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Pollution Prevention and Good Housekeeping Activities for Municipal Operations Developing the Storm Water Pollution Prevention Plan Presenter: Keith Noble, Saginaw Bay District Office
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How to develop a Storm Water Pollution Prevention Plan
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Who needs to develop the Storm Water Pollution Prevention Plan
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Including the following municipal operations: Airports Wastewater Treatment Plants (1MGD+) Maintenance facilities for bus and waste Hauling vehicles Land fills Land Applications sites Facilities regulated by the industrial storm water regulations
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Municipal owned or operated facilities that are not designated by the Industrial Storm Water regulations, which meet any of the following criteria, must develop and implement a SWPPP.
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There are storm water discharges to surface waters of the state Facilities will need to develop a SWPPP if:
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They meet the definition of a storage yard
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There is a fleet and maintenance activities for the fleet are conducted outside
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Maintenance is performed outside
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There is evidence of poor housekeeping
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Information on who needs to develop the SWPPP is in the Pollution Prevention and Good Housekeeping Activities for Municipal Operations compliance assistance document available on the DNRE storm water web site http://www.michigan.gov/deqstormwater
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The industrial storm water certified operator training provides instruction for the development and implementation of the SWPPP Contact District Water Bureau Staff to schedule training Certified Operator Training
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The Industrial Storm Water Certified Operator Training Manual is located @ http://www.michigan.gov/deqstormwater on the Industrial Program page. http://www.michigan.gov/deqstormwater Certified Operator Training
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The SWPPP needs to be developed and implemented by the due date for the SWPPI or SWMP For municipalities that are permitted under the watershed general permit they must have a industrial storm water certified operator unless the SWPPP is submitted as part of the SWPPI.
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Storm Water Pollution Prevention Plan (SWPPP)
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A lengthy plan is not necessarily an effective plan.
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Pollution Incident Prevention Plan (PIPP) (Part 5 Rules) Liquid Polluting Materials
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Solid Polluting Materials
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Spill Prevention Countermeasures and Control Plan (SPCC) (40 CFR 112) Oil Pollution Prevention
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Ethanol Plants Asphalt Plants
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Integrated Contingency Plans Typically include all environmental, health, and safety plans including SWPPP, PIPP, and SPCC
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Sample plans can be obtained from the DNRE district offices.
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SWPPP Requirements
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SWPPP must identify Significant Materials both outside… and inside the facility
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Goal Prevent the contamination of the surface waters of the state Sediment
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Remember…preventing pollution is the BEST SOLUTION
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Developing a SWPPP Storm Water Pollution Prevention Plan Source Identification Source Identification Non-Structural Controls Non-Structural Controls Structural Controls Structural Controls
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Site Map Development Source Identification
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Site map must show everything relevant to storm water Source Identification
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Identifying Significant Materials Source Identification
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Soils
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Salt
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Raw Materials Source Identification
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Fuels and Lubricants Source Identification
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Solvents and Detergents Source Identification
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Fertilizers and Pesticides Source Identification
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Waste Products Source Identification
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Polluting Materials Source Identification
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Wastewater
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Building Materials Source Identification
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All sources of contamination need to be identified Source Identification
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Remember The outside and inside of the facility must be evaluated Source Identification
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Significant Material Inventory Source Identification
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Pollutant Sources Source Identification
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Loading, unloading, and other material handling operations Source Identification
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Outdoor storage including secondary containment structures Source Identification
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On-site waste disposal practices Source Identification
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Maintenance and cleaning of vehicles, machines, and equipment Source Identification
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Areas of exposed and / or erodible soils Source Identification
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Sites of Environmental Contamination, under Part 201 Source Identification
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Other areas where storm water may contact significant materials Source Identification
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Inventory exposed materials and evaluate method of exposure Source Identification
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Listing of Significant Spills Source Identification
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Spill Report shall include: Date Volume Location of release Actions taken to clean up material Source Identification
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If a release occurs… It shall be managed in accordance with the SWPPP The SWPPP shall be updated to include corrective actions within 14 calendar days Source Identification
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Storm Water sampling IS NOT a requirement at most municipal facilities that develop a SWPPP Source Identification
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Developing a SWPPP Storm Water Pollution Prevention Plan Source Identification Source Identification Non-Structural Controls Non-Structural Controls Structural Controls Structural Controls
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Non-Structural Controls
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8 Non Structural Controls 1. Preventative Maintenance / Routine Inspections 2. Comprehensive Inspections 3. Good Housekeeping 4. Material Handling & Spill Prevention / Response Non-Structural Controls
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5. Sedimentation & Erosion Control 6. Employee Training 7. TMDL requirements 8. Significant Materials Present Non-Structural Controls
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1.Preventative Maintenance Non-Structural Controls
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Identifying and Preventing Breakdowns Non-Structural Controls
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Preventative Maintenance Program Description EquipmentTasksFrequency Silt Sacks Clean and Replace if needed After significant rain events Detention Pond Inspect outfall and remove collected debris if needed Every other month Fleet Vehicles Oil change and check over Every 3000 miles Non-Structural Controls
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Routine Inspections Responsibility of the Certified Operator or Storm Water Program Manager Recommended every two weeks Must be documented Non-Structural Controls
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Focus on areas that have a greater potential to contaminate storm water Non-Structural Controls
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Inspections should include: Non-Structural Controls Housekeeping activity areas Preventative maintenance items Material handling areas Fueling areas Etc.
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Non-Structural Controls
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2.Comprehensive Site Inspections Non-Structural Controls
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COMPREHENSIVE site inspection must be conducted quarterly or on an alternative schedule approved by the Department Non-Structural Controls
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All controls should be evaluated Non-Structural Controls
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Document comprehensive site inspections Responsible of the Certified Operator or smp Non-Structural Controls
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A schedule for COMPREHENSIVE site inspections must be identified in the SWPPP Non-Structural Controls
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3.Good Housekeeping Practices Non-Structural Controls
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Operation and Maintenance Procedures Non-Structural Controls
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Material Storage Practices and Inventory Procedures Non-Structural Controls
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Employee Participation Non-Structural Controls
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Housekeeping Procedures and Schedule Area/TaskTasksFrequency Chip & Refuse Dumpster Storage Area Inspect the area for spillage or leakage At the end of each shift Loading Dock Sweep collected material At the end of each shift Pallet Storage Area Inspect for cleanliness Every Friday Rack Storage Area Inspect for cleanliness Every Friday Non-Structural Controls
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4.Material Handling and Storage Procedures Non-Structural Controls
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Tracking spilled materials outside Non-Structural Controls
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Loading and Unloading Procedures Non-Structural Controls
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Poor material storage location Non-Structural Controls
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Material storage procedures Non-Structural Controls
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Avoid storing liquids near drains Non-Structural Controls
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Avoid storing leaky items near drains Non-Structural Controls
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Avoid storing flammable materials near heat Non-Structural Controls
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Avoid storing acids and bases near each other BOOM!!! Non-Structural Controls
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Avoid stacking materials too high
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Barrier posts in high risk areas Non-Structural Controls
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Proper labeling of containers Non-Structural Controls
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Barrels and Drums stored outside must be kept off the ground Non-Structural Controls
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Critical Materials in secondary containment Non-Structural Controls
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Spill Prevention & Response Non-Structural Controls
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Identify Spilled Material Contact SupervisorProtect Storm Drain Big Spill Contain Spill Hire Contractor Write Report Small Spill Clean Spill Dispose of Material Appropriately Non-Structural Controls
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Avoiding spills is economically preferred Non-Structural Controls
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Identifying Potential Spill Areas Non-Structural Controls
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Material Handling & Storage Procedures Non-Structural Controls
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Detailed clean-up procedures Spill kit locations Clean-up equipment Clean-up personal Phone numbers Non-Structural Controls
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Area Materials Present Response Plan Location Fuel Bay Absorbent Material, Absorbent Pads, Absorbent Booms Shift Supervisor’s Office Loading Dock Absorbent Material, Absorbent Pads, Absorbent Booms Shift Supervisor’s Office Chemical Storage Area Absorbent Material, Absorbent Pads, Absorbent Booms Shift Supervisor’s Office Non-Structural Controls
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In the event of a spill Non-Structural Controls
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DNRE Pollution Emergency Alert System (PEAS) 1-800-292-4706 Non-business hours Non-business hours Call the District Office During business hours During business hours Make sure a message is left with a person not an answering machine. Make sure a message is left with a person not an answering machine. Non-Structural Controls
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Spill report form is available on the DNRE website Non-Structural Controls
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5.Soil Erosion and Sedimentation Control Non-Structural Controls
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Erosion and Sedimentation Control Measures Area Of Concern Control Measures Gravel Parking Lot Catch Basin Inserts Detention Pond Outfall Rip Rap around the culvert and in the spill way Access Road Over Roadside Ditch Stone Filter Berm Non-Structural Controls
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Outlet pipes to ditches and streams Non-Structural Controls
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Culverts and Stream Crossings Non-Structural Controls
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Areas with exposed soils Non-Structural Controls
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Gravel / Dirt lots Non-Structural Controls
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DNRE Construction Storm Water Manual Non-Structural Controls The is available to download on the DNRE Storm Water Website on the Construction Site Program page. The Construction Site Certified Operator and SESC Training Manual is available to download on the DNRE Storm Water Website on the Construction Site Program page.
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6.Employee Training Non-Structural Controls
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Preventative Maintenance and Good Housekeeping Non-Structural Controls
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Spill prevention and response Non-Structural Controls
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Internal spill reporting procedures Non-Structural Controls
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Employee Training Schedule Topic Employees Included Frequency Good Housekeeping Practices All Employees Time of Hire & Annually Spill Prevention & Response 1) All Employees 2) Response Team 1) Time of Hire & Annually 2) 6 Months Internal Spill Reporting Procedures All Employees Time of Hire & Annually Non-Structural Controls
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Training events need to be documented Non-Structural Controls
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7.Total Maximum Daily Loads (TMDLs) Non-Structural Controls
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TMDL is the process used to determine how much pollutant load a lake or stream can handle from point and nonpoint sources. Non-Structural Controls
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Contact your district staff for specific TMDL information If the TMDL is listed in the Certificate of Coverage issued to the Municipality If a TMDL applies to your receiving waters, controls to meet the TMDL are required in your SWPPP Non-Structural Controls
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8. Significant Materials still present Non-Structural Controls
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Unnatural turbidity Non-Structural Controls
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Sediment deposit
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Unnatural oil film Non-Structural Controls
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Unnatural foam Non-Structural Controls
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If pollutants still remain after non-structural controls, structural controls will have to be installed. Non-Structural Controls
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Industrial Storm Water Certified Operator Class Provides Training On Specific Pollution Prevention Measures
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Fueling Stations Activity Specific Controls
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Vehicle and Equipment Maintenance Activity Specific Controls
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Controls for Painting Operations Activity Specific Controls
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Controls for washing: Equipment Vehicles Activity Specific Controls
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Equipment and vehicle wash water is not authorized
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Storm sewer inlet Vehicle wash water
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Controls for Loading and Unloading Operations Activity Specific Controls
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Controls for liquid storage in above ground tanks
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Controls for outside storage of materials
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Controls For Outside Waste Disposal Areas Activity Specific Controls
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Controls For Dewatering Activity Specific Controls
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Cease the discharge
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For dewatering on emergency repair jobs Do not discharge directly into: Storm Sewers Surface Waters Discharge into: Stone Dense growth of vegetation
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Catch Basin Protection Catch Basin Insert Activity Specific Controls
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Straw bales are not effective
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