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Article # 0064

Essential Elements of a Storm Water Pollution Prevention Plan for Fiberglass Manufacturers

By Karen Bullard, P.E.

Introduction


This document is an example of a storm water pollution prevention plan for a fiberglass manufacturer, integrating the worksheets that the Texas Commission on Environmental Quality provided after the last update to the storm water permit in 2011. This plan covers the most essential elements for prevention of storm water pollution.


Generic, Inc.

Storm Water Pollution Prevention Plan


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 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.


Generic, Inc. encourages any suggestions that employees may have for improving our Storm Water Pollution Prevention Plan, as Generic, Inc. is committed to developing and maintaining an effective plan. 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.


Team Member: Safety Manager


Responsibilities: Safety Manager is responsible for the written storm water pollution prevention plan. Copies of the written plan may be obtained from the safety office. It is a company policy to make our plan available to our employees. Employees can obtain access to the plan by asking the safety manager for assistance.



SWP3 Committee: Production Manager, Safety Manager and all department heads

Responsibilities: Production Manager, Safety Manager and all department heads make up Genericís 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:

  1. Implementing all general permit and pollution prevention plan requirements.

  2. Defining and agreeing upon an appropriate set of goals for the facility's storm water management program.

  3. 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


Approved Non-Storm Water Discharges

Type of Discharge

Process or Activity

City fire hydrant

Testing procedures

Narrative Description of Approved Non-Storm Water Discharges:

Generic has one area of non-storm water discharge. There is a city fire hydrant located on the front of the property. This hydrant is used periodically for testing procedures. All testing water is natural city water without chlorine. After testing is completed this is discharged directly on company grounds.

Narrative Description of Non-Storm Water Discharge Investigation:


Non-Storm Water Discharge Investigation

Date

Findings

Corrective Action Taken








Certification:


I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations.



Inventory of Exposed Materials

Material

Quantity

Storage Location or Activity

Specific Pollutant(s)

Catalyst and Solvents



MEKP, Toluene, Xylene, MEK, Water-based solvents. During Loading process there is always potential of spillage.

Waste Drums



Used raw materials stored in 55-gallon drums. Oily water and acetone wastes are also stored in covered outdoor area.

Fiberglass Molds



Catalyzed resin and gel coat, waxes, solvents and fine fiberglass dust.

Finished Fiberglass Products



Catalyzed resin and gel coat, waxes, solvents and fine fiberglass dust.

Bulk Resin Storage Tank



Uncatalyzed fiberglass resin.

Dumpsters



Plant trash


Description of Potential Pollutant Sources

Narrative Description: The inventory above lists the materials that could potentially cause storm water contamination.

Catalysts and solvents, both in the virgin form and the spent form as drummed waste, have the potential to be exposed to the environment as they are received from suppliers at the loading dock, moved around the plant, and off-loaded for disposal at the waste storage dock. Normal plant activities would not cause these materials to be exposed to storm water because the materials are received and handled in sealed containers.

Fiberglass molds and completed fiberglass parts may be stored outdoors under cover. Completed parts may also be stored temporarily without cover. These materials may potentially have small residues of materials that could be exposed to storm water during a rain event.

The large plant trash dumpster is uncovered and is a potential source of exposure of pollutants if it were to become overly full. However when used properly and compacted in a timely and reasonable fashion, possible exposure is greatly reduced.

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 there are no known particular points of storm water "outfall." In other words, the water natural drains in these directions, but there are no known discharge points.

Generic maintains a current drainage site map and topographic map of the facility. The entire area is well-covered with thick grass and is not expected to experience significant soil erosion.

Description of Potential Pollutant Sources

Spills and Leaks

There have been no significant spills and leaks of toxic or hazardous materials at the facility that would be expected to add pollutants to storm water discharges.

The following is a summary of the facility's 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 original NOI: Generic has not had any occurrences in the last five years of any release to land or water of toxic or hazardous chemicals or SARA Title III water priority chemicals.

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: Company steel materials, framework and pieces of cement blocks and stepping-stones, and fiberglass molds. None of these materials contained hazardous chemicals. There have been no laboratory analyses of storm water discharge samples.


Spill & Leak Log

Date of Spill

Material Spilled

Quantity Spilled

Did the Spill Result in a Discharge?

Corrective Action Taken

Date Reported to TCEQ








Pollution Prevention Measures & Controls


It is the policy of Generic 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, Generic 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. Other general housekeeping measures include protecting wet and dry materials from rainfall and runoff. This is accomplished by working in covered areas, closing open bags when not in use, and covering piles of exposed material with tarps. Also, waste will never be buried. Whenever trash is observed to have escaped the appropriate container or dumpster, employees will correct the problem.


Good Housekeeping Measures

Location Within the Facility

Housekeeping Measure


Raw Material and Waste Handling



Chemical material handler will make sure all chemical containers are covered properly. 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. Chemical handler drums the company waste and transports to the loading dock for proper disposal. All drums are properly labeled, sealed and secured.



Fiberglass Molds, Finished Fiberglass Products and Metal Frames



These materials will be neatly stacked outdoors. Molds and fiberglass products will generally be stored under cover, but may temporarily be stored without cover. Employees should inspect these storage areas for debris to be placed in trash dumpsters.


Fiberglass Department



The chemical storage room will be kept free of debris. Drip pans will be used on all open containers. Fiberglass supervisor will check all his exit doors for any possible containers that may have been placed outside.



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.



Pollution Prevention Measures & Controls


Spill prevention & response procedures:

The primary potential sources of contamination from spills are the chemical storage and waste storage areas. The outdoor chemical storage rooms and the interior chemical storage rooms are each 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.

Waste storage areas are located indoors or under cover on an elevated dock outdoors. All waste containers are kept sealed and are properly labeled to identify the contents.

Chemical spill kits are located near the two interior chemical storage rooms. Spills will be cleaned with absorbent and contained with absorbent socks. The current inventory of these kits is as follows:

Fiberglass Shop Spill Kit

10 sorbent socks

20 sorbent pillows

Two Tyvek suits consisting of:

Chemical Handler is responsible for spill prevention at the facility. The responsibilities for this position are: to be sure that the company spill kits are full of necessary supplies, and with the help of the safety manager be sure everyone is trained on the spill procedures.

Generic has established procedures for helping to ensure proper material handling and storage. In general, only chemical material handler and lead man are authorized to distribute chemicals. Chemical Material Handler makes sure that all containers are labeled properly with HMIS labels.

Procedures for the proper cleanup of spills are as follow:

In addition, we have posted on all the production floor telephones the direct 800 numbers for the poison control center. The safety manager 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.


Pollution Prevention Measures & Controls

Erosion and Sedimentation Control Measures

In general, the entire plant property (outside of the production areas) is well-covered with thick grass 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.


Erosion and Sedimentation Control Measures

BMP

Location

Used

( check)

Not Used

(check)


Soil Stabilization through Vegetative Cover


Entire plant property outside of production areas



Contouring Slopes


N/A



Paving


N/A



Installation of Structural Controls


N/A




Pollution Prevention Measures & Controls

Maintenance Program for Structural Controls

The condition of the grass cover will be observed during quarterly inspections to determine if any repairs or replanting is required to prevent soil erosion.

Generic also maintains an ongoing preventive maintenance program. On a regular basis Generic inspects the catch basins at the air compressor and acetone waste areas. Generic checks for leaks or cracks that may cause a leak. The safety manager and the maintenance man are responsible for these inspections.

On a daily basis the chemical material handler inspects chemical containers, storage buildings, 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, the air compressor area and all material handling equipment is visually inspected for any leaks. The maintenance men and the person or persons operating material handling equipment do these checks.

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.


Maintenance Program for Structural Controls

Structural Control

Inspection Schedule

Inspector

Maintenance Frequency

Volume of Solids Removed

Concrete pad under sandblasting area to prevent run-off of blasting media

Periodically




Preventative Maintenance


Safety Manager



Chemical containers, storage building, and tank inspection

Daily

Chemical Handler





Pollution Prevention Measures & Controls


Best Management Practices

Location Within the Facility

Best Management Practice

Implementation Date


Outdoor dumpsters and waste management


Generic current utilizes a compaction dumpster for the majority of the facilities trash and non hazardous waste. The compactor is fully enclosed which reduces the chances of pollution. In the future Generic would like to reduce the overall amount waste and trash disposed of at the facility so that they may be able to utilize a much smaller dumpster to further reduce the chances of storm water pollution.




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. Generic has taken a number of precautions at our facility 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. These precautions include: 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




Fiberglass Molds and Finished Fiberglass Products




For finished products and metal frames that no longer have a customer destination, Generic will look for alternate methods of use and/or disposal. Generic will list materials in the TCEQ RENEW database to encourage recycling of usable materials. As a last resort, Generic will begin disposal of fiberglass parts as refuse. To aid in the prevention of storm water pollution, when available, molds and finished products will be stored in the warehouse or rack storage areas.







Pollution Prevention Measures & Controls

Employee Training Program and Employee Education

At Generic, regular employee training in storm water pollution prevention is maintained 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. This includes familiarization with good housekeeping measures, BMPs and goals of the SWP3.

Generic has established procedures for helping to ensure proper material handling and storage. In general, only chemical material handler and lead man are authorized to distribute chemicals. Chemical handler makes sure that all containers are labeled properly with HMIS labels.

All department managers have been trained in proper spill response and these managers inform their employees of the necessary procedures. As shown in the training documentation, spill response training includes information on proper material management and handling practices for chemicals, fluids, and other materials encountered at the facility, spill prevention methods, the location of materials and equipment necessary for spill clean-up, spill clean up techniques and spill reporting procedures.

The Safety Manager 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.



Employee Training Program

Training Topic

Was this topic covered?

Date of Training

Yes

No

Year 1

Year 2

Year 3

Year 4

Year 5

Materials management & handling








Spill prevention methods








Location of spill cleanup supplies








Spill cleanup equipment








Spill cleanup techniques








Proper spill reporting








Good housekeeping measures








Best management practices








Goals of the SWP3









Employee Education Program

Training Topic

Was this topic covered?

Date of Training

Yes

No

Year 1

Year 2

Year 3

Year 4

Year 5

Basic goals of the SWP3








Contacting the Pollution Prevention Team










Pollution Prevention Measures & Controls

Routine Facility Inspections

The Safety Manager 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, the water drains into two general areas. During the next significant storm water event, the Safety Manager will visually inspect the drainage areas and document any findings. If possible, a sample of the storm water run-off will be collected from both areas 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, Generic will implement a system for collecting rainfall data. Every day the Safety Manager will make a note of whether there was rainfall and if so, whether there was enough to cause runoff. A rain gauge may be used to document the amount of rainfall. If there is not enough rainfall to cause runoff during a particular quarter, monitoring will not be accomplished for that time period.

Record keeping and Reporting Procedures

Our record keeping system ensures adequate implementation of the storm water pollution prevention plan. A storm water management program binder is located in the safety office. This has copies of the program, training logs, and other records.


Pollution Prevention Measures & Controls

Routine Facility Inspections

The Safety Manager 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 two general areas. During the next significant storm water event, the Safety Manager will visually inspect the drainage areas and document any findings. If possible, a sample of the storm water run-off will be collected from both areas 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, Generic will implement a system for collecting rainfall data. Every day the Safety Manager will make a note of whether there was rainfall and if so, whether there was enough to cause runoff. A rain gauge may be used to document the amount of rainfall. If there is not enough rainfall to cause runoff during a particular quarter, monitoring will not be accomplished for that time period.

Record keeping and Reporting Procedures

Our record keeping system ensures adequate implementation of the storm water pollution prevention plan. A storm water management program binder is located in the safety office. This has copies of the program, training logs, and other records.

Biography 

Karen M. Bullard, P.E. is an Engineering Partner and the President of Bullard Environmental Consulting, Inc.   She has over 20 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 June 25, 2014 from previously composed material.


Article # 0064 

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