Best Management. Guidance Manual. Practices (BMP) for Developing

Transcription

1 United States Office of water EPA 833-B Environmenta Protection (EN-336) October 1993 Agency Guidance Manua for Deveoping Best Management Practices (BMP)

2 TABLE OF CONTENTS 1. INTRODUCTION TO BEST MANAGEMENT PRACTICES PURPOSE OF THIS MANUAL BACKGROUND OF NPDES PERMITTING BMP Reguatory History BEST MANAGEMENT PRACTICES AND POLLUTION PREVENTION BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT PURPOSE OF THIS CHAPTER BMP APPLICABILITY What Activities and Materias at an Industria Faciity Are Best Addressed by BMP? How Do BMPS Work? What Are the Types of BMPS? COMPONENTS OF BMP PLANS BMP Pan Panning Phase BMP Committee BMP Poicy Statement Reease Identification and Assessment BMP Pan Deveopment Phase Good Housekeeping Preventive Maintenance Inspections Security Empoyee Training Recordkeeping and Reporting BMP Pan Evauation and Reevauation Phase Pan Evauation Pan Reevauation INDUSTRY-SPECIFIC BEST MANAGEMENT PRACTICES PURPOSE OF THIS CHAPTER INDUSTRY CATEGORY SELECTION METAL FINISHING Industry Profie Effective BMPs ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS (OCPSF) MANUFACTURING Industry Profie Effective BMPs TEXTILES MANUFACTURING Industry Profie Effective BMPs PULP AND PAPER MANUFACTURING Industry Profie NPDES Best Management Practices Manua 1

3 TABLE OF CONTENTS Effective BMPs PESTICIDES FORMULATION Industry Profies Effective BMPs PHARMACEUTICALS MANUFACTURING Industry Profie Effective BMPs PRIMARY METALS MANUFACTURING Industry Profie Effective BMPs PETROLEUM REFINING Industry Profie Effective BMPs INORGANIC CHEMICALS MANUFACTURING Industry Profie Effective BMPs RESOURCES AVAILABLE FOR DETERMINING BEST MANAGEMENT PRACTICES PURPOSE OF THIS CHAPTER NATIONAL AND INTERNATIONAL RESOURCES Poution Prevention Information Cearinghouse (PPIC) Internationa Ceaner Production Information Cearinghouse (ICPIC) Waste Reduction Institute for Training and Appications Research, Inc. (WRITAR) Nationa Technica Information Service (NTIS) Nonpoint Source (NPS) Information Exchange Buetin Board System (BBS) Office of Water Resource Center REGIONAL RESOURCES Northeast Mutimedia Poution Prevention (NEMPP) Program Waste Reduction Resource Center for the Southeast (WRRC) Pacific Northwest Poution Prevention Research Center (PNPPRC) EPA Offices and Libraries STATE, UNIVERSITY, AND OTHER AVAILABLE RESOURCES Center for Waste Reduction Technoogies (CWRT) Soid Waste Information Cearinghouse (SWICH) State Resources University-Affiiated Resources NPDES Best Management Practices Manua

4 TABLE OF CONTENTS APPENDIX A - BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHECKLIST APPENDIX B - EXAMPLE FORMS AND CHECKLISTS APPENDIX C - THEORETICAL DECISION-MAKING PROCESS FOR BMP PLAN DEVELOPMENT APPENDIX D - BIBLIOGRAPHY NPDES Best Management Practices Manua 3

5 LIST OF EXHIBITS FACTORS AFFECTING SPECIFIC BMP SELECTION SUGGESTED ELEMENTS OF A BASELINE BMP PLAN BMP COMMITTEE ACTIVITIES AND RESPONSIBILITIES EXAMPLE OF COMMITTEE FORMATION TO EFFECTIVELY MANAGE AN ENVIRONMENTAL PROGRAM EXAMPLE OF THE USE OF A POLICY AN EXAMPLE OF THE EFFECTIVENESS OF USING A RELEASE IDENTIFICATION AND ASSESSMENT APPROACH AN EXAMPLE OF THE SUCCESSFUL IMPLEMENTATION OF A GOOD HOUSEKEEPING PROGRAM CONSIDERATIONS FOR SELECTION OF MITIGATIVE PRACTICES DEMONSTRATION OF THE NEED FOR AN EFFECTIVE PM PROGRAM EXAMPLES OF POOR COORDINATION BETWEEN OPERATIONS AND MAINTENANCE STAFF RELEASES WHICH COULD HAVE BEEN PREVENTED BY EFFECTIVE INSPECTION PROGRAMS POSSIBLE COMPONENTS OF A SECURITY PLAN EXAMPLE OF THE IMPLEMENTATION OF EMPLOYEE TRAINING TO ENSURE THE SUCCESS OF ENVIRONMENTAL CONTROLS EXAMPLE OF AN EFFECTIVE REPORTING PROGRAM DESIGNED TO PREVENT ENVIRONMENTAL RELEASES BMP SELECTION PROCESS SUMMARY OF BMPs UTILIZED IN THE METAL FINISHING INDUSTRY SUMMARY OF BMPs UTILIZED IN THE OCPSF MANUFACTURING INDUSTRY SUMMARY OF BMPs UTILIZED IN THE TEXTILES MANUFACTURING INDUSTRY SUMMARY OF BMPs UTILIZED IN THE PULP AND PAPER MANUFACTURING INDUSTRY SUMMARY OF BMPs UTILIZED IN THE PESTICIDES FORMULATION INDUSTRY SUMMARY OF BMPs UTILIZED IN THE PHARMACEUTICAL MANUFACTURING INDUSTRY SUMMARY OF BMPs UTILIZED IN THE PRIMARY METALS MANUFACTURING INDUSTRY SUMMARY OF BMPs UTILIZED IN THE PETROLEUM REFINING INDUSTRY TYPES OF INORGANIC CHEMICALS SUMMARY OF BMPs UTILIZED IN THE INORGANIC CHEMICALS MANUFACTURING INDUSTRY PPIC CONTACT INFORMATION INSTRUCTIONS FOR PIES USE ICPIC CONTACT INFORMATION WRITAR CONTACT INFORMATION NPDES Best Management Practices Manua

6 LIST OF EXHIBITS 4-5 NTIS CONTACT INFORMATION NPS BBS CONTACT INFORMATION OFFICE OF WATER RESOURCE CENTER CONTACT INFORMATION NEMPP CONTACT INFORMATION WRRC CONTACT INFORMATION PNPPRC CONTACT INFORMATION EPA REGIONAL POLLUTION PREVENTION CONTACTS EPA LIBRARY CONTACT INFORMATION CWRT CONTACT INFORMATION SWICH CONTACT INFORMATION STATE PROGRAM INFORMATION UNIVERSITY AFFILIATED RESOURCES NPDES Best Management Practices Manua 5

7 INTRODUCTION TO BEST MANAGEMENT PRACTICES CHAPTER 1 1. INTRODUCTION TO BEST MANAGEMENT PRACTICES Best management practices (BMPs) are recognized as an important part of the Nationa Poutant Discharge Eimination System (NPDES) permitting process to prevent the reease of toxic and hazardous chemicas. Over the years, as BMPs for many different types of faciities have been deveoped, case studies have demonstrated not ony the success but the fexibiity of the BMP approach in controing reeases of poutants to receiving waters. More recenty, poution prevention practices have become part of the NPDES program, working in conjunction with BMPs to reduce potentia poutant reeases. Poution prevention methods have been shown to reduce costs as we as poution risks through source reduction and recycing/reuse techniques. The Federa Water Poution Contro Act of 1972 estabished the objectives of restoring and maintaining the chemica, physica, and bioogica integrity of the Nation s waters. These objectives remained unchanged in the 1977, 1982, and 1987 amendments, commony referred to as the Cean Water Act (CWA). To achieve these objectives, the CWA sets forth a series of goas, incuding attaining fishabe and swimmabe designations by 1983 and eiminating the discharge of poutants into navigabe waters by As part of the CWA strategy to eiminate discharges of poutants to receiving waters, NPDES permit imitations have become more stringent. The Environmenta Protection Agency (EPA) recognizes that industria and municipa faciities subject to the NPDES program may need to undertake additiona measures to meet these permit imitations, as we as the goas of the CWA. EPA beieves that such measures can be technoogicay and economicay achievabe through the deveopment of formaized pans that contain BMPs and poution prevention practices. 1.1 PURPOSE OF THIS MANUAL The purpose of this manua is to provide guidance to NPDES permittees in the deveopment of BMPs for their faciities. The manua may aso be usefu to NPDES permit writers and inspectors charged with evauating the adequacy of BMP pans. In particuar, the manua promotes the integration of poution prevention concepts and practices in BMP pans. This manua has four major goas: (1) to provide a genera understanding of the requirements of the CWA pertaining to BMPs and show the reationship between BMPs and poution prevention practices; (2) to provide a starting NPDES Best Management Practices Manua -

8 CHAPTER 1 INTRODUCTION TO BEST MANAGEMENT PRACTICES point for deveoping and impementing an effective BMP pan that integrates faciity-specific and genera BMPs and poution prevention practices; (3) to provide specific exampes of effective BMPs and poution prevention practices to aid faciities endeavoring to deveop their own BMPs; and finay (4) to identify sources which a faciity may consut when deveoping BMPs and poution prevention practices. This manua incudes four chapters intended to achieve the above goas. Chapter 1 provides an introduction to the NPDES program and the reguatory context for BMPs. The reationship between BMPs and other poution prevention requirements such as the Poutant Prevention Act is aso discussed. Chapter 2 discusses the suggested components of a BMP pan, incuding committee formation, poicy derivation, reease identification and assessment, good housekeeping, preventive maintenance, inspections, security, empoyee training, and recordkeeping and reporting. Each component is defined and described in terms of what the component is, how the component functions, methods to create the component, and what to do/what not to do. Additionay, the usefuness of each component is iustrated by an exampe, thereby promoting the deveopment of an effective BMP pan. Chapter 3 sets forth process-specific BMPs for the meta pating and finishing, pesticides, texties, pup and paper, organic chemicas, pharmaceuticas, primary metas manufacturing and forming, inorganic chemicas, and petroeum refining industries. Successfu and demonstrated BMPs are discussed in this chapter in terms of benefits to water, benefits to other media, and other incentives. Data sources are aso cited to enabe readers to consut the referenced document. Finay, a discussion of avaiabe resources at the internationa, nationa, regiona, and State eves is presented in Chapter 4. Programs are summarized in terms of the genera resources avaiabe and imitations in the scope of assistance. Specific information is provided to enabe readers to contact programs directy and obtain necessary information. 1.2 BACKGROUND OF NPDES PERMITTING The principa mechanism for reducing the discharge of poutants from point sources is through impementation of the NPDES program, estabished by Section 402 of the CWA. A faciities with point source discharges must appy for and obtain a NPDES permit. NPDESauthorized States are tasked with issuing permits. Where State NPDES authorization has not yet occurred, EPA Regions issue NPDES permits. 1-2 NPDES Best Management Practices Manua

9 INTRODUCTION TO BEST MANAGEMENT PRACTICES CHAPTER 1 Four minimum eements are typicay incuded in each permit issued: (1) effuent discharge imitations; (2) monitoring and reporting requirements; (3) standard conditions; and (4) specia conditions. The numeric effuent discharge imits contained in a NPDES permit are based on the most stringent vaue among technoogy-based effuent guideines imitations, water quaity-based imitations, and imitations derived on a case-by-case basis. Permits aso contain standard conditions that prescribe primariy administrative and ega requirements to which a faciities are subject. Finay, permits may contain any suppementa contros, referred to as specia conditions, that may be needed in order to ensure that the reguations driving the NPDES program and, utimatey, the goas of the CWA are met. Best management practices are one such type of suppementa contro BMP Reguatory History Section 304(e) of the CWA authorized the EPA Administrator to pubish reguations to contro discharges of significant amounts of toxic poutants isted under Section 307 or hazardous substances isted under Section 311 from industria activities that the Administrator determines are associated with or anciary to industria manufacturing or treatment processes. As defined by the CWA, the discharges to be controed by BMPs are pant site runoff, spiage or eaks, sudge or waste disposa, and drainage-from raw materia storage. On September 1, 1978, EPA proposed reguations (43 FR 39282) addressing the use of procedures and practices to contro discharges from activities associated with or anciary to industria manufacturing or treatment processes. The proposed rue indicated how BMPs woud be imposed in NPDES permits to prevent the reease of toxic and hazardous poutants to surface waters. The reguations (40 CFR Part 125, Subpart K, Criteria and Standards for Best Management Practices Authorized Under Section 304(e) of the CWA) were proposed on August 21, 1978, in the NPDES reguations (43 FR 37078). Whie this Subpart never became effective, it remains in the Code of Federa Reguations and can be used as guidance by permit writers. Athough 40 CFR Part 125, Subpart K was not finaized, EPA and States continue to incorporate BMPs into permits based on the authority contained in Section 304(e) of the CWA and the reguations set forth in 40 CFR (k). Whie Section 304(e) of the CWA restricts the NPDES Best Management Practices Manua 1-3

10 CHAPTER 1 INTRODUCTION TO BEST MANAGEMENT PRACTICES appication of BMPs to anciary sources and certain chemicas, the reguations contained in 40 CFR (k) authorize the use of BMPs to abate the discharge of poutants when (1) they are deveoped in accordance with Section 304(e) of the CWA, (2) numeric imitations are infeasibe, or (3) the practices are necessary to achieve imitations/standards or meet the intent of the CWA. Thus, permit writers are afforded considerabe atitude in empoying BMPs as poution contro mechanisms. 1.3 BEST MANAGEMENT PRACTICES AND POLLUTION PREVENTION Best management practices are inherenty poution prevention practices. Traditionay, BMPs have focused on good housekeeping measures and good managementechniques intending to avoid contact between poutants and water media as a resut of eaks, spis, and improper waste disposa. However, based on the authority granted under the reguations, BMPs may incude the universe of poution prevention encompassing production modifications, operationa changes, materias substitution, materias and water conservation, and other such measures. EPA endorses poution prevention as one of the best means of poution contro. In 1990, the Poution Prevention Act was enacted and set forth a nationa poicy that: I... poution shoud be prevented or reduced at the source whenever feasibe; poution that cannot be prevented shoud be recyced in an environmentay safe manner, whenever feasibe; poution that cannot be prevented or recyced shoud be treated in an environmentay safe manner whenever feasibe; and disposa or other reease into the environment shoud be empoyed ony as a ast resort and shoud be conducted in an environmentay safe manner. EPA recognizes that significant opportunities exist for industry to reduce or prevent poution through cost-effective changes in production, operation, and raw materias use. In addition, such changes may offer industry substantia savings in reduced raw materias, poution contro, and iabiity costs, as we as protect the environment and reduce heath and safety risks to workers. Where poution prevention practices can be both environmentay beneficia and economicay feasibe, EPA finds their impementation to be prudent. -4 NPDES Best Management Practices Manua

11 INTRODUCTION TO BEST MANAGEMENT PRACTICES CHAPTER 1 EPA beieves that the intent of poution prevention practices and BMPs are simiar and that they can be concurrenty deveoped in a technoogicay sound and cost-effective manner. Thus, athough this manua primariy focuses on best management practices, which pertain to the NPDES program, the reader may be compeed to aso consider poution prevention for a media in order to maximize the benefits achieved. NPDES Best Management Practices Manua -5

12 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAPTER 2 2. BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT Many faciities currenty impement successfu measures to reduce and contro environmenta reeases of a types of poutants. These measures have been successfuy impemented both formay as part of best management practice (BMP) pans and informay as part of unwritten standard operating procedures. In the context of the NPDES permit program, permittees are required to deveop BMP pans to address specific areas of concern. The BMP pan deveoped by the permittee becomes an enforceabe condition of the permit. The Environmenta Protection Agency (EPA) beieves that to ensure the continuing and greater successes of these programs, poution prevention measures shoud be incorporated into a written company-wide pan. 2.1 PURPOSE OF THIS CHAPTER This chapter provides the reader with the information needed to deveop and impement a BMP pan. The chapter begins with a discussion of appicabiity of BMP pans to industria faciities. The remainder of the chapter provides a detaied discussion of each of the recommended components of a BMP pan, set forth in the foowing format: What is the component? A description is given incuding definitions, appicabiity, and genera imitations. How does the component function? The text discusses how the component interacts with other components, considerations when deveoping the component, and an outine of the steps invoved in the deveopment process. How is the component created/deveoped.? An expanation of the detaied steps to take in deveoping a program around the eement is provided. What to do/what not to do. Guidance has been offered in terms of hepfu hints as we as potentia probems to avoid. To increase the usefuness of the information, exampes of actua BMPs accompany the text. Additionay, three appendices suppement this Chapter. Considerations when panning and deveoping the BMP pan are set forth in a checkist format in Appendix A. Exampe forms and checkists that may be usefu to faciities in the deveopment and impementation of BMP pan NPDES Best Management Practices Manua 2-1

13 CHAPTER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT activities are provided in Appendix B. Appendix C contains an exampe BMP pan and the decision- making process used during its deveopment. 2.2 BMP APPLICABILITY BMPs are deveoped as part of the Nationa Poutant Discharge Eimination System (NPDES) permitting requirements to contro reeases of harmfu substances. BMPs may appy to an entire site or be appropriate for discrete areas of an industria faciity. Many of the same environmenta contros promoted as part of a BMP pan may currenty be used by industry in storm water poution prevention pans, spi prevention contro and countermeasure (SPCC) pans, Occupationa Safety and Heath Administration (OSHA) safety programs, fire protection programs, insurance poicy requirements, or standard operating procedures. Additionay, where faciities have deveoped poution prevention programs, contros such as source reduction and recycing/reuse may be simiar to those promoted as part of a BMP pan. The foowing basic questions can be used to estabish the scope of BMP pans: (1) What activities and materias at an industria faciity are best addressed by BMPs? (2) How do BMPs work? and (3) What are the types of BMPs? What Activities and Materias at an Industria Faciity Are Best Addressed by BMPs? Traditionay, BMP activities have focussed on activities associated with or anciary to industria manufacturing or treatment processes. These have been identified in Section 304(e) of the Cean Water Act as pant site runoff, spiage or eaks, sudge or waste disposa, and drainage from raw materia storage which the Administrator determines are associated with or anciary to the industria manufacturing or treatment process." These activities have historicay been found to be amenabe to contro by BMPs. Some exampes incude the foowing: Materia storage areas for toxic, hazardous, and other chemicas incuding raw materias, intermediates, fina products, or byproducts. Storage areas may be pies of materias or containerized substances. Typica storage containers coud incude iquid storage vesses ranging in size from arge tanks to 55-gaon drums; dry storage in bags, bins, sios and boxes; and gas storage in tanks and vesses. The storage areas can be open to the environment, partiay encosed, or fuy contained. Loading and unoading operations invoving the transfer of materias to and from trucks or rai cars, incuding in-pant transfers. These operations incude pumping of iquids or gases from truck or rai car to a storage faciity or vice versa, pneumatic transfer of dry 2-2 NPDES Best Management Practices Manua

14 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAPTER 2 chemicas during vehice oading or unoading, transfer by mechanica conveyor systems, and transfer of bags, boxes, drums, or other containers from vehices by fork-ift, hand, or other materias handing methods. Faciity runofgenerated principay from rainfa on a pant site. Runoff can become contaminated with harmfu substances when it comes in contact with materia storage areas, oading and unoading areas, in-pant transfers areas, and sudge and other waste storage/disposa sites. Faout, resuting from pant air emissions that sette on the pant site, may aso contribute to contaminated runoff. In addition to BMPs, faciity runoff from industria sites may aso be directy reguated under the NPDES storm water permitting program. Sudge and waste stomge and disposa areas incuding andfis, pits, ponds, agoons, and deep-we injection sites. Depending on the construction and operation of these sites, there may be a potentia for eaching of toxic poutants or hazardous substances to groundwater, which can eventuay reach surface waters. In addition, iquids may overfow to surface waters from these disposa operations. With the increasing in awareness of poution prevention opportunities as we as the increase in egisation and reguatory poicies directing efforts towards poution prevention, much of the traditiona focus of BMP activities is being redirected from anciary activities to industria manufacturing processes. This redirection is resuting in the integrated appication of traditiona BMPs and poution prevention practices into cohesive and encompassing pans that cover a aspects of industria faciities How Do BMPs Work? BMPs arepmctices orprocedures. They incude methods to prevent toxic and hazardous substances from reaching receiving waters. They are most effective when organized into a comprehensive faciity BMP pan. * BMPs are quaitative. They are designed to address the quaity of a faciity s practices, and- may utimatey affect the abiity of the faciity to meet environmenta contro standards.. BMPs are fexibe. Many different practices can be used to achieve simiar environmentay protective resuts. With faciity-specific considerations as the major consideration in seecting appropriate BMPs, this fexibiity aows a faciity to taior a BMP pan to meet its needs using the capabiities and resources avaiabe. NPDES Best Management Practices Manua 2-3

15 CHAPTER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT What Are the Types of BMPs? BMPs may be divided into genera BMPs, appicabe to a wide range of industria operations, and faciity-specific (or process-specific) BMPs, taiored to the requirements of an individua site. Genera BMPs are widey practiced measures that are independent of chemica compound, source of poutant, or industria category. Genera BMPs are aso referred to as baseine practices, and are typicay ow in cost and easiy impemented. Genera BMPs are practiced to some extent at amost a faciities. Common genera BMPs incude good housekeeping, preventive maintenance, inspections, security, empoyee training, and recordkeeping and reporting. Faciity-specific BMPs are measures used to contro reeases associated with individuay identified toxic and hazardous substances and/or one or more particuar anciary source. Faciity- specific BMPs are often deveoped when a faciity notes a history of probem reeases of toxic or hazardous chemicas, or when faciity personne beieve that actua or potentia poutant discharge probems shoud be addressed. Faciity-specific BMPs may incude many different practices such as source reduction and on-site recyce/reuse. Faciity-specific BMPs wi vary from site to site depending upon site characteristics, industria processes, and poutants. For exampe, a site-specific BMP in the form of area dikes may be adopted due to the ocation of the faciity: faciities in fat areas or on sopes are ikey to utiize dikes to contro spis whereas there may be no need for dikes for faciities ocated in basins. Additionay, pants handing and storing arge amounts of iquid chemicas woud be more ikey to utiize dikes than faciities storing and using dry chemicas. Faciities experiencing erosion and sediment contro probems may consider estabishing vegetative buffer strips or indigenous ground cover for purposes of soi stabiization and infitration of runoff. Faciity sites ocated adjacent to other industria areas may consider runon contros to prevent extraneous spis and contaminated runon from entering the faciity site. Other site-specific considerations, such as endangered species, may motivate faciities to store materias in an aternate ocation so as to prevent exposure. Processes aso drive the determination of appropriate specific BMPs. Materias handing procedures that expose empoyees to toxic chemicas (e.g., hand drawing) may prompt the 2-4 NPDES Best Management Practices Manua

16 BEST MANAGEMENT PRAmICES PLAN DEVELOPMENT CHAPTER 2 consideration of procedures that reduce the potentia for exposure (e.g., automated pneumatic pumping in encosed conduits). Some exampes of process-specific BMPs incude the foowing: Using spash pates designed to prevent spis at a meta finishing faciity Instaing sovent recovery equipment to contro benzene reeases at a petroeum refinery Purchasing sovents in reusabe containers rather than %-gaon drums to ease storage concerns and reduce wastewater resuting from requirements to tripe rinse drums. Poutant characteristics such as voatiity and toxicity aso affect BMP seection. More and more, harmfu chemicas are being considered for repacement with ess toxic aternatives, or for eimination from the process. Ozone ayer-depeting sovents which are used for ceaning at many faciities are being repaced with detergent-based ceaning agents. Additionay, faciities using materias with toxic properties have been inspired to take more proactive contro measures (e.g., doube waed containment). The choice of faciity-specitic BMPs can be affected by a number of factors such as those discussed in Exhibit COMPONENTS OF BMP PLANS Suggested components of BMP pans are defined and described in this section. The suggested eements of a good BMP pan can be separated into three phases: panning, deveopment and impementation, and evauation/reevauation. Generay, the panning phase, discussed in Section 2.3.1, incudes demonstrating management support for the BMP pan and identifying and evauating areas of the faciity to be addressed by BMPs. The goa of pan deveopment shoud be to ensure that its impementation wi prevent or minimize the generation and the potentia for reease of poutants from the faciity to the waters of the U.S. The deveopment phase consists of determining, deveoping, and impementing genera and faciity-specific BMPs and is described in Section The evauation/reevauation phase described in Section consists of an assessment of the components of a BMP pan and reevauation of pan components periodicay, or as a resut of factors such as environmenta reeases and/or changes at the faciity. Suggested eements of a BMP pan are provided in Exhibit 2-2. NPDES Best Management Practices Manua 2-5

17 CHAPTER 2 BEST MANAGEMENT PRACI ICES PLAN DEVELOPMENT EXHIBIT 2-: FACTORS AFFECTING SPECIFIC BMP SELECTION Chemica nature: The need to contro materias based on toxicity and fate and tgusp0-t. Praximity to waterbodies: The need to contro iquid spis prior to their reease to media such as water from which materias may not ater be separated. Receiving waters: Ihe need to protect sensitive receiving waters which are more severey impacted by rekases of toxic or hazardous materias. The need to protect the water uses incuding recreationa waters, drinking water suppies, and fragie aquatic and biota communities. Proximity to popuace: The need to contro hazardous materias with potentia to be reeased near popuated areas. Cimate: The need to prevent voatiization and ignitabiity in warmer cimates. The need to reduce wear on moving parts in freezing cimates. The need to avoid spis in cimates and under circumstances where mitigation cannot occur. Age of the faciity/equipment: The need to prevent reeases caused by oder equipment with greater capacity for faiure. The need to address obsoete and outdated instruments and processes which are not environmentay protective. Process compexity: The need to address probems of materias incompatibiity. Engineering design: The need to address design faws and deficiencies. Empoyee safety: The need to prevent unnecessary exposure between empoyee and chemicas. Environmenta reease record: The need to contro reeases from specific areas demonstrating previous probems BMP Pan Panning Phase In the panning phase, a faciity must decide who wi take the responsibiity for estabishing and carrying out the BMP pan. The pan shoud be initiated with cear support and input from faciity management and empoyees. The faciity must aso identify and evauate areas of the faciity that, because of the substances invoved and their management, wi be addressed in the BMP pan. Each of these eements is discussed in detai on the foowing pages BMP Committee What is a BMP Committee? A BMP committee is comprised of interested staff within the faciity s organization. The committee wi represent the company s interests in a phases of BMP pan deveopment, 24 NPDES Best Management Practices Manua

18 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAPTER 2 impementation; oversight, and pan evauation. EXHIBIT 2-2: SUGGESTED ELEMENTS OF A BASELINE BMP PLAN It shoud be noted that a BMP committee may function simiary to other committees that might exist at an industria faciity (e.g., poution prevention committee) and may incude the same empoyees. How Does the BMP Committee Function? The BMP committee is deveoped to assist a faciity in managing a aspects of the BMP pan. The committee functions to conduct activities and shouder the responsibiities of a eements discussed in Exhibit 2-3. Panning Phase Considerations 1. BMP committee 2. BMP poicy statement 3. Reease identification and assessment Deveopment Phase Considerations 4. Good housekeeping 5. Preventive maintenance 6. Inspections 7. Security 8. Empoyee training 9. Recordkeeping and reporting Evauation and Reevauation Phase Considerations 10. Evauate pan impementation benefits 11. Periodicay or as needed, repeat steps -9 To be most effective, the committee must perform tasks efficienty and smoothy. In arge part, the personne seected to act as committee members wi determine the committee s success. Some of the considerations for personne seection incude the foowing: A ead committee member must be determined Committee members must incude persons knowedgeabe of the pant areas invoved (e.g., process areas, tank farms) and utiization of chemicas and generation of poutants (e.g., sovents, products, chemica reactants) at the faciity Committee members shoud have the authority to make decisions effecting BMP pan deveopment and impementation The size of the committee must be appropriate to the faciity. The committee must represent affected areas of the pant and empoyees. An exampe of the effectiveness of the formation of a committee is provided in Exhibit 2-4. NPDES Best Management Practices Manua 2-7

19 CHAF TER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT EXHIBI f 2-3: BMP COMMITTEE ACTIVITIES & RESPONSIBILITIES Deveop the scope of the BMP pan Make recommendations to management in support of company BMP poicy Review any existing accidenta spi contro pans to evauate existing BMPs Identify toxic and hazardous substances Identify areas with potentia for reease to the environment Conduct assessments to prioritize substances and areas of concern Determine and seect appropriate BMPs Set forth standard operating procedures for impementation of BMPs Oversee the impementation of the BMPs Estabish procedures for recordkeeping and reporting Coordinate faciity environmenta reease response, ceanup, and reguatory agency notification procedures Estabish BMP training for pant and contractor personne Evauate the effectiveness of the BMP pan in preventing and mitigating reeases of poutants Periodicay review the BMP pan to evauate the need to update and/or modify the BMP pan. How Is a BMP Committee Deveoped? The BMP committee is responsibe for deveoping the BMP pan and assisting the faciity management in its impementation, periodic evauation, and updating. Whie the BMP committee is responsibe for deveoping the pan and overseeing its impementation, a activities need not be imited to committee members. Rather, appropriate company personne who are knowedgeabe in the areas of concern can carry out certain activities associated with BMP pan deveopment. With this in mind, the seection of the committee members can be imited to a seect set of individuas, whie the resources of interested and knowedgeabe empoyees can sti be utiized. In order to ensure a propery run organization, one person shoud be designated as the ead committee member. Thus, the first step in deveoping a BMP committee is to determine the appropriate committee chairperson. The determination of a singe eader wi assist in the smooth conduct of meetings and the designation of tasks, and wi aid in the decision-making process. Generay, the chairperson shoud be highy motivated to deveop and impement the BMP pan, famiiar with a committee members and their areas of expertise, and experienced in managing tasks 2-8 NPDES Best Management Practices Manua

20 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAPTER 2 EXHIBIT 2-4: EXAMPLE OF COMMITTEE FORMATION TO EFFECTIVELY MANAGE AN ENVIRONMENTAL PROGRAM The 3M company, a manufacturer of diverse products such as coated abrasives, pressure sensitive tape, photographic fim, eectrica insuation materias, and reposition notes, has deveoped a corporate phiosophy that Poution Prevention Pays (referred to as the 3P program). As part of the 3P program, 3M has created a 3P Coordinating Committee which incudes empoyee representatives from the engineering manufacturing, aboratory, and corporate environmenta sectors. The 3P Coordinating Committee provides support and coordination for nationwide teams estabishing 3P programs. These 3P Teams are organized by empoyees that have identified poution probems and recognize potentia soutions. The 3P Coordinating Committee and the 3P Teams have been instrumenta in source reduction of hydrocarbons, odor, water, dissoved soids, sufur, zinc, acoho, and incinerated scrap. In the first year of the 3P programs, air poutants have been reduced by 123,000 tons, water poutants by 16,400 tons, wastewater by 1,600 miion gaons, and soid wastes poutants by 409,000 tons. This has resuted in savings of more than $500 miion. Adapted from: T. Zea, Case Study: How 3M Makes Poution Prevention Pay Big Dividends, Poution Prevention Review, Winter of this magnitude. The chairperson wi be responsibe for ensuring that a tasks are assigned to appropriate personne, keeping faciity management and empoyees informed, and cohesivey deveoping the BMP pan. Potentia candidates for this roe are pant managers, environmenta coordinators, or other distincty knowedgeabe technica and management personne. The next step is to seect the appropriate personne to comprise the committee. Personne seected shoud represent a affected faciity areas. Members might aso be seected based on their areas of expertise (e.g., industria processes). Personne might be seected who have a fu understanding of the manufacture processes from raw materias to fina products, as we as of the recycing, treatment, and disposa of wastes. Possibe candidates incude foremen in manufacturing, production, or waste treatment and disposa; maintenance engineers; environmenta and safety coordinators; and materias storage and transfer managers. Not ony must committee members understand the activities conducted throughout the entire faciity, members of the BMP committee NPDES Best Management Practices Manua 2-9

21 CHAPTER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT must aso incude individuas who are in the decision-making positions within the company structure. Some committee members must represent company management and have the authority to impement measures adopted by the committee. Whie the BMP committee shoud refect the ines of authority within the company, it shoud aso be sensitive to genera empoyee interests. It is crucia to ensure that empoyees are aware of and in support of the BMP pan and the responsibe committee, as it is primariy the empoyees who wi impement the changes resuting from committee decisions. Forming a committee comprised soey of upper eve management and administrative personne woud excude genera personne whose input is critica for the deveopment and impementation of the pan. Seecting empoyeechosen representatives, such as union stewards, may be an appropriate means to ensure empoyee invovement. The size of a BMP committee shoud refect the size and compexity of the faciity, as we as the quantity and toxicity of the materias at the faciity. The committee must be sma enough to communicate in a open and interactive manner, yet arge enough to aow for input from a necessary parties. Where needed, committee members shoud ca upon the expertise of others through the estabishment of project-specific task forces. For exampe, personne invoved in research and deveopment may be asked to research the effectiveness of product substitution and process changes that are being considered as part of BMP pan deveopment. This method of caing upon speciaists, when the need arises, shoud aow the committee to remain a manageabe size. Generay, the size seection process outined beow presents a good rue of thumb: For sma faciities, a singe committee member is acceptabe as ong as that person has the requisite expertise and authority For arger faciities, seection of six to eight peope as permanent members of the committee shoud be idea NPDES Best Management Practices Manua

22 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAPTER 2 BMP Committee - What to Do Deveop a roster of BMP committee members which incudes area of speciaization and projected responsibiities. This ist heps identify any hoes in the panned BMP deveopment activities and any missing expertise. Incude a ist of aternate BMP committee members where transfers are expected to occur during the ife of the BMP pan. Post BMP committee member names and incuding them in the pan to aow any interested parties the opportunity to contact BMP committee members. Whie deveoping and updating the BMP pan, incude input from interested empoyees not on the committee. Empoyee input sessions and suggestions boxes can be used to meet this goa. Extend technica reviews to personne not on the BMP committee, where speciaized expertise is necessary or where interest is expressed. Foow up with a responsibe parties on a periodic basis to ensure they are aware of their BMP-reated responsibiities. Encourage BMP committee members to spend time on-the-ine in order to communicate with other potentiay interested parties. Set schedues with miestone dates for the performance of important activities. This avoids possibe procrastination and aows the BMP pan deveopment to remain on schedue. BMP Committee - What Not to Do The committee shoud enabe, not impede, the decision-making process for preventing or mitigating spis or otherwise responding to events addressed by the BMP pan. Remember that personne contributing to the design of a BMP need not be member of the BMP committee. This is of particuar importance where a technica speciaist or manager simpy woud not have the time to contribute on a reguar basis BMP Poicy Statement What Is a BMP Poicy Statement? A BMP poicy statement describes the objectives of the BMP program in cear, concise anguage and estabishes the company poicies reated to BMPs. Exhibit 2-5 provides exampes of the successfu use of a poicy. NPDES Best Management Practices Manua 2-11

23 CHAPTER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT EXHIBIT 2-5: EXAMPLE OF THE USE OF A POLICY Dow Chemica has observed a significant impact as a resut of their company s environmenta poicy. As part of their Environmenta Poicy and Guideines, Dow has set forth a hierarchy simiar to that deveoped as part of the Poution Prevention Act of Dow s poicy sets forth preferences to hande materias by reducing poutants at the source, foowed by recyce and use of materias whenever possibe. Where disposa is necessary, Dow has specified that incineration be considered first, foowed by and disposa on Dow-owned property, and finay and disposa on property not owned by Dow. Dow s decision to foow its disposa hierarchy was based in arge part on the iabiity of disposa. Dow reasoned that incineration was the most appropriate disposa method since it resuted in the poutants in the ash materias being in eementa form. In many cases, the company has identified opportunities for recyce of materias found in the incinerator ash. Dow aso imposed a $215 per drum surcharge for hazardous wastes going to a andfi to provide incentives for finding aternatives to andfiing. Dow aso beieves that they can better exercise contro of onsite disposa, thus infuencing the preferences for onsite rather than offsite disposa. Dow s poicy has resuted in an impact on the environmenta reeases. For exampe, at the Dow Pit&burg, Caifornia faciity, wastewater discharges have been reduced by 95 percent over the past 10 years. Additionay, the approximatey 10.2 miion pounds of chorinated organics wastes which are generated are either incinerated or recyced. Adapted from: D. Sarokin, W. Muir, C. Mier, S. Sperber, Cutting chemica Wastes: What 29 organic chemica Pants are Doing to Reduce Hazardous Wastes, INFORM, Inc., New York, New York, How Does a BMP Poicy Statement Function? The poicy statement provides two major functions: (1) it demonstrates and reinforces management s support of the BMP pan; and (2) it describes the intent and goas of the BMP pan. It is very important that the BMP poicy represent both the company s goas and genera empoyee concerns. Severa steps to take in deveoping an effective BMP poicy statement incude the foowing: 2-12 NPDES Best Management Practices Manua

24 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAF TER 2 Determine the appropriate author Deveop tone and content that are positive, but that estabish reaistic and achievabe goas Distribute the poicy statement effectivey. How Is a BMP Poicy Statement Created? The first step in creating a BMP poicy statement is determining the appropriate author. To indicate management s commitment, the poicy statement shoud be signed by a responsibe corporate officer. A responsibe corporate officer can be the president, vice president, or the principa manager of manufacturing, production, or operations. Generay, the poicy statement author shoud be a person who performs poicy- or decision-making functions for the corporation/faciity. The next step in deveoping the BMP poicy statement is to craft the specific anguage. The poicy statement may incude references to the company s commitment to being a good environmenta citizen, expected improvements in pant safety, and potentia cost savings. Regardess of persona stye, in a cases the poicy shoud: (1) indicate the company s support of BMPs to improve overa faciity management and (2) introduce the intent of the BMP pan. The ength and eve of detai of the poicy statement wi vary depending on the writer s persona stye. The foowing variations may be incuded in a BMP poicy statement: An outine of steps that wi be taken A discussion of the time frames for deveopment and impementation An indication of the areas and poutants of focus A projection of the end resut of the BMP pan Create enthusiasm and support for the BMP pan by a empoyees. The tone of the BMP poicy statement is aso important. The projected positive impacts of BMP impementation shoud be discussed in genera terms. If specific goas are outined, the eve of information and the expectations presented shoud be reasonabe, to avoid overwheming the reader. Utimatey, the poicy shoud provide an upbeat message of the improved working environment that wi resut from BMP impementation. Since gaining empoyee support is so NPDES Best Management Practices Manua 2-13

25 CHAPTER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT important, it may be appropriate to soicit empoyee concerns prior to the deveopment of the BMP poicy. These concerns can be highighted as areas which wi be evauated during BMP pan deveopment. Finay, to ensure that a empoyees are aware of the impending BMP pan, the poicy statement shoud be printed on company etterhead (for an officia appearance) and distributed to ah empoyees. Compete distribution can be best ensured if the statement is both deivered to each empoyee and posted in common areas. BMP Poicy Statement - What to Do Utiize meetings and open sessions to soicit empoyee participation in the deveopment of the BMP poicy. Demonstrate that empoyee ideas are wecome by immediate foow-up on suggestions. Discuss possibe impementation opportunities or reasons that impementation is feasibe. Keep the statement cear and concise. Post the BMP poicy statement in key ocations where empoyees congregate so that empoyees wi discuss it. Use the poicy statemento promote an embem/motto that represents the BMP pan and its benefits. Emboss the objectives of the BMP poicy on a paque. BMP Poicy Statement - What Not to Do Do not incude detais of the BMP pan in the poicy statement. The BMP poicy statement shoud not be issued soey by the BMP committee. It shoud be issued by the company NPDES Best Management Practices Manua

26 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT CHAPTER Reease Identification and Assessment What Is Reease Identification and Assessment? Reease identification is the systematic cataoging of areas at a faciity with ongoing or potentia reeases to the environment. A reease assessment is used to determine the impacts on human heath and the environment of any on-going or potentia reeases identified. The identification and assessment process invoves the evauation of both current discharges and potentia discharges. The reease identification and assessment process can provide a focus for the range of BMPs being considered on those activities and areas of a faciity where the risks (considering the potentia for reease and the hazard posed) are the greatest. In some cases, the assessment may be performed based on experience and knowedge of the substances and circumstances invoved. In other cases, more detaied anayses may be necessary to provide the correct focus, and reease assessments may then rey on some of the techniques of risk assessment (e.g., pathway anaysis, toxicity, reative risk). Understanding the dangers of reeases invoves both an understanding of the hazards each potentia poutant poses to human heath and the environment, as we as the probabiity of reease due to the faciity s methods of storage, handing, and/or transportation. Some faciities may identify a number of situations or circumstances representing actua or potentia hazards that shoud a be addressed in some detai through the BMP pan. However, in some instances prioritizing potentia hazards is the most sensibe and cost effective approach. The foowing exampe iustrates the need for BMP prioritization: ACME Concrete is a concrete and suppy faciity with a designated area used to house maintenance vehices and materias as we as to stockpie construction materias and equipment. Among other things, this faciity contains a arge stockpie of buiding sand used to prepare concrete, a vehice maintenance area where oi is drained from company vehices, and a shed where drums of sovents used in ceaning operations are stored. Athough each of the three materias mentioned at the site (sand, used oi, and sovents) can cause environmenta or heath damage uness they are controed, it woud not be feasibe or reasonabe to contro osses of sma amounts of cean buiding sand with the same carefu attention given to the reease of toxic sovents. As this simpistic exampe shows, priorities for BMPs shoud refect a basic understanding of the oss potentia and hazards posed by these potentia osses. A prudent NPDES Best Management Practices Manua 2-15

27 CHAPTER 2 BEST MANAGEMENT PRACTICES PLAN DEVELOPMENT manager of the ACME Concrete maintenance yard coud first imit the potentia for escape of sovents through carefu training and periodic preventative maintenance and inspection of drums and storage faciities, then prevent runoff of used oi to surface waters or groundwater by coecting and recycing used oi, and finay contro major osses of sand through constructions of fiter fences or sediment ponds. How Does Reease Potentia Identification and Assessment Function? Identifying and assessing the risk of poutant reeases for purposes of a BMP pan can best be accompished in accordance with a five-step procedure: Reviewing existing materias and pans, as a source of information, to ensure consistency, and to eiminate dupication Characterizing actua and potentia poutant sources that might be subject to reease Evauating potentia poutants based on the hazards they present to human heath and the environment Identifying pathways through which poutants identified at the site might reach environmenta and human receptors Prioritizing potentia reeases. Once estabished, these priorities may be used in deveoping a BMP pan that paces the greatest emphasis on the sources with the greatest overa risk to human heath and the environment, considering the ikeihood of reease and the potentia hazards if a reease shoud occur, whie sti impementing ow cost BMPs that might contribute to safety or other worker driven needs. An exampe of the effectiveness of this type of assessment is provided in Exhibit 2-6. An exampe of a reease identification and assessment worksheet is provided in Appendix B. A competed version is aso provided to demonstrate how this worksheet can assist faciities in data compiation NPDES Best Management Practices Manua