Annual Storm Water Pollution Prevention Plan and Spill Prevention, Control and Countermeasures Plan Compliance Inspection

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1 Annual Storm Water Pollution Prevention Plan and Spill Prevention, Control and Countermeasures Plan Compliance Inspection September 22, 2014 Prepared By: Facilities Management Environmental Resources University of Virginia P.O. Box Charlottesville, VA Jessica S. Wenger (434) and Jeffrey A. Sitler, CPG (434)

2 Introduction In accordance with the Storm Water Pollution Prevention Plan (SWPPP) for the University of Virginia s Parking and Transportation Facility and the University s and Spill Prevention, Control, and Countermeasures Plan (SPCC), an annual inspection is required of the facility. This inspection covers all areas of the facility including Best Management Practices (BMPs), areas where industrial materials or activities may be exposed to stormwater, and specific areas listed in the SWPPP. These areas include storage areas for vehicles awaiting maintenance, fueling areas, indoor and outdoor vehicle maintenance areas, material storage areas, vehicle cleaning areas, and areas where spills have occurred in the past. The purpose of the inspection is to insure that BMPs are effective and that no changes have occurred at the facility that may impact stormwater quality. The inspection also included checking any problems found during last year s inspection to determine if the problem had been properly corrected. Aboveground petroleum storage containers were also inspected to ensure that adequate secondary containment is in place. Inspection Personnel The inspection was conducted by Jeffrey Sitler and Jessica Wenger of Facilities Management Environmental Resources (ER) on September 19, 2014 with Oscar Goode of Parking and Transportation providing access to materials storage areas inside the Parking and Transportation (P&T) building. Scope of the Inspection The inspection covered all aspects of the Parking and Transportation site including both indoor and outdoor areas. The inspection utilized the Annual Comprehensive Site Compliance Evaluation Checklist as provided in the facility s Stormwater Pollution Prevention Plan (SWPPP). The interior inspection covered all areas where industrial activity occurs including the sign shop, vehicle and equipment maintenance areas, vehicle and parts washing areas, and material storage areas. Exterior inspections covered the oil-water separators, vehicle fueling areas, vehicle washing areas, vehicle parking areas, the perimeter of the lot, and the area where stormwater runoff exits the site. Specific Area Findings Parking Lot In August 2011, the former asphalt bus parking area was repaved with concrete. Concrete was chosen because it is much more resilient than asphalt and therefore will not degrade in the presence of petroleum based fluids dripping from the buses. The bus parking area was inspected on September 19th. The concrete bus parking area continues to hold up well to the weight of the busses and associated petroleum drips. There is no evidence of any cracks in or degradation of the concrete that would allow any contaminants associated with the fuel drips to reach the soil below. During the inspection, two buses at the 9/22/2014 Page 1

3 lower level of the parking area closest to the BaySaver were actively dripping fuel out of the fill port (Figures 1-2). The buses kneeling function, which allows passengers to easily enter the bus, combined with the slope of the parking spaces and the warm weather caused fuel to leak out of the fuel tank and onto the ground. Upon discovery of the leak, ER reported the issue to David Durrer of P&T, who turned on the buses to burn off some fuel, thus dropping the level of fuel in the tank below the height of the fill port. The leaking stopped before ER left the site. P&T staff need to be diligent about regularly walking through the bus parking area and looking for leaks. In addition, those fueling the buses need to fully utilize the bus fueling ramp so the buses cannot be filled completely before they are parked. While the area does drain to the BaySaver so the fuel does not contaminate stormwater, the primary means of protecting stormwater should be preventing leaks before they occur. Figure 1. Fuel leaking from a parked bus. 9/22/2014 Page 2

4 Figure 2. Fuel leaking from a second parked bus. In order to keep the concrete in the best possible condition, the accumulated oil and grease needs to be scraped up and absorbed annually to prevent a thick build-up of oil and fuel on the surface. The scrapings should be properly disposed of with other spill clean-up material. While stains will not be completely removed from the concrete by manual scraping, preventing a built up of material on the surface will go a long way in not only improving the quality of stormwater runoff, but also prolonging the life of the pad and thereby helping P&T protect their investment. In addition, any absorbent material applied to control or clean up leaks should be swept up and properly disposed of the same day that it is put down (Figure 3). Figure 3. Absorbent material near the gasoline fueling pumps. 9/22/2014 Page 3

5 The BaySaver oil water separator in the bus parking area is functioning correctly and capturing oil from the runoff from the bus parking area. The BaySaver is on a quarterly maintenance and clean out schedule. Stormwater flows originating from the BaySaver are monitored quarterly for oil or other contaminants. The flows from both the parking lot and BaySaver have been relatively clean for the last year. The inspections showed little to no visible evidence of oil or other materials leaving the site via stormwater conveyances or overland flow. In recent years the number of buses at P&T had expanded to the point that not all buses were able to be parked in the designated bus parking area. These outside areas did not drain to an oil water separator to remove contaminants associated with drips, leaks, or spills from buses. In recognition of this problem, P&T worked with UVa Facilities Management (FM) to install an additional oil water separator in the parking lot in July of All storm drains in the back parking area of the P&T site that were not previously tied into oil-water separators have now been connected to a new oil water separator located to underneath the parking lot to the west of the bus maintenance bays. The installation of the new oil-water separator ensures that all areas where buses may potentially be parked drain to oil water separators. The separator is on a monthly and semi-annual preventative maintenance schedule as well as a quarterly maintenance and clean out schedule. In addition to the new oil-water separator, a new storm drain inlet and an asphalt berm were installed at the back edge of the parking lot to prevent any potentially contaminated runoff from draining into the grassy swale behind the lot (Figure 4). The new inlet is piped to the new oil-water separator, therefore, this berm and drain system has eliminated the swale as a discharge point for the back side of the P&T lot. All runoff from paved areas of the site now drain into an on-site storm drain network which discharges from the P&T near the gate at the southeast corner of the site. This discharge point connects with the City of Charlottesville s storm sewer system. The rest of the parking lot and surrounding area continue to remain in good condition. Staff should continue to monitor the lot to remove trash, illegally dumped material, and stay-dry that has been applied to spills. Stay-dry needs to be cleaned up the same day it is applied to ensure that contaminants do not get washed into the storm sewer system. While the oil-water separators are installed to protect all areas of the lot, they should be considered a last resort and their installation does not mean that on-site maintenance and good housekeeping can be neglected. There were a few patches of stay-dry that needed to be cleaned up during the time of the inspection and there was miscellaneous litter scattered around the edges of the parking lot. This same issue was described in the 2013 Annual Inspection Report. P&T staff should resume weekly walks around the lot to make sure items have not been illegally dumped around the site, to check for other problems, and to ensure good housekeeping procedures are being followed on site. One good housekeeping issue that was noted on the day of the inspection was the abundance of discarded materials that had piled up in several places on site. Old bike racks have been piled up in the grassy area next to the dumpster in the southwest corner of the site. 9/22/2014 Page 4

6 Miscellaneous trash and debris was also found around the dumpster. This same issue was mentioned in the 2013 Annual Inspection Report and pictures taken in 2013 and 2014 show the exact same material piled in the exact same place (Figures 4-5). These unused bike racks should be stored out of the elements so that they can be re-used in the future or should be properly recycled as scrap if no longer needed. Other miscellaneous material piled around the dumpster should be properly discarded as well and a general trash pickup around the dumpster is needed. In addition, a discarded break drum from a car was found discarded along the berm behind the parking lot. Miscellaneous trash was found the area behind the berm and behind the wall that separates the P&T parking lot from the The Park (Figures 6-7). This entire area behind the parking lot could benefit from a complete clean out. Figure 4. Discarded bike racks near the dumpster in 2013 (left) and 2014 (right) should be properly stored or disposed of. Figure 5. Miscellaneous materials stored near the dumpster in 2013 (left) and 2014 (right) should be properly stored or disposed of. 9/22/2014 Page 5

7 Figure 6. Discarded car break drum found along the berm in the back parking lot. Other debris can be seen in the background. Figure 7. Miscellaneous debris found behind the parking lot wall. Piles of new and old bus tires, and miscellaneous equipment and parts were stacked next to the building (Figure 8). P&T should not be storing or accumulating waste materials outside where it can be exposed to the elements. Material should be either stored indoors or covered with tarps so that the material it is not exposed to stormwater and so that stormwater cannot collect inside. The tarps can easily be shaken off after rainstorm events to prevent collection of stagnant water on top of the trap. Mr. Goode indicated he is looking for a heavy-duty storage container that can be used in conjunction with a forklift to store parts. 9/22/2014 Page 6

8 Figure 8. Tires stored outdoors need to be protected from the elements. Vehicle Washing Area A bus had been washed in the vehicle washing area on the day of the inspection and a check of the storm drains leading from this area indicate that staff are properly operating the valved drain system. Whenever a vehicle is washed, the drain valve is positioned to send water to the sanitary sewer via the oil-water separator. At all other times the drain is open to allow rain water to enter the storm sewer. In the summer of 2014, P&T had the asphalt berm surrounding the vehicle washing area replaced. The former berm had been starting to crack and break up due to wear and tear from the weight of the buses driving over them. The new asphalt berm is in excellent condition and is functioning to keep wash water confined to the bus washing area (Figure 9). 9/22/2014 Page 7

9 Figure 9. New pavement and berm around the bus washing area. Bus Fueling Area The concrete berms around the bus fueling area are continuing to function adequately and have withstood the weight of the busses. There are no gaps between concrete sections nor have the berms deformed under the weight of the bus traffic. Asphalt ramps lead up to the berms on either side to make it easier for the busses to cross the berms to enter and exit the fueling area. The berms were installed to prevent releases of diesel fuel to the environment in the event of a spill during the fueling of the busses. Maintenance staff and bus drivers are reminded during annual training to follow facility safe fueling practices that require their presence at the pump while fuel is being dispensed. In addition to the berms, a concrete ramp was installed within the bus fueling area in The ramp is positioned so as to tilt the buses away from the side where the fuel tank is located. The tilting of the buses in this manner prevents them from ever being overfilled. The ramp also tilts the buses in the same direction as the tilt of the bus parking area, which will keep fuel from expanding and leaking out when the fuel warms up on hot summer days. Maintenance staff and bus drivers are reminded by ER to use the fueling ramps during training and Mr. Goode also reminds drivers regularly to use the bus fueling ramps, in an effort to prevent previously described leaks from parked buses. A 500-gallon backup diesel tank remains located in the bus fueling area underneath the canopy. The tank sits in a plastic secondary containment tub that will hold the entire contents of the tank in the event of a spill or leak. The fueling area berms would also serve as secondary containment in the event the containment failed. Bollards are located in front of the tank to prevent the tank from being struck by a vehicle. On the day of the inspection there was some miscellaneous trash in the containment tub, which should be cleaned out as soon as possible. 9/22/2014 Page 8

10 A gel-filled emergency storm drain cover is stored within the bus fueling area. The cover is intended to be used to protect the storm drain located immediately outside of the bus fueling area berm in the event of a large spill that escaped the confines of the fueling area. The storm drain cover has deteriorated due to its age and is leaking gel material. This cover should be discarded and a new cover should be purchased to have on hand in the event of a large spill. Figure 10. Deteriorated emergency storm drain cover. In the diesel fueling area, Mr. Goode designed and constructed a rack to hold the drip pan underneath the engine fluid dispenser and hose reel. The rack allows the drip pan to slide in and out in order to change out absorbent in the pan. The elevation of the pan means that drips do not have so far to fall and are less likely to splash out of the pan than they were when the pan was located on the ground. The drip rack is working very well and had adequate absorbent located in the pan on the day of the inspection. Gasoline Dispensing Area In addition to the drip pan Mr. Goode made for the bus fueling area, a second one was made and installed under the engine oil dispenser in the gasoline fueling area similar to the one installed in the bus fueling area. As with the pan in the bus fueling area, this drip pan appears to be functioning properly. Bulk Automotive Fluid Storage Room The small berm that was placed in the door to the bulk fluid storage room is used to provide secondary containment in the event of a leak or spill of any drum in the room. An inspection of the room did not indicate the presence of any past or current leaks and all drums appeared to be in good condition. The room is serving as secondary containment therefore there cannot be any drains in the floor which would allow spills to escape the room (Figure 16). 9/22/2014 Page 9

11 Figure 11. Bulk oil storage room. Other Interior BMPs There has been no change in the conditions of the used oil storage tank from last year s inspection. The used oil storage tank has adequate secondary containment to prevent water contamination in the event of a leak or spill. The secondary containment installed around the used oil storage tank is in good condition and will contain all of the oil from the tank in the event of a leak or tank failure. The tank is located inside the building where interior drains lead to the sanitary sewer via an oil-water separator. The building provides extra containment in addition to the secondary containment in the event of tank failure. The tank is located in a no traffic corner of the building and a protective metal railing has also been placed around it to prevent equipment from accidentally hitting it and causing a leak. Spills occurring during the transfer of oil into the container are cleaned up with stay-dry. Bladder secondary containment pallets are still in place under all 55 gallon oil drums in the bus maintenance area. The containment pallets are designed to contain spills or leaks from the drums by directing the release to attached expandable bladders. During this year s inspection, the pallets were free of debris or any obstructions that would prevent them from functioning properly. 9/22/2014 Page 10

12 Conclusions and Required Actions Based on observations made during the inspection, the facility is largely compliant with both its current SWPPP and the secondary containment provisions of the University s SPCC Plan. The following issues need to be addressed for the facility to be in compliance: 1. Discarded materials and vehicle parts, including tires, should be stored inside, under a tarp, or otherwise protected from the elements. 2. General good housekeeping is needed in back parking lot area trash, debris, and bike racks collected near the back dumpster and trash behind the wall. As all of the aforementioned issues were noted in the 2013 Annual Inspection Report, the entire area behind the parking lot could benefit from a complete clean out. P&T staff should continue to remain diligent about inspecting the facility in order to discover problems before they become an issue. The following recommendations will help ensure continued compliance at the facility: 1. At least once a day check buses in the bus parking area for fuel and other leaks 2. Clean the bus parking area approximately annually to remove build-up of spilled and leaked material 3. All spills should be cleaned up immediately with stay dry and stay dry should be swept up promptly after the oil is absorbed and should be properly disposed of 4. Replace the existing damaged/failed emergency storm drain cover located in the bus fueling area P&T staff made great strides in the past few years to improve the cleanliness of the site and improve BMPs on site. Some additional attention to the maintenance and good housekeeping practices on site will go one step further in ensuring P&T s continued compliance with stormwater and petroleum regulations and will help ensure P&T s operations are helping to meet sustainability goals. 9/22/2014 Page 11

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