NPDES
Best Management Practices
GUIDANCE DOCUMENT
Environmental Protection Agency
Office of Water Enforcement and Permits
NPDES Technical Support Branch
June 1981
-------
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.
-------
- 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.
-------
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
-------
- 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
-------
- 3 -
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
-------
- 4 -
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
-------
- 5 -
Final Guidance Document
RESERVED
-------
- 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.
-------
- 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
-------
- 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.
-------
- 9 -
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.
-------
- 10 -
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
-------
- 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
-------
- 12 -
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.
-------
- 13 -
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.
-------
- 14 -
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.
-------
- 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
-------
- 16 -
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.
-------
- 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.
-------
- 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.
-------
- 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
-------
- 20 -
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
-------
- 21 -
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.
-------
- 22 -
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
-------
- 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.
-------
- 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.
-------
- 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.
-------
- 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
-------
- 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.
-------
- 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),
-------
- 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.
-------
- 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.
-------
- 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
-------
- 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
-------
- 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.
-------
- 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.
------- |