The sand and gravel general permit requires the permittee to develop and maintain a spill plan. The plan must identify the materials of concern, spill prevention measures, and spill response procedures. The information below provides general guidance on permit requirements and useful information for permit compliance. The permittee is responsible for reading the full text of the permit and complying with all applicable permit requirements.
Materials of Concern: Identify the materials of concern including equipment that may contain or transport these materials. The materials of concern will mostly be petroleum products that amount to 10 gallons or more. Other materials might include admixtures, cleaning solutions, paint, acid or alkaline solutions, antifreeze, and other liquid materials that amount to 10 gallons or more and have potential environmental concern. The inventory of materials created for the stormwater pollution prevention plan should already include these materials. Highlight those materials on this list and add a list of equipment that poses a spill threat.
Spill Response Procedures: Provide a detailed description of actions to take, and the order in which the actions should take place. At a minimum include:
Spill Prevention: Describe the steps that help prevent spills from happening and structures that contain or treat spills. Employee training and material handling procedures (e.g., fueling procedures) are examples of steps that help prevent spills. Concrete containment structures for fuel tanks and oil/water separators for road runoff are typical structures for containing or treating spills.
The following list of best management practices is only intended to cover
some of the BMPs that should be part of the spill plan.
Training: Spill response will be most effective if all employees are trained to take appropriate and immediate action when they observe a spill. Company policy needs to support employee spill response and provide incentives to "do the right thing." It can be very difficult to convince employees that they should respond to a spill on Friday at quitting time. Training must address the "why respond" as well as the how to respond.
Spill Response Materials: The permittee is required to maintain spill response materials onsite. Providing a spill response shed for the bulk of materials and spill response "kits" on major equipment can be an effective strategy. This strategy can be enhanced by a logo or color of paint that readily identifies the location of spill response materials.
Covered Containment: Store barrels and other containers in a covered area with an impervious floor and berm. Pay attention to design and assure that the materials are easily accessed and used in the covered and contained area. If employees find it necessary to remove materials in order to use them, the value of covered containment is diminished. Make the area easy to get into and out of. Allow room for easy access and use of the materials.
Covered Temporary Storage: Provide a covered area to collect material from spill cleanup. Small spills require cleanup but often do not produce enough material for transport to a permanent disposal site. Providing a covered temporary storage area for this waste material can make cleanup quicker and more efficient, encouraging employees to respond.
Post BMP Instructions: Post information on proper handling procedures and storage requirements at the area where the material is located. For example, fueling procedures should be posted at the fueling station. Spill response procedures and contact person should be posted with the spill response materials.
Scheduled Maintenance: Schedule vehicle maintenance to reduce spills. Hydraulic oil, transmission oil, and engine oil leaks from vehicles and equipment are one of the most common spills onsite. Preventative maintenance can reduce the quantity and frequency of these events.
Paved Surfaces and Drains: In areas where minor spills happen frequently such as fueling stations, an impervious surface will prevent immediate contamination of the ground. These areas should slope to a drain that will capture the contaminant. The drain should connect to a dead end sump or suitable treatment facility (e.g., oil/water separator for runoff from a fueling pad).
The plan is not intended to just sit on the shelf after completion. The permit requires periodic review and updates to keep the plan current. The plan should also be used during employee training. The plan is intended to become a part of doing business at a site and to be a living document.
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