FACILITY ENVIRONMENTAL COMPLIANCE

Transcription

1 FACILITY ENVIRONMENTAL COMPLIANCE 2014 TxDOT Environmental Conference 2014 TxDOT Environmental Conference 2014 TxDOT Environmental Conference

2 Table of Contents 1 Introduction 1 2 Facility Environmental Compliance Areas 3 3 Risk of Compliance Inspection by TCEQ or EPA 4 4 Compliance Program Overview TxDOT Facility Compliance Surveys TxDOT Environmental Conference 2

3 Facility Environmental Compliance Environmental compliance is not always associated with transportation projects. TxDOT operates roughly one maintenance section per county in addition to 25 district facilities and several other offices. Many day-to-day operations require compliance with various environmental regulations. Presentation will cover: Common compliance issues associated with facility operations. High risk operations. Facility operations to monitor. Compliance survey program TxDOT Environmental Conference 3

4 Facility Compliance Areas Petroleum Storage Tank Management. Wastewater Management. Spill Prevention Control and Countermeasure Planning. Waste Management. Used Oil and Oil Filter Management. Used Antifreeze Management. Used Lead Acid Battery Management. Scrap Tire Management TxDOT Environmental Conference 4

5 Risk of Compliance Inspection by TCEQ or EPA Higher Risk Program Area Petroleum Storage Tank Management. Wastewater Management. Spill Prevention Control and Countermeasure Planning. Waste Management. Used Oil and Oil Filter Management. Scrap Tire Management. Used Lead Acid Battery Management. Used Antifreeze Management. Lower risk only if utilizing good housekeeping practices otherwise risk increases. Lower Risk 2014 TxDOT Environmental Conference 5

6 Petroleum Storage Tank (PST) Management Highest compliance risk operation. PST operations include: Underground Storage Tanks (USTs). Above Ground Storage Tanks (ASTs) TxDOT Environmental Conference 6

7 Petroleum Storage Tank Management USTs much higher compliance risk than ASTs. TCEQ will inspect UST facilities once every three years. TxDOT averages about three to six UST enforcement actions a year. UST penalty typically range from $4,000 to $6,000. Penalty paid by the district. Typical UST problems cited: Missing or incomplete UST inventory control records for release detection. No proof of tightness testing for UST piping TxDOT Environmental Conference 7

8 Petroleum Storage Tank Management What you need to know: Trained staff onsite? Complete inventory control records? What type UST systems do you have? Pressure system or suction system? Steel tank or fiberglass tanks? UST System type determine equipment inspection and record keeping requirements TxDOT Environmental Conference 8

9 Wastewater Management Historically a costly problem for TxDOT. We have better management practices today. Issue is about controlling non-stormwater runoff from facility. Compliance with MS4 permit for applicable areas What to monitor: Equipment washing runoff. Runoff from salt stockpiles and winter mix stockpiles TxDOT Environmental Conference 9

10 Spill Prevention Control and Countermeasure EPA SPCC program provides requirements for oil spill prevention, preparedness, and response to prevent oil discharges to waters and adjoining shorelines. Triggers: Aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons. Emulsion tank capacity is what typically requires a TxDOT facility to comply with requirements TxDOT Environmental Conference 10

11 Spill Prevention Control and Countermeasure Possibility EPA will inspect facility. What you need to know: Familiarize yourself with your SPCC plans. Train applicable staff annually. Conduct monthly inspections. Monitor emulsion tank operations TxDOT Environmental Conference 11

12 Waste Management & Recycling Waste Management & Recycling Programs at the districts include: Used Oil and Oil Filter Management. Used Antifreeze Management. Used Lead Acid Battery Management. Scrap Tire Management. Typically TxDOT has a vendor contracted to remove waste or recycle materials TxDOT Environmental Conference 12

13 Things to consider: Waste Management & Recycling Do you monitor recycling and waste contractors to ensure they are following the contract terms and conditions. Complaints from neighbors are what usually trigger unscheduled TCEQ inspections. Good Housekeeping is the best defense against unwanted inspections. Walk the yards periodically to see how things look TxDOT Environmental Conference 13

14 TxDOT Facility Survey Program Surveys conducted of selected TxDOT facilities and operations. Surveys conducted for the purpose of assessing compliance with various environmental regulations associated with facility operations TxDOT Environmental Conference 14

15 Facility Surveys Are a Valuable Compliance Tool Verify the effectiveness of District environmental compliance programs. Provide feedback that will improve TxDOT Survey typically is an overview of many programs. Not an in-depth review. May single out one program area and conduct an in-depth review TxDOT Environmental Conference 15

16 Survey a district approximately every 18 months to 24 months. Travel budget, staffing and project work load determine schedule. May only include a representative sampling of District facilities. TxDOT s MS4 Statewide permit will require facility surveys and will specify a frequency. Survey Frequency 2014 TxDOT Environmental Conference 16

17 Program Areas Surveyed Waste Management. Used Oil and Oil Filter Management. Used Antifreeze Management. Used Lead Acid Battery Management. Scrap Tire Management TxDOT Environmental Conference 17

18 Program Areas Surveyed (continued) General House Keeping. Equipment Washing Wastewater Management. Spill Prevention Control and Countermeasure Planning. Petroleum Storage Tank Management TxDOT Environmental Conference 18

19 An environmental survey checklist is used to conduct each facility survey. Survey takes approximately two hours per facility. Deficiencies noted during the survey are indicated on the checklist. Specific regulatory citations and recommended actions for each deficiency are included on the checklist. Survey Procedures 2014 TxDOT Environmental Conference

20 Survey Procedures District: BMP = Recommended Best Management Practice = Required By State or Federal Rule Category Area Reviewed NA Yes No Action Standard Reference Is there a designated used oil and used oil filter drum/tank? Used oil must be stored in a dedicated tank or drum. The container must be labeled Used Oil 40 CFR Used USED OIL. Oil Storage Used Oil Are containers covered/lids fastened and in good conditionl? Keep lids and covers closed when used oil tank is not being filled. 40 CFR Used Oil Rules 40 CFR Used Oil Storage Construct a secondary containment berm equipped with a drain pipe and lockable 40 CFR Oil Used Oil Is secondary containment tank in place for storage area? BMP or valve. Secondary containment is required if the facility has a SPCC plan and the Pollution Prevention Used Oil Storage container capacity is 55 gallons or greater. 30 TAC Spill Prevention and Control Used Oil Are the used oil collection and storage areas generally spillfree? BMP Handle used oil in a manner so that spills are minimized. Spilled oil leads to 30 TAC Used Oil Rules Texas Water Code polluted storm water discharge. Section Unauthorized discharge prohibited Oil jugs and containers should be emptied by normal mechanical means. Emptied Guidance Manual - Are empty oil and grease containers stored/disposed of BMP containers can be collected for recycling, if this service is available, or may be properly? disposed of into the dumpster. Used Oil House Keeping - Disposing of Containers Used Oil Used Oil Used Oil Used Oil Used Oil Used Oil TxDOT Facility Environmental Compliance Checklist Maintenance Section Checklist Facility: Does the district maintain records indicating that the used oil transporter is a TCEQ/EPA registered transporter (Not necessary if self transporting one 55 gallon drum or less)? Does the facility prevent the mixture of other waste fluids with the used oil? When internally transporting used oil, does the facility ensure it transports less than one 55 gallon drum of used oil at any time? If the facility is required to maintain a SPCC plan, is the facility's used oil storage tank(s) or storage drums included in the SPCC plan. Is the used oil storage tanks/ containers in good condition (no severe rusting, apparent structural defects or deterioration) and not leaking. Are the used oil storage tanks/containers and any associated fill pipes used to transfer used oil to the storage tank/container clearly labeled with the words "Used Oil" BMP Used oil generators must use only transporters that have obtained an EPA identification number for off-site shipments of used oil. Used Oil Mixed with Fuels: Mixtures of used oil with fuel or fuel products are subject to regulation as used oil under 40 CFR 279. Used Oil Mixed with Hazardous Waste: While certain mixtures of hazardous waste with used oil are allowed, such mixtures should not be routinely allowed. Unless the mixture rules are strictly followed, there is a high potential that the mixture will be classified as hazardous waste once mixed. If hazardous waste is routinely mixed with the used oil, the facility should have sufficient documentation to support that the mixture is allowed to be managed as used oil and not hazardous waste. Used oil generators may self transport up to 55 gallons of used oil to a licensed or permitted collection center or to an aggregation collection point that belongs to TxDOT. Used oil generators are subject to all applicable SPCC requirements included in 40 CFR part 112. Containers and above ground tanks used to store used oil must be in good condition (no severe rusting, apparent structural defects or deterioration) and not leaking (no visible leaks). Used oil storage tanks/containers and any associated fill pipes used to transfer used oil to the storage tank/container must be clearly labeled with the words "Used Oil" 40 CFR CFR (b) & (d) 40 CFR CFR CFR (b)(1),(2) 40 CFR (c)(1)(2) Used Oil Filters Does the facility store six or fewer 55 gallon drums of filters at any one time? Facilities may not store used oil filter that in the aggregate have a volume greater than six 55 gallons drums unless the facility is a registered used oil storage facility. TAC (a) & (b)(1) Used Oil Filters Does the district maintain copies the bills of lading for the transported used filters for a period of three years? Facilities shipping used oil filters off-site must maintain a copy of the bills of lading for a period of at least three years after the date the filters were transported off-site. TAC (a) & (b) Used Oil Filters Does the district maintain records indicating that the used oil filter transporter is a TCEQ/EPA registered transporter (Not necessary if facility is self transporting one 55 gallon drum or less)? A transporter, storage facility, or processor may not store, process, recycle or dispose of used oil filters unless they are registered with the TCEQ. TAC TxDOT Environmental Conference 20

21 Specific facility issues are listed in a table describing the findings and the recommended corrective actions or standards. Survey Findings Recommended standards are usually a direct reference to the state or federal regulatory requirement. When a federal or state regulatory standard is not referenced, a Best Management Practice (BMP) is recommended TxDOT Environmental Conference 21

22 Facility Environmental Compliance Survey Findings Facility: Terlingua Sub-Section Category Area Reviewed No Action Standard Reference House Keeping House Keeping SPCC Are storage containers labeled, covered with secured lids, and in good condition? x BMP Comment Section House Keeping: Does the written plan and site map accurately reflect the operations and physical layout at this facility? x x Instruct facility personnel to protect waste or product containers from rainwater accumulation and accidental spillage (overfilling) by keeping containers covered with proper lids when not in use. Label each tank and storage container with contents. Brown drum labeled as trash needs to be properly labeled or disposed. The written plan is a primary component of the SPCC regulation. Review the site plan for accuracy and revise as needed when changes in facility layout or operations change. BMP & Guidance Manual - House Keeping - Container Management 40 CFR 112.7(e) Guidelines for Plan Preparation and Implementation SPCC Are tank pump starter controls locked in the "Off" position when not in use or located in a site accessible to only to authorized personnel? x The starter control on all oil pumps must be locked in the "Off" position or located in a site accessible only to authorized personnel when the pumps are in the non-operating or stand-by status. 40 CFR 112.7(e)(9)(iii) - Security SPCC Does the facility conduct and document the monthly SPCC inspections as required? x Monthly inspections are required as per the facility's SPCC plan. Record the inspections using the checklists in Appendix B of the plan. 40 CFR 112.7(e)(8) - Facility Inspections x SPCC Comment Section SPCC: SPCC Plan not found at facility (reviewed copy located in ENV office). Need to maintain a copy of the plan onsite. Inspection records look good, but need to add used oil tank to the inspections. Need to install lock on emulsion tank valve (it is reportedly normally locked, but was not during inspection). Fuel trailer was not being stored in containment at the time of the inspection. Plan needs to be updated to reflect changing gasoline tank to diesel and new facility supervisor TxDOT Environmental Conference 22

23 Requested District Actions Districts implement corrective actions in accordance with the associated standard described in the report. District completes a Response Report documenting the corrective action measures taken to address deficiencies TxDOT Environmental Conference 23

24 Facility Environmental Compliance District Response Report Requested District Actions Facility: Alpine Maintenance Category Area Reviewed Action District's Corrective Action Used Oil Are the used oil collection and storage areas generally spill-free? BMP Used Oil Used Oil Filters House Keeping SPCC Does the facility prevent the mixture of other waste fluids with the used oil? Is oil drained from the used oil filters before storage? Are storage containers labeled, covered with secured lids, and in good condition? Does the written plan and site map accurately reflect the operations and physical layout at this facility? BMP BMP SPCC Are tank pump starter controls locked in the "Off" position when not in use or located in a site accessible to only to authorized personnel? 2014 TxDOT Environmental Conference 24