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Article # 0054
This document is a template for a storm water pollution prevention plan that could be for a cured in place pipe (CIPP) facility to meet the requirements described in this plan. For more information on the CIPP process itself, please refer to the previously-published article " Equipment and Processes Used at “Cured in Place Pipe” (CIPP) Wetout Facilities" by Karen M. Bullard, P.E.. The diagram of the site plan mentioned in this document is not included, but is self-explanatory from the description.
The storm water pollution prevention plan (SWP3) for this operation was developed in accordance with, and follows the format of Texas Commission on Environmental Quality General Permit Number TXR050000 Relating To Storm Water Discharges Associated With Industrial Activity.
Developed by Karen M. Bullard. P.E. of Bullard Environmental Consulting, Inc.
General Company Policy
The purpose of this program is to inform interested persons, including employees, that CIPP Generic, Inc. is complying with EPA requirements for preparing and maintaining a Storm water Written Pollution Prevention Plan under the storm water regulations (Title 40, Code of Federal Regulations, Part 122).
This written pollution prevention plan consists of:
(1) An evaluation of the potential sources of pollution at the facility, and
(2) A description of the practices and program elements to control pollutants in areas identified as being potential pollutant sources for storm water discharges associated with industrial activity; and
(3) A demonstration of how practices and program elements will help to ensure compliance with the terms and conditions of the general permit. This will be accomplished by addressing each requirement in the order and format shown in the permit itself.
CIPP Generic, Inc. encourages any suggestions that employees may have for improving our Storm Water Pollution Prevention Plan, as CIPP Generic, Inc. is committed to developing and maintaining an effective plan. CIPP Generic, Inc. strives for clear understanding, safe behavior and involvement in the plan from every level of the company.
Consistency with Other Plans
Other environmental management plans will be reviewed for consistency with the SWP3. Any applicable provisions will be incorporated into the SWP3. Other related plans may include the Preparedness, Prevention and Contingency Plan (40 CFR Parts 264 and 265), the Spill Control and Countermeasures requirements (40 CFR Part 112), the National Pollutant Discharge Elimination System Toxic Organic Management Plan (40 CFR Parts 413, 433 and 469), and the Occupational Safety and Health Administration (OSHA) Emergency Action Plan (29 CFR Part 1910). At this time, it does not appear that any of these other plans apply to operations at this site.
Pollution Prevention Team
Pollution Prevention Staff
Responsibilities of Team Members:
Each individual on the storm water pollution prevention team has a specific set of responsibilities which are detailed throughout the plan.
Mr. Manager is responsible for the written storm water pollution prevention plan. Copies of the written plan may be obtained from his office. It is a company policy to make the plan available to the employees. Employees can obtain access to the plan by asking Mr. Manager for assistance.
Responsibility of Team as a Whole
Mr. Manager and all department heads make up CIPP Generic, Inc.'s storm water pollution prevention committee. This committee is responsible for developing the storm water pollution prevention plan and assisting the plant manager in its implementation, maintenance and revision. In addition, the pollution prevention team is also responsible for:
A. Implementing all general permit and pollution prevention plan requirements.
B. Defining and agreeing upon an appropriate set of goals for the facility's storm water management program.
C. Maintaining a clear line of communication with plant management to ensure a cooperative partnership.
The pollution prevention team also must evaluate existing environmental management plans for consistency and determine which, if any, provisions should be incorporated into the Storm water Pollution Prevention Plan. Other related plans may include the Preparedness, Prevention and Contingency Plan (40 CFR Parts 264 and 265), the Spill Control and Countermeasures requirements (40 CFR Part 112), the National Pollutant Discharge Elimination System Toxic Organic Management Plan (40 CFR Parts 413, 433 and 469), and the Occupational Safety and Health Administration (OSHA) Emergency Action Plan (29 CFR Part 1910). As described earlier, at this time it does not appear that any of these plans apply to this site.
Non-Storm Water Discharges
CIPP Generic, Inc. has one area of non-storm water discharge which meets Part II.A.5.b of the general permit allows discharge of “potable water sources.”
Samples of polymerized liners may be pressure-tested with potable water. All testing waters are city water and after testing is completed are discharged directly on company grounds and absorbed naturally into the ground. The site does not have a separate storm sewer discharge.
Description of Potential Pollutants and Sources
Inventory of Exposed Materials
Broken and Crushed Used Asphalt Asphalt particulate
Crushed Limestone Limestone particulate
Sand Silica/uncontaminated sand particulate
Resin, Catalyst, and Solvents Uncatalyzed Resin, Acetone, Superblue and Supergreen solvents, Perkadox, and Trigonox. During loading process there is always a potential of spillage.
Liner Samples Catalyzed resin and fiberglass particulate on rough edges
Bulk Resin Storage Tank Uncatalyzed fiberglass resin
Dumpsters Plant trash
The inventory above lists the materials that could potentially cause storm water contamination. The first three materials are broken and crushed used asphalt, limestone, and sand. Piles of these materials may be stored in the general area indicated on the site map. Exposure to storm water can potentially occur as storm water runoff leaves the area of these piles. In addition, exposure could occur if these materials are spilled from trucks as they are loaded for transport to off-site locations.
Resin, catalysts, and solvents have the potential to be exposed to the environment as they are received from suppliers at the loading dock and moved around the plant. Normal plant activities would not cause these materials to be exposed to storm water because the materials are received and handled in sealed containers.
Liner samples may be stored outdoors. These materials may potentially have rough edges where fiberglass could be exposed to storm water during a rain event.
Some of the plant trash dumpsters are uncovered and are a potential source of exposure of pollutants if they become overly full. The bulk resin tank is a potential source of storm water contamination only in the event of a spill. Containment walls around the tank help to reduce the possibility of storm water exposure.
The site map showing the direction of storm water flow indicates that all water ends up in the drainage ditch on the east side of the property. There are no known particular points of storm water “outfall.” In other words, the water naturally drains in these directions, but there are no known discharge points.
CIPP Generic, Inc. maintains a current drainage site map of the facility. The property outside the production area is covered with grass or paved and is not expected to experience significant soil erosion.
See attachments for the site map. This map shows the location of all outdoor activities and/or items with the potential to cause exposure of pollutants to storm water. The blue arrows show the direction and destination of storm water run-off. As indicated, there are no distinct “outfalls” where water discharge from the property is observed.
Spills and Leaks
CIPP Generic, Inc. has experienced no significant spills and leaks of toxic or hazardous materials at the facility that would be expected to add pollutants to storm water discharges.
In addition the facility has had no releases to land or water of toxic or hazardous pollutants, or SARA Title III water priority chemicals that have occurred at any time during the three years prior to the submittal of the NOI.
The following are significant materials that have been treated, stored or disposed in a matter to allow exposure to storm water between the time of three years prior to the submittal of the NOI and the present: hardened asphalt, sand, and limestone. None of these materials contained hazardous chemicals. There have been no laboratory analyses of storm water discharge samples.
Pollution Prevention Measures and Controls
Good Housekeeping Measures
It is the policy of CIPP Generic, Inc. to maintain a clean, orderly facility to minimize potential for industrial runoff as well as to ensure the safety of employees. The good housekeeping program emphasizes reducing the possibility of mishandling chemicals or equipment and training of employees in housekeeping techniques.
In general, CIPP Generic, Inc. employees may spend the last half-hour of a work shift participating in clean-up activities. These include general trash pick-up and proper disposal in interior containers and dumpsters. Also, waste will never be buried. Whenever trash is observed to have escaped the appropriate container or dumpster, employees will correct the problem.
Raw Material Handling – The chemical material handler will make sure all chemical containers are covered properly. The shipping/receiving supervisor will make sure nothing is running into the bottom of the loading docks, and will check all exit doors for any possible open containers. After asphalt, sand, or limestone material is loaded onto trucks for transport off-site, the immediate area and the path of transport will be inspected for spills. Any spilled material will be picked up and placed in the appropriate raw material pile.
Liner Samples – These materials will be neatly arranged outdoors. When significant rainfall events are anticipated, these materials will be covered to prevent runoff.
Bulk Resin Storage Tank – Storm water drainage pipes leading from the bulk tank containment compartments must be kept capped. After a storm water event the containment compartments should be inspected to ensure no leaks from the tank have contaminated the storm water. If there have been no leaks, the drainage pipes may be uncapped to drain the accumulated storm water. If there have been chemical leaks, the contaminated storm water must be pumped into waste drums and disposed of as waste.
Spill Prevention and Response Measures
The primary potential sources of contamination from spills are the chemical storage areas. The interior chemical storage is surrounded by concrete curbs and walls to prevent exposure of any spilled materials to storm water. In addition, the resin bulk storage tank also has a containment wall to prevent exposure of spilled resin to storm water run-off. All chemical containers are labeled properly to identify the contents.
A chemical spill kit is located (insert location). Spills will be cleaned with absorbent and contained with absorbent socks. The current inventory of these kits is as follows:
10 sorbent socks
20 sorbent pillows
Two Tyvek suits consisting of:
Two sets of protective boots
Two sets protective face shields
Two sets protective gloves
Two sets protective clothing
Mr. Manager is responsible for spill prevention at the facility. The responsibilities for this position are: to ensure that the company spill kits are full of necessary supplies, and with the help of the safety manager, to ensure everyone is trained on the spill procedures.
CIPP Generic, Inc. has established procedures for helping to ensure proper material handling and storage. In general, only the chemical material handler and the shipping/receiving supervisor are authorized to distribute chemicals. The chemical material handler makes sure that all containers are labeled properly with HMIS labels.
Procedures for the proper cleanup of spills are as follows:
In addition, we have posted on all the production floor telephones the direct 800 numbers for the poison control center. The safety manager, Mr. Prevention, also has an Emergency Response Guidebook (ERG) for quick reference. All new employees receive an orientation to the SWP3 and all department managers have been trained in proper spill response.
Erosion Control Measures
In general, the entire plant property (outside of the production areas) is well-covered with grass or is paved and is not expected to experience significant soil erosion due to this effective soil stabilization technique. The slope of the property does not require additional contouring slopes, paving, or other structural controls to effectively control erosion.
Maintenance Program for Structural Controls
The condition of the grass cover and paving will be observed during quarterly inspections to determine if any repairs or replanting is required to prevent soil erosion.
CIPP Generic, Inc. also maintains an ongoing preventive maintenance program. On a regular basis CIPP Generic, Inc. inspects (list equipment and who does this.)
On a daily basis Mr. Manager inspects chemical containers, storage areas, as well as the resin tank and piping for any leakage. If a leak occurs, the safety manager and maintenance department are notified. On a daily basis all material handling equipment is visually inspected for any leaks. The maintenance men and the person or persons operating material handling equipment perform these inspections.
Best Management Practices
Outdoor dumpsters and waste management – Dumpsters will be observed daily to determine if they are becoming full. To prevent overflow and potential storm water exposure, CIPP Generic, Inc. will notify the disposal company of the need for trash pickup before dumpsters become full. Dumpsters equipped with lids will be closed when not in use.
Raw Material Piles – CIPP Generic, Inc. will install silt fencing appropriately around the raw material piles to prevent particulate runoff. After each significant rainfall event, the fencing will be inspected for buildup and raw material will be returned to the appropriate pile as needed.
Raw Material and Waste Handling – When material is being loaded or unloaded, employees will observe the process and immediately respond to any leaks or spills. Upon receiving of all chemical containers, the MSDS paperwork is reviewed which in then issued a HMIS sticker with all hazardous info placed on the sticker including compatible and non-compatible materials and proper storage. These steps help to ensure that the materials of construction for containers handling hazardous substances or toxic pollutants are compatible with the container's contents and surrounding environment
Employee Training Program and Employee Education
Employees at the site will be trained in the following areas:
CIPP Generic, Inc. maintains regular employee training in storm water pollution prevention to inform personnel at all levels of responsibility of the components and goals of the storm water pollution prevention plan. During new employee orientation all safety and environmental policies and procedures are explained. Education will be provided to those employees at the facility that are not directly responsible for implementing or maintaining activities identified in the SWP3, and that do not participate in the employee training program. At a minimum, these employees will be informed of the basic goal of the SWP3 and how to contact Mr. Manager regarding storm water issues.
Employee training sessions will be conducted at least annually and records of training activities will be maintained. Mr. Prevention will periodically (at least annually) update department managers on good housekeeping procedures, BMPs, and the goals of the SWP3. He is also responsible for documenting in the pollution prevention plan the periodic completion of employee training.
Mr. Manager, Mr Prevention or another employee familiar with the industrial activities performed at the facility will perform a quarterly inspection using the attached checklist to determine the effectiveness of the Good Housekeeping Measures, Spill Prevention and Response Measures, Erosion Control Measures, Maintenance Program for Structural Controls, Best Management Practices, and the Employee Training Program.
When revisions or additions to the SWP3 are recommended as a result of the inspections, a summary description must be attached to the checklist. The summary must also discuss timeframes for the changes.
Quarterly Visual Monitoring
The property does not have any specific storm water discharge points. However, as shown on the site map detailing the direction of run-off, the water drains into one general area. During the next significant storm water event and on at least a quarterly basis, Mr. Manager or Mr. Prevention will visually inspect the drainage areas and document any findings. If possible, a sample of the storm water run-off will be collected from the area to examine for color, clarity, floating solids, settled solids, suspended solids, foam, oil sheen and other obvious indications of storm water pollution. Any noticeable odors will also be noted. Records of this monitoring will include the date and time of collection, name of personnel that collected and examined the sample, nature of the run-off (i.e. rain, snow melt) and visual quality of the storm water discharge. The results will be reviewed by the program manager and appropriate members of the SWP3 team. The SWP3 will be modified as necessary to address the conclusions of the team.
Since it is likely that there will be quarters where there is not enough rainfall to cause runoff, CIPP Generic, Inc. will implement a system for collecting rainfall data. Every week the Production Manager, Mr. Production, will make a note of whether there was rainfall and if so, whether there was enough to cause runoff. A rain gauge will be used to document the amount of rainfall on at least a weekly basis. Rainfall data must be collected daily during storm events. If there is not enough rainfall to cause runoff during a particular quarter, monitoring will not be accomplished for that time period. Rain gauge monitoring and recordkeeping may be temporarily suspended during a given monitoring period (a quarter) if a representative storm event has occurred and the required sampling and analyses has been conducted.
Record keeping and Reporting Procedures
The record keeping system will ensure adequate implementation of the storm water pollution prevention plan. Records shall document and describe maintenance activities, inspections, spills, employee training activities, employee education activities, SWP3 updates/modifications, and other events relative to each element of the SWP3.
Management of Runoff with Structural Controls
There will be no additional physical structures other than those described under the BMP section.
Velocity Dissipation Devices
Velocity dissipation devices will not be needed at this site because storm water discharge will not destroy the natural physical characteristics of receiving waters by erosion.
Annual Comprehensive Site Compliance Evaluation
The comprehensive site compliance evaluation is a required site inspection and an overall assessment of the effectiveness of the current SWP3. This evaluation is in addition to other routine inspections required by the permit (e.g. inspections of good housekeeping measures, structural controls, and for identification of non-storm water sources). This evaluation may, however, substitute for the periodic quarterly inspection if it is conducted during the regularly scheduled period for the periodic inspection.
The evaluation will be conducted at least once per year by either one or more qualified employees or designated representatives, who are familiar with the industrial activities performed at the facility and the elements of the SWP3.
The evaluation will include:
Annual Site Compliance Evaluation Report
The report will include a narrative discussion of CIPP Generic, Inc's compliance with the current SWP3. The report will document the personnel conducting the evaluation, the dates of the evaluation, and any incidents of non-compliance.
Revision of the SWP3
The SWP3 will be revised to include and address the findings of the Site Compliance Evaluation Report within 30 days following completion of the evaluation. Revisions will include all applicable changes that result from the comprehensive site compliance report and all applicable updates to:
Copy of Multi-Sector General Permit (MSGP)
A copy of the general permit shall be included either as part of the SWP3 or as an attachment to the SWP3.
Inspection of the Storm Water Pollution Prevention Plan (SWP3, or Plan) and Site
Inspection and entry shall be allowed under Texas Water Code Chapters 26-28, Health and Safety Code §§ 361.032-361.033 and 361.037, and 40 Code of Federal Regulations
The SWP3 shall be maintained, with a copy of this general permit, either at the site or be readily available for review by authorized TCEQ personnel upon request. The SWP3 will be modified by the as often as necessary. Each revision will be dated and all revisions will be retained for at least three years.
General Monitoring and Records Requirements
Representative Storm Events
Monitoring, sampling, examinations, and inspections of storm water discharges that are required as a provision of the general permit will be conducted on discharges of runoff from a representative storm event. For the purposes of the general permit, a representative storm event is an event with at least 0.1 inch of measured precipitation that occurs with a minimum interval from the preceding measurable storm of at least 72 hours.
This facility does not use retention ponds as a BMP. The facility will use a rain gauge on-site in order to determine when a representative storm event occurs. The rain gauge will be monitored a minimum of once per week, and once per day during storm events. Records will be retained on-site or made readily available for review. Rain gauge monitoring and recordkeeping may be temporarily suspended during a given monitoring period if a representative storm event has occurred and the required sampling and analyses has been conducted.
Representative Discharges from Substantially Similar Outfalls
The property does not have any specific storm water discharge points. However, as shown on the site map detailing the direction of run-off, the water drains into one general area. Any sample that can be collected as run-off draining off-property can be assumed to be representative of any outfalls that could be identified on the property. The justification for this discharge as substantially similar is as follows:
· The industrial activities that occur in the drainage area to each outfall are all the same;
· The significant materials stored or handled within the drainage area to each outfall are all the same; and
· The management practices and pollution control structures that occur within the drainage area of each outfall are all the same.
· The whole drainage area could be considered “one outfall.”
Representative Discharge Samples
All samples will be representative of the discharge. Sampling will be completed within the first 30 minutes of discharge using a grab sample. If it is not practicable to take the sample, or to complete the sampling, within the first 30 minutes, sampling will be completed within the first hour of discharge. If sampling is not completed within the first 30 minutes of discharge, the reason will be documented and attached to all required reports and records of the sampling activity.
Sampling for Compliance with Specific Numeric Effluent Limitations
The operations at this site are described by operations covered by SIC codes 3999 for miscellaneous manufacturing of polymeric products. Therefore the Sector Y: Rubber, Miscellaneous Plastic Products, And Miscellaneous Manufacturing Facilities specific limitations apply. There are no specific numeric effluent limitations for this SIC code.
Authorized Storm Water Discharges that Combine with Other Flows
The storm water discharges authorized under this general permit will not combine with either other storm or with wastewater authorized under a separate permit.
Analytical Test Procedures
All procedures will comply with the standards specified in 30 TAC §§319.11 - 319.12.
Sampling, inspections, and examinations that are required on a quarterly basis will be conducted during the following periods: first quarter - January through March; second quarter - April through June; third quarter - July through September; and fourth quarter - October through December. Monitoring, inspections, and examinations that are required on an annual basis will be conducted before December 31st of each year. Sampling, inspections and examinations will begin in the first full quarter following submission of the NOI.
Temporary Suspension and Waivers from Monitoring Requirements
Requirements to sample, inspect, examine or otherwise monitor storm water discharges within a prescribed monitoring period may be temporarily suspended for adverse weather conditions. Adverse weather conditions are conditions that are either dangerous to personnel (e.g. high wind, excessive lightning) or weather conditions that prohibit access to a discharge (e.g. flooding, freezing conditions, extended periods of drought). Adverse conditions that result in the temporary suspension of a permit requirement to sample, inspect, examine, or otherwise monitor storm water discharges will be documented and included as part of the SWP3. Documentation will include the date, time, names of personnel that witnessed the adverse condition, and the nature of the adverse condition.
When monitoring is temporarily suspended, that monitoring will be conducted in the next quarter, in addition to any monitoring required for that period. If the temporarily suspended monitoring requirement cannot be fulfilled during the next quarter, it is permanently waived.
Inactive Industrial Facilities
If this facility becomes inactive, CIPP Generic, Inc. will provide written notice to the executive director of this status.
Following the notification of inactivity, permit requirements to sample, inspect, examine, or otherwise monitor storm water discharges will be waived during the period that the facility maintains inactive status.
CIPP Generic, Inc. will notify the executive director in writing at least 48 hours before commencing industrial activities and transferring to active status from inactive.
Monitoring and reporting records, copies of all other records required by the general permit, and records of all data used to complete the application for the general permit will be retained at the facility or shall be readily available for review by authorized TCEQ personnel upon request, for a period of three years from the date of the record or sample, measurement, report, application, or certification. The SWP3 will be maintained, and be made readily available for inspection and review by authorized TCEQ personnel upon request. Additionally, a copy of each revised SWP3 for the preceding three-year period will be maintained and made readily available for review. If the permit is terminated or allowed to expire without renewal, the SWP3 will be maintained and made readily available for review for a minimum period of one year.
Numeric Effluent Limitations and Discharges of Storm Water to Inland and Tidal Waters
Numeric Limitations, Daily Maximum Effluent Limitations, Daily Composite Effluent Limitation, Monthly Average Effluent Limitation, and Reporting Requirements
Do not apply. The facility is eligible for the hazardous metals waiver as shown below.
Waiver from Numeric Effluent Limitation
The operations at this site qualify for a waiver from hazardous metal monitoring because they do not use a raw material, produce an intermediate product, or produce a final product that contains one of these hazardous metals. A copy of the waiver certification form is attached to this SWP3 and will be either maintained onsite or made readily available for review by authorized TCEQ personnel upon request.
Coal Pile Runoff
Not applicable. This facility does not have piles of coal.
Karen M. Bullard, P.E. is an Engineering Partner and the President of Bullard Environmental Consulting, Inc. She has over 18 years experience in environmental engineering, compliance and permitting. She worked for the Texas Commission on Environmental Quality (TCEQ) for four years as an Air Permit Specialist in the Coatings and Combustion Section, where she developed a thorough understanding of the governmental procedures and policies in Texas. Karen has a Bachelors of Science Degree in Chemical Engineering from the University of Texas at Austin.
Karen M. Bullard, P.E. No. 88449
Final edition completed May 26, 2011 from previously composed material.