2.0 GENERAL SITE INFORMATION .................................................................. 2 2.1 FACILITY IDENTIFICATION ..................................................................... 2 2.2 PHYSICAL CHARACTERISTICS .............................................................. 2
2.2.1 Facility Layout ..................................................................................... 2 2.2.2 Relief and Drainage ............................................................................ 3 2.2.3 Climate ................................................................................................ 3 2.2.4 Regional and Site Geology ................................................................. 3
3.0 PRIMARY RESPONSE TOOLS .................................................................... 5 3.1 Emergency Coordinators (Spills or Releases to Environment) .................. 5 3.2 Criteria to Implement CMWA Integrated Contingency Plan (ICP) .............. 6 3.3 Implementation of CMWA Integrated Contingency Plan (ICP) .................. 7
3.3.1 Immediately Upon the Discovery of an imminent, or Actual, Emergency Situation ........................................................................... 7
3.6.1 State Follow-Up ................................................................................ 11 3.6.2 Federal Follow-Up ............................................................................ 11
4.0 GROUNDWATER PROTECTION PLAN .................................................... 13 4.1 Implementation Team .............................................................................. 13 4.2 Identification of Covered Activities under GWPP..................................... 13 4.3 STEEL DIVISION PLANT ........................................................................ 15
4.7.3 Wastewater Treatment Area ............................................................. 23 4.7.4 Hazardous Materials/Waste Storage Area ........................................ 23 4.7.5 ALUMINUM DIVISION PLANT ......................................................... 24
4.7.5.1 Existing Plant Area Activities ...................................................... 24 4.7.5.2 Rolloff Storage Area ................................................................... 25 4.7.5.3 Pole Barn ................................................................................... 26 4.7.5.4 Oil Storage Room ....................................................................... 26
Integrated Contingency Plan April 2015 CMWA; Paris, KY Page ii
5.0 SPILL PREVENTION CONTROL AND CONTERMEASURES PLAN ........ 27 5.1 Applicability ............................................................................................. 27 5.2 Definition of Terms .................................................................................. 28 5.3 Review and Amendments ....................................................................... 30 5.4 Facility Drainage and Layout ................................................................... 30 5.5 Potential Spill Sources ............................................................................ 31
5.5.1 STEEL DIVISION Building ................................................................ 32 5.5.2 ALUMINUM DIVISION Building ........................................................ 36 5.5.3 Pole Barn .......................................................................................... 38 5.5.4 Wastewater Treatment Oil Storage Area .......................................... 39
5.6 Emergency Procedures Posting .............................................................. 39 5.7 Inspection Procedures ............................................................................. 40 5.8 Inspection Records .................................................................................. 42 5.9 Safeguards for New and Existing Equipment .......................................... 42
6.0 STORMWATER BEST MANAGEMENT PLAN ........................................... 44 6.1 Background ............................................................................................. 44
6.9.1 Hazardous Materials Storage Area ................................................... 53 6.9.2 Industrial Storing/Handling Inside Main Facilities .............................. 54 6.9.3 Shipping/Receiving Areas ................................................................. 54 6.9.4 Rolloff Storage Area – STEEL DIVISION .......................................... 54 6.9.5 Wastewater Treatment Area ............................................................. 54 6.9.6 Dust Collectors ................................................................................. 54 6.9.7 Salt Storage ...................................................................................... 54
6.10 Summary of Stormwater Sampling Data ............................................... 54 6.11 Corrective Action Reports and SWPPP Modification ............................. 55 6.12 History of Past Spills and Leaks ............................................................ 56
7.0 EMERGENCY PROCEDURES FOR HAZARDOUS WASTE ..................... 58 7.1 Emergency Coordinators ......................................................................... 58 7.2 Implementation of Emergency Response Procedures ............................ 58 7.3 List of Emergency Equipment for Hazardous Waste Purposes ............... 58 7.4 Coordination Agreements and Quick Reference Guide ........................... 59 7.5 Evacuation Plan ...................................................................................... 60 7.6 Required Reports .................................................................................... 60 7.7 Identification of Hazardous Materials ...................................................... 60 7.8 Procedure for Proper Control of Waste Generated ................................. 60
8.0 TRAINING ................................................................................................... 62 8.1 Spill Prevention and Response ............................................................... 62
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8.1.1 Enhanced Training ............................................................................ 62 8.2 Good Housekeeping ................................................................................ 63 8.3 Inspections .............................................................................................. 64 8.4 Tools for a Successful Training Program ................................................ 64 8.5 How Often to Conduct Training ............................................................... 64 8.6 Training Documentation .......................................................................... 63
9.0 MEASURES AND CONTROLS .................................................................. 66 9.1 General Activities .................................................................................... 66
9.1.1 Good Housekeeping ......................................................................... 66 9.1.2 Operation and Maintenance Practices .............................................. 66 9.1.3 Material Storage Practices ................................................................ 67 9.1.4 Material Inventory Procedures .......................................................... 67 9.1.5 Employee Participation ..................................................................... 68
9.2 Total Productive Maintenance - TPM ...................................................... 68 9.2.1 Identification of Equipment to Inspect ............................................... 68 9.2.2 Visual Inspections ............................................................................. 69 9.3 Spill Prevention and Response ............................................................ 70
10.0 ANNUAL SITE COMPLIANCE INSPECTION ........................................... 73 10.1 Plan Revisions ........................................................................................ 74
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TABLES
Table 1 Bulk Petroleum/Oil Storage
FIGURES
Figure 1 Site Location Plan Figure 2 General Location Map Figure 3 STEEL DIVISION Facility Layout Figure 4 ALUMINUM DIVISION Facility Layout Figure 5 Geologic Map Figure 6 Wastewater Treatment Facility Figure 7 Surface Water Flow Path
APPENDICES
Appendix A Certification Forms Appendix B Employee Training Records Appendix C Spill Response Procedures Appendix D Spill Response Instruction and Spill Reporting Form Appendix E Groundwater Protection Practices Appendix F No Substantial Harm Certification Appendix G SPCC Inspection Records Appendix H List of Significant Spills and Leaks Appendix I Copy of NOI-KYR00, KYR003305 Coverage Letter, and General KPDES Permit KYR000000 Appendix J Non-Stormwater Certification Appendix K Daily Precipitation Log Appendix L Control Measures Maintenance and Repair Log Appendix M SWPPP Inspection Reports: Quarterly and 2-year, 24-hour Events Appendix N Outfall Inspection Form Appendix O Annual Comprehensive Site Inspection Report Appendix P Revision History
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SPCC CROSS REFERENCE
40 CFR 112 REFERENCE PLAN SECTION
Subpart A – General Requirements
112.1 – Purpose and Applicability (optional text) 5.0 and 5.1
112.3(d), 112.5(c)– PE Certification 5.3 and Appendix A
112.3(e)– Availability of the Plan (optional text) (Maintain a complete copy at the facility)
5.3
112.4 – Written Notification to Federal Agencies (optional text) (Submit to EPA when discharge >1000 gals or have two releases within one year >42 gal each )
3.2 and 3.6.2
112.5(a) – Amendments to plan caused by facility changes (optional text)
(Changes to design, construction, O&M )
5.3
112.5(b) – Five-Year Review (optional text) 5.3
112.7 – Management Approval 5.3 and Appendix A
112.7 – Plan Sequence (Follows 40 CFR 112 or Cross Reference locates requirements of 40 CFR 112)
Pages i-iv of SPCC Cross Reference Table
112.7(a)(3) – Facility Description (Layout of facility, includes a description of site drainage)
5.4
112.7(a)(3) – Facility Diagram (Must include each AST, UST, contents, capacities, loading/unloading area, and associated piping)
Figure 3 and Figure 4
112.7(a)(3)(i) – Type of oil and capacity of each container Table 1
112.7(a)(3)(ii) – Discharge Prevention Measures (Loading/unloading and transfer procedures) 5.5
112.7(a)(3)(iii) – Discharge/drainage controls (Secondary containment, equipment, and procedures to control discharge)
5.5
112.7(a)(3)(iv) – Spill discovery, response, and cleanup. (Include Facility and contractor capabilities, i.e. list of spill clean up materials)
7.4, 9.3, Appendix C, Appendix D
112.7(a)(3)(v) – Disposal Plan (Methods of disposal of recovered materials in accordance with regulations)
Appendix C
112.7(a)(3)(vi) – Contact List (NRC, EPA, State Environmental Agency, LEPC, Spill Response Contractors [if applicable])
3.3 and Appendix C
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SPCC CROSS REFERENCE – Continued
40 CFR 112 REFERENCE PLAN SECTION 112.7(a)(4) – Spill Reporting Procedures (Location, time, material, quantity, source, control actions)
3.5 and 3.6
112.7(b) – Spill Prediction (Discuss direction, rate of flow, total quantity of oil discharged as a result of failure from major equipment)
5.5
112.7(c) – Facility-wide Containment to Prevent any Oil Spills from Leaving the Facility (Dikes/berms/walls, curbing, culverts/gutters, weirs/booms, diversion ponds, retention ponds, sorbent materials)
5.5 and Table 1
112.7(d) – If Containment is Not Practicable explain why impractical; Oil Contingency Plan (If impractical conduct tank integrity and integrity/leak tests on piping and valves. **Note: Cost of installation/construction does not make addition of secondary containment infeasible.)
Not Applicable
112.7(e) – Inspections, Tests, Records (Written procedures, records of tests/inspections signed by appropriate supervisor/inspector must be filed with SPCC Plan for three years except for tank testing records)
5.8 and 5.9
112.7 (f) – Personnel Training & Spill Prevention Briefings 8.0
112.7(f)(2) – Discharge Prevention and Emergency Coordinator Assigned (i.e. Emergency response coordinator or environmental coordinator)
3.1
112.7(g) – Security; Fencing; Lighting 2.2, 5.7 and Figure 7
112.7(h) – Facility Tank Car and Tank Truck Loading/Unloading Rack Not Applicable
112.7(i) – Brittle Fracture Damage to Aboveground Storage Tanks (If field erected tank undergoes a repair, alteration, reconstruction, or service change that might affect risk of discharge due to brittle fracture or has failed due to brittle fracture, tank must be evaluated for risk of discharge/failure due to brittle fracture or other catastrophe)
5.7
112.7(j) – Conformance with State or Local Spill Prevention Rules Not Applicable
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SPCC CROSS REFERENCE – Continued
40 CFR 112 REFERENCE PLAN SECTION
Subpart B – Requirements for Petroleum Facilities (112.8)
112.8(b)(1) – Manual Drainage from Dikes (Restrain drainage from containment areas using manually activated valves or manually activated pumps.)
5.5.4
112.8(b)(2) – Inspection of Rainwater Prior to Release (Inspect for sheen) 5.7 and 6.3
112.8(b)(3) – Areas Without Dikes (Designed to flow into ponds/lagoons/basin designed to retain oil or return it to facility)
Not Applicable
112.8(b)(4) – Ditches to Retain Oil Within Facility Boundary (Drainage Diversion System) (If no dikes or ponds, then diversion system or other method of containment that would retain release in facility)
Not Applicable
112.8(b)(5) – Treated Drainage (If a treatment system is used for containment it must be engineered to prevent a discharge)
Not Applicable
112.8(c) – Bulk Storage Tanks and Containers 5.5 and Table 1
112.8(c)(1) – Compatibility (Materials/construction compatible with material stored and conditions of storage)
5.5 and Table 1
112.8(c)(2) – Secondary Containment (Contain entire capacity of largest tank plus precipitation, sufficiently impervious)
5.5 and Table 1
112.8(c)(3) – Drainage from Tank Farm Areas (Manually operated valves or pumps, inspect for sheen prior to release, document release and file with records)
Not Applicable
112.8(c)(4) – Buried Metallic Storage Tanks (not registered, i.e. heating oil tanks) (Protective coatings in place, cathodic protection)
Not Applicable
112.8(c)(5) – Partially Buried Storage Tanks (Buried section has protective coating and cathodic protection)
Not Applicable
112.8(c)(6) – Tank Integrity Testing (Visual inspection in addition to another testing technique – not necessary for elevated and shop fabricated tanks or drums, but it must be stated that it is not necessary)
5.7
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SPCC CROSS REFERENCE – Continued
40 CFR 112 REFERENCE PLAN SECTION 112.8(c)(7) – Tank Internal Heating Coils (Monitor steam return and exhaust lines or pass the blow down through an oil/water separator)
112.8(c)(9) – Inspection of Treated Plant Effluents 5.7
112.8(c)(10) – Correct Deficiencies (Correct visible discharges, remove accumulation of oil in diked areas)
5.5
112.8(c)(11) – Mobile Portable Storage Tanks (Positioned to have containment)
5.5
112.8(d) – Facility Transfer Operations 5.9
112.8(d)(1) – Buried Piping; Exposed Buried Piping Must be Visually Inspected (Piping installed after 8/16/02 must have cathodic protection, protective wrapping and coating)
Not Applicable
112.8(d)(2) – Out of Service Piping (Capped/blank flanged, marked as to origin)
5.9
112.8(d)(3) – Pipe Supports (Minimize abrasion and corrosion, allow for expansion/contraction)
5.5
112.8(d)(4) – Inspection of Aboveground valves and Pipelines; Buried Piping must be Integrity Tested at Time of Installation, Modification, Relocation, or Replacement (Visual inspection)
5.7, 5.9
112.8(d)(5) – Warn vehicles about aboveground piping 5.5
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1.0 INTRODUCTION This plan has been developed by the Smith Management Group (SMG) to serve as a comprehensive environmental document for your facility that could potentially discharge petroleum products and/or hazardous materials to ground or surface waters. This Integrated Contingency Plan (ICP) has been developed to incorporate a Groundwater Protection Plan (GWPP), a Spill Prevention Control and Countermeasures Plan (SPCC), a Stormwater Pollution Prevention Plan (SWPPP), and an Emergency Procedures Contingency Plan (EPCP) for hazardous wastes. All four plans reflect similar preventive measures for the facility to implement to minimize or eliminate the impact of contamination to the surrounding environment. 1.1 Emergency Spill Notification Any spill that our Hazardous Materials Team cannot manage where the volume of a known substance(s) is spilled, or released in excess of the reportable quantity (RQ) – OR – any event of a spill, or release of a substance, including solid, liquid or gas/vapor, whose origin is unknown or not clearly identified, shall be handled according to the Integrated Contingency Plan work instruction GENEV-002 (refer to Appendix C).
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2.0 GENERAL SITE INFORMATION
2.1 FACILITY IDENTIFICATION a. Facility Name Central Motor Wheel of America, dba CMWA & Address 125 Wheat Drive Paris, Kentucky 40361 b. Facility Telephone: (859) 987-0500 Facility Facsimile: (859) 987-0608 c. Location: Bourbon County, Kentucky Latitude: 38o 13’ 13” Longitude: 84o 16’ 21” d. Date Established: 1987 e. Hours of Operation: 24 hours per day; 6 days per week f. Corporate Owner Central Motor Wheel of America, dba CMWA & Address: 125 Wheat Drive Paris, Kentucky 40361 g. Description of the Facility Activities: Central Motor Wheel of America, dba CMWA, (CMWA) currently operates a manufacturing facility in Paris, Bourbon County, Kentucky. The facility manufactures aluminum and steel wheels for automobiles and light-duty trucks. The facility is included in the Standard Industrial Classification (SIC) Codes 3714, Motor Vehicle Parts and Manufacturing, and SIC Code 3363, Aluminum Die Casting. The facility employs approximately 575 employees. h. Major Releases: None i. EPA Identification Number: KYD – 175 – 598 – 267 j. Plan Prepared by: Smith Management Group
1405 Mercer Rd. Lexington, Kentucky 40511 2.2 PHYSICAL CHARACTERISTICS 2.2.1 Facility Layout The CMWA facility is located on Wheat Road approximately one mile northwest of the city in Paris, Bourbon County, Kentucky. The site location is identified in Figure 1, Site Location Map. The surrounding area includes mostly light commercial and farming. The site layout includes two main buildings: the STEEL
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DIVISION facility and the ALUMINUM DIVISION facility. Both facilities are constructed of steel and concrete block. Perimeter fencing encloses the facilities and a security guard shack is located at the entrance to production areas. Additional structures on the property include the wastewater treatment facility and covered storage areas for hazardous waste, roll-off boxes and aluminum storage. Figure 2, General Location Map identifies the location of the two main buildings, the wastewater treatment facility, and the outdoor storage areas. Figure 3, STEEL DIVISION Facility Layout is a more detailed drawing of the STEEL DIVISION facility, including the location of where certain activities are performed inside of the facility. Figure 4, ALUMINUM DIVISION Facility Layout is a similar drawing for the ALUMINUM DIVISION facility. 2.2.2 Relief and Drainage In the area of the CMWA facility, local drainage is provided by Houston Creek which lies to the south and east of the complex and an unnamed tributary of Stoner Creek. Both Houston Creek and the unnamed tributary are tributaries of Stoner Creek which provides regional drainage for Paris and Bourbon County. The topographic high on the CMWA property occurs on the west property boundary, at an elevation of about 900 feet M.S.L. The original topographic gradient on the site was similar to current topography. The topographic low occurs on the north property boundary, at an elevation of about 880 feet M.S.L. 2.2.3 Climate The climate of Bourbon County is temperate with generally warm and humid summers and moderately cold winters. Average precipitation is fairly well distributed throughout the year. Most soils are saturated with water in the spring, as winter and early in the spring are the seasonal recharge periods. Drought periods are most common late in the summer and in the fall. Chances are 1 in 10 that September will have less than one inch of rain. Chances are 1 in 10 that any summer month will have less than 2 inches of rain. Soils on broad flats and in depressed areas have some rather prolonged wet periods that occur mostly in the spring during years of above average rainfall. 2.2.4 Regional and Site Geology The CMWA facility is underlain by the Millersburg Limestone formation which is a member of the Ordovician System. Millersburg Limestone is described as limestone and shale with a thickness of approximately 100 feet. About 70 percent of the unit is of two types (1) medium gray, weathers yellowish brown, consists principally of large whole and broken fossils in a micritic, argillaceous matrix, in irregular beds to rubbly beds as much as 8 inches thick; and (2) medium gray, weathers brownish gray, consists of coarse fossil fragments in sparry, locally cherty, matrix with silt beds, in irregular to even beds about 6
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inches to 2 feet thick. Figure 5, Geologic Map is a geologic map of the CMWA complex. Limestone locally includes chert masses with vugs containing crystals of calcite, quartz, and barite. Shale, medium-dark-gray; calcareous; occurs as partings and sets as much as 6 inches thick interlaminated and interbedded with limestone. Lower contact locally sharp, but at places unit is gradational with underlying Tanglewood Limestone Member. The soil in the vicinity of the CMWA property is of the Maury-McAfee-Lowell association. This association consists of nearly level to gently sloping soils on long, broad ridges and sloping to moderately steep soils in moderately broad to narrow areas around sinkholes and along drainage ways. Most areas of this unit are drained by streams, and some areas are drained by small limestone sinkholes. Karst topography and sinkholes are common. The major soils formed in material that weathered mainly from phosphatic limestone. About 28 percent of the map unit is Maury soils, 24 percent is McAfee soils, 9 percent is Lowell soils, and 18 percent is minor soils. All of these soils are predominantly clay subsoil with a silt loam layer. Permeability is moderately slow in McAfee and Lowell soils and moderate or moderately rapid in Maury soils. Maury and Lowell soils are deep to bedrock, and McAfee soils are moderately deep. The soils are well suited to most urban uses and to intensive recreation uses. The main limitations are moderate depth to rock in McAfee soils, moderately slow permeability of the subsoil in Lowell and McAfee soils, the moderate shrink-swell potential of Lowell and McAfee soils, and steepness of slopes.
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3.0 PRIMARY RESPONSE TOOLS The CMWA facility has developed procedures to decrease the response time associated with any spill or release that could adversely impact the waters of the Commonwealth of Kentucky, stormwater or groundwater, or result in the release of any hazardous waste, to the environment. Please see Work Instruction GENEV-001 – Spill Reporting and Response for more detail. The facility has response teams on-site comprised of individuals with the following titles and responsibilities: 3.1 Emergency Coordinators (Spills or Releases to Environment) There shall be an Emergency Coordinator on the premises, or on call, at all times. The Coordinator(s) shall be responsible for coordinating all emergency response measures and have the authority to commit resources (incur debts) to carry out the Integrated Contingency Plan (ICP). Please see Work Instruction GENEV-002 – Integrated Contingency Plan (ICP) for more details. Persons listed as Emergency Coordinators are familiar with and are knowledgeable about: 1. All aspects of the ICP; 2. All operations and activities at the facility; 3. The location and characteristics of materials handled; 4. The location of records within the facility; and 5. The facility layout. Primary Emergency Coordinator: Mr. Bruce Allison, General Manager Steel Division 1053 Harrods Creek Road Paris, KY 40361 Office Phone Number: 859-987-0500 Cell Phone Number: 859-621-2654 First Alternate Emergency Coordinator: Mr. Mike Mahoney, Senior Safety & Environmental Specialist 829 Broadmoor Circle Lexington, KY 40509 Office Phone Number: 859-987-0500 Home Phone Number: 859-263-0171 Cell Phone Number: 859-509-7222
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3.2 Criteria to Implement CMWA Integrated Contingency Plan (ICP) The Integrated Contingency Plan should be implemented in the event of an imminent, or actual spill, or release of a substance (hereby referred to as “incident”) that could, or potentially, harm the health of CMWA employees, members of the community, and/or the environment. Definition of an incident: Any event where the volume of a known substance(s) is spilled, or released, in excess of the reportable quantity (RQ)
– or – Any event of a spill, or release of a substance, or combination of substances, including solid, liquid or gas/vapor, whose origin is unknown, or not clearly identified.
The Emergency Coordinator will immediately make an assessment of the situation to determine if the release is reportable and to whom. The factors to consider include:
1. If the release was contained in the secondary containment vessel; 2. The quantity of the release; 3. If the release reached the environment (soil, ditch, surface water, ground
water, etc.); 4. If the release reached the Waters of the Commonwealth; or 5. If the quantity is a harmful quantity indicated in 40 CFR 110.3.
If the definition is met CALL 911.
The spill of petroleum products must be reported to applicable regulatory authorities if any of the following three mechanisms occur: A Hazardous Substance is released above the respective Reportable
Quantity (RQ). The spill results in a release of a “harmful quantity” as defined in the Clean
Water Act - a quantity which violates applicable water quality standards or a quantity sufficient to cause a sheen upon the receiving water or a sludge deposited beneath the surface or on the shoreline;
The spill results in a release of oil in quantities of 25 gallons or more in a
24-hour period, except for diesel fuel which the reportable amount is 75 gallons or more in a 24 hour period as set forth in KRS 224.01-400(11).
In addition to “incident-specific” reporting for each individual release, the facility may be required to make an additional notification to the EPA. If the facility discharges more than 1,000 gallons of oil in a single discharge or discharges more than 42 gallons of oil in each of 2 discharges within a 12-month period, a
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report must be submitted within 60 days to the EPA Regional Administrator and the State Agency. The report should include the following:
1) Name of the facility; 2) Name of person making report; 3) Location of the facility; 4) Maximum storage capacity and normal daily throughput of oil; 5) Corrective actions and countermeasures taken (i.e. repairs, etc.); 6) Description of the facility with maps, flow diagrams, topographic maps as
necessary; 7) The cause of the discharge along with a failure analysis of the system in
which the failure occurred; 8) Preventive measures taken or contemplated to minimize a recurrence; and 9) Other information that the Regional Administrator may reasonably need on
the Plan or the discharge. In addition to assessing the spill or release to determine if it is reportable and to whom, the Emergency Coordinator also needs to be aware of any situation that may result in fires or explosions. The criteria to be used include the following: Fires
1. The fire could cause the release of toxic fumes; 2. If the fire spreads, it could ignite materials at other location on-site; 3. The fire could spread to off-site areas; or 4. The use of water as the fire suppression agent could result in contaminated
runoff. Explosions An imminent danger exists that an explosion could occur; or An explosion has occurred.
3.3 Implementation of CMWA Integrated Contingency Plan (ICP) Once the decision is made to implement the ICP, the Emergency Coordinator must take a series of actions: 3.3.1 Immediately Upon the Discovery of an imminent, or Actual, Emergency Situation
1. Activate the internal alarms or immediately contact supervisors to notify facility personnel.
a) Account for all personnel.
b) Determine if there are any injuries.
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2. Identify the source, characteristic, amount and extent of the released
material. Notify local, state, and federal agencies, as necessary.
a) Paris Fire Department 911 (emergency) Paris Police Department 911 (emergency) Paris-Bourbon County Disaster and Emergency Service 911 (emergency) 859-987-2151 (office) 859-987-2151 (fax) b) Kentucky Environmental Emergency Response Team 800-928-2380 (24 hours) 502-564-2380 (24 hours) c) National Response Center 800-424-8802 202-426-2567
Notify the Facilities Manager of CMWA (or other designated Manager), if he is not on-site.
Mr. Bruce Allison, General Manager Steel Division 1053 Harrods Creek Road Paris, KY 40361 Office Phone Number: 859-987-0500 Cell Phone Number: 859-621-2654
3.3.2 Assessment of Emergency Situation
1. With the determination of characteristics, exact source, amount and extent of any released materials:
a) Determine if facility evacuation is necessary. If necessary to evacuate,
please see GENEV-003 – CMWA Emergency Action Plan; and b) Determine if facility personnel can control the situation.
2. Assess hazards to the environment and human health. 3. Determine if evacuation of the local area is advisable. If so, notify local
authorities.
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4. Take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other materials at the facility.
3.4 Emergency Control Phase Measures The following steps are to be taken by the Emergency Coordinator and the plant personnel when responding to a spill, release, fire or explosion. Drum Storage Spill
1. Determine source of spill and material(s) involved. 2. Determine the hazard(s) involved and eliminate all sources of ignition. 3. Responding personnel are to be properly equipped (safety equipment,
clothing and respiratory protection). 4. Responding personnel are to approach the leaking drum or spilled
material from an upwind direction, if possible, using absorbent or neutralization agents, if necessary.
5. Contain the spill to the smallest area possible, using absorbent or neutralization agents, if necessary.
6. Upright any overturned drums or overpacked leaking containers. 7. If the spilled material is unrecoverable, treat or absorb the material. 8. Remove spilled and sorbed materials and contaminated soils. 9. Clean, restore, or replace spill response equipment and return it to original
location(s). Storage Tank Spill
1. Determine source of spill and material(s) involved. 2. Determine the hazard(s) involved and eliminate all sources of ignition. 3. Responding personnel are to be properly equipped (safety equipment,
clothing and respiratory protection). 4. Responding personnel are to approach the area from an upwind direction,
if possible. 5. Stop all flows to the tank involved, and close all valves on all tanks. 6. Contain the spill to the smallest areas possible. 7. After the spill is contained, recover, treat or absorb the material. 8. Remove spilled and sorbed materials and contaminated soils. 9. Clean, restore or replace spill response equipment and return it to original
location(s). Other Releases
1. Determine source of spill and material(s) involved. 2. Determine the hazard(s) involved and eliminate all sources of ignition. 3. Responding personnel are to be properly equipped (safety equipment,
clothing and respiratory protection).
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4. Responding personnel are to approach the area from an upwind direction, if possible.
5. Contain the spill to the smallest areas possible, using absorbent or neutralization agents, if necessary.
6. After the spill is contained, recover, treat or absorb the material. 7. Remove spilled and sorbed materials and contaminated soils. 8. Clean, restore or replace spill response equipment and return it to original
location(s). Drum or Tank Storage Area Fire or Explosion
1. Determine what is on fire. 2. Determine the hazard(s) involved. 3. Evacuate all endangered or unnecessary personnel. 4. Determine if evacuation of off-site areas is necessary. 5. On-site personnel may respond to small (single barrel) fires while the fire
department is en route. Water hoses, fire extinguishers, dirt or sand may be utilized. Any such response may be taken IF it will not endanger the responder’s life or health. Appropriate safety equipment must be worn.
6. Allow the fire department to take appropriate and necessary measures. 7. After the fire is extinguished, clean up affected areas. 8. Clean, restore, or replace emergency equipment and return to original
location(s). 3.5 Follow-up Activities The following follow-up activities must be completed by the appropriate facility personnel once the spill, release, fire or explosion has been properly responded to:
1. Provide for treating, storing or disposing of recovered waste, contaminated soil, surface water or other material resulting from the incident.
2. Ensure that clean-up procedures are completed and emergency equipment is fit for use before resuming operation in the affected areas.
3. Notify local, state and federal officials before resuming operation. 4. Submit written reports on the incident, as required, to the Kentucky
Department of Waste Management, the U.S. Environmental Protection Agency, and the Bourbon County Emergency Planning Committee.
3.6 Follow-up Documentation For all spill events, a record of the following information should be maintained during the event, and recorded later on a copy of the form provided in the ICP Work Instruction.
1. Agency Name; 2. Name of person spoken with during notification; 3. Date and time of call;
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4. Agencies which arrived at the scene of the event; 5. Person in command of response for agency; and 6. Date and time of arrival.
The original completed forms should be numbered and retained by the Senior Safety & Environmental Specialist. 3.6.1 State Follow-Up Based upon the type and extent of the reported spill or release, a written follow-up report may be required by the Kentucky Natural Resources and Environmental Protection Cabinet (KRS 224.01-400). This report must be submitted within seven (7) days of the request to Kentucky Environmental Response Team, Department for Environmental Protection, 14 Reilly Road, Frankfort, Kentucky 40601. The report must contain information such as that listed below:
1. Precise location of the release; 2. Name, address and phone number of the person in charge at the time of
the release, persons knowledgeable of the release, and a contact person for additional information;
3. Concentration and quantity of the release; 4. Circumstances and cause of the release; 5. Efforts taken to control or mitigate the release; 6. Any harmful effects of the release; 7. Where the release occurred and the potential for movement away from the
site; 8. Any present or proposed action at the site to correct the release or its
effects; and 9. Any other information that may assist in the response at the site.
Under Kentucky law, once a release has occurred, even if less than a reportable quantity, the responsible person must characterize the full extent of the release to determine its effect on the environment and correct the effect of the release on the environment. The Cabinet may require submittal of the demonstration of characterization and remediation on releases of less than a reportable quantity. For releases that exceed the reportable quantity, the Cabinet must approve site characterization and remedial actions (KRS 224.01-400). 3.6.2 Federal Follow-Up Oil spills in excess of 1,000 gallons in a single event, or two reportable oil spills within any twelve (12) month period, requires submission of a written report to the U.S. EPA Region IV at 61 Forsyth St, SW, Atlanta, Georgia, 30303-8960. The written report shall be submitted within 60 days of the spill event and shall include a detailed description of the facility, spill event, corrective actions being taken, and a complete copy of the SPCC Plan. Failure to submit such a report may lead to daily fines.
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Oil spills which result in a discharge to a U.S. navigable water may also require the submission of a written report to the U.S. EPA. If the U.S. EPA is notified of a discharge or threatened discharge of oil(s) or hazardous substance(s) into surface waters from the facility, a “Clean Water Act Section 308 Letter – Information Required for Oil Spills” notice may be sent to the facility. The required information must be submitted within a specific time frame (i.e., 20 calendar days) after receipt of the information request. A written request for an extension to the time limit for responding must be made within five (5) calendar days after receipt of the information request. Due to the level of detail contained in the information request, it is critical that all activities and persons involved in the spill and subsequent response are documented as thoroughly as possible.
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4.0 GROUNDWATER PROTECTION PLAN
This plan is written to comply with the Groundwater Protection Regulations (401 KAR 5:037) promulgated by the state legislature on August 24, 1994 requiring the preparation and implementation of groundwater protection plans to “ensure protection for all current and future uses of groundwater and to prevent groundwater pollution”. According to the regulations, groundwater is defined as “the subsurface water occurring in the zone of saturation beneath the water table and perched water zones below the B soil horizon including water circulating though fractures, bedding planes, or solution conduits”. This plan is designed to first identify potential sources of pollution or contamination at the site and, second, select and carry out actions that prevent the pollution of groundwater. 4.1 Implementation Team CMWA has an environmental committee that oversees the environmental concerns of the facility. Key members of CMWA shall be responsible for the implementation of the Groundwater Protection Plan (GWPP). This plan shall be retained at the facility at all times. All records evidencing compliance shall be maintained and available for review for a period of six (6) years. The regulations require any person who receives a request from any citizen to review the GWPP to provide the plan within ten (10) working days. A written response must be provided to the person making the request stating that the plan may be reviewed at:
1. The Division of Water in Frankfort; 2. A regional office of the Division of Water; 3. The facility; or 4. A local public library.
4.2 Identification of Covered Activities under GWPP The regulations identify certain activities for which groundwater protection plans must be prepared and implemented. The environmental committee must be familiar with the listed activities in order to modify the GWPP before a new or modified activity is conducted at the facility. Also, the GWPP must be reviewed in its entirety every three years, updated if necessary by the environmental committee, and recertified. For these reasons, the designated CMWA personnel must be familiar with the following activities that are covered by the regulations:
Storing or related handling of bulk quantities of pesticides or fertilizers for commercial purposes;
Storing or related handling of bulk quantities of pesticides or fertilizers for the purpose of distribution to a retail sales outlet;
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On-site application of pesticides or fertilizers for commercial purposes;
Applying of fertilizers or pesticides for public right-of-way maintenance or institutional lawn care;
Land treatment or land disposal of a pollutant;
Storing, treating, disposing or related handling of hazardous waste, solid waste or special waste in landfills, incinerators, surface impoundments, tanks, drums or other containers, or in piles;
Commercial or industrial storing or related handling in bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants in tanks, drums or other containers or in piles;
Transmission in pipelines of raw materials, intermediate substances or products, finished products, or other pollutants;
Installation or operation of on-site sewage disposal systems;
Storing or related handling of road oils, dust suppressants or deicing agents at a central location;
Application or related handling of road oils, dust suppressant or deicing materials;
Installation, construction, operation or abandonment of wells, bore holes or core holes;
Collection or disposal of pollutants in an industrial or commercial facility through the use of floor drains which are not connected to on-site sewage disposal systems, closed-loop collection or recovery systems, or a waste treatment system permitted under the Kentucky Pollutant Discharge Elimination System;
Impoundment or containment of pollutants in surface impoundments, lagoons, pits, or ditches; and
Commercial or industrial transfer, including loading and unloading, in bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling of material or pollutants.
The following activities are the apparent activities conducted at CMWA facility in Paris, Kentucky that are listed in the groundwater regulations and require specific protection measures. Some of the activities meet the provisions for “specific exclusion” and are identified for completeness of the plan. By listing these activities, the environmental committee can better identify changes at the facility that might cause an activity that previously met the exclusion provision to require protection practices. The CMWA Complex includes two distinct manufacturing
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plants (STEEL DIVISION and ALUMINUM DIVISION) as well as a wastewater treatment facility and hazardous waste storage area that serves both facilities. For simplification, major sections of the CMWA Complex are listed separately along with the activities covered under the groundwater protection regulations for that section of the complex. 4.3 STEEL DIVISION PLANT A schematic of the STEEL DIVISION Facility is provided in Figure 3, STEEL DIVISION Facility Layout. There are no floor drains in the facility connected to stormwater, or directly discharged to groundwater. 4.3.1 Steel Processes Sump Pits/Trenches/Echo Drains – Echo drains, sumps and pits are located throughout the facility and generally are placed around process equipment to collect spills and also wastewater discharged from the equipment. Trenches and sumps are used to collect and transport the wastewater to the wastewater treatment plant. Transportation and storing of pollutants is a regulated activity according to the groundwater protection regulations. Coolant Recirculation Tanks – The STEEL DIVISION facility has three mixing coolant tanks. The coolant is recirculated to the various forming/trimming processes at the rim lines and then returned to the tanks. A groundwater protection plan is required for this activity because it meets the definition of bulk storage of pollutants (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”). Henry Filter Pits – There are two Henry Filters currently in operation at the STEEL DIVISION facility. The Henry Filters range in size from two thousand (2,000) gallons to seventeen thousand (17,000) gallons. Because the pits contain coolant, groundwater protection practices are required. Decking and Filter Tanks are part of the Henry Filter System and are located throughout the STEEL DIVISION facility for the purpose of collecting coolant and returning it to the Henry Filter. Transportation and storing of pollutants is a regulated activity according to the groundwater protection regulations. Cooling Water Pits – The cooling water supply pits and the return pit contain cooling water from the various processes and heat exchangers within the STEEL DIVISION facility. The return water pit has three pumps that are designed to handle expected flows. The pit has an alarm that sounds with a freeboard of 1.5 feet. Although discharge to the stormwater system is unlikely, groundwater protection practices are required for this activity due to the potential for discharge to the stormwater system. The applicable regulation for this activity is 401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of
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raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”. Paint Storage/Mix Room – Paint drums are temporarily stored and used in the paint mix room. The paint mix room is located inside the plant and does not have floor drains. The room is designed to contain any spills or leaks from the paint drums should they occur. Bulk paint unloading is also conducted inside the building in an area with echo drains to collect spills or leaks. Because this activity is conducted entirely inside the building and the floor in the paint mix room and unloading area does not have any floor drains and is sufficient to prevent release to the groundwater, it meets the specific exclusions of the groundwater protection regulations. Chemical Storage Area – Various raw materials are stored in the Chemical Storage Area including: metal conditioning chemicals, coolants, hydrochloric acid, caustic, sodium hypochlorite, and phosphate. Materials are stored in containers ranging from 5-gallon buckets to 220-gallon totes. There are no floor drains in the Chemical Storage Area. A groundwater protection plan is required for this activity because it meets the definition of bulk storage of raw materials (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”). Oil Storage Area – Various oils and lubricants are stored in the Oil Storage area. Materials are stored in containers ranging from 5-gallon buckets to 70-gallon totes with secondary containment. There are no floor drains in the Oil Storage Area. A groundwater protection plan is required for this activity because it meets the definition of bulk storage of raw materials (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”). Reverse Osmosis (RO) Room – Various raw materials are stored in the RO Room including: water treatment chemicals, descalers, and polymers for the resin beds. Materials are stored in containers of 55-gallon or 60-gallon drums. There are no floor drains in the RO Room, and there is a vinyl liner under the concrete floor and the gravel base. The RO room is lined with the vinyl liner, which is used to collect any material that may be accidentally released. A groundwater protection plan is required for this activity because it meets the definition of bulk storage of raw materials (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”).
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Mechanical Room # 1 – Water treatment chemicals including sodium hypochlorite are stored in the room. Also inside this room are seven compressors that contain 55-gallons of oil in each unit. The room is designed to contain any spills or leaks from the stored materials should they occur. Because the floor in Mechanical Room #1 is sufficient to prevent releases to the groundwater, it meets the specific exclusions of the groundwater protection regulations. Steel Pretreat and E-Coat – Various raw materials are stored in the Steel Pretreat and E-Coat area including: metal conditioning chemicals, coolants, hydrochloric acid, caustic, sodium hypochlorite, and phosphate. Materials are stored in 55-gallon drums. Echo floor drains are located in this area. Additionally, there are floor berms in the area to contain any chemicals spilled onto the floor. A groundwater protection plan is required for this activity because it meets the definition of bulk storage of raw materials (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”). Rim Lines, Assembly Lines, and Press Area – Machine hydraulic oil (oil-based coolant) are contained in these areas, either inside a tank that is part of the equipment or in 275-gallon totes. Echo drains, sumps, and trenches are located in these areas to contain the oil coolant if necessary. Additionally, there are floor berms in the area to contain any chemicals spilled onto the floor. A groundwater protection plan is required for this activity because it meets the definition of bulk storage of raw materials (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”). Wastewater Transmission – The STEEL DIVISION has wastewater pipelines that extend from the plant to the Wastewater Treatment Plant. Transmission of pollutants in pipelines is a regulated activity per 401 KAR 5:037 Section 2 (2)(h) and requires groundwater pollution prevention practices. Shipping and Receiving – Loading and unloading areas have a high spill potential because the nature of the activity involves transfer of materials from one location to another and are therefore subject to the groundwater protection regulations, specifically401 KAR 5:037 Section 2 (2)(p) ”industrial transfer of raw materials, intermediate substances or products, finished products, substances held for recycling or other pollutants”. The spill potential is affected by the integrity of the container, the form of the chemical being transferred, the design of the transfer area, the proximity of this area to the storage area, and procedures for loading and unloading. Rolloff Storage Area – The STEEL DIVISION facility has a rolloff shed located on the east side of the facility that is used for rolloff hopper storage for the waste
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press waste and other industrial solid waste. Waste products generated during the manufacturing process are subject to groundwater protection regulations, specifically 401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”. 4.4 Wastewater Treatment Area The wastewater treatment facility is located between the STEEL DIVISION and ALUMINUM DIVISION facilities on the eastern end of the CMWA complex and provides treatment for all process wastewater discharged from both plants. Wastewater treatment processes include, metals coagulation and precipitation, final clarification, sand filtration and final pH adjustment prior to discharge to the Paris Wastewater Treatment Plant. Sludge from the precipitation process is concentrated using a filter press. (401 KAR 5:037 Section 2 (2)(f) “storing, treating, disposing, or related handling of hazardous waste, solid waste, or special waste in landfills, incinerators, surface impoundments, tanks, drums or other containers, or in piles”). 4.5 Hazardous Materials/Waste Storage Area The hazardous material storage area is located adjacent to the wastewater treatment plant. Hazardous materials, including hazardous waste, waste oils, waste coolants, spent solvents, waste paint, etc., are stored in this area until hauled off site by a contract waste hauler. Waste containers include drums, totes, hoppers, and tanks. Handling of hazardous waste is a regulated activity and requires specific groundwater protection measures. (401 KAR 5:037 Section 2 (2)(f) “ storing, treating, disposing, or related handling of hazardous waste, solid waste, or special waste in landfills, incinerators, surface impoundments, tanks, drums or other containers, or in piles”). 4.6 ALUMINUM DIVISION PLANT Sump Pits/Trenches/Echo Drains – Echo drains are located throughout the facility and are generally part of the individual machines self-containment system. The purpose of the drains is to collect spills and process wastewater discharged from the equipment. Because transportation and storing of pollutants are regulated by the groundwater protection regulations, specific groundwater protection practices are required. Pretreatment Process – The aluminum wheel manufacturing processes includes pre-rinse, pre-degrease, degrease, rinses, and coating. Process tanks contain bulk pollutants that require groundwater protection activities. (Refer to 401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”).
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Paint Storage/Mix Room – Paint containers are temporarily stored and used in the paint mix room. The paint mix room is adjacent to the plant and does not have floor drains. The room is designed to contain any spills or leaks from the paint drums should they occur. Bulk paint unloading is also conducted inside the building in an area with echo drains to collect spills or leaks. Because this activity is conducted entirely inside the building and the floor in the paint mix room and unloading area is sufficient to prevent releases to the groundwater, it meets the specific exclusions of the groundwater protection regulations. Shipping and Receiving – Loading and unloading areas have a high spill potential because the nature of the activity involves transfer of materials from one location to another and are therefore subject to the groundwater protection regulations (401 KAR 5:037 Section 2 (2)(p) “industrial transfer of raw materials, including loading and unloading, in bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants”). The spill potential is affected by the integrity of the container, the form of the chemical being transferred, the design of the transfer area, the proximity of this area to the storage area, and procedures for loading and unloading. Wastewater Transmission – The ALUMINUM DIVISION has wastewater pipelines that extend from the plant to the Wastewater Treatment Facility. Transmission of pollutants in pipelines is a regulated activity per 401 KAR 5:037 Section 2 (2)(h) and requires groundwater pollution prevention practices. Henry Filter Pits – There are six Henry Filters currently in operation at the ALUMINUM DIVISION facility. The Henry Filters range in size from two thousand (2,000) gallons to seventeen thousand (17,000) gallons. Because the pits contain coolant, groundwater protection practices are required. Decking and Filter Tanks are part of the Henry Filter System and are located throughout the ALUMINUM DIVISION facility for the purpose of collecting coolant and returning it to the Henry Filter. Transportation and storing of pollutants is a regulated activity according to the groundwater protection regulations. Pole Barn – The Pole Barn is a totally enclosed building adjacent to the Waste Storage Shed with echo drains running the full length of the building. The building is used for oil, die coat, and coolant storage. This activity requires a groundwater protection plan because it meets the definition of bulk storage of raw materials (401 KAR 5:037 Section 2 (2)(g) “industrial storing or related handling of bulk quantities of raw materials, intermediate substances or products, finished products, substances held for recycling, or other pollutants held in tanks, drums or other containers, or in piles”). Dust Collectors –The ALUMINUM DIVISION facility has dust collectors that use drums to store the dust material. The dust collectors discharge to a drum where the material is stored until the drum reaches capacity. Waste products generated
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during the manufacturing process are subject to groundwater protection regulations (401 KAR 5:037 Section 2 (2)(f) “storing, treating, disposing, or related handling of hazardous waste, solid waste, or special waste in landfills, incinerators, surface impoundments, tanks, drums or other containers, or in piles”). 4.7 Groundwater Protection Activities 4.7.1 Specific Practices The specific practices chosen to protect the groundwater for each of the listed activities are described below. Specific Best Management Practices (BMP’s) are maintained by the Product Assurance Document Control Administrator. Completed BMP’s are maintained by the Plant Services Coordinator. Appendix E - Groundwater Protection Practices contains the practices and frequencies for the various groundwater protection practices. General practices applicable to the specific practices such as good housekeeping, preventative maintenance, visual inspections, and spill prevention and response are described in Section 9.0 Measures and Controls. 4.7.2 STEEL DIVISION PLANT 4.7.2.1 Steel Processes Coolant Storage – The STEEL DIVISION facility has three rim line coolant recirculation tanks and one Henry Filter Pit (17,000 gallon). Once the coolant is spent, it is hauled off site by a contract waste hauler. The recirculating tanks are constructed of stainless steel. Because the pit contain coolant, groundwater protection practices are required. Groundwater Protection Practices – The structural integrity of the tanks will be inspected each time the pits are emptied. Any signs of deterioration will be noted and corrected promptly. The decking and filter tank is part of the Henry Filter System and is located in close proximity to the Henry Filter Pit, for the purpose of collecting coolant and returning it to the Henry Filter. Transportation and storing of pollutants is a regulated activity according to the groundwater protection regulations. Sump Pits/Trenches/Echo Drains – Echo drains, sumps and pits are located throughout the facility and are generally placed around process equipment to collect spills and wastewater discharged from the equipment. Trenches and sumps are used to collect and transport the wastewater to the wastewater treatment plant. Groundwater Protection Practices – which will be followed to ensure groundwater protection will include routine inspection of the structural integrity of the sump pits, trenches and echo drains. Structural failure due to deterioration of the
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concrete would be the most likely cause of an environmental release to the groundwater. Groundwater protection goals will involve: Semi-annual cleaning and inspection of the sump, trench, and echo drain
structures on the rim line; and
Preventing release of materials which are non-compatible with concrete and minimizing the effect should a release of non-compatible material occur.
Steel Pretreat and E-Coat – Materials stored and handled in these areas require groundwater protection practices to reduce the possibility of pollutants being accidentally discharged to groundwater. Although secondary containment is not provided for all materials in these areas, the following steps will be followed to provide groundwater protection. Groundwater Protection Practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. Spill response equipment will be kept near these areas for prompt response to spills and leaks. Reverse Osmosis (RO) Room – Materials stored and handled in these areas require groundwater protection practices to reduce the possibility of pollutants being accidentally discharged to groundwater. Although there is a vinyl liner under the concrete pad and the gravel base, the following steps will be followed to provide groundwater protection: Groundwater Protection Practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. Spill response equipment will be kept near these areas for prompt response to spills and leaks. The sump will be inspected weekly and pumped of any liquid as needed. 4.7.2.2 Cooling Water Pit The supply cooling water pits contain approximately 40,000 gallons and 30,000 gallons, respectively, of cooling water. The return cooling pit contains approximately 30,000 gallons. Although discharge to the stormwater system is unlikely, groundwater protection practices are required for this activity due to the potential for discharge to the stormwater system. Groundwater Protection Practices The overflow from the pit to the stormwater system was plugged, preventing cooling water from entering the stormwater system via the overflow. A new overflow line was routed to the waste treatment plant. Current practices and equipment include:
a) The return water pit has three pumps designed to handle expected flows; b) The pit has an alarm which sounds if the water exceed normal level; and
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c) A freeboard of 1.5 feet is observed. 4.7.2.3 Mechanical Room #1 Boiler feed chemicals are stored in Mechanical Room #1. Materials stored and handled in these areas require groundwater protection practices to reduce the possibility of pollutants being accidentally discharged to groundwater. Although secondary containment is not provided for all materials in the area, the following steps will be followed to provide groundwater protection. Groundwater Protection Practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. Spill response equipment will be kept in the area for prompt response to spills and leaks. 4.7.2.4 Wastewater Transmission The STEEL DIVISION has gravity process lines that discharge to a lift station on the east side of the facility near the Rolloff Storage Shed. The lift station pumps all process water to the Wastewater Treatment Plant. There is a sanitary sewer line on the northeast side of the facility near the Guard Shack. The sanitary sewer line contains sanitary water only and does not carry any process water. Based upon a review of existing plumbing lines, there is no practical way by which to isolate the sanitary sewer line. Because the sanitary sewer line poses a low potential of significant adverse impact upon the groundwater, it is proposed that no testing will be conducted on the sanitary sewer line near the Guard Shack. Groundwater Protection Practices – The most likely cause of a release from wastewater transmission lines containing process water will be due to a break in the force main. Therefore, the STEEL DIVISION will conduct a pressure tightness test on the force main at least every other year. Any pressure drop that would indicate a possible leak in the force main containing process water will be immediately investigated. 4.7.2.5 Oil Storage/Shipping and Receiving Materials stored and handled in these areas require groundwater protection practices to reduce the possibility of pollutants being accidentally discharged to groundwater. Although secondary containment is not provided for all materials in these areas, the following steps will be followed to provide groundwater protection. Groundwater Protection Practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures.
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4.7.2.6 Rolloff Storage Area Waste products generated during the manufacturing process must be stored outside and are therefore subject to the groundwater protection regulation. Groundwater Protection Practices – The STEEL DIVISION has constructed a rolloff shed on the east side of the facility which reduces the possibility for contaminant transport. All press waste and other industrial solid wastes are stored under the rolloff shed. The floor of the shed is constructed of concrete and is sloped towards a centrally located drain. The drain discharges to a lift station which pumps all wastewater collected to the wastewater treatment plant. A vinyl liner was installed beneath the concrete pad for additional protection. Rolloff hoppers that are not kept under this shed are only used for non-industrial waste. Employees are trained in proper disposal of all waste products. 4.7.3 Wastewater Treatment Area The wastewater treatment facility is located between the STEEL DIVISION and ALUMINUM DIVISION facilities on the eastern end of the CMWA complex and provides treatment for all wastewater discharged from both plants. A schematic of the wastewater treatment grounds is provided in Figure 6, Wastewater Treatment Facility. Wastewater treatment processes include metals coagulation and precipitation, final clarification and final pH adjustment prior to discharge to the Paris Wastewater Treatment Plant. Sludge from the precipitation process is concentrated using a filter press. Groundwater Protection Practices – Wastewater treatment tanks are located both on the inside and outside of the wastewater treatment building. The entire area surrounding the wastewater treatment complex has a soil berm to provide containment and a collection system with a capacity greater than the largest tank (Equalization Tank). The containment structure has a drainage system with a manually controlled valve at the topographic low point. Wastewater treatment operators are also trained in preventative maintenance, good housekeeping, and spill prevention and response. 4.7.4 Hazardous Materials/Waste Storage Area The hazardous waste storage area is located adjacent to the wastewater treatment plant. See Figure 6, Wastewater Treatment Facility. All hazardous materials including hazardous waste, recycled oils, waste coolants, spent solvents, waste paints, etc. are stored in this area until hauled off site by a contract waste hauler. Containers include drums, totes, hoppers, and tanks. Groundwater Protection Practices – CMWA has the following groundwater protection practices currently in place.
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All material is placed on a concrete pad with a concrete berm located along the perimeter to provide secondary containment. A vinyl liner was installed beneath the concrete pad for additional protection.
The floor of the storage area is sloped towards two sumps that are
manually pumped as needed into either the #1 Equalization Tank or into totes for shipment off site.
The storage area is covered by a metal truss roof structure to minimize
stormwater contact. The entire area is also within the earthen berm of the wastewater
treatment plant. Spill response equipment is stored in the building for ready access in the
event of a spill during transporting from the plants to the building. Employees are trained in spill prevention and response. All hazardous waste is moved from satellite storage to hazardous waste
storage area. 4.7.5 ALUMINUM DIVISION PLANT 4.7.5.1 Existing Plant Area Activities Sump Pits/Trenches/Echo Drains – Echo drains are located throughout the facility and are generally part of the individual machine self-containment system. The purpose of the drains is to collect spills and process wastewater discharged from the equipment. Groundwater Protection Practices – Routine inspection of the structural integrity of the sump pits, trenches and echo drains. Structural failure due to deterioration of the concrete would be the most likely cause of an environmental release to the groundwater. Groundwater protection goals will involve: Semi-annual cleaning and inspection of the sump, trench, and echo drain
structures; and
Preventing release of materials that are non-compatible with concrete and minimizing the effect should a release of non-compatible material occur.
Shipping and Receiving – Materials stored and handled in these areas require groundwater protection practices to reduce the possibility of pollutants being accidentally discharged to groundwater. Although secondary containment is not provided for all materials in these areas, the following steps will be followed to provide groundwater protection.
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Groundwater Protection practices – This includes employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. Spill response equipment will be kept near these areas for prompt response to spills and leaks. These areas will be periodically observed by employees who work in these areas and inspected on a weekly basis. Wastewater Transmission – The ALUMINUM DIVISION has gravity process lines which discharge to a lift station. The lift station pumps all process water to the Wastewater Treatment Plant. Groundwater Protection Practices – The most likely cause of a release from the wastewater transmission lines would be due to a break in the force main. CMWA conducts a pressure tightness test on the force main at least once every two years. Any pressure drop that would indicate a possible leak will be immediately investigated. Henry Filter Pits – There are six Henry Filters currently in operation at the ALUMINUM DIVISION facility. The Henry Filters range in size from two thousand (2,000) gallons to seventeen thousand (17,000) gallons. Because the pits contain coolant, groundwater protection practices are required. Groundwater Protection Practices – The pits are constructed of reinforced concrete with a liner. The spent coolant will be pumped to tanker truck and hauled off site by a contract waste hauler. The structural integrity of the pit will be inspected each time the coolant is emptied. Any signs of spalling, pitting, cracking or other deterioration of the concrete will be identified and appropriate measures will be taken immediately. 4.7.5.2 Rolloff Storage Area Waste products generated during the manufacturing process must be stored outside and are therefore subject to the groundwater protection regulations. Groundwater Protection Practices – The ALUMINUM DIVISION has constructed a rolloff shed on the east side of the facility which reduces the possibility for contaminant transport. Aluminum chips and other industrial solid waste are stored under the rolloff shed. The floor of the shed is constructed of concrete and is sloped towards a centrally located drain. The drain discharges to a lift station which pumps all wastewater collected to the wastewater treatment plant. A vinyl liner was installed beneath the concrete pad for additional protection. Rolloff hoppers that are not kept under this shed are only used for non-industrial waste. Employees are trained in proper disposal of all waste products.
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4.7.5.3 Pole Barn The Pole Barn is a totally enclosed building adjacent to the Waste Storage Shed. The building is used for oil, die coat, and coolant storage. Materials stored and handled in the area require groundwater protection practices to reduce the possibility of pollutants being accidentally discharged to groundwater. There is a secondary containment echo drain that runs the full length of the building. The following steps will be followed to provide groundwater protection. Groundwater Protection Practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. Spill response equipment will be kept in the area for prompt response to spills and leaks. 4.7.5.4 Oil Storage Room Two 100-gallon capacity hydraulic oil carts and multiple maintenance oil, glycol, and grease containers ranging in capacity from 5 to 55 gallons are located in the Oil Storage Room. These containers are constructed of steel and plastic. Totes are open top, while the drums are typically closed top with bunghole openings. Manual pumps used to remove fluids are attached to several of these drums, while the cart utilizes a pneumatic diaphragm pump. Other chemicals located in this area include coolant biocides and water treatment chemicals. Groundwater Protection Practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. Spill response equipment will be kept in the area for prompt response to spills and leaks.
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5.0 SPILL PREVENTION CONTROL AND CONTERMEASURES PLAN CMWA understands the risk and potential liabilities associated with the storage and use of oil. The purpose of this document is to reduce the potential for spills and releases of oil, and minimize the environmental impact in the event of a spill or release. Oil spill prevention is accomplished by responsible operation of properly designed facilities. Good housekeeping, equipment maintenance, adherence to operation procedures and effective personnel training are the best insurance against a spill. If an oil spill should occur, it may require quick and decisive action to mitigate potentially disastrous effects. While no two spills are ever identical, this plan provides guidelines for spill response, control and countermeasures. 5.1 Applicability In 1970, the United States Congress enacted the Water Quality Improvement Act which stated that the policy of the United States (U.S.) is that there shall be no discharges of oil into the navigable waters of the U.S. The Federal Water Pollution Control Act Amendments of 1972 required the United States Environmental Protection Agency (USEPA) Administrator along with other federal, state and local agencies, to initiate programs designed to prevent, reduce, or eliminate pollution of the navigable waters of the U.S. On December 11, 1973, the USEPA published regulations for the prevention of pollution of waters of the U.S. by oil located at non-transportation related onshore and offshore facilities. The regulations are identified as Title 40, Code of Federal Regulations, Part 112 (40 CFR 112), “Oil Pollution Prevention – Non-transportation Related Onshore and Offshore Facilities”, and became effective January 10, 1974. 40 CFR 110, “EPA Regulations on Discharge of Oil” was promulgated originally at 41 Federal Register 49810 on November 11, 1976. These regulations prohibit the discharge of oil into or upon the navigable waters of the U.S. or adjoining shorelines or into or upon the waters of the contiguous zone in such quantities that it has been determined may be harmful to the public health or welfare of the U.S. These regulations identify requirements, procedures, methods, and/or equipment to prevent the discharge of harmful quantities of oil into or upon the navigable waters of the United States. A SPCC Plan must be written and certified for a facility when one of the following conditions exists:
1. There is a reasonable potential for discharging oil from fixed facilities into water of the U.S.; or
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2. The oil storage capacity on-site exceeds either:
a) 42,000 gallons of total underground storage; or b) 1,320 gallons of total aboveground storage.
The facility is not subject to 40 CFR 112.20, because the facility does not have an oil storage capacity of one million gallons and does not transfer oil over water to or from vessels as outlined in the Oil Pollution Act of 1990. There are several terms that require further definition to avoid confusion. These definitions are provided in subsection 5.2. 5.2 Definition of Terms Act – means the Federal Water pollution Control Act (FWPCA), as amended, 33 U.S.C. 1251 et seq., also known as the Clean Water Act (40 CFR 110). Applicable Water Quality Standards – means State water quality standards adopted by the State pursuant to Section 303 of the Act or promulgated by the EPA pursuant to that section (40 CFR 110). Discharge – includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting or emptying or dumping. Discharges of oil which are authorized by permits issued pursuant to Section 13 of the River and Harbor Act of 1899, or Section 402 or 405 of the FWPCA Amendments of 1972 (40 CFR 112) are not included in this definition. Environment – means the water of the Commonwealth, land surface, and subsurface soils and strata, or ambient air within the Commonwealth or under the jurisdiction of the Commonwealth (KRS 224.01-400). This includes secondary containment systems and areas inside buildings. Environmental Emergency – means any release or threatened release of materials into the environment in such quantities or concentrations as cause or threatens to cause an imminent and substantial danger to human health or the environment. The term includes, but is not limited to, discharges of oil and hazardous substances prohibited by Section 311 (b)(3) of the Federal Clean Water Act – (Public Law 92-500), as amended (KRS 224.01-400). Harmful Quantities – is any discharge of oil that violates applicable water quality standards, or causes a film, or sheen upon, or discoloration of, the surface of the water or adjoining shorelines, or causes a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines (40 CFR 110). Navigable Water* –The term “navigable waters” of the United States means “navigable waters” as defined in section 502(7) of the Federal Water Pollution Control Act (FWPCA), and includes:
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1. all navigable waters of the United States, as defined in judicial decisions prior to the passage of the 1972 Amendments of the FWPCA (Pub. L. 92-500) also known as the Clean Water Act (CWA), and tributaries of such waters as;
2. interstate waters; 3. intrastate lakes, rivers, and streams which are utilized by interstate
travelers for recreational or other purposes; and 4. intrastate lakes, rivers, and streams from which fish or shellfish are taken
and sold in interstate commerce. Oil – means oil of any kind or in any form, including, but not limited to petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredged soil (40 CFR 1120). Petroleum and Petroleum Products – means crude oil or any fraction thereof, which is a liquid at standard conditions of temperature and pressure, which means at sixty (60) degrees Fahrenheit, and 14.7 pounds per square inch absolute. The term includes motor gasoline, gasohol, other alcohol-blended fuels, diesel fuel, heating oil, special fuels, lubricants, and used oil (KRS 224.60 - 115(14)). Reportable Oil Spill or Reportable Release – is any discharge of oil in harmful quantities that enters, or has the potential to enter, navigable water or waters of the state. Any release that requires response action to prevent draining, seeping, running or otherwise entering waters of the State is a reportable spill event. Sheen – means an iridescent appearance on the surface of water (40 CFR 110). Sludge – means an aggregate of oil or oil and other matter of any kind in any form other than dredged spoil having a combined specific gravity equivalent to or greater than water (40 CFR 110). Threatened Release – means a circumstance that presents a substantial threat of a release (KRS 224.01-400). Waters of the State – includes all streams, lakes, ponds, marshes, watercourses, waterways, wells, springs, irrigation systems, drainage systems and all other bodies or accumulations of waters, surface and underground, natural or artificial, public or private, which are contained within, flow through or border upon this state; except that bodies of water confined to, and retained within, the limits of private property shall not be considered “waters of the state”.
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5.3 Review and Amendments This SPCC Plan shall be amended whenever there is a change in the facility’s design, construction, operation, or maintenance that materially affects the potential to discharge oil. Such amendments shall be fully implemented as soon as possible, but no later than six months after such change occurs. This SPCC Plan shall be evaluated following the completion of a spill event that required the execution of activities contained in or use of the Plan. The evaluation will be conducted by personnel involved in the specific response and personnel typically involved in the response. The Plan evaluation will include a review of the following:
a) Accuracy of information; b) Ease or difficulty obtaining needed information; and c) Clarity of information.
This plan will be reviewed at least every 5 years to include a review of more effective preventive and control technology. The owner or operator must then sign a statement affirming CMWA’s commitment to provide the necessary resources to fully implement the SPCC. The statement shall be included as an appendix to the Plan. The statement must include language similar to the following:
“I have completed the review and evaluation of the SPCC Plan for (name of facility) on (date) and will or will not modify the Plan as a result.”
Professional Engineer certification is required for technical amendments to this Plan. Administrative or non-technical changes (facility name change, contact name changes, phone number changes, etc.) do not require certification by a Professional Engineer. A copy of the Spill Prevention, Control and Countermeasure (SPCC) Plan Management Approval and Registered Professional Engineer certification form is contained in Appendix A – Certification Forms. Furthermore, the owner or operator of the facility must maintain a certification form if the facility does not meet the substantial harm criteria listed in Attachment C-II of Appendix C of 40 CFR 112. The “Certification of the Applicability of Substantial Harm Criteria” is in included in Appendix F – No Substantial Harm Certification. As part of the Integrated Contingency Plan, a complete copy of the SPCC will be available at the CMWA facility at all times. 5.4 Facility Drainage and Layout The CMWA facility discharges industrial wastewater to an on-site treatment facility located north of the STEEL DIVISION building. The majority of each
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facility’s floor or trench drains are covered, preventing disposal of process or material waste products. Waste streams produced by operations inside the facility are reused, recycled, or discharged directly into the on-site treatment facility. The on-site treatment facility discharges processed water directly to the Paris sanitary sewer system’s main line near the southeast boundary of the property. No lines of the sanitary sewer system are connected to the stormwater drainage system. Stormwater inlets (area drains and culverts) located outside of the STEEL DIVISION building generally convey water to the south and/or east through underground drainage systems and open ditches. Stormwater inlets located outside of the ALUMINUM DIVISION building generally convey water to the northeast or northwest through underground drainage systems and open ditches. Discharges from these drainage systems flow offsite through surface drainage ditches and eventually into either Houston Creek (south and directly east) or an unnamed tributary (north) that discharges to Stoner Creek. Figure 1, Site Location Plan shows the approximate location of the STEEL DIVISION and associated ALUMINUM DIVISION facilities on a USGS topographic map. A more detailed plant layout drawing, which shows the arrangement and location of buildings, storage containers, and underground drainage systems, for STEEL DIVISION is provided by Figure 3, STEEL DIVISION Facility Layout and for ALUMINUM DIVISION by Figure 4, ALUMINUM DIVISION Facility Layout. 5.5 Potential Spill Sources This section outlines the potential spill sources and the specific control measures that the facility has taken to prevent oil, fuel, and hazardous materials contamination from spills. Drum storage presents the largest spill potential due to frequent handling. Other potential spill sources include transfer hoses and pumps. Spills may be the result of operator error, hose failure, pump leaks, corrosion, and damaged or overturned drums. A ruptured container or drum could conceivably spill its entire liquid volume in a matter of seconds. Spills due to container or drum overfill, equipment failure, and other causes would be limited by the pumping or leakage rates. Releases from corrosion, pump seals, and other sources would be relatively slow and small in quantity. The maximum potential quantity of oil that could be discharged to navigable waters is the total capacity of all storage containers. However, a majority of containers stored on-site are located indoors or in secondarily contained areas, and spills would not normally be expected to reach navigable water. The maximum probable discharge would be less that the most frequently handled container on-site (55 gallons). Actual oil spills would typically be less than the maximum probable because corrective actions would be promptly implemented following a spill. Table 1 - Bulk Petroleum/Oil Storage summarizes the major petroleum storage at the facility. Overhead piping is periodically used to transfer
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oil between areas, but the piping has been elevated (20 ft.) to prevent accidental damage.
Table 1: Bulk Petroleum/Oil Storage Source Material Capacity (Gallons) Storage Type Secondary
Containment (Passive)
STEEL DIVISION Building
Petroleum Oils Maintenance Oils New/Used/Waste Oil Diesel Fuel Mineral Oil
Multiple @ 55/275/550
Multiple @ 60 100
354/500 2,277/470
Drums/Totes/ASTs
Containers Tote
Emergency Generators Transformers
Yes – 2 @ 550
Yes Yes Yes*
None* ALUMINUM DIVISION Building
Petroleum Oils Maintenance Oils New/Used/Waste Oil Diesel Fuel Mineral Oil
Wastewater Treatment Oil Storage Area (STEEL DIVISION)
Re-refined Oil/Water Used/Waste Oil Diesel Fuel
2 @ 1,500
Multiple @ 345 185
AST
Totes Emergency Generator
Yes Yes Yes
*Potential spill source located outdoors with spill response equipment located throughout the facility to serve as active secondary containment. 5.5.1 STEEL DIVISION Building The STEEL DIVISION building is located on the south portion of the property. The building contains several assembly lines used to manufacture automotive wheels. Indoor Sources Chemical / Oil Storage Maintenance fluids (including DTE Light, Maxo, Blastoff, Tapamatic, Vactra, and WD40) are stored in 60-gallon capacity rectangular metal storage containers. The storage containers are elevated above ground level by a metal lattice and are horizontally positioned. Hoses are attached to openings near the bottom of the containers to allow fluid transfers. Outgoing fluid uses gravity to flow through spigots below the containers when spigot valves are open. Incoming fluid is transferred from drums into the containers by a small pump. Fluid level sight glasses on the outside of the containers are visually monitored to identify when the containers are full and the pump should be deactivated. To prevent container over filling, the containers are nearly empty prior to incoming transfers.
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These 60-gallon containers are secondarily contained by a metal pan beneath the lattice structure. The pan is approximately eight feet long, eight feet wide, and three inches high. The volume of the pan is approximately 120 gallons, sufficient to contain the largest container in the system, which is 60 gallons. Liquids that accumulate in the containment area are removed on a periodic basis as needed with a suction pump. A metal tray is located beneath each of the spigots to contain minor leaks and drips. Adjacent to the 60-gallon containers, 55-gallon capacity drums and 5-gallon containers are stored. These containers store automatic transmission fluid, machine oils and gear lubes. A spill would likely pool near the source, but could potentially flow toward the rear of the shelving and into the storage area. Also stored in this area, are acids, corrosives, caustics, production and water treatment chemicals. There are no containment devices around or under this storage area. Any spill in this area should be addressed by Hazmat trained employees, due to the risk hazards associated with these chemicals. There is a spill response cabinet with necessary PPE and spill containment socks and pads. There is also a spill response board with necessary emergency contacts photo posted. Oil Carts Metal rolling containment carts hold two 55-gallon capacity drums and a 375-gallon capacity tote of hydraulic oil. These containers are constructed of steel and closed top with bunghole openings (drums) or open top (tote). A manual pump used to transfer fluid is attached to one of the drums. The carts could contain minimal amounts of fluid from drips, leaks, or spills. Oven Room The oven room contains a lube cart with grease and oil, and (1) 55-gallon capacity drum that is used for heat exchanger cleaner. Other petroleum products are also stored in the oven room. The oil storage carts are constructed of steel, and the grease containers are closed top with removable lids. The 55-gallon drum is constructed of plastic and has plastic bungs. Bulk Hydraulic Oil Storage Two 550-gallon capacity above-ground storage tanks (ASTs) are located in the northeast portion of the building. Hydraulic oil for the rim line and press is stored in the tanks. A secondary containment pit surrounds both of the ASTs. This pit is large enough to collect any leaks, spills, or drips from both of the ASTs. Press Totes Water and oil from the press are collected in totes located near the press.
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Rim Line Tote An additional 275-gallon capacity tote used for waste oil collection from the centrifuge system of the rim line is located near the Henry Filter. Rim Line Drums Two 55-gallon capacity drums, one containing coolant and the second containing waste oil, are located at the end of the rim lines. The waste oil drum is open top. A flexible hose transfers the waste oil from the process lines into the drum. The tote and drum are visually inspected periodically to identify their liquid levels and the need to exchange containers. Press Coolant Drums Several 55-gallon capacity drums of coolant are located in the northeast corner of the building, near the rim line press. These drums are constructed of steel, and are closed top with bunghole openings. Additional 55-gallon drums containing oil are located in-between the equipment in the central part of the building. Spills inside the STEEL DIVISION Building may result from the following:
a) Leaking, ruptured, overturned, or otherwise damaged containers during storage, transfers, or from vehicular movement within the building;
b) Leaking, ruptured, or otherwise damaged manufacturing equipment; c) Overfilling of equipment or storage containers; d) Leaking transfer lines, fittings, or pumps; or e) Failure to close a valve associated with the gravity maintenance fluid
distribution containers. The largest single uncontained storage container inside the STEEL DIVISION Building has a capacity of 550 gallons (hydraulic oil). However, the most likely volume of fluid that may be expected to be released is either 55 or 60 gallons. The constant handling of 55-gallon drums throughout the building provides potential for an accident that may result in the release of the contents of one drum. Fluid transfers from the 60-gallon storage containers are controlled through a gravity flow hose connected to a manual valve. A damaged hose above the valve could allow the release of the contents of one container. The floor inside the STEEL DIVISION Building is concrete. Leaks, drips, or spills from the containers in the building would, depending upon the volume, either pool adjacent to the container or flow toward a nearby floor or trench drain. Floor drains are connected to an on-site industrial waste treatment facility located northeast of the building. Inspections of the ASTs occur periodically and are recorded on the inspection checklist that is maintained by the Product Assurance Document Control Administrator. Spill response equipment are located throughout the facility to serve as active secondary containment measures.
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Outdoor Sources Generator #1, #2, and #6 Two diesel emergency generators are located outside the west wall of the STEEL DIVISION building. Generator #2 located near the southwest corner has a 500-gallon capacity integrated double-walled diesel fuel tank, while generator #1 near the northwest corner of the building has a 354 gallon capacity integrated double-walled diesel fuel tank. Generator #6 is located next to the Wastewater Treatment building that houses the sludge press. The generator has a 185-gallon capacity integrated double-walled diesel fuel tank. These generators are primarily used as back-up power supplies in the event of a power outage, but are tested weekly to ensure operability. Transfers of fuel to these generators occur on an as needed basis by an outside contractor using a 1,000-gallon capacity tanker truck. The largest expected single uncontained spill from any of these generators would be 500 gallons. A spill from generator #1 would flow north toward an unnamed tributary to Stoner Creek. A spill from generator #2 would flow south and then west toward an unnamed tributary of Houston Creek. A spill from generator #6 would be contained by the earthen berm south of the wastewater treatment plant. Transformers Four transformers containing transformer oil (i.e. mineral oil) are located near the building. One large transformer is located in the fenced in area outside of the southwest corner of the building. The large transformer contains a total of 2,277 gallons of oil. Three pad-mounted transformers are located near the large transformer. Each pad-mounted transformer contains 470 gallons of oil. Potential spills would be directed to the southwest corner to outfall 2 and eventually to an unnamed tributary of Houston Creek. One transformer containing 470 gallons of oil is not in service and in the pole barn located east of the STEEL DIVISION building. The transformer is a spare for the pad-mounted transformers. Spills outside the STEEL DIVISION Building may result from the following:
a) Leaking, ruptured, overturned, or otherwise damaged containers during storage outside or transfers to and from the building;
b) Overfilling of emergency generators or ASTs; or c) Leaking transfer lines, fittings, or pumps.
Spill response equipment are located throughout the facility to serve as active secondary containment measures.
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5.5.2 ALUMINUM DIVISION Building The ALUMINUM DIVISION Building is located on the north portion of the property. The building contains several assembly lines used to manufacture automotive wheels. Indoor Sources Oil Storage Room Two 100-gallon capacity hydraulic oil carts and multiple maintenance oil, glycol, and grease containers ranging in capacity from 5 to 55 gallons are located in the Oil Storage Room. These containers are constructed of steel and plastic. Totes are open top, while the drums typically are closed top with bunghole openings. Manual pumps used to remove fluids are attached to several of these drums, while the cart utilizes a pneumatic diaphragm pump. Other chemicals located in this area include coolant biocides and water treatment chemicals. Machining Center #1 (083) A tote of Machining Coolant is stored at this machining center. It is stored over top of a shallow drip pan, but the pan is located over the top of chip handling conveyor pit. Any spills in this area would flow into the pit. Machining Center #2 (084) A tote of Machining Coolant is stored at this machining center. It is stored over top of a shallow drip pan, but the pan is located over the top of chip handling conveyor pit. Any spills in this area would flow into the pit. Shot Blast Wet Air Scrubber There is a tote located over a containment pan that is used for the accumulation of waste water off of the wet scrubber. Any spill that might occur in this area would be partially contained by the containment pan. Die Maintenance This area contains a 55-gallon drum of Die Lubricating Oil that is stored over top of a containment pan. Also stored in this area is Spray Coating Material. Die Assurance This area houses a vat of Liquid Caustic used to dip and clean dies. The vat is constructed of stainless steel. Also stored in this area is a 55-gallon drum of Citric Acid, which is constructed of plastic with removable bungs.
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Pre-treat Line 067 and 068 Along both of the pretreatment lines contains several cleaners, degreasers, liquid caustic, and water treatment chemicals. The chemicals are stored in plastic 55-gallon drums. There are no oils stored in this area. The tops are typically closed with removable bungs. Vacuum Room Liquid Caustic soda 20% is stored in this area in a 55-gallon drum with removable bungs. Spills inside the ALUMINUM DIVISION Building may result from the following:
a) Leaking, ruptured, overturned, or otherwise damaged containers during storage, transfers, or from vehicular movement within the building;
b) Leaking, ruptured, or otherwise damaged manufacturing equipment; c) Overfilling of equipment or storage containers; d) Leaking transfer lines, fittings, or pumps; or e) Failure to close a valve associated with the gravity maintenance fluid
distribution containers. The largest single uncontained storage container inside the ALUMINUM DIVISION Building has a capacity of 350 gallons (hydraulic oil). However, the most likely volume of fluid that may be expected to be released is 55 gallons. The constant handling of 55-gallon drums throughout the building provides potential for an accident that may result in the release of the contents of one drum. The floor of the ALUMINUM DIVISION building is concrete and contains no floor drains. A release would likely pool near the source, but large volume releases could possibly travel into other areas of the building under the metal walls. Visual inspections of the totes, cart, containers, and drums occur periodically. Spill response equipment are located throughout the facility to serve as active secondary containment measures. Outdoor Sources Generators #3 (South Wall), #4 (West Wall), #5 and #7 (East Wall) Four diesel emergency generators are located outside the ALUMINUM DIVISION facility. Generator #3 has a 250-gallon integrated single-walled diesel fuel tank and is located south of the building. Passive earthen secondary containment for Generator #3 is provided by the surrounding topography along with active containment provided by the spill response equipment located in the nearby Pole Barn. Emergency generator #4 has a 500-gallon capacity integrated double-walled diesel fuel tank and is located on a concrete pad outside the building’s west wall. Generator #5 has a 1,000-gallon integrated double-walled diesel fuel
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tank. Generator #7 has a 300-gallon integrated double-walled diesel fuel tank. Both generator #5 and generator #7 are located east of the building. These generators are primarily used as back-up power supplies in the event of a power outage, but are tested monthly to ensure operability. Transfers of fuel to any of these generators occur on an as needed basis by an outside contractor using a 1,000-gallon capacity tanker truck. Any uncontained leaks or spills would flow east or north eventually to an unnamed tributary of Stoner Creek. Transformers Two transformers containing transformer oil (i.e. mineral oil) are located near the building. One large transformer is located in the fenced in area west of the building. The large transformer contains a total of 3,172 gallons of oil. One pad-mounted transformer is located near the large transformer. The pad-mounted transformer contains 540 gallons of oil. Potential spills would be directed to the north toward outfall 3 and eventually to an unnamed tributary of Stoner Creek. Spills outside of the ALUMINUM DIVISION Building may result from the following:
a) Leaking, ruptured, overturned, or otherwise damaged containers during storage or transfers to and from the building;
b) Overfilling of emergency generators or storage containers; or c) Leaking transfer lines, fittings, or pumps.
Spill response equipment are located throughout the facility to serve as active secondary containment measures. 5.5.3 Pole Barn The Pole Barn is located east of the ALUMINUM DIVISION building and stores supplies, oil, and equipment that are manually transported for use in the STEEL DIVISION and ALUMINUM DIVISION buildings. Multiple 55-gallon capacity drums containing glycol-based lubricating fluids are located in the benchstock storage area. These drums are constructed of steel and are typically closed top with bunghole openings. Manual pumps used to remove the fluids are attached to some of these drums. Additionally, five-gallon containers of vacuum pump oil, gear oil, grease, and cylinder oil, a 375-gallon tote of hydraulic oil, and several 300-gallon coolant totes are stored in the building. Waste coolant is contained in a 3,500-gallon tank with containment. (The coolant is considered used oil because petroleum based oil is a component of the coolant.) The floor of the Pole Barn is concrete and contains an echo drain that runs the full length of the building. Spills associated with the Pole Barn may result from the following:
a) Leaking, ruptured, overturned, or otherwise damaged containers during storage or transfers to and from the building;
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b) Overfilling of storage containers; or c) Leaking transfer lines, fittings, or pumps.
Spill response equipment is located in the Pole Barn to serve as active secondary containment measures. 5.5.4 Wastewater Treatment Oil Storage Area An open wall shelter with an extended overhang is located northeast of the STEEL DIVISION Building. Multiple 345-gallon capacity totes containing used/waste oil are located in the southwest corner of the shelter. Three 1,500-gallon capacity vertical aboveground storage tanks are located in the northeast corner of the shelter. The tanks hold the used oil refined from the separating process. Multiple 55-gallon capacity drums are also located on a used oil storage pad located adjacent to the oil/water separator. These drums are constructed of steel and are typically closed top with bunghole openings. An adjacent uncovered concrete pad is located off the southeast corner of the shelter. This pad is used for container transfers from vehicles. The pad has a concrete sump on the northeast corner to recover liquids that are released on the pad. An automatic pump inside the sump transfers liquid through piping to the sump under the shelter. Spills associated with the Shelter may result from the following:
a) Leaking, ruptured, overturned, or otherwise damaged containers during storage or transfers to and from the shelter;
b) Leaking from rupture of the ASTs or associated piping at the shelter; c) Overfilling of storage containers or ASTs; or d) Leaking transfer lines, fittings, or pumps during transfers to recovery
vehicles. The largest expected single uncontained spill quantity in this area would be 1,500 gallons. The shelter floor is concrete sloping from the southern boundary of the shelter, which is level with the outside area, to the northwest. The floor has an elevated portion along the eastside of the shelter. Based upon the dimensions, the floor has the capacity to contain approximately 5,950 gallons of liquid. A sump is located in the northwest corner of the floor. Uncontained spills on the floor would flow by gravity toward the sump. The sump has an additional capacity of approximately 200 gallons. A manual pump in the sump can transfer liquid from the sump to a wastewater holding tank at the industrial treatment facility located directly west of the shelter. Spill response equipment is located in the Wastewater Treatment Area to serve as active secondary containment. 5.6 Emergency Procedures Posting Emergency Response procedures for all employees, relating to evacuation and fire are posted in a conspicuous location in each department.
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5.7 Inspection Procedures The entire facility is subject to monthly inspection by the operating personnel. A copy of the checklist used is maintained by the Product Assurance Document Control Administrator. These inspections include observation of facility drainage, bulk storage, transfer operations, and security. Specific items inspected include drum and container storage, secondary containment, valves, hoses, lighting, locks and other equipment. Any sign of damage, deterioration, or leakage is noted on the checklist and investigated. Corrective actions are initiated as soon as practical following the investigation, and are recorded on the checklist. An evaluation for fracture will occur for all field constructed aboveground oil-containing tanks and containers undergoing repair, alteration, reconstruction or change in service that might affect the risk of discharge. In addition, all existing and new aboveground tanks and containers will undergo regularly scheduled inspections and/or testing as well as inspections and/or testing in association with any repairs based on guidance documents, industry standards, and good engineering judgments. The frequency and type of integrity testing varies with container size and design, and could include either visual observation, hydrostatic testing, ultrasonic testing, radiographic testing, or other non-destructive shell testing according to guidance documents, industry standards, and good engineering judgments. Integrity testing is necessary to determine if the container is suitable for continued use until the next formal inspection. Based on the good engineering judgment of the certifying engineer, the following criteria describe the general bulk storage containers that must be included in a periodic visual inspection. However, these criteria may allow the bulk storage containers to deviate from periodic integrity testing based on either environmental equivalence or industry standards:
1. 55-gallon drums of petroleum products/oils that are stored in
secondary containment and are not stored in contact with the ground (based on Question 5, US EPA Memo Sep 30, 2002 and the SPCC Guidance for Regional Inspectors dated August 28, 2013), or
(ASTs) when equipped with automatic detection devices to detect discharges into the interstitial space (based on OSWER MEMO 9360.8-38 and Steel Tank Institute standard SP001, 5th edition), or
3. Generally containers with a shell capacity of 30,000 gallons or less,
stored in secondary containment, and that are a. shop-fabricated, and b. supported or elevated where all sides and the bottom are visible
to periodic inspections, c. whose contents are not considered corrosive to the container’s
materials of construction, and
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d. whose storage or use location would not pose a risk to the environment if the entire contents of the container were released in the immediate location of the bulk storage container
(based on Steel Tank Institute Standard SP001, 5th Edition, good engineering practice and two SPCC Guidance for Regional Inspectors dated February 3, 2006 and August 28, 2013).
Therefore, based on good engineering judgment by the certifying professional engineer, the 55-gallon drums and plastic totes containing oil are stored inside the facility buildings and do not require integrity testing based on the following practices that provide equivalent environmental protection pursuant to 40 CFR 112.7(a)(2):
a. the drums and totes are located inside the building, b. the drums and totes are shop fabricated, c. each drum and tote has full secondary containment, that includes
either plastic containment pallets or concrete flooring with curb or walls, around them and the secondary containment is sufficient to hold the contents of one of the containers,
d. they are located on an impervious surface (concrete floor) with curbing or building walls,
e. the drums and totes are not located adjacent to a door to the outside, f. the drums and totes are not located adjacent to a drain where a spill
would migrate to the environment, g. the drums and totes are constructed of material compatible with the
contents of the tanks, h. there was little evidence that the drums and totes had been involved in
any major spills or leaks, i. the drums and totes are not stored in contact with the ground but are
on impervious flooring, j. the drum areas are included on a monthly inspection checklist
developed for the ISO 14001 program and maintained by the Product Assurance Document Control Administrator, and
k. the spill response kit and materials are immediately available in the facility building in the event of a spill.
According to the Steel Tank Institute standard SP001, the elevated steel, 3,500-gallon Used Oil Tank in the pole barn can comply with the integrity testing requirements found in 40 CFR 112.8(c)(6) by utilizing a release prevention barrier and monthly and annual inspections to detect any discharges from the tank. The release prevention barrier consists of the impervious concrete flooring under the elevated tank that directs any large spill or release onto the floor for visual detection and containment. The facility will perform specific monthly and annual inspections of the tank to comply with the industry standard. The monthly inspection will be performed using the previously developed ISO 14001 inspection checklist for the Alum Division Pole Barn that is maintained by the Product Assurance Document Control Administrator. The annual Inspection will be performed using the STI SP001 Annual Inspection Checklist to comply with
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the industry standard. A copy of the STI SP001 Annual inspection Checklist is found in Appendix G. Integrity testing inspections would also be applicable to the seven emergency generators located on the property. The tank structures and housing are subject to the integrity testing requirements because the tanks are not pivotal to the operation of the generators; therefore, the generators do not meet the definition of “oil filled equipment” and are subject to aboveground bulk storage requirements. The diesel tanks inside the generators are either double-walled or contain built-in secondary containment. The generators are equipped with high fuel level alarms. All of the generators are positioned on top of a concrete pad. Integrity testing must be performed according to industry standards for the generator tanks. The standards used to develop the testing requirements are from the Steel Tank Institute (STI) “SP001 Standard for the Inspection of Aboveground Storage Tanks” (STI SP001). Based on the type and construction of the integral diesel tanks of the emergency generators, formal external inspections conducted by a certified inspector are not required. However, the tanks do meet the minimum category for requirement of an inspection schedule for integrity testing on a monthly basis and an annual basis to comply with the industry standard. The monthly inspection will be performed using the previously developed ISO 14001 inspection checklists for each generator that is maintained by the Product Assurance Document Control Administrator. The annual inspection will be performed using the STI SP001 Annual Inspection Checklist to comply with the industry standard. A copy of the STI SP001 Annual Inspection Checklist is included in Appendix G. 5.8 Inspection Records Copies of the completed inspection forms are signed by the appropriate supervisor or inspector. Inspection forms/reports shall be kept on-site for at least three years as per 40 CFR 112.7(e). Records of SPCC inspections can be found in Appendix G. 5.9 Safeguards for New and Existing Equipment For new construction of oil handling equipment, safeguards must be included for corrosion protection. Any new buried piping installed or replaced at the facility must have protective wrapping and coating, or cathodic protection, or otherwise satisfy federal requirements of 40 CFR 280 or state requirements approved under 40 CFR 281 for corrosion protection. If any existing piping is placed out of service, the terminal connection must be capped or blank flanged at the transfer point with appropriate marking to indicate the origin of when the piping was taken out of service. If secondary containment is not practical to install for a tank or containers, the facility must explain why it is not practical. If secondary containment is not
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practical to install, written procedures must be developed by the facility for the inspection and testing of tanks, containers and pertinent equipment such as valves and piping.
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6.0 STORMWATER POLLUTION PREVENTION PLAN 6.1 Background In 1987, the Clean Water Act (CWA) was amended by congress to address issues related to stormwater discharges. The revised CWA amendments required EPA to establish National Pollution Discharge Elimination System (NPDES) permit application requirements for stormwater discharges associated with specific sources, which included industrial activities. In response to this requirement, the EPA published permit application requirements in the Federal Register on November 16, 1990 (55 FR 47990). One of the provisions of the CWA was that it allowed States to request EPA authorization to administer the NPDES program instead of EPA. Upon authorization of a State program, the State is primarily responsible for overseeing the program, including issuing permits and administering the NPDES program within the State. Following authorization, the State NPDES must be consistent with the minimum Federal requirements, although they may always be more stringent. The state of Kentucky has received approval from the EPA to administer its own program, i.e. the KPDES permit program. In order to satisfy the requirements of the EPA’s stormwater program, Kentucky’s Division of Water (DOW) drafted and submitted its general stormwater permit in 1991 to the EPA for approval. The DOW was subsequently granted permit approval by the EPA in 1992. The DOW then began issuing general permits (KYR000000) for industrial activities in September 1992. Permit requirements were expanded with the DOW release of the re-issued general permit for stormwater discharges associated with industrial activity in June 2013. In August 2013, the DOW issued STEEL DIVISION and ALUMINUM DIVISION permit coverage (KYR003305). Kentucky’s general industrial stormwater permit consists of six parts:
a) Section 1 - Effluent Monitoring Requirements; b) Section 2 - Non-numeric Effluent Requirements; c) Section 3 - Stormwater Pollution Prevention Plan; d) Section 4 - Additional Requirements e) Section 5 - NOI Requirements and Conditional Exclusion for No
Exposure f) Section 6 - Standard Conditions
In addition to the monitoring requirements and permit conditions outlined in Section 1 and Section 2, the general permit requires the development and implementation of a stormwater Pollution Prevention (SWPP) Plan. The SWPP Plan must be developed in accordance with good engineering practices and must outline site-specific BMP’s, or Best Management Practices, which will reduce or eliminate pollution entering surface waters.
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In order to be covered under the general permit, an applicable facility with industrial activity must submit a notice-of-intent (NOI) to the DOW. Upon issuance of a general permit, the facility has 180 days to complete or implement compliance requirements for permit conditions. The current KYR000000 permit was effective as of June 1, 2013; therefore, CMWA must fully implement the SWPPP for control and management of stormwater discharges by December 1, 2013. A copy of the submitted NOI form, coverage letter and general KPDES permit KYR000000 can be found in Appendix I. CMWA has prepared the following SWPPP in accordance with the requirements of Kentucky’s General Permit KYR000000 Section 3 and the EPA document titled Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators (EPA 833-B-09-002, February 2009). 6.1.1 Facility Owner and Operator This information is included in Section 2.1, Facility Identification. 6.1.2 Responsible Individual The person responsible for the implementation of the plan (PLAN IMPLEMENTER) is: Bruce Allison, General Manager Steel Division
This plan should be certified by a responsible official of CMWA and retained by the Environmental Management Program Coordinator at the facility at all times. The responsible official must have the responsibility for the overall operation of the facility, such as a manager, operator, superintendent, or have a position that has overall responsibility for environmental matters. All records evidencing compliance including monitoring information shall be maintained and available for review for a period of six (6) years from the date of measurement, report or application. The SWPPP shall be retained until at least one year after coverage under the General Permit terminates. The regulations require that the plan implementer provide the SWPPP upon request to the Director of the DOW or other State or local agencies approving stormwater discharges associated with industrial activity. In addition, because the SWPPP is considered public record under the CWA, the plan implementer shall make the Plan available to the public upon request. However, the permittee may claim any portion of the SWPPP as confidential and therefore unauthorized for public review. The plan implementer shall amend the SWPPP whenever there is a change in design, construction, operation, or maintenance that has a significant potential for the discharge of pollutants to the waters of the Commonwealth. Additional revisions may become necessary if the plan proves to be ineffective in preventing
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or minimizing pollutants or fails in achieving the general objectives of controlling pollutants in stormwater discharges. 6.2 Stormwater Pollution Prevention Team and Environmental Committee The first step in implementing the Stormwater SWPP Plan is to identify individuals within the facility organization to be members of a Stormwater Pollution Prevention Team. The team is responsible for developing the plan and assisting in its implementation, maintenance, and revision. The responsibilities of each team member are clearly identified. The activities and responsibilities of the team address all aspects of the facility’s SWPP Plan. The team will provide adequate structure and direction to the facility’s stormwater management system. Each member of the team must have ready access to a copy of the KYR000000 permit. CMWA’s Environmental Committee will provide guidance and support for the Stormwater Pollution Prevention Team. The Environmental Committee is comprised of key plant personnel who are responsible for developing company environmental policies and ensuring compliance with environmental regulations. The President of the facility chairs the committee. The General Manager Steel Division at CMWA will oversee the Stormwater Pollution Prevention Team. It is his responsibility for reviewing policies, providing guidance to Plant personnel, and overseeing implementation of CMWA’s SWPP Plan. He will appoint other individuals if necessary to carry out the specific Stormwater protection practices including developing a training and education program that address the legal, operational, and technical requirements for managing stormwater protection. The Plant Services Coordinator and other members of the environmental committee will be responsible for implementing developing, tracking, monitoring, and reporting on stormwater protection management. The purpose of designating specific team members makes it clear that it is part of these individuals' responsibilities to prevent stormwater pollution. It also provides a point of contact to other facility personnel and regulatory officials to discuss specific aspects of the plan. The team is made up of key on-site personnel who are familiar with the facility and its operations. The team is comprised of representatives from all phases of the facility’s operations. It includes personnel from management, operation, waste material handling, maintenance, and shipping and receiving. The team is responsible for the following: Implementing all pollution prevention plan requirements.
Defining and agreeing upon an appropriate set of goals for the facility’s
stormwater management program.
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Being aware of changes that are made in facility operations and
determining whether changes must be made to the SWPP Plan. Overseeing routine materials inventory and recommending ways to reduce
or eliminate hazardous materials. Implementing and overseeing employee training and the inspection
program. Identifying potential pollutant sources and recommending ways to alleviate
problem areas through changes in operations, equipment, layout and materials.
Coordinating the implementation of best management practices, reviewing
the effectiveness of the program, and updating the program as needed. Reporting the results and advising Management of problems encountered.
6.3 Monitoring Requirements Under the terms of the General Permit, CMWA will be required to conduct monitoring of its stormwater discharge at a frequency of two times per year. Sampling will consist of collecting grab samples at each stormwater drainage location prior to discharge off-site. The location of the stormwater sampling points is outlined in Figure 7, Surface Water Flow Path. Grab samples will be collected within the first 30 minutes of a significant rainfall event. A significant rainfall event is defined as a storm event that is greater than 0.1 inches and at least 72 hours following the previous measurable (greater than 0.1 inch rainfall) storm event. Under the General permit, monitoring requirements do not apply to stormwater events greater in magnitude than the ten year, 24-hour storm event. If sample collection within the first 30 minutes is not possible, a grab sample can be taken within the first hour of the discharge. The Plan Implementer should then note the reason why a grab sample during the first thirty minutes was impractical. All grab samples collected by CMWA must be properly handled and analyzed by methods outlined in 40 CFR Part 136. Analytical requirements under CMWA’s General Permit are as follows: Parameter Sample Type Preservative Sample Hold Time Flow Instantaneous N/A N/A
Total Suspended Solids Grab None 7 Days
Oil and Grease Grab HCl 28 Days
pH Grab None On-Site
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Once the stormwater grab samples have been collected, CMWA will submit the samples to a qualified laboratory for analyses. All analytical results received from the laboratory, along with chain-of-custody sheets, will be maintained on-site. The records of monitoring information will include the following:
1. The date, location, and time of sampling and measurements; 2. The individuals who performed the sampling and measurements; 3. The dates the analyses were performed; 4. The individuals who performed the analyses; 5. The analytical techniques or methods used; and 6. The results of the analyses.
In order to determine the flow as required by the General Permit, it will be necessary to determine the total flow volume within the stormwater conveyance. Ideally, a weir or a pipe of known size that can be measured for depth of flow should be available at each discharge location. The discharge flow rate could then be calculated based on the depth of flow values. If this is not practical, then the estimated flow can be obtained by measuring the velocity of the discharge. The velocity can be estimated by timing the flow between two points of known distance. Once the velocity measurement is obtained, the flow volume can be calculated using the cross-sectional area of the conveyance as follows: Q(cfm) = Velocity (fpm) x Area (square feet) The maximum flow rate for the storm event is the highest value recorded during the storm’s duration. 6.4 Regular Inspections and 2-Year, 24-Hour Inspections In addition to the required numeric monitoring requirements, the General Permit requires that the stormwater discharge be free of floating solids, visible sheen, or visible foam other than trace amounts. An Outfall Inspection Form (Appendix N) will be completed on a quarterly basis to verify that the outfalls are free of floating solids, visible sheen, or visible foam. Regular inspections, at least quarterly, are a requirement of the general KPDES permit. The purpose of the quarterly inspections is to visually determine the effectiveness of control measures and BMPs, to identify maintenance and repair needs, and to identify any potential or actual permit violations. Additionally, CMWA shall conduct inspections in response to storm events in excess of the 2-year, 24-hour storm event to verify the stability of the installed control measures and BMPs. As defined by the National Weather Service in Technical Paper No. 40, “Rainfall Frequency Atlas of the United States,” May 1961, the 2-year, 24-hour event for the CMWA location is approximately equal to 3.0 inches of rain during a 24-hour period.
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CMWA shall also conduct an annual site assessment (see Section 10) in addition to the regularly scheduled quarterly inspections. The annual assessment shall include a review of the SWPPP and determination that there are no new pollutant sources on the property, in conjunction with confirmation that existing stormwater controls are functioning properly. A comprehensive site assessment checklist is included in Appendix O. The Stormwater Pollution Prevention Team shall prepare a report for each inspection conducted by the team that documents the following information:
1. The inspection date and time; 2. The type of inspection (i.e. scheduled or in response to a precipitation
event in excess of a 2-year, 24-hour event); 3. The name(s) and signature(s) of the inspector(s); 4. Weather information and a description of any discharges occurring at the
time of the inspection; 5. Any previously unidentified discharges of pollutants from the site; 6. Any control measures needing maintenance or repairs; 7. Any failed control measures that need replacement; 8. Any additional control measures that need replacement; and 9. Any other corrective action required as a result of the inspection.
Inspection reports can be found in Appendix M and Appendix N. The facility is required to keep a precipitation log and record daily precipitation on at least a monthly basis. This permit requirement will be satisfied by using daily readings from the rain gage located on-site. The daily precipitation log shall be retained as an addendum to the SWPPP in Appendix K. 6.5 Additional Permit Conditions In addition to the Section 1 monitoring requirements, the General Permit establishes additional conditions under Sections 2 - 5 for facilities required to have coverage for stormwater discharges associated with industrial activities that are not required to obtain an individual KPDES permit. Section 6 of the General Permit applies the KPDES permit conditions outlined in 401 KAR 5:065, Section 1. This regulation outlines the conditions applicable to all KPDES permits and the procedures for establishing and calculating permit conditions. Section 2 of the General Permit outlines non-numeric effluent requirements specific to stormwater discharges. 6.6 Evaluation of Non-stormwater Discharges Among the additional requirements outlined in Section 4 of the General Permit is a prohibition of non-stormwater discharges. Any discharges of materials must be in compliance with a KPDES permit (other that the General Permit) issued for the discharge. Examples of non-stormwater discharges include non-contact cooling water, sanitary wastes, vehicle wash water and any water used directly in the
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manufacturing process. Exceptions to the non-stormwater prohibition include allowable discharges from the following:
a) Fire-fighting activities; b) Fire hydrant flushings; c) Potable water, including water line flushings; d) Uncontaminated condensate from air conditioners, coolers, and other
compressors and from outside storage of refrigerated gases or liquids; e) Irrigation drainage; f) Landscape watering provided all pesticides, herbicides, and fertilizers
have been applied in accordance with the approved labeling; g) Pavement wash waters where no detergents are used and no spills or
leaks of toxic or hazardous materials have occurred (unless all spilled material has been removed);
h) Routine external building washdown that does not use detergents; i) Uncontaminated ground water or spring water; j) Foundation or footing drains where flows are not contaminated with
process materials; and k) Incidental windblown mist from cooling towers that collects on rooftops or
adjacent portions of the facility, but not intentional discharges from cooling tower.
In order to determine whether illicit non-stormwater connections exist, all outfalls must be tested or evaluated for the presence of non-stormwater discharges. Acceptable procedures include: dry weather observations of outfalls or other appropriate observation locations; the analysis and validation of accurate piping schematics; dye tests; or other procedures for ensuring that there are no inappropriate connections or discharges to the storm drain system. CMWA’s authorized representative must certify that there are no non-exempt non-stormwater discharges from the CMWA facility to the stormwater conveyance system. The certification includes the following:
a) Identification of potential non-stormwater discharges; b) A description of the results of any test and/or evaluation for the presence
of non-stormwater discharges; c) The evaluation criteria or test method used; d) The date of testing and/or evaluation; and e) The on-site drainage points that were directly observed during the test
and/or evaluation. Certification records are maintained on-site. If the testing or evaluation determines that there is a non-stormwater discharge to the stormwater collection system, the discharge should either be disconnected immediately or permitted under the KPDES program. Any control measures used to eliminate unauthorized discharges shall be documented with the certification. The description of the evaluation must include: the procedure of any test conducted for the presence of non-stormwater discharges; the results of such tests or other relevant observations; potential sources of non-stormwater discharges to the
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storm sewer; and why adequate test for such storm sewers were not feasible. The updated certification for the evaluation of non-stormwater discharges is included in Appendix J. 6.7 Potential Pollutant Sources The second step of the SWPPP is to provide a description of potential sources which may be reasonably expected to add significant amounts of pollutants to stormwater discharges or which may result in the discharge of pollutants during dry weather from separate storm sewers. The potential sources of stormwater pollutants are assessed by evaluating drainage from the facility, conducting a materials inventory, evaluating past spills and leaks, identifying any non-stormwater discharges and illicit connections to the storm sewer, and evaluating any existing stormwater quality data. This assessment provides a risk-based approach by assisting in targeting the most important pollutant sources for corrective and/or preventive action. 6.7.1 Site Drainage The CMWA facility, located in Paris, Kentucky is situated on approximately 55 acres. The primary products manufactured are aluminum and steel wheels for automobiles and light-duty trucks. The site layout includes two main buildings: the STEEL DIVISION facility and the ALUMINUM DIVISION facility. Both facilities are constructed of steel and concrete block. Additional structures on the property include the wastewater treatment facility, covered storage areas for hazardous wastes, roll-off boxes and aluminum storage. There are a total of seven principal stormwater conveyance pathways that discharge from the CMWA property: one flowing to the north of the ALUMINUM DIVISION facility, three flowing to the east of the ALUMINUM DIVISION facility, and three flowing to the south of the STEEL DIVISION facility. The ALUMINUM DIVISION’s runoff is to the north or east and the STEEL DIVISION’s runoff is predominately to the south. A portion of the stormwater generated in the southeast drains to a detention basin prior to discharge from a permitted outfall. Stormwater discharges from the STEEL DIVISION facility with potential industrial activity exposure flow primarily to the southeast discharge point, Outfall 001. The drainage area for this discharge point includes shipping and receiving, roll-off storage and a portion of the wastewater treatment facility. The southwest discharge point (Outfall 002) includes STEEL DIVISION’s office parking area and most of the grass area in front (west) of the STEEL DIVISION facility. Drainage between Outfalls 002 and 001 is generated at the southern side of the building and is directed to Outfall 007. Stormwater discharges with potential industrial activity exposure at the ALUMINUM DIVISION flow primarily to the eastern discharge points, Outfalls 004, 005, 006. The areas which have potential exposure include the receiving, dust collectors and wash bay/oil storage area. Additionally, the ALUMINUM
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DIVISION facility’s drain system also discharges to the northwest drainage point, Outfall 003. The drainage area for the northwest discharge point includes the main employee parking area and ALUMINUM DIVISION’s shipping and office parking areas. A site drainage map provided in Figure 7, Surface Water Flow Path outlines the following information:
a) Property boundaries; b) Buildings and structures; c) Grassy, graveled and paved areas; d) Operation or process areas; e) Stormwater conveyances and outfalls; f) Drainage areas and flow direction; g) Structural stormwater controls; and h) Surface water bodies.
6.8 Assessment Summary Potential pollutant risks identified are generally limited to housekeeping activities, loading/unloading, and transfer of process chemicals or hazardous wastes from the storage facility. The transfer of chemicals and hazardous wastes probably constitute the major source of potential stormwater contamination. No means of containment presently exists should a spill occur along the drive areas. Likewise, pollutant risks associated with the loading/unloading areas exist due to the lack of any secondary containment. Aluminum and Steel Division Chemical Storage List Maps are maintained that depicts chemical storage areas by location. 6.9 Materials Inventory The CMWA facility has few materials that are exposed or potentially exposed to stormwater. The facility has some outdoor loading and unloading operations that may result in materials coming in contact with stormwater associated with runoff. In addition, hazardous wastes generated from production processes are transferred from the two main facilities to the hazardous waste storage area. Storage of drums or chemical containers outside either the main facilities or hazardous waste storage area is not allowed. The MIRS database contains a list of materials used or stored on-site. For those chemicals that CMWA has deemed to have a potential to exceed Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III reporting thresholds, the following information is also included in the MIRS database:
a) Name of material; b) Storage location; and c) Quantity of material used or stored.
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For chemicals that are currently used by the facility, CMWA has identified the products that have a potential to impact stormwater associated with runoff and has developed material handling procedures to minimize the potential of stormwater impact. NPAF-001 – New Product Approval Form will be completed before a new material is brought into the facility. The New Product Approval Form will contain physical and constituent information on the new material being used, as well as information on the safe and proper handling of the material. Information contained on the New Product Approval Form can be entered into both the MIRS database and also the Environmental Monitoring & Measurement Summary. The following subsections outline the methods and locations of on-site storage and the associated existing materials management practices employed to minimize the contact of these materials with stormwater. 6.9.1 Hazardous Waste Storage Area Hazardous waste is taken directly from satellite storage areas to the Hazardous Waste Storage Area. CMWA has already taken steps to assure stormwater protection. Specifically, CMWA has constructed the hazardous waste storage structure which itself is a protective practice. The structure is covered with a steel roof that serves to minimize the stormwater exposure. The structure has a concrete slab floor with a concrete berm to provide secondary containment. The floor is sloped towards sumps that collect any spills or leaks. A vinyl liner was installed beneath the concrete pad for additional protection. As described above, CMWA has in place many stormwater protection measures for hazardous waste storage, including: Storage of the material inside a covered structure. The structure is designed to prevent contact with stormwater should a spill
or leak occur, i.e., concrete berms have been constructed and sloped towards a sump.
The structure has restricted access when appropriate personnel are not
on-site. Spill response equipment is stored for ready access in the event of a spill
during transport from the plants to the structure. Employees are trained in spill prevention and response. All hazardous waste is moved within two (2) days from satellite storage to
hazardous waste storage area. Transfer route is paved.
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6.9.2 Industrial Storing/Handling Inside Main Facilities Bulk quantities of regulated substances are temporarily stored and handled at various locations inside the two main facilities. These include solvents, coolants, acids and caustics, and pretreatment chemicals. Because the materials are stored and handled within the two facilities, there is little potential for exposure to stormwater. All floor drains and echo drains within each facility discharge to the wastewater treatment facility. There are no illicit drains that discharge from either facility. 6.9.3 Shipping/Receiving Areas The greatest risk associated with management of the materials is during the loading and unloading of materials and the transfer of materials between storage and use locations. There are no containment areas around the shipping and receiving locations that would prevent spillage from migrating into outlying areas. Specific stormwater protection practices will include employee training to educate employees on proper material handling procedures, spill response measures, good housekeeping and reporting/notification procedures. 6.9.4 Rolloff Storage Area – STEEL DIVISION The STEEL DIVISION has constructed a rolloff shed on the eastside of the facility which minimizes exposure to stormwater. All press wastes and other industrial solid wastes are stored under the rolloff shed. The floor of the shed is constructed of concrete and is sloped towards a centrally located drain. The drain discharges to a lift station that was installed to the south of the concrete pad and is stainless steel lined for additional protection. A vinyl liner was installed beneath the concrete pad for additional protection. Rolloff hoppers which are not kept under this shed are used for non-industrial wastes only. Employees are trained in the proper disposal of all waste products. 6.9.5 Wastewater Treatment Area The wastewater treatment facility is located between the STEEL DIVISION and the ALUMINUM DIVISION facilities on the eastern end of the CMWA complex and provides treatment for all wastewater discharged from both plants. Wastewater treatment processes include coagulation and precipitation, clarification, and final pH adjustment. Sludge from the precipitation process is concentrated using a filter press. Wastewater treatment tanks are located both inside and outside of the wastewater treatment building. The entire area surrounding the wastewater treatment complex has a soil berm to provide containment and a collection system with a capacity greater than the largest tank (Equalization Tank). The containment structure has a drainage system with a manually controlled valve at the topographic low point.
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The potential for stormwater exposure and pollutant runoff at the wastewater complex is minimal. All treatment chemicals and sludge wastes are stored within the wastewater treatment building and are therefore not exposed to rainwater. Potential exposure of treatment chemicals to stormwater would most likely be from the transfer and handling of the chemicals outside the treatment building. Wastewater treatment operators are trained in good housekeeping, proper material handling procedures, and spill prevention and response. 6.9.6 Dust Collectors Dust collectors are used at the STEEL DIVISION to control particulate emissions from various processes (i.e. welding). Because the dust collection systems are completely contained, there is minimal risk of stormwater exposure. The waste is collected from each dust collector is stored in individual drums. The drums are checked routinely and replaced once capacity is reached. 6.9.7 Salt Storage The facility uses deicing salt for paved surfaces during the winter. However, the bagged salt is stored on wooden pallets inside the pole barn located behind the STEEL DIVISION. The facility does not have any salt storage piles exposed to precipitation. 6.10 Summary of Stormwater Sampling Data A summary of the stormwater sampling data from the permit coverage between July 2008 and April 2013 is included on the following page. The values are average values for each parameter obtained at a particular outfall. Summary of Stormwater Sampling Data (7/28/08 to 4/24/13)
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6.11 Corrective Action Reports and SWPPP Modification The Stormwater Pollution Prevention Team shall review and revise as necessary the selection design, installation, and implementation of the control measures and BMP’s as a result of the following events:
1. An unauthorized discharge or release of pollutants from the facility; 2. As a result of an inspection or evaluation by the Stormwater Pollution
Prevention Team, or any federal, state, or local authority or their representative who determines that the control measures and/or BMPs are not being properly operated or maintained or are not achieving compliance with the conditions of this permit; or
3. Changes at the facility which significantly alter the nature of pollutants discharged in stormwater or significantly increases the quantity of pollutants discharged.
As soon as practicable after the discovery of any of the preceding conditions the Stormwater Pollution Prevention Team shall document in an initial Corrective Action Report the following: (1) identification of the condition triggering the need for corrective action review, (2) description of the problem identified, and (3) date the problem was identified. As soon as practicable after the discovery of any of the preceding conditions the Stormwater Pollution Prevention Team shall document in a comprehensive Corrective Action Report the following: (1) a summary of corrective actions taken or to be taken, (2) date corrective actions were or are to be initiated, (3) date corrective actions were completed or expected to be completed, (4) summary of any necessary SWPPP modifications, (5) date SWPPP modifications are to be completed. The SWPPP shall be modified whenever necessary to address any noted corrective actions. Refer also to Section 10 – Annual Site Compliance Inspection. A copy of the report template for Corrective Action Reports can be found in Part D of Appendix O. 6.12 History of Past Spills and Leaks A List of Significant Spills and Leaks (Appendix H) will be maintained by the Stormwater Pollution Prevention Team and will include a list of spills and leaks at the facility should they occur. The table should be updated as soon as possible following a release. The table report should also include as much information as possible to describe the site conditions leading up to the release. The information in Appendix H satisfies the Incident Reports requirement for the SWPPP and shall be retained with the plan. Releases of hazardous wastes or hazardous materials to the stormwater system in excess of reportable quantities are subject to the reporting requirements under applicable state and federal requirements. In addition, the SWPPP shall be modified as necessary upon knowledge of a release to: provide a description of
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the release, circumstances causing the release, date of the release, and corrective actions. The SWPPP must be reviewed and modified where appropriate to identify measures to prevent the reoccurrence of the release and to respond to any future releases. The Stormwater Pollution Prevention Team shall document the details of the release in a Corrective Action Report.
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7.0 EMERGENCY PROCEDURES FOR HAZARDOUS WASTE The purpose of this document is to minimize hazards to human health or the environment from fires, explosions, or any unplanned releases of hazardous materials or hazardous substances to air, soil, or surface water. The provisions of this document will be carried out immediately whenever there is a fire, explosion, or release of hazardous materials or hazardous substances that could threaten human health or the environment. A copy of this document and all revisions will be maintained at the facility and submitted to all local police departments, fire departments, hospitals, and state local emergency response teams that may be called upon to provide emergency services. This document will be reviewed, and immediately amended, if necessary, whenever;
a) Applicable regulations are revised; b) The plan fails in an emergency; c) The facility changes in its design, construction, operation, maintenance, or
other circumstances; in a way that materially increases the potential for fires, explosions, or releases of hazardous materials or hazardous substances; or changes the response necessary in an emergency;
d) The list of emergency coordinators changes; or e) The list of emergency equipment changes.
7.1 Emergency Coordinators This information is included in Section 3.1, Emergency Coordinators. The duties and responsibilities of the Emergency Coordinators is as described in Section 3.1, 7.2 Implementation of Emergency Response Procedures This Contingency Plan must be implemented as described in Sections 3.2 through 3.5 if an imminent or actual incident could threaten human health or the environment. 7.3 List of Emergency Equipment for Hazardous Waste Purposes Hazardous wastes generated by CMWA are containerized in approved DOT containers, and placed in the designated hazardous waste storage area, which is on a concrete pad. This accumulation area is located north of the waste water treatment building, outside the plant. The purpose of this list is to inventory all emergency equipment that will be obtained for use in an emergency situation involving the hazardous waste storage area or the wastewater treatment process. This list includes, for each item:
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a) location; b) physical description; and c) brief outline of capabilities
Alarm
CMWA has a facility wide Fire Control Instruments, Inc. alarm system that is monitored by a security guard 24 hours a day.
Fire Extinguishers
Hand held fire extinguishers are located throughout the plant. The extinguishers are ABC, CO2, halon and Metal-X type extinguishers, effective on combustible material (A), flammable liquid (B), electrical (C), and combustible metals (D) fires. A plant-wide sprinkler system is maintained by CMWA.
Communication System
CMWA utilizes a UHF Band radio system for in-plant communication. All maintenance and production coordinators and team leaders carry radios at all times. Security personnel have access to another walkie-talkie. In chemical release situations, personnel have been instructed to immediately contact a supervisor, maintenance manager or quality coordinator. Plant personnel will be alerted of chemical release situations either verbally or by means of the in-plant alarm.
Spill Response Equipment
CMWA maintains a supply of absorbent socks, pillows, mats and personal protection equipment (PPE) in spill cabinets. These supplies can be used to contain and clean up small releases of chemicals or oil.
7.4 Coordination Agreements and Quick Reference Guide 40 CFR 112.7 (a) (3) (vi) requires a contact list and phone numbers of state, federal, and cleanup contractors who have an agreement for response and local agencies who must be contacted in case of a discharge. See also Sections 3.3.1 and 3.3.2. 40 CFR 262.262 (b) requires a large quantity generator that first becomes subject to these provisions after May 30, 2017 or a large quantity generator that is otherwise amending its contingency plan must at that time submit a quick reference guide of the contingency plan to the local emergency responders identified at paragraph (a) of this section or, as appropriate, the Local Emergency Planning Committee. See Appendix P Quick Reference Guide.
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7.5 Evacuation Plan Because CMWA’s hazardous waste container storage area is located outside and away from other plant facilities, a comprehensive, plant-wide evacuation plan would be necessary only in the event of a massive release. Because CMWA stores only small quantities of waste, such an event is unlikely to occur. For more information, refer to GENEV-003 – CMWA Emergency Action Plan (EAP). Department Evacuation Maps shall be maintained by Department Coordinators as records supporting our EAP. For evacuation of the outside container storage area, the following procedures apply. If and when the Emergency Coordinator determines that evacuation of the storage area is necessary, he is to instruct employees in the area to evacuate. The Emergency Coordinator is to account for all employees. The Fire Department should be notified of any employees unaccounted for. As previously discussed, the storage area is sufficiently isolated to negate the necessity of an evacuation of production areas. 7.6 Required Reports Copies of written reports required by federal, state and local authorities as a result of ICP implementation will be maintained in the appropriate locations. 7.7 Identification of Hazardous Materials Copies of the Material Safety Data Sheets (MSDS) for hazardous materials used and stored on-site can be accessed via computers located: STEEL DIVISION Cafeteria ALUMINUM DIVISION Cafeteria Hard copies are maintained in the Guard Shack
7.8 Procedure for Proper Control of Waste Generated The following steps are to be followed to ensure proper disposal of waste generated:
1. Select proper container for storage while waste is being generated. (Non-leakage). Remove or cover all labels on container.
2. After properly selecting an appropriate container, identify container by
writing type of waste being generated and attaching hazardous waste label along with a cross-reference number.
3. After container is full, deliver to the Hazardous Waste Storage Area.
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4. Refer to Work Instruction PSO24-W Hazardous Waste Material Control & Waste Labeling for more information on labeling and disposal of hazardous waste.
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8.0 TRAINING Employee training programs must inform personnel at all levels of responsibility of the components and goals of the Integrated Contingency Plan (ICP). Training should be structured to give each employee the necessary information to carry out the components of the ICP. Topics should include: Good Housekeeping as explained in the Toyota Production System (TPS)
Training. Material Management Practices Inspections
Employee training is essential to effective implementation of the ICP. The purpose of a training program is to teach personnel at all levels of responsibility the components and goals of the ICP. When properly trained, personnel are more capable of preventing spills, responding safely and effectively to an accident when one occurs, and recognizing situations that could lead to groundwater contamination. 8.1 Spill Prevention and Response Spill Prevention and response procedures are described in detail in Section 3 – Primary Response Tools. These procedures are discussed as part of the Awareness Training that all members must complete. All members must know what they are to do in the event of the spill. For more details, see Work Instruction GENEV–001– Spill Reporting and Response. In addition, all members who handle oil will receive initial SPCC training upon employment. The initial training should include general facility operations, operation and maintenance of equipment to prevent discharge of oil, applicable laws, facility procedures, and contents of the Plan. Discharge prevention briefings for oil handling employees shall be included as part of the annual spill training and OSHA 1910.120 HAZWOPER training. Each member is encouraged to make suggestions in our Kaizen program to minimize spills in the workplace. Our Kaizen suggestion form was changed and an Environment suggestion box was added for member ideas to be written and evaluated. 8.1.1 Enhanced Training We recognize that some spills that may occur may require more training and expertise to effectively respond than what is taught in good housekeeping and Toyota Production System 5S training. Some members have been selected to be part of our Incidental Spill Response Team and will be asked to manage spills
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that may occur within their own departments. These spills are small in nature and do not require and personal protective equipment to clean up. We have also selected Plant and General Services members to be part of a Hazardous Materials Response Team. The following summarizes the additional training that these members receive:
1. Hazard Communication Training has been completed and is continually updated regarding hazardous materials.
2. Members of the Hazardous Materials Team may respond to medical
emergencies and at least one member of the team shall be current in F.A. and CPR training.
3. Emergency Response training for both our Incidental Response and
Hazardous Materials groups is updated annually through in house training or outside contacts.
4. Members of our Hazardous Materials Team who may need to wear
Personal Protective Equipment (PPE) shall be trained in its use. These members who may be required to wear respiratory equipment such as an air purifying respirator shall undergo a medical evaluation and fit testing on a periodic basis.
8.2 Good Housekeeping Personnel should also be taught how to maintain a clean and orderly work environment. The following points should be emphasized in our Continuous Improvement System (CI) training: The regular sweeping and cleaning of the floors, and promptly cleaning up
any spilled materials.
Identify places where brooms, dust pans, etc., are located.
Display signs reminding members of the importance and procedures of good housekeeping.
Emphasize the importance of neat and organized storage of materials and
tools through the use of Toyota Production System 5S Training and using good visual control.
Identify hazardous materials or substances that are stored, handled, used,
or produced on-site.
Openly discuss proper procedure for handling of hazardous materials.
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Members who handle or transport hazardous materials in drums, totes or other containers shall be required to check for any leaks or spills. 8.3 Inspections Employees designated to conduct inspections will be:
a) instructed on which items/systems to inspect; b) instructed on the required minimum frequency of inspections; and c) trained in the proper inspection procedures.
8.4 Tools for a Successful Training Program Here are some suggestions of training tools that can be included in the training program: Employee handbooks Films and slide presentations Drills Routine employee meetings Bulletin boards Suggestions boxes Newsletters Environmental excellence awards or other employee incentive programs.
Providing employees with incentives, such as Kaizen that awards members for suggestions to improve environmental performance, is a good way to motivate personnel in working to achieve the goals of the ICP. 8.5 How Often to Conduct Training At a minimum, employees should be trained annually. However, they should take into account the complexity of the management practices and the nature of the staff, including staff turnover and changes in job assignments. The implementation schedule specifies the training frequency for this facility. In any case, the effectiveness of the training program should be periodically evaluated. In many cases, this will simply involve speaking with the employees to verify that information has been communicated effectively. 8.6 Training Documentation A list of employee training topics and a schedule for conducting the training is maintained on-site and updated by the Environmental Health and Safety Specialist. At a minimum, training topics should include good housekeeping, proper procedures for material handling, groundwater protection practices, stormwater best management practices, and spill prevention and response procedures. Signature sheets with employee names and date of training will be stored with a summary of the training agenda. Specifically, retention of
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employee training records is required by the SPCC Rule and the new general stormwater permit, KYR000000. Refer to Appendix B for employee training records.
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9.0 MEASURES AND CONTROLS 9.1 General Activities The following sections outline general pollution prevention plans and best management practices (BMP) in place at CMWA. These practices were derived from EPA Guidance documents designed to assist the facility in implementing pollution prevention plans and BMP’s. These protection activities describe the steps that should be taken facility-wide to ensure maximum groundwater and surface water protection. 9.1.1 Good Housekeeping Good housekeeping practices are designed to maintain a clean and orderly work environment. One of the most effective first steps towards preventing stormwater pollution simply involves good common sense to improve the facility’s basic housekeeping methods. Poor housekeeping can result in more waste being generated than necessary and an increased potential for stormwater contamination. A clean and orderly work area reduces the possibility of accidental spills caused by mishandling of chemicals and equipment and should reduce safety hazards to plant personnel. The procedures that will be used to promote good housekeeping include inventory controls, routine and regular clean-up schedules, maintaining well organized work areas, and educational programs for employees about all of these practices. The following section describes these good housekeeping procedures. 9.1.2 Operation and Maintenance Practices The desired outcome of the following practices is to ensure processes and equipment are functioning properly: Maintain dry and clean floors and ground surfaces by using brooms,
shovels, vacuum cleaners, or cleaning machines; Regularly pickup and disposal of garbage and waste material; Make sure equipment is working properly; Routinely inspect for leaks or conditions that could lead to discharges of
chemicals; Routinely inspect for situations where stormwater could come in contact
with raw materials, intermediate materials, waste materials, or products; and
Ensure that spill cleanup procedures are understood by employees.
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9.1.3 Material Storage Practices Improper storage can result in the release of materials and chemicals that can cause stormwater pollution. Proper storage techniques include: Providing adequate aisle space to facilitate material transfer and easy
access for inspections; Storing containers, drums, and bags away from direct traffic routes to
prevent accidental spills; Stacking containers according to manufacturers’ instructions to avoid
damaging the containers from improper weight distribution; Storing containers on pallets or similar devices to prevent corrosion of the
containers which can result when containers come in contact with moisture on the ground; and
Assigning the responsibility of hazardous material inventory to a limited
number of people who are trained to handle hazardous materials. 9.1.4 Material Inventory Procedures Keeping an up-to-date inventory of all materials (hazardous and non-hazardous) present will keep material cost down caused by overstocking, track how materials are stored and handled on-site, and identify materials and activities that pose the most risk to the environment. The following instructions explain the basic steps to completing a material inventory.
1. Identify all chemical substances present in the workplace. Walk through the facility and review the purchase orders for the previous year. List all of the chemical substances used in the workplace, and then obtain the Material Safety Data Sheet (MSDS) for each.
2. Label all containers to show the name and type of substance, stock
number, expiration date, health hazards, suggestion for handling, and first aid information. This information can usually be found on the MSDS. Unlabeled chemicals and chemicals with deteriorated labels are often disposed of unnecessarily and improperly.
3. Clearly mark on the inventory hazardous materials that require special
handling, storage, use and disposal consideration.
Improved material tracking and inventory practices, such as instituting a shelf-life program, can reduce the waste that results from overstocking and the disposal of outdated materials. Careful tracking of all materials may also result in more efficient materials use.
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9.1.5 Employee Participation Frequent and proper training of employees in good housekeeping techniques reduces the possibility that the chemicals or equipment will be mishandled. Motivating employees to reduce waste generation is another important pollutant prevention technique. Methods for involving employees in good housekeeping practices should include the following: Incorporating information sessions on good housekeeping practices into
the facility’s employee training programs; Discussing good housekeeping at employee meetings; Publicize pollution prevention concepts through posters; and Post bulletin boards with updated good housekeeping procedures, tips
and reminders. 9.2 Total Productive Maintenance - TPM Total Productive Maintenance involves the regular inspection and testing of plant equipment and operational systems. These inspections should uncover conditions such as cracks or slow leaks that could cause breakdowns or failures that result in discharges of chemicals to the soil and stormwater. The program should prevent breakdowns and failures by adjustment, repair or replacement of equipment. An effective preventative maintenance program should therefore include the following elements: Identification of equipment, systems, and facility areas that should be
inspected; Schedule for periodic inspections or tests of these equipment and
systems; Appropriate and timely adjustment, repair or replacement of equipment
and systems; and Organized retention of complete records for inspections of equipment and
process systems. 9.2.1 Identification of Equipment to Inspect The first step is to identify which systems or equipment may malfunction and cause spills, leaks, or other situations that could lead to soil or stormwater contamination. The following list identifies some types of equipment to include in the preventative maintenance inspection and testing program:
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a) Pipes; b) Pumps; c) Storage tanks and bins; d) Pressure vessels; e) Pressure release valves; and f) Process and material handling equipment.
After identifying the equipment and areas to inspect, routine inspections should be set. Examination for leaks, corrosion, support or foundation failure, or the forms of deterioration should be performed. Periodic testing of plant equipment for structural soundness is a key element of preventative maintenance. This can be done by making sure storage tanks are solid and strong enough to hold materials. Defective equipment should be repaired or replaced promptly. Spare parts should be kept for equipment that needs frequent repair. Include a suitable records system for scheduling tests and documenting inspections in the preventive maintenance program. Record test results and follow up with corrective action. Make sure records are complete and detailed. These records should be kept with other visual inspection records. 9.2.2 Visual Inspections Preventing stormwater pollution requires good housekeeping in areas where material is handled, stored, or transferred and preventive maintenance of process equipment and systems. Regular inspection is the means to ensure that all of the elements of the plan are in place and working properly. This visual inspection is simply a way to confirm that the measures chosen are in place and working. The following list identifies some types of equipment and plant areas to include in the visual inspections and preventative maintenance plan: Areas where spills and leaks have occurred in the past; Material storage areas (tank farms, drum storage); Outdoor material process areas; Material handling areas (loading, unloading, transfer); and Waste generation, storage, treatment and disposal areas.
It is not necessary for the visual inspection plan to be highly technical, complicated or labor-intensive. However, employees that carry out the visual inspection program should be properly trained, familiar with the SWPPP, and knowledgeable about proper record keeping and reporting procedures. The most important thing to remember is to document all inspections. Documentation should include when the inspection was done, who conducted
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the inspection, what areas were inspected, what problems were found and steps taken to correct any problems, including who has been notified. Inspection records should be kept with the stormwater protection plan. Refer to Section 6 for more information on inspections following measurable storm events. Upon inspection, employees must document findings for any control measures that require attention or are in need of repair/replacement. See Appendix L for a log for Control Measure Maintenance and Repair that must be retained as an addendum to the SWPPP. 9.3 Spill Prevention and Response Spills and leaks are the most common sources of stormwater pollution. Avoiding spills and leaks is preferable to cleaning them up after they occur, not only from an environmental standpoint, but also because spills cause increased operating costs and lower productivity. Activities and areas where spills are likely to occur include the following: Loading and unloading areas; Storage areas; Process activities; Dust or particulate processes; and Waste disposal activities.
Loading and unloading areas have a high spill potential because the nature of the activity involves transfer of materials from one container to another. The spill potential is affected by the integrity of the container, the form of the chemical being transferred, the design of the transfer area, the proximity of this area to the storage area, and procedures for loading and unloading. Storage areas, both indoor and outdoor, are potential spill areas. Facility floor drains do not provide a direct connection to stormwater because all floor drains are either closed-loop systems or are connected to the on-site wastewater treatment facility. This evaluation should consider the type, age, and condition of storage containers and structures, including tanks, drums, bags, and bottles. An evaluation of the spill potential of storage areas should also focus on how employees handle materials. Consideration of the following activities or process alterations is recommended to reduce the likelihood that spills will occur: Develop ways to recycle, reclaim and/or reuse process material to reduce
the volume brought into the facility;
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Install leak detection devices, overflow controls, and diversion berms;
Disconnect drains from processing areas that lead to storm sewers or drain field (be sure that any such action would not create a health hazard within the facility);
Adopt effective housekeeping practices; Adopt a materials flow/plant layout (i.e., do not store bags that are easily
punctured near high-traffic areas where they may be hit by moving equipment or personnel);
Perform regular visual inspection to identify signs of wear on tanks, drums,
containers, storage shelves, and berms and to identify sloppy housekeeping or other clues that could lead to potential spills;
Perform preventative maintenance on storage tanks, valves, pumps,
pipes, and other equipment; Use filling procedures for tanks and other equipment that minimize spills; Use material transfer procedures that reduce the chance of leaks or spills; Substitute less or non-toxic materials for toxic materials; and Ensure appropriate security.
In the event that spill prevention measures fail, a swiftly executed response may prevent contamination of stormwater. Spill response procedures should be clear, concise, step-by-step instructions for responding to the spill events at the facility. Organize the plan to facilitate rapid identification of the appropriate set of procedure. For example, the plan may work best when organized by spill location. Another possible method of organization is by spilled material. The key component to implementation is the ability of employees to use the plan quickly and effectively. The specific approach will depend on the specific conditions at the facility such as size and number of employees. Development of the spill response plan is based on the spill potential scenarios identified. It reflects a consideration of the potential magnitude and frequency of spills, of the types of material spilled, and of the variety of potential spill locations. Specific procedures may be needed to correspond to particular chemicals on-site. Personnel with appropriate training and authority should be available to respond to spills at any time during the operation of the facility. The spill response plan should describe: Identification of spill response “team” responsible for implementing the
spill response plan;
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Safety measures; Procedures to notify appropriate authorities providing assistance (police,
fire, hospital, Publicly Owned Treatment Works (POTW), etc.); Spill containment, diversion, isolation, and cleanup procedures; and An inventory of spill response equipment including:
Safety equipment such as respirators, eye guard, protective clothing,
fire extinguisher, and two-way radios; Clean-up equipment such as booms, barriers, sweeps, absorbents,
containers, etc.
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10.0 ANNUAL SITE COMPLIANCE INSPECTION
The site compliance inspection will provide a basis for evaluating the overall effectiveness of the ICP. A comprehensive site compliance inspection will be conducted at least annually. The comprehensive inspection is in addition to the routine site inspections previously discussed. Internal Auditors or qualified personnel will conduct the comprehensive site inspection to: Confirm the accuracy of the description of potential pollutant sources
contained in the ICP; Determine the effectiveness of the plan; and Assess compliance with the terms and condition of the appropriate
regulations. The process for conducting the site inspection will include reviewing the ICP; developing a list of those items which are part of the material handling, storage, transfer areas covered by the plan; and reviewing the facility’s past year operations to determine if any additional areas should be included in the plan. A site inspection will also be conducted to determine if all pollution prevention measures are accurately identified in the plan and that they are in place and working properly. Comprehensive Site Inspection Records are maintained on-site. During the site inspection, the compliance team will: Visually inspect material handling areas, storage areas, stormwater
drainage areas, and other potential sources of pollution for evidence of pollutants entering the drainage system;
Evaluate the effectiveness of control measures to reduce pollutant
loadings and determine whether additional measures are needed; Observe structural measures, sediment controls, and other BMP’s to
ensure they are properly maintained and operated; and Inspect any equipment need to implement the ICP, such as spill response
equipment. The description of potential pollutant sources and stormwater control measures may need to be revised, based on the results of the site inspections. If necessary, the plan will be revised within two weeks after the date of the inspection. Changes in the control measures will be scheduled for implementation on-site in a timely manner. The results of the compliance inspection will be documented in a report signed by an authorized company official. The report will summarize inspection results,
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identify any incidence of non-compliance, and describe the follow-up actions. The Annual Site Inspection Report must note all revisions that have taken place during the preceding year. If the facility is in compliance, the report must contain a certification that the facility is in compliance with the plan. The report will include: Scope of the inspection;
Personnel making the inspection;
Date(s) of the inspection; and
Major observations relating to the implementation of the ICP.
The evaluation reports will be retained at the facility for at least one year after the date of the compliance inspection. A copy of the report template can be found in Appendix O. 10.1 Plan Revisions If the site evaluation report lists changes at the facility that have a significant effect on the potential for the discharge of pollutants to the environment, the ICP shall be amended. These changes may include construction activity or changes in operations or maintenance. In addition, modifications to the ICP that improve the effectiveness of the plan shall also be included. The ICP will be revised where needed, and revisions will be noted on the Inspection Report Form. The Environmental Management Program Coordinator will have the responsibility for revising the plan so that it reflects current conditions at the facility, and for documenting these revisions to reflect the facility’s efforts to control stormwater pollution.
