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Things Aren’t Always What They Seem A Stormwater Pollution Prevention / Good Housekeeping Case Study in Western New York
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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
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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
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Western New York
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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
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Stormwater Investigations: Preparation
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Stormwater Investigation: Site Visit
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Stormwater Investigation: SPCC Petroleum Bulk Storage (PBS) Aboveground Storage Tanks (AST) Underground Storage Tanks (UST) 55 Gallons Drums
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Stormwater Investigation: PBS Aboveground Storage Tank (AST) Label Secondary Containment Fill Port Color Coding Diesel – Yellow Gasoline – White w/ Black Cross Fuel Gauge
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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
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Stormwater Investigations: Summary Memo
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Case Study: Highway Facility
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? TRENCH DRAINS SEPTIC TANK KITCHEN SINK EXISTING OWS OLD NEW
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Case Study: Highway Facility
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Case Study: Park Facility
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Observations / Lessons Learned Be prepared
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Observations / Lessons Learned Be patient
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Observations / Lessons Learned Expect the unexpected
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Observations / Lessons Learned Expect the unexpected Kitchen Sink
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Observations / Lessons Learned Expect the unexpected
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Observations / Lessons Learned Verify as much as possible Document Everything
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Observations / Lessons Learned Municipal employees are a wealth of knowledge Involve local regulatory agencies early in the process
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Observations / Lessons Learned Designate one point of contact Regularly educate staff on federal and state regulations Update records regularly
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Observations / Lessons Learned Remember the “basics” of design Remember the ultimate goal
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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
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Questions / Discussion 1. What two federal regulations related to stormwater and petroleum storage are municipal facilities governed by?
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Questions / Discussion 2. What type of discharge does a SPDES permit regulate?
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Questions / Discussion 3. What volume of above ground petroleum bulk storage will require your facility to prepare a SPCC plan?
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Questions / Discussion 4. How often are you required to perform interstitial space leak testing for underground petroleum storage?
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Questions / Discussion 5. Name two important lessons learned from this project.
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Thank you. Wendel Jamie Johnson, PE Lauren Glose, EIT wendelcompanies.com 877.293.6335 716.688.0766
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