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THE UNIVERSITY OF MICHIGAN – FLINT

THE UNIVERSITY OF MICHIGAN – FLINT. Environmental Compliance with… 1- New NPDES Storm Water Management Permits 2- SPCC & Michigan PART 5 Requirements 3- Environmental Due Care Env ., Health and Safety & Facilities Management March 2010

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THE UNIVERSITY OF MICHIGAN – FLINT

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  1. THE UNIVERSITY OF MICHIGAN – FLINT Environmental Compliance with… 1- New NPDES Storm Water Management Permits 2- SPCC & Michigan PART 5 Requirements 3- Environmental Due Care Env., Health and Safety & Facilities Management March 2010 Portions of Training materials adopted from UM OSEH

  2. Storm Water Mgt. is strictly regulated… it dates back several decades • Federal Clean Water Act of 1972 • CWA amendments of 1987 required permits for storm water discharge (Phase I and II). • Federal Phase I SW Regulations began 1990 • Industrial Sites: certified ISW operator • Construction sites over 5 acres: requires SESC plans, weekly inspections by certified CSW operator • Municipalities over 100,000: public education, illicit connections, maximum extent practicable measures • Federal Phase II SW Regulations (1999) • Industrial Sites: about the same as above, certified operator • Construction sites 1-5 acres: w/ certified operator • Municipalities under 100,000: • Three permit options under Phase II: • General permit, Individual permit, or Modification –MS4 • UM ‘s renewed 2009 Combined Permit (AA, Dearborn & Flint) • UM-Flint’s pool discharge permit

  3. Michigan Env. Protection Regulations • Part 31, Water Resources Protection of NRP Act of 1994 • Empowers Director of MDEQ to protect & conserve water resources… adopt, establish/enforce rules, penalties • Prohibits pollution of state’s waters, etc. • Part 91, Soil Erosion and Sedimentation Control of NRP Act of 1994 • Requires control of soil erosion and sedimentation • Permits, SESC plans for “earth Changes” of one acre or more or any “earth change” within 500 feet of river, lake, stream… • Regulated by local, county or state • Authorized Public Agency (APA) • Part 301, Inland Lakes and Streams (1994) • Regulates activities in lakes/streams, requires permit, i.e dredging, SESC, etc • Part 303 Wetland Protection Act (1994) • Protected like other surface water from SW contamination • Part 17, Michigan Environmental Protection Act • Provides for citizens to bring legal action “for conduct that may pollute, impair, or destroy the air, water, or natural resources.” • Part 305 Natural Rivers Act (1970) • Regultes activities w/in 400 ft of “Natural River District” … building, removal of vegitation, land alteration, bridge work…

  4. The “Big Picture” of Storm Water Discharges

  5. So what does this mean for UM-Flint?* UM-Flint is in the Flint River Watershed * Stop pollutants from entering the Flint River… through storm drains or by runoff directly to the river or ditches that lead to the river* Report illicit discharges & spills immediately to Public Safety/EHS* Always use best management practices at work, home and play* Attend trainings and workshops * Encourage others to do the right thing

  6. UM Ann Arbor has been operating under a “Voluntary” NPDES permit dating back to the Federal Phase I (1990’s) Flint and Dearborn were required to comply w/ SW Regulations under Phase II by March 2003. UM has petitioned MDEQ to include the Flint and Dearborn campuses into the existing permit… all under “The Regents of UM”. NOW, All THREE campuses fall under one MDEQ (new renamed MDNRE) permit. Increased documentation, inspections, education/training for employees, contractors and the general public.

  7. UM Storm Water Permit Requirements (NPDES Permit # MIS049000) • Authorized Discharges - ONLY STORM WATER! • Some minor exceptions… irrigation, uncontaminated groundwater, potable water, foundation drains, lawn water runoff, water line flushing and discharge of potable water, non-commercial car washing, residual street wash waters, flows from emergency fire fighting activities. • Discharges Requiring Authorization • Use of Tracer Dyes • Use of Water Treatment Additives • Waste Water associated with concrete activities • Requires written authorization from MDNRE office, must coordinate with EHS &OSEH-EM to receive authorization • Dechlorinated swimming pool discharge requires separate NPDES permit- August 2009. • Discharge of “any pollutants” is prohibited.

  8. MDNRE Requires SWM Program~ Minimum Measures ~ • identify and map discharge locations • illicit discharge detection and elimination • pollution prevention and good housekeeping for site operations- Best Management Practices • construction site storm water runoff control • post-construction storm water management • employee and contractor training • public education and outreach • public involvement and participation NOTE: The current SWMP (Jan 2010) has been recently revised and comments on the document are being encourage over the next 30 days please be sure to participate in the review and provide your suggestions, etc. http://www.oseh.umich.edu/stormwater/SWMP2010.pdf

  9. UM-Flint’s Role (EHS, FM & others) complying w/ MDNRE Permit conditions • Review & adopt UM’s written SWMP (Jan 2010) • Implement & enforce best management practices with UM employees and contractors • Find & Eliminate Illicit Discharges and Connections • Post-Construction SW Mgt. for (Re)Development • > equal to 1 acre… or < 1 acre but part of a larger development • With in 500 feet of the River • Require to include structural and nonstructural BMPS i.e buffers, minimal disturbance of soil & vegetation, detention ponds, • Ensure isolation of storm drains from polluting materials… use of secondary containment, fabric filters, silt sacks, absorbent pads, etc. • Conduct & Participate in Public Education • residents, faculty, staff, students, visitors • Partner w/ City of Flint, FRWC, CAER & Outreach, others • Household Haz Waste and e-Waste Collection - 2x year

  10. complying w/ MDNRE Permit conditions • Construction Storm Water Runoff Controls • SESC requirement • Procedures to receive complaints from the public • Pollution Prevention & Good Housekeeping • Material storage & containment– drums, bags, dumpsters, stockpiles, etc. • Maintenance of Structural Controls– catch basins, sedimentation or infiltration basins, manage waste from drains • Street cleaning & catch basin maintenance, Reduce discharge of pollutantsassociated with maintaining streets • Ensure vehicle maintenance activities do not impact SW… discharge of wash water to SW drains is not authorized under permit. • Pesticides and Fertilizers– minimize discharge of pollutants related to handling, application and storage of chemicals BMPS required include employee training, soil testing to minimize application and treatments, • Assess Program, Annual Reporting to OSEH & MDEQ • Identify measurable goals, monitor progress and document everything… BMPS, spills, purchases, training, compliance expenses, etc

  11. complying w/ MDEQ Permit conditions

  12. Inlet Fabric Filters and Silt Sacks

  13. EHS and Facilities Mgt. preparation for UM SWM Annual Report to MDNRE • Time period April 2009 – July 2010 • Track frequency of storm/sanitary repairs • Map outfalls and test water quality at point of discharge • Street sweeping and related activities • Waste management – litter collection/disposal • Inspection and Maintenance on catch basins • Use of protective measures on drains • Spills and clean up • Parking lot & ramp cleaning/maintenance • Education and training, classes, brochures, bulletin boards, website, special events, etc. • Pesticide Management and related testing • Public outreach… FRWC, CAER, County planning boards, etc.

  14. EPA/MDEQ Requires 6 Minimum Measures in UM SW Mgt. Program EPA/MDEQ Requires 6 Minimum Measures in UM SW Mgt. Program Video Storm Water Pollution PreventionEveryday Best Management Practices (BMPs) • public education and outreach • public involvement and participation • illicit discharge detection and elimination • construction site storm water runoff control • post-construction storm water management, and • pollution prevention and good housekeeping for site operations.

  15. Storm water questions? Identify five (5) Best Management Practices that can be implemented by Housekeeping Staff? by Grounds keeping staff? Other staff? Identify three (3) past practices that should be avoided in the future? What material is permitted to be discharged down the UM storm drains? When do you need to call EHS? When do you call your supervisor?

  16. Spill Prevention Control and Countermeasure Plan (SPCC) • Plan required by the United States Environmental Protection Agency under 40 CFR part 112 • UMF SPCC Plan - 2003, rev 2006, rev 2009 PURPOSE: Plan outlines measures to prevent the discharge of OIL into the navigable waters.

  17. Spill Prevention Control and Countermeasure Plan (SPCC) • Definition of OIL – oil of any kind or in any form, including but not limited to: Petroleum fuel oil sludge oil refuse kitchen grease animal fats oil mixed with wastes

  18. Spill Prevention Control and Countermeasure Plan (SPCC) Who is Required to Implement a SPCC Plan? A facility that exceeds: Total UNDERGROUND storage capacity greater than 42,000 gallons or An aggregate or combined aboveground storage capacity greater than 1,320 gallons, and Reasonable expectation that a discharge could reach a navigable waterway.

  19. Spill Prevention Control and Countermeasure Plan (SPCC) What is required of a Facility under the regulations? 1. A written plan certified by a Professional Engineer (PE) every 3 years. 2. Oil storage management and control 3. U-M Facility Personnel involvement Routine inspections Spill prevention and spill control Best Management Practices Record keeping

  20. SPCC Plan RequirementsWritten Plan • State general information of the facility • Facility Response Coordinator and Alternate • Name of facility, address, phone numbers • Nearby surface water body/ distance • Facility Description • Description of campus • Facility drainage areas (storm water discharges to streams, creeks) • Oil storage, distribution and use (explain type of containers) • Spill history • Potential releases and prevention controls • Loading and unloading operations

  21. SPCC Plan RequirementsWritten Plan - Continued • Spill Response Plan • UMF has a effective ERP that serves as a guidance document. The ERP incorporates the criteria for oil removal contingency plans specified in 40 CFR Part 109. • Approximately 30 U-M personnel have completed the 32-hour Hazardous Waste Operations Emergency Response Technician/ Incident Command Level training. • Remedial action – Plan distinguishes between incidental spill nad emergency release • ERP available online at www.umflint.edu/ehs/ • Inspection schedule –(monthly, quarterly & annually) • Describe the routine inspection schedule • Current schedule was approved by the EPA in 2001

  22. SPCC Plan RequirementsWritten Plan - Continued • Personnel training • Oil handling personnel trained in • Become familiar with laws and regulations regarding spills, releases, and pollution control • Contents of the UMF SPCC plan (rev 2009) • Operation and maintenance of equipment to prevent discharges including performing the routine inspections.

  23. SPCC Plan RequirementsOil Storage Management and Control Oil storage management and control as stated in the regulations and in the written plan. • Lighting • Security • Secondary Containment • Catchment during loading and unloading fuel

  24. SPCC Plan RequirementsOil Storage Management and Control Lighting Per the EPA, as long as the oil storage area is accessible with a flashlight, this is considered adequate lighting. Security To assist in preventing spill or release from being caused by accidental or unknown entry or vandalism. Fenced area Padlocks Security guards Stored inside building

  25. SPCC Plan RequirementsOil Storage Management and Control Secondary Containment • Secondary containment is required for OIL containers with the capacity of 55 gallons or greater and is to prevent any spills from any leaking or damaged containers. • The secondary containment must have the capacity to hold the volume of the largest container or 10% of the combined containers, whichever larger. • If room has no floor drains, then the room itself may be considered sufficient secondary containment. If the room is considered the secondary containment ensure there is a lip at the door so no liquids can exit the room in the event of a leak.

  26. Secondary Containment

  27. SPCC Plan RequirementsOil Storage Management and Control Fuel Catchment The SPCC plan requires catchment to be in place during refueling operations from a tanker truck to an aboveground or underground storage tank that will hold the capacity of the largest inner single compartment of the delivery truck.

  28. Fuel Catchment

  29. SPCC Plan RequirementsUM-Flint Personnel Involvement • Container Inspections • Monthly and quarterly inspections • Trained oil-handling personnel should perform the routine inspections. OSEH & EHS provides assistance to the Facility Managers and Supervisors by explaining the environmental regulatory requirement and therefore relies on the FM and Supervisors to ensure the routine inspections are being performed on time. Container CapacityFrequencyPersonnel AST >= 55 gallons Quarterly Facilities Mgt. UST >= 55 gallons Quarterly* Facilities Mgt. Drums >= 55 gallons Monthly Facilities Mgt.. Transformers >= 55 gallons Quarterly Facilities Mgt./Electricians • Except FWT Library UST must be inspected monthly per Part 211 • EHS & OSEH will monitor & inspect at least annually

  30. SPCC Plan RequirementsUM-Flint Personnel Involvement Inspection Checklist Example (In handout) UMF Facilities Management has incorporated the monthly/quarterly inspections into their PM program Completed & signed inspections forms are forwarded to EHS, copies are kept with FM

  31. U-M Flint Oil Storage locations Total of 12 Tank inspections Total of 6 drums inspections

  32. SPCC Plan RequirementsUM-Flint Personnel Involvement Spill prevention and spill control Immediately block nearby drains. Contain all releases with absorbent material if the scene is safe. If the scene is not safe, contact DPS at 762-3335 and EHS at 766-6763. Record keeping All records must be kept on site for at least three years.

  33. SPCCTEST 1.The SPCC Plan regulates the following pollutant. a. Water b. Salt c. Oil • Soil 2. Which of the following is a form of oil that is regulated by 40 CFR 112? a. Kitchen grease b. Gasoline c. Diesel Fuel • All the above 3. How many years do the records need to be kept on file? a. 3 years b. 3 months c. forever • 7 years 4. Which containers are required to be inspected monthly? a. Underground storage tanks b. Aboveground storage tanks c. 55-gallon drums • All the above 5- Whenever loading/unloading oil products from a tanker truck, the FM employee must do which of the following: a. Apply drain blockers to the near by storm drains prior to fueling b. Stay with the vehicle while fueling • All the above 6- Who do you call FIRST in the event of an emergency release into the storm drain? • DPS & EHS • Young’s Environmental • City of Flint • Supervisor

  34. MI Part 5 RulesSpillage of Oil and Polluting Materials PURPOSE: The MI Part 5 Rules are intended to prevent releases of polluting materials to surface waters or ground waters of the state.

  35. MI Part 5 Rules • Chemicals affected by the MI Part 5 Rules • Oil • Salt • Any material specified in table 1 ( ~ 964 chemicals) • Any compound or product that contains 1%, or more, by weight, of oil, salt or any material listed table 1.

  36. MI Part 5 RulesMain Requirements 1. Secondary containment • Oil, Salt, or Compounds or products containing > 1% of any material listed in the Polluting Materials list and exceed the threshold management quantities of the following: • Salt, in solid form, at any location in a quantity greater than 5 tons • Salt, in liquid form, at any location in a quantity great than 1,000 gallons • Oil, stored aboveground in quantities greater than 1,320 gallons or in a single AST with a capacity of 660 gallons. NOTE: Oil storage and use does not need to be addressed in a the PIPP if a facility complies with 40 CFR 112 (SPCC Plan) • All other polluting materials at any discrete outdoor location in aggregate quantities greater than 440 pounds • All other polluting materials at any discrete indoor location in aggregate quantities greater than 2200 pounds.

  37. MI Part 5 RulesMain Requirements NOTE: Even without threshold quantities, secondary containment may still be needed • Local Sewer Use Ordinance to protect accidental release to the City of Flint sewers

  38. MI Part 5 Rules Main Requirements 2. Pollution Incident Prevention Plan (PIPP) Required if a facility exceeds the threshold management quantity for oil, salt, or any of the 964 polluting materials. Threshold management quantity is the total amount of chemical in one discrete area that determines if a facility is required to implement a PIPP and provide secondary containment. Contents of a PIPP (similar to SPCC Plan requirements) A. Identification Information • Facility • Parent corporation and owners • Facility description and operations • Spill clean-up responders

  39. MI Part 5 Rules Main Requirements 2. Pollution Incident Prevention Plan (PIPP) Contents of a PIPP Cont’d B. Materials used or stored on the polluting materials list. C. Storage tanks D. Spill prevention and control E. Spill response and clean up procedures F. Chemical Inventory G. Secondary Containment Structures

  40. MI Part 5 Rules (PIPP) Vs. SPCCSummary SPCC • 40 CFR Part 112 (FEDERAL) • Regulate oil products only • Require routine inspections on containers of OIL greater than 55 gallons • Plan required if storing 42,000 gal underground or an aggregate of 1320 gal of oil PIPP • MI Part 5 Rules (STATE) • Regulate oil, salt, and ~964 polluting materials • Don’t require routine inspections • Plan required if exceed threshold management quantity for oil (same as SPCC), salt, or the polluting materials

  41. PIPP TEST 1.The PIPP Plan regulates the following pollutant(s). a. Water b. Salt c. Oil • All the above 2. Where are the your department MSDSs located? a. CEP Control Room b. Hubbard Building front office c. Lunch room • Tim Barden Joel Ellis’ office 3. The PIPP is intended to prevent releases of polluting materials to surface waters or ground waters of the state. a. True b. False • Which of the following is part of the FM/CEP spill clean up procedures? • Notify the appropriate response coordinator • Sound the alarm and evacuate personnel • Attempt to control the situation • All the above • Who do you call FIRST in the event of an emergency release into the storm drain? • Young’s Environmental • DPS & EHS • Supervisor • Director

  42. Due Care Regulatory Requirements: ENVIRONMENTAL DUE CARE AT UM-FLINT

  43. Due Care Regulatory Requirements: • UM-Flint is subject to due care obligations for all activities that may disturb the soil/earth i.e. construction, maintenance, subsurface activities at the following properties: • WSW Building and surrounding areas including former Horse Barn • Former Perry Printing Site • Parking Lot A and all surrounding areas (CE/MGP) • Hubbard Compound • Northbank Center, NBC Parking Ramp and surrounding areas • Proposed Student Hosing Site and surrounding areas • The properties are classified as a “facility” (Part 201 of Act 451) because contamination has been detected in soil and/or groundwater at concentrations exceeding generic residential cleanup criteria. • UM and its contractors have legally enforceable responsibilities for ensuring that: • Its actions do not exacerbate existing contamination • The intended use of the property will not result in unacceptable exposures to hazardous substances • It takes reasonable precautions with regard to acts or omissions of third parties. • These requirements are a result of previous existing environmental site conditions that existed prior to UM acquiring the property.

  44. Due Care Regulatory Requirements: PERRY WSW CE MGP CEP USTs NBC STUDENT HOUSING

  45. Due Care Regulatory Requirements: • Notification to adjacent property owners, utility workers, contractors, state and local agencies. • Develop and implement property specific Due Care Plans for the contaminants found in the soil or groundwater at that location. • Internal/institutional controls… letter to FM Director, internal policies, distributed Due Care Plans, contractual language for construction projects… • Monitoring of site conditions, protective barriers, odors, staining of soil, sheen on water outfalls, etc. • Monitoring of site activities by employees and contractors… FM, Project Mgrs., EHS • Soil/groundwater sampling and analysis • Management of soils, groundwater, dewatering activities, spoils, decontamination, personal hygiene • Documentation

  46. How does this effect routine activities or planning projects at UM-Flint? • Notify EHS of subsurface work on campus… participate in preplanning of project/activity. • Proper selection of PPE for UMF employees… know the specific contaminants, their location and hazards in the work the area • Management of soils on site, replace protective cap/barrier • Manifest soils leaving site… Contact EHS. • Test/document clean soils on site…. Contact EHS 5-15 days ahead of time to allow for sampling of the source. • Monitor protective barriers that are in place • ECDC Playgrounds: GeoFabric at 12-18 inches below grade • WSW: 6-9 inches of clean topsoil • NBC: paved parking areas • PERRY: 2-4 feet of clean fill across the site • CE MGP: paved surface Lot A, some replaced soils near Rec Center, impacts and contamination is found DEEP under River and WSW Site 60-100 feet. • Housing & Kearsley Street- GeoFabric at 9 - 12 inches below grade • Inform contractors in writing, monitor compliance w/ established Due Care requirements

  47. SUMMARY • Nothing but water permitted down storm drains! Report spills immediately, protect drains if you can do so safely. • Due Care, SWM, SESC, SPCC, BMPs are all related… protecting our natural resources, preventing degradation of the surface water, reducing exposure to potentially harmful pollutants and ultimately protecting the public’s health . • Implement Best Management Practices into everyday work practice to comply with NPDES Permit and SWM Program. Provide feedback to EHS on SWMP over the next 30 days. • Plan ahead… incorporate BMPs into projects ahead of time regardless of the size of the project. • SESC Plan required for >1 acre or within 500 feet of River • Project Managers and Supervisors incorporate these requirements into SOPs, project specifications, monitor and enforce compliance with contractors and employees. • Use a Team Approach when complying with Env. Regulatory Requirements… FM, EHS/OSEH, Supervisors, Project Managers, Contractors, MDNRE… • Notify EHS of any subsurface work on campus.

  48. Questions Please contact Environment, Health and Safety at 766-6763 or 919-1709

  49. Soil Erosion &Sedimentation Control EROSION= Soil particles dislodged by wind, water, or gravity SEDIMENTATION= Soil particles deposited on land or in water bodies

  50. Rill Erosion Gully Erosion Washout

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