STORM WATER POLLUTION PREVENTION PLAN

Transcription

1 STORM WATER POLLUTION PREVENTION PLAN RIPPEL READY MIX, INCORPORATED 1803 WEST WASHINGTON STREET BLOOMINGTON, ILLINOIS Prepared For: RIPPEL READY MIX, INC. 609 STATE ROUTE 251 RUTLAND, ILLINOIS Worldwide Engineering, Environmental, Construction, and IT Services

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3 TABLE OF CONTENTS Section Page 1.0 INTRODUCTION BACKGROUND APPLICABILITY OVERVIEW POLLUTION PREVENTION TEAM POTENTIAL POLLUTANT SOURCE EVALUATION/ASSESSMENT SITE LOCATION AND DESCRIPTION MATERIAL INVENTORY EXPOSED MATERIAL STORAGE AREAS SOLID WASTE STORAGE AREAS RECYCLABLE STORAGE AREAS STORAGE TANKS LOADING AND UNLOADING AREAS HISTORY OF PAST SPILLS AND LEAKS NON-STORM WATER DISCHARGES EXISTING STORM WATER MONITORING DATA EVALUATION SUMMARY BEST MANAGEMENT PRACTICES GOOD HOUSEKEEPING TRADITIONAL STORM WATER MANAGEMENT PRACTICES PREVENTATIVE MAINTENANCE VISUAL INSPECTIONS SPILL PREVENTION AND RESPONSE EMPLOYEE TRAINING RECORDKEEPING AND REPORTING SEDIMENT AND EROSION CONTROL MANAGEMENT OF RUNOFF POLLUTION PREVENTION PLAN EVALUATION ANNUAL SITE COMPLIANCE EVALUATION PLAN REVISIONS (3) i CONESTOGA-ROVERS & ASSOCIATES

4 LIST OF FIGURES FIGURE 1 FIGURE 2 SITE LOCATION MAP SITE PLAN LIST OF TABLES TABLE 1 TABLE 2 TABLE 3 TABLE 4 TABLE 5 TABLE 6 POLLUTION PREVENTION TEAM SIGNIFICANT MATERIALS USED, STORED, OR PRODUCED ON SITE LIST OF SIGNIFICANT SPILLS AND LEAKS SUMMARY TABLE OF POLLUTANT SOURCES AND POLLUTANTS OF CONCERN SUMMARY OF BEST MANAGEMENT PRACTICES INSPECTION CHECKLIST LIST OF APPENDICES APPENDIX A APPENDIX B GENERAL STORM WATER PERMIT AND SWPPP GUIDELINES ANNUAL COMPLIANCE EVALUATION FORM (3) ii CONESTOGA-ROVERS & ASSOCIATES

5 1.0 INTRODUCTION 1.1 BACKGROUND In November of 1990, the U.S. Environmental Protection Agency (USEPA) published final regulations establishing specific requirements for permitting storm water discharges associated with industrial activities. These rules defined a storm water discharge associated with industrial activity as any discharge from any conveyance which is used for collecting and conveying storm water (point source) and is directly related to manufacturing, processing, or raw materials storage areas at an industrial plant. USEPA further clarified its ruling by stipulating that only storm water discharged to waters of the state would be regulated. The definition targets specific industries within certain Standard Industrial Classification (SIC) Codes, on the premise that these industries pose a higher potential to contribute pollutants to storm water runoff than others [40 CFR (b)(14)(i)-(x)]. Among the many industries specifically included by virtue of their SIC codes were ready mix concrete plants (SIC ). The finalized regulations also allowed authorized states to issue general or individual National Pollutant Discharge Elimination System (NPDES) permits. Authorization was conditionally granted to the petitioning states as long as each permit issued established requirements for the preparation of a Storm Water Pollution Prevention Plan (SWPPP) and an Annual Report describing the results of the annual facility inspection mandated under the SWPPP guidelines. The Illinois Environmental Protection Agency (IEPA) has been authorized by USEPA to administer the storm water permitting program within the State of Illinois. 1.2 APPLICABILITY The Rippel Ready Mix Plant ( Rippel or the Plant ) in Bloomington, Illinois discharges storm water via surface water flow into one of two storm water sewer manholes located on the site. These storm water sewer manholes connect to a storm sewer operated by the City of Bloomington and the collected surface water is conveyed to Sugar Creek. Additionally, because the plant is considered to be a regulated industrial activity area based on the plant s SIC code (3273), it has been specifically targeted by the NPDES storm water permit requirements [40 CFR (b)(14)(ii)]. As a condition of the plant s NPDES storm water permit, Rippel must develop a SWPPP and annually submit a report detailing facility inspection results (3) 1 CONESTOGA-ROVERS & ASSOCIATES

6 1.3 OVERVIEW The goal of this SWPPP is to assure water quality by significantly reducing the potential for pollutants contained in storm water run off from leaving the plant location. This SWPPP has been prepared in accordance with good engineering practices. The plan identifies the sources of potential pollution and describes measures that will be implemented to prevent and/or control the discharge of these constituents in storm water runoff. This SWPPP outlines site-specific Best Management Practices (BMPs) used to reduce the amount of constituents, if any, from entering waters of the state. This plan has been divided into five sections, with the first section devoted to providing the general rationale for the plan. Section 2 establishes management responsibility for the plan. Section 3 identifies individual areas of the plant that potentially could contribute pollutants to the discharge. Section 4 itemizes specific structural and non-structural control measures that will be implemented. Section 5 is devoted to establishing a system for the evaluation of this SWPPP and its periodic revision and maintenance. Pursuant to the requirements of 40 CFR Part 122, this plan describes the activities, materials, and physical features of the plant that may contribute significant amounts of pollutants to storm water runoff and the measures that have been or will be implemented to control these pollutants. As conditions and operational practices change, Rippel will re-evaluate and revise the pollution prevention activities accordingly. The format for this SWPPP is designed to accommodate necessary revisions with minimal rewriting. This plan will be signed by Rippel s Plant Superintendent who has been given direct accountability and responsibility for implementation and maintenance of the SWPPP at this plant. This SWPPP will be retained on-site and made available upon request to the Director of the IEPA or his/her authorized representative. This document has been prepared using USEPA s Storm Water Management for Industrial Activities: Developing Pollution Prevention Plans and Best Management Practices guidance document (USEPA, 1992) (3) 2 CONESTOGA-ROVERS & ASSOCIATES

7 2.0 POLLUTION PREVENTION TEAM The Rippel Storm Water Pollution Prevention team is comprised of the President and as assigned employees. The team is responsible for developing the plan and assisting in its implementation, maintenance, and revision. The names and responsibilities of each individual team member are described in Table 1. Each member of the team has been selected based upon his knowledge and/or experience with the storm water regulations, personnel training, and various plant processes. The team will collectively provide direction and structure to the plant s SWPPP. The President will chair meetings of the pollution prevention team and will be responsible for oversight, development, and implementation of storm water management policies. The team will be responsible for developing and implementing specific pollution prevention measures in accordance with Best Management Practices (BMPs). Items that the team will be responsible for include: Implementation of NPDES permit and pollution prevention plan requirements. Defining and prioritizing goals for the plant s storm water management program. Tracking changes in plant operations and implementing a system for altering the storm water management plan, if necessary. Maintaining a clear line of communication with plant and corporate management to ensure cooperation at all levels. Development, implementation, and oversight of employee training (as it pertains to storm water management and/or spill prevention). Development and implementation of a periodic site inspection program. Identification of potential pollutant sources and recommending ways to eliminate problem areas through process changes, raw material substitutions, or layout alterations. Coordination of BMPs, periodic review of the program s effectiveness, and implementation of new preventative measures as needed to reduce potential problems (3) 3 CONESTOGA-ROVERS & ASSOCIATES

8 3.0 POTENTIAL POLLUTANT SOURCE EVALUATION/ASSESSMENT The purpose of this section of the SWPPP is to provide a description of potential sources that could reasonably be expected to add pollutants to Sugar Creek. 3.1 SITE LOCATION AND DESCRIPTION The Plant is located at 1803 West Washington Street in Bloomington, Illinois. The plant is situated on approximately three acres of land and is presently bordered to the west by the Stark Excavating Company, to the east by Caroline Street, to the north by vacant land and a City access road and to the south by Saint Mary s Cemetery and a Cargill Grain Plant. (See Figure 1 - Site Location Map). The Rippel plant consists of a Terex 524 Truck Mix batch plant, two silos (one fly ash and one cement), two aggregate conveyors, two transfer augers, a sales office, several additive tanks (air entraining agents, water reducer/retarders and accelerators), stockpiles of sand and aggregate, concrete storage bins for the aggregate and a truck washout area (See Figure 2 Site Plan). The Rippel batch plant, like most concrete batching plants, produces concrete in transit for the building construction industry. In the batch process, raw materials consisting of sand and aggregate are mixed with portland cement and fly ash in dry weigh hoppers and gravity fed into mixer trucks along with the requisite amount of water. The concrete is then mixed in the trucks on the way to the site where the concrete is to be poured. At the Rippel facility, sand and aggregate are delivered to the site in trucks and stockpiled in concrete storage bins. Portland cement and fly ash are delivered to the plant in enclosed tankers and pneumatically transferred to the designated storage silos. Production processes associated with the ready mix operation include the transfer of the sand and aggregate from the individual stockpiles to overhead storage bins (with a front end loader), conveyor delivery of the materials and cement into weigh hoppers, and computerized transfer of the desired ingredients into the mixer trucks. Raw ingredients used in the concrete production process which are exposed to storm water runoff include sand and the various grades of aggregate stockpiled on site. Residual amounts of concrete, fly ash and/or portland cement may also be present in the form of spillage from the mixing process. In addition to the raw ingredients used to produce the concrete, Rippel uses a number of ancillary materials in its day to day operations. These materials include air entraining (3) 4 CONESTOGA-ROVERS & ASSOCIATES

9 agents, water reducers/retarders and accelerators. These additives are stored in polyethylene tanks within the office building on a concrete slab. 3.2 MATERIAL INVENTORY A SWPPP pollutant source assessment has been performed at the Rippel Ready Mix Plant. An inventory of materials that are potentially exposed to storm water has been evaluated based upon the following recommendations offered by USEPA in its 1992 SWPPP guidance document. Coordination of BMPs, periodic review of the program s effectiveness, and implementation of new preventative measures as needed to reduce potential problems. List the significant materials that could be exposed to storm water, with a focus on planned storage and processing areas, transportation corridors, and transfer points. Provide a summary of planned methodology and locations of on-site storage. Provide a description of materials management practices planned to minimize contact of the materials with storm water runoff. A discussion of planned structural and non-structural control measures used to reduce pollutants in storm water runoff. A discussion of planned treatment of storm water runoff. Table 2 contains an inventory of significant materials which could potentially be used, stored, or produced on site that could have a potential to contribute pollutants to storm water runoff. This table will be updated whenever new materials are used, stored, or produced, and when existing listed materials are no longer used at the Plant. The location of each of the referenced potential pollutant sources has been identified on the Site Plan. Non-hazardous wastes or recycled material, which may be generated by the Plant, include: Used oil Dust collector fines Used dust filters Hardened concrete and washout residues Normal refuse associated with daily operations (3) 5 CONESTOGA-ROVERS & ASSOCIATES

10 The used oil, hardened concrete and washout residues will be recycled off-site. Baghouse fines and excess solids will be returned to the manufacturing process, if possible. All other waste will be properly disposed of in an off-site landfill as appropriate. Methods and location of on-site storage and the associated planned materials management practices employed to minimize the contact of these materials with storm water are presented in the following subsections. A narrative description of the associated storm water structural and non-structural control measures is also included. BMPs are discussed in Section EXPOSED MATERIAL STORAGE AREAS Exposed material storage areas include aggregate and sand stockpiles. These stockpiles are positioned to the north of the plant along the northern edge of the access drive SOLID WASTE STORAGE AREAS A covered dumpster used to dispose office waste (i.e. paper, boxes) is located in close proximity to the office building control center RECYCLABLE STORAGE AREAS There is potential for residual aggregates and cement in a slurry form to be present in the washout pit located on site. These materials will periodically be removed using a front-end loader and sent off-site to be dried and used as a construction sub-grade fill material. It may be necessary to wash down the area following removal of the recyclable materials. If clean-up is necessary, Rippel will take any necessary measure to contain and return the residual rinsate to the washout pit STORAGE TANKS The only storage tank located at this facility which will be exposed to the elements will be the 6,000 gallon polyethylene tank reserved to contain any overflow originating from the washout pits (3) 6 CONESTOGA-ROVERS & ASSOCIATES

11 There may be as many as four polyethylene tanks used for storage of admixtures used in the process but these tanks will be positioned within the building to prevent exposure to the weather LOADING AND UNLOADING AREAS Aggregate and sand conveyed to the ready mix plant is off-loaded from tandems and semis into uncovered storage bins positioned to the north of the ready mix plant. These materials are transferred from the storage bins to the mix process on elevated conveyors. There is some residual sand aggregate that is spilled during the process; however, this material is scraped up and re-piled for use in subsequent production runs. Portland cement and fly ash is delivered to the ready mix plant in tankers and transferred pneumatically to their respective storage silos. There is virtually no residual lost during this process. Loading of the aggregate, sand, portland cement and fly ash into the individual mixing trucks is conducted directly below the mixing chamber in the batch plant. Any potential spillage associated with loading of the vehicles is captured in the truck bay directly below the mixing chamber. This area is periodically cleaned and the collected materials are returned to the batch process. Unloading of residual cement in mix trucks at the conclusion of a work day is conducted in the washout pits positioned at the northeast corner of the property. In this process residuals in the mixer are rinsed out of the truck into the washout pit using water recycled from the washout pit. The washout pit is constructed so that trucks can back into the washout pit to preclude the rinsing of any concrete constituents on to plant surfaces (i.e. rinsate is captured in the washout pit). Periodically, the accumulated solid residuals are removed and sold for reuse as subgrade fill. 3.3 HISTORY OF PAST SPILLS AND LEAKS Table 3 is used to outline specific information required in the event that a significant spill or leak should occur. In the event that a spill or leak does occur, Table 3 would be used to record the pertinent details and would be included in this plan as a revision. There have been no releases, spill or leaks reported at this facility (3) 7 CONESTOGA-ROVERS & ASSOCIATES

12 3.4 NON-STORM WATER DISCHARGES The Illinois Environmental Protection Agency has defined Non-Storm water discharges as any discharge not entirely composed of storm water. There are no Non-Storm water discharges identified in this assessment of the plant. 3.5 EXISTING STORM WATER MONITORING DATA There has been no storm water data collected at this location. 3.6 EVALUATION SUMMARY Potential pollutant risks identified at this plant are associated with exposed material storage areas, fugitive suspended particulate from road way traffic, and residual fly ash, and cement exhausted via fugitive emission sources (i.e. baghouse emissions, etc). There is also some risk potential associated with loading and unloading activities near the storage silos and wind-blown particulate in and around the stockpiles (Summary Table of Pollutant Sources and Pollutants of Concern - Table 4) (3) 8 CONESTOGA-ROVERS & ASSOCIATES

13 4.0 BEST MANAGEMENT PRACTICES Best Management Practices (BMPs) are measures used to prevent or mitigate storm water from becoming contaminated with pollutants. BMPs are broad ranging and may include processes, procedures, and structural controls. The BMPs included in this SWPPP have been designed to: a) eliminate sources of storm water contamination by implementing a number of improvements and structural controls; and b) to prevent subsequent contamination by stressing the importance of storm water management and employee awareness of potential pollutant sources. The SWPPP guidelines require plant management to develop a description of storm water management controls appropriate for the plant and implement such controls. At a minimum, the SWPPP rules require that Rippel evaluate and address the following components: Preventative Maintenance Good Housekeeping Visual Inspections (At least annually) Spill Prevention and Response Employee Training Recordkeeping and Reporting Sediment and Erosion Prevention. Rippel will implement the above referenced measures. The BMPs to be implemented to date are shown in Table 5: Summary of Best Management Practices. Revisions to the SWPPP will be made as necessary. In order to effectively implement the SWPPP, specific individuals, including representatives from the Pollution Prevention Team, have been delegated responsibility for ensuring that the BMPs are monitored on a periodic basis. Actual performance of specific tasks that make up the BMP, e.g. good housekeeping, will be the responsibility of everyone. 4.1 GOOD HOUSEKEEPING The good housekeeping practices described in this SWPPP have been selected in order to maintain a clean and orderly work environment. It is believed that a clean work environment will reduce the potential for storm water contact with sand, aggregate, (3) 9 CONESTOGA-ROVERS & ASSOCIATES

14 cement products, intermediates, and miscellaneous materials that could affect the quality of water in the Plant s runoff. The following good housekeeping measures have been implemented in an effort to prevent pollutants from entering storm water discharges. Strict adherence to plant operation procedures and maintenance schedules Neat and orderly material storage practices Implementation of appropriate material inventory procedures Mandatory employee participation. Rippel employs a number of good housekeeping practices to maintain the plant s overall performance and appearance. Among these practices are periodic sweeping of the plant entrance and paved areas; traffic signs and traffic signals posted to control speed and reduce the possibility of spilling materials during transportation; cleaning and replacing baghouse filters as needed; water spray to control road dust, and reusing collected materials. In order to insure that good housekeeping practices are being observed, employees are trained to recognize the importance of managing materials properly. Such training shall include: Providing the employee with information on good housekeeping practices Discussion of good housekeeping practices during employee meetings Posting of good housekeeping tips and reminders on employee bulletin boards 4.2 TRADITIONAL STORM WATER MANAGEMENT PRACTICES Traditional storm water management practices used at the Rippel Ready Mix Plant include prompt collection of spilled materials beneath silos and around aggregate storage areas, maintenance of entry and exit drives and implementation of security measures (facility lighting, gated entry, etc.). 4.3 PREVENTATIVE MAINTENANCE All equipment at the Plant is maintained in good working condition. Regular preventative maintenance tasks are part of the plant s operating plan and include, among other things, routine checks and maintenance on production equipment and (3) 10 CONESTOGA-ROVERS & ASSOCIATES

15 vehicles and regular inspections of potential problem areas (i.e. baghouse discharges, conveyors, etc.). 4.4 VISUAL INSPECTIONS A designated employee or Pollution Prevention Team member is responsible for conducting or insuring that an inspection is performed. A summary schedule of the various inspections that should be performed at the plant is described as follows: Inspection Inspect materials storage areas for storm water problems Perform housekeeping inspections Inspect storm water sewer drains and grates and concrete containment structure Inspect spill response equipment Inspect fire prevention equipment Conduct plant inspection Minimum Frequency Monthly Weekly Weekly Quarterly Quarterly Annually 4.5 SPILL PREVENTION AND RESPONSE The only potential spill areas located at the plant are related to pneumatic transfer of fly ash or cement near the facility silos, residual materials removed from the washout pit and small amounts of leakage associated with vehicle traffic across the property. Spills of the dry fly ash and cement will be swept up as quickly as possible following discovery. Rinsate and residuals from the washout pit will be contained and returned to the washout pit. Small leaks of oil, antifreeze, gasoline and other fluids originating from on-site vehicles will be cleaned up using oil dry and placed in appropriate containers for off-site disposal. As there is no storage of petroleum products on-site Rippel will not need to prepare a Spill Prevention Control and Countermeasures (SPCC) plan for the site (3) 11 CONESTOGA-ROVERS & ASSOCIATES

16 4.6 EMPLOYEE TRAINING Storm water pollution prevention training will consist of the identification of potential pollution contributors and practicable measures for insuring good housekeeping and preventative maintenance procedures are routinely employed. Employees participating in the administration and application of this plan will be trained annually in conjunction with the OSHA Safety training program. 4.7 RECORDKEEPING AND REPORTING All housekeeping and preventative maintenance inspections will be documented using the Inspection Form found in Table 6. This inspection form contains the following information: The date and time the inspection was performed. Name and signature of the inspector. Inspected area(s). Problems encountered (if any). Remedial action required. Date remedial action was taken. All inspection records will be retained at the plant for at least one year after the expiration date of the permit. 4.8 SEDIMENT AND EROSION CONTROL Controls that have been implemented at the Plant to reduce and/or eliminate erosion and sediment deposition include measures previously discussed in Section 4.1 (sweeping entrance and paved areas, dust suppression with water spray, etc.). Rippel has also accentuated existing contours of the facility (via grading) to ensure that surface water run-off will be channeled to one of two storm drains via grass covered swales prior to release to Sugar Creek. 4.9 MANAGEMENT OF RUNOFF Storm water runoff at the Rippel Plant will follow existing and accentuated site contours to either the narrow grass covered swale along the northern end of the production area (3) 12 CONESTOGA-ROVERS & ASSOCIATES

17 or to the grass covered swale (or ditch) at the southwest corner of the site. Runoff in contact with the northern portion of the property including aggregate storage areas and silo positions will follow topographical features northward to a narrow (3 feet in width) grass covered swale extending west to east across the site. Runoff captured in this swale is transferred east to the storm sewer positioned at the northeast corner of the paved entrance to the property at Caroline Street. Runoff along the southern portion of the property follows existing contours to a grass covered swale located at the southwest corner of the property. A storm sewer inlet is positioned in this swale to release captured runoff to the storm sewer and eventually to Sugar Creek. With the exception of a gravel covered drive immediately north of the swale, the southern half of the property is paved. With the exception of the grass covered swales which help to reduce sediment movement and to prevent erosion, no other storm water management is planned (3) 13 CONESTOGA-ROVERS & ASSOCIATES

18 5.0 POLLUTION PREVENTION PLAN EVALUATION 5.1 ANNUAL SITE COMPLIANCE EVALUATION Rippel will conduct an annual compliance evaluation designed to evaluate the overall effectiveness of this SWPPP. The Annual Compliance Evaluation Form is in Appendix B. This evaluation form includes a review of the routine inspections conducted during the previous year and addresses the following items: Confirmation of the accuracy of the potential pollutant sources contained in the SWPPP Determination of the effectiveness of the SWPPP Assess compliance with the terms and conditions of the storm water permit. This evaluation will be performed by the members of the Pollution Prevention Team and assisted by other employees as necessary to insure that each area of the plan is adequately addressed. The process for conducting the site evaluation will include a review of the SWPPP; development of a list of items that are part of the material handling/storage/transfer areas covered by the SWPPP; and a review of the plant s operations over the past year to determine if any additional areas should be included in the SWPPP. A site inspection will also be conducted to determine if storm water pollution prevention measures are accurately identified in the plan and that they are in place and working properly. During the site inspection, the compliance evaluation team will: Visually inspect material handling areas, storage areas, storm water 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 storm water BMPs to ensure they are properly maintained and operated. Inspect any equipment needed to implement the plan, such as spill response equipment (3) 14 CONESTOGA-ROVERS & ASSOCIATES

19 The description of potential pollutant sources and storm water control measures may need to be revised, based on the results of the site inspections. If necessary, the plan will be revised within 30 days of the inspection. Changes in the control measures will be scheduled for implementation on-site in a timely manner. The results of the compliance evaluation will be documented in a report signed by the Plant Superintendent. The report will summarize inspection results, identify any incidence of non-compliance, and describe the follow-up actions. The Annual Site Compliance Report will also note plan revisions, which have taken place during the preceding year. If the plant is in compliance, the report will contain a certification stating that compliance has been achieved. This report will be retained by Rippel for a period of at least one year following the expiration date of the storm water permit. 5.2 PLAN REVISIONS If the Annual Site Compliance Report lists changes at the Bloomington Plant that could significantly effect the potential for the discharge of pollutants to storm water, the SWPPP will be amended. These changes may include alterations to current materials handling, changes to plant operations, or changes in maintenance practices. The SWPPP will be revised as needed and revisions will be noted on the Inspection Form. The Plant Superintendent will have the responsibility for revising the plan so that it reflects current conditions at the facility and for documenting these revisions to reflect Rippel s efforts to control pollution in its storm water runoff (3) 15 CONESTOGA-ROVERS & ASSOCIATES

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28 APPENDIX A GENERAL STORM WATER PERMIT AND SWPPP GUIDELINES (3)

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41 APPENDIX B ANNUAL COMPLIANCE EVALUATION FORM (3)

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