EPA REGION X
GUIDANCE MANUAL FOR THE DEVELOPMENT
OF AN ACCIDENTAL SPILL
PREVENTION PROGRAM
February 1986
Propo-tv o' U.S. Envro.-rt-p-
1200 Sixth Avei-iua/
Prepared for:
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Prepared by:
Science Applications International Corporation
8400 Westpark Drive
McLean, Virginia 22102
EPA Contract No. 68-01-7043, WA #P-17
SAIC Project No. 2-834-07-173-83
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TABLE OF CONTENTS
Page
PREFACE
1. INTRODUCTION 1-1
1.1 PURPOSE OF THE MANUAL 1-1
1.2 BENEFITS OF AN ASPP 1-3
1.2.1 POTW Benefits 1-3
1.2.2 Industrial User Benefits 1-4
1.3 OVERVIEW OF THE REGULATORY REQUIREMENTS 1-5
1.3.1 Federal Regulations 1-5
1.3.2 State Regulations 1-6
1.3.3 Local Regulations 1-6
1.4 GENERAL GUIDANCE FOR POTW ASPP DEVELOPMENT 1-7
1.4.1 POTW Overall Strategy for Preventive Program 1-8
1.4.2 POTW Responsibilities in a Spill Response Program 1-9
1.4.3 Requirements of a POTW ASPP Procedural Document 1-10
2. ASPP DEVELOPMENT PROCEDURES/POTW AND INDUSTRIAL
USER RESPONSIBILITIES 2-1
2.1 IDENTIFICATION OF THE INDUSTRIAL COMMUNITY
TO BE REGULATED 2-2
2.1.1 Selection Criteria 2-3
2.1.2 Data Collection and Review 2-7
2.2 CLASSIFICATION OF INDUSTRIAL FACILITIES 2-9
2.2.1 Evaluation of Spill Potential and Effects 2-9
2.2.2 Summary Data Form 2-14
2.3 ADMINISTRATIVE PROCEDURES FOR REGULATING INDUSTRIAL
AND COMMERCIAL FACILITIES CAPABLE OF SPILLS AND/OR
SLUG DISCHARGES TO THE POTW 2-16
2.3.1 Notification of the Affected Sources 2-17
2.3.2 Contents of an Industry's ASPP Submission 2-20
2.3.3 POTW Review and Approval Process 2-22
2.3.4 Inspection and Monitoring of Commercial
and Industrial Facilities 2-22
2.3.5 Industrial Reporting Requirements 2-25
2.3.6 Data Collection/Data Management 2-26
2.3.7 Evaluation of Legal Authority and Enforcement 2-27
2.4 SUMMARY OF CHAPTER 2 2-27
ALBWW
RXODQD01151
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TABLE OF CONTENTS (Continued;
Page
3. POTW SPILL RESPONSE PROGRAM 3-1
3.1 DEVELOPMENT OF RESOURCES 3-2
3.1.1 Personnel 3-2
3.1.2 Equipment 3-3
3.1.3 Finances 3-5
3.2 COORDINATION BETWEEN AGENCIES 3-6
3.2.1 Assistance from Other Sources 3-6
3.2.2 Delineation of Responsiblities and Formaliration
of Cooperative Procedures 3-7
3.3 SPILL SOURCES, DETECTION & NOTIFICATION 3-8
3.3.1 Sources of Spills 3-8
3.3.2 Initial Detection 3-9
3.3.3 Coordination of Response 3-11
3.4 EVALUATION OF INITIATIVE ACTION 3-11
3.4.1 Assessment of Spill 3-11
3.4.2 Safety Considerations 3-13
3.5 CONTAINMENT AND CUUNTERMEASURES 3-15
3.5.1 Containment and Diversion Options 3-15
3.5.2 Treatment Options 3-16
3.5.3 Waste Disposal Options 3-16
3.6 SPILL EVENT INVESTIGATION AND DOCUMENTATION 3-18
3.6.1 Investigative.Actions 3-18
3.6.2 Sampling and Analysis 3-19
3.6.3 Recordkeeping 3-22
3.7 FOLLOW-UP REVIEW AND' ACTION 3-23
3.7.1 Review of IU's Follow-up Report 3-24
3.7.2 Review of IU's ASPP 3-24
3.7.3 IU ASPP Modification 3-25
3.7.4 Civil and Monetary Penalties 3-26
3.8 POTW'S ASPP REVIEW AND MODIFICATIONS 3-26
3.9 FOLLOW-UP REPORTS 3-27
3.10 SUMMARY OF CHAPTER 3 3-27
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TABLE OF CONTENTS (Continued)
Page
4. DEVELOPMENT OF THE POTW'S ASPP PROCEDURAL DOCUMENT 4-1
4.1 INTRODUCTION 4-1
4.2 FORMAT AND INFORMATION REQUIREMENTS OF THE ASPP PLAN 4-2
4.2.1 General and Historical Information 4-3
4.2.2 Evaluation of Legal Authority and
Enforcement Procedures 4-4
4.2.3 Identification of Potential Sources and
Spill Potential 4-4
4.2.4 Administrative Program for Regulating Sources 4-5
4.2.5 Spill Response Program 4-6
4.2.6 Data Management 4-8
4.2.7 ASPP Implementation Schedule and Resources 4-9
APPENDICES
APPENDIX 1 - POTW ASPP DEVELOPMENT
• Flow Chart of Fundamental Procedures for POTW ASPP Development
t Model POTW ASPP
t Model POTW ASPP Format
APPENDIX 2-40 CFR 117 DETERMINATION OF REPORTABLE QUANTITIES FOR'HAZARDOUS
MATERIALS
APPENDIX 3 - DETAILED INFORMATION TO BE CONSIDERED IN DEVELOPMENT OF IU ASPPs.
• Identification of Potential Spill and Slug Discharge Sites and
Pathways
t Existing and Proposed Spill Prevention Equipment
• Spill Prevention Procedures
• Existing and Proposed Spill Response Procedures
• Follow-up Reporting and Documentation Procedures
APPENDIX 4 - EXAMPLE FORMAT FOR AN IU ASPP
APPENDIX 5 - INDUSTRIAL ASPP PLAN REVIEW CHECKLIST FOR POTWs
APPENDIX 6 - EXAMPLE DOCUMENTATION OF A TOXIC SPILL EVENT
APPENDIX 7 - EXAMPLE FORMS TO DOCUMENT SPILL EVENTS
• Spill Notification Log Sheet
• Log of Contact with Other Agencies
• Log of Key Events of the Spill
t Final Report form
APPENDIX 8 - BIBLIOGRAPHY OF REFERENCE MATERIALS
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LIST OF TABLES
Taple Page
2-1 EVALUATION UF SPILL POTENTIAL DATA SHEET (FACILITY STORES
AND/OR UTILIZES CHEMICALS) 2-11
2-2 EVALUATION OF SPILL POTENTIAL DATA SHEET (FACILITY DISCHARGES
STRICTLY CONVENTIONAL WASTES} 2-12
2-3 EVALUATION OF SPILL POTENTIAL SUMMARY DATA TABLE 2-15
3-1 TREATMENT COUNTERMEASURES FOR MATERIALS WITH THE FOLLOWING
CHARACTERISTICS ENTERING THE WASTEWATER COLLECTION AND/OR
TREATMENT SYSTEM 3-17
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PREFACE
This document was prepared for EPA Region X to assist POTWs in
•implementing a component of their Pretreatment Program, namely the prevention
of accidental spills and slug discharges from industrial users. Such spills
and slug discharges coulo cause damage to a POTWs collection system, inter-
fere with the operation of its treatment plant, affect water quality and
sluage usage, and potentially affect worker health and safety.
To rteiynten the POTWs' level of consciousness regarding not only
regulation of "normal" wastewater discharges from their significant
industries, but accidental spills and slug discharges from all potential
industrial and commercial users, the EPA Region X Office has required local
sewerage agencies to develop an Accidental Spill Prevention Program (ASPP)
that outlines a commitment from each POTW authority to consciously implement a
program to prevent spills and slug discnarges from occurring as well as
respond to them.
This document is not "intended to replace local programs that address
hazardous waste management in the community. Fire Departments and County
Health Departments may already have programs to respond to hazardous spills;
however, their programs may not always involve coordination with POTW offi-
cials. The document was developed to assist POTWs in developing programs that
would prevent spills and slug loads from entering the POTW, and provides
information on evaluating the spill and slug load potential of industrial and
commercial facilities. Throughout the document, a team concept of managing
hazardous materials in the community is stressed. Cooperation between the
POTW and specialized personnel of other local agencies, such as Hazardous
Material Response Teams and Fire Departments, is strongly recommended and
would be beneficial to program implementation. Again, it Is important to note
that although this document addresses both spill and slug load prevention and
response, its primary focus is prevention.
Throughout this document, the term "spill" is utilized^ The reader may
connect the term strictly with toxics or hazardous wastes. Although the
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document does lean towards a discussion of prevention and response to toxic
spills because of their severity, tne need to coordinate witn other response
agencies, and the need for specialized training and equipment, it is important
for the POTW to recognize that slug discharges of high strength conventional
wastes can result from an accidental spill at a processing plant. For
example, a worker at a dairy could accidentally spill whey into the sewer
system, or a faulty valve at a food processing plant could result in a slug
discharge of high strength wastes entering the sewers.
The POTW will need to think in terms of conventional and toxic wastes
throughout this document, particularly in developing its ASPP.
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1. INTRODUCTION
i.I PURPOSE OF THE MANUAL
This manual was developed to provide guidance to publicly owned treatment
WOTKS (POTWs} in the development and implementation of an Accicental Spill
Prevention Program (ASPP). Although targeted to POTWs required to implement a
local pretreatment program, it should be useful to other POTWs as well.
An ASPP developed by a POTW is a set of procedures and a regulatory
structure that will minimize the occurrence of accidental spills of hazardous
materials and slug discharges of high-strength conventional pollutants from
industrial and commercial establishments. These types of discharges can
damage a collection system, cause interference at the wastewater treatment
plant and impact water quality and sludge utilization. These discharges can
also adversely affect public health and safety and could potentially harm
workers at the industrial site, along the collection system, or at the
municipal treatment plant.
The important elements of an ASPP include the following:
• Identification of potential sources and risks
• Evaluation and/or development of legal authority to regulate spills
and slug discharges
t Requirements for industrial users (IUs) to develop ASPP plans and
suomit them to the POTW for review
t Inspection and monitoring of potential sources of problem discharges
• Development of emergency response procedures and resources.
An ASPP plan should not simply focus on significant industrial sources.
Other apparently insignificant users can -have the potential for spillage of
toxic chemicals into floor drains connected to the POTW. The POTW should
investigate facilities that claim to be dry but store large volumes of
chemicals onsite. Such facilities include: chemical warehouses, radiator
shops, major engine rebuilding shops, railroad yards, pesticide applicators,
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commercia'; truck washing ooerations, and railroad tank car wasninc operations.
In addition, fooa processors, meat pacxayers, and otner industries wno nave
seasonal discharges or batcn discharges that could result in significant slugs
of conventional wastes to the PUTWs wastewater treatment system should also
be investiyatefl.
At tne onset, it must oe stressed tnat this manual is not advocating that
a program separate from the pretreatment program be developed by POTWs.
Implementation of a program to prevent spills and slug discharge is implicit
in the general pretreatment regulations (40 CFR Part 403), and as such should
be considered an inherent part of a local pretreatment program strategy.
Most POTW pretreatment programs are generally designed to regulate the
normal discharge of wastewater from categorical industries, such as electro-
plater/metal finishers, pulp and paper processors, organic chemical manufac-
turers, and industries discharging high-strength conventional wastes such as
food processors. If the POTW staff is conscientious during their pretreatment
compliance inspections and look for evidence of past spills or poor house-
keeping, chemical storage, and waste disposal methods, some level of control
of the industrial user will result. However, most POTWs have not developed
written procedures for a spill prevention program. Region X feels that such
written procedures are necessary for protection of the POTW, its employees,
and the community.
For those POTWs who have designed their pretreatment program strategy to
include written procedures for preventing accidental spills and slug dis-
charges, as well as responding to them, this manual should serve as an addi-
tional resource to POTW staff. Some modification to existing procedures may
be recommended by the staff after review of the manual. For the balance of
the POTWs, this guidance manual should assist in the development of logical
and straightforward written procedures that can be easily implemented.
The size of the community and its basic needs and resources will
generally dictate the scope of the POTW's ASPP strategy and written
procedures. This manual provides the basic framework upon which the POTW can
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develop its ASPP. Specific information is provided on: spill potential/risk
assessment, spill prevention, minimization of spill potential ana impact,
spill containment, and industrial user spill response procedures, including
notification and reporting requirements.
Appendix 1 includes a flowchart of the fundamental procedures in the
development of an ASPP and a model POTW ASPP format, and an example POTW ASPP.
These items snould assist the POTW in developing an ASPP tailored for the
community it serves.
1.2 BENEFITS OF AN ASPP
POTW or IU ASPPs provide the greatest benefit in minimizing the potential
for emergency situations by initiating forethought and planning to develop
preventive controls and procedures. Development of an ASPP provides an
opportunity to assess the potential for spills and slug discharges from indus-
trial users, and to develop appropriate response techniques and procedures for
emergency situations.
1.2.1 POTW Benefits
By identifying and categorizing potential spill and sluy discharge
sources arid implementing a program to prevent such discharges, the munici-
pality can work to minimize the risks associated with these sources. Instal-
lation of spill prevention and control equipment and appropriate training of
the industrial and POTW personnel can aid in minimizing the risks. Addition-
ally, by identifying the types of spills and slug discharges likely to occur,
the City can coordinate with other agencies and develop the resources nec-
essary to respond to a variety of events. Anticipation of problems and
preparation for emergency response will benefit the POTW. The chance that
spills or slug discharges of hazardous materials, or high strength conven-
tional wastes will occur, cause damage to the treatment plant, interfere with
the treatment plant operation, affect water quality or sludge utilization, or
cause harm to the safety and health of workers will be greatly reduced.
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1.2.2 Industrial Use" Benefits
An industrial user, wnether its manufacturing process generates process
wastewaters or not, can also greatly benefit by developing an ASPP for the
facility. Where the potential exists for an accidental spill of chemicals or
process waters to occur, worker safety can be maximized by the safe handling
of hazardous materials and the minimization of tne spill potential. Addi-
tionally, as a result of spill prevention measures an industry may be able to
recycle or reclaim process materials that might otherwise be lost to the
sewerage system and reduce the penalties imposed by a POTW for contribution of
excess strength loadings.
If the industrial user's chief concern is prevention or minimization of
slug discharge of nigh-strength wastes, flow equalization techniques and
structures, proper instruction to staff, and POTW notification will greatly
enhance the POTW's ability to operate its treatment plant within. NPDES permit
limits. These measures will also help reduce the industry's operating costs,
as well as extra costs that may be borne by the industry if its discharges
cause damage to the collection system or treatment plant.
Finalization and documentation of the preventive measures and "house-
keeping" procedures to be employed by the IU will provide a means of
instructing all facility employees of the proper control procedures. Spill
prevention, spill response, cleanup, and POTW notification procedures included
in an industrial ASPP should ensure that all employees can initiate the appro-
priate response to a spill or slug discharge and minimize industry liability.
Some lUs may not need a "fancy" or detailed ASPP. Good housekeeping prac-
tices, employee education, and timely notification to the POTW may be all that
is needed.
Finally, the effort and finances expended towards spill prevention will
be far less than what is needed for cleanup of a hazardous material spill and
payment of appropriate fines. The economics of spill cleanup alone can
justify the development of preventive measures.
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1.5 OVERVIEW OF THE REGULATORY REQUIREMENTS
The regulatory basis for control of spills can be found at most levels of
government from Federal regulation to local sewer use ordinances. Each
specific regulation may focus on a particular type of waste or discharge, but
in general the common goal is the prevention of improper and unsafe disposal
of hazardous materials or slug discharges of high-strength wastes.
1.3.1 Federal Regulations
There are many Federal Regulations that deal with the discharge and
disposal of hazardous materials. Specific Congressional Acts such as the
Resource Conservation and Recovery Act (RCRA), and the Clean Water Act (CWA)
regulate the disposal of waste materials so as to protect the environment and
improve human safety.
RCRA primarily focuses on the disposal of hazardous waste by methods
other than discharge to a POTW or a surface water. The EPA has published a
document to provide POTWs with a better understanding of RCRA requirements.
The document is titled RCRA Information on Hazardous Hastes for Publicly Owned
Treatment Works (September 1985) and is available from the EPA Region X
office.
The CWA regulates the following types of discharges to surface waterways:
from direct sources such as a POTW or an industrial facility; indirect
sources, such as an industrial facility discharging to a POTW; and other
discharges like those from nonpoint sources such as agricultural runoff.
While the NPOES permit system regulates direct discharges, the pretreatment
program regulates indirect discharges to POTWs.
The Spill Prevention Control and Counter-measures (SPCC) program (40 CFR
Part 112), developed under Section 311 of the CWA, currently addresses
accidental spills resulting from the storage of petroleum products. The SPCC
regulation provides a basis for assessing the risk of accidental petroleum
spills and the adequacy of preventive and control measures. The regulation
also establishes a schedule of fines and penalties. Although the regulation
specifically addresses petroleum storage, many of the preventive and control
measures are applicable to the storage of other hazardous materials. In
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aaaltlon to tne SPCC requirements, otner regulations unaer Section 311 of tne
Clean Water Act address spills of Hazardous materials. The regulations detail
tne reporting requirements for specific hazardous materials and the fines and
penalties that can De levied. Appendix 2 includes a listing from 40 CFR 117
that presents the reportable quantities of hazardous materials subject to
Federal regulations. A method to change the reportable quantities which are
listed in pounds into an equivalent gallon value is discussed in Section 2.2.1
of this document.
The CWA also addresses spills of hazardous or toxic substances and slug
discharges through NPDES permit requirements and the pretreatment program. As
mentioned earlier, it is explicit within the General Pretreatment Regulations
that spills of toxic materials and slug discharges of high-strength wastes can
have a detrimental effect on a POTW. A POTW pretreatment program should be
designed to regulate the routine discharge of manufacturing process waste-
waters, as well as prevent these incidences from occurring.
1.3.2 State Regulations
The specific regulations each state may have to supplement the Federal
regulation will vary. From the standpoint of dealing with hazardous wastes,
the State may have a response team or advisory personnel that may be called
upon to assist in a spill event. They may also be able to activate contin-
gency funds to pay for the initial cleanup costs before the responsible party
can be identified. During development of the POTW ASPP, the POTW should
review the State regulations and policies addressing hazardous waste disposal,
discharges of hazardous materials to POTWs, and accidental spills of toxic
chemicals or slug discharges of high-strength wastes to POTWs. The POTW staff
should also talk with the appropriate State agencies to determine what future
regulations are planned and what assistance may be available.
1.3.3 Local Regulations
The sewer use ordinances of many municipalities may already include
prohibitions against the discharge of hazardous materials and slug discharges,
as well as requiring industries to develop ASPPs. The sewer use ordinance may
also specify reporting requirements for accidental spills and may cite
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specific fines and penalties that could be levied as a result of a spill or
slug discnarge or failure to notify tne POTW. If tne sewer use ordinance does
not address these items, the City may want to consider amending the ordinance
to clarify and strengthen the City's authority. Appendix 1 provides an
example of language in an enacted sewer use ordinance (as part of the model
POTW ASPP). It addresses some of the issues noted above. In addition, a
community can develop an ordinance that addresses hazardous materials storage,
use, and disposal. The ordinance can detail specific secondary containment
requirements for chemical storage, chemical inventory reporting requirements,
and cooperative efforts between the POTW, the fire department, and any other
appropriate agencies.
1.4 GENERAL GUIDANCE FOR POTW ASPP DEVELOPMENT
An ASPP strategy developed by a POTW should involve more effort in
prevention and therefore a limited need for response. The key to an ASPP
implemented by a POTW will be well-defined procedures for prevention of spills
of toxic materials and sluy discharges of high-strength wastes. These
procedures should be straightforward, and written in the format of a simple
procedural document. The basic framework of the program should include the
following:
Spill Prevention Program
• Identification of potential sources and risks associated with each
industry
0 Evaluation of legal authority to regulate spills and slug discharges
• Evaluation of staff and resources
• Development of an administrative program for regulating sources
- Notification of affected sources
- use of an enforcement mechanism (permit, contract, industrial waste
acceptance form) to convey IU ASPP requirements
- Requi rement for IU ASPP
- POTW review of IU ASPP
- Data management
• Inspection and monitoring of industrial sources.
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Soil1 Response
• Emergency response procedures
- Training of POTW staff
- Coordination procedures with other appropriate agencies
- Detection and notification of spills and slug discharges
Evaluation of spills and slug discharges
- Spill containment and counter measures/slug discharge mitigation
measures
• Acquisition of spill response, sampling, and safety equipment
• Spill event and slug load investigation and documentation
• Recovery of damages (enforcement)
e Evaluation of POTW and IU ASPP effectiveness.
Each of the above topics is fully discussed in the following chapters.
Again, it is stressed that the above activities should be considered part of a
local pretreatment program. Developing procedures for addressing the
potential for spills and slug discharges will communicate to the Approval
Authorities (State or EPA) and the industrial community that the POTW is
committed to protection of the integrity of its collection system and
treatment plant and to the protection of public health and the environment.
1.4.1 POTW Overall Strategy for Preventive Program
POTW officials need to determine the potential risks for problem
discharges throughout the community during development of an ASPP. Each
industry regulated by the POTW's pretreatment program, as well as other
facilities that store, use, or treat hazardous materials and have a sewerage
connection, and all others (industrial and commercial) who have the potential
to discharge prohibitive type wastes or slug discharges of high strength
wastes that could have an effect on the treatment system, should be evaluated.
Hazardous material spills and slug discharges to a wastewater treatment
facility may originate throughout the service area from three general
categories of sources:
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• In-transit facilities sucn as barges, railroad cars and tanK trucks
(generally wasning operations)
• Stationary facilities including manufacturing plants, warehouses,
chemical processing plants, power generating, facilities, food
processors, service stations, tank farms, truck and train terminals
• Infiltration into the sewerage system from underground sources (e.g.,
leaking tanns).
The evaluation of spill and slug load potential and possible effects is based
on a number of factors discussed in detail in Chapter 2.
A POTW's ASPP program will regulate these industries by requiring some to
develop ASPPs of their own. Not all industries will need to develop programs,
but all should have an understanding of the regulations and most importantly
the reporting requirements in the event of a spill or slug discharge. The
POTW may develop a tiered system to regulate industrial users. High risk
facilities may be required to develop full ASPP programs, while low risk
facilities may only need to provide information on chemical storage and use
practices, an industry contact and telephone number and be required to notify
the POTW in the event of a spill or slug discharge. A telephone number that
can be used to contact an industry representative(s) during both operating and
nonoperating hours should be obtained in all cases.
The POTW review of the industrial ASPP will provide the necessary
oversight to ensure the information reported by the industries is complete.
Accuracy o-f the information can be determined through the POTW's ongoing
inspection program and/or by the fire department's inspection of fire hazards.
1.4.2 POTW Responsibilities in a Spill Response Program
A POTW ASPP must not only contain procedures for prevention but must also
contain procedures for responding to spills and slug discharges. In many
cases, responding to spills is handled by other local agencies, such as fire
departments, and possibly State and Federal agencies. Consequently, some of
the tasks outlined in this manual may already be performed by these agencies.
However, it must be recognized that the POTW is ultimately responsible for
material that enters its collection system. All POTWs must recognize the need
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for defining tne cooperative roles anc responsi oi lines of various local/
State/Federal agencies in tne ASPP. wnere mere is overlap in aesnanatec
responsibilities, the appropriate lead authority should be described in the
ASPP.
Local emergency response agencies (police and fire departments) often
involved witn controlling a hazardous spill yenerally are not aware of the
operations of the wastewater treatment plant. Emergency agencies have only
recently become aware of the ramifications of flushing spilled materials into
the nearest sewer. rf_coordinatlon does not presently: .exist.,-Ji_will_be
impj)rta.nt_fpr the emergency response, agencies and tne POTW, to develop the
needed cpordtnat^Qn and training. For emergency response agencies this would
mean proper training on handling hazardous materials and communication with
the POTW; identification of alternatives for handling spills; and developing
an understanding of the ramifications of these alternatives to wastewater
collection and treatment systems. If a local hazardous materials spill
contingency plan is developed, the wastewater treatment agencies should
participate in the development.
Sharing these responsibilities will not relieve the POTW of its
requirement under the pretreatment program. In all coordinated efforts the
POTW should be sure that the ASPP 1s being properly implemented. Coordinated
efforts should be detailed in the ASPP so that all parties are aware of their
responsibilities, and to ensure that all areas of an ASPP are being addressed.
Documentation of coordinated efforts will show EPA Region X who is conducting
the individual elements of the POTW ASPP.
1.4.3 Requirements of a POTVi ASPP Procedural Document
The ASPP procedural document that the POTW develops should clearly
specify the following: the criteria used to identify the sources and evaluate
the risk in the industrial community; criteria used to review the industrial
user ASPP; administrative system for preventing spills and slug discharges,
inspecting and monitoring the industrial users and spill and slug discharge
response procedures. In addition, a discussion of the staffing requirements,
and legal authority should be included in the document. As noted previously
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the details of coordinated efforts with otner agencies should also be
documented.
The ASPP document should be appropriately sized to describe in detail the
POTW's program. However, a lengthy document to describe a small program is
not necessary; rather the document should be as concise as possible. Specific
recommendations for the procedural document are discussed in Chapter 4.
Note:
In formulating its ASPP, a POTM may discover that there is no single
local agency responsible for responding to spills, or that an agency does not
have adequate resources, equipment, training or necessary procedures. If this
is the case, the POT* has its work cut out. A decision will have to be made
regarding which local agency will take the lead. If the POTH takes on the
lead, the ASPP will need to be comprehensive and will take a substantial
effort. The document that is submitted to Region X will most likely need to
include a schedule for development of detailed written response procedures.
Chapter 3 provides guidance on areas that should be covered.
For the majority of the cases, there will already be a local, State, or
federal agency with the lead responsibility. The POTH staff will need to meet
with them to review their procedures to ensure that the POTW's interests have
been taken into consideration. At a minimum, under this scenario the POTH
must be notified of any spill that has the potential to be discharged to the
sewer system so that staff can react. Accordingly, Chapter 3 does discuss
response activities by the POTH where another agency is the lead such as
notification, on-scene response by a POTH staff member, cooperative agree-
ments, sampling, diverting wastes that have already entered the sewer system,
containing wastes at the site, regulating flows in the sewer lines, follow-up
investigations and review of IU ASPP. Additionally, the model ASPP in
Appendix 1 assumes that the POTH is not the lead agency for spill response.
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2. ASPP DEVELOPMENT PROCEDURE5/POTW AND
INDUSTRIAL USER RESPONSIBILITIES
As outlined in tne previous chapter, an ASPP developed by a POTW should
have two basic components: procedures for prevention of spills and slug dis-
charges, and procedures for responding to these discharges. This particular
chapter will focus mainly on the preventive component. Chapter 3 is dedicated
to a discussion of the response component.
The following areas will be covered in this chapter:
• Identification and classification of the industrial and commercial
community to be regulated.
• Administrative procedures for properly regulating the affected sources
of potential spill's and slug discharges. This will involve:
- Notification of affected sources
- Development of IU ASPP requirements
- POTW review and approval of IU ASPP
• Inspection and monitoring of industrial and commercial facilities.
• Data collection/data management.
• Evaluation of POTW legal authority.
The detailed information provided in this chapter should- be used to guide the
POTW through the development of procedures that are specific to the POTW and
meet the need to adequately reduce the risk of accidental spills and slug
discharges.
Because accidental spills of hazardous materials in many cases are a
potentially serious problem for the user as well as the POTW, much of the
discussion deals with spills of hazardous materials. This is not to say that
slug discharges of nonhazardous high-strength wastes cannot pose a serious
problem. The ASPP developed by the POTW must also include procedures for
preventing slugs of high-strength wastes from occurring and procedures for
responding to them. This guidance manual is simply recognizing that generally
POTW personnel are more familiar with nonhazardous high-strength discharges.
2-1
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L/REG X-4/#8
2.1 IDENTIFICATION-OP THE INDUSTRIAL COMMUNITY TO BE REGULATED
The Accidental Spill Prevention Program (ASPP) is designed to prevent
accidental spill and slug discharge of materials that could damaye the POTW
and/or endanger the community and the environment. These human health/
environmental impacts include:
t Potential tnreat to the health of industry workers, local residents,
and/or cleanup personnel
• Potential upset/shutdown of tne POTW's operation
• Potential contamination of local drinking water sources and/or ground-
water
• Potential impacts of water quality if the materials pass through the
plant or upset the plant resulting in unacceptable levels of BOD and
TSS discharged to the receiving waters
• Possible contamination of POTW's sludge.
The most critical part of a POTW ASPP is the actual determination of
industrial and commercial sources that have the potential to spill hazardous
materials or to overload the municipality's treatment plant with high-strength
wastes. If a POTW conducted a comprehensive industrial survey as part of
developing its pretreatment program, the task at hand should be straight-
forward and simple. If gaps do exist in the original industrial survey, some
follow-up of the survey may be required to secure the necessary data to allow
the POTW to realistically assess which users have the potential to spill
material or slug load high-strength conventional wastes. This information
will help the POTW determine which industries will need to develop ASPPs of
their own and which users will require close scrutiny by way of inspections.
If additional information is needed, it can be collected by using a
comcination of the following methods:
t Developing a simple questionnaire that asks specific questions
concerning materials used, produced, and wasted, and information on
floor drains, discharge points, etc.
• Conducting a site inspection of potential facilities to verify
existing data and/or to collect additional information.
2-2
-------
L/REG X-4/#8
• Review Fire Department recoras of commercial ana industrial
insoections.
• Review EPA listing of hazardous waste generating facilities. Tnis can
be obtained from the EPA Region x office.
The determination of those facilities for which an ASPP is applicable are
discussed below. Also discussed in this section are data collection and
review procedures required in making this aetermination. The selection
criteria presented in this section should be used to evaluate the spill
potential of industrial facilities. Categorization of the industries is
further discussed in Section 2.2, Classification of Industrial Facilities.
Note;
A common procedure by POTWs in conducting the original industrial user
survey was to Initially screen out establishments of no immediate concern and
those that did not have a "process discharge." A POTW might have concentrated
on collecting data via a questionnaire on facilities that routinely discharge
process wastewaters. In some cases, the questionnaire may not have requested
information on the storage and disposal of chemicals, an IlJ's ASPP, presence
of floor drains, and potential-for accidental spills or slug discharges. This
being the case, a number of facility types (such as those listed in Section
2.1.1) may not have been surveyed to determine the potential for spills of
toxics or slug load of high strength wastes.
2.1.1 Selection Criteria
In most communities, the POTW and local fire department share the
responsibilities associated with initial emergency spill response within the
community, whereas for slug discharges of high-strength wastes, the POTW is
strictly responsible for prevention and response. Where dual responsibility
exists for toxic spills, the POTW should be prepared to coordinate spill
response activities at the industrial user sites, as well as deal directly if
the spill enters the collection system. Moreover, the POTW should also be
aware of the types and quantities of chemicals transported in and out of the
community, and should be prepared to respond to spills occurring as a result
of chemical transport.
2-3
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L/REG X-4/*8
In identifying industrial facilities reauirec to suomit an ASP0 plan of
us own, tne POTW should consider tne types ana quantities of cnemicals storec
at each Industrial facility. For discharges of conventional wastes (such as
food processors, meat packers, breweries, concentrated groups of restaurants
that discnarge fats, oils, and greases), the POTW needs to assess the poten-
tial for slug discharges, particularly if the user has an intermittent or
seasonal discharge or a history of problems with high-strength wastes.
A POTW should not just consider the significant industrial users they
regulate through the pretreatment program. Facilities regulated under the
ASPP could be expanded to include facilities that may occasionally discharge
spent chemicals, oils, solvents, and contaminated wastewater. These include
the following:
t Major printing and publishing firms
• Radiator shops (these discharges may corrode sewer lines and contain
extremely high concentrations of lead, copper, zinc, ethylene glycol,
etc.)
t Major automobile repair shops
• Industrial laundries
• Commercial pesticide and agriculture suppliers who may mix chemicals
in tanks and wash the tanks down into floor drains
• Railroad tank car cleaning facilities (railroad yards)
• Commercial truck washing facilities.
Facilities with a relatively minor wastewater discharge but which may store
large quantities of toxic chemicals (including warehouses) could also be
regulated by the ASPP. Industrial facilities who possess a NPDES permit, but
could have the potential or history of accidentally spilling material into the
sewers via floor drains should also be investigated.
It is important for POTW and IU personnel to recognize the types of
chemicals which can cause problems when discharged to the sewerage system.
The following chemical types are likely to cause one or more of the adverse
impacts described earlier:
2-4
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L/REG X-4/#8
• Strong acias (e.g., hydrocnioric acid, sulfuric acid, nitric acid,
chromic acici, etc.;
0 Strong cases (e.g., caustic soda, lye, ammonia, r.,ae, etc.)
• Noxious/fuminy chemicals (e.g., phosphorous pentachloride or
oxycnloride, hydrofluoric acid, benzene, chloroform, etc.)
• Flammable chemicals (e.g., phosphorous pentasulfide, acetone, napntha,
methyl isooutyl ketone, sodium sulfide, hexane, cyclohexane, etc.)
• Explosive chemicals (e.g., TNT, nitroglycerin, metallic sodium,
ammonium nitrate, picric acid, lead azide, etc.)
• Oxidants (e.g., chlorine dioxide, phosphorous pentoxide, potassium
permanganate, sodium chlorate, etc.)
• Reductants (e.g., sodium borohydride, phosphine, methyl hydrazine,
etc.)
0 Oils and fuels (e.g., diesel oil, bunker fuel oil, gasoline, cotton-
seed oil, linseed oil, etc.)
• Tars, creosotes, and pitch
• Varnishes, laquers, and waxes
• Paints, pigments, and thinners
• Dyes and inks
• Plating baths
0 Pickling liquors
• Detergents
0 Biological wastes {a slug discharge of antibiotics could reduce the
population of organisms at the treatment plant reducing wastewater
treatment efficiency)
0 Metal sludges (e.g., metal hydroxide sludges from pretreatment
operations)
0 Toxic wastes (e.g., pesticides, etc.)
• Resins (e.g., ABS resins, phenolic resins, vinyl resins, etc.)
0 Chemical feedstocks (e.g., nitrobenzene, aniline, phenol, cumene
phtnalic anhydride, cyclohexane, etc.)
2-5
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L/REG X-4/#8
• Solvents (e.g., alcohols, methyl etnyl ketone, metnyl isobutyl ketone,
furfural, aioxane, etc.)
• Radioactive materials.
The above list should not be considered a definitive list of hazardous
chemicals.
The POTW should develop criteria for making determinations on which
industrial facilities will be required to develop an ASPP. This criteria
should consist of setting cutoff values for volumes of various chemicals. If
a facility normally stores less than the cutoff value of a certain chemical,
then an ASPP may not be required. On the other hand, if the facility normally
stores more, or in the future could potentially store more than the cutoff
value, then the facility should be required to have an ASPP.
To assist the POTW in developing an understanding of what a significant
amount of a particular chemical may be, Appendix 2 presents the Federal
regulation concerning the "reportable quantities" of chemicals regulated by
Section 311 of the CWA. This section of the law does not address all of the
chemicals a POTW may be concerned with. The selection criteria cited in this
section are provided merely as guidance. Regulation of an industry by the
ASPP should depend upon the nature of the materials stored within its juris-
diction, the spill controls and procedures present at the IDs, and/or local
emergency response capabilities.
Identification of sources of nonhazardous high-strength slug discharges
is easier than that for sources of hazardous chemical spills. In most cases,
POTW officials have a fairly good knowledge of those industries that discharge
conventional wastes where there exists the potential for slug discharges.
Historical records, such as the POTW's user surcharge program, are generally
all that is needed for the POTW to assess which of these industrial or
commercial user types need to develop an ASPP.
2-6
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L/REG X-4/#8
2.1.2 Data Collection and Review
In oraer to ascertain the nature and quantifies of hazardous materials
stored within and/or transported through a POTW's jurisdiction and to deter-
mine the potential for spills or slug discharges of high-strength wastes, the
POTW must have access to relevant data from the industrial facilities
involved. The POTW can obtain this information from the following sources:
• The industrial waste survey conducted during pretreatment program
development or permit application
t Baseline Monitoring Reports
• Local permit applications (Data Disclosure Form)
• NPDES permit applications
• Industrial user inspection reports
• Local emergency response agencies (e.g., fire department, county
health department)
• State/Federal agencies responsible for emergency response as well as
implementing RCRA requirements
• ASPP site Investigation reports.
As discussed earlier in this chapter, the original industrial waste survey, if
comprehensive, should provide the POTW with a significant amount of informa-
tion regarding the types and quantities of chemicals stored at each industrial
user of the POTW and the potential for slug discharges of conventional pol-
lutants. The survey should also provide information regarding the exact
locations of each industrial user's sewer connections. Thus, the routes by
which a spill or slug discharge could enter a POTW collection are readily
identified. Additionally, the survey should provide information on the size
and operation of each facility. This information can be valuable in assessing
the potential magnitude and probable transport time of chemical spills from an
industrial facility to the treatment plant.
If the POTW's industrial waste survey questionnaire or permit application
does not address these points the POTW should consider modifying the question-
naire or the pretreatment permit application to request the desired data. The
2-7
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L/REG X-4/#8
POTW car tnen use the responses to update their pretreatment files. Specifi-
cally, the following Information should be provided oy eacn industrial user:
• Industry name and address
• SIC codes applicable to the industry
• Wastewater flow data
• Analytical data on wastewater discharges
• Listing of products manufactured
• Description of pretreatment practices
• Locations of wastewater discharge points
t Raw materials inventories and storage locations (i.e., chemical
utilization)
• Location of floor drains, sumps, etc.
• Flow diagram and sewer map of the facility
• Numoer of employees
• Operation and production schedules
t Potential for spills or" slug discharges
• Spill prevention plans or control measures currently adopted.
Many noncategorical industries or insignificant industrial users and all
direct industrial dischargers are not routinely inspected as part of the
POTW's pretreatment program. However, it is recommended that the POTW conduct
initial ASPP investigations of all industrial facilities that have the
potential to spill chemicals or discharge high-strength wastes. As long as an
industrial facility is connected to the sewer, the POTW usually has the
authority to conduct such an inspection. The types of information the POTW
should collect while conducting ASPP inspections are discussed in more detail
in Section 2.3.4 of this manual.
Contacting the local fire department and/or the State/Federal agencies
responsible for tracking the use and storage of chemicals and responding to
spills is a very essential step in the process. Fire departments routinely
inspect industrial and commercial facilities to assess fire hazards and will
generally have a file on industries listing chemicals utilized. Some fire
departments may already require some industrial facilities to develop an ASPP
and to install spill containment equipment.
2-3
-------
L/REG X-4/#8
Additionally, under the Resource Conservation and Recovery Act (RCRA),
industrial ana commercial facilities wno use, generate, store, or transport
RCRA regulated materials are tracked by the State and/or EPA. These
facilities were required by the RCRA regulations to submit information to the
appropriate authority regarding the types and volumes of materials handled.
The POTW should be able to contact the appropriate agency to access infor-
mation in their files for facilities located within the POTW's jurisdiction.
RCRA generally applies only to hazardous wastes. Industrial facilities are
not required to submit information on hazardous materials that are not wastes.
The EPA guidance manual entitled RCRA Information on Hazardous Wastes for
Publicly Owned Treatment Works provides the specific information for POTWs
regarding the regulation of hazardous wastes. The above information and
sources of information should assist the POTW in assessing the potential for
chemical spills at these facilities, as well as the potential impacts of
spills.
Note:
If the POTW lacks the essential information to assess whether all
industrial and commercial facilities have the potential to spill toxics or
slug discharge conventional pollutants, then It will need to conduct a
streamline survey to update its original survey. This will need to be
described in the POTW's ASPP document and submitted to Region X, along with a
schedule for completing the taste.
2.2 CLASSIFICATION OF INDUSTRIAL FACILITIES
2.2.1 Evaluation of Spill Potential and Effects
In Section 2.1, fundamental data sources and potential toxic materials
were described. A POTW might use these to assess which industrial facilities
within its jurisdiction could potentially create a chemical'spill or slug
discharge of high-strength wastes injurious to human health or the environ-
ment. In assessing the risks associated with these potential sources, several
factors must be taken into account for each industrial facility. Such factors
as the following should be assessed:
2-9
-------
L/REG X-4/#8
t Volume anc type of cnemicals stored
• Volume ana type of discharge of conventional wastes
t Existence of spill prevention and contingency procedures and training
programs
• Presence of spill controls and structures
• Potential effect of spills and slug discharges
t Locations of Indirect discharge points
t Results of Inspections
t Historical perspective on the potential sources (i.e., source has a
history of spills and/or slug discharges).
Note:
In order for the POTW to conduct a thorough evaluation, an inspection of
the facility usually needs to be conducted. A POTW inspector can generally
determine at a glance such things as good housekeeping practices, improper
storage and containment, and general condition of the facility.
This information can be used to determine the industrial facility's spill and
slug discharge potential. The facilities can then be separated into low-risk,
moderate-risk, and high-risk groups. Administrative procedures will probably
vary between each group, high-risk facilities requiring formal ASPPs and
frequent POTW inspections, low-risk facilities only being advised of the POTW
ASPP requirements with some limited monitoring by the POTW.
The information collected from each industry can be organized through a
table such as is shown in Tables 2-1 and Table 2-2. In these tables, the
following information is presented:
• The industry's name, address, and phone number (for the specific risk)
• Responsiole industry official(s)
• Nonbusiness hour phone number(s)
2-10
-------
•RE5. 1-4/ilO
TABLE 2-1.
EVALUATION OF SPILL POTENTIAL DATA SHEET
(FACILITY STORES AND/OR UTILIZES CHEMICALS)
Inaustrv Name:
Inaustry Address:
inaustry Pnone:
XYZ Plating Co.
100 Main St.
Any town, IN 90922
(994) 909.9099; Mr. Jonn Smitn, Superintendent
Chemical
Cadi mum cyanide
placing Cain
Sulfuric acid
Chemical Inventory
Quantity Stored
1250 gallons
1000 gallons
•Chemical Classifications:
Classifications*
Re. T,l
C. fte, T
f
£
C
Re
N
T
rta
Flammable
Explosive
Corrosive
Reactive
Noxious/Fuming
Toxic
Radioactive
I « Innibitory to POTH operation
Fl * Floataole
S * Soluable
Se • Seuleaele
Dlscm'ryg Points
Discharge: So ley Indirect
City Sewer Connection Storm Sewer Connection
10 location ID Location
CS001 Benind cadimum
line plating
tank, connects
to Main St.
trunk
CS002 Adjacent to
anoaizing tank,
connects to
Main Sc.
trunk
SSOOl west side of
plant; Hain St.
scorn sewers
oHcnarge to
Anytown River
Direct Discharge Location
10 Location
None
Inspection Ocsernatlons
1. Sloppy operations.
1. Floor drains to trie sanitary sewer in process area.
3. Chemicals not stored properly.
i. No Dermec areas arouns plating tanks to contain spills.
5. NO
2-11
-------
3/REG.
TABLE 2-2. EVALUATION OF SPILL POTENTIAL DATA SHEET
(FACILITY DISCHARGES STRICTLY CONVENTIONAL WASTE,
TOXIC WASTES NOT STORED)
Industry Name:
Anytown Dairy Products
Inaustrv Aaoress: 100 Ola Farmstead Roafl
Anytown, IN 90922
Inoustry Pnone:
Contdc::
(994) 999-9998
Mr. Jonn Brown, Owner
Waste Materials ana Stored Chemicals
Materials
uney waste
Process Taru wasn Down
Nitric Acid
Caustic (Sodium
Hydroxide)
Quantity Pollutants of Concern
Continuous up to 10,000 gpd Excessive BOO, COD
Intermittent Batch pH
Discharge Max 1,000 gal.
Waste mixed with process Low pH
tank wasn down water
2,000 gallons stored
Same as NUric Add High pH
City Sewer Connection
ID
Location
CS 101 Process waste
line connects
in front park-
ing lot. Old
Farmstead Rd.
TrunK Line
CS 102 Sanitary waste
line connects
aenind office
to Ola farmstead
Trunk Line
Discharge Points
Storm Sewer Connection
SS 202 Runoff flow to
Lone Pine Cree*
from entire
facility.
Direct Discharge Location
None
Inspection Observations
1. Top not en operation (very clean).
2. Preventive maintenance performed on all valves.
3. Developed an ASPP. Needs to t>e reviewed by POTH.
4. Floor drains -- potential exists for slug discharge. Should seal floor
drain or Build a containment structure around acid and caustic storage in
case of an accidental spill.
-------
./RES X-4/=6
• Cnenncal inventory, including maximum anc averaue storage volumes.
• Comments/oDservations regarding *"loor drains, improper storage,
presence/aosence of ASPP, improper/inadequate containment of storage,
operational data, general process Information, potential for spills
and slugs.
It should also be noted that the quantities included in Tables 2-1 and
2-2 are by volume (gallons) rather than by weight (pounds). Volume data are
yenerally more vaiuaole tnan weignt data to tnose responding to spill
situations. Consequently, it is recommended that all chemical inventory data
ootained on a weignt basis also be converted to volume basis if possible. The
following guidance is provided in that regard:
• For pure or nearly pure chemical liquids, the chemicals specific
gravity should be obtained from the chemical literature, such as tne
Handbook of Chemistry and Physics, or Lang's Handbook of Chemistry.
The weight data can tnen oe converted as follows:
,, . ,, weight, pounds
Volume, gallons s (specific gravity) (a.3454)
• FOP dilute aqueous mixtures, the above formula can be used, with
specific gravity-* 1.0.
• weights of solids (e.g., salts), sludges, and/or complex chemical
mixtures may not be convertible to a volume basis. In these cases,
inventory volumes should be estimated from tank size, bag or drum size
and count, and/or other measures of existing storage facilities.
The above information can be used to modify the reportable quantities of
hazardous materials listed in Appendix 2 from pounds to gallons.
Also presented in Table 2-1 is an example of a chemical code system.
This code indicates hazards associated with a spill of each chemical at a
facility and can provide valuable information concerning appropriate spill
control and cleanup techniques. The PUTW should see* the assistance of
industry personnel and the local fire department in classifying chemicals.
Inventories should have available for the PQTW staff the material safety data
sheets for each chemical. These can be very useful in this effort. The POTW
should also include all hazardous waste products that may be stored at the
plant prior to disposal; such as pretreatment plant sludges.
2-13
-------
L/REG X-4/*b
for facilities capaDie of cnscnarying nign-strengtn wastes instead of or
in aacicion to nazaraous materials, tne POTw may want to list tne type of
conventional wastes and the description of tne industry's type of discharge
(oaten, continuous, intermittent), industry operation (seasonal, yearly), and
normal production figures (.see Table 2-2).
At tne Dottom of Tables 2-1 and 2-2, the locations of all discharge
points at tne industrial facility are indicated. These discnarge points can
potentially proviae a path by wnicn a spilled chemical or slug discharge of
niyn-strengtn wastes could travel, eventually upsetting a POTW or contami-
nating a water body. Three distinct types of discharge points are listed:
city sewer connections, storm sewer connections, and direct discharge out-
falls. Information on storm sewers and direct discharge information may be
important if tne POTW nas combined sewers, or if a spill would affect a.
drinking water source. Also, it should be noted that facilities that
discharge directly out have connections to the sanitary sewer may still be
candidates for ASPP due to the spill potential to the sanitary sewer system.
Also at the Dottom of the tables are some general observations from an
inspection of the facilities.
2.2.2 Summary Data Form
To facilitate the evaluation of spill potential and to assist in tracking
and identification of sources, it is recommended that the POTW have some
mechanism of summarizing the data provided by the industrial users and
oDtained from POTW inspections of the facility. This can be done auto-
matically by programming changes in an existing computer database or by use of
a summary data table such as the one presented in Table 2-3. Included in this
table are:
• A list of all industries within the PGTW's jurisdiction
• An indication as to the discharge mode, direct or indirect
• An indication as to the presence of city sewer, storm sewer, and
direct discharge points
• A delineation of chemical classifications applicable to each facility
2-14
-------
TAOLE 2-3. EVALUATION OF SPILL POTENTIAL SUMMARY DATA TABLE
Industry
Hame
til PI a tint)
An/town Dairy
fir-it
Railidtors
Discharge
SS CS Direct
1
X >
X 1
Chmical Classification
XX X X
X X
X XX
Pollutants of
Concern
CN. H.SO..C«,Cr.Ni.pH
Whey waste (HIIO. COO).
Wf>, pll
Cn, Pb, In. ar.iillc wastes
Spill
Potential
.,*
tow
Heel.
Patent ial
High
Med.
Hed.
Risk
Hiqh
Hert.
«e.l.
Has A SIT/
Needs ASI'P Conine
Nepils ASI'P I'dcir
w ,i<;t(
Has ASPP «SIJP
t-y Ci
Neeils *SPP Henls
ethylene glycol
s to he rpvi
City fm dilei]iidi y
Vtme traproncuwnl in
iny J'lil u't'lct -
of wdst-f ili'.pi1, il
Car Cleaning
Inc.
X II
ABC Restaurant 1
rv>
i
l~t Pestle tiles
01 Applicator
Inc. X
Sewer:
SS * Storm sewer connect ion
CS - Citj sewer connection
BOD. OtC, phenols . Hed. Heel.
nethylene chluri.le.
peptic I ites
. oil imt grease lo«
Pesticides, fertlliters Med. tow
Cheoical
F * Mumble
[ * fiplosive
C * Corrosive
Re > Reactive
H = Honiiius/FiMiin<|
f * fo.ic
fta - H*«ltu»ctl»e
I = Inhibitory to PIIIU
Hed. Needs ASI'P Hr.tc t '. c-,
low Does not need ««eds tn hp-ailvised «(
oiire«w'"i <, <"<
oil ami grease
Hert.
ASPP In washiny of mi< nr
applicatiun tanks imsiti<,
Uoor.lrjins in stoiajc J'«-
-------
L/REG X-4/#8
« Major materials of Importance stored or usec at tne facility
• Potential for spills of toxics
* Potential for slug discharge of high-strength wastes
* Classification of risk (high, medium, low)
* Requirement for ID ASPP
• Comments/ooservations.
Tnis summary provides at a glance an idea of which industrial facilities could
pose tne greatest risk to human health, the treatment system, and/or the
environment as a result of a chemical spill or slug discharge. The POTW can
then refer to the risk assessment data sheet for a specific facility to obtain
more detailed information.
It should be pointed out that the POTW implementing a pretreatment
program should already possess a manual or automatic system for organization
of data on its users. These existing data collection and storage capabilities
should hopefully accommodate the material discussed above and therefore the
existing system need only be expanded to include additional data and indus-
tries who are not presently beiny tracked under the pretreatment program.
2.3 ADMINISTRATIVE PROCEDURES FOR REGULATING INDUSTRIAL AND COMMERCIAL
FACILITIES CAPABLE OF SPILLS AND/OR SLUG DISCHARGES TO THE POTW
After an evaluation of the entire industrial community, the POTW can then
determine what will be required from each facility. The following is a
potential scenario of the results of the survey:
t Some facilities may need no ASPP at all.
• Some facilities may not need a full ASPP; they may only need to
improve housekeeping efforts, while others may need to provide
additional information to the POTW of any operational changes.
• For some facilities, there may simply be a need to remove or seal
floor drains.
2-16
-------
L/KES X-4/#8
• Some facilities may alreaay nave an ASPP, -however, it had not oeen
suomittec to trie POTW for review ana approval . These facilities are
more tnan meiy significant inaustnes regulated under tne POTWs
pretreatment program.
• Some facilities may not have any ASPP and will need to develop one.
Tnis document is advocating a tiered approach to regulating the
industries and assumes that all significant industrial facilities already
reyulatea oy tne POTW's pretreatment program are considered nigh-risk
facilities warranting development of an ASPP (that is, if they do not already
nave one). This should provide adequate protection for the POTW, environment,
and worker's health and safety without an overbearing administrative burden.
Additionally, it is assumed that the POTW has an effective control mechanism
(i.e., permit, contract, IWA) under its local pretreatment program targeted at
reyulating significant users. This mechanism may need to be modified to
incorporate the requirements of the ASPP. Administration procedures that
should be part of a POTW's ASPP are:
• Notification of the affected sources
t Requirements for an IU ASPP (use of control mechanism to convey ASPP
requi rements)
• Review of an lU's ASPP
• Inspection and monitoring of commercial and industrial facilities
• IU reporting requirements
• Data collection/data management.
The following sections discuss each of these components.
2.3.1 Notification of The Affected Sources
Keyardless of what approach the POTW utilizes, there are often critical
items that the POTW should communicate to each potential source. They are:
• Notification procedures the industry must comply with in the event of
a spill or slug
2-17
-------
L/REG X-4/#8
• POTW's rights'0 inspect the facility and its rignt to require the
industry to develop an ASPP in tne future
• Requirement to notify the POTW if tnere are any significant
operational or cnemical storaye modifications
• Requirement for notices to oe posted with POTW phone number in event
of spill or slug discharge
• written report to POTW aescrioing events leading to tne incidence, and
response actions.
In some cases, a POTW may wish to require standard warning devices, sucn
as all industrial users with a pH permit limit are required to install a pH
effluent monitoring device to identify violations. As noted previously, a
tiered approach to administration of the program is recommended. The
following classifications are a simple way of categorizing the facilities.
The method that the POTW uses to convey the above items to-the affected
users will depend on how they are categorized. For example, low risk users
would probably only need to get a letter highlighting the above points,
whereas the high risk user would have those requirements contained in a
permit, contract, or industrial 'waste acceptance form. As discussed earlier,
inspections of tne affected IDs will have to take place to appropriately
categorize the use as well as determine what corrective measures might be in
order.
Low-Risk Facilities
The PUTW should send a letter to the affected source(s) highlighting the
above critical areas. This letter could also discuss some yeneral precautions
and-preventive measures, such as good housekeeping practices that might be
considered.
Moderate-Risk Facilities
A moderate-risk facility may be one which actually needs to take some
corrective measures to prevent spills or slug discharges. The materials at
such a facility, if accidentally spilled or discharged as a slug, will not
create as severe a problem as the high-risk category. These facilities can be
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assumed to have some direct connections (floor drains included) to the DOTW
collection system. The facility may simply neea to plug tneir floor drains,
have better housekeeping practices, construct diversionary terms, conspicu-
ously post signs advisiny employees not to dump material down the drain, make
moflifications to their existing storage and handling of chemicals and haz-
ardous waste, have preventive maintenance on valves, and have procedures for
notifying the PUTW of a spill.
Ayain, the notification of requirements should take the form of an
official letter, which may apply to a large number of facilities included in
this category. (Some POTWs may want to use a permit to communicate specific
requirements.) In some cases, trie letters will need to be customized to
discuss a specific corrective measure which resulted from the POTW visiting
some of these facilities. All letters will have to include at a minimum the
five "bulleted" items on the previous page.
High-Risk Facilities
These facilities should include all users classified as significant under
the POTW pretreatment program, plus any additional facilities discovered as a
result of the assessment process discussed in Section 2.!l. All these facili-
ties should be required to develop and implement an ASPP.
Many industrial facilities regulated under other laws and regulations
(e.y., RCRA) may already have spill prevention and response procedures (e.g.,
contingency or SPCC plans). An industrial facility which does have such
procedures may only need to submit them to the POTW for review and approval.
In some cases, certain modifications may be needed to meet the requirements of
the POTW. For such cases, the POTW will need to take existing procedures and
spill prevention equipment into consideration.
A permit, contract, IWA, or agreement in place to administer the
pretreatment program should be utilized for all high-risk facilities. It
should include:
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i Details of tne specific requirement for development of an ASPP
• A schedule for subnittal to tne POTW
t A requirement for the user to implement the program once approved by
the POTW
t Specific reporting procedures for spills and slug discharges.
If tnese requirements ao not already exist in a control aocument, the POTW
needs to modify it to include the requirements so that ASPP concerns are
addressed. For facilities which do not have an enforceable document, the POTW
would need to issue one to include the necessary requirements. The control
mechanism for facilities not previously regulated under the pretreatment
program would only need to contain requirements for the ASPP, unless the POTW
decided otherwise. The POTW may precede modification of issuance of a permit
witn a letter to the affected source advising them of the requirement to
develop an ASPP and the intent to develop an adequate control mechanism. This
letter could contain excerpts from this guidance document and the sewer use
ordinance as appropriate.
2.2.2 Contents of An Industry's ASPP Submission
In Sections 2.1 and 2.2, the identification and classification of
industrial facilities required to submit accidental spill prevention program
{ASPP) plans were discussed. In this section, the recommended contents of an
IU ASPP plan will be outlined. Specific guidance as to what specific material
should oe considered in development of an IU ASPP will be provided in Appendix
3. Specifically, the following information should be provided in detail in
each industry's ASPP plan:
Potential Spill and Slug Discharge Sites and Pathways
0 Vicinity of chemical storage, transfer, or transport areas or
equipment to sewer connections
• Vicinity of manufacturing processing equipment to sewer connections
• Vicinity of pumps, valves, and other fluid flow equipment to sewer
connections
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• Identification of any presently leaning or malfunctioning units
• Inventory of cnemicals
Existing and Proposed Spill Prevention Equipment and Procedures
• Equipment to prevent spills
t Equipment to contain spills
• Spill prevention procedures in storage, transfer, or transport of
materials areas
• Spill prevention procedures in manufacturing process areas
• Other existing prevention procedures including personnel training
and good housekeeping
Existing and Proposed Spill Response Procedures
t Safety measures
a Acquisition of assistance
• Spill and slug discharge containment/diversion/isolation
Spill Response, Follow-up Reporting, and Documentation Procedures
• Causes of the spill or slug discharge
• Adequacy of the spill and sluy discharge response procedures.
A detailed discussion of each of these items is included in Appendix 3. This
appendix provides background information on the preventive measures available
to the industrial community. As such, this will assist the industry in
development of a complete ASPP, as well as assist the POTW in the review of
industrial facilities and the ASPP submissions. Additionally, an example
format of an industrial ASPP is included in Appendix.4. To provide consis-
tency for-all ID ASPPs, a POTW may want to use a model ASPP that specifically
requests all of the information the POTW needs to know. The IU and the POTW
should be familiar with the information in Chapter 3. This will assist in the
evaluation of the IU spill response program. In particular, the information
presented in Section 3.5, Containment and Countermeasures, is directly
applicable to an industry's spill response efforts.
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Some of tne information requirec in an IU ASPP may oe oetter presented
•jsing arawings, diagrams, or tables (with an abbreviated narrative if
necessary). For example, the locations of Hazardous material piping, valves,
ana tanks can be shown on piping and instrumentation diagrams (PID) which many
facilities will have. Otner required information can be shown on plant
layouts.
2.2.3 POTU Review and Approval Process
It is highly recommended that the POTW review the ASPP submission of each
industrial facility to ensure that all pertinent spill prevention issues
addressed in this chapter and Appendix 3 are fully discussed. If the PUTW
elects not to institute a review and approval process, but merely a require-
ment that the IU develop a program and submit it, the POTW must ensure that
the facility implements those procedures.
As guidance in reviewing ASPP submissions, it is recommended that
Appendices 3 and 4, which detail specific items to be considered and addressed
in an IU ASPP, and Appendix 5, which includes an ASPP Plan Review Checklist,
be utilized to aid the POTW in conducting a thorough review.
The POTW should consider, as part of its review process, meetings with
company officals; site visits to confirm the contents of the ASPP; and
follow-up inspections where the company indicated that it would be developing
certain procedures or installing or replacing equipment. In meeting with the
industrial facility officials, the POTW may consider providing a tour of the
treatment plant and/or the collection systems. This will provide the indus-
trial representative with the opportunity to see what they are protecting in
their spill control efforts, as well as see evidence of any previous problems
(such as sewer line corrosion).
2.3.4 Inspection and Monitoring of Commercial and Industrial Facilities
The POTW should, as part of its pretreatment program, conduct periodic
inspections of its significant industrial users. Such inspections serve many
purposes which are important to the pretreatment program in general as well as
implementation of the ASPP. In order to adequately assess the potential for
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spills of toxic chemicals and slue discharges and classify the industrial
users, Sections 2.1 arc 2.2 advocate tnat tne POTW must conduct preliminary
inspections.
As discussed earlier in tnis chapter, tne PQTW should probably have a
three-tiered strategy for implementing the ASPP. Ideally inspections should
ae oerfortned at all sources that have the potential for accidental spills or
sluy discharges. Because of resource constraints and the need to inspect
those sources with the- greatest spill potential tnat would seriously impact
the treatment system, the environment, and worker's health and safety, POTW
inspection of low- to moderate-risk facilities should be limited and
selective.
As a general rule, the majority of the facilities posing the highest risk
are already significant industries that come under the POTW's pretreatment
monitoring program. ConseQuently, these facilities will normally be visited
and their wastewaters sampled more frequently. There will, however, be
facilities which are classified as "high-risk" facilities for tne ASPP which
were not originally classified as "significant" when the pretreatment program
was developed. These facilities will need to be visited and their effluent
(if they have one) checked or sampled occasionally.
The amount of effort or resources to conduct the ongoing inspections and
monitoring should not increase significantly over what already exists for the
pretreatment program monitoring program. Before conducting inspections, it is
important that the POTW inspector be fully familiar with the lU's ASPP plan on
file at the POTW. In particular during a compliance monitoring inspection of
a significant user already covered by pretreatment requirements, the POTW
inspector should be observing ASPP practices of the company. The following
items are of great importance during a compliance inspection:
t Identifying any process changes, modifications to the facility or to
the discharge location
• Updating information on facility contact, phone number, address,
chemical inventory, and spill control equipment and procedures
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L/RE« X-4/#£
* Evaluating tne concition of materials storage, transfer, ana transport
eauipment
• Revising facility SKetcnes to include cnanges or modifications
« Continuing evaluation of evidence/potential for spills
t Evaluating proyress of work for a compliance schedule
t Cneckiny for good nouseKeeping and cnemical Handling proceaures,
* Evaluating containment structures.
During the inspection, the inspector may wish to pose a hypothetical
spill situation in a storage area, and inquire of industry personnel how they
would respond. For example, the inspector might inquire as to how personnel
would respond if a cnemical tank truck accidentally departed from a storage
tank with the feed hose still connected oetween truck and tank. The following
questions would come immediately to mind:
• Would the contents of the storage tank be spilled as a result, or is
there a valve at the tank connection which can be closed?
t Is there secondary containment around the area, and is it adequate to
hold a spill equivalent to the volume of the tank? (The inspector may
wish to estimate containment volume to verify).
t If the material was explosive or flammable, what additional
precautions would be taken?
• Could the material contact and react with incompatible materials
nearby?
Other examples could be: What happens if a valve malfunctions at a food
processing plant? What happens if a caustic tank at a radiator shop ruptures?
The POTW should seek to verify all ASPP plan information during the
facility inspection. The nature of this information has been outlined in
Section 2.3 and is detailed in Appendix 3.
Based upon the inspector's observations of the industrial facility, the
inspector should ascertain the facility's spill and slug discharge prevention
and response preparedness status. The inspector should report on any defi-
ciencies observed in the industry's current program, and suggest alternatives
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./REG X-4/#8
ana modifications. If a facility nas a compliance schedule, tne POTW snould
visit the facil:ty curing construction and at least upon completion cf tne
activity.
In communities where the fire department is involved in the inspection
program, a memorandum of understanding (MOU) between the POTW and tne fire
aepartment should be developed. This is especially important if the fire
department will be conducting a majority of the inspections. Tne MOU will
ensure the information is transferred to the POTW. Additionally, it is
important to note tnat the fire department does not sample wastewater during
its inspections. It is the POTW's responsibility to conduct all sampling
efforts.
The rule of thumb should be more site inspections versus sampling
inspections, however, it may be important for the POTW inspector to obtain and
analyze the discharge. Sampling may be in order to assess the magnitude of
the discharge, confirm whether unpermitted material is being accidentally
discharged, to support complaints by workers at the industrial site, or
support evidence of collection system or treatment plant problems. Quite
often, a POTW sampling program may require sampling in the collection system
to confirm and track illegal dumping of toxic material.
2.3.5 Industrial Reporting Requirements
Timely reporting of chemical spills and slug discharges of high-strength
wastes is critical to the minimization of the associated risks to worker
health, environment, and integrity of the POTW's collection and treatment
system.
Upon becoming aware of a spill or slug discharge, the industrial or
commercial facility is responsible for immediately notifying the appropriate
local agencies and, if required, State and Federal agencies. At the local
level, this should be the fire department and/or the POTW. The person(s) to
contact with appropriate phone numbers should be conspicuously posted for all
workers. If the incident is a slug discharge of high-strength wastes or a
spill of some chemical which does not present an imminent danger in terms of
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exolosivity or fire, tne POTW may only need to be contacted. As discussed In
Cnaoters I ana 3, it becomes extremely important that roles ana responsioi 1 i-
ties of tne local response ayencies be clearly defined in the POTW ASPP.
Once the spill or slug discharge is reported, the company should
follow-up with a written report within 5 days. The industry should describe
in tne ASPP the follow-up reporting and documentation procedures it will use
in tne event of a spill or a slug discharge. The items to be discussed in tne
follow-up report are:
• Cause of the incident
• Specific details of the incident (time, volume, damage, etc.)
• Response provided by the industry
• Future preventative mechanisms to avoid a reoccurrence of similar
incidents
0 An evaluation of the effectiveness of the industry's spill response
capabilities
• Information update.
Finally, the company, needs to report changes in its operation and its
ASPP, and report completion of each phase of a compliance schedule (i.e.,
construction of preventive devices, training staff, correcting existing
problem areas, etc.).
2.3.6 Data Collection/Data Management
As part of implementation of an ASPP by the POTW or industrial facility,
documentation is critical, particularly in response to spills or slug dis-
charge. Data management by the POTW is addressed throughout this report in
Section 2.2, Classification of Industrial Users, and Section 4.2.4, Data
Management. Proper management of this data is essential especially when
potential enforcement is indicated against a company.
In terms of data collection by the industrial facility, it is especially
important tnat the industry maintain complete records where spills or slug
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discnarges have occurred. Additionally, the industry should maintain complete
records of chemicals storage, contents of 'Storage drums, wastewater treatment
sludges, and ultimately disposal of spent chemicals.
2.3.7 Evaluation of Legal Authority and Enforcement
Most, if not all, POTWs required to develop pretreatment programs already
contain ample legal/enforcement authority to deal with accidental spills and
slug discharges. The POTW in its ASPP procedural document should hignlight
this.
2.4 SUMMARY OF CHAPTER 2
Through-out this chapter, procedures to develop an ASPP were discussed for
all of the major elements of the preventive portions of an ASPP. The
foil owing list summarizes the material presented in the chapter and highlights
the critical steps that must be taken in program development.
0 The industrial community needs to be surveyed and data collected for
assessment of spill or slug discharge potential
- Selection of criteria appropriate for the industries of concern and
the POTW need to be developed
- Current data on the industries needs to be collected and reviewed.
• Each industrial faci-lity which the potential for spills or slug
discharges needs to be evaluated and classified so that appropriate
regulatory measures can be taken
- Evaluation of each facility for the potential occurence and danger
of accidental spills and slug discharges
- A classification scheme should be developed along with appropriate
regulatory measures for each classification.
• Administrative procedures for regulating facilities which are capable
of accidentally spills of chemicals or slug discharges
- Notification of affected users depending on risks
- Requirement for facilities to develop ASPPs
- POTW review and approval of an Ill's ASPP
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Industrial reporting requirements
- Data collection/data management.
• For those industries required to develop ASPPs, the information to be
requested by tne POTW needs to be determined and communicated to tne
industry. This information should at least include tne following:
- Potentially spilled material, storage, transport, transfer, and
process sites and spill pathways
- Existing and proposed spill prevention equipment and procedures
- Existing and proposed spill and slug discharge response procedures
- Spill response, follow-up reporting, and documentation procedures.
• To review the industrial user's ASPP, the POTW should develop a clear
understanding of what it needs to know from an industry. To assist in
the ASPP review, a checklist can be used to provide consistency. The
review should be conducted at a sufficient level of detail to ensure
that the facility is thoroughly evaluated and that the ASPP has taken
all relevent aspects into consideration.
• To verify and augment information in the lU's ASPP Plans, the POTW
should conduct inspections of the IDs and monitor their discharges.
• Information collected concerning the industrial community will have to
be periodically updated. This is necessary for the POTW to be sure
its ASPP adequately addresses the needs of the community.
• In order to fully implement its ASPP plan, the POTW must ensure that
it possesses adequate legal authority and enforcement authority.
These authorities most likely already exist for most POTWs
implementing pretreatment programs.
Administrative procedures to ensure adequate coordination with other
local agencies that will be involved in the implementation of the PO
ASPP. This is particularly important if the other agency is taking
tne lead in the program.
POTW
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J/.REG X-4/#6
3. POTW SPILL RESPONSE PROGRAM
To promptly and properly respond to a spill of hazardous wastes or slug
discharges at an Industrial facility, in the collection system, or at the
treatment plant, tne POTW must have the following capabilities:
• Ability to identify potential sources of spills or slug discharges
• Aaequate resources (personnel, equipment, finances)
• Knowledge of the assistance available from other sources (agencies and
private contractors)
t Ability to detect spills and slug discharges and coordinate response,
as appropriate
• Assessment of the type and magnitude of spills
• Knowledge of appropriate containment and countermeasure procedures
• Procedures to analyze spill events, provide proper documentation, and
follow-up review of the spill prevention programs of the industrial
facility and POTW
t Procedures to implement the necessary modifications in the POTW's
ASPP.
The above-mentioned factors are essential for the development of a POTW's
spill response program and are discussed in detail in the following sub-
sections.
Note;
As mentioned in the preface to this guidance document, the responsibility
for responding to spills of chemicals and hazardous wastes or emergencies at
an industrial site may rest with a local, county, State, or Federal agency,
with the POTW providing various back-up roles at the site. If this is the
case, certain sections of this chapter (such as 3.2, 3.3, 3.4, 3.5) may not be
fully appropriate. Because another agency may be the lead agency for respond-
ing to spills does not relieve the POTW of certain responsibilities. This
chapter does cover areas that the PQTW will be active in, such as developing
coordinating procedures, training staff, reviewing other agency procedures,
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J/REG X-
notification, applicable containment procedures, spill investigation and
follow-up, IU ASPP modification, sampling and analyzing tne spilled material,
and enforcement.
Generally, the POTW is on its own when it comes to responding to slug
discharges of hign-strength conventional wastes. Although this chapter
centers on toxic cnemicals, some of tne sections will still be applicable to
responding to slug discharges.
3.1 DEVELOPMENT OF RESOURCES
3.1.1 Personnel
A POTW may not need to hire additional personnel to respond to accidental
spills or slug discharges, however, there must be adequate staff with proper
training and responsibility to respond to a spill event. If the evening or
night shift operators are not adequately trained to react to spills or slug
discharges, they must know the procedure to contact the appropriate staff who
should be available on a on-call basis at all times.
For many POTWs, certain parts, or all of the collection system, are
maintained by a separate crew of the city or county (or by other cities) and
the POTW is not responsible for the collection system. Coordination between
the responsible agencies is very important. For a spill or slug discharge
that has reached the collection system, the POTW personnel should know to
contact the appropriate person responsible for the maintenance of the col-
lection system. Additionally, if the collection system staff identifies
unusual corrosion of .a pipe or wastewater with unusual characteristics, they
should be aware of the notification procedures developed to alert the POTW.
If the POTW is the lead agency for reacting to spills, then the personnel
with responsibilities for spill control should be thoroughly trained on all
aspects of spill response and should be allowed to practice their specific
areas of responsibility. If another agency is the lead agency, then the POTW
staff should be familiar with their specific duties relative to providing
assistance onsite as well as their responsibility once the spill enters the
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J/REG X-4/#6
sewer system. Spill control lends itself to case studies and especially to
simulation. Appendix 6 includes a case stuay of a spill. On-site drills
should be conducted routinely, such as a drill once per year. Personnel
should be trained to know the capabilities of spill control and decontami-
nation facilities available to them and the staff should be encouraged to
attend short courses/seminars on spill prevention and control to expand their
expertise. Monetary compensation should be provided for such activities.
3.1.2 Equipment
Safety equipment kept at POTWs will not normally be sufficient to respond
to a spill, particularly if the POTW has the lead in responding. The POTW
should obtain or have access to all necessary equipment that is likely to be
used during control of a spill or slug discharge. One of the most important
aspects of response to an emergency situation is communication.
Initially identification of a spill is essential and automatic sensing
and alarm systems may be very useful if they are practical. In addition, the
availability of appropriate and adequate communication equipment will assist
the POTW in spill response. The equipment may include telephones, CBs, and
short wave radios. These items will keep key individuals involved in the
response in contact and will facilitate coordination of spill control efforts.
Other types of equipment that may be required for spill response include
fire fighting equipment, decontamination equipment and spill control and
clean-up equipment. To obtain the availability of this equipment, the POTW
should consider agreements with local fire and police departments, neighboring
POTWs, and nearby industries to borrow appropriate response equipment when
needed. The POTW should also be familiar with suppliers of such equipment and
local contractors equipped to clean up spills.
Protective clothing and respiratory protection may be necessary for the
personnel coming in contact with the spilled hazardous material. Various
types of such equipment are described here.
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-------
K/RES X-4/fo
Protective Clothing Respiratory Protection
• Total encapsulation unit i Self-contained breaming apparatus
* Rubberized rain gear • Gas mask with organic vapor canister
t Disposal coveralls t Half mask respirator with dust cartridge.
t Normal working cothing • Disposaole dust respirator
Tne type of clothing or respiratory protection needed in different situations
snould be designated (e.g., tne operator should Know that he or she must be
wearing disposable coveralls and a gas mask with an organic vapor cartridge).
As tne potential for exposure decreases, the levels of protection could be
decreased. Supervisors, who are required to both use protective equipment and
to supervise workers using it, should undergo a comprehensive training
program.
The availability of safety equipment during spill response is extremely
important. In addition to protective clothing and respiratory protection
equipment, safety equipment should include the following:
• General first aid kit
• Eye and skin contact response kit
• Explosive and poisonous gas detectors
t Proper lighting and warning equipment (e.g., barricade, traffic cones,
flashing lights).
Spill control equipment should be available to the POTW. Such equipment
snould include the following:
t Temporary containment devices (e.g., booms)
• Absorbant materials
• Spill cleanup tools
• Ventilation equipment
• Liquid vacuum pumps
• Containers for storing spilled material
• Decontamination equipment.
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The investigation of a spill or slug discharge may require sampling and
analysis of tne spilled material in trie collection system or at the plant
site. The level of resources needed will depend on tne volume of hazardous
materials and degree of risk of problem discharges from industries in the
POTW's jurisdiction. The POTW should have adequate sampling equipment which
can be used during a spill event. The personnel taking samples should be
knowledgeable about the appropriate sampling techniques and methods of
preservations, etc. The analyses of samples could be performed in the POTW
laooratory or at a commercial laboratory. If the POTW routinely utilizes a
commercial laboratory to perform analysis of wastewater samples, the POTW
should establish a contract with the laboratory to provide emergency analyt-
ical services. Identification of a spilled material will be necessary to
identify an unknown source, or to determine if long-term clean up efforts will
be needed.
3.1.3 Finances
POTWs implementing pretreatment programs should generally have staff,
equipment and finances to deal with emergency response. Further analysis of
the POTW's ASPP needs might result in additional funds to effectively imple-
ment the spill prevention program. While it is not easy to predict the rate
of accidental spills in which a POTW may be involved, a reasonable estimate of
the financial requirements for personnel training, equipment costs, routine
drills, etc. can be made. It should be noted that a heavy financial commit-
ment to implement this program is not expected or anticipated. Many of the
procedural elements, staff, and basic equipment probably exist-in the
community already, particularly with the fire department.
The POTW should also be familar with the laws and procedures of
recovering spill handling.costs from the industrial or nonindustrial pol-
luters. Details of legal remedies and emergency relief are presented in the
U.S. EPA's Guidance Manual for POTW Pretreatment Program Development. October
1983.
'3-5
-------
2.2 COORDINATION BETWEEN AGENCIES
3.2.1 Assistance From Other Sources
Assuming that the 3OTW will t>e responsible for responding to spills,
there can be several sources (Federal, State, county, and local agencies) in
or outside tne area that may be able to assist the POTW with the manpower and
equipment necessary for spill prevention and control. The POTU should explore
all sucn available sources and list the appropriate names, addresses, phone
numbers and tne extent of service (manpower, equipment) that can be obtained
from such sources; neighboring jurisdictions or even some industries with
specialized equipment, etc., may be willing to help in the case of accidental
spills. Included in Appendix 7 is a listing of National organizations that
may be of assistance during a spill or slug discharge event.
All agreements regarding the use of resources from local agencies should
be made in advance to avoid delays in making arrangements and to insure the
availability of resources. Some agencies may provide information by phone and
only during normal working hours, while others may have 24-hour a day service.
Some manufacturers of hazardous materials may also be willing to provide
information about properly handling specific substances. All restrictions or
availability should be documented in the ASPP. The POTW should also explore
the extent of services available from local contractors for spill control,
transport and ultimate disposal of the spilled material.
The local police and fire departments may already have personnel
specially trained in handling hazardous materials spills. Many fire
departments have a Hazardous Materials Unit staffed 24 hours a day with
specialized firefighters available for response anywhere in the city, as well
as for potential response to the county and other mutual aid requests. The
unit may be equipped with positive pressure breathing apparatus, acid gas
suits, explosives meter, radiological markers, kits for stopping leaks,
absorbent material, recovery drums, and manuals for identification and
handling of hazardous materials. It is important to check with the fire or
police department in advance to determine the assistance they will provide.
The fire department may be the primary response agency, or may be able to
train the POTW staff in the proper response procedures.
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3.2.2 Delineation of Responsibilities ana FormalIzatlon of Cooperative
Proceoures
The POTW must identify an employee as the Spill Control Coordinator who
will direct the spill response effort or who .will represent the POTW in
assisting the primary local agency responsible for the spill. The work
reception/radio personnel receiving information about a spill event will make
an initial call to trie Spill Control Coordinator who will then evaluate the
information and direct the personnel for further actions. An example of a
form that can be used to organize the information from this first call is
included in Appendix 7. There must be one individual on the spill site who
will have full responsibility and will coordinate the field actions.
The response to a spill can be a multi-agency effort depending upon the
type and quantity of spilled material. The POTW must be involved in every
case where a spilled material has entered or has the potential to enter the
collection system. Under such circumstances, the responsibilities of all POTW
personnel and other agencies Involved should be clearly defined to avoid
confusion. It is necessary to make the other departments (police, fire, etc.)
understand the potential impacts of spills or slug discharges on the POTW. To
ensure a coordinated response to a spill, representatives from all appropriate
agencies and industries should meet to evaluate appropriate coordination
procedures for different circumstances. The procedures of cooperation should
be formalized and agreed upon by the various parties responding to the spill.
In many municipalities, the POTW does not have responsibility of
maintaining the collection system. That function is performed by a separate
maintenance crew of the city or county. In such cases, the maintenance
supervisor/ personnel should be involved in spill control efforts and their
duties and responsibilities should be defined.- The POTW should be aware of
the resources available and the technical capabilities of the maintenance
staff.
Cooperation will benefit all involved by providing additional resources,
expertise, and databases; the POTW industrial users database may be of assis-
tance to the local fire marshall. To facilitate the exchange of information,
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J/REG X-4/#6
it is important that tne POTW formalize cooperative agreements. The ASPP plan
snou'id delineate tne responsibilities and roles of eacn local agency.
3.3 SPILL SOURCES, DETECTION & NOTIFICATION
3.3.1 Sources of Spills
Hazardous material spills or slug discharges of high-strength wastes to a
POTW may originate throughout the service area from two general categories of
sources. One category is in-transit facilities such as barges, railroad cars
and tank trucks. Spills or slug discharges from in-transit facilities can
reach a treatment plant through manholes to sanitary sewers or storm drains
into combined sewers. The other source category is stationary facilities,
these include manufacturing plants, warehouses, chemical processing plants,
power generating facilities, food processors, service stations, tank farms,
and terminals. Spills or slug discharges from stationary sources can be
transported to a treatment plant through the sanitary sewerage lines from the
plant, floor drains, or through process waste lines that normally carry waste
streams regulated by categorical standards or local limits.
The POTW should note that although the primary goal of the ASPP is to
protect the POTW, hazardous materials spills that do not enter the POTW may
still pose a threat to the community. These threats can be from contaminated
water sources, explosions, fire, and toxic fumes. Where the POTW has devel-
oped spill control expertise and acquired spill control equipment as appro-
priate, they may be called upon to assist in a spill event that does not
directly affect the POTW.
Due to the community service an ASPP provides, a comprehensive inventory
of major sources of potential hazardous material spills should be developed.
Identification of stationary facilities is very important as they are the most
likely sources. The inventory can then be expanded to include in-transit
facilities that may affect the community. A methodology to conduct such a
survey was discussed in Chapter 2. For the most part, hazardous materials
stored, consumed or generated at a stationary facility are generally trans-
ported through the service area. These materials, identified through the
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stationary source survey will provide tne POTW with an idea of what type of
cnermcais are transported within tne service area, and in wnat volumes. How-
ever, nazardous materials that are transported through the service area
without stopping are not accounted for by an inventory of only stationary
facilities. Additionally, the POTW should make an attempt to identify tne
general types, volumes and routes of other'hazardous material transport
through the area. This will provide a more comprehensive evaluaton of the
potential for hazardous material spills.
3.3.2 Initial Detection
The warning of a spill and potential toxic influent wastewater or slug
discharge of high-strength wastes may come from any of several sources, such
as a remote early warning system, notification from an individual or agency,
or by visual or other observations of influent wastewaters. The quickest
warning would orginate from the party responsible for the spill or slug dis-
charge. If the facility has been identified by the POTW during the stationary
facility survey the personnel should be aware of the proper contact procedures
and necessary control actions. Notification responsibilities and procedures
could be detailed in the facility's permit, contract, agreement, or ASPP.
Facilities that were not contacted during development of the POTW ASPP or
other users are unlikely to alert the POTW. In an attempt to aprise all
potential sources of spills or slug discharges of their responsibilities and
of the proper reporting procedures the City should be sure to conduct a
thorough survey and evaluation of risks as detailed in Chapter 2. The City
may also consider a periodic advertisement or notice in the paper identifying
the proper notification procedures for all users of the POTW. Timely notifi-
cation of a spill event will facilitate the POTW's response. It is essential
for the POTW to stress notification of slug discharges of high-strength
conventional wastes by industrial users that routinely discharge such wastes.
Notification will help the POTW personnel prepare for treatment of the slug
load.
If the police and fire departments are the lead group for responding to
spills, they will be notified first. In addition, regulatory agencies such as
the Environmental Protection Agency, or the State Health or Environmental
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Resources Aqencies could also get notification of a spill prior to tne POTW.
Cooraination is essential between tnese agencies. Appendix 7 includes a form
for organizing the initial information received concerning a spill. The
police, fire and regulatory agencies should all be aware of the need to notify
tne POTW of the spill event. The agencies should be provided with the
appropriate pnone numoers in advance. In every case where a spilled material
nas entered, or nas tne potential for entering the collection system, the POTW
should be actively involved in the control and clean up of the spilled
material.
The POTW should realize that in an emergency situation other responders,
such as the fire department, may feel that the best solution is to flush the
spill down the sewer. This idea is particularly prevalent when responding to
spills of flammable materials, such as a tank truck accident where gasoline
and chemicals could discharge into a combined sewer. In these situations the
knowledge and experience of the POTW official is critical to determine what
the best course of action is, and if the spill is to be, or has been flushed
what action is needed to protect the collection system and the treatment
plant.
A monitoring and surveillance system can provide continuous documentation
of the variations in influent character which will result from certain haz-
ardous material spills or slug discharges. If the expense can be justified, a
monitoring and surveillance system at key points within the collection system
can provide notification of the spill or slug discharge and based on the
location of the sensing apparatus, the time of the spill's/slug discharge's
arrival at the plant can be estimated. This may be practical if the indus-
trial users in a community are centralized in one area, such as an industrial
park. The monitoring and surveillance system can assist in implementing spill
countermeasures at the plant or in the collection system. Test dye runs
throughout the collection system during nonemergency times can be used to
calculate estimated flow rates through the sewer from specific industries, or
areas. These flow rates can then be used to calculate travel time from a
spill site to a pump station, another industry, a residential area, the
treatment plant, or to identify some point along the route that can be used to
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trap the spill. This effort can result in a better response during a spill by
proviaing tne necessary information to make evacuation, containment, ana clean
up decisions.
3.3.3 Coordination of Response
There must be one individual on the spill site who will have full
responsibility for coordination of field actions. The Spill Control
Coordinator (PQTW, fire department, or other official) should direct the
coordination of the POTW and other response units including the police and the
fire departments. This will facilitate the initiation of mitigating measures.
In the management of spill materials, the Spill Control Coordinator should
make arrangements for any outside assistance necessary for containment, clean
up or disposal of the material. To achieve an effectively coordinated spill
response, the duties and responsibilities of all personnel should be clearly
delineated as discussed earlier in Section 3.2.2.
The Spill Control Coordinator can be an official from any one of the
local agencies involved in spill response; however, It is important to
determine beforehand which agency will be the lead group. Confusion at a
spill site should be minimized by adequate forethought and planning and an
understanding that the Spill Control Coordinator is in charge.
3.4 EVALUATION OF INITIATIVE ACTION
3.4.1 Assessment of Spill
Once spilled materials enter the collection system, there are several
potential effects:
• Vapors resulting from the spill may back up the1 sewer lines into
residences, or other industrial facilities, creating additional
hazardous situations
t Operating personnel may be endangered or the collection system or
plant facilities may be damaged
• Materials may pass through the treatment plant unaltered and be
discharged to the receiving water
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J./REG X-4/*6
* Biological treatment processes may remove or reduce trie quantity of
sail lee materials entering tne receiving stream, however, tnere may oe
floataole or settleaDle solios to dispose of
t Biological treatment processes may be upset, and in tne time required
to re-establish maximum efficiency poorly treated wastewater will be
discharged.
These effects will be a function of the type and quantity of spilled material,
contingency reactions, and types of treatment processes at the POTW.
The main elements of the POTW's initial response can be monitoring,
venting, and dilution of tne spill material in the collection system. Pumping
out tne spilled material may also be possible. A review of the collection
system should be made to determine where the spill will travel in the collec-
tion system. A crew can be dispatched to locate the leading edge of the
spill. Sites downstream of the spill front can then be identified as possible
containment areas. Another crew can monitor the spillsite and work downstream
to mitigate damage to the collection system. If the flow is expected to go
through any metering installation, the appropriate officials should be
directed to put the facility out of electrical service if the spill material
is flammable, or explosive. Additionally all downstream industrial facili-
ties, commercial establishments or residences that could be endangered should
be notified and the necessary precautions taken. Proper venting and any
necessary dilution of flow in the collection system should be handled by
appropriate maintenance crews along the spill route. Any dilution water
should be carefully applied to ensure that turbulence is not set up which
would result in a release of gases and fumes.
If the spill flow will enter any sewage pumping station, then appropriate
officials should be notified by the Spill Control Coordinator to have person-
nel proceed to the facility. All personnel stationed at the pump station, or
sent thtre in response to the spill, should be advised of the potential danger
from volatile fumes. Depending on the quantity and type of material involved
in the spill, a decision should be made whether to capture and remove the
material from the collection system or to let it flow to the treatment plant.
Approximate flow rates through the collection system can be developed through
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tne use of dye studies. The POTW may want to conduct such studies throughout
tne system to determine tne hign ana low flow rates from particular industries
to the treatment plant. This will allow for the selection of containment
locations based on tnese flow rates. The decision to contain the spill, and
wnere, snould be made by the Spill Control Coordinator.
If the spilled or slug discharged material has reached the treatment
plant, all information concerning spill type and quantity should be provided
to plant operating personnel. They will be able to advise the response team
of containment options at the treatment plant. If containment and subsequent
removal of the material is possible, all removal activities of the spill
material should be coordinated to minimize the impact on the plant. If
removal is not possible, then the plant personnel could provide information on
bypassing the material around specific unit processes rather than allowing the
spill to go through the normal treatment process and potential options for
diverting spilled material for future treatment or removal rather than
discharging it to surface waters. The agency administering the NPDES program
(State or EPA) should be notified of potential problems and the need to
by-pass.
3.4.2 Safety Considerations
The safety protocol that is used for hazardous materials response varies
with the event. However, the basic elements that should be followed are:
• One person in charge.
• Command and control
t Minimize exposure
• Appropriate personnel
• Safety supervision.
Some person must accept responsibility as Spill Control Coordinator
whether it be an official of the POTW, city administration, fire department,
or other official. The Spill Control Coordinator must clearly be in charge
and must understand the problem and act accordingly. The Spill Control
Coordinator sets the safety standards based on his perceptions of the problem,
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experience, and references to literature sources. Without command and
control, safety Decomes an individual responsibility. In a typical hazardous
materials accident in which many different groups with diverse interests and
objectives are working simultaneously, it is vital that a single command
structure controls and coordinates activities so that no one is injured by
someone else's actions. As noted earlier, the command strategy should be
arranged prior to a spill event.
A high degree of relative safety can be achieved and maintained by
adequate training of the response team and using hazardous materials safety
officers to brief and supervise work. While individual safety training is
necessary, safety is too important to be an individual responsibility.
Training hazardous materials safety officers should be priority because of
their key role in incident safety. These people assist the Spill Control
Coordinator to identify and interpret the chemical hazards, act as a liaison
between chemical experts, enforce the general safety protocol and supervise
the work that is being performed.
To be effective and maximize safety, the total number of people exposed
in the immediate danger zone must be kept to the absolute minimum. In the
event of a catastrophic accident this will minimize total injury. Safety
standards must also be followed by those in authority. Precept and example
are the basis of leadership. - Safety zones need to be established upon arrival
of emergency personnel and remain until the end of the accident.
Depending upon the hazard, the safety/work zone should be outside of the
minimum safety isolation distance. It needs to be well marked and patroled by
the safety officers. All personnel must be aware of the zone and the rules
that apply. Each person working in the zone must be briefed by the safety
officer as to the hazards, proper protection, safety etiquette, protocol and
prearranged evacuation signal. Proper safety clothing, safety equipment and
work equipment appropriate to the physical as well as the chemical hazards
should be a prerequisite for entry.
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Note:
It snould be understood tnat all spill sites will not need this level of
detail, but adequate safety precautions should be maintained.
3.5 CONTAINMENT AND COUNTERMEASURES
3.5.1 Containment and Diversion Options
First, an effort should be made to contain the spill material near its
source and prevent the material from getting into the collection system.
Several means of containment include:
• Changing position of the ruptured container, tank, or containment
structure
0 Repairing or rebuilding the container, tank, or containment structure
t Building a substitute tank or containment structure
0 Enclosing the container, tank, or containment structure.
A .substitute containment structure may be made by:
• Forming dikes from earth, sand bags, or inflatable water bags
0 Erecting temporary tanks or containment structures
0 Digging a pit or sump, preferably lined.
When sewer drains present an avenue of continued spreading of the spilled
material, they should be blocked. In the absence of high-expansion foam
systems, materials at hand should be used to form dikes. In-sewer means of
control include inflatable plugs, "pipestoppers," or dams usually used in
sewer maintenance.
Within the treatment plant, the operator can divert and contain the
spilled material provided he has been forwarned and is adequately prepared,
e.g., a treatment plant with several units (primary clarifiers or activated
sludge) can allow the flow with spilled material to enter specific units. By
operating appropriate valves, the flow to the units with captured spilled
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J/REG X-4/*6
material can t>e turnefi off ana contained spi M material conic be removed or
processed if possible.
3.5.2 Treatment Potions
Upon Identification of the spilled material, appropriate treatment
can be usec. Taole 3-1 presents an overview of treatment alternatives which
may be implemented in the collection system or at the PQTW.'Of course, factors
suo> as volume of the spill, time, location, availability of equipment and
supplies, will dictate the appropriateness of any given countermeasure. Taole
3-1 presents hazardous materials as 19 groups, consisting of oxides, pesti-
cides, flammable hydrocarbons, etc. The POTW could also increase the number
of in-plant treatment options with some in-plartt modifications, e.g., with a
modification to provide chemical addition between grit removal and pre-
aeration, the chemical sludge could then be settled in the primary clarifier.
3.5.3 Waste Disposal Options
The spilled material treated at the POTW's treatment plant would most
likely contaminate the sludge or pass through the plant. The contaminated
sludge or collected spilled material may be classified as hazardous material
and therefore, will need to be disposed of as hazardous waste or if not
hazardous, it may still need to be disposed of in a nonroutine manner. The
POTW needs to evaluate the availability of local contractors/haulers for
transporting, and the hazardous waste disposal sites for ultimately disposing
of the contaminated sludge or removed spill material. Non land-based alter-
natives for disposing of the hazardous material should also be explored, e.g.,
neighboring municipalities, utilities, or companies may be willing to burn the
hazardous material in their incinerators. Some large industries in the local
area may dispose of their process wastewaters by land spray-irrigation
systems. Prearrangement with such industries could be made to dispose of the
hazardous materials.
If the spilled material passed through the plant, estimates should be
quickly made to determine the levels of harmful pollutants in the effluent and
their effect on the receiving stream. If it appears that problems may occur,
3-16
-------
TABLE 3-1. TREATMENT COUN It MEASURES FOR MATERIALS H! Ill THE FOLLOWING CHARACTERISTICS
ENTERING THE VASTEUATER COLLECTION AND/OR TREATMENT SYSI EH
HAZARDOUS
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J/REG X-4/46
some mitigating measures such as recirculating or removing the effluent for
further treatment may be needed. Monitoriny of the effluent may also need to
be done. Again, the State/EPA will need to be notified of the pass through
pollutants.
POTWs that identify a high risk for a potential spill that would result
in disposal problems should seriously investigate the disposal options
available to them as part of the development of the ASPP. Response actions
may be modified as a result of the disposal options, or if disposal options
are severly limiting, the POTW may recognize the need to have the industrial
facilities develop stringent ASPP programs that are strictly enforced.
3.6 SPILL EVENT INVESTIGATION AND DOCUMENTATION
3.6.1 Investigative Actions
. If tne POTW receives information about the source, time and nature of the
spilled or slug discharged material, the spill response can be implemented
quickly and efficiently. However, this may not always be the case. . If the
spill is detected at the plant, or notification is from a poorly informed
third source, and no information is available regarding its source, then an
investigation would be necessary.
Since the collection system is probably extensive, the investigation
should begin at a point with maximum potential for receiving spilled material,
e.g., a key-manhole which receives all or predominantly industrial discharges.
Residential areas are less likely to spill significant quantities of hazardous
materials. Based on some preliminary idea of the nature of the spill (color,
odor, foam, fumes, etc.), some Icey-manholes in commercial areas (with paint
shops, warehouses, garages, etc.) could also be explored. Once contamination
is detected in a key-manhole, a review of the collection system (maps,
drawings) can indicate potential sources of the spill located upstream.
Several other manholes may have to be checked before the origin of spill is
detected.
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3.6.2 Sampling and'Analysis
Sampling can be conducted either manually or through the use of automatic
devices. Normally a grab or multiple grab samples would be appropriate for
the analysis of spilled material. Samples of the virgin material, of the flow
immediately downstream of the spill, and at the POTW influent are recommended.
Because of the potential for significant errors associated with sampling,
it is essential that extreme care be exercised in selecting sampling devices
and procedures. A good reference for sampling procedures is the EPA document,
NPDES Compliance Sampling Inspection Manual (PB81-153215), available through
NTIS. (See Appendix 8 for additional information on NTIS.)
Once an accurate sample has been obtained, several steps should be taken
to assure that the validity and objectivity of the monitoring operations are
maintained. The sample should be properly preserved and promptly delivered to
the laboratory to prevent sample degradation. Proper chain-of-custody
procedures should be used where such procedures will not hinder response to a
spill. Sample preservation techniques and holding times are outlined in
various analytical handbooks, such as'the EPA Manual of Methods for Chemical
Analysis of Water and Wastes (PB259973), available through NTIS, and Standard
Methods for the Examination of Water and Wastewater (16th Edition, 1985),
published by the American Public Health Association.
It is important that POTW sampling personnel properly document the
methods used to collect the sample, as well as the chain of possession of the
sample from collection to analysis. Chain-of-custody procedures should
already be routinely used by the POTW for most sampling to ensure validity of
the resultant analytical data. Since it is impossible to predict which case
will require legal action, it should be assumed that all data generated from
sampling will be used in court. If a case ultimately goes to trial, the1
integrity of the data must be established. The sampling results will only be
admissible in court if POTW personnel can prove that a sample has been
properly collected, preserved, and analyzed, has not been tampered with or
mishandled and can demonstrate the chain-of-custody of all samples. If POTW
personnel cannot demonstrate these "technicalities," sampling results, however
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damaging to an accused violator, may not De aamitteC Into evidence ana,
therefore, may not exist in the eyes of the law.
Some of the items tnat need to be considered, at a minimum, to adequately
address chain-of-custody concerns are:
* Name of person collecting the sample
• Date and time of sample collection
t Location of sample collection
« Type of sample collected (i.e., grab, composite)
* Preservatives used for each sample type
c Names and signatures of any persons handling the samples in the field
and laboratory.
It is often convenient and efficient for a POTW to develop a chain-of-
custody form that can be used by its sampling team. A sample of such a form
is presented in Appendix 7. This form should accompany the sample at all
times. It may also be in the best interest of the POTW to properly document
the protocols followed during the sampling and analysis of spilled materials.
Adequate documentation is particularly important in the case of priority
pollutant sampling where the sampling and analysis techniques are not as well
recognized as those for conventional pollutants. Documentation is also useful
when writing the follow-up report that recounts a spill event and the actions
taken.
Analytical results should be accurate and reproducible to ensure that
monitoring activities will provide the quality of information necessary for a
successful spill response program. Precise and well-recognized techniques
have been established for the analysis of conventional and heavy metal parame-
ters in wastewaters. Three often-referenced manuals that provide methods for
analysis of these parameters are the Chemical Methods Manual and Standard
Methods (both mentioned above) as well as the Annual Book of Standards, Part
Q (Water, Atmospheric Analysis), 1975, published by the American Society for
Testing and Materials. Each of these documents provides a synopsis of the
-------
J/REG X-4/#6
analytical tnethoa for a parameter, information on Interfering substances, and
step-oy-step instructions on now to carry out the analysis. Also included is
information on the calculation of results, the precision and accuracy of the
analytical method, and techniques for chemically stabilizing and preserving
samples. EPA has procedures for the analysis of toxic organic chemicals in
"Guidelines Estaolisning Test Procedures for the Analysis of Pollutants" (40
CFR 136). These were printed in the Federal Register (49 FR 43260) on Friday,
October 26, 1984. Some of these methods can also be found in the 16th edition
of Standard Methods. Both sources include quality control techniques,
glassware requirements, and sample preservation procedures for toxic organic
pollutants.
Although not as great as the error associated with poor sampling tech-
niques, the potential for error occurring during analysis of wastewater
samples can have a great impact on the acceptability of monitoring informa-
tion. Without the aid of independent checks and general quality control, the
POTW laboratory technician may report erroneous results without being aware
that a problem exists. Analytical quality control assistance is available in
several forms from EPA. A document entitled Handbook for Analytical Quality
Control in Water and Wastewater Laboratories (PB213884) has been published by
the EPA Technology Transfer Program and is available through NTIS. This hand-
book provides specific information to guide the laboratory technician or
chemist toward sound and reliable techniques and procedures.
Many of the considerations discussed above are generally applicable to
larye POTWs where laboratories exist to handle industrial wastewater analysis
or where such facilities can be developed. However, if the POTW is not
equipped with a laboratory capable of analysis of all toxic pollutants, the
analytical work will probably be performed by commercial laboratories. To
ensure the quality of the commercial service, a quality assurance program
should be implemented. Spiked or blank samples can be sent to the chosen
laboratory, or identical samples can be sent to two or more commercial labo-
ratories and the results compared to determine the reliability and accuracy of
laboratory. The quality assurance/quality control procedures should be
performed routinely as part of the pretreatment program; the POTVI should not
wait for an emergency situation to verify the accuracy of the laboratory.
3-21
-------
Note:
Source identification and monitoring for slug discharges of high-strength
wastes is usually simple and straightforward. Generally, the POTW has a
fairly good idea of those facilities that might have caused the spill.
2.6.3 Recordkeeuinq
Good recordfceeping is an important part of tne response program. As
documentation of the events surrounding the spill or slug discharge and its
cleanup, these written records may have important legal implications, par-
ticularly in cost recovery or reimbursement. The records may also serve as a
learning tool in that the knowledge gained from the spill or slug discharge
can be applied to future spill situations. It is a good practice after the
spill is cleaned up, and the emergency is over, to go back and assess the
measures taken at tne scene. Evaluation of this sort is important in improv-
ing response techniques. A record of the progress being made in the cleanup
is also important in making decisions at the scene of the spill.
It is important to have preestablished recordkeeping procedures and forms
to make recordkeeping that much easier during a spill. If the procedures are
in place and are practiced, it is less likely that items will be missed.
During emergency response periods, where recordkeeping is not feasible or
could hinder response actions, recordkeeping can be postponed until time is
available.
One recommended recording method is for the spill coordinator to keep a
permanently bound book, log or diary, documenting the chronological events
from the time of notification of the spill until the cleanup and his duties
are completed. All events of any significance should be recorded in the log
with notations of the date and time. The information should include records
of flow, operation, maintenance sampling, problems encountered, telephone
conversations, meetings held, orders isures, weather obvservations, etc. The
log should be kept in a bound, sequentially numbered notebook. Entries should
be made in the log immediately and the date and time indicated. No pages
should be removed from the notebook. If a page is ruined, it should be marked
"VOID." Important observations involving judgment and sampling records should
be signed by the principal investigator and countersigned by a witness.
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J/REG X-4/#6
Tne important records tnat snould oe Kept in the notebook can De listed
as follows:
1. General events - for each day start/stop times for cleanup
activities, arrival or procurement of equipment, documentation for
authorization, weather obervations.
2. Treatment - by each process, hours of operation of each process,
maintenance neeaed and/or performed, equipment breakdowns, ultimate
disposal.
3. Sampling - records of sampling, sample preservation methods, and
destination and analyses required of samples.
4. Personnel - a record of all personnel on site, their function, and
the actual times present. This is especially important for those
personnel, whether from a government agency or third party con-
tractor, associated with the cleanup/treatment operation itself. It
is imperative that the spill coordinator develop a rigid communica-
tion network with the personnel attending the respective operation.
5. Photographs - a record of times and locations of all photographs
including a Drief description of the subject.
Another method that can be used to supplement the log book are forms that
indicate all of the information that is needed for appropriate documentation
of a spill event. Examples of such forms are provided in Appendix 7. The
forms address documentation of the initial report on the incident, listings of
all key events pertaining to spill response and cleanup and a recommended
format for a final report. The forms also include the names of National
organizations that can assist in some manner during a spill event; space has
been left for regional or local agencies to be included.
3.7 FOLLOW-UP REVIEW AND ACTIONS
A follow-up review of an event is important to provide an evaluation of
the industrial and POTW ASPPs and to provide a comprehensive summary of the
key aspects of the event. The POTW should be sure to conduct the follow-up
review and write the final report in a thorough manner. The final report will
most likely be the document that will represent the event and be referenced
during modification of the IU or POTW ASPP, or during the occurence of similar
spills or slug discharges in the future.
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Tnls section dfscusses procedures tnat can be used by a PQTW in
conducting trie review and highlights areas of concern tnat snould be investi-
gated during the review. Appendix 3 addresses the review of a spill event by
an inspector from the industrial facility, the information presented is also
applicable to a POTW review of the event. Also discussed in this section are
procedures for requiring modification of the ID ASPP and instituting civil and
monetary penalties.
3.7.1 Review of lU's Follow-Up Report
In cases where an IU was identified as the source of a spill or slug
discharge, a follow-up report should have been submitted five days after the
event. This report should have addressed the cause of the spill or slug
discnarge and what future precautions can be taken to prevent a reoccurrence.
The industry should also provide an evaluation of the spill response capa-
bilities onsite and how they could be improved in the future. The POTW should
review this Information as part of the follow-up review.
3.7.2 Review of Ill's ASPP
The industrial user's ASPP should be reviewed after the spill clean-up to
determine the deficiencies in the implementation of the lU's designed spill
prevention program. It is possible that the designed ASPP may be inadequate,
or a well-designed ASPP was not implemented properly. The design of the ASPP
should be reviewed in the following general areas:
• Storage areas for toxic and hazardous chemicals as raw materials,
intermediates, final products or by-products. These could include
liquid 55-gallon drums or dry storage bags, piles, bins, silos, tanks,
etc. The rev.iew should include an evaluation of any containment
structures, such as berms, located around the storage areas.
• Loading and unloading operations involving the transfer of materials
but not in-plant transfers. These operations include pumping of
liquids from truck or railcar to a storage facility or vice versa,
pneumatic transfer of dry chemicals to or form the loading or
unloading vehicle, transfer by mechanical conveyer systems, etc.
Again, secondary containment structures should be evaluated.
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t In-plant transfer areas, process areas and material Handling areas.
Tnese include transfer of liquids oy pipelines with appurtenances sucri
as pumps, valves arcd fittings, movement of bulk materials Dy mecnan-
ical conveyor-oelt systems, etc. All transfer operations within the
process area with a potential for release of toxic pollutants and
hazardous suostances to other than the process wastewater system
snould be reviewed in this group.
• Improper maintenance schedule for valves.
The specific requirements that should be reviewed in the above- mentioned
areas include materials compatibility, good housekeeping, preventive mainte-
nance, security, employee training, as well as specific process conditions at
the time of the spill or slug discharge, such as temperature and pressure vs.
strength of container, fittings, etc. For example, incompatibiltiy of
materials with the container and the environment can cause equipment failure
resulting from fire, corrosion or explosion. Elements of good housekeeping
would include neat and orderly storage of chemicals and prompt cleanup of
spilled liquids or powders to prevent them from reaching the collection
system. An effective preventive maintenance should include periodic inspec-
tions and testing of equipment systems, appropriate adjustment, repair, or
replacement of parts. Also, a security system which would prevent accidental
or Intentional entry to the IU site would reduce the risk of vandalism, theft,
sabotage, or other illegal use of plant facility that could possible cause a
spill. Additionally, an employee training program would provide a complete
understanding of 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 spills.
Employee training programs should be provided for employees at all levels of
responsibility.
3.7.3 IU ASPP Modification
Based on a thorough review as described in Section 3.7,2, the POTW should
pinpoint the deficiencies in IU's design or effective implementation of its
ASPP. In some cases, the corrective measures required at the IU's site where
the spill originated could require time (e.g., structural modification like
putting dikes, curbs, etc). In such cases, the IU should be provided a
compliance schedule to implement all necessary spill prevention measures
within a reasonable period of time.
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2.7.4 Civil and Monetary Penalties
The POTW should evaluate its authority to recover tne costs associated
with removal of spill or activities associated with reacting to a slug dis-
charge of conventional wastes and recovery of the damage done to the POTVi and
tne collection system. If the POTW has police powers, it can establish the
authority to enforce civil or criminal penalties against the Ills that violate
the prohibited discharge standards or requirements as established under the
POTW's pretreatment program. Details of legal remedies and emergency relief
are presented in the USEPA's Guidance Manual for PQTW Pretreatment Program
Development, October, 1983.
3.8 POTW'S ASPP REVIEW AND MODIFICATIONS
After the spill incident is concluded, the POTW should review its own
ASPP. All the problems encountered by the POTW from the time of notification
of the spill to its complete removal, disposal, and follow-up activities,
should be analyzed. The analysis of all the records and activities could
indicate certain areas where the POTW's program is not adequate. The objec-
tive of this review should be to identify the areas of deficiencies in the
spill response program and to implement modifications/corrective measures to
improve the ASPP.
The areas of deficiency could be in any of the number of steps discussed
in this chapter, including inadequate authority in the sewer use ordinance
that resulted in ability to collect fines/penalties, lack of coordination
between the various groups/agencies involved in spill control, inappropriate
sampling procedures and poor documentation. Some examples of modifications
could be as follows:
• An industrial discharge sampling program for collection and treatment
systems located in heavily industrialized areas may be desirable for
continuous maintenance of satisfactory plant performance and effluent
quality and determining potential future spill conditions.
• A monitoring and surveillance system could be installed at critical
points in the collection system and at the head end of treatment
plants to facilitate activation of spill contingency plans.
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• Emergency response agencies (e.g., police, fire) could be trained to
nandie nazaraous materials spills, oe informed of the alternative for
handling spills and informed of tne ramifications of these alter-
natives with regard to wastewater collection and treatment systems.
• The potential for spills of hazardous materials may need to be
reassessed. A more thorough inventory of hazardous materials stored
within the POTW service area may be warranted. If the POTW already
has sucn an inventory, it will need regular updating to keep the
information current.
t Disposal options for spilled materials or other contaminated materials
may need to be investigated. The hazardous material content of
resultant activated sludge after spills or chronic discharges of
nondomestic wastes may need to be quantified. The additional costs
incurred for disposal of hazardous materials could also result in a
revaluation of the budget for spill control.
All POTW's will not have the above-mentioned difficulties, but depending
upon the specific problems encountered by a POTW during a spill event appro-
priate modifications should be implemented at that POTW to improve future
spill control and response, and prevent reoccurence of similar spills.
3.9 FOLLOW-UP REPORTS
Throughout the spill emergency, cleanup, and review of the ID ASPP and
the POTW ASPP, the POTW should be documenting the event and all steps taken to
correct the situation. A final follow-up report summarizing all actions taken
including initiation of enforcement activities should be made and included in
the file.
3.10 SUMMARY OF CHAPTER 3
For an ASPP to be effective, the POTW must provide the necessary fore-
thought, planning, and resources to a spill response program. Regardless of
how effective the preventive portion of an ASPP is, a spill/slug discharge can
occur and the results devastating. An effective pretreatment program should
include adequate procedures for reacting to spills and slug discharges. If
the POTW is prepared, the damages resulting from a spill can be mitigated.
Chapter 3 details the items that are of major concern in the development of a
spill response program. The following is a summary of the key elements that
were discussed:
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* Tne POTW neeas to accurately evaluate the resource needs for program
implementation oasec on wnlcn local agency will tatce tne leac in
responding ro spills. The items to be considered should include:
- Personnel: adequate staffing, training, and clear lines of
responsibility and authority.
- Equipment: safety, control, treatment, and cleanup equipment is
needed. The specific items will depend on the actual industries in
tne community ana wnicn local agency nas tne leaa.
- Finances: finances to provide for the necessary personnel and
equipment as well as provide emergency funding for spill control
and cleanup.
Note: The local fire department and other agencies will have many
of these items available for responding to spills.
« Coordination between other agencies (particularly the fire department)
should be formalized so that the POTW is aware of who can assist in
what capacity, and amongst the local agencies who will be responsible
for different facets of the ASPP. A certain amount of training may
also be available from other agencies.
• A spill control coordinator should be designated prior to commencement
of spill response. This coordinator may be a representative of the
POTW, fire department or other agency. The assignment of a coordi-
nator and his responsibilities should be spelled .out as much as
possible in coordination agreements with other agencies.
• Identification of spill or slug discharge sources and proper detection
and notification procedures, although an administrative function is
the mechanism that initiates spill response. As such, the staff
involved with spill response should be aware of where the high risk
sources throughout the community are, what detector mechanisms may
exist to provide early warning, what the current notification process
is, and what other notification processes might occur in the event of
an actual spill.
• In an emergency situation, a rapid response time is essential,
therefore, a.preplanned methodology for the assessment of a spill or
slug discharge is beneficial. The POTW should evaluate the response
procedures and the steps that will be taken to initiate spill control
and cleanup.
0 Prior to a spill or slug discharge event, the POTW should closely
examine the containment and countermeasure options available. The
POTW may need to expand its resources to improve the containment and
countermeasure response to an event. An evaluation of personnel,
equipment, and funding may be needed.
• The POTW needs to develop thorough policies and procedures to
investigate a spill or slug discharge and to document the spill event
and subsequent investigation or enforcement action.
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• Document at io'n of the event will provide the POTW with the information
to conauct a comprenensive review of the industrial ASPP. The POTW
should evaluate the ASPP for deficiencies and for poor implementation.
As a result of the review, appropriate remedial action should be
taken. Prior to a spill, the POTW should be sure that it has tne
legal authorities necessary to require appropriate remedial actions.
• After a spill or-slug discharge event, the POTW should also evaluate
its ASPP for adequacy ar\d determine if modifications are needed.
• Finally, after a spill or slug discharge event, a final follow-up
report detailing the key elements of the spill and all significant
investigative and enforcement efforts should be made. This report
should oe retained with all other appropriate information, but it will
serve as a consise summary of the event.
Although these are the basic components of an ASPP spill response program,
each POTW will have to tailor its program to address the needs of the
community. Each program will be a function of the industrial community
composition and the community resources available for a program.
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4. DEVELOPMENT OF THE POTW's ASPP PROCEDURAL DOCUMENT
4.1 INTRODUCTION
In order for a POTW to have an effective pretreatment program, it is
extremely important that its implementation strategy include written pro-
cedures for the prevention of accidental spills of toxic materials or slug
discharges of high-strength wastes from entering its collection system. In
addition, the POTW pretreatment program strategy must consider procedures for
responding to spills and slug discharges. These procedures for prevention of
spills and discharges and for responding to spills and slug discharges make up
the ASPP procedural document (ASPP Plan).
In an attempt to increase the level of consciousness among POTWs in the
northwest, their industrial customers, local officials, and local response
agencies, EPA Region X has requested that POTWs with pretreatment programs
develop simple and straightforward written procedures for the prevention and
response to spills and slug discharges. The procedural document will not only
indicate to the Region and State a commitment that the pretreatment program is
being fully implemented, but will provide information on the community's
procedures for preventing spills as well as dealing with them. All procedures
that exist or will be developed should be spelled out in the ASPP procedural
document.
The benefits of establishing a written plan to respond to hazardous
material spills and slug discharges of high-strength wastes throughout the
POTW service area should more than outweigh the resources necessary to develop
such a plan. The goal of requiring ASPP development is to motivate the
municipality to think about preventing spills and slug discharges as well as
think through an emergency situation, and prepare for it. The procedural
document developed by the POTW should be the formalization of that thought
process; it should state the policies and procedures the municipality will use
to guide implementation of the program.
The following assumptions are made regarding development of the ASPP
procedural document by the POTW implementing a pretreatment program.
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« Tne POTU is at leas', regulating significant industries witnin its
system tnrougn implementation of its pretreatment program.
• At a minimum, all significant users will De required to develop its
own ASPP, or if an industry already has one, it will be required to
formalize the ASPP and forward it to the POTW, Additionally, other
users fitting tne criteria and classification estaolished in Sections
2.1 and 2.2 will develop an ASPP.
* Tne POTlv ASPP will most likely have some time schedules for completing
some of tne components.
• The POTU should recoynize tnat some of the aoministrative procedures
{such as MSK assessment, finaliz-iny tne list of affected sources,
inspection, development of review procedures of an IU ASPP, estab-
lishing ccorainatiny procedures with otner local agencies, etc.) migrtt
in some cases require additional time. Because of tne potential
seriousness of spills and slug discharges, tne POTW should attempt to
have tneir ASPP implementation procedures in place as quickly as
possible.
• At a minimum the local fire department (or some other agency outside
the POTW) has some involvement in responding to reported spills of
chemicals (in some cases, they may De tne lead agency) and has safety
equipment, procedures, and trainee staff for emergency response. The
ASPP will-have to elucidate the roles and responsibilities of the POTW
and local emergency response agencies. It must be recognized that if
a spill has tne potential to enter the collection system, the POTW
and/or and public work's staff who handle the collection system must
be involved.
In the previous chapters, information was provided with regards to the
objective of an ASPP, the Benefits, wnat procedural strategies should be
considered in developing and implementing an ASPP. Additionally, there were
discussions on the components of an ASPP developed by a POTW and an industrial
facility. Tnis chapter will recommend a strategy for developing the ASPP
plan, discuss a recommended format and wnat type of information to include
within the ASPP document. A model POTW ASPP based on the criteria in this
manual is included in Appendix 1.
4.2 FORMAT AND INFORMATION REQUIREMENTS OF THE ASPP PLAN
The ASPP procedural document should be straightforward and concise. The
document can be effectively written by using a descriptive outline. Such a
format will allow for the logical presentation of information, and can be
enhanced by including organizational charts, flow charts, and forms to present
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more aetailea Information. Tne text should provide general Information
concerniny tne treatment plants, regulated Ills, and tne past History of spills
and POTW upsets. Information on legal authority and enforcement authority
should be induced in the document.
All critical elements of the ASPP, from administration of the prevention
component of the program to response procedures, should also be addressed in
tne ASPP document. Proyram prevention element will most IKely De a POTW
responsioility whereas response procedures vail be a snared responsibility
with other agencies. In addition, all agreements the POTW has with other
agencies concerning program implementation and response should be either fully
detailed or a schedule provided for developing the necessary agreements.
Finally, the document snould specify the schedule for implementation of
the ASPP and the resources available to the program such as staff, equipment
(sampling, safety, containment), and training. It should also discuss the
sources and extent of funding for program implementation, particularly for
emergency response and cleanup.
4.2.1 General and Historical Information
In this first section, the POTW should provide general information on the
POTW. Such information should include tne following:
• POTW Information
- POTW name and address
- Responsible official (ASPP coordinator/spill coordinator)
- Telephone number
t Treatment Plant Information
- Date of Pretreatment Program Approval
- Name(s) of treatment pi ant(s), daily flow rates, percent industrial
flows, and level of treatment
» List of types of industries (including categorical industries) and the
number of facilities of each type discharging to the POTW. This
should be an all inclusive list containing industry types (including
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in-transit, stationary; covered by pretreatment requirements, in
addition to commercial ana industrial types tnat could oe affected Dy
the ASPP.
The POTW should also describe 'any past incidents of spills and POTW
upsets resulting from spills or high strength slug discharges. This descrip-
tion should include: date of incident; type and quantity of pollutant(s)
discharged; description of upset or damage to POTW and resulting problems or
violations; health effects on workers or community; and remedial and
enforcement actions taken.
4.2.2 Evaluation of Legal Authority and Enforcement Procedures
The POTW needs to outline its legal authorities and should include a
copy of the language in its sewer use ordinance. The POTW needs to outline
what type of enforcement mechanism (i.e., permit, contract, industrial waste
acceptance form) it will utilize to communicate to the industry the require-
ments of developing and implementing an ASPP to include specifically reporting
requirements. Related to this discussion, the POTW should include a copy of
the language in its control mechanism that it will be utilizing to convey ASPP
requirements to the affected lUs. Additionally, if the POTW will use some
form of notification letter to inform low-medium risk IDs about ASPP require-
ments, a copy of an example letter with standard conditions should be
attached. -The POTW should also include in this section an outline of the
type of enforcement procedures it can utilize to deal with spills or slug
discharges caused by a facility. For POTWs implementing pretreatment pro-
grams, this description should be brief and simply reiterate existing
enforcement options available to it.
4.2.3 Identification of Potential Sources and Spill Potential
The POTW should describe the process for examining its industrial and
commercial base, and developing a list of users that have the potential to
have accidental spill of chemicals and/or slug discharges of high-strength
wastes. If tnis process has not been completed yet (i.e., as part of POTW
pretreatment program development), then the plan needs to include a time frame
for completing it. Chapter 2 recommends the following categorization: low
risk, moderate risk, and hign risk facilities.
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Tne process description should cover tne following:
• Sources utilized to identify users (most likely the POTW original
industrial user survey, fire department data, RCRA data from
State/EPA site inspection reports)
• Selection criteria used to screen data (data collection and review
criteria tor-selectiny potential candidates, risk assessment criteria
for review of potential candidates)
t Listing of potential candidates appropriately categorized
• Schedule for additional data collection, such as inspection of all
potential users capaole of spill chemicals and slug discharging nign-
strength wastes.
This process should result in a larger number of industrial and
commercial facilities that are already covered by the pretreatment program.
Most POTWs1 efforts focus on regulating process wastewaters from significant
users. At a minimum, tne classification system should result in the
significant users being required to develop an ASPP.
The plan should either Include the list of users categorized as low,
'medium, high risk or provide a schedule for developing and submitting the 11st
to Region X or the State.
4.2.4 Administrative Program for Regulating Sources
This section deals with the POTW's Program for the prevention of
accidental spills and slug discharges. The POTW needs to outline its pro-
cedures which should be well thought out and as simple as possible. The
following areas need to be discussed:
• III ASPP development requirements
Discussion of the different ASPP development requirements for each
category, such as low, medium, and high risk facilities.
• Notification of affected sources
- What type of IU notification system will be utilized. The guidance
document recommends three types of notification based on risks
(low, medium, high), namely use of form letters, permit-type
mechanism to convey requirements.
- A time frame for notification must be part of the ASPP plan.
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t keauirements of an ID ASPP
Tne POTW needs to discuss in its program plan, the type of users wno
will be required to develop a plan, wnat will be required in the IU
ASPP, time frame for submittal of the ASPP, the POTW's criteria for
reviewing tne IU ASPP, and the industries' reporting requirements.
(Appendix 3 contains recommendations for an IU ASPP and Appendix 4
contains an outline of review criteria for the POTW's consideration.
Tne POTW in its ASPP may want to simply refer to these in lieu of
developing tneir own criteria.)
» Inspection and monitoring of affected sources
The POTW should briefly outline its procedures for ongoing inspection
and monitoriny of affected sources. Hopefully, this will simply
result in highlighting these procedures as an extension of the POTW's
existing pretreatment compliance monitoring effort. The inspection
strategy should cover all affected sources, but in terms of frequency
concentrate on tne nigh-risk sources. (Medium to low risk facilities
should De randomly inspected less frequently than high risk facili-
ties.) The POTW inspection program snould be sufficient to verify the
information provided by the industry and determine whether the IU ASPP
is being properly implemented. In addition, inspections should
provide information for a continued evaluation of spill potential.
Inspections should be dynamic; namely, the POTW should have a process
to modify the list of users to be inspected.
This section of the plan should discuss:
- How inspections will be conducted (include level of effort)
- Criteria for sampling
- Use of forms
- Documentation of inspections
- Use of safety equipment/sampling equipment
- Type of staff involved
- Frequency of Inspections
• Coordination With Other Agencies
Coordinated efforts with other agencies should be explained in the
document, being sure to identify any other agencies with respon-
sibilities for implementation of the prevention component of the ASPP.
4.2.5 Spill Response Program
To develop this section of the ASPP, the POTW should carefully review
Chapters 2 and 3, as we'll as refer to the manuals listed in Appendix 8. These
manuals have been referenced throughout this manual or were used in the
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development of the manual. They will provide specific technical information
tne POTW may wisn to incorporate or reference in the ASPP. In addition, some
could be useful reference books to be used for training for an emergency. As
discussed in the introduction to this chapter, it is critical that the POTW
develop the necessary procedures as soon as possible and enact any necessary
cooperative agreements with other local agencies who share emergency response
responsibilities. Any cooperative agreements should be part of the ASPP
submittal to the State/EPA. It is anticipated that a number of POTWs have
certain agreements with the local fire department or police department, as
well as some type of response program so that they do not have to start from
scratch.
The written procedures (or processes) that need to be discussed in this
part of the plan will be dependent upon which local agency will be the primary
agency responsible for spill response of toxic wastes. If the POTW will be
the lead group, then the ASPP plan will have to be very comprehensive covering
all elements of Chapter 3. If the POTW is not the lead, then the ASPP plan
will need to reflect a shared responsibility for responding to spills or
emergencies at an industrial site. If coordinating agreements have not been
enacted or coordinating procedures have not been finalized, then the POTW
should provide a schedule for completing this task and forwarding it to the
EPA and State.
In terms of responding to slug discharges of high-strength wastes, the
POTW should describe procedures for detection, identification of source,
assessment of slug discharge, typical response measures (containment, treat-
ment), investigation, sampling and analysis, recordkeeping, review of ID ASPP,
and enforcement.
The following points should be discussed:
• Primary response agency
Narrative discussion of which local agency will take the primary role
in spill response. The POTW needs to mention who will be the spill
coordinator for the community. If multiple agencies are involved, the
agreements with them should be described. In addition, if the POTW
anticipates utilizing any outside assistance (in terms of trained
personnel, equipment, etc.), this needs'to be mentioned.
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• Detection ano notification of spills ana slug discharges
The POTW should describe any monitoring systems it has to detect
spills and slug discharges, the industrial reporting requirements,
and which local agency takes the lead in responding.
If an incident occurs outside the normal business hours, the plan
should describe how notification of the POTW is handled.
t Evaluation of spills and slug discharges
The POTW should outline how it responds to a spill, how risks are
assessed (e.g., there would be a difference in response if a spill has
not entered the collection system vs. if it has, (determination of
resource and equipment needs, safety considerations, etc.).
t Spill containment and countermeasure options and equipment
The POTW simply needs to outline what the municipality's response
capabilities are, and the types of options available for containment
at the site, in the collection system, and/or at the treatment plant.
The treatment options available should be listed along with the type
of safety equipment and equipment utilized to contain or treat the
spill.
• Spill and slug discharge event investigation and documentation
The POTW plan should outline how an investigation is conducted. The
POTW should include any standard forms used for documentation and
describe what type of on-site reporting and follow-up reporting is
utilized. The POTW must very clearly indicate in its ASPP plan that
all incidents are fully documented and filed accordingly.
• ASPP evaluation and modification
The plan should outline how the POTW's ASPP and IU ASPP is
occasionally evaluated and modified.
d.2.6 Data Management
There are various components of a POTW ASPP that warrant data gathering
and filing: initial assessment of industries, notification, IU ASPPs,
inspection and monitoring, spill response and investigation. Data management
for most POTWs implementing a pretreatment program should not be a problem,
since they should already have a system. If anything, it may have to be
expanded to accomodate different types of data and/or increase number of
facilities affected by the ASPP. The use of standard forms will be
beneficial. Appendix 7 contains a few suggested forms.
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The POTW ASPP.plan should outline the data needs and now the data will oe
organizea. It should also contain all forms used in the ASPD.
4.2.7 ASPP Implementation Schedule and Resources
The ASPP Plan should detail all of the steps that will be undertaken to
implement the program and, where appropriate, a time frame for accomplishing
those tasks (i.e., all industries will be inspected within 30 days, all
industrial user ASPPs will be reviewed and approved within 45 days, etc.) The
plan should provide the EPA Regional Office with a good idea of how long the
program will take to be set up and in full operation.
The POTW needs to evaluate and report in its plan its staff/funding/
equipment. Generally, POTWs implementing pretreatment programs should be in
fairly good shape. There may be a need to provide some training to staff on
spill response. Also, they may need to obtain some additional safety equip-
ment or equipment for responding to spills and slug discharges. The POTW may
be able to work out an arrangement with the fire department and other local
emergency response agencies to collectively acquire equipment to keep the cost
of the program down.
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APPENDICES
-------
C/RES. X-4/*18
APPENDIX 1
POTW ASPP DEVELOPMENT
• Flowchart of Fundamental
Procedures for POTW ASPP
Development
t Model POTW ASPP Format
• Model POTW ASPP
-------
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C/Reg. X-4/#5
MODEL POTW ASPP FORMAT
ACCIDENTAL SPILL PREVENTION PROGRAM PLAN
(POTW Name)
(Date) ,,1985
I. GENERAL AND HISTORICAL INFORMATION
A. POTW Information
Authority Name
Mailing Address
ASPP Coordinator/
Spill Coordinator
Phone NumDer
B. Treatment Plant Information
Flow % Indus- Level of Ratio Separate/
Name (mgd) trial Treatment Combined Sewers
1.
2.
3.
C. Pretreatment Program Information
Date of program approval
Regulated industries by type (include industries that are and are
not regulated by categorical pretreatment standards) The list
should be an all inclusive list of all industry types (chemical,
industrial, in-transit, stationary) potentially capable of spilling
chemicals or.slug discharging high-strength wastes.
Type of Industry Number of Facilities
1. . ..
2.
3. . . ^
4. ___
5. ;
6.
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C/Rec. X-4./*t
D. Past History of Spills ana POTW Upsets
II. ASPP LEGAL AUTHORITY AND ENFORCEMENT PROCEDURES
A. Sewer Use Ordinance Language (Please attach copy)
B. Control Mecnanism Language that Conveys ASPP Requirements (Please
attacn copy;
C. Outline of Enforcement Procedures
III. IDENTIFICATION OF POTENTIAL SOUKCES ANU SPILL POTENTIAL
A. Description of Process Used to Identify Potential Sources of Spills
and Slug Discharges
0 Updating survey, gathering additional data, inspecting facilities
« Description of mechanism used to notify all potentially regulated
industries and of the notification process
B. Description of Criteria and Classification Scheme Used to Select
Potential Sources and Assign Level of Risk
C. List of All Users Appropriately Categorized (high, medium, low)
Note: Provide schedule for gathering data and characterizing users,
if additional time is needed.
IV. ADMINISTRATIVE PROGRAM FOR REGULATING SOURCES
A. ID ASPP Development Requirements
B. Description of IU Notification System (example language for permit,
letters, Section II.A and B above)
C. Requirements of an IU ASPP
0. Inspection and Monitoring of Affected Sources
E. Coordination With Other Agencies for Prevention Component of ASPP
(if appropriate)
V. SPILL RESPONSE PROGRAM
A. Coordination of Spill Response (narrative discussion on which local
agency takes tire primary lead)
B. Detection and Notification of Spills and Slug Discharges
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C/Reg. X-4/#6
C. Evaluation of Spills and Slug Discharges
D. Spltl Containment ana Countermeasure Options and Equipment
E. Spill and Slug Discharge Event Investigation and Documentation
F. ASPP Evaluation and Modification
Note: This section should be t>ro
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C/Reg. X-4a/*22
MODEL POTW ASPP
To illustrate the ASPP requirements specified in Chapter 4 and provide an
example, a POTW ASPP model was prepared.
The model ASPP gives some ideas on the types of proclems a POTW may want
to address and possible solutions for these problems. In certain sections of
the manual, references are made to forms and other information that has been
provided in the text and Appendices of the ASPP Guidance Manual. These
references are enclosed by brackets and typed in bold. They were used to
avoid unnecessary repetition of material within the manual. In addition,
other specific information, such as why a certain procedure might be bene-
ficial, has also been included in brackets throughout the model.
Additionally, the level of detail in a POTW ASPP will vary depending on a
POTW's circumstances, whether it will be the primary agency for responding to
spills, the number and type of industrial users in the community, existing
spill programs, etc. A POTW should review the ASPP requirements in Chapters
2, 3, and 4 of the guidance manual and determine how much detail 1s needed in
its ASPP.
Region X recognizes that a POTW may not be able to complete development
and implementation of all of the ASPP requirements at the time of submittal of
the plan. In fact, the model plan illustrates how to address procedures and
agreements which are not fully developed at the time of submittat. In such
cases where the POTW's plan is deficient, the actions planned that have yet to
be taken need to be mentioned in the appropriate sections of the ASPP. The
expected completion dates of all items under development must then be detailed
in the plan in Section VILA - ASPP Implementation Schedule.
Finally, it is important to reiterate that this is a model. not an ASPP
to be adopted by any particular POTW verbatum. An ASPP needs to be developed
by a POTW after careful consideration of all elements with respect to its
needs, resources, and community-wide efforts.
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H/REG X-4a/*21
11/1/85
ACCIDENTAL SPILL PREVENTION PROGRAM PLAN
I. GENERAL AND HISTORICAL INFORMATION
A. POTW Information
Authority Name
Mailing Address
ASPP Coordinator/
Spill Coordinator
Phone Number
Proooa City Sanitary Commission (PCSC-
15 Main Street
Proppa City, UA 99999
Ray Topper
(919) 919-9191
B. Treatment Plant Information
1.
2.
3.
Fl ow
Name (myd)
Proppa City STP 11
% Indus-
trial
21
Level of
Treatment
Secondary
Ratio Separate/
Combined Sewers
80/20
C. Pretreatment Program Information
Date of program approval 6/23/84
Regulated industries by type (include industries that are and are
not regulated by categorical pretreatment standards)
Type of Industry
1. Electroplating/Metal Finishing
2. Wood Preserving
3., Pulp and Paper
4. Commercial Laundries
5. Photofinishlng '
6» Paint Manufacturer
7. Companies with Warehouses Containing
Hazardous Materials
8. Miscellaneous Dry Industries,
Number of Facilities
3
1
1
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H/REG X-4a/*21
Type of Industry Numoer of Fa c in ties
9. Fooc 3rocessors 3
10. Raalator Shoos
11. Service Stations 26_
12. Pesticide Applicators 6_
12. Major Restaurants . 15
14. Meat
15. Railroad Yard
16. Truck Washino Facility
17. Railroad Tank Car Washing Facility
18. Hospital
19. University
20. Landfill
The above list is an all inclusive list of industry commercial type
(stationary and in-transit) wnich may be capable of spilling cnem-
icals or slug discharging hign-strength wastes. Under our present
pretreatment program, we regulate a number of these-facilities as
significant users. A permit system is used for conveying pre-
treatment requirements to these users. The other users that are
listed were taken from our original industrial survey. "As discussed
in Section III, we will have to evaluate whether these users should
be covered under our ASPP program. We will have to secure addi-
tional data and conduct onsite inspections to determine how each
user should be categorized (low, medium, hiyh risk). Once we com-
plete this evaluation, we will be generating a table categorizing
and classifying each of the above users. This process will take
some time to complete. Section VII contains a schedule for comple-
tion. The table will be forwarded to the EPA Region X office once
completed.
D. Past History of Spills and PQTW Upsets
t Prior to 1981:
- 5,000 gallons of chromic acid traced to Acme Plating, STP down
for one week; no enforcement action, civil suit to recover
damages.
- Gasoline discharges and resulting potential for explosion and
fire (source not identified).
- Treatment plant process efficiency drops (source not
identified).
- Severe increases in the levels of cadmium, chromium, and
copper in the sludge (source not identified).
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H/REG X-4a/#21
Strong solvent oaors in the collection system wnicn In one
case causec a PCSC worKe^ to oecome i11 for several aays
(source not identified).
- Treatment plant overloaded on several occasions due to slug
loading from meat processing plant. NPDES limits exceeded.
1981 POTW action to control spills:
- PCSC strengthened its City ordinance to regulate industrial
aiscnarges, recover operating costs ana meet trie requirements
of the Federal pretreatment regulations.
- PCSC created the Industrial Pretreatment Division (IPO) to
develop and implement the pretreatment program.
- Investigation and documentation of slug discharges has
improved.
Spills and corrective actions after inception of IPO:
- December 1981 - A gasoline spill of 200 gallons was reported
Oy a truciang company. The spill was washed into a combined
sewer by the fire department. After this incident, a new
policy was developed with the fire department: in known cases
of gasoline or other explosive liquids, containment was
preferred to flushing into the sewers. [Risks of the con-
tainment of such materials versus the explosive hazard in the
sewers due to the potential of fumes backing up Into other
Industries and homes need to be evaluated.]
- October 1982 - Extreme decrease in the treatment plant
efficiency observed one night; effluent BOD levels exceeded
NPOES permit limits for the next two days. Sluy discharge of
high strength or toxic waste was suspected but the materials
or source could not be determined.
- May 1983 - A fire in a warehouse containing pesticides caused
a discharge of pesticide laden water to be discharged through
the floor drains in the building to the sanitary sewer. The
PCSC tried to take measures at the plant to minimize the
effects of the discharge, but the plant still was knocked out
for several days. The PCSC tried to recover costs of the
plant upset from the company that owned the warehouse, but the
company went out of business. The fire department was first
on the scene and could have contained material from entering
sewers. [Coordination procedures need to be developed between
all participating local agencies.]
- November 1984 - A faulty tank valve caused a leak of toluene
into a floor drain and into the sanitary sewer. After 200
gallons had been discharged, the IU discovered the leak and
notified the fire department who in turn notified the IPO.
All work within the system was stopped until the toluene had
passed through.
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H/REG X-4a/#21
AS?D LEGAL AUTHORITY AND ENFORCEMENT PROCEDURES
A. Sewer Use Ordinance Language
Presented below Is an excerpt from the PCSC ordinance whicn covers ASPP
requirements for I Us.
ACCIDENTAL SPILLS AND SLUG DISCHARGES
(A) Each User snail provide protection from accidental or
slug discharges of restricted materials or other
substances regulated Dy tms Ordinance. Facilities to
prevent accidental discharges to restricted materials
shall be provided and maintained at the owner or User's
own cost and expense.
(B) Certain Users will be required to prepare Accidental
Spill Prevention Program Plans showinu facilities and
operating procedures to provide this protection. These
plans shall be suomitted to the Industrial Pretreatment
Division (IPO) for review and approval. All existing
Users required to have ASPPs snail submit such a plan
within three months of notification by the IPD and
complete implementation within six months of notifica-
tion. No User who commences contribution to the PCSC
system after the effective date of this Ordinance shall
be permitted to Introduce pollutants into the system
until accidental discharge procedures have been approved
by the IPO. Review and approval of such plans and
operating procedures shall not relieve the User from the
responsibility to modify the User's facility as neces-
sary to meet the requirements of this ordinance.
(C) In the case of an accidental spill or slug discharge, it
is the responsibility of the User to immediately notify
the IPD of the incident. The notification shall include
location of discharge, type of waste concentration and
volume, and corrective action.
(D) Within five (5) days following an accidental spill or
slug discharge, the User shall submit to the IPD a
detailed written report describing the cause of the
discharge and the measures being taken by the User to
prevent similar future occurrences. Such notification
shall not relieve the User of any expense, loss, damage,
or other liability which may be incurred as a result of
damage to the PCSC system, fish kills, or any other
damage to person or property, nor shall notification
relieve the User of any fines, civil penalties, or other
liability which may be imposed by the ordinance or other
applicable law.
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H/REG X-4a/#21
A notice snail oe permanently posted on tne User's
premises advising employees whom to call In the event o
an accidental or sluy aiscnarge. Tne User shall insure
tnat all employees who may cause, or allow sucn an
accidental or slug discharge to occur, are advised of
the emergency notification procedure.
B. Control Mechanism Language
The IPD uses a permitting system to control IDs and will utilize this
system for conveying ASPP requirements to the hiyn risk and some medium
risk users as appropriate. Low risk users will be notified via letter
(see Section IV.B). The typical language used in the permit to cover
ASPP requirements are presented below. The reporting requirements apply
to all I Us,. The ASPP Plan requirements apply only to certain industrial
users that meet the criteria specified in Section III.B, below.
REPORTING REQUIREMENTS
The Industrial User shall notify the Industrial Pretreatment
Division (IPO) at 919-9191 immediately upon any accidental or
slug discharge to the sanitary sewer as outlined in the
Accidental Spills and Slug Discharges section of the PCSC's
Ordinance. The Industrial User will be required to post
notices in conspicuous locations regarding notifying the POTW
in the event of a spill of slug discharge. Formal written
notification, discussing circumstances and remedies shall be
submitted to the IPD within 5 days of the occurrence.
ASPP PLAN REQUIREMENTS
The Industrial User shalli- submit an Accidental Spill
Prevention Plan (ASPP) within three months and complete
implementation of the Plan within six months of notification
by the IPD. The Plan must detail facilities and procedures
to eliminate or minimize the accidental spill or slug
discharge of pollutants into the sewer system, which could
have an effect on the PCSC treatment plant, sludge, or cause
the PCSC to violate its NPDES permit. The ASPP should meet
the requirements and follow the format specified by the IPD.
Once approved by the IPD, the ASPP will become an enforceable
part of the permit. The IPD reserves the right to inspect
the facility to ensure that it is adequately implementing its
ASPP program.
C. Outline of Enforcement Procedures
A detailed description of the IPO's enforcement procedures was submitted
with the IPD's pretreatment program submittal. To briefly outline tnese
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H/REG X-4a/#21
procedures, trie fol "lowing succeeding enforcement actions are taken until
compliance is acmevea DV me IU.
1. Telephone or personal contact advising the IU to correct the problem
2. Notice of violation
2. Second notice of violation with references to administrative order
ana possiole loss of water and/or sewer service
4. Show cause hearing
5. Adminstrative Order
•6. Fines and penalties
7. Shut off water service
8. Block sewer connection.
III. IDENTIFICATION OF POTENTIAL SOURCES AND SPILL POTENTIAL
A. Identification Process
To identify potential sources of hazardous material spills and slug
discharges, the IPO first examined its pretreatment program data. This
data Includes the following:
t Industrial waste survey data obtained during pretreatment program
development
• Baseline monitoring report, final compliance reports
• Permit applications
• IU inspection reports
• Other miscellaneous data and correspondence.
The industrial waste survey conducted during development of the IPO
pretreatment program concentrated on significant users that discharge
process wastewaters. Our questionnaire gathered information from these
facilities on storage and usage of hazardous materials in any signifi-
cant quantity. These facilities were inspected to determine if any of
the materials were discharged or had the potential for discharge.
Industrial waste survey data was augmented with data from permit
applications and follow-up inspections. Such inspections were conducted
at large categorical IDs and at lUs where facility data was incomplete
or required verification.
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H/RES X-4a/#21
we nave a number of additional industrial and commercial type facilities
(see Section !.C) for wnicn we will nave to gather additional informs-
tion to assess the potential for spills or slue aiscnarges. We will jse
tne process Described in Section Z.I of tne ASPP Guidance Document to
gather the additional information. It will bascially consist of:
• Developing a simple questionnaire.
t Site inspection of each potential facility. (We will fill the
questionnaire out during the inspection).
• *Secure aata from fire department, EPA hazardous waste files.
• Tabluate data on each user using similar tables as Tables 2-1, 2-2 in
the ASPP guidance document.
*We discovered three additional users when reviewing these files.
These users were inspected and data gathered on each.
We will contact all potentially regulated industries with a letter
explaining the commission's intent to develop an ASPP. Industries from
which additional information is needed will also receive the
questionnaire mentioned above.
Based on this comprehensive data gathering and review process, we will
develop a list of lUs that meet the criteria (see. below) for inclusion
in the PCSC ASPP and will classify them according to the scheme outlined
in Section III.B, below.
Basic information and ASPP related data for lUs controlled under the
ASPP will be tabulated using a special format. [Two examples of
industry data forms and a summary form are provided In Tables 2-1, 2-2,
and 2.3 1n Chapter 2.] The data in the tables will be included in the
IPD data management systems described in Section VI.
This identification process will take additional time to complete. A
schedule has been included in Section VII. The list of all users
categorized and classified will be forwarded to EPA (State).
B. Criteria and Classification Scheme
To develop appropriate criteria for regulating lUs capable of
discharging toxic chemicals under the ASPP, the IPD decided that cut off
values for the amount of hazardous materials stored by an III should be
developed and used as guidelines for determining if an IU should be
included in the ASPP. To develop these cut off values, the IPO used the
EPA's list of hazardous materials and reportable quantities delineated
in 40 CFR Part 117 [Appendix II of this manual] as the basis for its
list of materials and cut off values.
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H/REG X-4a/?21
-or use"s aiscnarging nonnazaraous type wastes, tne IPD assessed tne
potential of slug discnarges of hign-strengtri wastes utilizing tne
following: general knowledge of the facility, past history, obser-
vations from inspections (sloppy operation vs. clean operation, good
housekeeping practices/bad housekeeping, condition of operating equip-
ment, spillage and containment facilities), flow cnaracteristics, type
wastes, we have a fairly good iaea of the potential slug discnargers of
nign-strength wastes.
CRITERIA FOR IU ASPD DEVELOPMEN
• If an Ill's maximum storage quantity of any of the listed
hazardous materials exceeds the EPA's reportable quantity, the
IU is included in the ASPP.
t If the maximum quantity of each material stored is less than the
reportable quantity Out the cumulative quantity of hazardous
materials in a particular category exceeds the reportaole
quantity, then the IU is included in the ASPP. [If an IU stores
600 Ibs each of acet aldehyde and acetic acid (both category C
materials with reportable quantities of 1,000 Ibs), the IU Is
Included in the ASPP because the cumulative quantity stored
exceeds the reportable quantity.]
0 If IU has the capability based on Its operating characteristics
to slug load the collection system or treatment plant.
0 The Ills that met the criteria for inclusion in the ASPP were
then classified according to the degree of risk they present to
the PCSC system, taking into consideration the potential for
spills and slug discharges as well as the types and quantities
of hazardous materials stored.
CLASSIFICATION OF IUs
0 Low risk facilities: Facilities that store hazardous materials
in quantities greater than the cut off levels but do not have
floor drains, sumps, or other connection to the sanitary sewer
which a spill could be discharged to. Facilities discharging
conventional wastes but pose no threat to slug loading the
system or having some other affect in the collection system or
treatment system.
0 Medium risk facilities: Facilities that store hazardous
materials in quantities greater than the cut off levels; have
floor drains, sumps, or other connection to the sanitary sewer
which a spill could be discharged to; and have already imple-
mented an accidental spill prevention program reducing the risk
of a spill or slug discharge. Facilities that could potentially
discharge slug discharges of high strength conventional wastes
are also included in this category.
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H/REG X-4a/#21
t Hlgn risk facilities: Same as medium risk facilities except IUs
have not completed implementation of an ASPP or their ASPP
failed anc is Being modi flea to prevent future problems. These
facilities pose a severe risk in terms of spilling cnernicals or
high-strength wastes that could have serious effects on our
collection system or treatment system.
[It should be noted that the above criteria are to be used as guidelines
for determining an appropriate category for an IU. Ultimately, best
engineering judgment is used to assign the appropriate category.]
IV. ADMINISTRATIVE PROGRAM FOR REGULATING SOURCES
A. IU ASPP Development Requirements
• Facilities in the low risk category do not need to implement an
ASPP
• Facilities in the medium risk category have to ensure that tneir
ASPP is up to date and continually being maintained
• Facilities in the high risk category must develop an ASPP and
complete its implementation within six months of notification by
the IPD.
All IUs controlled under the ASPP, regardless of the category assigned,
will be monitored by the IPO and included in the ASPP data management
system (See Section VI).
B. IU Notification System
All IUs neyulated by the Pretreatment Program or the ASPP (high, medium,
low risk) will be notified of the accidental spill and slug discharge
requirements as specified in the PCSC ordinance. Additionally, the IUs
that fall under tne ASPP will be notified of their respective require-
ments under the classification scheme previously discussed.
• Low risk facilities will be advised via letter that they should
notify the IPO of any increase in types or quantities of haz-
ardous materials stored or process wastewater discharges. The
letter will also contain the items contained in Section 2.3.1 of
the ASPP guidance document [five bulleted Hens in the first
paragraph].
• Most medium risk facilities will be notified via letter of their
responsibilities to update and maintain their ASPPs as necessary.
The letter will also-contain the general requirements contained
in Section 2.3.1of the ASPP guidance document. As outlined in
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H/REG X-4a/#2i
Section 2.2.1 unaer moderate risk facilities, we may nave to
customize some of our letters to deal witn specific circumstances
at these sites. Aaaitionally, we mignt decide in a few cases
that issuance of a simple permit may be appropriate.
• High risk facilities will be notified that tfiey must develop and
implement an ASPP. The permit will convey appropriate
requi rements.
For medium and mgn risk facilities tnat require permits or a
customized letter, we will incorporate tne language presentee in
Section II.A and B of this ASPP.
C. IU ASPP Requirements
As discussed above, lUs classified as medium and high risk facilities
must develop and implement an ASPP. The following are tne essential IU
requirements:
• The ASPP plan must follow the format and requirements specified
by the IPO. [See Appendix 4 of the manual for an example III ASPP
format.]
0 The ASPP must be submitted to the IPD within three months of
notification and implemented within six months.
• IPD will review-the ASPP for adequacy using a review checklist
[Appendix 5 of the manual provides such a checklist].
• After review, a notice of adequacy or deficiency will be sent to
the IU; inadequate submissions must be revised and resuomitted.
• lUs required to have an ASPP must report to the IPO any process
changes, facility modifications, or problems with tne ASPP, and
any subsequent changes made in their ASPPs.
• The permit or letter issued to the ID will contain specific
reporting requirements.
D. Inspection and Monitoring
Industrial inspections and monitoring are conducted under the following
circumstances:
t Inspections conducted as part of the industrial waste survey or
to obtain ASPP information
• Follow-up inspections conducted during the IU ASPP review period
to determine the adequacy and accuracy of the ASPP
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H/REG X-4a/#21
» Additional inspections and follow-up If the ASPP falls at any
time
t Routine Inspections to verify IU ASPP program Implementation.
The frequency of inspections will be based on the risk. All nigh
risk facilities will be inspected two times a year (most of these
are already inspected twice per year for pretreatment
requirements). Medium to low risk facilities will oe inspectefi
less frequently and randomly. The IPD will be developing a list
of users to be inspected eacn year. The first list will be
aevelopea in 60 aays ana will oe suomitted to EPA legion X.
« Inspections at an IU without an ASPP after the occurrence of a
spill or slug discharge
• Inspections conducted for pretreatment requirements will also
check ASPP requirements.
• Evidence of wastewater treatment plant interference or upset of
co11 action system problems.
• Complaints.
• Information obtained from fire department, other local, county,
State, Federal agencies.
To.aid in monitoring the IDs controlled under the ASPP, a data
management system will be developed. Further information on the data
management system Is provided In Section VI.
£. Coordination with Other Agencies
The fire department conducts inspections of many industrial users
throughout the community. They will copy the PCSC on all inspection
reports concerning industries regulated by the pretreatment program or
the ASPP, as well'as any industry of concern. In addition, the PCSC
will notify the fire department of any industries that may be a fire
hazard. An agreement has been signed by both parties.
V. SPILL RESPONSE PROGRAM
In terms of responding to toxic spills that could enter our sewer
system, the fire department is the lead agency. We will need to develop
agreements addressing coordination of spill response activities. In the
case of slug discharges of high-strength wastes, the IPO will have sole
responsibility for responding to these.
A. Coordination of Spill Response
The IPD has not formalized all agreements with any agencies at this
time. However, the local fire and police departments and State and.
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H/REG X-4a/*21
,-eaeral emergency response agencies nave all oeen aoviseo of me IPD's
Intent to assist anc oe Involved witn all spills potentially affecting
tne PCSC.
The IPD expects to formalize an agreement with the fire department
witnin the next two months. In lieu of a formal agreement, tne issues
to be coverea in the agreement and the present policies that have oeen
informally agreed to are discussed below.
1. Lead Agency
• The fire department will be the leaa agency for all spill
response actions. This includes response actions to spills and
fires at Ill's facilities, spills in the community's streets, and
spills to the collection system.
• The IPD will be the support agency for all response actions for
spills to the' collection system.
• Coordination between the two agencies during any spill event
involving both the fire department and IPU is extremely
important. An agreement will be developed between doth agencies
to detail the responsibilities of each agency and any mutual
training efforts for personnel in spill response.
t All slug discharges of high-strength waste will be handled
strictly by the IPD.
2. Spill Coordinators - The primary and alternate spill response
coordinators (as well as other response personnel) for both the fire
department and IPD have been designated. Lists of these people and
their day and evening phone numbers have been exchanged between the
two agencies. During any spill event, the lead agency's spill
response coordinators will direct the spill response actions.
3. Responsibilities of Spill Response Coordinators - At a minimum, the
spill response coordinators will be responsible for:
t Evaluating the spill
• Assessing potential dangers
• Communication with response personnel
• Implementation of response actions to contain or mitigate the
dangers of the spill
• Cleanup and disposal of the spilled material.
Spill Event Investigation, Documentation, and Evi
spfll event, the IPD spill response coordinator v
for investigating and documenting the spill event. The results of
4. Spill Event Investigation, Documentation, and Evaluation - After a
spfll event, the IPD spill response coordinator will be responsible
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H/REG X-4a/#21
the investigation will be used to evaluate the IPD ASPP (and
response procedures of otner agencies) and determine if any
modifications are needed.
5. Exchange of Equipment - This issue has yet to be worked out.
6. Training of IPD Personnel and Response Drills - The IPD spill
response coorainators nave attended a training session he!a by the
fire department. In the near future, it is expected that a special
seminar and response drills will be initiated to train all IPD
response personnel.
Formal agreements witn otner response agencies and private contractors
will be developed as the IPD become more knowledgeable of spill response
and determines that additional assistance may be needed.
B. Detection and Notification of Spills and Slug Discharges That Have
or Couio enter the Sewer System
The IPD can detect or be notified of spills or slug discharges from
three sources: (1) an alarmed explosive and toxic solvent discharge
detection system; (2) notification by the ID responsible for the
discharge; (3) notification by another source such as police, fire
department, or witness at the spill site. These sources are discussed
below.
The PCSC is developing a monitoring system to detect explosive and toxic
organic materials in its collection system. The reason for developing
such a system is the PCSC has had problems in the past with discharges
of solvents and gasoline which have caused explosions, fires, worker
illness, and upsets at the plant. The monitoring system will most
likely consist of explosion and hydrocarbon detectors strategically
placed in the collection system at points just downstream from lUs or
groups of IUs which could potentially discharge sueh materials. These
detectors will be designed to activate alarms at preset danger levels.
The alarms will sound at the treatment plant control room and at any
pump stations downstream from the detector. In turn, personnel at the
treatment plant control room {which is staffed 24 hours per day) will
notify appropriate IPD response personnel. The purpose of the alarms at
downstream pump stations is to alert any personnel that may be working
in the pump stations.
As shown in the PCSC ordinance and control mechanism language (Section
II), all IDs are required to immediately not-ify the IPD of any acci-
dental spill or slug discharge of hazardous material or high strength
waste. In addition, fire and police departments and State and Federal
response agencies have been advised via a memorandum of understanding to
notify the IPD of any spills or other discharge which could enter the
sewerage system (See Section V.B Coordination of Spill Response).
If the IPD is the first to receive a call from a third party, the IU, or
other local agency, the IPO receptionist and other staff members nave
-13-
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H/RE6 X-4a/*21
Deer, ci rected to refer spill anc slug discnarye calls to the spill
resoonse coordinator or one of nis alternates, wnoever is on auty and
available. For after ousiness nours, the IPD telephone will be for-
warded to an answering service wnicn will notify the spill response
coordinator on-call at that time. Once the spill response coordinator
is notified, he will take whatever actions are necessary including
notifying other IPD personnel and other response agencies.
C. Evaluation ana Response to Spills and Slue Discharges
As indicated aoove, the fire department will be the lead agency
responsiole for spills outside tne collection system and will evaluate
the dangers of these spills and the best methods for responding to tne
spills. The IPD spill response coordinator will provide assistance in
this evaluation if the spill could enter the sewerage system. If the
spill or a slug discharge has already entered the sewerage system, the
IPO spill response coordinator will evaluate the spill and determine the
appropriate resoonse actions utilizing guidance contained in Section 3.4
of the ASPP guidance document.
[Normally, once the spilled material has entered the collection system,
it is difficult to contain the material. This is because the short time
it takes for some wastes discharged by an IU to reach the treatment
plant, and because stopping wastewater flow In the collection system may
increase the hazard or create a problem for all users upstream. These
circumstances make it difficult to do anything to respond to discharges
other than to mitigate the effects of the spill and prevent damage to
persons or the POTW system.]
Response to a spill or slug discharge, where timely detection or
notification has been made, will typically begin with notification of
personnel at the treatment plant and working in the collection system
(particularly pump stations). [Personnel should be notified that the
material has entered the system and that they must take any measures
that are necessary to minimize the danger to POTU personnel and users of
the POTW system and to prevent damage to the collection system or
treatment 'plant.] The volume, type, and toxicity/danger of a spill will
then be assessed by the lead agency and spill containment and counter-
measures can be implemented.
[There are certain measures a POTU can take to minimize the danger to
personnel or damage to the system. For example, response to a large
acid discharge would consist of flushing the sewers with water or adding
alkaline materials at the headwords or a point upstream of the plant to
reduce the effect of the acid. For response to a discharge of flammable
materials (e.g., gasoline) ventilation of the sewers both down and
upstream of the discharge point would reduce the chance of explosion or
fire.]
The IPD response personnel attend annual safety workshops held for all
PCSC treatment plant and collection system workers. These workshops
traditionally cover chemical and equipment hazards, proper safety
-14-
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G/REG X-4a/#21
oractices, protective clothing, respirators, explosive gas detectors,
and first aid. In addition, the last workshoo (and all future worx-
snops) addressed spill and slug discharge response hazards and safety
procedures.
D. Spill Containment and Countermeasures Options and Equipment
The fire department, designated as the leaa agency for responding to
spills outside the collection system, nas most of the equipment and
tecnnical exoertise necessary to contain and collect spilled materials.
The IPO can call on these capabilities wnenever necessary. In addition,
the IPO has the capapility of shutting down pump- stations to stop
wastewater flow at these points, if absolutely necessary. This option
will only be utilized where extremely hazardous substances have entered
the sewerage system and cannot be controlled any other way. In such a
case, discharges upstream would be stopped and the material just above
the pump station collected by vacuum truck and disposed of properly.
The IPD also has equipment to block small sewers such as those from IDs.
This equipment would be used to prevent the discharge of some of the
toxic wastewater. However, immediate notification by the fire depart-
ment or IU is needed to provide the IPD enough time to block the sewer.
If the material has not entered the sewer system or some portion has the
IPD will construct or used containment structure to reduce the discharge
into the sewer system.
The treatment or disposal method used for collected materials would be
dependent on the material.
• If the material is compatible with the treatment plant processes
in low concentrations, it could be bled into the plant.
• The spilled material may be able to be treated in the Ill's own
treatment system
t Outside waste treatment and disposal firms will be contacted to
handle all other materials.
Wherever feasible, we will utilize as a guidance options discussed in
Section 3.5 of the ASPP Guidance Document.(?)
E. Spill and Slug Discharges Event Investigaton and Documentation
Investigations of spill events affecting the PCSC are conducted by the
IPD spill response coordinator or his alternates. The procedures for
conducting these investigations cannot be written down in any detail but
will generally follow the procedures outlined below. The forms used to
document the spill event and investigation of the event will be those
contained in Appendix VII of the ASPP Guidance Document.
-15-
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G/RE3 X-4a/*21
Where'the source of the spill or slue discharge is Known, sucn as
the case of an IU reporting the Discharge, tnen tne spill
response coodinator will investigate tne reason for the dis-
charge, document the reasons, ana recommend actions necessary to
prevent future occurrences.
Where the source of the discharge is unknown, the spin control
coorainator will try to isolate the location in tne PC3C system
where it came from.
[A good method of tracking down the source of a slug discharge is to
identify the material discharged and then identify all the lUs upstream
from the point the material Mas detected that use the material.]
The IPD has acquired the data to develop the ability to investigate and
identify spill sources by cataloging information on industrial users by
the substances or classes of substances onsite and the location of all
Ills. A review of this information during a soil! event identifies a
list of potential sources wnicn can then be examined and investigated to
determine the specific source.
The IPD also has the ability to track the discharged material upstream
through the collection system and look for traces of the material. This
method will mainly be used for materials that have easily detectable
characteristics such as unusual color, odor, foaming, etc.
After the investigation is completed, the efforts are documented in the
final report of the incident. This report will then be used to evaluate
the IPD ASPP and determine if any modifications are needed (See Section
V.F below).
All sampling conducted during the spill response and investigations will
use proper chain-of-custody procedures to ensure the validity of the
data. The only exception to this will be when chain-of-custody pro-
cedures would slow down obtaining analytical results necessary to deter-
mine appropriate response actions. Analysis of any samples taken will
be done by the PCSC treatment plant lab or its contract laboratory. Both
labs use standard EPA approved analytical procedures.
f. ASPP Evaluation and Modification
The documentation of the spill or slug discharge event is reviewed and
evaluated to determine what actions are necessary to prevent future
occurrences and what modifications to the IU or POTW ASPP are necessary.
Such evaluations and modifications will be done on a case-by-case basis
and will generally follow these criteria:
• If the spill or slug discharge came from an IU without an ASPP,
then the IU will be required to develop and implement an ASPP
• If the discharge came from an ID with an ASPP, then the Ill's ASPP
must be modified to prevent a future occurrence
-16-
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G/REG X-4a/#Zl
• If an ID is required to develop an ASPP or modify tneir ASPP, me
ID will oe put on a compliance schedule to ensure that the
necessary actions are taken
0 If the discharge came from a source other than an IU, the event
will be studied to determine if anything can be done to prevent
or minimize future occurrences of such a discharge
• The IPO's ASPP may also need to be modified to incorporate any
administrative changes required to control the sources, or if
some elements of the response sections of the ASPP failec or were
inadequate.
In most cases where a spill or slug discharge required expenditure of
IPO resources or resulted in damages to the PCSC system, and the source
was identified, the costs for these resources and repair of the damages
will be recovered from the responsible parties. The IPD may also assess
monetary penalties where the responsible party was clearly negligent or
intentionally caused the spill or slug discharge.
VI. DATA MANAGEMENT
A. Prevention Component
Data management for the prevention component of the ASPP will be used to
record the ASPP category of all Ills controlled by the ASPP and track
implementation of ASPPs by Ills. Also included in the system w-ill be
inspection data related to IU ASPPs, documentation of any spills or slug
discharges, and any problems or modifications of the IU ASPPs.
Many of the IUs that are sources of spills and slug discharges are
included in the IPD Pretreatment Program data management system
(PPDMS).* This database will be expanded to include the additional ASPP
data for IUs already in the system and information concerning lUs
currently not in the system.
B. Response Component
There are two areas of data management needed for the response component
of the ASPP. These are: (1) data and documentation from spill events
and investigation of these events; and (2) data related to investigation
and response to spills and slug discharges.
The PPDMS utilizes a personal computer backed up by manual files and cross
reference indexes. Key data on IUs are stored in the system and can be
manipulated and retrieved in a variety of formats.
-17-
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G/REG X-4a/*21
A simple manual data management system will be useo to handle aata anc
aocumentation from spill events and tne Investigation of these events.
~ne system will consist of storage of the documentation in manual files
according to the type of incident and within each type of incident,
filed in alphabetical order by responsible party name. The type of
incidents classified in the file are the following:
• Industrial User Spills
* Industrial User Slue Discnarges
• Spills from Noninaustrial Users
« Slug Discharges Resulting from Fires, Explosions, or other
Disasters
• Tank Truck or Other Vehicle Spills
* Miscellaneous Incidents
• Discharaes from Unknown Sources
To aid investigation and response to spills and slug discharges, an
automated data management system will be developed. This system, dubbed
the Accident Response Data Management System (ARDMS), will store data on
the hazardous materials stored by each IU controlled under the ASPP and
the IU's location in the PCSC system. The system will allow retrieval
of all lUs upstream of the detection point that store a particular
hazardous material or type of hazardous material. This capability will
allow the IPO to quickly determine which IU or Ills could have been
responsible for the discharge.
VII. ASPP IMPLEMENTATION SCHEDULE AND RESOURCES
A. ASPP Implementation Schedule
The ASPP tasks that have yet to be completed are outlined below with
expected completion dates.
1. Submit ASPP Plan to EPA 11/01/85 (today]
2. Formalize coordination agreement with
fire department/other agencies (county,
State, Federal) 12/15/85
3. Identification of potential sources and
spill potential/submittal of list to EPA 12/30/85
4. List of users to be inspected 01/30/86
5. Complete notification of all lUs 02/30/86
-18-
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3/REG X-4a/*21
6. Complete aevelooment of data management
systems to handle ASPP requirements 05/15/86
7. All IU ASPPs due 05/30/86
8. Complete inspection and review of IU ASPPs 07/30/86
9. Complete installation of explosive ana toxic
solvent discharge detection system 07/30/86
10. All IDs ream'red to have ASPPs must nave
completed implementation of tneir ASPPs 08/30/86
B. POTW Resources
The IPD does not anticipate the need for a special increase in staff to
handle the additional ASPP requirements. [There will be an increased
work load in existing staff initially to develop the list of users
affected by the ASPP and to complete the activities discussed in the
schedule.] However, the IPD has been trying to increase its staff to
reduce the workloads of overburdened staff members and to better
implement the pretreatment program. The implementation of the ASPP may
amount to an increase of one half-time person spread out over the entire
IPD staff. This increase will be taken into consideration in deter-
mining present and future staffing requirements for the IPD.
As a result of implementation of the IPD's ASPP, certain types of
response and safety equipment must be acquired. Approximately $1,500
worth of this equipment has been purchased or ordered already. Addi-
tional equipment will be obtained as further development of the response
component of the ASPP demonstrates that additional equipment is needed.
One thousand dollars has been budgeted for additional ASPP related
equipment in the next operating year. This amount is exclusive of the
cost for the explosive and toxic solvent discharge detection system
which will come out of the collection system operations budget.
Funding for the small increase in staff and ASPP related equipment is
included in the IPD budget which is funded by revenues drawn from
industrial permit and user fees.
C. Outside Resources
As indicated in Section V.D, the fire department will be the lead agency
for response to spills outside the collection system and will provide
any requested assistance for response to spills and slug discharges in
the collection system. Additional outside resources will be obtained as
the IPD gains experience with implementing its ASPP and determines that
these resources are needed.
-19-
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D/X-4a/#i3
APPENDIX 2
40 CFR 117
DETERMINATION OF REPORTABLE QUANTITIES
FOR HAZARDOUS MATERIALS
This information is provided to assist the
POTW in evaluating the magnitude of hazard
associated with a variety of chemicals.
-------
Chapter I—environmental Protection Agency Part 117
PART 117—DETERMINATION OF RS-
PORTABLE QUANTITIES FOR HAZ-
ARDOUS SUBSTANCES
Subpart A—G«n«ral Previiiont
Sec.
117.1 Definitions.
11T.2 Abbreviations.
117.3 Determination of reportable quanti-
ties.
Subpart B— Applicability
117.11 General applicability.
117.12 Applicability to discharges from fa-
cilities with NPDES permits.
117.13 Applicability to discharges from
publicly owned treatment ivories and
tneir users.
-------
S 117.1
Pitie 40—Protection of Environment
oec.
HT.l-i Dernorj:r=.i:or. project.
suaoert C— Noiic» ot Di«horae o'. a
i«perrabt* Quantify
117.21 Notice.
117.22 Penalties.
117.22 Liabilities for removal.
A—HORITY: Sees. 311 and 50l. Feaeral
Water PoiJuuor, Control Ac: ;22 U.S.C. 1251
e: sec.;, ••"•tit Ac:"; ind Executive Oraer
SOURCE: -44 F?. 5C77£. Aug. 25. 1979, unJess
otnerwise noted.
Subpart A — General Provisions
§ 117. 1 Definitions.
As used in this part, all terms shall
have the meanings seated Ln 40 CFR
Par; 116.
taJ "Reportabie 'quantities" means
quantities that may be harmful as set
forth in § 117.3, the discharge of
which is a violation of section
311(b><3) and requires notice as set
forth in § 117.21.
(b) "Administrator" means the Ad-
ministrator of the Environmental Pro-.
tection Agency ("EPA").
"Navigable waters" means
"•waters of the United States, includ-
ing the territorial seas." This term in-
cludes:
(1) AH waters which are currently
used, were used in the past, or may be
susceptible to use in interstate or for-
eign commerce, including all waters
which are subject to the ebb and flow
of the tide:
(2) Interstate waters, including
interstate wetlands:
(2) All other waters such as in:ra-
state lakes, rivers, streams, (including
intermittent streams), mudflats, sand-
Hats, and wetlands, the use, degrada-
tion or destruction of which would
affect or could affect interstate or for-
eign commerce including any such
waters:
(i) Which are or could be used by
interstate or foreign travelers for rec-
reational or other purposes:
(ii) From which fish or shellfish are
or could be taken and sold in inter-
state or foreign commerce:
(iii) Which are used or could be used
for industrial purposes by industries in
interstate commerce;
(4) All impoundments of waters oth-
erwise defined as navigable waters
under this paragraph;
-------
Chapter I—Environmental Protection Agency
(5; Tributaries of waters identified
in .paragraphs ii) (1) through <4) of
this section, including adjacent wet-
lands; and
(6) Wetlands adjacent to waters
identified in paragraphs (i) (1)
through (5) of this section ("Wet-
lands" means those areas that are in-
undated or saturated by surface or
ground water at a frequency and dura-
tion sufficient to support, and that
under normal circumstances do sup-
port, a prevalence of vegetation typi-
cally adapted for life in saturated soil
conditions. Wetlands generally includ-
ed playa lakes, swamps, marshes, bogs.
and similar areas such as sloughs, prai-
rie potholes, wet meadows, prairie
river overflows, mudflats, and natural
ponds): Provided, That waste treat-
ment systems (other than cooling
ponds meeting the criteria of this
paragraph) are not waters of the
United States.
(j) "Process waste water" means any
water which, during manufacturing or
processing, comes into direct contact
with or results from the production or
use of any raw material, intermediate
product, finished product, byproduct.
or waste product.
§117.2 Abbreviations.
NPDES equals National Pollutant
Discharge Elimination System. RQ
equals reportable quantity.
§ 117.3 Determination of reportable quan-
tities.
The quantity listed with each sub-
stance in Table 117.3 is determined to
be the reportable quantity for that
substance.
TABU 117.3—RCTORTABLE QuAjrrixiES or
HAZARDOUS SCBSTAWCSS
NOTE The first number under the column
headed "RQ" is the reportadle quantity in
sounds. The number,in parenthesis is the
metric equivalent tn Kilograms. For conven-
ience, the table contains a column headed
•'Category" which lists the code letters "X".
"A". "B". "C" and "D" associated with re-
sortable quantities of i. 10. 100. 1000 and
pounds respectively.
ency
Maienai
Acataioenyae
Acetic acio
Acetic annyonoe
Acetone cvanonyonn
Acetyi oromioe
Acetyi cnionae
Acroietn
Acrywitnie
AOIDIC acid ...
AlCTin
AIIVI aiconoi .
Aiiyi cnionae
Aluminum sultatc
Ammonia
Ammonium acetate „
Ammonium oenzoaie „
Ammonium ftcaroonata _
Ammonium Oicnrornate
Ammonium oitiuonoe „..
Ammonium Bisulfite _. «...
Ammonium carBamata
Ammonium careonate ..__...__..._...
Ammonium cnionoe _......
Ammonium enromait _.. .......
Ammonium citrate ..............
Ammonium Huooorate
Ammonium ttuonoe „. „..
Ammonmm nyoronoe
Ammonium oxaiate
Ammonium swcottuonoe .___ — „.
Ammonium luitamate
Ammonium suifioe
Ammonium sulfite .„ '
Ammonmm tmnt»i» T ,„.,,., ...„..,„,
Ammonium mweyanatt .
Amyi acetate .......... _.
Annmony potassium tartrate ,
Antimony tn(JuQn3e/,,t,,,.,,,,,,,,,lt1i ,
Antimony tnonq*
Arsenic oisuihoe „-«.„_..
Arsenic oentoiioe .......
Arsenic mcnionae _._
Arsenic tnoiiae
Arsenic tnsuifioe..._
3anumevani8e
Benzene. _„.. .
Senznc aoe _..„ .
Benzormnie
Benzoyi cnionae
Benzyi cnionae..
Berywium sntonoe
Beryllium fiuonoe „
Beryllium nitrate ,
Butyl acetate
n-8utyi ontnaiete .
Butyiarmne .._.
Butyric acic
Caomnjm acetate
Caomium oromioe
Caomium cnionoe
Caicium arsenate
Caicum arsenite
Calcium caroiae
Caicnjm cnrcmate
Ciicium cvanioe
Caioum aoaecyioennneswJicn-
•te.
§ 117.3
Cateeo- SC i" BOU.IOS
£ * 000 f454l
0 5 000 (2 273)
0 S 000 (2 ^7")
X 1 (0 454)
3 5 000 (2270)
3 tOO 14* 4)
C i MO f454i
0 5 000 i2273)
3 tOO <4S 4i
C 5.000 (2.270)
0 5 000 (2 272)
D 5.000 (2.270)
C 1.000(454)
D 5.000 (2.270)
0 5.000 (2.270)
0 S.OOO (2.273)
0 S.OOO (2.273)
D J.OOO (2.273)
C ', 000 145*1
D 5.000 (2.2-3)
0 S.OOO 12.273)
0 5.000 (2.270)
C 1.000(454)
0 S.OOO (2.270)
C 1.300 1.454)
0 S.OOO (2^70)
D S.OOO (2.270)
0 5 000 (1270)
0 5.000(2.270)
0 5.000 (1^270)
0 5.000 (2.270)
C 1.000 (454)
C 1.000 («S4)
C 1.000 (454)
C 1.000 (454)
C 1.000 (454)
C 1.000(454)
C 1.000 (454)
05 000 (2 270)
0 5.000 (2.275)
0 S.OOO (2.270)
D S.OOO (2.270)
0 5.000 (2.273)
3 5.000 (2.270)
A 10 14 54)
C 1.000(454)
0 5.000 (2.273)
C 1 .000 (454)
C 1.000(454)
9 100 MS 4)
0 S.OOO (2.273)
0 S.OOO (2.270)
0 S.OOO (2.270)
0 S.OOO (2.27C)
3 100 i«S 4)
C 1 000 (454)
0 S.S30 '2.273)
3 100 (45 4i
3 100 (45 4t
a 100 us 4i
C 1.500 i454>
C i.COO i4Sit
0 S.COO (2..""t)
A 10(45-'
C '. 300.454!
-------
S 117.3
Title 40—Protection of environment
va.era.
Cretan •
Ccoaitous tuitamate
C«.pf c acnatc
Cjsnc $u*(«i« ammofuat«a ;
Cvctorwnna — ^......«........— .— .i
2 4_0 Acid .-. ,..,-,,r-,-:
J 4-0 S*1»n lt,,,j,...,,--,,r 1
C'aiinon ,............._._......._...............;
Oicft'OOinii , ± 4............... ..._.„..„.„„.. i
2>cniorooa !
Dicnioroorooan* Minura. !
2.2-OicnioraorooiorMc acia
^:C.110fVO* „._..... ........
vi4tnviamin« ........ _..„..............._„...„'
>nitrooanzana
oln^lo^' """":
jiauat
Disuitoton
Cooteyte«nztn««ui>onie aoc
Jioosuiian
^nonn ........ .,. ,.,. ,
sinion _
" "wiafiaaiamina
£rnyi«nt oiof omioa
B3TA
••me ammonium eivata
s^tne ammonium oxaiaia
•vrtc cftiorida
-tmc fluorioa
••me miraia
-«"ou» ammonium juitata
Caieoo-
3
A
z
A
0
X
A
5
0
x
r
~
i-
r
c
c
c
c
A
c
3
3
A
9
A
B
B
A
C
B
X
X
c
c
X
3
0
D
A
X
c
c
c
c
c
x
g
C
x
x
c
A
c
o
o
c
c
g
c
c
C
5C m aounas
100 '45 4)
10 14 54|
1 CO 145 4)
10 (4 54)
5.000 (2.270)
£.000 (2.270)
1 (0 454)
10 14 54)
ICO 145 4)
5 OOC 12.2701
• (0.464)
l 000 (454)
1 000 I4S4)
VOOO (454)
i.OOO (454)
VOQO (454)
VOOO (454)
1.000 1454)
1.000 (454)
10 (4.54)
1.000 (454)
100 (45.4)
100 145 4)
100 (45 4)
10 (4.54)
100 (45.4)
100 (45 4)
10 (4.54)
100 (45.4)
100 (45.4)
10 (4.54)
1.000(454)
100 (45.4)
100 (45.4)
1 (0.454)
1 (0.454)
1.000 (454)
1.000(454)
1 (0.454)
100 (45.4)
5.000 (2.270)
50OO 19 27O1
5.000 (2.270)
5.000 (2,270)
10 (4.54)
1 (0.454)
1.000 (454)
1.000 (454)
1.000 (454)
1.000 (454)
1 000 (454)
1 000 (454)
1 (Q 454)
100 (454)
1.000 (454)
1 (0 454)
1 (0 454)
t 000 (454)
10 (4 54)
i 000 1454)
t nnn /444t
1 000 (454)
5 000 (2 270)
5 000 (2 270)
1 000 (454)
i 000 (454)
1 000 (454)
100 (45 4)
i 000 (454)
1 000 (454)
1.000 (454)
MiW,,,
-«rrous SL'i'aie
Pormic aea
Pumane aao.
Guinion
««otaenior
"voroenionc acic
•waroriuo'tc acs
"vorogen cvaniae
Hvorog»n soitiae
iscsrcsirioiimine oocecviMiv
tcncftuitonaw. i
KMOOn* ........... .._
Laafl aetiatt ..
Ltao ar«*nai«
Lead cflionot i
Laad fluoooratt
Laad ftuonoc . ,..„.
taad nitrata -
^aac staarata
Laa0 su'^'Of .....
Laao tniocyanaia ..«. ^.........»« ,
U.noaAa
Litnium cnromata ..H»..«w....._......-4
Maiatc led. ...t.«u........ —• !
Mawc •nnyonoc .n..,,,,,,'!
MafcaotootfRatrtuf ....»..».«••.. .«•••.•-•)
Marcunc nttraia ..........«.^««w^«^««^.i
fuarcuflc suitata.M .. ..«......•.«».•-.....!
Marcufic tHiocyanata ...*.»*M»«....»...J
MafCUTOUa Ollrala jjiii.tumT.nm.-mii-'
Mttnoxyenior \
Matftyt matnacrytata ........ MM...........
Matnyi oaraw*on ,,«,...........~...........i
Monoatnyiamm* ;
N
Nicxai ammonium sutfata ..._„ :
Ntcnat mtratB
Nitrootnztna :
Nitrog*n oioiioa _..:
Nurotoiuana
Paratormaioaoyoa
otmacnioroonanoi - „.;
PioaoeiH i
P^osonofic aao
Pnosonprus otntasuiiiaa
Piospno'us tncmonoa
Poiycmonnatafl Oionanyii
Z^-
~
x
*
A
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C
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0
0
0
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p»
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-------
Chapter i—Environmental Protection Agency
§ 117.11
Material
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dtrontium crvomata .......»M«.«......»...f
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2. 4. 5-T »its ..„_.. _i
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TncnioraamwMna
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-------
S 117.12
Title 40—Protection of Environment
permit conditions ;ssuec pursuant to
section 3005 of the Resource Conserva-
tion ana Recover-.- Act v90 Stai. 2T95:
42 U.S.C. 5901):
(e) In compliance with instructions
of the On-Scene Coordinator pursuant
to 40 CFR 1510 (the National Oil and
Hazardous Substances Pollution Plan)
or 33 CFP. 153.10(e) (Pollution by Oil
and Hazardous Substances) or in ac-
coraance w;th applicable removal reg-
ulations as required by section
311UXIXAJ:
(f) In compliance with a permit
issued under § 155.7 of Title 14 of the
State of California Administrative
Code;
(g) From a properly functioning
inert gas system when used to provide
inert gas to the cargo tanks of a vessel:
(h) rrom a permitted source and are
excluded by § 117.12 of this regulation:
(i) To a POTW and are specifically
excluded or reserved in § 117.13: or
(j) In compliance with a permit
issued under section 404(a) of the
Clean Water Act or when the dis-
charges are exempt from such require-
ments by section 404(f) or 404(r) of
the Act (33 U.S.C. 1344(a).
-------
C/Rey. X-4/#2
laentl fl cafi on of Potential Spill and Slue Discharge Sites and patnways
The Industrial facility snould induce in its ASPP plan a description of
all potential spill sites at the facility. As many such sites may exist
within an industrial facility, it is recommended that the sites be broken down
into the following three categories:
• Vicinity of chemical storage, transfer, or transport areas and
equipment
• Vicinity of chemical processing equipment
• Vicinity of pumps, valves, and other fluid flow equipment.
Chemical storage areas consist of tanks, drums, bags, or other containers in
which are stored either tne raw materials or the products of the industrial
process. The inaustry should provide in its ASPP plan an inventory of the
chemicals stored in these containers, as well as provide information on the
location and storage capacities for each of these chemicals. In addition, the
industry should identify the transport and transfer areas for these chemicals
throughout the plant. Specifically, the ASPP plan should indicate the
following:
• Whether above-ground storage and process tanks are open-topped or
closed
• Whether below-ground tanks are cathodically protected
• The period of storage for all drummed and bagged chemicals
t Whether storage or process units, as well as valves and pumps, are
currently showing signs of wear (e.g., rusty drums, torn bags, leaky
valves etc.)
• An industrial facility diagram indicating a process flow schematic,
all points, and the probable direction of flow of spilled material
• The location of secondary containment for storage, transfer, and
transport areas.
The industrial facility should describe the condition of the containers
and transfer equipment and .make an independent assessment of the spill
potential and possible effects at each industry.
-1-
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C/Reg. X-4/#2
Tne industrial-facility should also describe in its ASPP plan all
cnemical processing equipment anc tne cnemical contents of tnis equipment.
Chemical processing equipment includes, but is not limited to, the following:
• Chemical reaction vessels
• Plating/pickling batns
• Distillation vessels
• Extraction equipment/separators
• Condensers
• Evaporators
• Scrubbers.
In particular, the industrial facility should indicate what materials are
pumped in and out of each piece of process equipment, as well as what
catalysts and/or other material may be permanently stored in these vessels.
The industrial facility should also indicate whether chemical processing is
performed on a continuous, batch, or intermittent basis. The facility should
describe in general terms its manufacturing process and the potential that
exists for its process to result in accidental spills or slug discharges of
high-strength wastes. This should include identification of the locations of
major pumps and valves, as well as other potential process line "weak spots,"
such as major piping connections, rotometers, manometers, sight tubes, etc.
Existing and Proposed Spill Prevention Equipment
This section of the ASPP should describe all existing spill prevention
equipment that the industry has in place or plans to obtain for implementation
of the ASPP. Whether the equipment is existing or needs to be purchased
should be indicated in the listing.
Equipment required to control spills falls into two categories, equipment
to prevent spills and equipment to contain spills. The industry ASPP plan
should describe current and proposed inventories of both equipment types.
Equipment to prevent spills consists of appropriately selected chemical stor-
age and process equipment, as well as built-in safeguards to prevent chemicals
from being spilled. Spill containment equipment consists of apparatus
-2-
-------
C/Reg. X-4,'?2
availaole to
-------
C/Reg. X-4/#2
The ASP? plan snoula alscuss tne industrial facility's status in regara to tne
following S3"; 11 prevention equipment requi rements :
t All chemical storage vessels, as well as all process vessels and
fittings (pumps, valves, piping) must be constructed of material
compatible with the Chemicals oassing through them. In particular,
tanKS ana arums used to store corrosive cnemicals should be con-
structed of stainless steel or of a corrosion resistant plastic. Any
Dumcs or valves useo to process these chemicals must oossess
corrosion-resistant seals ano sackings. Similarly, pumps or valves
tnrougn wnicn organic chemicals pass must contain seals and pacnngs
whicn are dissolution-resistant. The industry should indicate in its
ASPP equipment inventory, wnere applicable, tnat appropriate materials
of construction nave been used, and are compatible with the cnemicals
being processed.
t Foundations and supports of large storage tanks, process vessels, and
piping must also meet comoatability and integrity reduirements. All
above ground vessels snouid be protected from venicular aaroage throuyn
tne use of truck guards. Underground vessels and pipes snouid be well
marked and weight limits placed on roadways tnat may cross these
underground vessels. All underground vessels snouid oe cathodically
protected to prevent damage due to corrosion. Underground piping
should be double-walled at vehicle crossings.
• Open storage and process tanks should be equipped with liquid level
control devices, and, where necessary, grounding apparatus. In
addition, overflow alarms should be installed to warn personnel of
tank overfilling events. Similarly, temperature and pressure alarms
should be installed on closed chemical processing equipment, to alert
industry personnel to runaway reactions or other factors resulting in
excessive temperatures and pressures. Such extreme conditions can
otherwise result in the automatic opening of relief valves, with the
subsequently spilling of the process vessel's contents.
• Proper drum handling equipment should be made readily available. The
practice of scooping drums with the forks of a forktruck must be
eliminated. Pallets should be used to aid handling and inspection.
Oil dispensing racks should be provided with drip pans.
• Loading/unloading pump station controls must be secured in a manner to
prevent the pumps from being turned on by unauthorized personnel.
Warning signs of physical obstructions such as crossing gates should
be used to prevent trucks from driving away while the loading hose is
connected.
• All contact and noncontact cooling water cross connections should be
eliminated. All unnecessary floor drains should be plugged.
• Many facilities face the potential of spills into plant stormwater or
sewer systems. Automatic stormwater and/or sewer sampling systems can
-4-
-------
C/Reg. X-4/#2
be utilized to monitor for spills. These sampling systems can be tied
ntc automatic snutor devices tnat wi . : prohibit discnarge
lant effiuent system.
Once spill potential reduction measures have been addressed, secondary
containment systems should be considered. A manufacturing facility which has
the potential for a spill or slug discharges should provide secondary con-
tainment systems, wnerever possible, tnat will control the spread of a soil;
of toxic wastes or slug discharges of high-strength wastes at or near a
potential spill source (e.g., storage tanks, processing equipment and piping).
Secondary containment systems which fail to function under rainstorm con-
ditions are considered to be inadequate. There exist several forms of
secondary containment systems:
0 Diking is the most effective form of secondary containment for bulk
chemical storaye. Dikes can be constructed from concrete, cinder
blocks, or earth. Bulk storaye tanks and/or drum storage should be
surrounded with an impervious dike that will hydrostatically contain
110% of the capacity of the largest tank or the capacity of the
largest tank plus water from a maximum 24 hour/10 year rainfall event,
whichever is greater. Drainage of accumulated rainwater from a diked
area should, be accomplished with a manually operated pump or siphon
system. In the event a valved pipe has been installed through the
dike wall, the drainage valve must be kept locked in the closed
position when not in use. Flapper valves must not be utilized.
Design of the dike should account for the containment of a spraying
leak from the side of the tank. Where this design is not feasible,
baffles could be installed at the top of the dike that would deflect
potential leaks and cause them to drop within the containment area.
• Diversion of flow of potentially spilled material away from its
naturally expected path can also be an effective means of secondary
containment. Diversionary structures consists of curbs, sumps, and/or
gutters which divert spilled material downgradient to a collection
tank. These structures should be used in areas where diking is
impractical or unsafe. For example, chemicals which emit noxious
fumes might be diverted to a closed tank in the event of a spill,
rather than left in an open diked area. Diversionary structures can
include quench tanks, which serve to simultaneously collect and treat
chemicals. Many industrial facilities possess process quench tanks to
control runaway chemical reactions.
• A quick drainage system is frequently employed in small volume storage
and loading areas. It consists of an impervious curbed or below
gradient pad that slopes into a drain that is connected to an imper-
vious sump. Spilled volumes of oil are collected in the impervious
sump and then removed and appropriately treated, discharged, or
disposed.
-5-
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C/Reg. X-4/«2
FinaMy, collection and recycle or c^sooscl of spilled rnateria1 or nign-
strenytn wastes is an "important step in a soil! response anc may require a
great aeal of time and manpower. Equipment required for tne cleanup of spill
varies and depends upon tne nature of the material spilled, volume spilled,
location of spill, and ultimate destination of spilled materials. Equipment
and materials that should oe made readily available for clean up of spills
include Dooms, surface or collecting agents, absorbent materials, skimmers and
oil/water separators and/or otner equipment that may be necessary depending
upon the types of spills that may be anticipated from the analyses described
above.
Spill Prevention Procedures
Equally important as the selection and installation of spill prevention
and containment equipment is tne implementation of spill prevention procedures
by industry employees. Such procedures consist of inspection and maintenance
practices, many of which should be already implemented by industrial facili-
ties as process control and product conservation measures. A list of spill
prevention procedures is presented below:
Tanks
Filling-overfilling practices
Sampling
Cleaning
Integrity testing
Inspections
Drums
Transfer of chemicals practices
Inspection of storage areas
Pipes, Valves, Fittings, Pumps, Electrical and Mechanical Equipment
Maintenance
Inspections
Chemical Disposal Practices
Security
Fence
Locked gates during off hours
Lock closing of tank outlets
Post warning signs
-6-
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C/Reg. X-4/#2
Dnor to filling a tank, Industry personnel snail inquire as to trie
tanx's previous contents, to ensure tnat incompatio'ie liquids anc/or vapors
will not be mixea as a result. In any event, temperature pressure and/or flow
meters should be constantly monitored througnout the filling process.
Whenever tanks are being filled, nersonnel should be monitoring fluid level
witnin the tan* to ensure tnat tanks are not overfilled. TanKS should be
periodically cleaned, ana tne contents of storage tanns periodically sampled
to ensure that chemical transformations nave not occurred. TanKs snouid oe
inspected for signs of wear and deterioration on a periodic oasis.
Drum handling procedures should be established, aimed at preventing
spillage of drum contents during fluid transfer operations. Ml drums and
drum storage areas should be periodically inspected for signs of drum wear
and/or leakage.
Pipes, valves, pumps, and other mechanical equipment and fittings should
be periodically inspected for leakage. A routine maintenance program snouid
be established for this equipment; all additions or alterations to the system
should be addressed in the ASPP.
A spill should not be the result of employee ignorance or negligence.
This can be critical in the disposal of chemicals. Signs should be posted to
indicate the proper way to transfer chemicals, and dispose of process wastes.
In particular signs indicating that wastes not be discharged to a drain are
very useful to prevent an absent-minded spill or slug discharge. Sealing all
unnecessary floor drains will also minimize this problem.
The industrial facility should exercise security measures to ensure that
spills do not result from vandalism or other intrusion. The industrial
facility's grounds, especially storage tank areas, should be fenced, and the
fences should always be locked at night. All outdoor valves should similarly
be locked shut at night.
Most of these procedures are simple common-sense procedures. The
industrial facility should detail in its ASPP plan its status in regard to the
-7-
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C/Reg. X-4/?p2
aoove requirements. In addition, the Industrial facility shoula include in
its ASPD plan a description of all spill response training programs requires
of its employees. Personnel should be periodically trained in the following
areas:
• Operation and maintenance practices specifically designed to prevent
ana control spills and slug discharges
• Applicable pollution control laws
• Current plant policies regarding spill prevention and slug discharges
• Plant spill and slug discharge response procedures (actions to be
taken, names and phone numbers of POTW and fire department personnel
to be contacted).
In general the potential for spills ana sluy discharges will neea to oe
evaluated and engineering changes may need to be made. These changes will
need to focus on the reduction of spill potential and minimization of the
damages if a spill does occur; particularly if it reaches the POTW collection
system.
Existing and Proposed Spill Response Procedures
Despite the implementation of spill preventive measures a spill may still
occur. To mitigate the damage resulting from a spill the industrial facility
will need to have a spill response program. The industrial facility should
detail in its ASPP plan its existing spill response program and any currently
proposed modifications to it. Spill response techniques required will very
greatly, depending on the nature, amount, and/or location of the material
spilled. However, all spill response activities can be grouped into the
following categories:
• Safety measures
t Acquision of assistance/notification
• Spill containment/diversion/isolation.
The above described activities must be carried out by industry spill response
personnel, and carried out in the order shown. If adequate spill prevention
-8-
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C/Reg. X-4/S2
and control measures have been taken, emergency spill control may not be
necessary; therefore, although spill control is of great imoortance, safety
and notification can be addressed first.
Safety Measures
The safety of industry personnel, and the community, is of paramount
importance at tne time of any cnemical spill. The threat of a spill to numan
health depends upon the nature, quantity, and location of the material
spilled. Under OSHA requirements, many industrial and commercial facilities
are already well versed on safety consideration in the work place. Although
every spill or slug discharge is unique, and no substitute exists for sound,
professional onsite assessments, certain general safety considerations can be
delineated:
• Personnel should De evacuated from areas where flammable, explosive,
reactive, or noxious/fuming (e.g., in unventilated areas) chemicals
have been spilled in large quantities.
t All heated or flame-producing apparatus in the vicinity of a spill of
flammable material should be immediately shutdown and/or cooled.
Exposed steam lines within such an area should be valved off.
Obviously* personnel should be prevented from creating any flame or
spark Within such an area.
• Incompatible materials stored within the vicinity of a spill must be
moved. Bagged bases, such as bicarbonate or lime, for example, must
be moved from the scene of an acid spill. With proper supervision and
certain precautions, these can be used to neutralize spilled acids.
Reductant chemicals should similarly be moved from the scene of an
oxidant spill. (Such measures should be taken only when the safety of
industry personnel performing the ta'sks is assured).
• Breathing apparatus should be immediately provided to all personnel in
the vicinity of a spill of noxious/fuming chemicals. Frequently, such
chemicals are also corrosive oxidants, consequently oxidation-
resistant clothing will also be essential.
0 Spill response personnel should carefully weigh each spill response
action in terms of safety; sometimes incorrect response activities do
much more harm then good. For example, fans may not be a good choice
of equipment for ventilating noxious fumes; if the fumes are flammable
or explosive, the fan's electrical motor could spark a fire or
explosion. Caution must be the watchword.
-9-
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C/Reg. X-^/=2
Acquisition of Assistance
Immediately upon insuring the safety of industry personnel on site,
through evacuation ana/or other precautions, the industry spill response
coordinator snould contact the POTW and fire department (it may oe also
required that the industry contact the county, State, Federal agency
responsible for emergency response]. These local agencies can provide
assistance in spill response and onsite cleanup coordination. In the case of
fire and/or explosion, the fire department should provide the expertise in
remedial actions. It is important to note that this call is also a safety
measure. A quick assessment of the severity of tne spill will dictate the
need to call the POTW or the Fire Department before official notification of
otner concerned agencies. It is best, and recommended to develop an under-
standing with these agencies in advance through a written response plan.
The industry snould obtain the names and phone numbers of appropriate
spill response personnel within both local agencies. These names and phone
numbers should be distributed and conspicuously posted throughout the plant.
As discussed under notification procedures, the POTW should be providing the
notification procedures to the industry.
Spi11 Contai nment/Di versi on/Isolati on
The highest priority in immediate spill response activities, next to
safety, is in spill isolation. Clearly, the first spill response step should
be to stop the flow of material being spilled, if possible. This activity
consists of shutting valves and/or stopping pumps from further feeding
chemicals to the vessel generating the spill. Generally, the size of a spill
can be limited to a single tank volume or less if prompt action is taken in
this regard.
Containment diversion activities depend upon the nature of the material
spilled. If appropriate safeguards, such as dikes and other secondary
containment vessels have been installed, industrial response requirements at
the site of a spill may be minimal. If the spilled material does not pose an
immediate safety hazard (e.g., flammble, explosive, reactive, noxious) and
spill containment equipment such as booms, barriers, sweeps, aborsorbents etc,
-------
C'/Reg. X-4/r2
are availaole, tne industry personnel snould commence trie cleanup activities
vntn tnis equipment.
Follow-up Reporting and Documentation Procedures
The industrial facility should also describe in its ASPP plan its
follow-up reporting and documentation procedures after a chemical spill or
slug discharge. Two major questions must be aadressed in such documentation:
t What caused the incident or and now can it be avoided in the future?
• How effective were response and cleanup activities and .how can
response procedures be improved as a result?
The industrial facility should conduct an internal investigation to
ascertain what sequence of events led to the incident. Two factors contribute
to the occurrence of most events:
• Improper process operations
• Insufficient inspection and maintenance programs.
A myriad of human errors in process operations can result 1n chemical
spills and slug discharges: accidential overfilling of open tanks, failure to
control reactor conditions and flow rates, inadvertent locking shut of high
pressure lines during process operation, hosing down material into floor
drains, etc. Logically, the industry investigator should begin by questioning
the individuals responsible for operating the equipment from which the spill
or slug oriyinated. The investigator should base his determination of the
cause of the incident upon the evidence provided by the process equipment, the
explanations of the plant personnel, and his own professional judgment. In
interpreting the information provided him by, pi ant operators, the investigator
should bear in mind that spills can be.caused by instrumentation error/
malfunction as well as operator neglect.
Poorly maintained process and storage equipment frequently results in
spills and slug discharges. The investigator should note in his report all
-11-
-------
:, kec.
details concerning the condition of tne eauipment from whicn the chemical
spilled. In particular, tne investigator should note tne following:
• Tanks - conditions of welded seams
• Drums - depth of rust, deterioration
• Pumas, valves - condition of seals, Decking
• Spill preventive equipment - availaoility, appropriateness, conaition.
The industrial facility should also report on the adequacy of its
response procedures. In particular, the investigator's reports should address
the following questions:
• Was the safety of industry personnel and the surrounding community
insured throughout the incident?
• Were personnel working close to the incident provided adequate access
to breathing apparatus, protective clothing, etc.?
t Was the spill confined quickly?
• Was fire extinguishing equipment adequate and readily available when
needed?
• Did secondary containment structures remain intact throughout the
spill response? Were these structures of adquate volume to confine
the spill or slug discharge?
• Were appropriate POTW and fire department officials immediately
notified of the incident?
Upon completion of the above-described investigation, improved opera-
tional, inspection, maintenance, and/or spill response procedures should
become evident to the industry investigator. He should detail these recommen-
dations in his report. The investigation report should then be made available
to the POTW, fire department, and insurance firms if applicable, to assist
these agencies in thier own investigations.
-------
APPENDIX 4
EXAMPLE FORMAT FOR AN IU ASPP
The information provided in an IU ASPP
snould meet all of the specifications
addressed in Section 2.3 and
Appendix 3 of this manual.
-------
EXAMPLE FORMAT FOR AN III ASPP DLAN
ACCIDENTAL SPILL PREVENTION PROGRAM
I. GENERAL INFORMATION
"acillty Name
Address
ASPP Plan contact Title
Work pnone no. After hours phone no.
Emergency response contact Title
Work pnone no. After hours phone no.
Secondary contact Title
Work phone no. ; After hours phone no.
Type of Business/Manufacturer
Operating Schedule
Number of employees: 1st shift 2nd shift 3rd shift __
Average daily discharge of wastewater (Identify continuous and batch
discharges):
Identify all categorical pretreatment standards applicable to your facility;
Description of previous spill' events and remedial measures taken to prevent
their reoccurrence
Description of security provisions and warning signs at the facility:
-1-
-------
II. "ACILI'Y LAYOUT AND FLOW DIAGRAMS
Attach drawings (suggested no larger than 36" x 50") of the facility which
show the following:
• General layout of the facility
• Property boundaries
• Entrance and exit routes to facility
• Areas occupied by manufacturing or commercial activities
• Hazardous materials process and storage areas
• Waste handling, storage, and treatment facilities
t Loading and unloading areas
• Direction of drainage from hazardous material and waste handling,
process, storage, and treatment areas
• Floor drains, pipes, and channels which lead away from potential leak
or spill"areas [identify by coding, footnotes, or narratives where
these drain to (e.g., sanitary sewer, holding tank pumped out by •
hazardous waste hauler, etc.)].
t Flow diagram(s) showing chemical and wastewater flow including piping
and instrumentation, flow rates, tanks and capacities, treatment
systems and final destinations of flows.
Please provide narrative discussions where needed to clarify any of the above
items.
-2-
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D/UEG. X-4a/ffl5
111. HAZARDOUS MATERIAL DATA
Hazardous
Material
Location
in Plant
Maximum
Volume
Container
Volume
Type j
Container
Remarks'
i
Cvl
I
*The facility should provide information on the type of container or tank used (e.g., steel drum, fiberglass carboy,
etc.) and the materials of construction of the container or tank.
2Remarks should include comments concerning the toxicity or hazards associated with the hazardous material and any
special precautions needed to handle the material properly. The remarks should also include brief discussions of Hie
compatibility of the materials of construction of the container or tank with ils contents, the condition of tho
container, and whether it is open or closed top.
-------
F/X-4a/#6
IV. SPILL AND LEAK PREVENTION EQUIPMENT AND PROCEDURES
Equipment
Identify the location and provide a description of all spill prevention
structures and equipment employed (such as dikes, berms, sealed drains,
alarms, leak detection equipment at the facility, diversionary structures,
etc.). Reference to the location should be made with the layout drawings
requireo in the previous section.
Procedures
Discuss all routine operation and maintenance procedures geared to minimize
spills and leaks at the facility. Include descriptions of the type and
frequency of inspections and monitoring for leaks or other conditions that
could lead to spills.
V. EMERGENCY RESPONSE EQUIPMENT AND PROCEDURES
Equipment
Provide an up-to-date list of available emergency response equipment including
its location (the location can be indicated on a facility layout) and a
physical description. This list of equipment should include the following:
• Communication equipment and alarms
• Spill containment and control equipment and tools
• Spilled material storage containers
t Protective clothing and respirators
-4-
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t Decontamination equipment
• Ventilation equipment.
procedures
Provide a derailed description of procedures to be followed in responding to a
spill at the facility. This description should cover the following items:
• Notification of facility personnel responsible for responding to
spills
• Chain of command for spill response
• Evacuation procedures
• Notification of response agencies and contractors
0 Spill assessment and response procedures
• Procedures for preventing contact between incompatible materials
t Procedures for disposing or treating spilled materials.
VI. SPILL REPORTING AND ASPP MODIFICATION PROCEDURES
Describe procedures for reporting spills (attach any. forms used) and for
modifying the ASPP Plan where procedures were inadequate or where changes at
the facility warrant modification.
VII. TRAINING PROGRAM
Outline, in detail, the training program given to employees which will enable
them to understand the processes and materials with which they are working,
the safety and health hazards, and the procedures and practices for preventing
and responding to spills. A discussion of the appropriateness of training
provided to each employee or group of employees (e.g. chemical handling
personnel, plating department supervisor, etc.) should also be included.
-5-
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ICA'IONS
I certify that the information provided in this document is to the best of my
knowledge true and tnat the accidental spill prevention measures described in
the document will be imolementeo as described.
Name; ;it i e Date
, an authorized representative of
the industry responsible for the
ASPP)
I certify that the spill prevention and control equipment installed by the
industry will provide adequate protection from accidental spills when used
properly.
Name P.E. Registration Number Date
-6-
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G/X-4a/*13
APPENDIX 5
INDUSTRIAL ASPP PLAN REVIEW CHECKLIST FOR POTWs
-------
3/X-4a/«16
IU ASPP PLAN REVIEW CHECKLIS'
The IU ASPP should be evaluated using the following requirements criteria and
checking the appropriate column. A check in the "S" Column means the ASPP
Plan satisfactorily meets the retirements; "IT means the Plan unsatisfactori-
ly meets tne requirements; "A" means that additional information is neeaec tc
determine if the reauirement is being met; and N/A means the reauirement is
not aDPiicaole to tne facility. The reviewer snouid use Dest engineering
judgement in determining :he aaeauateness of the 3lan in meeting eacn
reauirement. Comments should be provided as appropriate.
U
General Information
Facility Name, Address, Contacts and
Phone Numbers
*ype of Business, Operating Schedule,
Number of Employees
Daily Wastewater Discharge Flow Rates(s)
Applicable Categorical Standards
Previous Spill Events
Security and Warning Signs
Comments:
II. Facility Layout and Flow Diagrams
General Layout of Facility Showing:
Property Boundaries
Entrance and Exit Routes
Manufacturing Areas
Hazardous Materials Process
Waste Handling, Storage and
Facilities
Loading and Unloading Areas
Drainage Direction,
Floor Drains, Pipes, and Channels
Drainage Destinations
Flow Diagram(s) Showing:
Piping and Instrumentation
Flow Rates
Tanks and Capacities
Treatment Systems
Final Destinations of Flows
Comments:
& Storage Areas
Treatment
and
-1-
-------
Hazardous Materials Data
Hazardous Materials
Location
Maximum Vol uine
Ccnta"! ne" l/ol ume
~yoe Container
Comments:
IV. Spill and Leak Prevention Equipment
and Procedures
Adequate Equipment in the Following Areas:
Storage
Loading/Unloading
Process
Treatment
Other Areas:
Comments:
Adequate Procedures Including the Following:
Inspections and Maintenance of
Containers and Tanks
Inspections and Maintenance of Spill
Prevention and Response Equipment
Inspections of Storage, Process, Loading
and Unloading Areas
Proper Label ing
Other Procedures Needed:
Comments:
-2-
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5/X-A a/* 16
V. Emergency Resoonse Equipment and Procedures
Availability of the Following Equipment:
Communication Equipment and Alarms
Spill Containment and Control Equipment
and Tools
Spilled Mats-ial Storage Containers
Protective Clothing
Respirators
First Aid Kits
Decontamination Equipment
Ventilation Equipment
Other Equipment Needed:
Comments;
Adequate Procedures Including the Following:
Notification of Responsible Facility
Personnel
Chain of Command for Spill Response
Safety and First Aid Procedures
Evacuation Procedures
Notification of Outside Assistance
Spill Assessment Procedures
Spill Containment Procedures
Spill Cleanup Procedures
Decontamination Procedures
Procedures for Preventing Contact Between
Incompatible Materials
Procedures for Disposing or Treating
Spilled Materials
Other Procedures Needed:
Comments:
-3-
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VI. Spill Reporting and ASPP Modification
Procedures
Spi": Reporting Procecurss
AS?D Modification Procedures
Comments:
VII. Training Program
Detailed Outline of Training Program
Training Aporopriate to Job Description
Hazards of Chemicals LJsea at the Facility
Emergency Response Training
Comments:
VIII. Certifications
Facility Representative Certification
Professional Engineer Certification
Comments:
General Comments and Follow-up Actions Needed:
Reviewed by:
Date:
(POTW Reviewer;
-4-
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D/X-4a/#13
APPENDIX 6
EXAMPLE DOCUMENTATION OF A TOXIC SPILL EVENT
-------
C/Reu. X-ia/=l<*
FINAL REPORT FORM
June 17-18, 1985, American Chrome Plating Nickel Solution Spill
SPILL IDENTIFICATION (type of spill, volume, time, date, location)
June 17-18, 1985 (overnignt spill) of 2,000 gallons of concentrated nicicel
plating solution from an American Chrome Plating process tank.
Approx.: 20% chloride
10% sulfide
70% nickel
Precipitate from the tan< and washdown of cnromic acid and chromium and
zinc residues also entered sewer.
BRIEF DESCRIPTION OF INCIDENT (schematic of spill if appropriate, explanation
of cause of spill)
• Leak in nickel process tank filter hose drained tank contents onto the
floor withia a bermed area
• Sump pump in the bermed area was set to pump directly to the sanitary
sewer instead of a collection tank for waste neutralization (normal
discharge point).
(See attached letter from the industry for schematic.)
AFFECT ON THE POTW (documentation of pass through and interference, and POTW
damages)
• Pho-Strip System was upset on June 18, 1985
t Total phospate limit in NPDES permit was exceeded for the month of
June.
SUMMARY OF CHRONOLOGICAL EVENTS (spill. cleanup, disposal)
Date Event
June 18, 1985 STP Operator, Jack-Smith, reported a complete upset of
the entire Pho-Strip System. He was suspicious of a
toxic waste entering the Treatment Facility.
-------
;/Rec. X-4d/ = K
Operator Informs STP Superintendent, Chuck Jones, of
serious toxic discharge and problems with trte
Pho-Strip operation. Superintenaent as
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C/Reg. X—*a/?i*
ASPP £ VALUATION AND REMEDIAL ACTION (Summary of evaluation, resulting
modifications, ana compliance scneaules)
t Modification of piping to prevent automatic discharge to sanitary sewer
prior to neutralization in pretreatment system
• Operation of sumo pump only wnen attended.
ENFORCEMENT ACTION ;fines ano penalties, litigation for damages)
• Fines of $4,000 for damages, investigative costs, and follow-up effort.
Money to be applied to Industrial Waste Division Budget for procurement
of additional sampling equipment.
PRESENT STATUS (in compliance, cleanup effort, POTW operations, enforcement
efforts)
• Industry in compliance, modifications made at the plant
0 POTW Pno-Strip operation on Vine and operating correctly
• Fi nes 1evied, awai tl ng payment.
SCHEMATIC DRAWING OF INCIDENT (detail of spill site, direction of flow)
See attached letter from ttie industry for a schematic.
-3-
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EXAMPLE OF IU DOCUMENTATION OF TOXIC SPILL TO POTW
Mr. Fred Brown
Industrial Waste Division
iOU East Commerce Street
Anytown, IN 90922
Dear Mr. Brown:
This letter is in reponse to your request to detail the accidental discharge
into the city sewer system whicn occurred on June 18, 1985, at the American
Chrome Plating Facility located at 200 West Airport Avenue, Anytown, IN 90922.
This facility has in operation an automatic nickel plating line.
Duriny tne day of June 17, botn the filter pump ana pi Ding on tne collection
"an< nad undergone maintenance worK. The filter pump had oeen "emoved for
repair and replaced. Sometime during that night, a leak developed in the
filter line leading from the main nickel tank, the filter pump was turned
off, out a sipnomng action resulted in the tank being drained onto the floor.
A dike retaining wall (over 5,000 gallons capacity) which surrounds the entire
plating operation captured the spill and normally would have contained the
2,200 gallons held in the nickel tank. But other conditions compounded the
problem.
All the ongoing wastewater is fed to a sump pump located inside the dike area
and pumps into a large collection tank used to neutralize the wastewater
before discharging into the sewer line, or the sump can be pumped directly
into the sewer line. Because the collection tank pipe system was being worked
on also, the sump pump was set to pump directly into the sewer line, wnich was
accepable since the plating line was not operating (see attached schematic
diagram).
These were tne conditions when the shop closed down at 3:30 p.m., June 17.
When the plant reopened the following morning at 7 a.m., June 18, the 2,200
93!Ion nickel tank was 90 percent drained and the sump pump had pumped the
spill out of the dike into the sewer line. A heavy duty flexible rubber hose
which feeds over the lip of the tank to the pump was found to have developed a
crack where the plating solution leaked out. While the crack was located
several feet from the pump connection, the repair work of the previous day
obviously contributed to the hose failure.
A cnemical analysis of the constituents in the nickel tank had been made on
June 12, 1985. No additions or adjustments had been made from this data to
the date of the spill and can be assumed to be the concentrations discharged
into the sewer system.
The following corrective action is planned to prevent any such incident from
reoccurring:
-4-
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C/'Rec. X-4
A. time control actuated switch is being installed on the sump pump.
Tne control will be set to only allow the pump to operate during
working hours.
2} Until tne clock is installed (estimated completion 7/31/85),
procedures are in place to shut down the pump when the operation is
unattended.
American Chrome has operated the Anytown facility since 1980. This is tne
first incident of any type of spill. A combination of unusual circumstances
resulted in this unforturnate accident. We truly regret the downstream impact
to the Anytown Treatment Facility.
If further information is required, I can be contacted at (994) 999-9997.
Very truly yours,
Ed Rogers
Manufacturing Manager
ER:dr
Enclosure
-5-
-------
AREA SURFACE AND HOLDING CAPACITY
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lw
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_? — Sump
^
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"• ;
^, ~^~~f | 220° Sallons
Broken
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-6-
-------
« /<• A, I Jil 1
u/ A-43/r iw
APPENDIX 7
EXAMPLE FORMS TO DOCUMENT SPILL EVENTS
• SPILL NOTIFICATION LOG SHEET
• LOG OF CONTACT WITH OTHER AGENCIES
• LOG .OF KEY EVENTS OF THE SPILL
• FINAL REPORT FORM
-------
D/Reg. X-4a/*3
SPILL INFORMATION
Type of Spill
Location/Facility
Address
Reoorted bv
SPILL NOTIFICATION LOG SHEET
Phone No,
Comments
DESCRIPTION OF SPILL
Time/Date
Spilled Material
Discharged to
Containment in place
Current response efforts
Comments
Amount
HAZARD EVLUATION
Fire hazard
Corrosive
Explosive
Fumes
Personnel Safety Concerns: Exposure
Structural Danger
Comments
INITIATION OF RESPONSE
Report Received By
Date/Time
Agencies Contacted
Date/Time
-------
3/X-4a/#3
LOG OF CONTACT WITH OTHER AGENCIES
(Only some of these agencies may need so be notified in a particular incident;
spill coordinator's best judgment should be used.)
TELEPHONE
AGENCY NUMBER CONTACT DATE/TIME REMARKS
rederal Agencies
Dept. of Transnortation
Hazardous Materials (202) 425-2301
Nat. Bureau of
Standards (301) 921-1000
Oil and Haz. Mat. Teen.
Asst. Oata System (202) 245-3040
O.S.H.A. (301) 523-9700
Resource Conservation &
Recovery (Haz. Waste) (800) 424-9346
U.S. Coast Guard (BOO) 424-0201
U.S. Energy Department {202} 252-5000
U.S. EPA Region X
National Institute
Disease Control (800) 424-8802
U.S. Nuclear Reg. Comm. (301) 492-7000
State Agencies
Health Department
Solid & Haz. Waste
Water Resources Dept.
Local Agencies
?ire Department
Health Department
Hospital
Police Department
Water Plant
-------
"E.EDHON£
NUMBER CONTACT DATE/TIME REMARKS
Ciienlcal Companies
Amer. Cyanamid (201) 825-3100
Ash tana (6H) 276-5143
J. '. BflKe" (201; 359-2152
Chemtrac (300) 424-9300
Dow (517) 526-UOO
Du Pont (302) 77^-7500
Hoo
-------
LOG OF ;
-------
FINAL REPORT rORM
SPILL IDENTIFICATION (type of spill, volume, time, date, location)
BRIEF DESCRIPTION OF INCIDENT (scnemaric of spill if appropriate, explanation
of cause of spill)
AFFECT ON THE POTW (documentation of pass through and interference, and POTW
damages)
SUMMARY OF CHRONOLOGICAL EVENTS (spill, cleanup, disposal)
-------
3/X-ia/?;
-.5?° _EVALUATION AND REMEDIAL AC'ISN (Summary of evaluation, -esuitinc
modi f;cat"! ons, ana corns! :ancs scneauies
ENFORCEMENT ACTION (fines and penalties, litigation for damages)
PRESENT STATUS (in compliance, cleanup effort, POTW operations, enforcement
efforts)
-------
j/X-4a/?3
SCHEMATIC DRAWING OF INCIDENT (detail of soil1, site, flow)
-------
D/X-4a/?l3
APPENDIX 8
BIBLIOGRAPHY OF REFERENCE MATERIALS
These materials were useo as reference materials in
the development of this manual. Many of them are
useful documents that would benefit PQTWs In the
implementation of pretreatment programs and ASPP.
These manuals possess a lot of technical information,
much of it addressing spill prevention, control, and
response. They include procedural -information'as well
as forms and response guides.
-------
C,'X-4a/#2
ca' Oual'tv CsnfcT: In '^atgr anc Wastewatsr Laocratsr-! es ''PS21338-}*1
] SOOK of Standards, Jart 51 (Water ana Atmosonenc Analysis) 1S75,
Amen can society for Testing ana Materials
Effects of Hazardous Material Soills on Biological Treatment Processes,
U.i. -PA, 600/2-77-23y
auloance Manual for PQTW Pretreatrcent Program Development, U.S. EPA
HandDooK of C)iem7stry anc3 Physics
HandDOQK of Toxic and Hazardous Chemicals and Carcinogens, 2nd ed., 1985,
Marsnan iims.
Hazardous Chemicals, Spill Cleanup, ed. by J.S. Robinson, 1979.
Hazardous Chemical Data Book, ed. by G. Weiss, 1980,
Hazargous Materials and Natural Disaster Emergencies, Incident Action
SulaeDooK. Ernest o. Terrlen, Technomlc Publishing Co., 1984
Hazardous Material Spills and Responses for Municipalities. U.S. EPA,
500-2-80-108'
Lang's Handbook of Chemistry
OH and Hazardous Substances Respon.se Manual, U.S. EPA Region X Emergency
Response Team.
NPDE3 Compliance Sampling and Inspection Manual, (PB-81-15-3215)*
Manual and Methods for Chemical Analysis of Water and Wastes. (P8259973)*
Standard Methods for the Examination of Water and Wastewater, 16th Ed., 1985
""These publications are available from National Technical Information
Services, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4600.
-------
C/REG X-4/*4
This project has been funded at least in part with
Federal funds from the USEPA, Office of Water
Enforcement and Permits under contract number
68-01-7043, WA #P-17. The content of this publica-
tion does not necessarily reflect the views or
policies of the Office of Water Enforcement and
Permits, nor does mention of trade names, commer-
cial products, or organizations imply endorsement
by the U.S. Government.
-------
'—Environmental Protection Agency
§ 117.22
that such cooling water or storm water
is noc contaminated by an on-site spill
of a hazardous substance: or
ui) A continuous or anticipated
intermittent discharge of process
waste water, and the discharge origi-
nates within the manufacturing or
treatment systems: or
(iii) An upset or failure of a treat-
ment system or of a process producing
a continuous or anticipated intermit-
tent discharge where :he upset or fail-
ure results from a control problem, an
operator error, a system failure or
malfunction, an equipment or system
startup or shutdown, an equipment
wash, or a production schedule
change, provided that such upset or.
failure is not caused by an on-site spill
of a hazardous substance.
C44 FR 50776. Aug. 29. 1979. as amended at
44 7R 58910. Oct. 12. 1979]
§ 117.13 Applicability to discharges from
publicly owned treatment works and
their users.
(a) [Reserved]
(b) These regulations apply to all
discharges of reportable quantities to
a FOTW. where the discharge origi-
nates from a mobile source, except
where such source has contracted
with, or otherwise received written
permission from the owners or opera-
tors of the POTW to discharge that
quantity, and the mobile source can
show that prior to accepting the sub-
stance from an industrial discharger.
the substance had been treated to
comply with any effluent limitation
under sections 301. 302 or 306 or pre-
tr«atment standard under section 307
applicable to that facility.
§117.14 Demonstration projects.
Notwithstanding any other provision
°f this part, the Administrator of the
Environmental Protection Agency
may. on a case-by-case basis, allow the
discharge of designated hazardous
substances in connection with re-
search or demonstration projects re-
lating to the prevention, control, or
a&atement of hazardous substance pol-
lution. The Administrator will allow
such a discharge only where he deter-
mines that the expected environmen-
tal benefit from such a discharge will
outweigh the potential hazard associ-
ated with the discharge.
Subpart C—Notice of Discharge of a
Reportabie Quantity
§117.21 Notice.
Any person in charge of a vessel or
an onshore or an offshore facility
shall, as soon as he has knowledge of
any discharge of a designated hazard-
ous substance from such vessel or fa-
cility in quantities equal to or exceed-
ing in any 24-hour period the report-
able quantity determined by this part,
immediately notify the appropriate
agency of the United States Govern-
ment of such discharge. Notice shall
be given in accordance with such pro-
cedures as the Secretary of Transpor-
tation has set forth in 33 CFR 153.203.
This provision applies to all discharges
not specifically excluded or reserved
by another section of these regula-
tions.
§ 117.22 Penalties.
(a) Any person in charge of a vessel
or an onshore or offshore facility who
fails to notify the United States Gov-
ernment of a prohibited discharge pur-
suant to § 117.21 (except in the case of
a discharge beyond the contiguous
zone, where the person in charge of a
vessel is not otherwise subject to the
jurisdiction of the United States) shall
be subject to a fine of not more than
$10,000 or imprisonment for not more
than-one year, or both, pursuant to
section 311(bK5). ;.;-
(b) The owner, operator or person in
charge of a vessel or an onshore or off-
shore facility from which is discharged
a hazardous substance designated in
40 CFR Pan 116 in a quantity equal to
or- exceeding in any 24-hour period.
the reportable quantity established in
this part (except in the case of a dis-
charge beyond the contiguous zone.
where the person in charge of a vessel
is not otherwise subject to the jurisdic-
tion of the United States), shall be as-
sessed a civil penalty of up to 55.000
per violation under section
311(b)(6KA). Alternatively, upon a de-
termination by the Administrator, a
civil action will be commenced under
section 311(b)(6KB) to impose a penal-
-------
§ 117.23 "iiie 40—Protection of Environment
ty not :c exceed S50.000 uniess sucn
discharge is the result of willful negli-
gence or willful misconduct w;ih:n :he
privity anc knowieage of :he owner.
operator, or person in charge, in which
case the penalty shall not exceed
S250.000.
NOTE: The Adminstrator will Lake into ac-
count the gravity of me offense and the
standard of care manifest 5y :he owner. CD-
erator. or person in charge in determining
whether a civil action will oe commenced
under section 311Cbx6KB). The gravity of
the offense will be interpreted to include
the size of trie discharge, the degree of
danger or harm to the public health, safety,
or the environment, including consideration
of toxicity. degradability. and dispersal
characteristics of :he substance.. previous
spill history, and previous violation of any
spill prevention regulations. Particular em-
phasis will be placed on ihe standard of care
and the extent of mitigation efforts mani-
fest by the owner, operator, or person in
charge.
§ 117.22 Liabilities for removal.
In any case where a substance desig-
nated as hazardous in 40 CFR Part 116
is discharged from any vessel or on-
shore or offshore facility in a quantity
equal to or exceeding the reportable
quantity determined by this part, the
owner, operator or person in charge
will be liable, pursuant to sections 311
(f) and
-------
G/X-4a/*13
APPENDIX 3
Detailed Information to be Considered in Development of ILJ ASPPs:
• Identification of Potential Spill and Slug Discharge Sites and
Pathways
• Existing and Proposed Spill Prevention Equipment
t Spill Prevention Procedures
• Existing and Proposed Spill Response Procedures
• Follow-up Reporting and- Documentation Procedures
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