NPDES

  Best Management Practices
   GUIDANCE DOCUMENT
   Environmental Protection Agency
Office of Water Enforcement and Permits
   NPDES Technical Support Branch

           June 1981

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                          PREFACE

     During the period June 13, 1978, to February 26, 1979,
Hydroscience, Inc., under Contract No. 68-03-2568 to the Environ-
mental 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.  The comment period subsequently was extended twice,
resulting in a total 120-day comment period on the report.  After
evaluating the comments received, EPA revised the draft report,
and published this final document.  This document supersedes the
Hydroscience draft report dated December, 1979.

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                             - 11 -



                          ABSTRACT


     The purpose of this document is to assist National Pollutant

Discharge Elimination System  (NPDES) permitting authorities,

compliance officers and permit applicants to develop Best Manage-

ment 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 general types of discharges to be controlled by BMPs are

plant site runoff, spillage and leaks, sludge and waste disposal,

and drainage from material storage areas.


     This document provides a basis for developing BMP plans.

The proper use  of the document requires engineering experience

with industrial manufacturing and treatment processes and know-
                                                              \
ledge of current laws and regulations applicable to NPOES permits,

BMP plans, and  Spill, Prevention, Control and Countermeasure

(SPCC) plans.


     The guidance herein is based on a review by Hydroscience,

Inc. (EPA Contract No. 68-03-2568) 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 (also termed material

safety data sheets) on specific compounds, and discussions with

industry through telephone contacts, written questionnaires, and

site visits.

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                         SECTION I
                       INTRODUCTION
Backcround
     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 fror.

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, TSS, etc.) were considered the parameters

which most urgently needed controls.  In second round permitting,

however, the Agency emphasis is shifting from the conventional

pollutants to the control of toxic pollutants and hazardous

substances.


     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

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                              -  2  -

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  incorporated as  permit  conditions.   In the  context of the
•NPDES program,  BMPs are  actions or  procedures  to prevent or
minimize the  potential for the  release of toxic pollutants or  •
hazardous  substances 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 listed under  Section  307 or hazardous substances
listed 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)(l) of  the Act allows  the Administrator to
prescribe  conditions in  a  permit  determined  necessary 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

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 Section  311  of  the  Act, 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 favorable comments about the
 Oil Pollution Prevention Regulations, the NPDES BMP regulation
 has been structured to  be similar to the  oil SPCC regulation.

 BMP Regulatory  History

     On  September 1, 1978, EPA  proposed regulations  (43 FR 39282)
 addressing the  use  of procedures  to control discharges frorr.
"activities associated with or ancillary to industrial manufactur-
 ing or treatment  processes".   The  proposed rule indicated how best
 management practices would be imposed in  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 regulat-
 ed by  Subpart K were to develop a BMP program and submit the

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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 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 revised the draft report and published



this guidance documment.







Final BKP Regulation
                            RESERVED

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Final Guidance Document
                            RESERVED

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                             - 6 -
                           SECTION II
                   USE OF THE GUIDANCE DOCUMENT
     This document should be used for guidance in developing BMP.

plans.  The document is not intended to specify site-specific or

pollutant-specific BMPs.  As its name suggests, the NPDES Best

Management Practices Guidance Document is to be considered

guidance by NPDES permitting authorities, compliance officers,

permit applicants and permittees and should be used in a flexible

manner in the formulation of BMP plans.  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 facility's BMP

plan.


     In utilizing this  document to develop a BMP plan, the

applicant/permittee is  encouraged to use the most cost-effective

and innovative techniques to fit the particular facility or

circumstances.  The format and content of a BMP plan may vary

from site to site and industry to industry, depending upon the

specific situation.  In addition, an applicant/permittee nay add,

delete, or modify the elements of the specific requirements

presented in the document where equivalent results can be attained


     If an applicant/permittee needs assistance to develop a BMP

plan, he/she may contact the appropriate permit issuing authority

for advice.  The permitting authority, as necessary, may seek

assistance from the Technical Program Development Section of the

NPDES Technical Support Branch in Washington, D.C.

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                             - 7 -
                         SECTION III
                         BMP PLANS
Scone
     The activities which are associated with or ancillary to the

industrial manufacturing or treatment process are subject to

BMPs.  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

pollutants or hazardous substances 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 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

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                             - 8 -

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.

     Plant runoff is generated principally from rainfall on a
plant site.  -Runoff from material storage areas, in-plant transfer
areas, loading and unloading areas, and sludge disposal sites
potentially could become contaminated with toxic pollutants and
hazardous substances.  Heavy metals from sludge disposal sites
are of special concern.  Fallout, resulting from the plant air
emissions which settle on the plant site, may also contribute
to contaminated runoff.  Contaminated runoff may reach a receiving
body of water through overland flow, drainage ditches, storm or
noncontact cooling water sewers, or overflows from combined sewer
systems.

     In-plant transfer areas, process areas, and material handling
areas encompass all in-plant transfer operations from 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 pollutants and hazardous
substances to other than the process waste water system are
addressed in this grouping.

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     Sludge and hazardous waste disposal areas are potential
sources of contamination of receiving waters.  These 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
pollutants or hazardous substances to seep into the ground water,
eventually reaching surface waters, or for liquids to overflow to
surface waters from 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, SPCC plans for oil and hazardous substances,
safety programs, fire protection, protection against loss of  '
valuable raw materials or products, insurance policy requirements
or public relations.  The minimum requirements of a BMP Plan are
listed in Table 1 and are divided into two categories:  general
requirements and specific requirements.

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              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

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                             - 11 -

General Requirements

     The BMP plan should be organized and described in an orderly
narrative format and should be reviewed by the plant engineering
staff and plant manager.  A description of the. facility, including
the plant name, the type of plant/ processes used,  and-the
                                                i
products manufactured should be included in the BMP plan.  A nap
showing the location of the facility and the adjacent -receiving
waters also should be part of the plan.  Specific objectives for
the control of toxic pollutants and hazardous substances should
be included in the statement of corporate policy.

Specific Requirements

     Each of the 9 specific requirements listed in Table 1 should
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.  A fundamental
concept of the BMP plan is determining the potential for toxic
and hazardous chemicals to reach receiving waters and taking
appropriate preventive measures.

     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.  All
elements may not be applicable to all facilities.  Elements
should be added, deleted or modified to fit the needs of a

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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, 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 BMP plan,
such as identification of toxic and hazardous materials handled
in the plant; identification of potential spill sources; establish-
ment of incident reporting procedures; development of BMP inspec-
tion 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 construc-
tion 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 on BMP-related matters.

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     Plant management has overall responsibility for the BMP



plan.  The plan should contain a clear statement of the management's



policies and responsibilities related to BMPs.  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 mitigating spills and



incidents.





     The size and composition 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,



safety and health specilaists, and treatment plant supervisor



should be included.  In some small plants, the Committee might



consist of the one manager or engineer assigned 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.

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     Elements of the "BMP Committee", listed below,  should be
considered in developing a BMP plan:

     o Inclusion of facility personnel knowledgeable in spill
       control, safety and health, and waste treatment such c~
       environmental specialists/ production foreman,  occupational
       safety and health specilaists, and treatment plant supervisor.
     o 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 and contractor
           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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                               -  15  -



       2.  Risk  Identification  and Assessment



       The areas  of  the  plant  subject to  BMP requirements  should be

•  identified by the  BMP  Committee, plant  engineering group, environ-

  mental  engineer, or  others in the  plant.  Each such area should

  be  examined for the  potential risks for discharges to receiving

  waters  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.
                                       -    f~


       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 materials flowing  from one area to

  another.  The direction of flow of potential spills and  surface

*  runoff  could  also  be estimated  based on site topography  and

  indicated on  the plant site  drawings.   Dry chemicals which are

  toxic pollutants or  hazardous substances should 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".  The  detail  of  the materials inventory should be

  proportionate to the quantity of toxic  pollutants and hazardous

  substances on site and their potential  for reaching 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

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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 could be minimally detailed, and may not
include the identity, quantity, or location of each material but
might 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 would 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 accommodate
fluctuations in public demand.  Consequently, the materials used
for the batch process vary from week to week, oftentimes unexpect-
edly.  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.

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                             - 17 -

     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 informa-
tion should be made available to the BMP Committee but may
require separate filing from the BMP plan documents to protect
proprietary information or trade secrets.  This data may include
physical, chemical, toxicological and health information (e.g.,
technical bulletins or material safety data sheets) on the toxic
pollutants 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.

     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:

     o Identification of areas of the plant subject to BMP
       requirements.

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                             - IB -

     o Examination of  identified areas for potential risks of BMP
       incidents reaching receiving waters.
     o Identification  of existing site-specific or pollutant-specific
       containment measures.
     o Plant plot plans or drawings that clearly label the
       identified areas.
     o Simplified flowsheet(s) of the major process operations.
     o Estimation of the direction of flow of potential discharges
       toward navigable waters.
     o Evaluation of the potential for materials planned for
       future use to be discharged to receiving waters in signif-
       icant amounts.
     o Materials inventory system tailored to the need of the
       particular facility.
     o Physical, chemical, toxicological, and health information
       on the toxic and hazardous chemicals on-site.

     3. Reporting of BMP Incidents

     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 Committee
should include:  notification of a discharge to appropriate plant
personnel to initiate  immediate action; formal written reports
for review and evaluation by management 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.

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                             - 19 -

     The reporting system should designate the avenues of report-
ing and the responsible company and government officials to whom
the incidents would be reported.  A list of names, office telephone
numbers, and residence telephone numbers of key employees in the
order of responsibility should be utilized when necessary for
immediate reporting of BMP 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 the 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

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authorities.  In some circumstances, voluntary reporting to



authorities such as municipal sewage treatment works, drinking



water treatment plants, and fish and wildlife 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:





     o Maintenance of records of incidents through formal reports



       for internal review.



     o Notification as required by law to governmental and



       environmental agencies should an incident occur.



     o Procedures for notifying the appropriate plant personnel,



       and taking preventive or mitigating actions.



     o identification of responsible company and government



       officials;



     o A list of names, office telephone extensions, and residence



       telephone numbers of key personnel.



     o 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

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can be prevented by ensuring that the materials of construction
for containers handling hazardous substances or toxic pollutants
are compatible with the containers'  contents and surrounding
environment.

     Materials compatibility encompasses three aspects:  compati-
bility 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.
     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 delineat-
ing 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 from corrosion.

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     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 compatibil-
ity 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 Compatibility", listed below, should
be considered in developing a BMP plan:

     o Evaluation of process changes or revisions for materials
       compatibility.
     o Incorporation of existing engineering practices  for
       materials of construction, corrosion, and other  aspects of
       materials compatibility.
     o Evaluation of procedures for mixing of chemicals and of
       possible incompatibility with other chemicals present.
     o Cleansing of vessels and transfer lines before they are
       used for another chemical.
     o Use of proper coatings and cathodic protection on -buried
       pipelines if required to prevent failure  due to  external
       corrosion.

     5. Good Housekeeping

     Good housekeeping is essentially the maintenance of a clean,
orderly work environment and contributes to the  overall facility

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                             - 23 -            .






pollution control effort.  Periodic training of employees on



housekeeping techniques for those plant areas where the potential



exists for BMP incidents reduces the possibility of 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 receiv-



ing 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 housekeep-



ing 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:





     o Neat and- orderly storage of chemicals.



     o Prompt removal of spillage.



     o Maintenance of dry and clean floors by use of brooms,



       vacuum cleaners, etc.



     o Proper pathways and walkways and no containers and drums



       that protrude onto walkways.

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                             - 24 -




     o Minimum accumulation of liquid and solid chemicals on the


       ground or floor.


     o Stimulation of employee interest in good housekeeping.




     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 replace-


ment 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) identifi-


cation of equipment or systems to which the PM program should


apply (2) periodic inspections 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.

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                             - 25 -

     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 particular system included or
referenced in the BMP plan.  In general, it will be 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 pla'n:

     o Identification of equipment and systems to which the PM
       program should apply.
     o Periodic inspections of identified equipment and systems.
     o Periodic testing of such equipment and systems.
     o Appropriate adjustment, repair, or replacement of parts.
     o 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 response 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.

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                             - 26 -






     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 inspections 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.  Furthermore, 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 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 "Inspec-



tion 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 significant discharges.  Liquid storage areas should be

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                             - 27 -

inspected for leaks  in  tanks, for corrosion of tanks, for deteriora-
tion of foundations  or  supports/ and for closure of drain valves
in containment facilities.   Inspections could include the examina-
tion 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 systems and pneumatic conveying
systems used for transferring dry chemicals should 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 transfer lines are
disconnected and that there is no evidence of leakage from any
outlet.

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                             -  28 -






     For plant  runoff,  inspections should be used for examining



the integrity of the  stormwater collection system and the diver-



sion or overflow 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 sign-



"ificant amounts.   Inspections also should include diXed areas to



ensure that hazardous and  toxic chemicals are not dischargee frorr.



inside diked areas to waterways.  Any liquid, including rainwater,



should be  examined, and where necessary, analyzed, before being



released from the  diked areas to a receiving water.






     For sludge and hazardous waste disposal sites, visual



inspections should include examinations for leaks, seepage, and



overflows  from  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 Bf-iP plan



by reference.





     Elements of "Inspection and Records", listed below, should



be considered in developing a BMP plan:





     o Inspection  of:



           storage  facilities,



           transfer pipelines,



           loading  and unloading areas,



           pipes, pumps, valves, and fittings,



           tank  corrosion  (internal and external),

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                             - 29 -

          windblowing 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,
          integrity of stormwater collection system,
          leaks, seepage, and overflows from sludge and waste
            disposal sites.
     o Records of all inspections
     o Tracking procedures to assure adequate response and
       corrective actions have been taken when inspections reveal
       deficiencies.

     8. Security

     A security system is needed to prevent accidental or inten-
tional 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 receiv-
ing waters in significant quantities.  Documentation of the
security system may require separate filing from the BMP plan
documents to prevent unauthorized individuals from gaining access
to confidential information.

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                             - 30 -





     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 fox 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 purep starters; and television surveillance of appropriate



plant sites, such as plant entrance, and loading and unloading



areas.





     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 may not be qualified or may 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.

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                             - 31 -

     Elements  of  "Security", listed below, should be considered
in developing  a BMP plan:

     o Routine patrols of plant by security personnel.
     o Fencing*
     o Good  lighting.
     o Vehicular  traffic control.
     o Controlled access at guardhouse or main entrance gate.
     o Visitor passes.
     o Locked  entrances.
     o Locks on certain drain valves and pump starters.
     o Television monitoring.

     9. Employee  Training

     Employee  training programs should instill in personnel, at
all levels of  responsibility, a complete understanding of the BM?
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 conducted at least annually to assure adequate understanding
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 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

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                             - 32 -



or environmental incident drills may serve to improve the employee's

reactions to BMP incidents.  Plants are encouraged to conduct

spill drills on a quarterly or semi-annual basis.  Spill drills
                                      I
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 success-

ful 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 incident's.


     The training program also should 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

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                               -  33  -

  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, 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 in  procedures for preventing BM?
  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:

       o Meetings held at least annually  to assure adequate under-
         standing of program  goals and  objectives.
       o Environmental Incident (Spill) drills used  at least
         semiannually.

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                        - 34 -


o Periodic input from management'.

o Adequate training in particular job and process operation

  and the effect on other operations.

o Transmission of knowledge of past incidents and causes.
       •
o Making employees aware of BMP plan and .incident reporting

  •procedures.

o Training in the use of sorbents, gelling agents, foams,

  and neutralizing agents for cleanup or mitigation of

  incidents.

o Operating manuals and standard procedures.

o Making employees aware of health risks of chemicals

  handled through both the plant's EM? plan and safety

  program.

o Motivating employees concerning incident prevention and

  control.

o Records of the personnel who were trained, and of the

  dates, instructors, subject matter, and lesson plans of

  the training sessions.

o Training and supervision of contractors and temporary

  personnel.

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