Things Aren’t Always What They Seem A Stormwater Pollution Prevention / Good Housekeeping Case Study in Western New York

Learning Objectives Get to know your facility Perform regular pollution prevention / good housekeeping Have basic understanding of applicable federal and state regulations as they relate to stormwater and petroleum bulk storage

Project Background Federal Regulations Clean Water Act (CWA) Resource Conservation & Recovery Act (RCRA) State Level Regulations Environmental Conservation Law (ECL) Petroleum Bulk Storage (PBS) Regulations

Western New York

Environmental Compliance Project Stormwater investigation Recommendations State Pollutant Discharge Elimination System (SPDES) permit Spill Prevention Control & Countermeasures (SPCC) Plans Industrial discharges Best management practice designs

Stormwater Investigations: Preparation

Stormwater Investigation: Site Visit

Stormwater Investigation: SPCC Petroleum Bulk Storage (PBS) Aboveground Storage Tanks (AST) Underground Storage Tanks (UST) 55 Gallons Drums

Stormwater Investigation: PBS Aboveground Storage Tank (AST) Label Secondary Containment Fill Port Color Coding Diesel – Yellow Gasoline – White w/ Black Cross Fuel Gauge

Stormwater Investigation: PBS Underground Storage Tank (UST) Fill Port Cover Label Inventory Records (Daily) Interstitial Space Leak Test Records (Weekly) Tightness Test Records (Annually) SERIAL OR ID NUMBER: PBS #9-XXXXXX TANK ID:#X PRODUCT STORED:GASOLINE WORKING CAPACITY:3,600 GALLONS TANK CAPACITY:4,000 GALLONS INSTALLED DATE:12/01/2000 TANK TYPE/MODEL #:STEEL/CARBON STEEL/IRON THIS TANK CONFORMS WITH 6 NYCRR PART 614 FOR ALL MOTOR FUELS

Stormwater Investigations: Summary Memo

Case Study: Highway Facility

? TRENCH DRAINS SEPTIC TANK KITCHEN SINK EXISTING OWS OLD NEW

Case Study: Highway Facility

Case Study: Park Facility

Observations / Lessons Learned Be prepared

Observations / Lessons Learned Be patient

Observations / Lessons Learned Expect the unexpected

Observations / Lessons Learned Expect the unexpected Kitchen Sink

Observations / Lessons Learned Expect the unexpected

Observations / Lessons Learned Verify as much as possible Document Everything

Observations / Lessons Learned Municipal employees are a wealth of knowledge Involve local regulatory agencies early in the process

Observations / Lessons Learned Designate one point of contact Regularly educate staff on federal and state regulations Update records regularly

Observations / Lessons Learned Remember the “basics” of design Remember the ultimate goal

Learning Objectives Revisited Get to know your facility Perform regular pollution prevention / good housekeeping Have basic understanding of applicable federal and state regulations as they relate to stormwater and petroleum bulk storage

Questions / Discussion 1. What two federal regulations related to stormwater and petroleum storage are municipal facilities governed by?

Questions / Discussion 2. What type of discharge does a SPDES permit regulate?

Questions / Discussion 3. What volume of above ground petroleum bulk storage will require your facility to prepare a SPCC plan?

Questions / Discussion 4. How often are you required to perform interstitial space leak testing for underground petroleum storage?

Questions / Discussion 5. Name two important lessons learned from this project.

Thank you. Wendel Jamie Johnson, PE Lauren Glose, EIT wendelcompanies.com