1. Storm Water Pollution Prevention Training
For Industrial Facilities
In the City of Memphis

2. City of Memphis Public Works- Storm Water Program
What is Storm Water?
4/21/2017
Storm water is water flowing over the land during and immediately after a rain storm.
Storm water does not flow into a wastewater treatment system, it flows into our surface waters
In the Memphis area, our storm water system consists of our gutters, storm drains, underground pipes, open channels, culverts, and creeks. Our storm water system discharges into the Wolf, Nonconnah, Loosahatchie and Mississippi Rivers.
What we do on the land affects the water quality and the habitat of our creeks and rivers. It also affects our quality of life, our fisheries, and our recreation.
Prepared by Hess Environmental Services, Inc.

3. Why do we have to do something to improve our storm water discharges?
City of Memphis Public Works- Storm Water Program
Why do we have to do something to improve our storm water discharges?
4/21/2017
In 1972, Congress passed the Clean Water Act and focused on point source pollution discharges to surface waters. Most point sources have been eliminated, others are permitted.
In 1990, the EPA began the National Pollutant Discharge Elimination System (NPDES) Permitting process to address non-point sources of pollution.
Industries have to have an NPDES Permit for their storm water discharges. The permit requires that industrial facilities have a Storm Water Pollution Prevention Plan (SWPPP), observe their discharges (some also have to sample) and work to implement Best Management Practices (BMPs) to minimize pollutants from leaving their facility.
Ask the class to define the difference between point and non-point sources of pollution and give examples.
Discuss Love Canal 1978, Lake Eerie.
Prepared by Hess Environmental Services, Inc.

4. City of Memphis’ Storm Water Program
As a result of an NPDES permit issued to the City of Memphis, the City is responsible for enforcing storm water pollution prevention requirements.
The City of Memphis is committed to an active role in the reduction of pollution and the protection of human health and the environment.
City facilities with industrial activities will be required to comply with the NPDES industrial permit regulations for their applicable sector beginning March 2003.

5. How do you achieve compliance with the NPDES permit?
Each facility needs its own SWPPP that addresses all potential pollutant sources and measures and controls needed to prevent pollution.
The facility must implement a quarterly facility inspection and document the inspections in an annual comprehensive site evaluation report and update SWPPP with new BMPs etc.
The facility must visually, and in some cases chemically, analyze its storm water runoff for signs of pollution.
BMPs must be implemented and, sometimes, engineering controls must be installed in order to prevent pollution from your facility.
Employees must be trained.

6. What is the goal of training employees about storm water?
City of Memphis Public Works- Storm Water Program
4/21/2017
What is the goal of training employees about storm water?
To stress the importance
of being AWARE of and
ALERT to conditions that
could result in the discharge
of pollutants to storm water!
To improve communication
employees and supervisors.
Prepared by Hess Environmental Services, Inc.

7. Employee training and improved communication could have helped here:
City of Memphis Public Works- Storm Water Program
Employee training and improved communication could have helped here:
4/21/2017
Tell story about purchasing and lack of communication causing environmental problems. This example: oil for a garbage compactor motor was ordered in the same quantity each year, regardless of the amount needed. The result: years of purchasing resulted in a unneeded stockpile of leaking drums.
Prepared by Hess Environmental Services, Inc.

8. Why is this a storm water problem?
City of Memphis Public Works- Storm Water Program
Why is this a storm water problem?
4/21/2017
Storm water comes in contact with the leaking drums and the petroleum contaminated soils in the area. This pollution then travels offsite in the storm water system.
Prepared by Hess Environmental Services, Inc.

9. City of Memphis Public Works- Storm Water Program
4/21/2017
What’s wrong here?
This is a fill port for a Used Oil Underground Storage Tank. The fill port is not adequate for pouring 55-gallon drums of used oil into.
Prepared by Hess Environmental Services, Inc.

10. City of Memphis Public Works- Storm Water Program
4/21/2017
…and here…
This is the outside of the building where the previous picture of the fill port is located. The spills that occur inside the building are able to release to the storm water.
Prepared by Hess Environmental Services, Inc.

11. What needs to happen here?
City of Memphis Public Works- Storm Water Program
What needs to happen here?
4/21/2017
The used oil fill port drains through this pipe to the underground storage tank below. The pipe is located in an area that may be driven over, in fact that is what had already happened.
At this point, state that these are examples of why we are here today. While we talk today, I want you to think of your facility and what potential pollutant sources there are.
…and what has already happened?
Prepared by Hess Environmental Services, Inc.

12. TRAINING TOPICS Vehicle Washing and Fueling
Fuel and Chemical Storage Activities
Sand/Soil Piles
Vehicle Parking Lots
Waste Containers and Drum Management
Outdoor Storage
Good Housekeeping
Preventive Maintenance
Spill Prevention and Response
Illicit Discharge Detection and Reporting

13. Non-storm water discharges must go to sanitary sewer
City of Memphis Public Works- Storm Water Program
4/21/2017
Non-storm water discharges must go to sanitary sewer
This means no washing vehicles outside!!!
STORY: There was an industrial facility that was required to perform analytical monitoring of its storm water discharges. It eliminated all outdoor storage and could not figure out why it was still exceeding its pollutant parameter cut off concentrations. It turned out that they had relocated a piece of equipment too close to the mop water discharge point to an oil water separator which discharged to the sanitary sewer. They did not know how much room was needed and didn’t find out. The woman that was working at night to wash floors at the facility began to unload the sweeper’s discharges into the storm drain outside. She didn’t know it was a big deal and didn’t communicate about it.
Lessons: training and communication with those performing the work when doing the decision making.
Ask the trainees if they understand the difference between the storm and sanitary sewer systems?
Prepared by Hess Environmental Services, Inc.

14. This means no washing vehicles outside!
City of Memphis Public Works- Storm Water Program
4/21/2017
This means no washing vehicles outside!
This picture is at a garbage truck transfer facility that is now closed. What do you think they were washing here? Is it possible that they were washing out the garbage trucks…
Prepared by Hess Environmental Services, Inc.

15. Fuel and Chemical Storage Activites
City of Memphis Public Works- Storm Water Program
Fuel and Chemical Storage Activites
4/21/2017
These were Above Ground Storage Tanks containing oil and antifreeze for fleet maintenance. The vehicles were also fueled at this location.
Prepared by Hess Environmental Services, Inc.

16. Fuel and Chemical Transfer Activities
City of Memphis Public Works- Storm Water Program
4/21/2017
Fuel and Chemical Transfer Activities
Consider how fuels and chemicals are transferred day to day to the fleet.
Evaluate and institute transfer procedures for fuels and chemicals from tank trucks to the ASTs and USTs at our facilities.
Implement Engineering Controls
Report Spills
Clean Up Spills
It is our responsibility to make sure that our vendors do not cause spills on our properties. It is ultimately our responsibility and not theirs to respond to those spills; therefore, we must make sure that we prevent them!!!
Is your facility required to have a Spill Prevention, Control and Countermeasures (SPCC) Plan? If so who is on your SPCC Team and who is trained to respond to spills?
Prepared by Hess Environmental Services, Inc.

17. What BMPs would have helped prevent the pollution leaving this site?
City of Memphis Public Works- Storm Water Program
4/21/2017
What BMPs would have helped prevent the pollution leaving this site?
Secondary containment for tanks and piping; automatic cutoff controls (overfill protection); training; spill response equipment (not only used but also swept up) etc.
Also ask the trainees if they see another pollution source leaving the site in this picture: it is the non-storm water discharge running from the right side of the picture. In this case it was a hose where people cleaned out trucks/washed vehicles.
Prepared by Hess Environmental Services, Inc.

18. Cover sand and soil piles to prevent pollution!!
City of Memphis Public Works- Storm Water Program
4/21/2017
Cover sand and soil piles to prevent pollution!!
It is required by the NPDES permit
Prepared by Hess Environmental Services, Inc.

19. Drums must be sealed with covers and bungs
And preferably inside a secondary containment area!!

20. City of Memphis Public Works- Storm Water Program
4/21/2017
Waste products must be stored in covered drums and staged in an assigned area with secondary containment.
What will happen when rainwater fills up this open topped container?
Prepared by Hess Environmental Services, Inc.

21. Outdoor Storage Areas ANYTHING STORED OUTSIDE MUST BE CLEANED OF CHEMICAL RESIDUES, PROPERLY CONTAINED, AND WE NEED TO CONSIDER WHY WE ARE KEEPING IT, AND FIGURE OUT HOW TO GET RID OF IT OR STORE IT INSIDE EACH FACILITY’S OUTDOOR STORAGE MUST BE ADDRESSED…

22. Good Housekeeping Prevents Pollution
Minimize exposure, inspect and report, cleanup spills and leaks promptly

23. Absorbent material placed on a spill…

24. …will end up at the outfall if not swept up!!!

25. Good Housekeeping Inside Buildings to Prevent Pollution
Make sure that there are no discharges from the building to storm water through doorways or other pathways
Make sure that spill response equipment is readily available throughout building to contain leaks and spills
Clean the floors and do not allow the wash water to discharge outside
Have a comprehensive chemical storage and management plan, specify co-located areas and accumulation amounts for vendor pick-ups

26. Vehicle Storage Areas Must Be Cleaned To Prevent Pollution

27. City of Memphis Public Works- Storm Water Program
4/21/2017
What needs to happen here?
Follow up with next slide after the trainees discuss the need for preventative maintenance.
Prepared by Hess Environmental Services, Inc.

28. Preventative Maintenance
Daily inspections of equipment and storage
Regular maintenance of equipment
Routine sediment/debris removal and surface cleaning of storm water management devices such as:
oil-water separators, ponds, inlets, ditches, & secondary containment of fuel farm

29. All types of outfalls…
…all need maintenance and cleaning

30. Leaking vehicles/equipment stored outside should be drained, absorbent material placed to capture releases

31. Spill Response
Clean all small fuel spills and leaks, and to report significant fuel spills or leaks to management immediately!
Always document spills in the SWPPP and SPCC plan in order to learn from mistakes
REMEMBER SPILLS ARE CAUSED, THEY DO NOT JUST HAPPEN!!

32. Spill Prevention and Response
1. Contain
2. Locate and Stop the Source
3. Clean Up
4. Dispose of Properly
5. Notify Pollution Prevention Team Members
6. Document Release and/or Report if over the applicable threshold
7. Follow Up:
- Evaluate changes needed and modify SWPPP
- Implement changes
- Replace spill response equipment used

33. Again, sweep up the spill absorbent materials!

34. Review of NPDES Permit Requirements for Industrial Facilities
Develop a Storm Water Pollution Prevention Plan
Conduct Quarterly Facility Inspections
Conduct Quarterly Visual (Sometimes Chemical) Examination of Storm Water
Conduct Annual Comprehensive Site Compliance Evaluation
Conduct Annual Pollution Prevention Training

35. Annual Comprehensive Site Compliance Evaluation
City of Memphis Public Works- Storm Water Program
4/21/2017
Annual Comprehensive Site Compliance Evaluation
Evaluate areas contributing storm water discharge associated with industrial activity for evidence of, or the potential for, pollutants entering the drainage system.
Measures to reduce pollutant loadings shall be evaluated to determine whether they are adequate and properly implemented in accordance with the terms of the permit or whether additional control measures are needed.
Structural storm water management measures, and other structural pollution prevention measures identified in the plan shall be observed to ensure that they are operating correctly.
Prepared by Hess Environmental Services, Inc.

36. Storm Water Hotline
Call to report information about illicit discharges or other problems that you detect

37. Visualize cleaner industrial facilities in Memphis… We can do it!!!