c. Establish specific best management practices to meet the objec-
tives identified under paragraph b of this section, addressing
each component or system capable of causing a release of sig-
nificant amounts of toxic or hazardous pollutants to the waters of
the United States.
d. Include any special conditions established in Part B of this sec-
tion.
e. Be reviewed by plant engineering staff and the plant manager.
5. Specific Requirements
The plan shall be consistent with the general guidance contained in
the publication entitled "NPDES Best Management Practices Guidance Docu-
ment" and shall include the following base line BMP's as a minimum:
a. BMP Committee
b. Reporting of BMP Incidents
c. Risk Identification and Assessment
d. Employee Training
e. Inspections and Records
f. Preventive Maintenance
g. Good Housekeeping
h. Materials Compatibility
i. Security
6. SPCC Plans
The BMP plan may reflect requirements for Spill Prevention Control and
Cnuntermeasure (SPCC) plans under section 311 of the Act and 40 CFR Part 151,
and may incorporate any part of such plans into the BMP plan by reference.
7. Hazardous Haste Management
The permittee shall assure the proper management of solid and hazard-
ous waste in accordance with regulations promulgated under the Solid Waste
Disposal Act, as amended by the Resource Conservation and Recovery Act of
1978 (RCRA) (40 U.S.C. 6901 et seq). Management practices required under
RCRA regulations shall be referenced in the BMP plan.
8. Documentation
The permittee shall maintain a description of the BMP plan at the
facility and shall make the plan available to the Director upon request.
v-8
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PART IV
3
Permit No. MO-0002453
9. BtW Plan Modification
The permittee shall amend the BMP plan whenever there is a change
in the facility or change in the operation of the facility which materially
increases the potential for the ancillary activities to result in a dis-
charge of significant amounts of hazardous or toxic pollutants.
10. Modification for Ineffectiveness
If the BMP plan proves to be ineffective in achieving the general
objective of preventing the release of significant amounts of toxic or
hazardous pollutants to surface waters and the specific objectives and
requirements under paragraphs b and c of Section 4, the permit and/or
the BMP plan shall be subject to modification to incorporate revised BMP
requirements.
SECTION B. SPECIFIC CONDITIONS
Nitrogen Section
1. All surface runoff from process areas subject to spills or
leaks of raw materials or products containing toxic or hazardous substances
shall be contained and diverted to the treatment pond system tributary
to Outfall 001 (Figure 1).
2. Surface runoff from less contaminated areas such as roofs,
parking lots and driveways that now bypasses the treatment ponds and
flows to the "Nitrogen Ditch" shall be controlled as follows:
a. Surface runoff shall be diverted to a new holding basin with a
minimum storage capacity equivalent to the volume of runoff
from the tributary drainage area produced by a 24-hour rainfall
occurring with a frequency of once in 10 years.
b. Runoff in excess of the 10-year frequency storm may be diverted
to the "Nitrogen Ditch" when the holding basin has filled.
The diverted flow should be the relatively cleaner "tail of
the hydrograph" and not the more contaminated runoff in the
holding basin.
c. The contents of the holding basin may be released to the
treatment ponds tributary to Outfall 001 or directly to the
"Nitrogen Ditch" through a new Outfall 002 (Figure 1) subject
to Specific Condition 2d.
d. The release of runoff from the holding basin shall be controlled
so that violations of effluent limits for Outfall 001 do not
occur and so that this discharge in combination with all other
discharges of wastewaters from the Atlas Plant (including
stormwater runoff from the Acid Area) do not increase concentrations
of un-ionized ammonia in Center Creek at HH Bridge above
0.1 mg/1 for all streamflows in the Creek equal to or greater
V-9
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4
PART IV
Permit No. MO-0002453
than 10.5 mgd. Release rates shall take into account flow,
temperature and pH in Center Creek as these affect impact un-
ionized ammonia levels.
3. The existing capability to divert stormwater runoff now bypassing
Outfall 001 to the "Storm Pond" shall be retained to allow diversion of
spills to the "Storm Pond".
4. Surface runoff from less contaminated areas tributary to the
"Pool Ditch" shall be controlled as follows:
a. The runoff shall be controlled by facilities described in
Specific Condition 12 for the "Acid Area" or;
b. A new holding basin shall be constructed with a detention
capacity equivalent to the volume of runoff from the tributary
drainage area produced by a 24-hour rainfall occurring with a
frequency of once in 10 years. Effluent from the holding
basin shall be discharged through Outfall 003 (Figure 1).
Excess surface runoff may be diverted to Outfall 003 as provided
in Specific Condition 2b. Release of runoff from the holding
basin shall be consistent with Specific Condition 2d and shall
not cause violations of effluent limits for Outfall 003.
5. No contaminated surface runoff from the manufacturing area
shall be discharged to the "Cooling Tower Ditch".
6. Use of the two evaporation/storage ponds immediately north of
the manufacturing area shall be discontinued and the area regraded to
prevent ponding of surface water. Any materials in or around the ponds
containing toxic or hazardous materials shall be disposed of in a manner
consistent with applicable State and Federal regulations.
7. Secondary containment shall be provided for the storage area
for copper sludges to prevent leaks or spills from storage drums from
reaching surface discharges.
8. All wastewater treatment pond sludges, cooling tower sludges
and copper sludges are to be stored and/or disposed of in accordance
with applicable State and Federal regulations for toxic or hazardous
wastes.
9. Secondary containment shall be provided for any areas storing
used lubricating oils to prevent release of oil and grease in surface
runoff from leaks or spills in the storage areas.
10. The dinitrotoleune (DNT) drums, accumulated in two areas,
shall be removed from the plant site or provided with suitable con-
tainment to prevent releases of DNT from these sources to surface
waters.
v-10
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PART IV
5
Permit No. MO-0002453
11. Air pollution control equipment in the fertilizer manufacturing
area shall be operated as efficiently as possible consistent with
applicable air pollution regulations to minimize the fallout of fer-
tilizer particulate matter over the plant site.
Acid Area
12. Surface runoff from the Acid Area tributary to Outfall 003
(including the "Pool Ditch" area of the Nitrogen Section if the option
in Specific Condition 4a is elected) shall be controlled as follows:
a. Surface runoff in excess of normal dry-weather flow shall be
diverted to the "Atlas Pond" and/or a new holding basin for
subsequent controlled release as provided in Specific Condition 2d.
Such release shall not cause violations of effluent limitations
for Outfall 003.
b. The minimum storage capacity of holding basins (the Atlas pond
and any new holding basins constructed) shall be at least
equal to the runoff from the tributary drainage area produced
by a 24-hour rainfall occurring with a frequency of once in 10
years.
c. The existing capability to control spills in the "Acid Area"
or "Pool Ditch" area of the "Nitrogen Section" by diversion to
the "Atlas Pond" shall be retained or replaced by equivalent
control procedures.
Powder Line Area
13. Appropriate secondary containment measures shall be provided
for the bulk dinitrotoluene storage tank to prevent spills or leaks from
reaching surface discharges.
14. Housekeeping practices in the "Powder Line" area shall be
specifically designed to prevent or minimize the contamination of
surface runoff with toxic or hazardous substances including NG and EGDN.
IMPLEMENTATION SCHEDULE
1. A basic Best Management Practices (BMP) plan for the entire
Atlas Plant shall be developed within six months of the effective date
of this permit and implemented within 18 months after the effective date
of this permit.
2. Plans and specifications for necessary construction associated
with the BMP plan including stormwater holding basins, flow diversion
structures, containment structures and closure of the evaporation ponds
shall be prepared within nine months of the effective date of this
permit.
v-li
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PART IV
6
Permit No. MO-0002453
3. Construction of the required BMP facilities shall begin within
12 months of the effective date of this permit.
4. All construction required by the BMP plan and these Specific
Conditions shall be completed and the facilities placed in operation
within 18 months of the effective date of this permit.
V-12
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RATIONALE FOR BEST MANAGEMENT PRACTICES SPECIAL CONDITIONS
Atlas Powder Company
Joplin, Missouri
Permit No. MO-0002453
General Approach
The principal pollution problem at this facility is the high level
of ammonia present in surface runoff from the areas surrounding the
fertilizer manufacturing complex and the nitric acid plant. This
contamination is primarily the result of fallout of fertilizer dust from
the ammonium nitrate and urea prill towers and past spills and leaks in
the nitric acid area. Violations of water quality standards in Center
Creek occur frequently when heavy rainfall follows a dry period of
several weeks.
Dry weather wastewater flows subject to BAT level permit limits
meet water quality standards in Center Creek. However, a substantial
reduction in peak stormwater runoff ammonia loads is needed to meet the
standards. Because of the large surface area involved, runoff volumes
are large. They also are very intermittent. Treatment of the runoff
for ammonia removal is not economically practical. Best management
practices, primarily the impoundment and controlled release of surface
runoff, offer a practical and economical solution to minimize ammonia
discharges and meet water quality standards.
No data were available on the ammonia levels in the surface runoff
from the fertilizer manufacturing area (new Outfall 002) that now
bypasses Outfall 001 and its associated treatment system (Figure 1). No
data were available on runoff in the Powder Line Ditch (new Outfall
004). Data on Outfall 003 on the Acid Area Ditch were available but
cover perhaps half of the runoff volume. For these reasons it was not
practicable to specify daily average or maximum ammonia load limits in
the permit for Outfalls 001 and 004. The controlling factor on releases
of storm runoff through Outfalls 001, 003 and 004 is the un-ionized
ammonia level in Center Creek at HH Bridge. This limit was incorporated
in the previous permit. However, the concentration limit has been
reduced from 0.3 mg/1 to 0.1 mg/1 to be consistent with expected revisions
in the water quality standards. Monitoring of ammonia loads discharged
through Outfalls 002, 003 and 004 is required to develop a data base to
evaluate the level of control achieved by the stormwater holding system.
Additional specific conditions are designed to reduce the potential
for contamination of surface runoff by toxic and hazardous substances.
v-13
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Specific Conditions
1. Most process areas in the fertilizer manufacturing area that are
subject to spills or leaks presently drain to the treatment ponds
tributary to Outfall 001. This condition formally requires continuation
and minor expansion of such containment so that all spills and leaks of
concentrated liquids will receive treatment prior to discharge rather
than contaminating surface runoff.
2. This condition is designed to control runoff from areas of the
fertilizer manufacturing area that are subject to contamination by
fallout of fertilizer particulates but not spills or leaks. A 10-year,
24-hour rainfall was used as the design storm for holding basin capacity
as this is a common design frequency for facilities such as farm animal
feedlots and industrial plants where complete containment of surface
runoff is needed. The initial runoff from larger storms would contain
the bulk of the ammonia contamination and would be contained by the
specified holding capacity. The runoff exceeding the holding capacity
would occur late in the storm and would have low levels of contamination
easily assimilated by the large streamflow produced by such a storm.
Condition 2b is designed to prevent slug release of the more concentrated
initial runoff.
Condition 2c encourages the release of the detained runoff through
the treatment ponds whenever excess capacity is available to achieve a
reduction in ammonia levels. This would be especially useful during low
streamflow periods or when runoff ammonia concentrations are high as the
result of a long dry spell.
Condition 2d is key in that it incorporates the requirement that
all releases of ammonia from the Atlas plant through both process
wastewater and storm runoff discharges shall not cause violations of the
un-ionized ammonia criterion in Center Creek. This provision was in the
previous permit. The un-ionized ammonia level was decreased from 0.3 -
mg/1 in the previous permit to 0.1 mg/1 to reflect proposed revisions in
water quality standards.
3. A structure presently exists in the storm drain channel for diverting
flows to the Storm Pond. This provision requires retention of this
capability so that any unusual spills that might occur in driveways,
parking areas, etc. can be diverted to the treatment ponds.
4. Surface runoff from the south end of the fertilizer manufacturing
area drains to the Pool Ditch (Figure 1) tributary to Outfall 003.
Space is available for construction of a holding basin on this ditch.
Alternately, runoff from this area could be controlled in combination
with runoff from the Acid Area also tributary to Outfall 003. Conditions
4a and 4b provide for these alternatives. The rationale for these
conditions is the same as for Condition 2.
V-14
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5. No stormwater retention is required for the Cooling Tower Ditch
(Figure 1) which receives only cooling tower blowdown from the fertilizer
area. Therefore, prohibition of contaminated surface runoff discharges
to this ditch is necessary.
6. There are two small ponds north of the manufacturing area that are
reportedly no longer used. They were reportedly used in the past to
store still bottoms and turnarounds from fertilizer manufacturing, spent
copper solutions and possibly other hazardous wastes. One pond appeared
to have recently overflowed when viewed in May 1980. Present liquid and
solid contents are unknown. To prevent contamination of surface runoff
and groundwater with toxic and/or hazardous substances, the ponds should
be closed and any toxic or hazardous materials disposed of properly.
7. Copper sludges resulting from the batch treatment of copper catalyst
solutions are presently stored in 55-gal. drums awaiting a suitable
market. About 100 drums are present. The storage area has no provision
for containment of spills. Containment is required to prevent contamina-
tion of surface runoff by any spills or leaks.
8. Sludges from the wastewater treatment ponds, cooling towers and
copper treatment system all contain toxic or hazardous substances. This
condition calls attention to the need for disposal of such sludges in
accordance with regulations for hazardous wastes.
9. About 300 55-gal. drums of used lubricating oils are stored on-site
without secondary containment. Such containment is needed to prevent
contamination of surface runoff.
10. About 6,000 drums that were used to transport dinitrotoluene (DNT),
a raw material for the explosives plant, have accumulated over the past
20 or more years. Each drum is reported to contain about a cupful of
DNT. The drums are stored in a jumbled pile on the hill between the
Powder Line and Nitrogen Section or in a neat stack near the cooling
tower for the fertilizer area. There is no secondary containment. DNT
is now received in bulk so no additional drums should be received at the
plant. Atlas wishes to remove the drums but must meet hazardous waste
transport requirements to do so. If the drums are not removed, secondary
containment is necessary to prevent contamination of surface runoff with
DNT, a priority pollutant. •
11. The primary source of ammonia contamination of surface runoff is
fallout of fertilizer particulate emissions. Maximum control of such
emissions will minimize such contamination.
12. This condition is designed to control surface runoff tributary to
Outfall 003. Runoff from the Acid Area is contaminated by the leaching
of old acid and ammonia spills and by fertilizer fallout. Runoff in the
Pool Ditch is contaminated by fertilizer fallout as previously discussed.
v-15
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Presently, flows in the Acid Area Ditch are monitored for pH and
conductivity. Any discharges outside of set limits are automatically
diverted to and held in the Atlas Pond. Low pH discharges trigger a
spill alarm. This ability to control spills is an absolute necessity
and is required by Condition 12c.
Condition 12b requires the same storm runoff holding capacity as
for other areas. The Atlas Pond capacity is inadequate for the entire
Outfall 003 tributary without improvement. Thus improvement and/or
construction of additional holding basins (including an optional basin
on the Pool Ditch) will be necessary.
13. DNT is received in bulk and stored in a 5000 gal. above ground
storage tank adjacent to the Pool Ditch. No secondary containment is
provided at the tank. The tank is upstream of the diversion gate to the
Atlas Pond which could capture a spill. However, this would require
timely spill detection. An improved method of secondary containment is
needed to prevent discharges of this priority pollutant through Outfall
003 from any spills or leaks.
14. No treatment or surface runoff controls are provided on the Powder
Line Ditch. Contamination in this area is low. It is important that
housekeeping practices are designed to eliminate any contamination by
toxic or hazardous substances.
Implementation Schedule
1. The schedule for development and implementation of a BMP plan is
based on expected final EPA BMP regulations.
2. This schedule allows an additional three months after completion of
the BMP plan for completion of construction plans and specifications
which is considered reasonable because basic needs will be defined
months earlier in the development of the BMP plan.
3. An additional three months are allowed for the bidding and contract
award process and start of construction.
4. Six months are considered adequate for completion of the relatively
simple structures to be constructed.
V-16
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WORKSHEET
V-17
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WORKSHEET
V-18
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ROLLINS ENVIRONMENTAL SERVICES
PART I
BEST MANAGEMENT PRACTICES PROGRAM (BMPP)
BASIC
Prepared By: Michael V. Poll to
US Environmental Protection Agency
Region II
Emergency Response & Hazardous
Materials Inspection Branch
Edison, New Jersey 08817
April 1980
v-19
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BEST MANAGEMENT PRACTICES PROGRAM (BMPP)
BASIC
GENERAL INFORMATION
1. Name of Facility
2. Type of Facility
3. Location of Facility
4. Mailing Address
5. Name and Address of
Owner/Operator
6. Designated Person Responsible For BMPP at Facility
Name :
Title
Phone
7. NPDES Number
MANAGEMENT APPROVAL
The BMPP will be implemented at the facility as described in this document
Name
Signature
Title
Address
v-20
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Environmental Incident Control Committee (EICC)
Definition - Environmental Incident
An environmental incident is any discharge, release, spilling, leaking, pouring,
pumping, emitting, emptying, dumping, dripping, leaching, migrating, and blowing
of chemicals, or other materials, particulates, and vapors to the surrounding
environment whether it is within, leading to or from, or outside the property
lines of Rollins Environmental.
These incidents include both minor and major events with or without accompanying
personal human injury. They are non-desireable events both continuous and
episodic and are discernable from normal plant operating releases by a "reasonable
man" determination.
Statement of Function
The Environmental Incident Control Committee is responsible for overseeing
the development, implementation and maintainence of the BMPP. Rollins management
fully assigns the responsibility and the authority for fully carrying
out the management program for achieving BMPP objectives to the EICC. The
committee is responsible for the facility materials inventory, identification
of potential spill sources, establishment of environmental incident reporting
system, the facility visual inspection program, a review of all environmental
incidents for adequate present and future prevention, departmental
coordination, the establishment of the employee training, BMPP implementation
and review of all new construction and process changes for adequate
spill prevention and control and review of existing facilities and
processes for adaptation of BMPP especially spill control.
Membership of EICC
Each operating department at Rollins will provide at least one member to serve
two years on the EICC with initial membership at the formation of the EICC
being three years for one-half the members and two years for the other half.
The EICC will consist of at least five members with the Plant Manager, or his
Deputy, being the Chairperson.
Reports
The Environmental Incident Control Committee (.EICC) is responsible for
the preparation of a semi-annual report to management on all actions of
the committee and the status of those actions. These reports shall be
maintained for a period of seven years or as otherwise required.
These reports will detail the work of the committee in all aspects of
the BMPP, with emphasis on spills, and methods to prevent their occurence.
All items addressed in the statement of committee function, and other
items of current assignment shall be treated in this report.
Schedule of Meetings
The Environmental Incident Control Committee shall meet the first work day of
February, May, August and November and at such other times as may be necessary.
V-21
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Minutes of Meeting
The minutes of the meeting or the EICC will be circulated to all supervisory
personnel and other appropriate plant management. Each supervisor will Be
responsible for posting the minutes of these meetings on his/her departmental
bulletin board.
V-22
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Membership
Primary
NAME JOB TITLE SPILL COMMITTEE OFFICE HOME DUTIES & RESPONSIBILITIES TERM EXPIRES
~ TITLE PHONE PHONE '
N)
Alternate
NAME JOB TITLE SPILL COMMITTEE OFFICE HOME DUTIES & RESPONSIBILITIES TERM EXPIRES
TITLE PHONE PHONE
-------
Spill Reporting and Response
General Statement
An environmental incident reporting system is used to keep records of environmental
incidents for the purpose of minimizing recurrence, expediting mitigation
of cleanup activities, and complying with legal requirements. Environmental
incident reporting procedures include notification of an environmental incident
to appropriate plant personnel, and to appropriate governmental and
environmental agencies. A copy of the Immediate Internal Environmental Incident
Report form is submitted to the Office of the Company President, the
Office of the Plant Engineer and Division EICC Head in which the environmental
incident occurs. The report is initiated as soon as an incident occurs.
After receipt of the immediate environmental incident report form,
and/or other appropriate notification, the Environmental Incident Control Committee
will complete the Environmental Incident Report Workbook, a copy of
which is attached.
V-24
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Immediate Internal Environmental Incident Report Form
Distribution: Corporate (White & Green) Date
EICC (Canary)
Plant Manager (Pink) Prepared By
Originator (.Goldenrod)
Time
1. Call Received From
Incident Observed By
Name Company/Department
Location A/C Telephone No..
Alternate Telephone No.
2. Incident: Air Land Water
Location
Date of Incident T.itne
Material: Gas Liquid Solid
Chemical Name
Quantity (gallons, cfm, Ibs.)
3. Possible Hazards:
U Life _
/~7 Property _
[J Pollution _
£7 Safety _
[J Odor _____
Other
V-25
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4. Describe Incident (use continuation sheets if necessary)
5. Who Has Been Notified?
Name Time Phone Name . Time Phone
1. 6.
2. 7.
3. 8.
4. 9.
5. 10.
6. Describe Response Action
V-26
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CONTINUATION SHEET - IMMEDIATE INTERNAL ENVIRONMENTAL INCIDENT REPORT FORM
v-27
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Telephone
Environmental Incident Notification
All Environmental Incidents will be reported to the chief operating
official at the facility and the Chairperson of the EICC. The Chairperson of
the EICC will effect the following as necessary, after alerting the
EICC Response Team.
Organization Address Telephone Number
1. USCG/EPA 800-424-8802
2. NJDEP 609-292-7172
3. NJ State Police
4. Delaware River Basin
Commission
5. Bridgeport Fire Dept.
6. Bridgeport Mayor's
Office
7. Corporate Headquarters
8. OSHA
Company officials to be subsequently notified as necessary:
NAME TITLE WORK PHONE HOME PHONE
The order listed also indicates the authority to direct actions if On
Duty personnel are not available.
V-28
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10
For all major incidents which in any way could present a danger to life
and property, the plant alarm shall be sounded to alert all personnel of
possible hazards. Loudspeaker announcements will be made from the
control center.
All cleanup will be effected primarily by plant personnel. If necessary,
the following cleanup contractors shall be contacted:
1.
2.
3.
Upon receipt of the incident notification, the EICC or one of the member
designees will notify the members of the Environmental Incident Response Team
who will respond on scene and appropriately institute mitigation efforts.
The efforts will include:
1. Process Shutdown
2. Spill Containment
3. Spill Cleanup
4. Process Repair
5. Effluent Shutdown
Action of the Environmental Incident Response Team is not limited to
EICC activation. Any responsible supervisor may activate the Team.
After the incident has been addressed, the EICC, through the Rollins
Corporate Legal Department, will send all written required reports to
appropriate regulatory agencies. These reporting requirements will vary
from incident to incident depending upon the substance involved, movement,
mass released, personnel injuries, effect on surrounding areas, public
interest generated, etc.
v-29
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11
Material Inventory System
The attached material inventory system identifies all sources of toxic
and hazardous materials handled, used, produced (through destruction
processes) or otherwise present and purchased at the plant. These
materials are received from various suppliers and stored and placed in
locations identified in drawing . Included in this
drawing is a material flowsheet which shows major process operations and
the direction and quantity of flow from one area to another. Arrows
colored red.in the diagram indicate the ground movement of liquids.
Included in this material inventory for each toxic or hazardous substance
are physical, chemical,toxicological (both human and aquatic) health
information, average quantities of materials on hand and the prevention,
containment, mitigation and ultimate disposal technique that will be
used in the event of a spill.
Before any new materials are accepted at the facility, an assessment of the
physical, chemical, toxicological, health effects, spill mitigation and
ultimate disposal shall be made, documented and become part of the
facility material inventory system described herein.
The preparation of this inventory is the responsibility of the EICC.
V-30
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Material Inventory.
Material Formula
Storage Location
Usual Quantity
On Hand
Human Aquatic Flash Corroslveness
Human Aquatic Flash
Tox1c1ty Toxlclty Point
i
OJ
Water
Toxlclty
Route
Technique
Alternate
Cleanup Technique
Ultimate Disposal
-Procedure
(The format of this Inventory can be data sheets, column listing or some other procedure.)
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13
Employee Training
Employee training programs are used to instill in personnel, at all levels
of responsibility, a complete understanding of the BMPP, the processes
and materials with which they are working, the safety hazards involved,
the practices for preventing environmental incidents and the procedures
for responding properly and rapidly to spills of toxic and hazardous
materials. Formal employee training meetings are conducted semi annually,
a frequency adequate to ensure adequate understanding of the goals and
objectives of the BMPP and the individual responsibility of each employee.
Because of our dedication to the BMPP, these meetings are held separately
from safety and fire prevention and protection. All spills, failures or
other environmental incidents occurring since the last meeting are
reviewed with a general discussion as to the means for fostering a
better BMPP.
Apart from this BMPP meeting, environmental incident drills are conducted
with the elite incident response team utilizing the deployment of equipment
and information channels in mock exercises. These drills will be conducted
semiannually with a critique provided by the EICC and Plant Manager as
soon after the exercise as is practical.
We view of particular importance the strong commitment and continuous involvement
of our highest management to the training programs. A vice president, or
equivalent rank management person, must attend each formal training
class, establishing comraderie and environmental concern.
Each member of top management must attend at least yearly the environmental
incident exercise drill of the elite response team, and issue a critical
report on his/her observations.
Our employees are especially skilled and aware of their jobs and its effect
on other actions at the facility. Our training program is aimed at making
employees aware of the protocol used to report spills, and activiation of
the environmental incident response team personnel, both through attendance
at spill control courses given by institutions such as the EPA, Texas
A&M, Vanderbilt University and others, and practical deployment of
sorbents, gelling agents, neutralizing agents and booms. Safety precautions
are stressed as well as the nature and chemical reactivity of chemicals
used at the facility.
In evaluating employees for promotion and merit raises, their interest and
knowledge of spill control will be an evaluating factor.
Records
Each employee's attendance at spill control courses, company training
courses and company semiannual environmental incident meeting will be recorded
and maintained by the personnel department with a copy included in the
documentation of the facility's BMPP.
V-32
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1.4
Incentive Award
Yearly, employees, whether they be hourly or salaried, who have made the
greatest contribution to furthering Environmental Incident Control at
the facility shall be provided the "Environmental Management Award". This
award shall consist of a Certificate of Merit and a cash award, the magnitude
of which is based upon the extent of employee contribution.
Nominations shall be made by each supervisor and the selection made by the
Corporate EICC and Corporate Headquarters.
v-33
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15
Visual Inspection
Visual inspection at the facility constitutes an important phase of the BMPP.
By constant vigilance to daily plant occurences, we can detect and correct
any significant flaw before it becomes a problem. Visual inspection consists
of touring the facility in a general way plus detailed observation by
plant personnel both supervisory and non-supervisory. In general, it is
our policy to instill in personnel a need to be alert for possible problems
by remaining alert to such matters.
Routine visual inspections are performed by the plant security personnel which
include visual observations of storage facilities, transfer pipelines
operating equipment, and treatment lagoons loading and unloading areas and
the incinerator for detection of leaks and spills. These tours are made by
both foot and vehicle, whichever is convenient and appropriate at a
particular time. Any spills are noted in the shift log and reported as
detailed in Spill Reporting.
Detailed inspections are made by plant personnel responsible for the
individual processes. These inspections include examination for pipe and
pump leaks, tank corrosion, barrel deterioration, wind blowing of dry
chemicals, deterioration of supports and foundations, stains on walls,
stains along drainage ditches and old tanks, strong odors, liquid pools on
the ground, sewer wells, etc. More specific consideration to ancillary
sources are described below.
Raw material storage areas for dry chemicals received in containers are
inspected for evidence of and potentiality to wind blow not only to plant
and off plant sites but to any sewer or plant lagoon which would lead to
surface waters. Caked or loose solids are especially suspect as potential
polluting areas. Liquid storage areas are inspected for leaks in, or
corrosion of, tanks, for deterioration of foundations and/or supports
and for closure of drain valves in containment facilities. Special
attention is given to the galvanically active areas at the base of the
tanks at the junction of the ground. Inspections also include an examination
of seams, rivets, nozzle connections, valves and pipelines directly
connected to a tank. Internal examination or inspection of storage
tanks would involve observation for evidence of corrosion, pitting,
cracks, and abnormalities of any type. Special attention is given to
dented areas where corrosion might initiate.
For in plant transfer and materials handling of liquids, visual inspections
provide evidence of leaks, splits, cracks, bulges, corrosion and deterioration
of pipelines, pumps, valves, seals and fittings. The general condition of
flanges, expansion joints, pipeline supports, locking valves, drip pans,
and metal surfaces are assessed continuously for leak potential. For in
plant transfer and material handling of solids, visual inspections focus on
leaks and drippages of solids, particulary in the incinerator area.
At the loading and unloading areas visual inspections during transfer of
chemicals permit rapid and immediate response if a spill occurs. All fixed
hardware is checked and monitored. Visual inspection, together with
monitoring, ensures that the transfer of material is complete before
flexible or fixed transfer lines are disconnected prior to vehicle
departure.
V-34 .
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16
Before any vehicle is filled, the lowermost drain valve and all
outlets of such vehicles are very closely examined for evidence,of leakage
and, if necessary, tightened, adjusted and/or replaced. Before departure,
all tank cars, tank trucks are closely examined to ensure that all transfer
lines are disconnected and that there is no evidence of leakage from any
outlet.
Supervisory personnel are especially diligent to observing that correct
procedures are carried on at the loading-unloading areas and that truck
drivers remain with their vehicles and promptly clean up leaks and spills
with provided adsorbents.
For runoff into the lagoons or flow by any secondary route off the property,
evidence of suspended solids, discoloration sheen or odor is made. Special
tours are made during periods of rainfall to make certain that all designed
control facilities are properly functioning. Not only is curbing checked
but the integrity of dikes, water levels and diversion systems.
To aid in this visual inspection, a Visual Inspection Checklist is attached.
This visual work sheet is forwarded to the plant engineer's office who
maintains them for a period of seven years or as otherwise appropriate.
V-35
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17
VISUAL INSPECTION CHECKLIST . '.'.'' . , ,
Facility & Equipment
Maintenance
Deteriation Indicator Equipment , Plant Area
Corrosion
Pitting
Splitting
Cracking ,
Bulging
Staining ,. _ ,
Seam Separation
Weld Point Integrity
Equipment Leaks
Piping
Pumps
Tanks
Tank Trucks
Drums
Hoses
Valves
Lagoon
Facility Housekeeping
Sludge Deposits
Caked Chemical
Loose Powders
Empty Drums
Excessive Chemical Storage
Ground Contamination
Other
Liquid Accumulations
Sumps
Diked Areas
Overflows (ponds, pits, lagoons)
Drains Clear of Debris
Odors
Chemical
Sewage
Other
General
Incompatable Liquid Storage
V-36
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18
Preventive Maintenance
In order to prevent the occurence of problems before they occur, a periodic
maintenance program occurs plant-wide which involves the inspection, servicing
and replacement of equipment. Any item identified by the manufacturer as
having a determined useful life, or identified as either problem causing or
operationally critical is replaced prior to a breakdown. Any item noticed in
the visual inspection program potentially faulty, leaking or otherwise suspect
is immediately serviced or replaced.
Our plant-wide preventive maintenance program involves all of the following,
and in terms of this BMP is selectively practiced and highlighted to minimize
and eliminate releases of not only hazardous or toxic substances, but any material
which could have an adverse effect on the surrounding environment.
Our preventive maintenance program includes all, but is not limited to, the
following, elements:
1. The identification of equipment and systems to which the preventive
maintenance program should apply by critical analysis for potential
failures and spill impact. This analytical analysis is reinforced
by actual plant experience and incorporates the helpful suggestions
of governmental regulatory personnel.
2. Integration of the visual inspection program with preventive
maintenance program, and the establishment of priority work
consignment.
3. Periodic testing and monitoring of all systems by accounting,
analyses, ultrasonic testing, vibration analyses, x-ray analyses
or any technique which would be pertinent.
4. A budget allocation for routine and emergency repair and replace-
ments.
5. A record system coupling visual observation, spill reporting and
preventive maintenance inspection, testing and repair. This
record keeping system is described below:
a. Upon receipt of any spill report or visual observation
report a log note is made in the plant engineer's special
log, Subsequently and as soon as practical, the plant
engineer's office will make a visual inspection.
b. All items reported are evaluated and, if necessary, are
assigned to the appropriate tradesman (plumber, pipe fitter,
electrician, mason, etc.) by a written work order.
c. After two working days the tradesman will report back on
the status of his action, either preliminary or final.
He will then, if further action is required, initiate a
finalizing solution.
d. A status log will be kept by the plant engineer with
appropriate periodic review, until the action is finalized.
v-37
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19
A list of all equipment requiring preventative maintenance, preventive
maintenance requirements and status cards are maintained in the plant
engineer's office.
A checklist should be developed by Rollins for Preventive Maintenance. For
a pump, I have developed the following list which may be more or less
complete. This list should be developed, adopted and completed for plant
requi rements.
Pump
1. Any evidences of external leakage?
2. Detection of unusual noises
3. Observation of unusual or excessive vibration
4. Wear on internal portions of pump
a. Extent of corrosion
b. Extent of erosion
5. Lubrication of moving parts
6. General condition from discussions with operators
7. Performance specifications being met
8. Behavior of gauges and other indicators
V-38
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20
Good Housekeeping
The management at Rollins believes that a clean tidy workplace not only
reduces the risk of spills but establishes a psychological attitude of
environmental concern among all employees. Our slogan is "Give a darn about
environmental harm".
The items we key in are the neat and orderly storage of chemicals, prompt
removal of small spillages, regular garbage and rubbish pickup, a neatly main-
tained drum storage area, removal of expended drums, cleanly maintained and
adequate walkways, the pickup of loose debris, the sweepup of spills of dry
chemicals.
Our housekeeping department is headquartered in the building and
is provided with vacuums, brooms, safety equipment chemical adsorbent, booms
and skimmers. The housekeeping foreperson is the head of our spill response
team, and as you can see, maintains in a state of readiness those items
needed for environmental response.
The foreperson also is charged with working in close concert with the EICC in
implementing spill cleanup where full activation of the Environmental Incident
Response Team is not required. He maintains the publicity program
through the display of posters obtained from management and the EICC.
He, in concert with the EICC, gives lectures and demonstrations of
spill control equipment. His training in spill control is more extensive
and detailed than any other plant personnel.
v-39
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21
Material Compatability
Because of the number and complexity of different materials which are
brought to Rollins for disposal, we are especially concerned about material
compatability. These materials include oils, combustible materials,
acidic and alkaline solutions, and solids having combustible and noncombustible
characteristics. Unstable chemicals and explosives are not handled.
All incoming wastes are analyzed before acceptance either by our facility
or by the shipper. Because of this variety of wastes, plant piping and
storage was evaluated for the ability to handle such wastes without
disintegration, corrosion, fire, explosion, etc. Based upon compatability
testing with materials on site, materials are routed to appropriate
storage and treatment areas. This testing is performed by graduate
chemists in our modern and well-equipped on site laboratory. Observations
as to exothermic or endothermic reactions, vapor releases, spontaneous
ignition, corrosivity, are made. Submitted and performed an!aysis
results are reviewed so that disposal can be made in accordance with
applicable municipal, State and Federal regulations.
V-40
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22
Security
A security system is in-place at the plant 24 hours a day to prevent
accidental or intentional entry into the plant, that could lead to sabotage,
vandalism, theft, or some other illegal act, that would result in a
release of a hazardous or toxic substances into the environment.
The plant is located in an isolated area of the Township bounded on one
side by farmland. The plant is separated from the farmland from a six-foot
high fence. On the west side of the plant is Racoon Creek. Deliberate
boat entry is a possibility, by way of Racoon Creek, but past experience
has shown this highly improbable. The entrance gate of the plant is
1000 yards from Highway 322, so that random vehicular traffic is eliminated.
The security guard maintains gate control and constant vigilence. All
persons and vehicles desiring entry to the plant must be interviewed by
the guard, sign in to the plant when entry is allowed, display a visitor
pass at all times, and sign out when business is completed. A security
patrol of the entire facility is made several times each shift on a
guarded schedule. Visual inspections and environmental incident observations
are a major part of this patrol.
Television monitoring of the plant is planned and will be implemented by
Lighting is maintained at the facility round the clock with auxiliary
lighting provided at crucial building points in the event of a power loss
A loudspeaker system is deployed throughout the plant, in addition to
the telephone system. In the event of detection of dangerous intruders,
and others remote contact and warnings can be made.
A list of emergency numbers is posted around the plant both for security
and environmental incident control.
Our security personnel are an important part of the BMPP. All security
personnel undergo two weeks basic plant orientation in material handling,
transfer and process operations. They are then, through this training program,
detailed orientation to the visual inspection program, and constructive
interactive on the job training* prepared to assist the BMPP.
V-41
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ENVIRONMENTAL INCIDENT CONTROL COMMITTEE
INCIDENT REPORT .
WORKBOOK
CASE NO.
SOURCE OF INCIDENT
LOCATION OF INCIDENT
DATE OF INCIDENT
.REPORTING UNIT
(Name & Location)
REPORT INCLUDES:
/ / STATEMENTS
/~7 PHOTOGRAPHS
/ / SAMPLES
OTHER (Specify)
Signature of Reporter
V-42
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INSTRUCTIONS
Items usually most vital to this investigation have been numbered. A
check mark should be entered in the box preceding a numbered item only
if that item is applicable and if the conditions found are pertinent. .
Do. not check the box if the item does not apply or is incomplete. Either
strike out the item or place an M/A (not applicable) opposite it. Do not
check the box if you found the item doubtful. Instead state the reason on
the blank page opposite the item. The blank page should also be used for
amplifying information.
This workbook, when completed, will become part of the case file with
the Immediate Internal Environmental Incident Report Form.
V-43
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INVESTIGATOR
1. / / Name of Investigator
/7 Rank, Rate
2. / / In my opinion the degree of impact of this incident is:
/ / Potential
/ / Negligible
/ / Slight
/ / Moderate
// Heavy
/ / Total Destruction
/ / Affected Areas Already Badly Polluted
3. / / Signature of Investigator and Date Signed
v-44
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A. DISCHARGE
1. / / Date Time Group
2. / / Location (Enter Opposite)
/ / Latitude/Longitude
/ / Area-Block
/ / River Mile
/ / Other (specify)
3. / / State
4. / / Water Body (Enter Opposite)
5. / / Source (Describe Opposite) or Suspected Source
6. / / Cause (Describe Opposite) in as much detail as possible
7. / / Operation (Describe Opposite)
/ / Transfer / / Incinerator
/. / Tank Cleaning ' / / Treatment Operation
/ / Pumping / / Other (specify)
8. / / Material
/ / Description of Materia.l- or Chemical
9. / / Quanity (Units).
/ / How Determined (include color, dimensions, odor)
10. / / The quanitity was sufficient to create a visible sheen, sludge or
emulsion on or under the surface of the water.
11. / / Operation Suspended (specify opposite the identity of the person
suspending the operation)
12. / / How did pollutant enter the air/water? Include map or sketch.
V-45
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D. RESPONSE
1. // Removal Initiated By
2. / / Time to Response . " hrs.
3. / / Removal was/is proper
4. / / No Response (specify reason opposite)
5. / / Immediate Internal Environmental Incident Report Form Completed
on Timely Basis
/ / Yes / / No
Explain '
V-46
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E. OTHER PERSONS' INVOLVED
/ / Identify All Opposite
o Name
o Address
o Telephone Number
o Relationship to Spill
o Position and Department
o Statement Taken
V-47
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F. OBSERVERS
1. / / Identify All Opposite as Appropriate
o Name
o Address
o Telephone Number (Business and Residence)
o Occupation/Employer
.0 Statement Enclosed?
V-48
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G. FACILITY DATA
1. •/ / Identify Opposite
o Name
o Address
o Telephone Number
2. // Type of Process
3. / / Owner(s)/0perator(s) (.identify Opporsite)
o Name
o Address
o Telephone Number
4. / / Person-in-Charge (Identify Opposite)
o Name
o Address
o Company Title
o Relationship to Incident
5. / / Operations Manual Available
V-49
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H. PHOTOGRAPHS
1. / / Photographs's Location
/ / Number
/ / Name of Photographer
/ / Photographs Available At
2. / / Date and Time of Photographs _
3. / / Photographs
/ / Long Range
/ / Short Range
/~T Color
I~~J Black & White
/ / Direction of Object From Lens
4. /J Shutter Speed
5. / / Type of Film
6. / / Lens Opening
7. / / Camera Used (Describe Opposite)
8. / / Description of Photograph
V-50
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I. SAMPLES
1. / / Samples Taken (List Opposite)
/_"~_/ Number
/ / Source
/ / Identification
2. / / Time and Date of Samples (List Opposite)
3. / / Heather Conditions Affecting Samples (Describe Opposite)
4. / / Samples Taken By
5. / / Samples Available At
6. / / Person Witnessing Sample Taking
L. SPILL INVESTIGATIVE RESULTS
L. SPILL INVESTIGATIVE RESULTS
1. / / Corrections to BMP (Describe Opposite)
2. / / Cost of BMP Correct!on-
3. / / Implementation Schedule
V-51
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M. REMARKS AND NARRATIVE OF EVENTS
V-52
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BMP CASE HISTORY
New Jersey Zinc Company
Palmerton, Pennsylvania
The New Jersey Zinc (N.J.Z.) Division of Gulf and Western Natural
Resources Group operates two plants in the Palmerton vicinity, a West Plant
built in 1898 and an East Plant built in 1910. The East Plant is located on
the south bank of Aquashioola Creek, about 2 miles upstream of the confluence
with the Lehigh River. This facility produces metallic zinc, zinc oxide,
cadmium, ammonia, sulfuric acid, carbon dioxide and indium. N.J.Z. employs
about 1500 people and operates 24 hours per day, 365 days per year.
Operations began at the East Plant in 1913 and since then, approximately
33 million tons of process residue (slag) from both the East and West Plants
have been deposited near the East Plant.
Receiving Water:
Aquashioola Creek originates about 6 miles east of Palmerton and flows
southwest to the Lehigh River. The creek is classified as a trout-stocking
stream which requires protection for the following uses in addition to
coldwater species: warmwater fishes; potable, industrial, livestock,
wildlife and irrigation water supply; boating, fishing, water contact sports
and esthetics. Water quality criteria applicable to Aquashicola Creek
include arsenic, coliform bacteria, IDS, DO, heavy metals, phenolics and
temperature. The criterion for zinc is £ 0.01 of the 96 hour LC50.
Stream Characterization:
There were significant contributions of zinc, cadmium and manganese to
Aquashioola Creek in the reach from Harris Bridge to the 6th Street Bridge,
V-53
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Ui
POHOPOCO
CREEK
AGGREGATES
IELD BRIDGE
TATION
BRIDGE
HARR
BRID
AQUASHICOLA CREEK
?)6TH STREET
BRIDGE
Figure 1
New Jersey Zinc East and West Plants
Aquashicola Creek and Lehigh River
Palmerton, Pennsylvania
Key:
NEIC Sampling Station
8)USGS GAGE STATION
(WALNUTPORT)
-------
located just downstream from the East Plant. Zinc and cadmium loads each
increased about thirty times in this reach, while manganese increased
sevenfold.
Most of the zinc and cadmium load was contributed to Aquashicola Creek
by groundwater and runoff sources. Only 18 and 8 percent, respectively, of
the total contribution of zinc and cadmium to Aquashicola Creek was due to
direct East Plant discharges. The remaining 82 and 92 percent contribution
of zinc and cadmium was due to non-point contributions between the Harris
and 6th Street Bridges. Most of the zinc enters the creek upstream of the
Field Station Bridge. However, most of the cadmium enters the creek between
the Field Station and 6th Street Bridges.
Higher zinc and cadmium levels were determined on the Cinder Bank side
of the creek. No significant metals concentrations were found in Mill
Creek, indicating that the runoff and groundwater from the drainage area on
the north side of Aquashicola Creek is relatively metal-free.
Particulate erosion from the Cinder Bank and the East Plant site
further increases cadmium, zinc, manganese, lead and copper levels in
Aquashicola Creek.
Metals contributed to Aquashicola Creek in the reach adjacent to the
Cinder Bank and the East Plant had a negative impact on water quality,
resulting in imbalanced aquatic communities. Benthic macroinvertebrate and
periphyton numbers and varieties were reduced, as was the survival of test
fish.
Effluent Characterization:
The only East Plant discharges that contributed significant amounts of
metals to Aquashicola Creek were Outfalls 001 and 011. The combination of
these outfalls accounted for 93 and 90 percent, respectively, of the zinc
and cadmium discharged. However, as was noted in the stream characterization
V-55
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conclusions, the total of all East Plant discharges accounted for only 18
and 8 percent of the zinc and cadmium contributions to the creek. The
remainder is attributable to non-point sources.
The acidic wastewater generated in the Acid Department is treated with
lime in the Waste Acid Treatment Plant. The neutralized waste is sent to
two thickeners, which discharge the sludge into two sludge lagoons. The
sludge, containing 50 to 60 percent water, is taken from the lagoons and
stockpiled outdoors in the southeast part of the East Plant used for storing
raw materials. The storage area has not been lined to prevent infiltration,
however, the area has been diked with the sludge itself to minimize runoff.
Currently more sludge is being stored than is recycled, therefore, the
solids are also being stockpiled on the Cinder Bank. The sludge contains
high concentrations of metals removed in the neutralization process. The
supernatant from the sludge lagoons is discharged to the sewer terminating
at Outfall 001.
During normal production periods of acid plant operations, the net zinc
and cadmium concentrations of Outfall 001 averaged 3.2 mg/1 and 0.08 mg/1,
respectively. During decreased production periods, the water quality at
this outfall was significantly affected. Metals concentrations and loads
during the normal production period were from two to ten times greater than
during decreased production periods.
The manual pH control system at the waste acid treatment plant effluent
was completely inadequate, resulting in numerous and severe fluctuations in
pH at Outfall 001. There were a total of 105 excursions outside the range
of 6.0 to 9.0, in times ranging from 1 to 432 minutes. These excursions
occurred more frequently and for longer periods when production was at
normal levels. Instantaneous pH measurements outside the 6.0 to 9.0
range occurred 25 percent of the time.
Outfall 001 was acutely toxic to rainbow trout. The primary toxicant
appeared to be dissolved zinc. Excessive pH variation probably accelerated
test fish response to dissolved zinc concentrations.
V-56
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Outfall 011 drains shallow groundwater from the waste sludge storage
area and other parts of the East Plant with a potential for metals contam-
ination. Since Outall 011 contained an average cadmium concentration of
0.75 mg/1, the highest detected during the study, it is apparent that the
shallow groundwater in this area of the plant was severely contaminated.
Zinc concentrations in Outfall 011 were also very high, averaging 66 mg/1.
This discharge was acutely toxic to rainbow trout. The primary toxicant
appeared to be dissolved zinc.
There were no significant levels of pollutants found in permitted
discharges 002-005, 012 and 014-016.
Cinder Bank Evaluation:
The Cinder Bank lies between the East Plant and Blue Mountain and is
composed of slag, cinders, briquettes and miscellaneous debris associated
with the smelting and refining of zinc and cadmium ores. It is estimated
that the Cinder Bank contains between 30 and 35 million tons of residue.
The Cinder Bank has been contoured to a slope approaching 2 to 1 which is
unstable. Additional contouring is required to stabilize the slopes and to
transport runoff from the Cinder Bank as quickly as possible.
As a result of either incomplete quenching or spontaneous combustion,
large portions of residue smolder continuously. Occasionally large blocks
of residue break off of the main mass of the Cinder Bank and tumble down the
steep north slope toward Aquashicola Creek. In areas that have not been
physically disturbed, large cracks develop, and as they develop, steam and
smoke issue from them leaving sublimated yellowish deposits on the adjacent
surfaces. These cracks and resulting broken rough surfaces provide avenues
for rapid infiltration and percolation of rain and snow melt, and facilitate
leaching of soluble constituents from the Cinder Bank.
Because of this, the company has attempted to isolate Blue Moutain
runoff from the Cinder Bank but with little success. Pipes were placed at
the surface discharges of two rills to convey this water over the Cinder
V-57
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Bank. The pipes on top of the Cinder Bank froze, split and were not repaired.
As a result, the water flows into the Cinder Bank.
The company has also been experimenting since 1976 with various grasses,
trees, plants, etc., to develop a revegetation program from the Blue Mountain
area behind the plant; the natural vegetation has been destroyed by plant
air emissions. The area requiring vegetation is estimated to be between
1100 and 1200 acres.
To date, technology has not been developed which would allow for the
economic recovery of the metals from the residue. Approximately 3.5 million
tons of residue has been recovered by contractors since 1957. The residue
has been reused by cinder block manufacturers or is used for cindering icy
roads by highway maintenance departments.
Data from samples of Blue Mountain runoff and seeps and springs at the
base of the Cinder Bank show clearly that cadmium and zinc are being leached
from the Cinder Bank and contribute to the contamination of Aquashicola
Creek.
Zinc concentrations in waters passing over or through the Cinder Bank
increased significantly. The high concentrations of zinc in runoff and
seepage from the east end of the Cinder Bank contributed to significant
increases of zinc in Aquashiciola Creek. In this area, zinc concentrations
increased from background levels ranging from 0.27 to 0.67 mg/1 in Blue
Mountain runoff, to values generally greater than 17 mg/1 and as high as
230 mg/1 in Cinder Bank runoff and seepage. Increases in Cinder Bank runoff
in cadmium concentrations were also highest in this area.
Groundwater at the East Plant was contaminated by zinc and cadmium
leaching from the Cinder Bank and the raw materials and waste sludge storage
areas. Zinc was detected in all 7 wells sampled, and cadmium was detected
in 4 of the 7 wells. The highest levels of both metals were detected in
shallow wells designated as Stations 93 and 94, where zinc and cadmium
concentrations ranged as high as 3.2 and 0.024 mg/1, respectively. The
V-58
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locations of these wells between the raw materials storage area and £quashicola
Creek suggests that the source of the metals is the raw materials storage
area. Similarly, the presence of as much as 78 mg/1 zinc and 0.77 mg/1
cadmium at Station Oil suggests severe contamination of the shallow aquifer
draining fron the waste sludge storage area. Groundwater from the deep
wells at the west end of the plant is much less susceptible to metals
contamination than are the shallow wells.
Note; The facts of this case were extracted frcm a report prepared by the
National Enforcement Investigations Center entitled "Evaluation of Runoff
and Discharge frcm New Jersey Zinc Company".
Requirement
1) Develop a BMP Plan for New Jersey Zinc. Mdress the waste treatment
facility, sludge disposal area and cinder bank.
2) Draft suitable language to include as a permit condition for NJZ.
V-59
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WORKSHEET
V-60
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ER-BWQ-15.1 9/78
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
BUREAU OF WATER QUALITY MANAGEMENT
WATER QUALITY MANAGEMENT PERMIT - PART 1
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT NO. PA 0012751
In compliance with the provisions of the Clean Water Act, 33 U.S.C. 1251 et. seq.
(the "Act") and Pennsylvania's Clean Streams Law, as amended, 35 P.S. Section 691.1 et.
seq., -
G. & W. Natural Resources Group
New Jersey Zinc Division
Fourth Street and Franklin Avenue
PaLrerton, Pennsylvania 18071
is authorized to discharge from a facility located at
Borough of Palmerton
Carbon County
to receiving waters named
Lehigh River and Aquashicola Creek
in accordance with effluent limitations, monitoring requirements and other conditions set
forth in Parts A, B, and C hereof.
This permit shall become effective on January 16, 1980 y . ' : . . "
Tt . •• • ... .... . . -
This permit and the authorization to discharge shall expire at midnight, Dec. 31, 1980
The authority granted by this permit is subject to the following further qualifications:
1. If there is a conflict between the application, its supporting documents and/or
amendments and the standard or special conditions, the standard or special
conditions shall apply.
2. Failure to comply with the rules and regulations of the Department or with the
terms or conditions of this permit shall void the authority to discharge given to the
permittee by this permit.
[Original Signed By
v PERMIT ISSUED BY 6EORGE L PAR*S
lieorge LI.
DATE January 2, 1980 TITLE Regional Water Quality Manager
V-61
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. , PARTC Pa9e 31 of 34
* • • " ,
OTHER REQUIREMENTS
1. The permittee must conply with Pennsylvania's Clean Streams Law.
2. The permittee shall monitor the intake water sources concurrently and on the
sane basis as the effluent where limitations are on the permittee's addition of
pollutants to the wastewater (i.e. net discharge). The intake water sources
are as follows: . •
•
a. For all outfalls except 005, 007, and 009 the existing water supply intakes
from the Aquashicola and Pohopoco Creeks.• •
b. For outfall 005, in addition to the existing water supply intake, at the
terminus of the mountain drainage ditch leading to 005.
• c. For outfalls 007 and 009, in addition to the existing water supply intake
at the terminus of the Palmerton Borough's storm sewer.
3.. The discharge limitations specified are under dry weather flow conditions and
are net values unless otherwise specified.
4; The permittee shall not be considered in violation of the gross oil and grease
limitations specified if the permittee demonstrates to the satisfaction of the
issuing authority that the non-compliance was the result of background conditions.
5. The discharges to the Aquashicola Creek and the Lehigh River.
a. During the period February 15 to July 31 shall not raise the temperature
of the receiving stream when the ambient stream temperature is 74 degrees F
or above and not more than a 5 degree F rise above ambient temperature
until the stream temperature reaches 74 degrees F.
b: During the remainder of the year, shall not raise the temperature of the
receiving stream when the ambient stream temperature -is 87 degrees F or
above and not more than a 5 degree F rise above ambient temperature until
the stream temperature reaches 87 degrees F.
c. Shall not change the. temperature of the receiving stream by more than
2 degrees F during any one hour period.
'», The ambient temperature of the receiving stream is considered the temperature of
the water body upstream or outside of the influence of a heated waste discharge
or waste discharge complex. The ambient temperature sampling point should be
unaffected by any sources of waste heat. ••
7. The permittee shall institute a comprehensive program for monitoring, analyzing
and evaluating the wet weather discharges from outfalls 001, 005, 009, and 015
• to develop a data base correlating the quantities of contaminants discharged
under wet weather conditions with time, the runoff flow rate, precipitation
rate, and the drainage area served by each named outfall. The data shall include,
v-62
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PARTC Page 32 of 34
OTHER REQUIREMENTS
but is not limited to, the analysis of samples obtained under both dry and wet
weather flow conditions. Samples collected under wet weather flow conditions
shall be analyzed for zinc, cadmium, lead, and"total suspended solids. An
interim report on the program, including all data, shall be submitted to.the
; • Department of Environmental Resources, Reading Regional Office, by January 23,
1980, and a final report submitted by August 1, 1980. The interim report shall
• include a discussion and evaluation of the results and findings of the program
to date, and if applicable, recommendations for improving the data collection
• and analyses efforts. The final report, in addition to all collected data,
shall also include the evaluation of treatment facilities and/or methods, in-
cluding cost data, required to reduce contaminants in the wet weather runoff
flows to acceptable levels for discharge. The contaminants discharged under
wet weather flow conditions in the remaining outfalls shall be estimated'using
the data obtained for the above named outfalls.
8. Runoff from Plant Site
a. The permittee shall control runoff frcm raw materials and sludge storage-
and handling areas as follows:
(1) Divert runoff from plant site around raw material, waste acid sludge
storage and handling areas.
(2) The contaminated water frcm the raw material 'and sludge storage and
handling areas shall comply with the effluent limitations and
monitoring requirements set forth in Part A-l of this permit.
b. The permittee shall also perform an assessment-of the effect of raw material
storage and sludge storage areas on the ground water.
9. Cinder Bank Control Program • .
The permittee shall control the discharge frcm the cinder bank by:
a. Commencing reclamation of a 40 acre area identified in the attached map as
Zone A by January 30, 1980.
(1) A bed of high lime Waelz kiln residues at the base of the cinder bank
including the outer face -of the 40 acre area shall be laid.
(2) Spread, grade and contour the entirety of Zone A. over the bed of high
lime residue.
(3) Apply sewage sludge at a minimum rate of 65-dry tons per acre to the
surface of the graded and contoured materials within Zone A. Lime
or V7aelz kiln residue shall be mixed either below or within the sludge
layer in the upper layers of Zone A. Zone A shall initially be seeded
by September 1980. •
V-63
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• * ' PARTC Page 33 of 34
OTHER REQUIREMENTS
(4) The discharge of runoff and seepage shall be monitored by grab samples
once per week at the parshall flume at the West end of Zone A commencing
immediately. ' - " . . .
(5) The discharge; as measured at the flume, shall comply with.the following
effluent limitations by September 1, 1981:
. Monthly .' Daily
• Average Max.
Parameter mg/1 mg/J
Total Zinc 5 10
Total Lead 2.5' 5.0
Total Cadmium 0.5 1.0
Total Iron 1.5 3.0
Total Suspended Solids 25 50
Selenium 5 10
Arsenic 0.1 0.2
(6) If the discharge does not comply with the effluent limitations, the
permittee shall treat the discharge or implement alternate program
to achieve compliance by July 1, 1984.
b. The springs at the extreme east end of the bank shall be diverted by July 1,
1980, to minimize discharge from the cinder bank.
c. The permittee shall submit a plan by July 1, 1980, to the Control Agency
to minimize the discharge of contaminants on the Aquashicola Creek. The
plan shall contain:
(1) Assessment of the discharges from various segments of the cinder bank.
The efflunet limitations in Requirement 9A (5) shall be used in the
assessment. • .
(2) Prospects and proposals for resource recovery through reprocessing,
commercial reuse and/or use as an energy source including estimates
of quantities and a time schedule.
(3) Alternative methods for minimizing the discharge of the cinder bank.
The methods shall include, but not be limited to, collection and
treatment of runoff and seepage and reclamation of the areas.of the
cinder bank other than Zone A.
(4) Evaluation of springs, rills and seeps on the cinder bank and their
effect on the contaminant level.
(5) Contingency compliance program for Zone A in the event that program for
achieving compliance for Zone A be inadequate.
V-64
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PARTC
Page 34 of 34
OTHER REQUIREMENTS
10. The permittee shall achieve cotpliance with #8 and' #9 in accordance with the
following schedule:
: a. For Zone A '
(1) Commence laying bed of high lime kiln residue by January 31, 1980.
(2) Commence spreading, grading and contouring of cinder bank by April
1, 1980.
(3) Complete sludge application and initial seeding by September, 1980.
Feseed as required by September 1981.
b. Submission of Assessments
(1) Submit cinder bank plan by July 1, 1980.
(2) Submit assessment of .effects of raw material storage, handling and
waste sludge by July 1, 1980.
11'.. This permit shall be modified, or alternatively revoked and reissued to comply
with any applicable effluent standard or limitation issued or approved under
Sections 301 (b) (2) (C), and (D), 304 (b) (2), and 307 (a)' (2) of the Clean
Water Act, if the effluent standard or limitation so issued or approved:
(1) Contains different conditions or -is otherwise more stringent than any
effluent limitation in the permit; or
(2) Controls any pollutant not limited in the permit.
The permit, as modified or reissued under this paragraph, shall also contain
any other requirements of the Act then applicable.
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BLUE. n O U M ' T A 1 W
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BMP CASE HISTORY
Kalama Chemical Incorporated
Kalama, Washington
Kalama Chemical (K.C.) in Kalama, Washington is situated along the
north shore of the Columbia River. K.C. operates a toluene processing plant
to refine toluene into other usable chemicals. The plant has the capability
to unload tank ships carrying toluene for processing. The bulk liquid is
stored in a 3,360,000 gallon full-capacity tank located about a quarter of
a mile from the unloading pier. For plant usage toluene is transferred from
bulk tank #70 to plant tank #42 along the pipeline indicated in the diagram
(see Figure 1).
Spill Event:
On November 19, 1979 at around 1:30 a.m., K.C. started an internal
transfer of toluene from tank #70 to tank #42. Intended transfer was to be
approximately 700,000 gallons of toluene. The duration of transfer was
about 31 hours, with the transfer completed around 8:30 a.m. on November 20,
1979. Fifteen minutes later an unusually high concentration of toluene
fumes was noticed at the pump house. It was discovered that there had been
a large land spill of toluene at the sump transfer area. The sump is
located about 20 yards from the north shore of the Columbia River.
K.C. determined that the cause of the spill was a 3/4 inch hydrostatic
test valve, for the pier piping, which had been left open during the transfer.
This valve is normally blind flanged shut but had been opened and used by
the Operations Department to empty the line running from the pier to the
main transfer header to permit maintenance to conduct a hydrostatic test on
November 1, 1979. The Maintenance Department performed the test in a proper
V-67
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KALAMA CHEMICAL
Sump
Pipe Line Lengths in ft,
Headers to T-70 1580
Headers to T-42 390
Headers to T-l 530
COLUMBIA RIVER
Headers for
unloading
FIGURE 1
V-68
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manner; that is, obtained a line opening permit, installed blind flanges,
tested and drained the section of pipe, removed the blind flanges, and
closed the entry permit. The Operations group was at fault since the group
did not remove the pump out connections and close the valve after preparing
the line for maintenance. This open valve was overlooked during the
start of the toluene transfer.
The toluene fron the open valve spilled into a pit approximately 9 feet
wide by 12 feet long. The pit has cinder block walls and a sand bottom,
having an area of roughly 100 square feet. The toluene leached through the
bottom of the pit and dispersed into the sand stratum of the pump house area
seeking a low point which was the river. By taking tank readings, the
amount of toluene unaccounted for and presumed to have leaked through the
valve was determined to be 67,498 gallons.
Transferred from T-70 = 784,372 gallons
T-42 Received = 716,874 gallons
Unaccountable = 67,498 gallons
During the 31 hours of transfer, the pump house, which is within 50
feet of the site of the leak, was inspected on three different occasions; at
9:00 a.m. and 6:00 p.m. on the 19th and 5:00 a.m. on the 20th. At no time
were toluene fumes noticed. Since the drain valve involved is located below
ground level in a valve, box, the leak was not sighted.
Spill Cleanup Procedure:
Once the spill had been discovered, the roads leading to the dock were
barricaded, T-70 and T-42 were gauged, supervision was notified, and the
control roan phone was restricted with instructions for all incoming and
outgoing calls to go 'through the switchboard.
The U. S. Coast Guard was notifed of the spill at 10:50 a.m. The delay
came about as a result of making sure the area was secure. Western Environmental
V-69
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Service (WES) was notified at 1:00 p.m. The delay in notifiying WES was due
to a lack of communication between the Production Superintendent and the
Shift Supervisor.
The spill cleanup began at about 1:15 p.m. By November 26, 1979 at
about 9:00 p.m., K.C. stated that approximately 8,250 gallons of toluene had
been recovered from the Columbia River. Over the six day period, the net
amount entering the river averages to 1,375 gal/day which is in violation of
the FWPCA since the net amount far exceeds the 216.66 gal/day limit imposed
by Federal regulations.
After November 26, 1979, K.C. began pumping toluene from ground wells.
This greatly reduced the toluene leaching info the river. However, toluene
continued to leach into the Columbia River at a small rate until January 30,
1979. The substance was too dispersed to be recovered and evaporated
shortly after entering the river.
Requirement;
1) What do you consider the cause(s) of the toluene spill at Kalama
Chemical?
2) Develop BMPs for Kalama Chemical to address the toluene storage and
transfer operation.
V-70
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WORKSHEET
V-71
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WORKSHEET
V-72
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SANITARY DISTRICT OF ROCKFORD
INDUSTRIAL TOXIC SPILL DETECTION
AND
CONTAINMENT AT THE WASTEWATER
TREATMENT PLANT
Richard W. Eick
Plant Operations Manager
August 29, 1980
V-73
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Exhibits
I Industrial Spill Reporting Procedures
II Technicon Cyanide Analyzer
III Spill Containment Procedures
Tables
I A to BB Summary of Plant Influent Grab Sample Analysis
II List of Treatment Plant Valve Numbers
III Summary of Phase Allocation
1 Wastewater Treatment Plant Site Plan
2 Influent pH Acid Dump
3 Influent pH Alkaline Dump
A Cyanide Analyzer Flow Diagram
5 Cyanide Slug of February 20, 1980
6 Allocation of Slug by Phases
7 Phase 0 - Normal Plant Process Flow Diagram
8 Phase I - Spill Containment in the Trickling Filter Final Tanks
9 Phase II - Spill Containment in the No. 1 Chlorine Contact Tank
10 Phase III - Spill Containment by Solution Displacement in Primary
Tanks 1, 2, 3, and 4
11 Phase IV - Spill Dilution through Primay Tanks 7,8, 9, and 10
12 Phase V - Spill Dilution through Primay Tanks 5, 6, 7, 8, 9, and 10
V-74
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I. Introduction
The Sanitary District of Rockford Wastewater Treatment Plant has been re-
ceiving shock and slug loads of industrial toxic pollutants for over 15
years. There has been some progress over the years at reducing the frequen-
cy of such shock loads, but there now seems to be a plateau of little pro-
gress. In fact, the frequency may be increasing because of the passage
recently of the Resource Conservation and Recovery Act by the United States
Environmental Protection Agency. These RCRA regulations place stringent
controls on how industry may dispose of their toxic industrial wastes and
and it may be easier to dump these down the sewer than to comply.
It is the District's hope that any intentional slug or accidental spill will
be detected before it enters the treatment plant process and causes damage
to equipment, process or employees. This early warning of a toxic spill may
come from industrial notification or wastewater treatment plant influent
monitoring on a continuous basis using pollutant monitors such as pH meters
and cyanide analyzers, etc. If a shock load of a toxic pollutant has reached
the treatment plant, (Figure I) procedures within the plant must be put into
action to minimize the detrimental effects on plant process and the environ-
ment in general. These best management practices (BMP) for publically owned
treatment works have been proposed by the USEPA.*
"These best management practices include spill prevention control
and counter-measures plans required by section 311(j). POTW's
will be required to plan for such discharges and develop best
management practices in advance for dealing with reported spills.
Once best management practices are incorporated into the POTW's
• permit, failure to implement applicable practices upon learning
of a spill to its sewers could subject the POTW to an enforcement
action under section 309."
The intent of this report is to outline best management practices that can
be used by the District personnel to control a toxic slug load as it is re-
ceived at the wastewater treatment plant.
II. Determination of a Toxic Slug Load.
Before District personnel can begin to control a toxic slug load in the
wastewater treatment plant, it must be determined that one is in the sani-
tary sewer in transit to the treatment plant or that one is just beginning
to enter the treatment plant. This toxic slug load can be determined in
several ways as given below.
A. Industrial Report of an Accidental Spill of a Toxic Waste
Rockford industry has been notified of the District's toxic spill
reporting procedures (See Exhibit I). The theory is that when an in-
dustry has an accidental spill of a toxic waste, it should be reported
as soon as possible, hopefully before the slug has reached the waste-
water treatment plant. With this information as reported, the plant
operators can begin spill containment procedures. To date spill re-
porting has been only mildly successful as only 23 reports have been
-Federal Register, 44 FR 10271; February 16, 1979; "EPA Proposed Rules for
Reporting Hazardous Substance Spills under the Clean Water Act."
V-75
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-2-
turned in since April 1979. All of these toxic spills were only of
limited volume or concentration and therefore, did not have an impact
on the treatment plant. Some of the problems with spill reporting:
1. Industry does not report the major or significant toxic spills
for fear of reprisal.
2. Industry or other source will not report'intentional dumping of
a toxic wastewater. Locking manholes with continuous Sanitary
District sampling should help control this.
3. The industry may not determine that there has been a spill until
the following work day. By this time, it has probably passed
through the treatment plant. This problem could be solved with
mandatory industrial spill containment.
B. Sanitary District Detection
The District has some means of determining when a toxic slug load is
entering the treatment plant. Since 1977 the District has recorded 476
separate incidents of atypical plant influent wastewater characteris-
tics. These incidents could have been caused or initiated a grab
sample being taken because of any of the reasons as discussed below.
Table IA to IBB are a summary of these incidents and as can be seen
a grab sample was not taken of every incident. The maximum influent
concentrations sampled for toxic pollutants are as follows:
pH Maximum 10.0
pH Mimimum 3.6
Cyanide 4.12 mg/1
Copper 9.0 mg/1
Cadmium 1.25 mg/1
Nickel 1.7 mg/1
Chromium (total) 30.0 mg/1
Chromium (+6) 25.0 mg/1
Zinc 14.6 mg/1
Iron 181.0 mg/1
Lead 1.99 mg/1
Chlorides 444 mg/1
COD 835 mg/1
Manganese 1.03 mg/1
Conductivity 3,670 umhos/cm
1. Continuous Monitoring of Influent pH
The District has been using a Fischer-Porter recording pH meter
with high and'low alarm set points. This has been of limited
success, since there are so many wastewaters that are discharged
by industry that could have a high pH and yet not contain toxic
pollutants of significant concentration. As can be seen by ex-
amination of Table IA to IBB, there has been a wide extreme of
pH values as measured in the plant influent. Figure 2 is an ex-
ample of an acid dump as received at the treatment plant. The
influent began to drop at 7:15 p.m. on Sunday evening and remined
depressed until around 4:00 a.m. the next morning. Unfortunately,
V-76
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-3-
no samples were taken of this dump as the administration building
was unoccupied. In the new influent monitoring facility to be
located in the addition to the administration building, a sep-
arate Manning Automatic Sampler will be activated by the pH meter
(or other device such as the cyanide analyzer) to take a discrete
sample of any atypical influent wastewater. Figure 3 is an ex-
ample of some alkaline type dumps as received at the treatment
plant.
2. Continuous Monitoring of Influent Cyanide
The District has purchased and shall install by November 1980 a
Technicon continuous cyanide analyzer to monitor the plant in-
fluent on a 24 hour/day basis (See Exhibit II and Figure 4). This
instrument shall be located in the plant influent monitoring room
in the new administration building addition. This "Monitor IV"
will continuously analyze the plant influent and final effluent
for cyanide, record the concentration on a strip chart, and sound
an alarm for high concentrations. This high level alarm will be
wired in to the new main pump station and the aeration control
building. This will also activate the discrete sampler via a
relay to sample the plant influent for later laboratory analysis.
As will be seen later in this report, if the cyanide high level
alarm is activated, the plant operator on duty will varify that
a high cyanide shock load has reached the plant and will take
the necessary actions to contain the slug within the treatment
plant system.
3. Spill Detection by Observation
Some toxic spills of certain chemicals are obvious to human sen-
sors as they are received at the plant. Such characteristics as
odor, color, heavy suspended solids, and oil layers have been
observed by the plant operator and grab samples have been taken.
A classic example is a+hexavalent chromium dump which is yellow
in color. One such Cr slug was received at the treatment plant
on January 6, 1978 at 9:40 p.m. and was observed by one of the
plant operators. A sample was taken and analyzed to reveal a
total chromium concentration,-of 30.0 mg/1 and a hexavalent chro-
mium of 25.0 mg/1. This Cr dump resulted in a NPDES Permit vio-
lation of the District's final effluent.
Cr+6 0.60 mg/1 81.32 KG/day
(limit) (0.3) (51.2)
At the time of this dump, the District did not have spill con-
tainment procedures. (BMP)
III. Spill Containment and Control by the Wastewater Treatment Plant
As described in Section II, there are various methods of determining that a
shock load of toxic chemical is about to or has entered the wastewater
treatment plant. It is hoped that the combination of these methods will
catch the majority if not all of the toxic slugs before they can damage the
plant processes or cause an excursion to the District's NPDES Permit
V-77
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-4-
limits. The following procedures (BMP) should minimize the effect of a
slug load on the treatment and also the receiving environment. The proce-
dures that the wastewater treatment plant operators are to follow are out-
lined in detail in Exhibit III. Table II is the sluice gate number system.
These steps are labeled from Phase 0 to Phase V and are discussed in a
general way below.
A. Spill Determination - Phase 0
Phase 0 is the actual spill determination as described in Section II of
this report. Figure 5 is an example of a cyanide slug that was re-
ceived at the wastewater treatment plant and sampled on an hourly
basis. It is expected that the cyanide analyzer will produce strip
charts of a similar nature and would send out a high level alarm to the
plant operator. The time required for this analysis is approximately
30 minutes, which is shown in Figure 5. Figure 6 represents the allo-
cation of a typical slug of toxic wastes as it is received at the
wastewater treatment plant to the various phases of spill containment
by the treatment plant. The amount of slug represented by Phase 0 was
determined by dissecting the curve and weighing each phase. Phase 0
represents 17.1% of this type of toxic slug. The phase allocations are
summarized in Table III. The 17.1% for Phase 0 could be reduced to
zero if industry notified the District of the impending toxic slug
before it reached the treatment plant. Figure 7 is a flow diagram of
the wastewater treatment plant normal process flow.
B. Spill Containment in the Trickling Filter Final Settling Tank - Phase I
As soon as the spill is detected, the plant operators will turn off
the main pumps, change the flow pattern as given in Exhibit III, and
turn the pumps on again directing the toxic slug to the trickling fil-
ter final settling tanks. This Phase I will be able to contain approx-
imately 43.4% of the slug as shown in Figure 6. The plant process flow
diagram for Phase I is shown in Figure 8. This phase is a true con-
tainment since the trickling filter final settling tanks are empty to
be used for such an emergency. Once the plant has recovered from any
part of the slug that was not contained, the contents of those tanks
can be bled slowly back into the plant influent for treatment. Phase
I should capture the most concentrated part of the slug.
C. Spill Containment in the No. 1 Chlorine Contact Tank - Phase II
Phase II consists of directing the next portion of toxic wastewater
slug into the No. 1 chlorine contact tank as outlined in Exhibit III.
Phase II will contain approximately 7.4% of the slug and is also true
containment since this tank is normally empty. However, as the plant
influent flows approach the 60.8 MGD design flow, both of the chlorine
tanks will have to be utilized and this phase will not be used. How-
ever, until that time this spill containment as shown in Figure 9 can
be used. Again once the plant has recovered from any uncontained
spill, the toxic wastewater in the contact tank No. 1 can be bled slow-
ly back into the plant influent.
D. Spill Containment by Displacement in Primary Tanks 1, 2, 3, and 4 -
Phase III
V-78
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_c _
Phase III is spill containment by displacing the solution in Primary
Tanks No. 1, 2, 3, and 4 with the next part of the toxic slug (See
Figure 6 and Figure 10 for the flow diagram). Phase III should contain
about 12.8% of the toxic spill. In the following days, the trapped
portion of toxic slug in primary tanks 1, 2, 3, and 4 could be slowly
displaced into the treatment plant process.
After Phase III, the trickling filter final settling tanks, the No. 1
chlorine contact tank, and the No. 1, 2, 3, and 4 primary tanks will
contain some of the toxic slug. As can be seen by Table III, the to-
tal amount of toxic slug contained by these three phases is approxi-
mately 63.8%. Samples could be taken of this contained slug for anal-
ysis to help determine the kind and source of the toxic slug.
E. Diversion to Primary Tanks 7, 8, 9, and 10 - Phase IV
Phase IV consists of diverting the next portion of the toxic slug (see
Figure 6) to the primary tanks 7, 8, 9, and 10, which will then flow
into the activated sludge system. This flow pattern (see Figure 11)
is not a spill containment, but is only dilution in the four primary
tanks. However, this portion of the slug only represents about 9.6%
of the total slug.
F. Diversion to Primary Tanks 5, 6, 7, 8, 9, and 10 - Phase V
This Phase V consists of further dilution in a step wise fashion-by
opening primary tanks 5 and 6 (See Figure 12). This means that the
residual amount of the toxic slug will be directed to the activated
sludge system in a somewhat step wise fashion. Phase V amounts to
9.7% of the toxic slug and will be processed directly by the activated
sludge system after passing through the primary tanks.
IV. Conclusion
As can be seen, there are various methods of determining that a toxic slug
is about to enter the wastewater treatment plant. Once this is determined,
it is possible to contain within the treatment plant about 63.8% of the
slug, while 18.3% will be treated by dilution and 17.1% will be lost in the
initial detection if the cyanide analyzer determines the spill. However,
these best management practices should minimize the impart of a toxic spill
on the treatment plant and the environment.
V-79
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EXHIBIT I
3333 Kishwaukee Street • P.O. Box918 • Rockford, IL 61105 • 397-9700
TRUSTEES
Robert B. Stringer, President
William C. Geissman, Vice President
Clifford A. Nelson, Clerk/Treasurer
Arthur W. Anderson, Trustee
George Jackson, Trustee
OFFICIALS
Jon L. Olson, District Director
Kenneth D. Miller, P.E., Director of Engineering
H. Emmett Folgate, Attorney
Re: Hazardous Substance Spill Reporting
D-ear Sirs:
The following information should be reported to the Sanitary District
of Rockford when a hazardous substance spill has occurred and if it
will or has entered the sanitary sewer system. If you don't have
all the information, it is still important that a report is made as
soon as possible. Tell us what you do know about the spill. If we
k;,iow a slug load is coming some operating techniques can be set into
motion to help minimize the impact on the treatment plant systems and
the receiving stream.
Report these spills to the Sanitary District of Rockford Treatment
Plant using the appropriate telephone numbers as given in Table I.
Thank you for your cooperation.
1. Company name and address ?
2. Time chemical spill started and stopped to the best of your
knowledge.
Brief description of the spill.
a. How it happened ?
b. Volume in gallons ?
c. pH ? (Is it acid or caustic ?)
d. Is the spill flammable ?
4. Spill catagory (refer to Table II of Hazardous Substances which
is enclosed) .
Catagory: X
A
B
C
V-80
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-2-
: If the spill contains chemicals of more than one catagory,
report more than one catagory.
5. Name of person Sanitary District can call for more information
6. Telephone number of that person.
Sincerely,
SANITARY DISTRICT OF ROCKFORD •
Richard W. Eick
Plant Operations Manager
RWE/mp
cc: J. Olson
SDR Plant Operations
IEPA, Region I
File .
Snclos- re: 2
V-81
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/?•;
D^to:
April 2, 1979
Copies to: JB Qlson
File
TO: Plant Operator Foreman (E. Sarver, Q, Sickele, C. Kobischka, D. Ross)
and Plant Operators
FROM: x-M)^
Richard .W. Eick ^y" •
SUBJECT: Hazardous Substance Spill Reporting by ^ndustry
All of you are aware that the treatment plant occasionally receives slug dis-
charges of toxic industrial wastes, which can upset the activated sludge
system as well as cause violations of the District's final effluent liicitations
to the Rock River. In order to gain some control of this problem, Sockford
Industry will be asked to report any hazardous substance spill to the Sanitary
District. A copy of the letter sent to Rockfovtf Industry is -.enclosed. There
are several important things that you should i*ote; •
1. A spill of hazardous substance can oqcur at; any time of the night
»•-.. ..:/ or day. On the off hours, industry wj,ll be reporting to you. (See
Table I) " ' ' . ' '' '"~l ^
2. The industry will be asked to report :a pqe-farrang^d set of information.
This information should be recorded by yoij on the Industrial Spill
- Reporting forms.
3. Once you have the information recorded^, you will be required to
notify myself or one of three other supervisory personnel, (See
Table III)
A. Depending on the circumstances, a decisiorj will be made at this time
as to the best method of handling the hazardous substance spill in
the treatment plant. v
P17E/mp . • ' .' • ' ...',"
Enclosure: 2 .
V-82
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SANITARY DISTRICT OF KGCK.FORD
Industrial Hazardous Substance Spill Reporting Procedure
EXHIBIT I
co
DAY
Monday - Friday
Monday - Friday
Weekends or Holidays
TIME
8:00 A.M. - 5:00 P.M.
5:00 P.M. - 8:00 A..M. .
TELEPHONE
397-9700
397-9585
397-9421
397-9585
REPORT TO
Richard Eick 290
Bob Steidel 295
Don Clerico 293
John Blisk 230
Pat Howe 11 291
Plant Operator
Foreman
Plant Operator
on Duty
RWE/mp
3/22/79
-------
EXHIBIT I
DO
SANITARY DISTRICT OF ROCKFORD
INDUSTRIAL HAZARDOUS SUBSTANCES SPILL REPORTING PROCEDURE
JLnst>6TR\j
->
/—. R
V y-
To *<* O
RWE/mp
-------
EXHIBIT I_
SANITARY DISTRICT OF ROCKFORD
Industrial Spill Reporting Form
1. Company Name
Address
2. Tine chemical spill started and stopped to the best of your knowledge.
Started A.M./P.M. DATE
Stopped^ A.M./P.M. DATE
3. Brief description of the spill.
a. How it happened?
b. Volume? . gallons
c. pH? (acid or caustic)
d. Is it flammable? Yes No
4. Spill Catagory ? (Circle as appropriate)
X A B C D
5. Name of person Sanitary District can call for more information.
6. Telephone number of that person
SANITARY DISTRICT OF ROCKFORD INFORMATION
1. Name of person receiving the Industrial Spill report.
2. Time of call ' A.M./P.M. DATE
3. Remarks
(RETURN THIS FORM TO PLANT OPERATIONS)
RKE/ra?
4/2/79
V-85
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EXHIBIT II
?,'•' .'•;•" ;':~.i'f>yf3?;r« ••'•>!^^.;:T!^^'-~--i".sii553k-?.
TECHNICON INDUSTRIAL SYSTEMS/ A Division of Technicon Instruments Corporation, Tarrytown, New York / 914-fi3?-SOOO
AUTOMATED ANALYSIS OF TOTAL CYANIDE IN WASTE STREAMS
• Continuous monitoring for on-stream analysis
• Discrete sampling for laboratory applications
Cyanide compounds, such as sodium cyanide or hydro-
cyanic acid, arc widely used in industrial processes.
Cyanide waste streams result from a number of major
industries such as electroplating, synthetics manufactur-
ing, ore extracting and steel production.
The greatest problem in the analysis of total cyanide
is often the erratic and low recovery of complex metallic
cyanides and thiocyanatc by existing procedures
utili/ing colorimctric or ion selective electrodes.
Additionally, these methods result in imprecise measure-
ments at low levels.
The TechnicorTMonitor IV Cyanide Analy/er for on-
siream applications and the Technicon'"AutoAnlily/ei"ll
i intinuouvflow analytical instrument system for labor-
.iloiy usage overcome these major problems, yet remain
Ik'xihle enough to he adjusted to regulatory procedure
iei|uiiemails as they develop. The utili/alion of a
continuous UV digestion system* provides greatly
improved recoveries nl the complex cyanides that are
incompletely or poorly recovered hy present distillation
and ion selective electrode methods, especially where
metallic complexes are involved. Total recovery in iron,
silver and nickel now becomes a simple routine.
Example1, of lecoveries of such compounds are shown in
Tahle I.
An additional henelit of the UV digestion system is
its llexihility. Close correlation with current regulatory
methods (.is ol January 1973) may be accomplished by
simpK turning off the UV digestion lamp.
•d.iul.lon. f'.U. Aluh.in U.K.and BiooksljJiik, P., An.ilv. Chem.,
44. IMS. (1'iT.1).
Precision is greatly improved through the use of
automation.
The foregoing information applies to both the labor-
atory and on-stream instruments. A description of each
instrument follows:
• Laboratory Application
This unit employs standard Technicon AutoAnalyzer II
continuous-flow modules with a special cartridge con-
taining the UV digestion quartz coil and lamp. Auto-
matic distillation is provided following the UV digestion
step. Subsequent to distillation, the addition of chlo-
ramine-T and pyridine-barbituric acid reagent or
pyridine-pyrazolone reagent provides conversion to
cyanogen chloride which with the pyridine-barbituric
acid or pyridine-pyrazolone form a red complex
measured at 570 nm in a phototube colorimeter.
As with all AutoAnalyzer II Laboratory Systems,
the same basic instrument can be utilized for many other
water parameters in addition to cyanide, such as
nutrients, phenol, chromium, COD, etc.
• On-Strcam Application
The Monitor IV is designed for continuous on-line
monitoring of waste water before and/or after waste
treatment to remove cyanides "amenable to chlorina-
tion". The UV digestion step is again utilized and a
gas-permeable membrane is used instead of distillation to
separate the liberated HCN gas from the interferences.
While recoveries of some metallic cyanide complexes are
less than with the AuloAnalyzcr II they are still superior
to the manual method not utilizing the UV step. The
Monitor IV unit can also be converted to perform other
analyses if required. Maintenance for'the Monitor IV is
minimal.
Section of Monitor IV showing the combined UV diges-
tion system and appropriate manifolding used to
monitor total cyanide.
V-86
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EXHIBIT III
SANITARY DISTRICT OF ROCKFORD
INDUSTRIAL TOXIC SPILL CONTAINMENT BY
THE WASTEWATER TREATMENT PLANT
Phase 0 Spill Determination
Sanitary District of Rockford detection or notification by industry of a
toxic spill.
Phase 1^ Containment of Raw Sewage Flow in the Trickling Filter Final Tanks
(1) Turn off raw sewage pumps.
(2) Close valve #15 and 16.
(3) Aeration operator to perform the following:
(A) Turn off flights in final tanks.
(B) Turn off return sludge pumps.
(C) Shut off chlorination.
(D) If necessary, turn off aerators.
(4) Open valve #6.
(5) Open valve #10.
(6) Open valve #13 and 14.
(7) Turn on raw sewage pumps.
(8) Allow trickling filter final settling tanks to fill within 1 ft. of the
weirs. This will take approximately 1 hour.
(9) Turn off raw sewage pumps.
(10) Close valve #10.
Phase I_^ Containment of Raw Sewage Flow in Contact Tank #1.
(1) Open valve #17.
(2) Close valves 20 and 21.
(3) Open valves 18 and 19.
Start Pumps.
Allow contact tank #1 to fill to approximately 1 ft. of overflow. Contact
tank capacity is 838,000 gals. At 1.5 MG/hr it will fill in approximately
35 minutes.
(4) Turn off pumps.
Open valves 20 and 21.
Close valves 18 and 19.
Close valve #17.
Close valve #6.
Open valves #15 and 16.
Pliaso III Containment of Raw Sewage Flow in Primary Tanks 1,2,3, & 4.
(1) Close valve #8.
(2) Close valve #7.
(3) Rend and record raw sewage totalizer.
(4) Start the necessary pumps.
(5) After pumping approximately 2MG to primaries 1,2,3, and 4 turn off pumps.
Approximately 1.3 hours @ 1.5 MG/hr.
Phase 1_V Diversion of Raw Sewage Flow to Primary Tanks 7,8,9, & 10
(1) Close valve #9.
(2) Open valve #8 to primaries 7,8,9, and 10.
V-87
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EXHIBIT III
(3) Turn appropriate pumps on and pumps 2MG (approximately 1.5 hr.).
(4) After pumping approximately 2MG (read totalizer, open valve #7 a_t the
Marshall Flume.
Phase V Diversion of Raw Sewage Flow to Primary Tanks 5,6,7,8,9, & 10
(1) Open valve #7 at Parshall Flume and put flow to primaries 5 and 6 (IMG)
Continue to operate as such until the contents of the trickling filter tank
and primary tanks 1-4 are analyzed and until the Activated sludge system has
recovered from any pollutant load that was not contained by the waste water
treatment plant. Additional instruction will come from Plant Operations re-
garding the procedures to follow in the days immediately following the Con-
tainment of a toxic spill.
RWE/DC/ra
8/18/80
V-88
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VI. LITERATURE ARTICLES
How One Chemical Company is
Attacking the Spill Problem
A New Pair of Eyes
Guidelines for Chemical Plants in the
Prevention, Control, and Reporting of Spills
Prevention and Control of
Chemical Spill Incidents
Best Management Practices for
Control of Toxic and Hazardous Materials
-------
How One Chemical
Company Is
Attacking the
Spill Problem
L. E. CARLSON, J. F.ERDMANN,
and G. J. HANKS, JR.
Union Carbide Corporation
Chemicals and Plastics Division
South Charleston, West Virginia
Texas City, Texas
INTRODUCTION
In recent years, as the country's concern for envi-
ronmental problems grew, the subject of chemical
spills has received increased attention from the public,
the regulatory agencies, Congress, and industry itself.
Because of dissatisfaction with the number of spillages
at its manufacturing plants, Union Carbide's Chem-
icals and Plastics Division, in May 1972, appointed a
chemicals spills study team under the direction of the
division's environmental protection manager.
In its charter, the team was instructed to
1. Make a detailed survey of the principal causes of
chemical spills at the company's manufacturing
and transportation sites.
2. Investigate the types of equipment used to effec-
tively prevent, reduce, or contain spills.
3. Identify effective training and other procedures
that encourage employee attention to the prob-
lem and prevent spills.
4. Make recommendations of the types of facili-
ties, procedures, and training which the company
should provide to minimize the possibility of
chemicals reaching waterways as a result of a
spillage.
This paper presents the results of that study, and the
progress made in implementing the team's recom-
mendations at one of Union Carbide's largest facili-
ties—its organic chemicals and plastics manufactur-
ing plant at Texas City, Texas.
THE CHEMICAL SPILLS
STUDY TEAM
Study Team Findings and Recommendations
The team began its work by assembling data on re-
ported losses of chemicals to the ground, waterways, or
to a waste treatment plant at nine of its principal manu-
facturing plants. It was apparent that not all spills were
well documented, and that each plant had different cri-
teria for what should be reported. However, with 545
spill reports that covered the period of January 1971 to
April 1972, it was believed that their data would be
representative of the problem.
A review of these reports showed that on a fre-
quency basis 58% of the spills were caused by human
error and 42% by mechanical failure of equipment. A
more detailed study of the mechanical failures revealed
that about half could be attributed to human error,
such as faulty design, wrong construction materials,
improper maintenance, and so on. Thus human fail-
ure of some sort probably was responsible for up to
80% of the spills reported.
These findings on the causes of spills are consistent
with the experience of others in the chemical industry.
Conversations with technical experts in other com-
panies generally confirm these data, and one of the
presentations at the 1972 National Conference on
Control of Hazardous Material Spills reported that in
a detailed study of 60 major chemical spills, 60% were
attributed to human error.
The study team knew that each Union Carbide plant
considered the control of spills to be a serious prob-
lem, and most had their own ongoing programs for
spill prevention, detection, and control. Each plant has
its own unique problems caused by location, products
line, topography, proximity to waterways, age of the
facility, and its physical layout and drainage plans. The
experiences, practices, and ideas of these plants, and
of others outside Union Carbide, collectively formed
the foundation for the recommendations of the study
team.
The principal recommendations of the study team
were grouped in the areas of prevention, detection, and
106
VI-1
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ONE COMPANY'S ATTACK
107
containment and control, and are summarized in the
following sections.
Spill Prevention
At present, the ability to remove or counteract most
chemicals spilled to waterways is poor at best. There-
fore, the greatest potential for minimizing the effects of
spills, and the most productive, is with a strong pre-
vention program. In general, such a program would
consist of determining where the weaknesses are and
improving personnel training, operating procedures,
and facilities accordingly. The following should be
considered in such a program:
1. Vulnerability survey. An examination of the
facilities and procedures and operating history of a
manufacturing plant or distribution terminal to deter-
mine how well it can prevent, detect, and control spills,
with the objective of correcting weaknesses identified.
Areas to be examined for potential spills or material
losses would include:
1. Transfer, loading and unloading facilities; and
the related procedures for moving chemicals to
and from storage tanks, trucks, rail cars, and
marine equipment
2. Sources of process upsets, and process startup,
shutdown and cleanup procedures
3. Equipment and storage tank diking, surface
drainage routing, and sewer system layout
4. Past history of individual departments with spill-
ages, the clarity of their operating procedures,
availability of information regarding the charac-
teristics of the chemicals handled, and their con-
tingency planning
New facilities should be reviewed in the design phase
and during construction for minimization of spill-
vulnerable sources.
2. Personnel training and orientation. Programs to
upgrade the interest, motivation, and skills of the
supervisory and work forces aimed toward conduct-
ing their tasks spill-free. Strong, continued emphasis
on the part of plant management is necessary for a suc-
cessful program, much as is the case with plant safety
programs.
Commitment must exist at all levels, by the depart-
mental supervisor as well as by the person who can ac-
tually cause or prevent a spill. The study team sug-
gested several programs that plants might consider in
this phase of activity and that might be adapted to a
plant's or individual department's needs:
1. Adoption of standardized written procedures,
with appropriate personnel training and periodic
review, for all routine phases of plant operation
2. Job procedure analysis and analysis of job in-
structions for identification of spill potential
3. Encouraging use of unsafe condition reports by
employees as a vehicle to point out spill potentials
4. Development of a spill reporting form for all
spills, large or small, of any materials, and
whether or not they reach a waterway; investiga-
tion and review of all significant spills, with the
objective of preventing recurrence
5. Establishment of periodic inspection procedures
for dike valve conditions, transfer station valves,
and so on
6. Conducting of spill containment drills
7. Use of flyers or bulletins to publicize spill in-
cidents or "near misses," or typical unsafe condi-
tions that employees should be alert for
8. Communication of new ideas on spill control
9. Use of slogans, posters, and so on to maintain
employee interest
10.Publicizing of plant and department spill-free
performance
II.Use of plant manager editorials in plant
newspaper, and regular emphasis on the im-
portance at employees' and supervisors' meetings
Obviously, many of these suggestions are techniques
that have been used successfully in company safety
programs. The similarity of the need for employee
attention to spill prevention is apparent.
3. Facilities and procedures. Special emphasis was
given to suggestions for procedures and to layout and
equipment features that are desirable, particularly
those for areas where materials are loaded, unloaded,
transferred, or stored.
Special attention was given in the team's report to
marine loading and unloading because of the com-
pany's extensive use of ships and barges for movement
of chemicals. The matters covered were too numerous
and specific to repeat here, but included such items as:
1. For marine facilities: mooring practices, boom-
ing, dock design, hose systems, catch or drip
pans, collection systems, curbing, spill con-
tingency equipment, preferred valve types, equip-
ment blanking practices, lighting, barge design,
loading logs, and communication systems.
2. For in-plant process and transfer equipment:
operating procedure recommendations, piping
and valve identification to service, capping or
plugging of drain valves and vent valves, hose
connection design, lighting, and winterizing
practices.
3. For storage tank areas: the practice recom-
mended is for diking to contain the contents of
the largest tank within the diked area, with dike
VI-2
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108
PREVENTION
valves maintained normally closed. Features for
a storage area and its dike, piping, pumping, and
instrumentation system were recommended.
4. For tank-car and tank-truck loading and unload-
ing facilities: these facilities were not found to
have been a frequent source of spills. However,
they do have potential for serious spills, so several
recommendations were made including vehi-
cle positioning and inspections, procedures to
keep equipment from being moved during load-
ing or unloading, equipment design features,
and instrument and employee monitoring of
operations.
Detection and Identification of
Materials Spilled
Efforts in this area fall into three classes: instru-
mentation, human vigilance, and procedural
techniques.
Instrumentation to detect the presence of chemicals
in water is generally expensive, but can be readily
justified to monitor waste treatment plant influent, and
major plant cooling water and surface drainage dis-
charges. Union Carbide had adopted the use of con-
tinuous total carbon analyzers for this purpose, with
telemetering to the appropriate operator stations. At
some plants, chromatographs are on standby to
identify materials that cause a peak in the analyzer out-
put. Other instruments that have been used success-
fully for spill detection in specific installations are pH
meters and hydrocarbon vapor analyzers. The study
team recommended that the company's instrument
specialists search for or develop a low-cost instrument
for detection of parts per million concentrations of or-
ganics in water. Such an instrument would make it
possible to vastly extend instrument monitoring. Other
types of instruments are used for prevention of spills.
Among these would be such devices as liquid level con-
trollers and alarms, valve position indicators, and
equipment running lights.
Obviously, however, one of the most effective detec-
tion devices is the alert human being. As mentioned
earlier, continual effort should be made to keep
employees aware of their obligation to prevent and
stop spills. Prompt action by employees can do more
than any instruments in keeping a minor spill from be-
coming a major incident. Similarly, there are certain
job procedures that can be used which will reduce the
likelihood of spill, and others which can help detect
that one has occurred. Some of the former were dis-
cussed under Spill Prevention; however, some that can
aid in spill detection include frequent inventory and
process efficiency checks, and monitoring material
transfers at'both the pumping and receiving ends.
Spill Containment and Control
Plant contingency planning is vital and, of course,
must be supported by proper equipment at proper
locations and by trained personnel. In addition to
overall contingency planning for the total plant site,
contingency planning on a department basis within the
plant was recommended by the study team. Such
plans should be written out, well understood by the de-
partment's personnel, and updated as necessary. They
should include such matters as:
1. Reporting requirements: how and whom to
notify to obtain prompt and proper help and how
to document the incident later
2. Steps to take to keep the chemical spilled from
reaching a waterway, or overloading a process
waste water sewer
3. Data on the toxicity, solubility, flammability,
and reactivity of materials being handled
4. Inventory of spill contingency equipment and
where it is located
5. Procedures for handling water-soluble and in-
soluble chemicals, and other chemicals which re-
quire special consideration
In addition to internal reporting procedures, the
around-the-clock plant supervision should clearly
understand external reporting needs, both those re-
quired by regulatory agencies as well as those to be fol-
lowed in good industrial citizenship. Information on
these requirements should be readily accessible to
supervisors along with lists of appropriate names and
telephone numbers. Each plant should also be pre-
pared to assess the impact or hazards of a specific spill,
should it reach a waterway. Expert opinions by a
plant's technical experts can be invaluable to a regula-
tory agency in determining response steps or in al-
leviating the agency's and the public's concerns.
SPILL CONTROL PROGRAM
FOR TEXAS CITY PLANT:
IMPLEMENTATION AND RESULTS
Texas City Location Facilities
The Texas City plant of Union Carbide's Chemicals
and Plastics Division is located about 40 miles south-
east of Houston out the Gulf Freeway toward
Galveston (Fig. 1). Two separate but interconnected
facilities are located in this area: the production plant
area (about 400 acres) on the western end of the Texas
City industrial area (Fig. 2) and the marine terminal
area (about 150 acres), which is an extension of the
Texas City Harbor along the west shore of Galveston
Bay (Fig. 3).
VI-3
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ONE COMPANY'S ATTACK
109
TEXAS CITY PLANT
MARINE TERMINAL
" „.,•»,•.-•' x- ~*s- --
Fig. I. Union Carbide Corporation chemicals and plastics facilities, Texas City location.
/. Plant area. The plant area is the site of a series of
coordinated processes using natural gas and refinery
concentrates as basic raw materials for producing re-
fined ethylene and other reactive hydrocarbons. These
purified materials are then used as starting materials
for various organic chemicals and plastics, such as
alcohols, ketones, aldehydes, esters, amines, glycols,
polyethylene, vinyl resins, and so on. Except for poly-
ethylene and vinyl resins, all other products manufac-
tured here are either completely water soluble or
enough so to be unrecoverable if they become mixed
with large volumes of water. Thus materials lost to a
drainage or wastewater system in the plant through un-
planned or accidental episodes are irretrievable in most
cases. These losses become part of the waste load going
to the wastewater treatment system, although, by our
definition, they are technically spills.
In the plant area a gravity sewer system has been
provided to collect and transfer dilute process waste-
water to several pump houses which conduct the
wastes to a treatment facility. In addition, a network of
surface ditches extends throughout the plant to collect
rainwater runoff. Over the years, as more production
processes were added and the plant area expanded,
VI-4
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110 PREVENTION
.;.. ,'
Fig. 2. Union Carbide Corporation chemicals and plastics manufacturing plant. Texas City, Texas.
both systems became interconnected so that consider-
able process wastes commonly have been discharged to
the surface ditches and relatively little distinction in
usage was understood by plant personnel. During dry
weather conditions this intermixing of ditch and
gravity sewer streams was of no consequence, since the
ditches were connected to the same pump houses as the
gravity sewers and the combined streams flowed to the
primary treatment area. However, during periods of
even moderate rainfall (over 1 in. in 30 min.), rain-
water would flood the ditches beyond the pump house
capacities and the excess water would be diverted into
local drainage canals through designated outfalls (Fig.
4). These rainwater outfalls were modified with con-
crete retaining dams fitted with slide gate valves that
were kept closed during dry weather but could be
opened for rainwater release (Fig. 5).
After installation of the gates, several incidents
occurred in which organic materials from the ditches
were discharged in slugs during rains into the canals,
and some localized fish kills occurred in the canals.
This led us to devise a segregation plan for the plant to
separate process wastes and rainwater. A plantwide
series of surveys, area by area, was initiated to remove
the process waste sources flowing to the ditches and to
divert rainwater drains out of the gravity sewers
wherever the chances were low for rainwater con-
tamination. Engineering work and Held modifications
recommended by these surveys were well underway
when the spill program was initiated. As a conse-
quence of the arrangement and operation of these
plant collection systems, the plant itself experienced
few spill losses to any outside drainage system, and
then only if the spilled material had contaminated a
VI-5
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ONE COMPANY'S ATTACK
III
Fig. 3. Union Carbide Corporation chemicals and plastics marine terminal facilities, Texas City, Texas.
drainage ditch which was being released during a
rainstorm. Thus the plant was considered a moderate
risk for external spills, although an unacceptable
amount of materials was being lost to the waste
treatment system inside the plant.
2. Marine terminal area. The marine terminal
handles barge and tanker shipments on the waterways
with minor connecting tank truck and rail tank car
transfer facilities. A large number of chemical storage
tanks are joined by various pipelines to the production
and raw material storage areas of the plant.
Here at this terminal there is presently no intercon-
nected system of ditches and underground sewers as
described for the plant. Most of the waste collection
has been done by isolated collection sumps with
vacuum truck pickup. Recently, these facilities be-
came overtaxed and contributed to increased spill inci-
dents and other malfunctions. Normally, transfers of
liquid products between fixed and mobile containers,
coupled with the close proximity of the tidal waters in
the turning basin and ship channel leading to
Galveston Bay, greatly increase the vulnerability for
spills into the navigable waters. The same water-
solubility characteristics of the products handled here,
as in the plant, result in poor possibility of recovery of
spilled materials from the waterway in this location.
Thus the marine terminal was considered an area of
very high spill risk and was selected as the highest
priority target for the spill control program (See Fig. 6
for a general plot plan of this area).
Spill Prevention and Control Program
After the spill study team report had been reviewed,
the Texas City plant manager indicated his under-
standing and acceptance of the report recommenda-
tions by appointing a plant spill prevention team to
VI-6
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112 PREVENTION
I H[ • Ji| S*ii 4
Fig. 4. Dilute waste and rainwater flow diagram, Texas City plant. Union Carbide Corporation.
chemical spills to the lowest possible size and fre-
quency, thereby reducing costs arising from: (a) loss of
chemical materials and/or property, (b) cleanup
operations, (c) liabilities incurred 10 others, and (d)
fines and penalties."
For our purposes, the following definition was com-
posed: "A spill is any liquid or solid chemical which is
not where it belongs for its proper use at the time." This
was further developed into a go-no go chart to help
operating and maintenance personnel with their day-
to-day activities (Fig. 7).
An appropriate footnote was added to this chart to
include as spills any materials that are intercepted by
impoundments or eventually reach the plant waste
collection systems. Such losses historically have made
up a large fraction of the reported or detected in-plant
spills, and we believe a large number of the unreported
ones as well. The major thrust of the in-plant program
has been to reduce these losses which have been fairly
common, but sometimes difficult to detect. Also, any
incident involving a mixup of materials during transfer
is considered a spill, with the "loss" being the sum total
of the mixed materials.
2. Program principles. The basic principles for the
Texas City program follow closely those described
earlier under the recommendations of the Study Team.
Briefly, they are: Spill prevention, which includes the
vulnerability surveys, personnel training and orienta-
tion, and improved facilities and procedures; detection
and identification of materials spilled; and spill
containment and control, including reporting
Fig. 5. Rain water outfall retaining wall with slide gates.
adapt the report recommendations to the local facili-
ties, including the marine terminal. Three persons were
assigned to the team: one was a former member of the
spill study team and a supervisor at the marine
terminal, the second was a shift supervisor with many
years of operating experience in all plant areas (who
was designated the spill coordinator), and the third was
the environmental protection coordinator with a
knowledge of the plant waste systems and enforce-
ment agency requirements.
/. Program objective. The principal objective for
the plant program was: "To reduce losses from
VI-7
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ONE COMPANY'S ATTACK 113
Fig. 6. Plot plan, marine terminal, Texas City, Texas.
procedures. A fourth item, performance evaluation,
was included at the Texas City plant as a vital feed-
back feature to show how well the program was
working. Several factors were considered in this area:
I. The number of vulnerability surveys completed
and adequately acted upon in terms of projects
and completions.
VI-8
2. The number and seriousness of spills reported via
the hazardous incident form, with a review of fol-
low-up actions and expected reduction in
vulnerability.
3. The number and seriousness of spills not reported
by the designated procedure, which are detected
by in-plant monitoring and observations.
-------
114 PREVENTION
I* Loss
Due To
Process
Design?
Did Materia
Reach
Navigable
Waterwayor
Tributary?
Materials which may be contained or impounded or
which may reach process sewers or surface ditches
are also classified as spills if they meet.above
Fig. 7. What is a spill?
4. A spill index devised to report the magnitude of
both reported and unreported spills in relation to
the total organics in the plant wastewater collec-
tion system. This index is somewhat like the com-
parison of lost time accidents to toal manhours
worked in our safety department.
3. Program Implementation
a. Personnel. The three-man spill prevention team's
activities became closely involved with other indi-
viduals and groups in the plant as the program evolved.
In the operating areas, production supervisors were
assigned by their department heads to work with the
spill coordinator, particularly on vulnerability surveys.
The engineering department assigned a group leader
and several engineers for projects stemming from the
survey recommendations. Support for the program
resulted from the commitment of the plant manager's
department through the line organziation to produc-
tion and maintenance department heads, the shift or-
ganization, and auxiliary groups throughout the plant.
b. Vulnerability surveys. This involved a unit-by-
unit review of 24 separate production, distribution,
and supporting areas. Each survey was initiated by the
spill coordinator working with supervisors from that
particular area as assinged by the department heads.
The survey was organized to uncover certain basic
weaknesses related to the risks of spills happening in
the facilities being inspected. These survey factors were
presented previously as major items under the spill
prevention heading.
A set of recommendations for corrective action was
developed as part of each survey and sent to the de-
partment head for his evaluation. Subsequent confer-
ences with each department resulted in agreed-upon
'action to be taken. Relative priorities were established
within the department for the various changes. As the
surveys continued, another system of priorities with
the engineering department developed on a plant scale
as project work initiated by the department heads
began to accumulate. Vulnerability surveys were
scheduled with the highest risk ones first, so that the
first projects requested of engineering would be the
most important. As a natural consequence, funding
and -construction follows so that the most vulnerable
situations are the first ones corrected.
c. Personnel orientation. Communicating the pro-
gram to plant personnel was accomplished in a step-
wise manner, starting from the plant manager's group
and progressing completely into the operating, main-
tenance and service departments to all hourly
personnel who handled chemical materials in any way.
The program consisted of: (1) program introduc-
tion, "OOPS" film from ORSANCO, and explana-
tion of the vital need for improvement at this location;
(2) review of the vulnerability survey program,
emphasizing purpose and content; (3) hazardous
incident reporting, explanation of new form and
procedure, with anticipated follow-up results; (4)
weekly bulletin board cartoons, "OOPS" flyers; (5)
highlighted items in weekly environmental protection
VI-9
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ONE COMPANY'S ATTACK
115
department report; (6) timely "Forecaster" (plant
newspaper) articles; (7) "we care" buttons awarded to
individuals making timely spill reports and
suggestions.
Questions and comments were encouraged from all
these groups, so that any suggestions could later be
brought up during the particular surveys as they were
being conducted. The revisions for the plant's hazard-
ous incident report form were being developed at this
time also, and helpful suggestions were offered to lend
support to this critical link in the system (Fig. 8).
The development of strong motives in plant
personnel to improve the prevention of spill incidents
was considered one of the most important long-term
factors in the program. Accordingly, we took a posi-
tive position which assumed that intelligent, well-
trained people, working with equipment designed to
cope with all required operations and most con-
tingencies, could prevent a large fraction of the spill
incidents. The program was begun with emphasis on
the seriousness of the problem and requested their par-
ticipation in helping to determine how to achieve the
necessary level of improvement. It was indicated that
the vulnerability surveys were designed to show weak-
nesses in facilities or procedures, which, when
corrected, would provide far better tools for their use.
An additional training factor considered valuable is
the follow-up to hazardous incident reports by which
causes, effects, remedies, and prevention methods can
be aired with the participation of those who have been
closely involved with problems.
d. Facility improvements. As previously mentioned,
one of the major objectives of this program is to
provide adequate facilities for dealing with situations
that cause spills. The vulnerability survey for existing
facilities is the initial step in that direction, but addi-
tional support for improvement projects is expected
from recommendations made as a result of hazardous
incident investigations. Furthermore, as an indication
of concern by some supervisors, several projects were
voluntarily initiated by individuals for particular
improvements in their areas of responsibility even
before we had completed the surveys.
In the past few years a number of older facilities have
been eliminated from the plant and new improved
processes are beginning to appear. Of great im-
portance in minimizing the environmental effects of
new facilities is a formalized review procedure
required by Union Carbide and which continues
through the conceptual, design, and construction
|.hases of a project. Emphasis is on reduction of pro-
cess wastes; however, adequate treatment of residuals
must be assured. Provision for spills control is
included, and is usually designed to fit into the
particular site requirements.
Program Status and Results
By the end of March 1974, all 24 areas into which the
plant and marine terminal were divided had under-
gone vulnerability surveys. These were conducted in
order to relative importance in terms of assumed risks,
based partly on spill reports at the start of the program
and partly upon general knowledge of the process
areas.
Recommendations in the completed vulnerability
surveys so far have resulted in one project for the entire
marine terminal for an estimated cost of $ 184,000 and
16 additional projects in the plant totaling about
$720,000. There are still almost an equal number to be
initiated.
To illustrate the sort of changes these projects call
for, following is a partial list of items included in the
marine terminal survey recommendations:
1. Assign an engineer full-time from the marine
terminal staff to work cooperatively with the
engineering department to design and imple-
ment the changes needed for the terminal
facilities.
2. For each dock handling liquid products, install
complete collection pans connected to a sump
and collection system.
3. For docks handling polyethylene pellets and
vinyl resins, install solid flooring with curbing.
4. Grade inside all diked areas to drain to the dike
valve, clean and repair drain systems and install
"elephant trunks" on the outside of dike drain
lines.
5. Install slide gates in all surface ditches from
operating areas leading to the water's edge to
serve as a backup impoundment for diked areas,
sumps, and transfer stations.
6. Relocate all tanks, pumps, and sumps involved in
cleaning barges and tankers far enough away
from the edge of the water so as to obtain
adequate spill protection.
7. Renew all tank and line identifications, includ-
ing pumps and transfer stations, to minimize
mixups.
8. Design a gravity sewer system for waste streams
throughout the terminal area completely
separated from surface drainage ditches, with
provisions for treating impounded rainwater if it
becomes contaminated.
Incident reports. The results of spill reporting ex-
periences are summarized in the chart on page 117.
Since strong emphasis was not previously placed on a
spill control program, the incidents and amounts of
materials reported for 1972 are considered only to be
those that had to be reported because too many people
knew about them. We believe that less than half of the
VI-10
-------
116
PREVENTION
»« INCIDENT IS AN UNPLANNED EVENT
THAT CtUStS INIUKT 01 LOSS OF
P»OPt«TV OK MATERIALS.
Tern City Plant 515
IEPORT INCIDENTS INVOlVINg SIIIOUS INJURYLOSS
OF 1100 01 MORE. OH IHICH MERIT INVEST 1GATION.
THIS SECTION TO BE COMPLETED BY PERSON REPORTING INCIBFMT
TYPE OF INCIDENT
(Ctlack Thou
L_|IN)URY UJEOUIPMENT DAMAGE C-JMU-UPOF FIIOOUCT
JlOSS OF PRODUCT
I POLLUTION-SPILL
I T IME
Hilt OF PERSON MiHINt
LOCATION
DESCRIPTION OF INCIDENT:
C«USE OF iNCintNT: (Cincn Thou »oollc«bl«l
CD
y>IHTF»lirf »tPtl«/IHST»LHTION
OPERtTING iBBOR
IUMSAfE >CT
UESIION»BL[ PBOCtSS/COMTBOL DESIGN
L»C« OF ROUTINE SURVEIll«NCE
I niir»T|QM>BLE lit CN/ELt CTR I C»l DESIGN
DEFECTIVE EQUIPMENT/COMPONENT
U»«
INSTRUMENT/CONTROL N»L FUNCT I ON CjF«U.TO IOLLH» S»f C T t P ROC£OU«E
CORROSION/E»OSION/F»TI6I1E/1E>« D OlttiB
HOI COULD IT H»E BEEN PREVENTED?
I UNO DIRECTION
I WIND SPEED
I TEMP.
ROUTI COPItS TO:
OEPT.HEtO CONDUCTS BEYIEW. COMPLETES SECTION 2, MAKES 2 MORE
l.dhll.)
OtHRTMENT MOO
COPIES » DISTRIBUTES COPIES «S fOLLO»S:
i.(Creen)
SNIFT SUPT.
i.ttal lo»)
COPT I-DEPT.HEAO RETAINS ONE COP« FOR BULLETIN OOARO/FILE
lAFETt » ENVIRON. AFFAIRS
COPY 6-ROUTES TO:MAHACERS OEPT./SAFETY t ENVIRON. AFFAIRS
9. (toll))
RETAINED IT ORieiNATOB
COPT T-80UTES T.O SHIFT SUPT/OR I6INATOR
THIS SECTION TO BE COMPLETED BY DEPARTMENT HEAD
DESCRIBE TOUR OASIS FOR ESTIMATING ACTUAL LOSS
PREVENTIVE ACTION: »NAT ADDITIONAL ACTION IS PLANNED TO AVOIO FUTURE INCIDENTS OF TNIS TTPE? INCLUDE OOTN IMMEDIATE AND
LONC RANGE PLANS. STUDIES. ASSIGNMENTS. ETC. RESPONSIBILITIES? COMPLETION OATES? (OR CHE C»: CUoOES NOT 1ABB.AHT FURTHER
ACTION) CONOITIONS ARE NOi SUCN THAT A REPEAT OF THIS INCIDENT IS:CZZIvERT IUELY. CZ3«EDUCEO IN PROOAOILITY.
CDNOT
lUMttHll
IN AOIITION t« TMt AM»i »TIM - A OITtUtl INttlTIIMHN II RltM»IIN»l>:
. 8/1/73
CT 1411-I
Fig. 8. Hazardous incident report.
VI-11
-------
ONE COMPANY'S ATTACK 117
1972
Marine Terminal Area
Incidents reported 8
Organics spilled, 55,000
gal (eslim.)
1972
Plant Area
Incidents reported 32
Organics spilled, 123.200
gal. (estim.)
1st
Half
9
38,000
(a)
1st
Half
44
30,000
1973
2nd
Half
14
10,000
(b)
1973
2nd
Half
43
53,000
Total
23
48,000
Total
87
83,000
TBXA,m CITY PLA.NT
XOTA.L
40
HO
aSeveral over 5,000 gal.
hOne about 2.000 gal., rest less than 300 gal.
actual incidents were ever formally reported and that
at least double this amount of organics was actually
lost.
The sharp increase in reported incidents in 1973
reflects the emphasis placed on the new spill control
and reporting procedures and the results of providing a
new and more appropriate reporting form. Later in
1973, reduced numbers of incidents, and particularly
smaller amounts of material lost in the later incidents,
indicate that more care and attention was being
exercised by people in the operation areas (Fig. 9). As
added incentive at the Marine Terminal, during the
second half of 1973 federal fines totaling $8,000 were
paid in penalty for spills which were self-reported or
discovered jointly by Coast Guard and Carbide per-
sonnel in 1972.
A, M J J *•
MONTH OP Y«A.»
Fig. 9 Chronological chart of reported spill incidents.
f
Fig. 10. Elephant trunk for tank farm dikes.
VI-12
-------
118 PREVENTION
The amounts of materials spilled is not indicative of
losses which reached the waterways since many of the
materials were intercepted and recovered, burned or
treated in plant waste treatment lagoons. Vacuum
trucks have become an important tool in our waste-
handling operations and are quite useful for quickly
collecting impounded materials in such a way that
some materials can be recycled and reprocessed, or at
least used for fuel in a boiler house. M ixups are also in-
cluded in these totals, and these are sometimes fully
recoverable.
Solution to a special problem. There have been a
number of large spills in which a storage tank inside a
dike overfloweed, but the dike drain valve had been left
open and the overflowing materials were lost to the
receiving waters. Dike drain valves cause many
problems because they are often hard to operate, get
plugged with shell or sand, and may be located in
remote and inaccessible places. In addition, it is
sometimes difficult to tell by looking whether a valve is
open or closed, and it takes time to check out the valves
in a whole tank farm.
A simple effective device was suggested by one of the
environmental protection supervisors to provide a sure
indication that no liquid could flow from the diked
area without anyone going near the dike valve. The
"elephant trunk" attached to the outside of the dike
drain line provides this security (Fig. 10). When the
hose is hung on the post, the top is above the dike top
and thus even with an open valve, no liquid can es-
cape. For draining rainwater from the dike, the hose is
dropped into the ditch. For removal of a spill, the hose
can be coupled to a vacuum truck. For draining of con-
taminated rainwater, the hose can be dropped into an
adjacent catch basin to a gravity sewer system leading
to waste treatment facilities. All installations must re-
tain the conventional metal gate valve as backup in
case of fire.
VI-13
-------
A NEW PAIR OF EYES
WILLIAM B. KATZ
Illinois Chemical Corporation
Highland Park, Illinois
What If?
An "old" pair of eyes sees a pipe, with an inverted
"U" on the end, emerging through a roof, and the
bearer of those eyes thinks, "there's a tank inside the
building." (See Figure 1).
A "new" pair of eyes sees that same pipe, and thinks,
"WHAT IF?." Those two words are the difference
between an old and a new way of looking at familiar
surroundings. The new way is essential if an effective
job of spill prevention is to be implemented. (See Fig-
ure 2).
"WHAT IF ... the tank doesn't have a high level
alarm or cut-off?" the tank is full?" the high level
cut-off malfunctions?" a product receipt is delivered
into the wrong tank?" the tank and intake manifold
have no shut-off valves?" the tank is overfilled, and
product discharges onto the roof?" it's raining?" the
roof has a drain, and the downspout discharges onto
the roadway below?" the roadway has a storm drain?"
the storm drain leads to a storm sewer discharging in-
to the river?"
Assumptions
Let's start off with some assumptions. They may
not always be true, but hopefully most of them are.
1. Facilities subject to possible spills of hazardous
materials are operated by people, not impersonal cor-
porations. Those people like a clean and safe environ-
ment, just as much as the most vocal environmentalists
do. They like to be safe in their work, to have clean
areas to spend their recreational time, and they hope
their children grow up in a safe and clean world (among
other things).
2. Plants manufacturing hazardous materials have a
very good idea of the problems involved in handling
those materials, and do a fairly good job is seeing that
the obvious control measures are taken. Accidents cost
a lot of money, in lost material, lost time, bad public
relations, and in many other ways. In addition to be-
ing good citizens, the people who run those plants
don't like to waste money.
3. Plants using hazardous materials, especially those
using small amounts (quantities of perhaps a few drums),
often have a poor idea of the problems involved in
handling those materials. Personnel in such plants
need education in spill prevention. (It is primarily to
this audience that this paper is directed).
4. In both kinds of plants, it is the non-obvious
sources of spills that need recognition, that require a
"new" pair of eyes and a "what if" attitude. The best
tool, in addition to experience in looking for spill
sources, is an active imagination. Access to a good file
of reports of past spill incidents does not hurt a bit!
5. Spills are accidents; as in nearly all accidents,
there usually occurs a chain of circumstances culminat-
ing in the accident itself. The purpose of a spill poten-
tial survey is to determine the probable series of events
that could lead to a spill, and where best and how to
break that chain. Zero spill potential will probably
never be achieved.
6. Spill probabilities can only be "guestimated". If
a spill hazard exists and has been recognized at a facil-
ity, usually (but not always) some preventative meas-
ures have been taken. The remaining problems are al-
ready reduced to relatively low-orobability occurences.
7. A decision of what to do (how much money to
spend to reduce still further an already low probability
of a spill) is at best an informed guess. Everyone knows
that spills cost money, but never how much, so eco-
nomic justification of expenditures for spill prevention
is almost impossible. Decisions will often be based in
part on emotion and public pressure, in addition to
what is (hopefully) good engineering judgment.
8. No plant can afford to make all the changes nec-
essary, or to have all the men and equipment available,
to handle every possible accidental product spill. It be-
comes necessary to evaluate spill probabilities and
damage potentials and to make decisions based on
those evaluations, to determine what and how much
must be done. What is essential, in today's political,
legal, and ecological climate, is that what is done, or
not done, be a deliberate decision. No one can afford
to find himself in the position of undergoing a spill
and having to say "I didn't realize there was a hazard."
It is far better to be able to say "Yes, we realized there
was a hazard, but our study indicated the probability
of an accident was very small, and we did 'this' and
Copyright 1976 by Information Transfer, Inc.
Used with permission.
VI-15
-------
2 A NEW PAIR OF EYES
TANK VENT
t
r
TANK
n
Figure 1: What a Visible Roof Vent Indicates to an "Old" Pair of Eyes.
OUTFALL?
TANK VENT
ROOF DRAIN?
RIVER?
£1 f
HIGH LEVEL
CUT-OFF?
TANK
VALVE?
n
VALVE?
MULTIPLE TANK CONNECTIONS?
VEHICLE CONTACT POSSIBLE?
'n STORM DRAIN?
V STORM DRAIN?
STORM SEWER?
Figure 2: Some of the Things a Visible Roof Vent Indicates to a "New" Pair of Eyes.
i VI-16
-------
A NEW PAIR OF EYES
'that' to reduce the probability and determined that
further action was not apt to be any more productive
in preventing an occurrence than the things we did."
9. One final assumption (frequently not true, espe-
cially for small users of hazardous materials) is that
the physical and chemical properties of the materials
are completely known. Every user of a hazardous ma-
terial which might be spilled should be able to answer
questions like these:
Is the product soluble in water, or non-soluble?
Is the product heavier or lighter than water?
Is the product toxic? Flammable? Explosive?
;'s the product reactive? With what?
What special precautions are required in the event
of a spill, for on-scene personnel not involved in
clean-up? Is there danger to the public in the area?
Do clean-up personnel require special clothing, equip-
ment?
Answers to those questions should be obtained in ad-
vance of any incident, obviously, from the manufac-
turer, or through CHEM-TREC, or other source.
Regulations
The various laws and regulations governing spills of
hazardous materials are often unclear, general, and in
many instances (considering local, state, and Federal
regulations) conflicting. In some areas they are almost
nonexistant.
One might argue with some of the details of the Fed-
eral EPA rules on oil spills', with the specifics of the
SPCC (Spill Prevention, Control, and Countermeasure)
plan requirements. But the aim seems quite correct, in
that it focuses the attention of a facility operator on
prevention instead of an after-spill clean-up. It will
take a while for data to confirm a reduction in the
number of oil spills, as a result of the SPCC approach.
The apparent reduction in business volume of many
oil spill clean-up contractors seems to indicate that
there has been a reduction in the number of spills.
Reportedly, the SPCC approach will be used by the
EPA against spills of hazardous materials. Perhaps by
the time this paper is presented at the Hazardous Ma-
terials Conference in 1976, the regulations will have
been published.
Questions
The balance of this paper will indicate the kind of
questions one must ask in making a spill potential sur-
vey The list of questions is not complete—such a list
never can be. It is intended only to give the reader a
"new" pair of eyes.
There is also a brief discussion of the value of spill
cooperatives; the availability of trained personnel; spill
problems resulting from the transfer of hazardous ma-
terials via pipelines; the potential effect on spills of
poor communications; emergency notification proce-
dures; and public relations. Much of this is the person-
al opinion of the author, based on experience. All of
the discussion involves questions that must be raised
and answered in any complete study of the hazardous
material spill potential of any specific plant.
In general, discharges of product may result either
from normal operations or from accidents. A detailed
survey must list each and every possible source of a
spill, of any magnitude, from any source. Each such
possible spill source should be studied to determine
where it might flow, both under normal and abnormal
conditions, and how it could best be contained and re-
covered. Detection of such spills and the response time
to get men and materials to handle the spill frequently
will dictate whether equipment or construction changes
are required to lessen the chance of a spill getting out
of control, or whether confinement and recovery after
a spill occurs is a reasonable alternative to (frequently)
expensive process, equipment, or facility changes.
A. Spill potential from operations not in buildings.
1. Tank storage. Are all above-ground tanks diked?
Are there valved drains in the dikes which could acci-
dentally be left open? Are the drain lines protected
with counterbalanced swing arms on the outlets, or
with siphons with "breakers" or with a shut-off device
of some sort activated by contact with stored product?
Are the dikes of sufficient size to hold the entire con-
tents of a tank and strong enough (if close to a tank)
to withstand the force of the product emerging from a
rupture at one point in the bottom of a tank? Are the
dike walls far enough from the tank so a tank leak
higher than the top of the dike could not pass the dike?
Are the dikes in good condition, free of cracks or holes?
Is the piping to the tank inside the dike? Are the
pipes and the tanks themselves subject to vandalism or
sabotage? Could a leak caused by a sniper with a high-
power rifle be controlled? Is there any protection against
this? Can all piping leading to and from the tanks be
shut off at the tank by remote control if access is pre-
cluded by a leak? Are tank dikes and floors sealed
against product leaks? If not, would a large leak soak
into the ground or remain within the dike, on the sur-
face? If the dike is not floored, should it be, and what
provision can be made for removal of rainwater and
for small amounts of product which might accumulate
on or in such rainwater?
Are below ground tanks inspected at intervals for
leaks or corrosion? Do such tanks have cathodic pro-
tection? If a rupture occured in an underground tank,
where would the product go? Is there room near the
tank, in the natural drainage path, to dig a deep ditch
to entrap such spilled product?
Where are the fill and vent pipe for all external tanks?
Where would a tank overfill flow? Are the fill pipe
areas protected against drippage, hose drainage, or
hose rupture causing product to flow or be carried by
rainwater into a storm drain leading to water? Can
such fill pipe areas be protected?
2. Drum Storage. Are drums of product, either full
or returned (and supposedly empty) stored outside?
Are docks and drum storage areas properly protected
by curbed and drained concrete pads? Do the drains,
if any, run through a product separator? Are water-
soluble liquids stored with non-soluble products, so
VI-17
-------
A NEW PAIR OF EYES
that a water-soluble product might get into a separator
and dissolve any non-soluble product accumulated in
the separator?
3. Roadways, parking lots, and other paved areas.
Are all paved areas guttered or would a spill drain off
into the ground? If they are guttered, what would pre-
vent drippage from leaky transmissions on vehicles, or
from an accident to a vehicle (particularly a tank truck)
from reaching a lake or river via the storm drains? Are
there storm drains, and do they lead through some
kind of separator? Is there inspection of both employ-
ees' and suppliers' vehicles to prevent drippage from
leaky transmissions? Is there a visitors parking area
where such control is impossible or difficult, and does
that area have storm drains? If so, where do they lead?
Are rail sidings protected against spillage if tank cars
are loaded or unloaded?
4. Product/water separators, retention ponds. Are
there separators, retention ponds, or other areas which
might accumulate product by design or accident? What
provision has been made for continual and automatic,
or regular manual, removal of product? Is the separa-
tor functioning properly under normal operating con-
ditions, and does it have adequate capacity to handle
the largest accidental discharge of product from any
source (including a large tank rupture) which might get
into the separator? Do retention ponds have baffles or
weirs designed to prevent product from escaping with
the effluent, and what provision has been made for
removal of accumulated product?
5. Security. Is there adequate security to prevent
vandalism or sabotage aimed at causing a spill? Is the
security good enough to detect a spill if it occurs any-
where on the property? How long could a leak exist
before it would be discovered? Have security personnel
been instructed as to the procedures to follow if a spill
is detected? Is there always an adequate number of
.trained personnel on duty to handle a spill? What is
the response time required to assemble equipment and
manpower to handle a spill? Is equipment always avail-
able in a known place, or must it be assembled? Is it
mobile (on a trailer or truck) or must transport be pro-
vided on demand?
' . Spill potentials from operation in buildings.
1. Small leaks from bearings, seals, packing glands,
pipe fittings. Where will such leaks go? If they go into
a drain, does the drain lead to a sump from which
product can be recovered, or does it lead to a storm
drain or sewer? Can such leaks be controlled by the
use of sorbents, better maintenance or drip pans? If
the product flows into a sump, where does the sump
lead? If to a separator, does the act of getting it there
create dispersions which will prevent the separator
from operating properly? (Many products, pumped
along with water by a centrifugal pump, will form par-
tial em 'sions which are exceedingly difficult to break).
Does the separator, if it exists, have provision for
automatic draining of product? Can a surge of water
or product dump the product already in the separator?
Where does the effluent from the separator go, and is
this adequate to prevent a large product surge from
getting into a river or lake? Can the load on the sepa-
rator be reduced or eliminated by closing some or all
floor drains, and requiring spillage to be mopped up
by hand? This procedure often improves operating
care, which reduces such spillages.
If there is a sump, from which accumulated product
and water are pumped to a separator or retention porld,
is there a by-pass which might permit discharge di-
rectly to a river or lake? If there is such a by-pass, is
it really necessary? What provision has been made to
prevent accidental or deliberate (sabotage) opening of
the by-pass valve? Are the valves locked, and do they
have positive visual or electronic indicators to assure
complete closure? Are all pipes and valves containing
product protected against accidental breakage by pass-
ing equipment or personnel? If not, can they be relo-
cated or protected with guards?
2. Inside tankage. Are all inside storage tanks, in-
cluding equipment reservoirs, protected against acci-
dental leaks of large amounts of product? If such leaks
occur, where will the liquid go? Are inside storage
areas diked or curbed to prevent spread of product
over a large area? Do the diked areas have drains,
and where do they lead? If there are drains, can some
or all safely be sealed shut? Have the diked areas suf-
ficiently high walls to hold the entire contents of the
tanks? Are the tanks vented, and if so, to where? If to
the outside of the building, are there adequate high-
level alarms to indicate a tank overfill? Are the vents
high enough to provide a head of more than the head
capacity of the pump feeding the tank? If so, is the
tank strong enough to hold that pressure? Are tanks
inspected for corrosion at regular intervals? If the
vents cannot be raised, or if the feed pumps have too
much head to use this form of protection, where will a
spill resulting from an overflow go? If to a roof, where
do the roof drains lead? If onto the ground, can the
overflow get into storm sewers? What is the character
of the ground below the vent, and could a large spill
reach the water table? Should all external vents be
piped to a slop tank?
3. Vapor discharges. To where do the vents from
compressors, emergency vents (rupture discs), exhaust
blowers, and other sources of vapor lead? If the vents
lead to the outside, do the discharges onto the ground,
building walls, or roof present the chance of rain wash-
ing small amounts of product into storm drains or
sewers which discharge into a river or lake? If vapors
are discharged into the atmosphere inside the plant,
will they condense into accumulations which can be
contacted by water or steam and washed into a plant
drain or sewer?
4. In-plant accidents. Is the storage of product and
in-plant handling of drums such that an accident in
and along the normal usage areas (from dock to ware-
house to storage area to final point of use) cannot
send product to a drain or other plant outlet which
will let it get out of control?
5. Piping. Are the walls and floors free from holes
caused by removal of old equipment? Are there cracks
VI-18
-------
A NEW PAIR OF EYES
in floors or walls, cut off pipe or conduit, pipe runs
coming up through the floor, that could provide a
path for a spill? Is plant piping sufficiently well marked,
and are operators sufficiently well trained, so that an
operating error could not result in an accidental dis-
charge of product? Is piping tested for leaks, or in-
spected regularly for corrosion?
6. Maintenance. Is the handling of product collected
in maintenance (flushing of equipment, washing of
machinery) such that it is not put into the sewer? How
te waste product stored and handled in the plant? How
is it removed from the plant, and what is the final dis-
posal? Are cleaning solutions, from floor mopping
and machinery cleaning, dumped into the sewer? Are
cleaning solutions containing detergents or other ma-
terials which may emulsify product, disposed of by
dumping them into a drain or sewer which will dis-
charge the solutions into a separator and possibly up-
set its operation? Can specific disposal drains or areas
be provided for such detergent solutions, and can
segregation of detergent solutions from product-con-
taining water be assured?
C. Potential spills which may leave the property.
In what ways could a spill leave the property? Could
it go directly to a ditch, creek, river, lake, or other
naturally occurring body of water? Could it get into a
sewer, and where does the sewer discharge? How much
time would be available to take protective steps if a
spill were discovered immediately on occurrence? What
are the parameters of the discharge - flow rate, sur-
face velocity, turbulence, discharge path dimensions?
How long is the discharge path, and how long a re-
sponse time would be available before a spill left the
discharge path and entered a lake or river? At what
points along the discharge path could retention booms,
weirs, straw dams, or other barriers be installed to
contain a non-soluble spill? What is the access for
equipment both for containment and removal of en-
trapped product?
Can equipment be stored along or at the end of the
discharge path with security from vandalism or pil-
ferage, or must it be stored within the plant and brought
to the site of a spill? Does the water in the area freeze
over in winter? What is the situation with regard to
debris, shore ice? Is there a location or locations where
permanent sorbents might be used to advantage to re-
move rainbows or sheens from the water or to retain
small spills? Is there a possibility of installing monitor-
ing equipment to warn of spills? Is there access by the
public anywhere along the discharge path? Into what
body of water does the discharge flow? What would
determine the extent of a spill leaving the discharge
path - tides, current, wind? What are the prevailing
winds? Are there waves, debris, boat traffic, or other
factors which might affect containment and recovery
operations?
D. Other considerations.
Cooperatives: Is there a spill cooperative in the area?
What equipment does it have, if any? What are the
membership requirements? Who is a member? Who
controls release of any equipment it owns?
In general, not too much is available in the way of
assistance from cooperatives in handling small day-to-
day spill problems. Mostly, these are paper organiza-
tions, and in many areas, once the paperwork is signed
and perhaps some equipment purchased, other than
for occasional meetings they become relatively inactive.
This is not to say that cooperatives are not worth-
while, for they do have a considerable value. They
provide for the availability of trained personnel and
equipment for very large spills; are a good medium
for the exchange of information on what other
companies are doing; give good publicity to the indus-
try; and serve as a medium for coordinating relation-
ships with the governmental authorities, the news me-
dia, and others. In the event of a large catastrophic
spill, the availability of equipment is a real help. In
these ways, cooperatives perform a valuable function
for industry, and as such, membership where they are
formed is both a practical and political necessity.
Personnel: Is there a training program on spill con-
trol for operating and/or security personnel? Does the
program include practical and classroom instruction?
Is there a written spill manual?
Many plants today which use hazardous materials
do not have sufficient personnel to handle a spill of
even moderate size. Some will find it difficult to do
even the minimum number of things necessary to pre-
vent or handle small spills. If company policy will not
permit an enlargement of the personnel roster to pro-
vide for handling spill equipment, some arrangement
will have to be made to get local help at the times
needed.
In some areas of the country, companies are enter-
ing the spill cleanup business, usually as a sideline to
another business, often-times waste disposal. These
companies have equipment, manpower, and experience.
They are expensive but are almost essential for large
spills.
Occasionally, local contractors may have some ex-
perience in spill cleanup. In many areas, septic tank
cleaners have available vacuum trucks which can be
used for cleanup of small spills. Waste-oil haulers also
are available in some locations. A list of local sources
should be maintained at any potential spill site, and
contact made with such contractors in advance, to as-
certain their capability, out-of-hours phone numbers,
and charges. This information should be included in
any spill survey.
Records: What records are kept of spill incidents?
Who keeps them? At all locations, a spill log in legally
acceptable form should be maintained. This probably
means a bound book, with each entry dated and timed,
and each page signed and witnessed.
A Polaroid camera, with space provided in the log
to mount the pictures, would be useful. Such a book
will not only provide a record of your actions to serve
as a basis of your own discussions of spill action, but
can also provide some legal protection against lawsuits,
VI-19
-------
A NEW PAIR OF EYES
either by government or private citizens. Such record
books should be in a standard form provided by the
company to all terminals, and they should be collected
at intervals and secured against loss, since suits are
frequently (and increasingly so) being filed several
years after an incident has occurred.
Supply Pipelines: Is product shipped or received by
pipeline? At what pressure does the line operate? Who
is responsible for maintenance and testing of the line?
How often is it tested and how? Does the line have
cathodic protection? How much product could escape
if there were a line leak? Where would it go? Can
the pipe alleys and/or pipeline manifolds be diked
for protection? What protection does the line have
from vandalism and sabotage?
Many hazardous materials are now being trans-
ported by pipeline. Liquid ammonia, LPG, LNG, coal
slurry, petroleum hydrocarbons—all are transported
long distances in pipelines up to several feet in dia-
meter. Within plants, and between plants relatively
short distances apart, materials such as acids, alkalies,
molten sulfur, liquid sodium, styrene, acrilonitrile,
and many others, are handled by pipeline. Long dis-
tance lines are generally common carriers; short inter
or intra plant lines are usually privately owned. Even
in a short distance product transfer, between a storage
tank farm and a plant, or from a dock to a plant stor-
age tank, the potential for large spills exists. A mile
of 10" diameter line, for example, holds approximate-
ly 22,000 gallons.
Communications: Is there reliable and immediate
communication between both ends of a pipeline—plant
tank farm and dock, or tank farm and pipeline pump-
ing station? Are both ends of the line attended during
the entire transfer period? Is the communication link,
radio or phone, assured in adverse weather, or a physi-
cal accident to the facilities? Is there an alternative
communications mode available?
The kind of problem requiring prompt communi-
cations, which might arise during transfer,, could be
the result of an operator error, such as switching into
'he wrong tank, a product which suddenly goes off
•pt cification.or an accident, such as a leak at a flange
"' ich could make it unsafe to attempt shutting off
I e flow at a pipeline manifold.
In some plants, communication is by voice, signal
light, or hand signals. In such instances, small port-
able radios should be provided for improved instant
communication.
In cases where the pump or metering station is some
distance away, communication is usually by telephone.
There is often a direct, private phone line between
the pump station and the pipeline manifold, but some-
times it is necessary to go to an office to make a phone
call, over commercial telephone lines. The manifolds
are frequently located at a considerable distance from
the office.
The operator may be out in the tank farm when he
discovers a problem. Without radio contact, there
could be a lapse of 10-15 minutes before an operator
could telephone to have the line shut down, which
VI-20
could mean the loss of a considerable volume of pro-
duct. Pipeline pumping rates can vary from 20,000 to
250,000 gals per hour so that the loss in a quarter-
hour could be anywhere from 5,000 to 60,000 gals be-
fore flow could be stopped.
Emergency Notification in the Event of Spills
Who should be notified in the event of a spill emer-
gency? Is a list posted, and are all personnel familiar
with the notification procedures, and order of prior-
ity? Are phone numbers up-to-date? Are night numbers
included? Are governmental authorities, emergency
clean-up help, Chem-Trec and similar organizations,
listed?
Every plant where a spill potential exists should have
posted in a prominent place, accessible and familiar to
all operating personnel, a list of procedures to be fol-
lowed in the event of a spill emergency. This should
include, in addition to actions to stop or confine the
spills, a list of names, addresses, and telephone num-
bers of company personnel and governmental authori-
ties to be notified and the order in which they should
be called. At various locations, the governmental
bodies to notify may be one or more of the United
States Coast Guard, the federal EPA, the state EPA,
or, in some instances, certain designated local authori-
ties. Arrangements are frequently made between state
and federal authorities so that notification of any one
constitutes legal notification of all. It should be deter-
mined for each location whether this is the case so
that the notification responsibilities can be discharged
properly.
In many instances, company procedures stipulate
that the terminal superintendent must notify a superior
within the company, who in turn may or may not have
the responsibility or authority to notify the proper
governmental authorities. As a result of this chain of
notification, there might be a considerable delay be-
tween the time a spill is found and the time notification
is actually made to the authorities. The legality of this
procedure must be determined and a policy set by each
company since in some instances the requirements
might be that the terminal superintendent must notify
the governmental authorities immediately and directly.
Public Relations
Who says what, if you have a spill?
Any spill survey should include a decision about
who will handle public relations in the event of a large
spill. P/R is always difficult at such times. The "old"
way was to "keep mum"; experience has shown that
this is a short-sighted policy. Full and complete co-
operation with the news media is advisable; adverse
publicity is greatly diminished by such cooperation.
A reporter has a job to do; hopefully he will do it with
accurate information, some understanding of the prob-
lems involved, and an appreciation of the advance
preparation the company has made to combat such a
low-probability (but nevertheless anticipated) event.
Hence the "new" way is to appoint some well in-
-------
A NEW PAIR OF EYES
formed person within the company to handle .P/R,
and to refer all requests for information (news media
and governmental authority) to him. The name and
phone number of that person should be available at
the local level, obviously.
Figures 3, 4 and 5 attempt to tabulate the ideas dis-
cssed in the.paper. It should be emphasized that the
tabulations include only some of the "where to look",
"what to look for", and "other factors" involved in
spill potential assessment.
OUTSIDE
AROUND BUILDINGS
Roofs; walla i loading docks ;tahher and rail
unloading areas directly into building;
TANK FARMS
Tanks; piping; dikes; manifolds;
SEPARATE TRANSFER FACILITIES
Docks; loading racks;
! GENERAL
Roadways; parking areas; full and returned drum
storage areas; unused buildings; old or dismantled
equipment ;garages;
IHSIDE
Nails ; floors ; ceil ings ; unused areas ; tunnels ; store-
rooms; drains; gutters;
, . STORAGE
Tanka;drums;eeniipnent sumps; maintenance supplies;
EQUIPMENT
Valns and piping; tanks; vents;
ANYTHING UNUSUAL. UNEXPECTED.OUT OF ORDINARY
Stains on walls,ground,along ditches;unused tanks
or piping,with old product;floor drains in
unused buildings,or portions of used buildings;
EQUIPMENT
Tanks vents; overfill a la nu; buried tanks and pipes;
tank coatings;cathodic protection;corrosion;
leaky seals,bearings, valves and fittings;valve
lockn;identification markings on lines,tanks,
valves;mechanical guards for tanks and piping;
GROUNDS
Drains and sewers;ditches;natural drainage(con-
tours );conta inment hasins;separators(area,
effluent clarity);gutters and curbs;
STRUCTURES
Roles;cracks;cut-off piping;leaks in unused areas;
Figure 4: What "New" Eyes Should Look For.
COMMUNICATIONS
Reliability;adequacy;
BOTIFICATIOH PROCEDURES
Company;government;public and news media(PR);
PERSONNEL
Availability;training;response time;contractors
(cost.capability,availability);
RECORD KEEPING
Spillstroutine operations;equipment tests;
SECURITY
Adequacy;coverage;reliability
WASTE DISPOSAL
From operations;from maintenance
Figure 3: Where "New" Eyes Should Look for Spill Hazards.
Figure 5: Other Factors "New" Eyes Should Consider.
REFERENCE
1. Federal Register, Vol. 48, #237, Part II, pp 34164-
34170, Dec. 11, 1973.
VI-21
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GUIDELINES
for Chemical Plants in the
Prevention, Control, and Reporting of Spills
Copyright 1972 by Manufacturing Chemists' Association, Inc.
Used with permission.
VI-23
-------
These guidelines are published as an activity of the Water Resources
Committee of the Manufacturing Chemis:s Association. Persons wishing
more detail may contact the staff editor, H. B. Brown.
© Manufacturing Chemists' Association, Inc. ? 972
The information and recommendations contained in this manual have been compiled
from sources believed to be reliable and to represent the best opinion on the sublet as
of 1972. However, no warranty, guarantee, or representation is made by the Manu-
facturing Chemists Association as to the correctness or sufficiency of any information
or recommendation herein, and the Association assumes no responsibility in connection
therewith; nor can it be assumed that all necessary warnings and precautionary meas-
ures are contained in this manual, or that other or additional information or measures
may not be required or desirable because of particular or exceptional conditions or
circumstances, or because of applicable federal, state, or local law.
VI-24
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FOREWORD
The responsibilities of industry to assure compliance with regulations to protect and enhance the quality of
receiving waters are becoming more definitive and performance requirements more restrictive. Therefore,
effective prevention, control, and reporting of spills are essential to water pollution control programs of
chemical plants.
This publication describes essential elements in individual chemical plant spill prevention. These guidelines
are to assist company and plant management in situation analysis, technique development, and planning. There
are no pat answers—each plant's physical arrangement and operational complexities present a unique set of
circumstances and problems in relation to achieving the objective of "zero" spills or "zero" effect of spills.
Effective programs must be developed in accord with local situations and executed by local management.
VI-25
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CONTENTS
1. TYPES AND CAUSES OF SPILLS
Page
1.1 Summary and Definition 7
.1 Boil Overs 7
.2 Transfer to and from Storage , 7
.3 Transfer to and from Carriers '. , ,.. 7
.4 Storage Facilities Leaks and Failures .... 9
.5 Process Facilities Leaks and Failures 8
.6 Bailout, Washup, and Process Shutdown Wastes 8
.7 Waste Treptment System Failures and Inefficiencies T. 8
.8 Storm Water Drainage 8
.9 Fire, Flood, and Explosions , ,. 8
2. DELETERIOUS EFFECTS OF SPILLS
2.1 Summary
2. .1 Fire or Explosion T T
2. .2 Release of Heat, Toxic, or Noxious Vapors
2. .3 Physical Damage to Sewerage and Treatment Facilities ....
2. .4 Upset of Inplant Waste Water and Waste Treatment Systems ....
2. .5 Shock Load to Municipal Waste Treatment Facilities 10
2. .6 Pollution of Ground Waters , 10
2. .7 Pollution of Receiving Waters : 10
3. ELEMENTS OF SPILL PREVENTION AND CONTROL
3.1 Summary , 11
3.1.1 Responsibility Assignment .,.,. 11
3.1.2 Assessment of Hazards ,. ,.. Jl
3.1.3 Inspections and Materials Control 11
3.1.4 Containment, Temporary Storage, Equalization, and
Controlled Discharge 12
3.1.5 Process Controls, Alarm Systems, and Fail Safe Procedures 12
3.1.6 Countermeasure Actions , , 12
3.1.7 Removal, Cleanup, and Proper Disposal of Spill«d Material* .... 12
3.1.8 Personnel Training, Review Teams, and Check Lists 12
4. RESPONSIVE REPORTING AND PUBLIC RELATIONS CONSIDERATIONS
4.1 inplant Reporting r 13
4.2 Reporting within the Company , , 13
4.3 External Reporting : , 13
4.4 Press, Television, and Radio 13
5. SPILL CONTROL REVIEWS
5.1 Summary 15
5.1.1 Reasons for Spill Prevention Review '. 15
5.2 Kinds of Review .: IS
5.2.1 Process Development Spill Prevention Review J5
5.2.2 Preliminary Spill Prevention Review 15
5.2.3 Project Design Spill Prevention Review 15
VI-27
-------
Page
5.2.4 Pre-startup Spill Prevention Review (Manufacturing) 15
5.2.5 Periodic Plant Spill Prevention Review (Manufacturing) 16
5.2.6 Review Reports ". :....:... 16
5.3 Organization of Spill Prevention Reviews ; 16
5.3.1 Team Approach 16
5.3.2 Composition of Review Team 16
5.3.3 Special Value of Central Group 16
5.3.4 Scheduling of Spill Prevention Reviews 17
5.3.5 Spill Prevention Review Meetings 17
5.3.6 Review in Depth 17
5.3.7 Recommendations by Team 17
5.3.8 Review Team Report 17
6. SPILL PREVENTION AND CONTROL CHECK LISTS
6.1 Define and Assess the Hazards of Materials Handled 18
6.1.1 Raw Materials 18
6.1.2 Intermediate Process Compounds 18
6.1.3 End Products . . 18
6.1.4 By-Products and Waste Products 18
6.1.5 Rating Guide 18
6.2 Assess the Potential of Spill Occurrence '. 18
6.2.1 Receiving and Unloading 18
6.2.2 Storage and Transfer 18
6.2.3 Process Operations : 18
6.2.4 In-Process Transfer 18
6.2.5 Laboratory and Pilot Operations 18
6.2.6 Shutdown and Clean-up 19
6.2.7 Maintenance Procedures 19
6.2.8 Auxiliary and Support Operations 19
6.3 Evaluate Influencing Physical Factors : 19
6.3.1 Plant Site 19
6.3.2 Machinery and Equipment ; 19
6.3.3 Buildings and Structures—Yard and Grounds , 19
6.3.4 Operating Areas 19
6.3.5 Sewerage Systems 20
6.3.6 Storm Water Runoff and Collection , 20
6.3.7 Utilities and Utilities Transmission 20
6.3.8 Potential of Natural Disasters 20
7. SUGGESTED REFERENCES
VI-28
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Guidelines for Chemical Plants
in the
Prevention, Control, and Reporting of Spills
1. TYPES AND CAUSES OF SPILLS
1.1 SUMMARY AND DEFINITION
For purposes of these guidelines a spill is defined
as the deposit or discharge of any material (dry,
semi-solid, or liquid), other than the normal in
process waste waters from production operations,
which might be:
Transported through plant sewerage (storm,
process or sanitary) or by surface runoff, or ulti-
mately discharged to plant waste treatment facili-
ties, to sewerage for transport to municipal treat-
ment facilities, or to receiving public or private
waters.
The source and types of such unusual or accidental
spills are numerous and widely variable. Since no
two plants are alike, each must be individually
reviewed in regard to spill potential and related
programs.
The causes of spills are as widely variable as the
types which might be encountered. Most are the
result of "people failure" and are, therefore, con-
trollable by the actions of people. Some more ob-
vious spill categories are considered in this section.
In recognizing and assessing spill potential it is
essential that all facts, factors, and circumstances be
considered and applied in the belief that "anything
that can happen will happen." Therefore, if "zero"
deleterious effect is to be achieved, basic problem
recognition, definition, and planning cannot be too
comprehensive.
1.1.1 Boil-Overs
Primary causes can be classified as either design,
maintenance or operational. Boil-overs result princi-
pally from bulk overheating, hot spots, uncontrolled
exothermic reactions and over-loading. Bulk over-
heating and hot spots result from:
Inadequate temperature controls,
Improper cooling system maintenance, and
Insufficient agitation
Causes of exothermic reactions are:
Faulty addition of ingredients, or
Operator laxity.
Many errors arise from incomplete instructions
and/or insufficient operator training. Where the pos-
sibility of a boil-over exists, personnel should be so
well indoctrinated that carelessness and over-
confidence are avoided.
1.1.2 Transfer to and from Storage
Overpumping is an important cause of spills.
However, operator inattention or error may be in-
fluenced by:
Equipment inadequacy,
Equipment failures, and/or
Improper preventive maintenance.
Inadequate personnel training, workforce instruc-
tions, maintenance inspections and maintenance cor-
rections may be causative factors, especially where
transfers are on an intermittent basis.
Inadvertent damage to facilities, i.e., valves, piping
and storage tanks by vehicles or work crews may also
contribute to accidental discharge.
1.1.3 Transfer to and from Carriers
Spills during transfer to and from transportation
vehicles result primarily from:
Improper or poorly maintained facilities and
equipment,
Malfunctions of equipment, and
Operator error.
Accidents of this type present a more serious
situation when all equipment and personnel are not
directly responsible to plant management. Also, po-
tential damage may involve municipal sewerage,
receiving waters or public use areas.
While overpumping is a major cause of accidental
spills during vehicle transfers, others include:
Inadequate facilities,
Improperly positioned pipes and hoses,
Faulty or wrong connections,
Mistakes in valve manipulation,
Improper identification of lines,
Defective transfer vehicles and storage vessels,
and
Incomplete operator instructions.
VI-29
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1.1.4 Storage Facilities Leaks ami Failures
Sudden failure of containment facilities, tanks or
lagoons, can result in serious spills. Leaks which
escape early detection can also be serious in that long
periods of time may elapse before the leak is noticed
or the loss detected.
Lagoons, utilized for temporary storage of concen-
trated wastes or reject materials, equalization of
wastes, or for controlled discharge, present a threat
of accidental discharge. Failures in walls, bottom
leaks, valves, deterioration of liners, or capacity over-
load may result in sudden large volume discharge or
small volume undetected over a longer period.
1.1.5 Process Facilities Leaks and Failures
Leaks in this category are usually of an intermit-
tent or repetitive nature. They reflect:
Operator inattention,
Poor maintenance inspection and reporting, and
Inadequate maintenance follow-up.
Although there may be a tendency on the part of
operators to ignore or "live with" inadequacies, such
leaks on a cumulative basis add substantial waste
load. Also, systems slugs can result when an accu-
mulation of waste material is flushed to the sewer.
Typical causes are:
Improperly functioning valves,
Incompletely closed valves,
Faulty piping connections,
Pump gland leaks, and
Improper valve and system operation.
Mechanical failures of valves, lines, pumps and
the like may directly or indirectly cause spills and
varying amounts of loss with varying effects on the
plant effluent system. Many are sudden and unpre-
dictable. Others occur because of:
Operator inattention,
Operator error, and
Poor preventive maintenance.
1.1.6 Boilout, Washup, and Process
Shutdown Wastes
Even relatively small volumes of highly concen-
trated wastes resulting from periodic clean-up of
equipment systems and storage facilities can be seri-
ous contributors to pollution.
Although disposal of such wastes may be infre-
quent, they are often unusual in strength and different
in composition than normal process wastes consisting
of raw material, intermediate compounds and end
products. Therefore, selection of cleaning materials,
control of clean-up procedures and a system for han-
dling them demands careful attention. The best
waste treatment facilities and pollution abatement
program can be nullified through improper clean-up
proc edures.
1.1.7 Waste Control (Treatment) System
Failures and Inefficiencies
A plant's pollution abatement program is no better
than the degree of treatment attained by inplant
waste treatment control facilities. They require the
same careful attention as process operations. Design
efficiencies must meet objectives and allow for pe-
riodic slugs and spills. Allied inplant controls must
attain pollution load reductions to avoid episodes
equaling or exceeding those caused by accident or
other unusual discharge. Above all, waste control
facilities cannot be provided and then forgotten.
1.1.8
Storm Water Drainage
Storm water is not always recognized as a poten-
tial pollution problem and may be overlooked within
and without industry. This oversight probably re-
sults from the "dilution" philosophy as well as the
unpredictable nature of storm water runoff. Pol-
lutants which might be carried by storm water should
be subject to control, especially in unroofed areas.
They include:
Spilled dry materials,
Dust collector accumulations, small leaks which
are impounded by topography,
Rubbish piles, and
Empty containers which contain residues.
Improperly designed and operated landfills of
waste materials are also potential causes of spills
via the surface water runoff route. Their delayed
action effect on sewerage, treatment facilities and
receiving waters can be serious.
Principal causes of such storm water runoff
hazards are:
Operator neglect,
Poor maintenance, and
Poor housekeeping.
Loading and unloading areas, tank farms and out-
door storage of raw or waste materials are particu-
larly significant.
1.1.9 Fire, Flood and Explosions
Water pollution is usually a relatively minor factor
in plant fires, explosions, or other catastrophes.
However, it should not be overlooked in the preoccu-
pation with other matters, since serious pollution
can result if containment and treatment facilities fail
or are overloaded during such abnormal conditions.
Therefore, personnel responsible for dealing with
emergency situations should include technical ex-
pertise in pollution control.
Plants and facilities subject to flooding are also
potential sources of deleterious spills in receiving
waters. Inundation of land with contaminated sur-
faces or of land utilized for storage or disposal of
materials can produce similar results. In these cir-
cumstances, as in storm water runoff, dilution cannot
be assumed an adequate offsetting factor.
VI-30
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2. DELETERIOUS EFFECTS OF SPILLS
2.1 SUMMARY
Although the effects of a spill may vary widely in
type and degree from plant to plant, the potential
outcome can be defined for a given set of circum-
stances. Therefore, specific definition, projection,
and assessment of hazard potentials are essential for
each plant. .Failure to recognize problems and act
accordingly can result in serious operational, legal,
and economic impact.
General considerations to be evaluated include:
The nature of raw, intermediate, and end prod-
ucts being handled,
Operational processes and practices,
Plant waste streams and systems,
Plant treatment and control facilities,
External sewerage and treatment systems, and
The nature and use of the receiving waters.
Thorough knowledge of these and other influenc-
ing factors is basic to controlling and minimizing the
deleterious effects of a spill.
2.1.1 Fire or Explosion
Some materials themselves or in combination with
others may present fire or explosion hazards when
spilled on the ground or into sewers. Others may
react to emit flammable or explosive fumes which are
hazardous when confined in plant or municipal
sewers.
The effects and methods of handling such spilled
materials vary in accordance with the specific chem-
ical compound and conditions surrounding the acci-
dent. Although the hazard is normally confined to
the immediate area of the spill and to nearby individ-
uals, negligence or improper action can compound
the problem in the immediate area or permit its
expansion to other areas.
2.1.2 Release of Heat, Toxic or
Noxious Vapors
Some compounds react exothermically when di-
luicd with water, combined with other materials, or
released from conditions of controlled storage.
Others release toxic, noxious, or nauseous fumes. As
a result, air pollution or industrial hygiene problems
can affect a relatively wide area, or persist for ex-
tended periods. Consequently, as with flammable or
explosive materials, problems with these materials
can be compounded through inadequate instruc-
tion and improper actions.
2.1.3 Physical Damage to Sewerage and
Treatment Facilities
The possibility of physical damage to sewerage
systuiis by fire or explosion is obvious, as is the
potential damage from chemical vapors. Less ob-
vious are the effects of spilled materials high in
suspended solids or those which interact to form
solids that coat or clog or form deposits in sewers.
Monitoring, control, and instrumentation equipment
and effluent transfer equipment can also be damaged
by such materials spilled.
WAT** rouunoN cormtoL KXSEAIICH unit* •
Water Quality Criteria Data Book
Volume 3
Ellieu ol Cbmitili on AqoMic LHt
•RA
ENVIRONMENTAL PROTECTION AGENCY RESEARCH AND MONITORING
2.1.4 Upset of Inplaiit Waste Water and
Waste Treatment Systems
The accidental discharge of concentrated materials
into plant sewerage systems can seriously affect phys-
ical facilities, recycle and reuse practices, pretreat-
ment processes, or internal waste water treatment
plants and the hazards of such an occurrence must
not be overlooked.
Some chemicals can permanently damage collec-
tion systems, piping, pumps and control equipment,
and upsetting normal recycling or reuse of waste
waters can render the best system inoperative and/or
seriously overtax inplant controls. This is especially
true when biological treatment systems are "killed"
or "poisoned" by the introduction of a slug of acid,
alkali, or highly toxic materials. Since the recovery
period of biological treatment systems is often
lengthy, the intervening pollutional load presents a
problem and. in some cases, might necessitate tem-
porary shutdown or curtailment of plant production.
VI-31
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2.1.5 Shock Load to Municipal Treatment
Facilities
Hazards similar to those inplant exist when a
highly concentrated waste is discharged to a munic-
ipal system, but with even more potentially serious
consequences. For while plant operations can be
shutdown for a recovery period, municipal plants
cannot cease to function without developing other
problems.
2.1.6 Pollution of Ground Waters
While many spills result in detrimental effects on
sewerage treatment systems or surface waters, some
can affect the quality of ground waters. Leaks from
storage tanks or impoundments with bottoms below
soil level can percolate downward or laterally into
shallow ground waters. Other sources include:
Contaminated surface water pools resulting
from rainwater, runoff, and
Improperly designed, operated, or maintained
landfills of waste materials.
The geology of the area is an influencing factor in
determining the migration of spills of this type.
Sandy soils are particularly subject to percolation of
pollutants into ground waters.
2.1.7 Pollution of Receiving Waters
Protecting the ultimate receiving water is the
primary consideration in dealing with inplant spills
or accidental discharges. Whether the introduction
of an unusual pollutional load is direct or indirect,
the consequences differ only in degree or in duration.
The potential effects range from fish kills and de-
struction of other biota to rendering the water un-
acceptable as a water resource for downstream users.
10
VI-32
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3. ELEMENTS OF SPILL PREVENTION
AND CONTROL
3.1 SUMMARY
Effective spill prevention and control programs
depend on pre-emergency recognition of inplant
hazards along with management action and direction
commensurate with the hazard potential. Action-
motivated programs are essential.
Applying the "if it can happen, it will" theory will
assure that accidents are anticipated and steps taken
to prevent them. In like manner, programs can be
designed so that unanticipated spills are managed so
as not to measurably affect discharge effluent charac-
teristics or cause deterioration of receiving water
quality.
Since most spills are caused by mechanical failure
and/or personnel error, most can be prevented or
minimized by:
Sound basic design,
Thorough training of operating, technical and
maintenance personnel,
Strict job responsibility,
Sound process control and alarm and monitor-
ing systems, and
Proper maintenance of equipment and facilities.
Acts of God, fire, explosion, or power failures may
be exceptions to the "zero spill" prevention rule.
However, thorough pre-emergency planning along
with frequent review and updating of emergency
procedures will help keep such spills under control
and reduce their deleterious effects.
Some specific spill prevention principles are pre-
sented in this section. Others will be found in Sec-
tions 5 and 6.
3.1.1 Responsibility Assignment
Although specific responsibility assignments vary
with organizational structure, it is vital that local
action responsibility be established. Needless to say,
someone must be in charge, to direct and coordinate
the work of others.
Although prevention and control programs require
substantial input of technical expertise, the assign-
ment of line responsibility normally is retained by
operations management. This is appropriate since
spills are mostly operational, and control measures
should be executed by operating personnel. Staff
technical or public relations assistance is important
but cannot substitute for effective supervision by
line management.
Communications, cooperation, and coordinated
efforts are essential to a successful program. Timely
input by knowledgeable personnel can mean the dif-
ference between routine solutions and crisis failures.
Team effort is required and team positions must be
assigned before the fact.
If an environmental incident occurs or Is imminent,
communication begins with a report by the party who
recognizes a problem or potential problem. That
person must know what to do, whom to report to,
and how to report promptly and accurately. In turn,
speed and quality of response is vital; pre-planned
procedures must be executed without searching ob-
servation of protocol.
Sections 5 and 6 present information on Spill Con-
trol Reviews and Spill Prevention and Control Check
Lists; these suggestions may be adapted to the indi-
vidual plant action program.
3.1.2 Assessment of Hazards
The hazard potential of each material, the spill
problems it poses, and their possible inplant and out-
side effects must be clearly recognized.
Each plant, therefore, must have the facts on all:
Raw materials,
Intermediate process compounds,
By-products,
Waste materials, and
End products.
The potential ill effects of spills must then be
projected in relation to situations that can be
anticipated.
Specific information about chemical materials, i.e.,
toxicity, biodegradability, reactivity, and odor, is
usually available or obtainable. The potentially
hazardous effects of such materials then require
intensive study, including such factors as types,
causes, and effects of spills which might occur. Of
extreme importance are the physical features and
terrain surrounding the plant in relation to run-off
to receiving waters.
3.1.3 Inspections and Materials Control
After surveying the hazard potential of materials
being handled and developing a program for preven-
tion of spills, it is important to regularly audit the
effectiveness of the program by inspections and by
materials loss control reporting. If extremely hazard-
ous materials arc involved, strict inventory control
systems and materials balance determinations are
required. There is no adequate excuse for not know-
ing and not taking prompt action when hazardous
materials are "lost."
Detailed daily reporting of spill incidents and com-
munication, of reports to top operating management
11
VI-33
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is one means of evaluating and establishing the rec-
ord. Such reporting also maintains a spill-conscious
attitude by operating personnel. Audits of the .phys-
ical facilities with respect to spill preventive mainte-
nance should be done on a routine basis by review
teams who report on their findings, performance rec-
ords, materials losses and the like.
3.1.4 Containment, Temporary Storage,
Equalization, and Controlled Discharge
Spills will occur regardless of preventive measures.
Therefore, providing ways to hold a spill is the first
step to control its effects. Such temporary storage
alleviates the need for decisions under emergency
conditions since, in many cases, the spill is best
coped with in its concentrated identifiable form
rather than after it has been diluted in plant sewerage.
Methods include:
Diking—similar to that used for tank farms.
These can be constructed around storage facili-
ties, loading and unloading areas, unit processes,
and the like. However, diked areas must be
constructed so as to preclude percolation to
ground waters.
Diversion—via pumping or gravity flow to a
temporary storage area. Automatic sewer cut-
offs with appropriate pumping facilities may be
useful.
In some circumstances spills may be routinely di-
verted to a strong wastes holding or equalization
facility for subsequent handling or combining with
normal waste discharges.
3.1.5 Process Controls. Alarm Systems, and
Fail-Safe Procedures
As with all accidents, spills are caused—they don't
just happen. Therefore, their causes as well as their
effects can be minimized through controls, alarms
and fail-safe procedures. Control equipment and
warning systems should be coordinated with pre-
determined personnel response.
Use of controls and alarms varies widely from
plant to plant. The sophistication required is de-
termined by a logical assessment of a spill's potential
seriousness and the probability that one might occur.
3.1.6 Countcrmeasure Actions
In some cases, the effect of a spilled material can
be negated or minimized by countermeasures. They
include:
Dilution with water,
Neutralization,
Addition of reactive materials,
Adding oxidizing agents, or
Other appropriate steps depending on the mate-
rial involved.
Preliminary steps may be containment, temporary
storai-j, or diversion to equalization facilities.
Memo to Plant Managers
I
1. Responsibility for spill incidents, including clean-up, j
must be fixed with supervision in the area that the
incident occurs.
2. Management vill emphasize the importance of eliminating
spills and, if they occur, emphasise proper clean-up
techniques.
3. Improved supervision may be necessary if the spill problem
is to be further reduced. Night supervision may be neces-
sary.
4. A spill-oriented educational program should be initiated
for both operators and supervision.
5. .Methods and equipment are available to handle spills
other than by flushing to the sewers.
6. A standardized spill reporting form will be completed
by a responsible surveillance group and filed vith plant
supervision. Reply to the report, detailing causes,
effects, clean-up and preventive measures, must be
made by the responsible party.
All countermeasure actions must be predeter-
mined; materials, equipment, and facilities must be
readily available; responsible personnel must be
assigned.
3.1.7 Removal, Cleanup, and Proper
Disposal of Spilled Materials
Eventually, spilled material must be removed, the
site of the spill cleaned, and the waste disposed of
without continuing or recurring ill effects.
Potential pollution of water, air, or soil and pos-
sible translation from one to the other must be
considered.
Normally, disposal can be accomplished by:
Biological or chemical treatment,
Incineration, landfill,
Deep well disposal, or
Deep water ocean barging.
In some cases it may be economically desirable to
recover the spilled material through product proc-
essing or to sell it as raw material for another use.
In others, contract disposal by a qualified firm may
be preferable.
3.1.8 Personnel Training, Review Teams
and Check Lists
A successful spill prevention and control program
is entirely dependent on the attitudes of plant per-
sonnel. Awareness and alertness are essential. Em-
ployees must be impressed that virtually anyone
can cause, contribute to, or be involved in a spill and
that his action or inactions influence the level of
control that is attained. On-going training should be
conducted by review teams and an action-oriented
task force.
Suggested organizations, review teams, and check
lists arc presented throughout this manual.
12
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4. RESPONSIVE REPORTING AND PUBLIC
RELATIONS CONSIDERATIONS
4.1 INPLANT REPORTING
Minimizing the effect of a spill depends on aware-
ness. Someone must recognize there is a problem
or potential problem. That someone must then know
what to do, to whom to report, and how to report
accurately.
In turn, the speed and quality of the response is
vital. Evaluation and the implementation of counter-
measures can be carried out effectively only by those
who are thoroughly familiar with the situation, the
materials involved, and the potential effects. Pro-
cedures must be established in advance; the program
must be operable at all times and fit all conceivable
incidents.
4.2 REPORTING WITHIN THE COMPANY
Depending upon the case, notification within the
company logically may come before or after report-
ing outside the company. If the situation is critical
and the person in charge is fully qualified, immediate
reporting to the appropriate public agency may be
more important than timely transmittal of informa-
tion up the internal management line. The objective
is to minimize deleterious effects, and early com-
munication should be with those who may best serve
in achieving it. Those who should be notified and
might be helpful at or after the fact include opera-
tions management; staff technical, safety, medical or
engineering personnel; and non-technical staff, i.e.,
insurance, legal, public relations and industrial rela-
tions.
WASTE CONTROL DEPARTMENT
ENVIRONMENTAL CONTROL REPORT F
, c_« i-, =.-
4.3 EXTERNAL REPORTING
As indicated above, communicating with the ap-
propriate public agency or agencies might be the
first step in minimizing the effects of a spill.
Each plant should know what agency the spill
affects and the degree of importance to that agency.
Those to be contacted vary from plant to plant and
state to state, but include:
Water and/or sewage treatment management,
Fire, health and emergency services,
Fish and game or conservation departments,
and/or
Water pollution control agency.
In some communities and states, official reporting
may be a legal requirement.
4.4 PRESS, TELEVISION AND RADIO
Regardless of the type of spill or its cause, the
potential for damage to a company's public reputa-
tion is high, particularly in a time of heightened
public awareness and concern over the environment.
Each company should have a definite plan for han-
dling the pres's and broadcasters if an unusual dis-
charge occurs at any of its facilities.
• Give special emphasis to deciding who will be
the information representative and spokesman. He
should be technically knowledgeable, poised, articu-
late, honest, able to think on his feet. Above all he
should not reject or outwardly resent any request for
information. To do so appears evasive, and arouses
suspicion. It is usually feasible to state that as soon
as facts are known they will be revealed. Ideally,
Lie spokesman should be the plant manager. If not,
ihe assistant manager or someone in top plant man-
agement, since newsmen are certain to want a state-
ment from one in authority.
Selecting the right man and training him appro-
priately could mean the difference between protect-
ing or damaging the plant's community relations—
and perhaps corporate public reputation—for years.
13
VI-35
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• Have the spokesman get acquainted with as
many of the local media people as possible. Let them
know he can be trusted to cooperate, that he'll always
call them if there is news at the plant affecting the
community.
• Cooperate fully and quickly with all the control
officials involved; tell the media this is being done.
• Develop a set of facts about the plant; its pollu-
tion control efforts, safety record, number of em-
ployees, economic value to the community and so
forth. Keep the facts up to date; offer them when
asked.
• Set up a quick clearance system for information
in an emergency situation and make sure that all such
information is channeled to the spokesman.
• Give a prompt, accurate account of the spill
situation. It could wind things up in a day or so and
is far better than doling out unpleasant facts in a
long, sordid serial—or having the facts picked over
by the press as a source for many stories.
• Help newsmen get the story. This generally
results in a fair—even sympathetic—reporting job.
Let newsmen in with cameras and tape recorders as
soon as practicable and safe. Don't force them to
obtain questionable information from excited or per-
haps biased outsiders.
• Provide enough telephones, typewriters, tables,
chairs and electrical outlets for today's expanded
media coverage. The latter may require a plant elec-
trician—to make sure television cameras and lights
do not overload circuits.
Obviously, if the plant has a public relations de-
partment, it should handle these details. Whether
there is such an in-plant department or not, contact
corporate headquarters as soon as possible for as-
sistance. Give them all the facts. Other company
plants may be getting distorted stories and need to
know the true situation. Keep plant employees up-
dated on the facts and what the plant has done about
the problem.
• Finally, as soon as the problem is fully resolved
(if it was of major proportions), develop an informa-
tion kit explaining step-by-step how the plant coped
with and resolved the situation. Include a statement
by the plant manager and photos, if available. Send
it to all local news media and to corporate public
relations. Also send a brief note of appreciation to
newspaper and broadcast news editors who reported
objectively.
14
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5. SPILL CONTROL REVIEWS
5.1 SUMMARY
5.1.1 Reasons for Spill Prevention Review
The purpose of a spill prevention review is to fore-
see hazards and to attack them before accidents
occur. The resulting savings more than justify the
cost.
5.2 KINDS OF REVIEW
Spill prevention review should cover:
Process development,
Plant modifications,
Pre-startup, and
Periodic spills.
5.2.1 Process Development Spill Prevention
Review
The research group responsible for developing a
process should be concerned also with anticipating
spill potential and the impact of process hazards on
the ultimate design of the plant. Since the choice of
solvents and reactants as well as conditions are of
prime importance, consultation with engineers likely
to be engaged in reducing the process technology to
commercial practice may be helpful. The spill pre-
vention review should be made prior to initiation
of the bench scale model or pilot plant and should:
Explore potential spill hazards if the process is
developed commercially,
Determine which of these hazards must be given
particular attention during process develop-
ment, and,
Provide for all hazards under normal and ab-
normal conditions during all phases of develop-
ment and production.
Such a review can result in substantial savings,
both during construction and operation. The results
should be incorporated in a special spill prevention
and control section of the tentative process report.
5.2.2 Preliminary Spill Prevention Review
As process development progresses and the final
project is initiated, engineering personnel become
responsible for spill prevention. Opinions should be
obtained from division (department), the manager
of environmental control, plant and corporate en-
gineers as well as a chemical engineer from an
outside department. The project manager should
consider each recommendation and comment on ap-
propriate action. Although at this stage the design
is ur'ally not far enough advanced to get into detail,
the recommendations are important in determining
alternative solutions and resolving judgment differ-
ences.
5.2.3 Project Design Spill Prevention Review
Any cost proposal to the company's executive
group for approval to proceed with a project should
include funds for a final preliminary spill prevention
review by all engineering participants. It should be
based on maximum spill potential and business inter-
ruption, and approval of capital for the project
should provide for such contingencies.
During the design .stage, the project manager
should review all phases of spill prevention—elec-
trical, fire protection, instrumentation, mechanical,
process and personnel safety—making certain they
are provided for at appropriate stages, not after
design is complete or after so many commitments
have been made that corrections are difficult or ex-
pensive. A check list is essential to such an effort and
a sample is included in Section 6.
5.2.4 Pre-Startup Spill Prevention Review
(Manufacturing)
A spill prevention review should be held prior to
completion of the plant operating manual and before
plant startup. It should:
Confirm that operating personnel are thoroughly
familiar with the hazards involved and the con-
trols that have been engineered into the process,
Determine whether any additional process haz-
ards are involved, including those which could
develop under abnormal conditions,
Check the adequacy of operating procedures,
emergency procedures and startup plans.
The manufacturing superintendent is responsible
for carrying out this review. Suggestions in Sec-
tion 6, "Spill Prevention and Control Check Lists"
can be profitably used for pre-startup deliberations.
While most of the items in the check lists will have
been given consideration, with hazards eliminated or
adequately controlled, review at this stage should
seek full understanding of recognized hazards and
procedures for avoiding or controlling them. It
should detect details which have been overlooked and
concentrate on the adequacy of plans to cope with
operating emergencies that might arise. Participants
should include research, engineering, and plant pollu-
tion abatement personnel as well as others who can
advise operation supervisors of hazard potentials and
spill prevention provisions which have been engi-
neered.
15
VI-37
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SPILL HANDLING AND REPORTING SYSTEM
This report presents (1) the current practice of handling
and reporting spills, (2) alternative methods for handling
spills, (3) the availability of equipment that could be
called in to clean-up a spill, (4) interviews with the
departmants involved with spills, and (5) a suggested
plan of action, including a revised reporting system and a
suggested rating guide.
5.2.5 Periodic Plant Spill Prevention Review
( Manufacturing )
Since minor changes in operating details, equip-
ment, piping connections, temperatures, pressures,
operating rates, and raw material inevitably occur
during operation, periodic reviews are essential to:
Keep operating personnel alert to hazards,
Determine whether operating procedures re-
quire revision,
Screen the operation for changes which may
have introduced new hazards,
Identify changes which should be made to re-
duce existing hazards.
Re-evaluate property and business interruption
exposures, and
Reveal through new experiences or information
potential hazards not previously recognized.
: The manufacturing superintendent should be re-
sponsible for holding periodic reviews. The tentative
Process Design Manual and Division Operating
Manual are helpful supplements to the "Spill Preven-
tion and Control Check Lists" in Section 6.
Each review should look particularly for changes
that have been introduced with or without the bene-
fit of process amendments or alteration projects.
Sometimes it is not a single change which creates a
hazard, but a combination of minor changes.
The periodic spill prevention review should also
ferret out recurring operating abnormalities and see
how they should be handled safely.
Maintenance check lists dealing with the inspec-
tion, cleaning and testing of critical control equip-
ment should also be reviewed.
5.2.6 Review Reports
Reports on spill prevention reviews should be sent
to the corporate or plant environmental control
gn jp. They enable the company to:
Compile suggestions for spill prevention and
control in other facilities, and
Develop a backlog of information to aid engi-
neers in designing new plants.
5.3 ORGANIZATION OF SPILL
PREVENTION REVIEWS
5.3.1 Team Approach
Spill-occurrence-probability analyses can best be
obtained through a review-team approach, utilizing
the knowledge and experience of qualified individ-
uals, with technical backgrounds of team members
varying according to the type of spill prevention
under consideration. For example:
The new project review team in a small plant or
company might include the same individuals who
would review existing operations. However, in a
multi-plant organization, such a team would more
likely comprise specialists from the corporate en-
vironmental control, operating, and pollution abate-
ment departments.
To secure an objective review, a chemist or chem-
ical engineer from a unit not concerned with the
success or failure of the new project should be in-
cluded in the review team.
Company size may affect the formation of a tech-
nically competent team. In some circumstances, the
services of qualified consultants or insurance com-
pany specialists may be required.
5.3.2 Composition of Review Team
The review team should normally be composed of
a central group which participates in reviews of all
units in the plant, and other groups appointed for the
particular review at hand. A representative from the
pollution abatement or environmental control depart-
ment should always be a member of the central
group. For larger plants, it usually consists of three
people. For very small plants, the central group may
comprise only the department representative and a
technical specialist.
A group appointed for a particular review should
include a representative from each of the functions
concerned with the operation, normally: manufactur-
ing, maintenance, technical, and possibly research,
engineering or other special categories, selected on
the basis of applicable expertise.
5.3.3 Special Value of Central Group
Although the central group will generally be the
most experienced, all groups should work as one
team. Central members should not direct or domi-
nate: they should not ask all the questions, but
should see that the proper questions are asked, while
participating on a basis of equality with the other
members.
The central group's primary role is to provide the
experience derived from prior reviews along with a
16
VI-38
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broad knowledge of interdependency of hazards
among various internal and external operations. As
a result it is most valuable in framing recommenda-
tions.
5.3.4 Scheduling of Spill Prevention Reviews
Spill prevention reviews for the different opera-
tions in a plant should be evenly scheduled. This pro-
vides for adequate preparation and in depth discus-
sions covering process, utilities, and maintenance
operations. Crash review programs are seldom bene-
ficial due to their shallowness.
5.3.5 Spill Prevention Review Meetings
A spill prevention review team should meet regu-
larly—at least once or twice a week—until its job is
completed. Length should be sufficient to permit
genuine accomplishment—perhaps four hours, al-
though some teams find six or even eight hours desir-
able. If the meeting is too brief, little will be accom-
plished per manhour.
During the review meetings team members should
not be called away for other than dire emergencies.
Attendance should take precedence over any other
phase of their jobs and all team members should be
present at all meetings in order to obtain maximum
benefits for the fewest total manhours.
5.3.6 Review in Depth
The spill prevention review should be a compre-
hensive step-by-step examination of the process to
uncover unsuspected hazards which could lead to
serious incidents, including:
Process chemistry,
Hazardous properties of all materials, and
Physical operations, including flow charts, utili-
ties, and plant layout.
Ideally, the team should engage in free discussion
guided by some logical sequence of operation cov-
erage. Reference to, or use of, a check list should be
postponed to the end of deliberations since faithfully
following one throughout tends to throttle the kind
of thinking so necessary for objective hazard analysis.
However, check lists do serve a useful function when
the audit team uses them to help prevent oversights.
Section 6, "Spill Prevention and Control Check
Lists,'' can be used for this purpose.
5.3.7 Recommendations by Team
The review team should develop recommenda-
tions for attacking recognized hazards, but not engi-
SPILl. RATIHC GUIDE (Example)
1. Opportunity Factor
Frequency 0-2 tines p*r month
2-10 tines per month
10-45 tines per month
Above 45 times per month
2. Detectability Factor
lomediately detectable by weight, overflow,
Detectable through inventory or analysis
V«ry difficult to detect
3. Consequence Factor
Caustic
rats and Oil*
Fuel Oil
803
Sulfuric Acid
Phosphoric Aeid
Armenia
Dyes
4. Local Conditions Factor
alarm, etc.
Points
10
!0
30
40
10
20
30
27
12
33
55
63
55
41
n
neer solutions. Its function is to analyze in depth,
not to design. Rather, it should assign to a particu-
lar department the responsibility for execution of
each recommendation. Sometimes the audit team
can suggest desirable approaches.
5.3.8 Review Team Report
The activity of the review team should culminate
in a concise, definite report with two primary sec-
tions:
(1) A listing of spill exposures
(2) A listing of hazards, recommendations, as-
signments of responsibility for actions and
target dates for completion.
The latter should also contain personnel assign-
ments and dates for a check on completion as well as
provision for closeout when action is satisfactorily
completed.
Each report should be dated and addressed to a
specific person with copies to a predetermined list.
Specifically, it should be determined whether the
plant manager wants a copy; in most plants he does
and is the person to whom the report should be
addressed.
17
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6. SPILL PREVENTION AND CONTROL
CHECK LISTS
6.1 DEFINE AND ASSESS THE HAZARDS
OF MATERIALS HANDLED
6.1.1 Raw Materials
Have all raw materials been considered?
Have the potential consequences of use of each
raw material been denned?
Has each raw material been identified in a spill
rating guide?
Is the inventor}' control of raw materials adequate?
Is the purchasing or procurement section aware of
raw materials quality control effects on possible
hazards?
6.1.2 Intermediate Process Compounds
Have all intermediates been identified?
What are the possible consequences of spillages
of intermediate compounds?
Have intermediates been considered in the spill
rating guide?
Do you have means for detecting and measuring
the losses of intermediate materials and compounds?
6.1.3 End Products
Have all end products been considered?
Have the potential consequences of spills of each
end product been defined?
Has each end product been identified in a spill
rating guide?
Is the inventory control of end products adequate?
6.1.4 By-Products and Waste Products
•Have all by-products and waste products been
considered?
Have the potential consequences of spills of each
by-product and waste products been defined?
Has each by-product and waste product been
identified in a spill rating guide?
Is the inventory control of by-products and waste
products adequate?
6.1.5 Rating Guide
Has a rating guide been prepared or considered?
Have the frequency, detectability, consequences,
and heal conditions factors been considered?
Have all raw materials, intermediates, by-products,
waste products, and end products been rated?
Who has access to and uses the rating guide?
6.2 ASSESS THE POTENTIAL OF SPILL
OCCURRENCE
6.2.1 Receiving and Unloading
Has the "anything that can happen, will" philos-
ophy been applied?
Are the operations controlled and supervised by
dependable and knowledgeable personnel?
Are losses monitored?
Are maintenance and preventive maintenance in-
spections reporting adequate?
6.2.2 Storage and Transfer
Are all materials inventoried and controlled?
Is the best equipment utilized?
Are small spills reported and properly and
promptly handled?
Has the probability of a major spill incident been
established?
6.2.3 Process Operations
What is the practice of controlling and reporting
emergency discharges?
Are process upsets and equipment failures repeti-
tive? If so, why? Are process errors recognized and
reported?
Do the operating personnel know and recognize
the detrimental effects of spills and accidental dis-
charges?
6.2.4 In-Process Transfer
What are the practices of controlling and reporting
emergency discharges?
Are process upsets and equipment failures repeti-
tive? If so, why?
Are process errors recognized and reported?
Do the operating personnel know and recognize
the detrimental effects of spills and accidental dis-
charges?
6.2.5 Laboratory and Pilot Operations
Are the potential ill effects of accidental or unusual
discharges recognized?
18
VI-40
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Are spill prevention and controls factors applied
in planning and design?
Is there adequate consideration of the waste prod-
ucts or hazards influencing feasibility factors in
development work?
Is waste control practiced in laboratory pro-
cedures, sampling, handling, disposal and trial opera-
tions?
6.2.6 Shutdown and Clean-up
Are procedures developed with spill prevention
and control in mind?
Can the unusual be isolated and handled as a
special case?
Are personnel aware that the problem can't be
flushed down the drain?
Have personnel been alerted to the unusual haz-
ards involved in start-up and shutdown, especially
emergency shutdowns?
6.2.7 Maintenance Procedures
Are maintenance personnel aware of spill preven-
tion and control problems?
Do production, technical and waste control per-
sonnel coordinate with maintenance?
6.2.8 Auxiliary and Support Operations
Do these other departments recognize their in-
volvement in spill prevention and control?
Does overtaxing support equipment and opera-
tions present spill problems?
6.3 EVALUATE INFLUENCING PHYSICAL
FACTORS
6.3.1 Plant Site
Are physical factors such as terrain and proximity
to receiving water considerations in planning, preven-
tion, and control of spills?
Do the backup, stoppage, and overflow of waste
waters affect the overall programs for spills control?
Are dikes and other containment devices in-
fluenced by physical factors of slope, runoff, flooding,
soil conditions, etc.?
Is the property underlain by shallow ground waters
which would be subject to pollution via percolation
of spills through the soil?
6.3.2 Machinery and Equipment
Are the existing plant machinery and equipment
significant factors in spill prevention?
Is related auxiliary and support equipment prop-
erly maintained?
Does spill prevention and control equipment re-
ceive adequate inspection and preventive mainte-
nance?
6.3.3 Buildings and Structures, Yard and
Grounds
What is the influence of buildings and other struc-
tures in the prevention and control of spills?
Are roof deposits potential spill hazards?
Are ground deposits potential spill hazards?
6.3.4 Operating Areas
Are spilled materials handled promptly and prop-
erly?
Do accumulations of small spills present a prob-
lem?
Can maintenance be performed without bypassing
safety devices and procedures?
MOTOR AND
TRANSFER
PUMP
UNLOADING AREA
SLOPED INTO
CURBED AREA
Containment curb-type spill catchment system,
depressed area form.
19
VI-41
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OVERFLOW TO STORM SEWER OR WATERCOURSE
4:
:»fj
SPILL
PROTEC
SEWER
\
^9\^
•.A
• 'i
«_•
x
1
' ~i
•ION
£•
;*i
*•;
t
CAPTURE VOLUME
FOR FLOATABLE MATERIAL
- - - t
c
[ft.
',,
'.4
,' *.
a-
&
'4
- ORIFICE FOR
CONTROLLING
DISCHARGE RATE
fl -ff
TO CITY SEWER
OR INDUSTRIAL
TREATMENT PLANT
Catchment basin system of flow-through type,
with orifice-controlled discharge rate.
6.3.5 Sewerage Systems
Arc sewers segregated or combined?
Can spills be diverted to minimize effects?
Is the plant sewerage system maintained properly?
Are blockages and back-up flooding a problem?
6.3.6 Storm Water Runoff and Collection
Has the effect of storm water been considered?
Can storm water be diverted away from spill
areas?
Arc roofs, buildings and ground a source of "Act
of God" spill effects?
Are storm water effluents measured, sampled and
evaluated?
6.3.7 Utilities and Utilities Transmission
Do spill prevention and control devices have ade-
quate uninterrupted power?
What is the effect of power interruption on alarms,
control systems, pumping, etc.?
Do the power plant and water treatment plant
contribute to potential for spills?
6.3.8 Potential of Natural Disasters
Has the probability of natural disasters been deter-
mined or considered?
What areas could be affected by natural disasters?
Can waste treatment ponds be influenced?
Is sewerage back-up a problem?
•
TO
TREATM
PLANT
Wa
^-v
Parking Lot
,
* *
Roadway
- STORM SEWER
_^1 -c — L ,
1 SANITARY 6 PROCESS WASTEWATER
* * •
Process
Building
Dust
Filter I
on Roof 1
s< Railroad Spur
i ^
O O O O
Tank Farm
TOO O O ,
T SPILL CONTROL SEWER
Unloading Area*
.r"—
O
— »
Curbw
Acldt
Causti
Tanks
M
•1
r"
•
Spill
Catchment
Buln
Basin-type spill catchment system.
20
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7. SUGGESTED REFERENCES
I. Control of Spillage of Hazardous Polluting Sub-
stances
U.S. Department of Interior—Federal Water Quality
Administration Water Pollution Control Research
Series 15090FOZ 10/70
2. Oil arid Hazardous Materials—Emergency Proce-
dures in the Water Environment
U.S. Department of Interior—Federal Water Quality
Administration CWR 10-1, August 1968
3. Guidelines for Risk Evaluation and Loss Preven-
tion in Chemical Plants
Manufacturing Chemists Association, 1970
4. Chemical Safety Data Sheets
Manufacturing Chemists Association
5. Federal Guidelines—Design, Operation and Mainte-
nance of Waste Water Treatment Facilities
U.S. Department of Interior—Federal Water Quality
Administration, September 1970
6. Permits for Discharges or Deposits into Navigable
Waters
Department of the Army, Corps of Engineers Proposed
Policy, Practice and Procedure, December 23, 1970
7. Abstract of Proceedings, Hazardous Polluting Sub-
stances Symposium, 14-16 September 1970, New
Orleans, Louisiana
Department of Transportation, United States Coast
Guard
8. Inorganic Chemical Pollution of Freshwater, Water
Quality Criteria Data Book, Volume 2
U.S. Environmental Protection Agency—18010DPV
07/71
9. Effects of Chemicals on Aquatic Life, Water Qual-
ity Criteria Data Book, Volume 3
U.S. Environmental Protection Agency—18050GWV
05/71
10. Control of Hazardous Material Spills, Proceedings
of the 1972 National Conference on Control of
Hazardous Material Spills
Graphic Management Corporation
11. National Oil and Hazardous Substances Pollution
Contingency Plan, August 1971
U.S. Government Printing Office, 1971-0-442-907
12. Dangerous Articles Emergency Guide, Recom-
mended Good Practice for Handling Fires or Spills
Involving Explosives and Other Dangerous Articles
Bureau of Explosives, Association of American Rail-
roads
13. Hazardous Chemicals Data 1967, NFPA No. 49
National Fire Protection Association
14. Manual of Hazardous Chemical Reactions, NFPA
No. 491M
National Fire Protection Association
15. Disaster Operations, A Handbook for Local Govern-
ment
Office of Civil Defense, December 1971
16. Accidental Episode Manual
A Report by Resources Research, Inc. for the U.S.
Environmental Protection Agency under Contract No.
68-02-0029. (Approved for Printing)
21
VI-43
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Prevention and control
of chemical incidents
EDWARD J SHIELDS
Edward J. Shields is a chemical engineer and
manager of pollution control for Allied Chemi-
cal Corp., Morristown, NJ. After 21 years of
chemical plant operating experience, including
4 years as a plant manager, he has spent the
last 6 years as a division and more recently
corporate manager of pollution control.
Copyright 1980 by Technical Publishing Company.
Used with permission.
-------
rial should be chemically resistant and essentially imper-
vious to the substances contained, and should meet
acceptable engineering design criteria to withstand a sud-
den massive release. To the extent feasible, dike walls
should not exceed an average height of 6 ft above the
interior grade. A greater height might require the obser-
vance of tank entry safety procedures including safety
harnesses, oxygen deficiency checks, standby observers
and other precautions each time it is necessary to enter
the diked area. For earthen dikes, a slope of 2.5:1 is
preferred. Earthen dike walls 3 ft or more in height
should have a flat walkway section at the top not less than
2 ft wide.
4. Percolation from diked areas—For hazardous and
toxic chemicals, the ground area within any diking or
curbing should be essentially impermeable. This can be
achieved by use of concrete, asphalt, or suitable clays.
However, if the chemical(s) involved can be neutralized
by crushed limestone, clam shells, or similar materials,
such materials may be used as ground cover within the
dike walls instead of the impermeable surfacing. For
example, the ground area around carbon tetrachloride or
chloroform storages should be suitably sealed. On the
other hand, it may be preferable to use crushed limestone
or clam shells within the diked area around a muriatic
acid storage tank. However, a disadvantage is that neu-
tralizing ground covers of this type should be removed
and replaced promptly after a significant spill.
5. Integrity of dike walls—It is recommended that there
be no discharge or loading pipes through the dike wall.
However, construction design should conform to local
and state regulations. As an example, some local fire
regulations, applicable to flammable liquids, require a
valved pipe through the dike wall, while others prohibit
this installation. If a drainage valve through the dike wall
is required, it should be kept locked in the closed position
when not in use. An effective seal, chemically resistant to
the material(s) involved, should be installed around any
pipe passing through the wall of a secondary containment
facility.
6. Other dike design considerations—Where feasible,
dikes should be installed at the appropriate height and
distance from tanks such that a leak on the side of a tank
will not spray over the dike. Where this design is not
feasible, appropriate baffles should be installed that will
deflect potential leaks and cause them to drop within the
contained area.
7. Disposal of rainwater and other liquids from within
diked areas—There should be suitable written proce-
dures for disposal of stormwaters which accumulate with-
in the dike. Removal of these waters is normally accom-
plished by a manually activated pump or siphon system.
Such accumulated stormwater must be removed from the
diked area so as to maintain adequate volume for a max-
imum spill. Operators should obtain permission from
their supervisor before pumping accumulated stormwat-
ers to disposal or collector systems. In situations where it
is desirable to keep stormwater outside the dike, it may be
necessary to install a roof over the tank and diked area.
8. Handling of contained spills—there should be written
procedures established for handling spills which may
occur within each dike system. These procedures should
spell out requirements for testing, recovery or disposal of
the contained material, and dike area cleanup.
Other means of containment—In some plant areas
where the location of storage tanks does not lend itself to
diking, other types of spill containment systems are
acceptable providing that the system collects and diverts
the spill from a waterway and/or a municipal sewer sys-
tem. The diversion should be constructed to prevent the
possibility of groundwater contamination and should be
directed to an impervious catch basin, pond, diked area,
or equivalent for future recovery or for environmentally
acceptable disposal.
Fr3v*ntion and containment of oil spills
Requirements for prevention and containment of oil
spills are specified by EPA regulations (40 CFR Part
112). These regulations seek to reduce the frequency of
oil spills and reduce their impact by requiring the devel-
opment, implementation and maintenance of spill preven-
tion, control and countermeasure (SPCC) plans. Each
plant that has the potential for stored oils to spill and flow
beyond the fence line to waterbodies, sewer systems or
groundwater must have an oil spill plant prepared in
accordance with federal guidelines and approved by a
registered professional engineer.
Secondary containment far other sources
As noted previously, the transfer of oil and chemical
solutions to or from railway cars, truck tanks, barges and
pipelines must be properly controlled by administrative
protocols. In addition, it is recommended that:
1. At all loading and unloading sites (transfer areas),
curbs and/or sumps should be installed to contain spil-
lage. To the extent feasible, such containment should be
designed to hold 110 percent of the capacity of the largest
unit handled (or largest unit contents plus the maximum
24-hr/10-yr rainfall event, if greater).
2. Above-ground pipelines used for transfer of oils and
hazardous liquids should be inspected frequently. At crit-
ical locations such as highways, railroads, water courses,
etc. double-walled piping or shielding may be necessary.
3. Where feasible, underground piping should be pres-
sure tested to installation standards annually. Buried iron
pipelines used for oils or hazardous liquids should be
coated with rustproofing material and cathodically pro-
tected in accordance with National Association of Corro-
sion Engineers recommended practice RP-01-69.
For • copy ol ttih artteto ctacto 302
on Roador Swvte* Cwd.
References
'Regulations proposed by EPA as 40 CFR Part 117 in 44 FR
10279-10284 (February 16, 1979).
^Natural Resources Defense Council vs Train, and Companion
Cases—8ERC2120 (D.D.C. 1976)
EPA proposed regulations to implement Section 3001 of
RCRA as 40 CFR Part 250, Subpart A in 43 FR 58954'
(December 18,1978)
POLLUTION ENGINEERING
VI-49
55
-------
BEST MANAGEMENT PRACTICES FOR CONTROL OF TOXIC AND
HAZARDOUS MATERIALS
C. W. Stuewe, Group Manager
J. G. Geary, Project Engineer
Hydroscience, Inc.
Knoxville, Tennessee 37919
H. M. Thron, Jr., Staff Chemical Engineer
Office of Water Enforcement
U. S. Environmental Protection Agency
Washington, DC 20460
INTRODUCTION
The Federal Water Pollution Control Act of 1972 as amended by the Clean Water Act of
1977 has as its cornerstone the policy of controlling pollution at its source. To implement
this policy, EPA relies heavily on the National Pollutant Discharge Elimination System
(NPDES) permit program. Any owner or opcratoi of a facility that discharges to waters oi
the U.S. must have an NPDES permit to comply with the legal requirements of the Clean
Water Act [ 1 ]. The NPDES permit program has been relatively successful in controlling the
major sources of conventional water pollution in the nation by imposing effluent limitations
in permits, normally daily mass load limits, on pollutant characteristics such as BOD, COD,
TSS and pH, and on certain heavy metals. As we enter the second or post-1977 phase of
NPDES permits issuance-most permits were issued in 1973-74 with an effective life of 5
years-it is essential to adopt a more comprehensive approach to pollution control efforts
by emphasizing the control of the toxic pollutants. It is toward this goal of total plant-site
control of toxic and hazardous pollutants that best management practices (BMP) are directed.
Congress authorized EPA to develop BMP for industrial dischargers in section 304(e) of the
Clean Water Act of 1977 [2]. Before industrial BMP are discussed in detail, it should be
understood that the concept of BMP for water pollution abatement is not new. The following
examples of BMP used by the EPA illustrate the usefulness of this qualitative or procedural
approach to water pollution abatement:
Dredge and Fill Program-In this program the agency uses BMP to prevent or minimize the
environment:!! :oiseqaences o" lischarging dredged or fJ.1 materials into streams, lal:es, wet-
lands or other water bodies. These BMP are procedures or practices to minimize changes in
stream or current flow, to prevent increases in sediment loads and the introduction of chemi-
cals into our waterways.
Areawide Waste Treatment Management (208) Program-Here the EPA uses BMP to define
measures for controlling nonpoint sources of pollution, e.g., agriculture, silviculture and
mining activities.
Urban Stormwater Runoff Program-The agency uses BMP in this program to minimize the
adverse impacts on water quality of runoff from urban areas through a source control program
stressing the reduction or prevention of runoff pollution. The central theme of urban runoff
control is to minimize pollution reaching the collection system or receiving water by using
BMP. Flow attenuation-increasing the time of concentration and decreasing the magnitude
of the peak runoff-is the basis for many of the urban Stormwater management BMP.
National Pollutant Discharge Elimination (NPDES) Permit Program—The most recent appli-
cation of the BMP approach to abate pollution is the use of BMP in the NPDES program, with
the aim of preventing or minimizing the release of toxic or hazardous substances to the surface
waters from ancillary industrial sources.
Several general characteristics of BMP are noteworthy. First, they frequently are proced-
ural and suggest methods or practices to accomplish certain goals. Second, they normally are
829
Copyright 1980 by Purdue Research Foundation.
Used with permission.
VI-51
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qualitative and are expected to be most effective when used in conjunction with quantitative
controls, such as effluent limitations. Finally, BMP are flexible and allow alternative methods
to be used to achieve equivalent results. These characteristics are important since cost is a
major consideration in determining the most appropriate BMP for a particular facility. The in-
herent flexibility of the BMP approach gives the engineer considerable technical discretion in
designing the most cost-effective BMP program for a particular situation.
During discussions with industry it was evident that there is some confusion about the dis-
tinction between BMP in the NPDES program and Spill Prevention Control and Counter-
measure (SPCC) Plans in the hazardous substance (section 311) program. The following dis-
cussion may be helpful in clarifying the relationship between these programs.
The NPDES program regulates wastewater discharges by imposing effluent limitations in
permits. The law requires that BMP established by regulation under authority of section .
304(e) must be included in NPDES permits. EPA also may impose BMP in permits based on
the permitting authority's best engineering judgement in the absence of formal BMP regula-
tions. The requirements for industry to develop BMP programs are based on the agency's
broad authority of section 402(a) (1) of the act, which allows the administrator to impose in
NPDES permits conditions that he considers necessary for complying with the provisions of the
act. Four general ancillary industrial sources are identified in Section 304(e) as subject to
BMP: plant-site runoff, spills or leaks, sludge or waste disposal and raw material drainage.
Through the inclusion of BMP for ancillary industrial sources in the NPDES permitting require-
ments, the EPA is in effect exercising the control over discharges of toxic and hazardous sub-
stances from the total plant site, as well as from the industrial facility's discrete outfall points.
The agency's hazardous substance program is authorized by section 3 11 of the act. SPCC
plans are designed to prevent hazardous substances (the section 311 pollutants) from reaching
surface waters by emphasizing methods to prevent the classic spill event. The foundation of
the hazardous substance propram is secondary containment, such as the use of dike? and berms;
however, SPCC plans also include some of the same control measures contained in BMPs.
The major differences between BMP and SPCC are given below:
BMP
Section 307 and 311 pollutants
Emphasize procedures
Included in NPDES permit
Flexible-allows equivalency
SPCC
Section 311 pollutants only
Emphasize procedures and construction
Included in SPCC plan, certified by a
Professional Engineer
Well-refined requirements
An important distinction between BMP and SPCC is that the former apply to both section
307 and 311 pollutants, whereas SPCC apply only to section 311 pollutants. Also, BMP empha-
size procedures, but SPCC stress both procedures and construction. BMP are being included
within the NPDES permitting program. An SPCC plan certified by a professional engineer will
be required for compliance with that program. Finally, BMP encourage equivalency by allow-
ing th•: use of alternative me hoi", to achieve equivalent r-^Fults. SPCC plans tend tc be mors
specific and more rigorous in their requirements.
BMP USED BY INDUSTRY
The EPA sponsored a study of current industrial practices used in the control of discharges
of toxic and hazardous substances from ancillary industrial activities to receiving waters. The
principal purposes of the study were to identify the BMP used by industry, to develop the
criteria for NPDES permitting authorities to use in prescribing BMP in NPDES permits and to
evaluate a facility's BMP program. Results of the study are incoporated in the guidance do-
cument 13] which is the basis for this paper.
In the study, current practices are identified from published articles and reports, technical
bulletins on specific compounds, and discussions with industry through telephone contacts,
written questionnaires, and site visits. A number of interesting general observations were made:
1. Some BMP are generic in nature, widely practiced, and appear to be independent of
chemical compound, source of pollutant or location of the industrial facility.
830
VI-52
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2. Other BMP are specific to groups of toxic and hazardous substances and to one or
more ancillary source. The use of these BMP is affected by such factors as site
location, topography, age of plant, potential impact of the substance on the receiving
water, engineering design, the company's safety and spill programs, and location of
the toxic and hazardous materials at the facility.
3. Many of the BMP used by industry for preventing spills of materials to receiving waters
are essentially the same practices used by industry for pollution control, safety, industrial
hygiene, fire protection, protection against loss of products and insurance company
requirements.
4. Many BMP are related to groups of toxic and hazardous materials with similar physical
and chemical characteristics rather than to specific chemical compounds.
In concert with these observations, the BMP are divided into two groups: baseline and ad-
vanced. Baseline BMP are defined as those management practices generally considered as good
practice, low in cost and applicable to broad categories of industry and types of substances,
Advanced BMP are defined as those best management practices specific to groups of toxic and
hazardous substances and related to one or more ancillary source.
BASE-LINE BMPS
Baseline or generic BMPs should, with few exceptions, be applicable to all ancillary sources
of all toxic and hazardous chemicals for all industry groups. From the many BM.P reported
in the literature and identified by companies in the survey, only those BMP that are broadly
applicable, that is, truly generic in nature, were selected as baseline BMP. These BMP require
human commitments and procedural actions and are therefore relatively low in cost compared
to most advanced BMP. The following nine practices are classified as baseline BMP.
Spill Control Committee
This committee would be responsible for developing, implementing and maintaining a BMP
program. It would function similarly to a fire prevention or safety committee, and would be
vested with the responsibility and authority to carry out management policy and .achieve BMP
program objectives.
Material Inventory
This system would involve the identification of all sources and quantities of toxic and hazar-
dous materials handled or produced at a particular site. The sources of the toxic and hazardous
materials should be clearly indicated on plant drawings and plot plans, along with the quantity
of materials used. A simplified materials flow sheet showing major process operations can be
used to indicate the direction and quantity of flow of materials frpm one area to another. The
system would also include physical, chemical, toxicological and health information on the toxic
and hazardous substances handled (e.g., technical bulletins or safety data sheets). The inven-
tory would serve to identify those materials that might be released and allow for an assessment
of the potential impact on water quality. The inventory and an assessment or risk evaluation can.
be usej to identify ;Kose area* rec,uirinj BMI for spill ccr.trol
Employee Training Programs
These programs are used to instill in personnel at all levels of responsibility a complete
understanding of the BMP program, the processes and materials with which they are working,
the safety hazards, the practices for preventing spills, and the procedures for responding pro-
perly and rapidly to spills of toxic and hazardous materials. Of particular importance would be
strong commitment and periodic input from top management to the employee-training program
to establish the necessary climate of concern icquired for a successful program.
Materials Compatibility
Three aspects are involved: compatibility of the contents with the materials of construction
of the container, compatibility of different chemicals combined in. for example, a landfill or a
container, and compatibility of the container with its environment. The BMP would establish
procedures to assure that all aspects of materials compatibility are adequately covered in-the
design and operation of all equipment handling toxic and hazardous materials.
831
VI-53
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Spill Reporting
In this BMP records of spills would be kept for the purpose of minimizing recurrence and tor
evaluating the efficiency of the facility's program. Spill reporting procedures, which may be
defined by the spill control committee, include notification of a spill to appropriate plant per-
sonnel for initiation of immediate action, formal written reports for reveiw and evaluation of
spills and revisions to the BMP program, and notification as required by law to governmental
and environmental agencies in the event that a spill reaches the surface water,
Visual Inspection
This program would include touring or patrolling of the plant facility to detect spills or evi-
dence of potential spills. Routine visual inspections can be performed by plant security person-
nel, plant supervisors and other employees and may include visual observations of storage facil-
ities, transfer pipelines, and loading and unloading areas for detection of leaks and spills. De-
tailed inspections of specific areas of the plant should be made by plant personnel responsible
for the individual processes and/or plants to evaluate the need for preventive maintenance, the
adequacy of housekeeping practices, and the potential for spills.
Preventive Maintenance
This practice covers the routine repair and replacement of worn out equipment parts, lub-
rication of equipment and overall surveillance to assure that equipment and instrumentation
systems are functioning properly. Preventive maintenance programs are normally used to
eliminate potential causes of accidents and to minimize equipment downtime but can also be
used as an effective means of reducing equipment failures, which can result in environmental
incidents. As an sxample, all environmental monitoring instrumentation would be checked
regularly to ensure reliable and accurate measurements.
Good Housekeeping
This BMP involves essentially the maintenance of a clean and orderly work environment.
Good housekeeping reduces the possibility of accidental spills caused by mishandling of equip-
ment and reduces the potential for accidents involving plant personnel. Another benefit of
good housekeeping is the conservation of raw materials and product with resultant cost
savings.
Security
A security system would be used to prevent accidental or intentional entry to a facility
which could possibly cause a chemical release. Protection measures against vandalism, theft,
sabotage or other improper and illegal use of plant facilities include routine patrol of the plant
by security guards by vehicle or on foot; fencing to prevent intruders from entering the plant
site; good lighting; vehicular traffic control; a guardhouse or main entrance gate, where all
visitors are required to sign in and obtain a visitor's pass; secure or locked entrances tO'the
plant; locked drain valves and pumps for chemical storage tanks and loading and unloading
facilities; and television monitoring of plant areas most susceptible to a spill.
ADVANCED BEST MANAGEMENT PRACTICES
Many of the reported BMP were more specific than baseline BMP. These practices were
grouped into the broad classification of advanced BMPs and are listed in Table I. Each prac-
tice is described in the guidance document [3]. As shown in the table, the advanced BMP
are divided into four main categories: prevention, containment, mitigation and ultimate dis-
position.
Prevention BMP are those practices beyond the baseline BMP that provide additional pro-
tection against releases. Monitoring and nondestructive testing are two examples of preven-
tion BMP that can be more effective than the baseline visual inspection BMP. Visual inspec- '
tions would not identify a structural weakness in a tank to the degree that it can be identified
and quantified by measuring tank wall thickness and internal stresses with nondestructive test-
ing.
832
VI-54
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Table I. Advanced BMP Alternatives
I
Ui
U1
Mitigation
Prevention
Monitoring
Nondestructive Testing
Labeling
Covering
Pneumatic and Vacuum
Conveying
Vehicle Positioning
Dry Cleanup
Containment - Cleanup
Secondary containment Physical
Flow diversion to Mechanical
secondary containment Chemical
Vapor control
Dust control
Scaling
Treatment
Liquid-solids separation
Volatilization
Carbon adsorption
Coagulation/
precipitation
Neutralisation
Ion exchange
Chemical oxidation
Biological treatment
Thermal oxidation
Ultimate Disposition
Deep-well injection
Landfill
Surface impoundments
Ocean disposal
Direct discharge to
receiving water
Reclamation
Municipal sewer system
Contract dis|iosal
-------
Containment BMP relate to the physical structures or collection equipment used to confine
a release of material after it has escaped from its primary location or containment. Dikes sur-
rounding material storage tanks are the most common example of containment.
Mitigation is the cleanup or treatment of a substance after it has spilled. Mitigation is used
to separate a substance for recovery or to reduce the potential impact of a spill before its
ultimate disposition. Sorbents, gelling agents, and treatment processes, such as carbon adsorp-
tion and biological treatment, are considered to fall in the mitigation category.
Ultimate disposition is the final removal of a substance from the site of the release and is
the final step in the overall handling of a substance that escapes from its original location.
Examples of ultimate disposition include landfills, surface impoundments and, less frequently,
ocean disposal.
ANCILLARY SOURCES
As mentioned above, advanced BMP are specific to one or more of the ancillary sources.
All the advanced BMP have been related to the following five ancillary sources.
1. Material storage areas include storage areas for loxic and hazardous chemicals as raw
materials, intermediates or final products.
2. In-plant transfer areas, process areas and material handling areas encompass all in-plant
transfer operations from raw materials to final product. AU process area operations that
could potentially release toxic and hazardous substances to other than the process
wastewater system are included in this grouping. Examples of sources of pollution from
material transfer operations include pipes, hoses, valves and fittings.
3. Loading and unloading operations involve transfer of materials to or from trucks or
railcais other than in-plant transfer.
4. Plant site runoff is generated from rainfall on a plant site. Runoff from such areas as
material storage areas, loading and unloading areas, sludge disposal sites and parking
lots potentially could become contaminated with toxic and hazardous substances. Con-
taminated runoff may reach a receiving body of water through overland flow, drainage
ditches, storm or clean cooling water sewers, or overflows from combined sewer systems.
5. Sludge and hazardous waste disposal areas are a source of potential contaminant losses to
receiving waters. The operations include landfills, pits, ponds, lagoons and deep-well
injection sites. Depending on the design, construction and operation of these sites,
there may be a potential for seepage of leachate containing hazardous materials to
ground water or for liquid overflows to surface waters.
CLASSIFICATION OF TOXIC AND HAZARDOUS SUBSTANCES
In selecting advanced BMP, companies reported that they considered not only the ancillary
source but also the physical and chemical properties of the substance involved. It was also
noted that, for groups of compounds with similar chemical and physical properties, companies
normally use the same BMP. This concept of relating specific BMP to groups of compounds
with similar chemic.il and physical prope-ties was adopted for use in t'lis study. A classifica-
tion of individual toxic and hazardous substances was developed for relating BMP alternatives
to groups of toxic and hazardous substances. The substances of interest are the 1 29 materials
[4] referred to as priority pollutants and the 299 compounds classified as hazardous
substances [5]. Of the 299 hazardous substances listed, 126 compounds are covered by the
priority pollutant list, leaving 1 73 compounds classified as hazardous substances only. The
combined list of 302 compounds was evaluated in developing the classification.
A number of systems have been reported in the literature for classifying toxic and hazard-
ous compounds [6,7]. Several of the physical and chemical properties, for example, the
physical state (solid, liquid or gas) and the characteristics of the substances, such as human
toxicity. flammability, corrosiveness, reactivity and volatility, are important considerations in
determing appropriate advanced BMP. Many of these characteristics, shown below, are com-
monly used for safety and fire protection programs and can be applied directly to best man-
agement practices:
834
VI-56
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Liquids
Solids
Gases
Human poisons
Flammables
Corrosives
Reactives
Volatiles
Floaters
Amenable to BUT
Human poisons
Flammablcs
Corrosives
Reactives
Amenable to BWT
Biodegradables
Solubles
Human poisons
Flammables
Corrosives
Reactivcs
Aquatic life toxics
Biodegradables
Aquatic life toxics
Aquatic life toxics
In the classification system developed for the BMP study the first grouping of any
specific compound is based on the physical state of the material at ambient tempera-
ture and pressure [20-25 C, I \ 10* Pa (1 atm)]. Of the 302 chemicals, 175 are solids,
111 are liquids and 16 are gases. The chemical's physical state will directly determine
the applicable BMPs. For example, BMP used for the cleanup of liquids, such as sor-
bents. gels and foams, will be different from those applicable to solids or dry chemicals,
svhich are normally cleaned up for recovery by physical and mechanical methods. All
of the 302 compounds were classified in accordance with this system for easy reference
by the user of the guidance document. Table II is a partial list of the liquid group
classification. Applicable categories are denoted by X for each compound listed.
RELATIONSHIPS OF ANCILLARY SOURCES, CHEMICAL GROUPS AND
ADVANCED BMPS
The important factors for selecting potentially applicable advanced BMP are illus-
trated in Figure 1. As noted previously, both the chemical grouping of the substance
and its ancillary source determine which advanced BMP alternatives are applicable. The
chemical grouping is primarily related to the physical state (solid, liquid or gas) of the
chemical. Other physical and chemical characteristics, such as human toxicity, flam-
mability and volatility, are also important considerations but are secondary in impor-
tance to the physical state in most situations. With knowledge of the ancillary source
and the chemical grouping, advanced BMP alternatives can be determined from the
guidance document [3].
FL: vr.'.iSLE CORROSIVE
iDVifjCE: EV- iLTEPNATIVEE
i. ****** of
BMP.
One example of how the above relationships affect which BMP to use is the chem-
ical acrylonitrile stored in bulk storage tanks. The ancillary source is material storage.
At ambient conditions, acrylonitrile is a liquid. It has a flash point below 38 C and is
classed as a flammable. It is classed as a volatile since its vapor pressure at 10 C is
greater than 10 mm Kg! It is amenable to biological waste treatment (BWT); that is,
it can be accepted by a BWT system without adverse impact. Also, acrylonitrile will
biodegrade. With the use of this information in the approach illustrated here, advanced
BMP alternatives can be chosen from the prevention, containment, mitigation and
ultimate disposition categories. For acrylonitrile, prevention BMP \vould be monitoring,
nondestructive testing and labeling.- For the containment category t^s alternatives would
be secondary containment, flow diversion, vapo: control and sealing. BMP for the
835
VI-57
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Table II. Liquid Group Classification
Liquid Human Poison
i.v(2-Chloroisopropyl) Ivlhcr
ft/'i(2-Chloroethoxy) Methane
6u(2-Chloroethyl) Ether
X
-
X
-
X
X
.
-
X
.
-
.
.
X
.b
X
Hammablc
X
X
X
X
X
X
.
X
-
X
-
.
-
-
.
.b
-
Corrosive
X
X
X
-
.
-
-
_
X
-
-
.
'
X
X
.
.
.b
-
Reactive
X
X
X
X
.
-
.
• • .
-
-
.
.
X
-
.
.
.b
-
Volatile Hoaler
X
X
X
X
X
X X
-
X
-
X X
-
-
-
X
X
X^ -b
X
Amenable to
Biological
Treatment
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x'>
X
X
Biodcgradeable
X
X
X
X
X
X
X
X
X
X
-
X
X
X
X
X
X
X
Xh
X
X
Highly Toxic to
Aquatic Life
X
-
X
-
-
-
-
-
-
-
-
-
ND
ND
ND
ND
' X denotes chemical is in (his category, - denotes chemical is not in this category, ND denotes no data available.
Assumed values, based on chemical groups of similar lypc substances.
-------
mitigation and ultimate disposition categories would be determined in a similar
manner.
With this basic approach, BMP alternatives can be identified for a facility. The
facility can then estimate the cost-effectiveness, consider their existing safety an(l spill
programs, and factor in the potential impact on the receiving water and other specific
characteristics of the site before selecting a particular BMP for a chemical. In ord.er
to promote flexibility in the development of BMP, the NPDES program encourages
companies to develop innovative and inexpensive BMP and, in many cases, will allow
equivalency or the use of alternative methods for achieving equivalent results. An
example of equivalency might be the use of liquid level alarms, nondestructive testing
and frequent visual inspections rather than secondary containment. This does not mean
that secondary containment will not be required of facilities if a spill occurs or if
future, more stringent, regulations are published by EPA. Companies are encouraged
to carefully review both BMP and SPCC requirements and to seek clarification from
the KPDES permitting authority, if necessary, before proceeding with major construc-
tion projects related to toxic or hazardous pollutant control.
SUMMARY
In summary, BMP in the context of the NPDES program are practices, procedures
or methods supplemental to effluent limitations to prevent toxic or hazardous pollutant
discharges from ancillary industrial activities to surface waters. Baseline BMPf those
which aro low-cost, procedural and broadly applicable to industry, should be considered
by all facilities using or producing toxic or hazardous chemicals. Advanced BMP, those
which are generally more costly, which provide additional protection beyond the base-
line BMPs, and which relate to a specific chemical or chemical group, should be em-
ployed by facilities as necessary to prevent environmental insults. The responsibility of
designing and implementing an effective BMP program rests with the individual com-
panies. Indirect benefits of a good BMP program include improved employee safety and
health, fire protection, and material conservation. Additional information on BMPs and
their application in the NPDES program is contained in the EPA publication NPDES
Best Management Practices Guidance Document [3].
REFERENCES
I. "Environmental Protection Agency Regulations on Policies and Procedures for the
National Pollutant Discharge Elimination System," Subpart B, Section 125.11,
paragraph (a) in 131 -Water, Environment Reporter. Federal Regulations
(Washington, D.C.: The Bureau of National Affairs, Inc.,)p. 131;2631
2. "Ft-oeral Water Pollution Control Act, As Amended by Clean Water Act of 1977,''
Section 304, paragraph (e), in 7]-Statutes and Orders, Environment Reporter.
Federal Lays (Washington, DC: The Bureau of National Affairs, Inc.) p. 71:5133.
3. Cleary, J. S., O. D. Ivins, G. J. Kehrberger, C. P. Ryan and C. W. Stuewe.
.\'PDES Best Management Practices Guidance Document, Industrial Environmental
Research Laboratory, EPA, Cincinnati, OH (in press).
4. "National Resources Defense Council vs. Train." Consent Decree 8, Environmental
Reporter Cqses, pp. 2121-2126 (June 1976).
5. Environmental Protection Agency. "Water Programs. Hazardous Substances,"
Federql Register, 43(49), Part II, 10474-10508 (March 1978).
6. Pier, S. M., et al. "Methods of Categorization of Hazardous Materials," in
Proceedings of 1978 National Conference on Control of Hazardous Material
Spills, Miami Beach, Florida: pp. 27-31.
7. Ward. C. H., et al. Categorization. Reports of Activities February 1976-
Dccember 1977 Research on Hazardous Substances in Support of Spill Preven-
tion Regulations, Vol. //(January 1978).
837
VI-59
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WORKSHOP SPEAKERS
and PARTICIPANTS
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WORKSHOP SPEAKERS
Robert Bragar, Esq.
Office of Water Enforcement
Enforcement Division
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Michael Pplito
Environmental Protection Agency
Region II
Emergency Response and Hazardous
Materials Inspection Branch
Edison, New Jersey 08817
Colburn Cherney, Esq.
Office of General Counsel
Water Quality Division
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Gary Polvi, P.E.
Office of Water Enforcement
Enforcement Division
Environmental Protection Agency
401 M Street, S.W.
Washington, D,C. 20460
R. Sarah Compton, Esq.
Deputy Assistant Administrator for
Water Enforcement
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Joseph Davis
Environmental Protection Agency
Region III
Curtis Building
6th and Walnut Street?
Philadelphia, Pennsylvania 19106
Thomas Gallagher
Director, National Enforcement
Investigations Center
Environmental Protection Agency
Building 53, Box 25227
Denver Federal Center
Denver, Colorado 80225
Eric R. Olson
Office of Water Enforcement
Permits Division
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Robert Romano, Ph.D.
Manager, Water Programs
Chemical Manufacturers Association
1825 Connecticut Avenue, N.W.
Washington, D,C. 20009
Harry M. Thron, Jr,
Office of Water Enforcement
Permits Division
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
James R. Vincent
National Enforcement Investigations
Center
Environmental Protection Agency
Building 53, Box 25227
Denver Federal Center
Denver, Colorado 80225
Richard Warner
National Enforcement Investigations
Center
Environmental Protection Agency
Building 53, Box 25227
Denver Federal Center
Denver, Colorado 80225
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WORKSHOP PARTICIPANTS
Anthony Adamczyk
Director, Bureau of Industrial
Programs
New York State Department of
Environmental Conservation
50 Wolf Road, Room #308
Albany, New York 12233
(518) 457-1067
James K. Alexander
Environmental Engineer,
Environmental Protection Branch
U.S. Department of Energy
P.O. Box E
Oak Ridge, Tennessee 37830
(615) 576-0849
George D. Allgeier
Industrial Wastes Engineer
Kentucky Department for Natural
Resources and Environmental
Protection, Division of Water
Century Plaza, No. 8
1065 U.S. 127 Bypass South
Frankfort, Kentucky 40601
(502) 564-7885
Joseph A. Alost, III
Planner
Board of Commissioners of the
Port of New Orleans
P.O. Box 60046
New Orleans, Louisiana 70160
(504) 522-2551
Lewis E. Andrews
Assistant Technical Manager
National Aeronautics and
Space Administration
Code LB-4
Washington, D.C. 20546
(202) 755-8383
Rodney R. Bartchy
Resources Engineer
Department of Natural Resources
and Environmental Control -
Water Pollution
Room 203, Second Floor
Blue Hen Mall
Dover, Delaware 19901
(302) 736-4761
Sam Becker
Chief, New Source Evaluation Section
Environmental Protection Agency,
Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
(214) 767-2765
J. R. Bell
Pollution Control Specialist
Virginia State Water Control Board
2111 North Hamilton Street
Richmond, Virginia 23230
(804) 257-6322
Arthur W. Berger
City Engineer/Publie Service Director
City of Painesville
7 Richmond Street
Painesville, Ohio 44077
(216) 352-9301
Michael Booth
Assistant Engineer
Maine Department of Environmental
Protection
State House, Station 17
Augusta, Maine 04330
(207) 289-3355
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Michael P. Boswell
Section Head, Plumbing Regulations
and Inspection Section
Department of Engineering
Washington Suburban Sanitary
Commission
312 Marshall Avenue
Laurel, Maryland 20810
(301) 441-4342
Richard A. Burkhalter
Supervisor, Industrial Section
Department of Ecology
St. Martin
Olympia, Washington 98502
(206) 753-2966
Oscar Cabra, Jr.
Chief, Industrial Permits Section,
Enforcement Division
Environmental Protection Agency,
Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
(214) 767-4375
Jerry W. Cain
Environmental Engineer, Industrial
Waste Water Control Section
Mississippi Bureau of Pollution
Control
P.O. Box 10385
Westland Station
Jackson, Mississippi 39209
(601) 961-5122
Vincent A. Carpano
Pollution Control Engineer
State Water Control Board
2111 North Hamilton Street
Richmond, Virginia 23230
(804) 257-6323
Joseph G. Cleary
HydroQual, Incorporated
1 Lethbridge Plaza
Mahwah, New Jersey 07430
(201) 529-5153,
Marc K. Cohen
Assistant Attorney General
Office of the Attorney General
201 West Preston Street, Fifth Floor
Baltimore, Maryland 21201
(301) 383-5560
Murray L. Corry
Hydraulics Engineer
Federal Highway Administration (DOT)
400 Seventh Street, S.W.
Washington, D.C, 20590
(202) 472-7690
Alfred B. Craig, Jr.
Environmental Engineer, Nonferrous
Metals and Minerals Branch
lERL-Ct
26 West St. Glair Street
Cincinnati, Ohio 45268
(513) 684-4491
Paul L. Dadak
Environmental Engineer
Environmental Protection Agency
Room 2109, J.F.K. Building
Boston, Massachusetts 02203
(617) 223-5061
Jose R. del Rio
Civil Engineer
Office of Surface Mining
1951 Constitution Avenue, N.W.
Washingtpn, D.C. 20240
(202) 343-4022
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John V. DiLoreto
Pretreatment Unit Supervisor
Department of Engineering
Washington Suburban Sanitary
Commission
312 Marshall Avenue
Laurel, Maryland 20810
(301) 441-4355
Frank Erwin
Engineering Technician, Water and
Sewer Department
City of Tulsa
2317 South Jackson Avenue
Tulsa, Oklahoma 74107
(918) 581-5574
W. Lee Fleming
Supervisor, State Wastewater
Review Unit, Permits and
Engineering Department
Natural Resources and Community
Development
P.O. Box 27687
Raleigh, North Carolina 27611
(919) 733-5181
Earl R. Fox
Grant Administrator and Liaison
on Sanitary Operations
Carroll County Bureau of Utilities
225 North Center Street
Westminster, Maryland 21157
(301) 848-4500, extension 230
Allan Geisendorfer
Senior Sanitary Engineer
New York State Department of
Environmental Conservation
Room 308, 50 Wolf Road
Albany, New York 12233
(518) 457-6717
John R. Healey
Environmental Engineer
Environmental Protection Agency
Room 2109, J.F.K. Building
Boston, Massachusetts 02203
(617) 223-5061
Alfred B. Hicks, Jr., CAPT., USAF
Course Director; Environmental/
Sanitary Engineering Course
School of Civil Engineering
Air Force Institute of Technology
AFIT/DET ,
Wright-Patterson AFB, Ohio 45433
(513) 255-4552
Patricia A. Jackson
Director, Division of Applied
Technology, Northern Region
Virginia State Water Control Board
5515 Cherokee Avenue, Suite 404
Alexandria, Virginia 22312
(703) 750-9111
Larry J. Kane
Chief, Permits and Approvals Section,
Division of Water Pollution Control
Indiana State Board of Health
1330 West Michigan Street
Indianapolis, Indiana 46206
(317) 633-0761
Richard C. Kibler
Environmental Engineer
Headquarters Air Force Engineering
and Services Center
Directorate of Environmental Planning
Tyndall Air Force Base, Florida 32403
(904) 283-6193
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August E. Maas
Sanitary Engineer
Erie County Health Department
606 West Second Street
Erie, Pennsylvania 16507
(814) 454-5811
Robert J. Mussro
Environmental Engineer, Industrial
Wastewater Section
State of Georgia Environmental
Protection Division
Room 700, 270 Washington Street, S.W.
Atlanta, Georgia 30334
(404) 656-4887
Joseph C. Newell, P.E.
Chief, Wastewater Section, Permits
Division
Texas Department of Water Resources
P.O. Box 13087, Capitol Station
Austin, Texas 78711
(512) 475-7896
Syed A. Nooruddin
Environmental Engineer
Environmental Protection Agency,
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 881-2328
Standish McCleary, III
Assistant Attorney General
Fifth Floor, 201 West Preston Street
Baltimore, Maryland 21201
(301) 383-5560
James H. McDermott
Acting Administrator, Environmental
Services
Environmental Health Administration
Suite 300, 415 12th Street, N.W.
Washington, D.C. 20004
(202) 724-4103
Mary F. McGhee
Toxics Control Coordinator,
Enforcement Division, Permits
Branch
Environmental Protection Agency,
Region VII
324 East llth Street
Kansas City, Missouri 64106
(816) 374-5955
John E. McLean
Principal Water Resources
Engineer, Office of Environmental
Planning
New York Department of Public Service
Building Three, Empire State Plaza
Albany, New York 12223
(518) 474-5363
Bill J. Opfer
Environmental Health Engineer,
Engineering Staff, Forest Service
United States Department of
Agriculture
P.O. Box 2417
Washington, D.C. 20013
(703) 235-1475
R.L. Peterson
Environmental Engineer, Safety and
Environment Division
Savannah River Operations Office
United States Department of Energy
P.O. Box A
Aiken, South Carolina 29801
(803) 725-3968
Michael V. Polito
Hazardous Material Consultant
Environmental Protection Agency
174 Flanders Drive
Somerville, New Jersey 08876
(201) 321-6652
W. Lawrence Ramsey
Head, NPDES Section
Office of Environmental Programs
Tawes State Office Building (D-3)
Annapolis, Maryland 21401
(301) 269-3821
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Stephen D. Riner,
Pollution Control Specialist
Minnesota Pollution Control Agency
1935 West County Road, B-2
Roseville, Minnesota 55113
(612) 296-7349
Donald P. Satchell
Board Member
Illinois Pollution Control Board
P.O. Box 1210
Carbondale, Illinois 62901
(619) 549-7384
Robert D. Shankland
Environmental Engineer
Environmental Protection Agency
Suite 103, 1860 Lincoln Street
Denver, Colorado 80295
(303) 837-4901
Randy M. Sovie
Head, Industrial Waste Section
West Virginia Department of
Natural Resources
1201 Greenbriar Street
Charleston, West Virginia 25311
(304) 348-8856
Stan Springer
Department of Ecology
Mail Stop PV-11
Olympia, Washington 98504
(206) 753-3864
Edmund J. Struzeski, Jr.
Industrial Waste Consultant
linvironmental Protection Agency,
NEIC
Denver Federal Center, Building 53
Denver, Colorado 80225
(303) FTS-234-4656
Susanna V. Tomlinson
Supervisor, Environmental Compliance
Section
National Fertilizer Development
Center
Tennessee Valley Authority
T101 NFDC
Muscle Shoals, Alabama 35660
(205) 386-2825
Michael A. Travaglini
Environmental Engineer, Environmental
Protection Branch
United States Department of Energy
Post Office Box "E"
Oak Ridge, Tennessee 37830
(615) 576-0848
A. C. Turnage, Jr.
Manager, Permits and Engineering
Department of Natural Resources and
Community Development
P.O. Box 27687
Raleigh, North Carolina 27611
(919) 733-7120
James R. Vincent
Environmental Engineer
National Enforcement Investigations
Center
Environmental Protection Agency
Building 53, Box 25227
Denver Federal Center
Denver, Colorado 80225
(303) 234-4656
Douglas S. Walsh
Environmental Engineer, Division of
Water Resources
Tennessee Valley Authority
A251 "401" Building
Chattanooga, Tennessee 37401
(615) 755-3173
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John Whitescarver Robert G. Wooten
Consultant Supervisory Environmental Engineer
Environmental Protection Agency Water Enforcement Branch
50M Edwards Ferry Road Environmental Protection Agency,
Leesburg, Virginia 22075 Region IV
(703) 777-5665 345 Courtland Street, N.E.
Atlanta, Georgia 30365
Valerie A. Wickstrom <404> 881-2328
Environmental Engineer, Enforcement
Division
Environmental Protection Agency,
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 881-2017/2018
Steven N. Williams
Environmental Specialist
Iowa Department of Environmental
Quality
900 East Grand Street
Des Moines, Iowa 50319
(515) 281-8995
Durwood Willis
Virginia State Water Control Board
2111 North Hamilton Street
Box 11143
Richmond, Virginia 23230
(804) 257-6326
Michael Witt
Assistant Chief, Industrial
Wastewater Section
Wisconsin Department of Natural
Resources
101 South Webster Street
Madison, Wisconsin 53707
(608) 266-1494
William S. Wolinski
Water Quality Coordinator
Department of Public Works
City of Baltimore
305 Municipal Building
Baltimore, Maryland 21237
(301) 396-3441
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NOTES
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Notes
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Notes
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Notes
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