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SWPP Marta V2 (Armour)

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Transcript of SWPP Marta V2 (Armour)

DEPARTMENT OF SAFETY AND QUALITY ASSURANCE
ARMOUR YARD RAIL MAINTENANCE FACILITY
STORM WATER POLLUTION PREVENTION & EMERGENCY RESPONSE TRAINING
To meet requirements of Regulatory Programs*










To make everyone aware of MARTA’s responsibilities during environmental emergencies.

To conform to Armour Yard’s Environmental Management System (EMS).
National Pollutant Discharge Elimination System (NPDES) General Permit.

Oil Storage and Hazardous Waste (40 Code of Federal Regulations [CFR] 112, 40 CFR 265 Subpart D, Georgia Environmental Protection Division [GAEPD] Rule 391-3-11).

*Many requirements for regulatory programs overlap significantly
PURPOSE OF THIS TRAINING
This training program is intended to increase the awareness so that MARTA employees understand the MARTA response management system and the essential steps necessary to initiate, conduct, and terminate an emergency response action.

PURPOSE
SPILL RESPONSE LEVELS
LEVEL I
LEVEL II
LEVEL III
An incident, which can be controlled, cleaned up, and disposed of by the facility personnel. The incident is confined to a small area. The incident has no environmental impact. Only evacuation of the immediate area is required.
An incident beyond the facility’s capabilities involving a greater hazard or larger area that could be a potential threat to life or property and that may require a limited evacuation of the surrounding area. There has been an environmental impact.

An incident involving a severe hazard or large area that poses an extreme threat to life and/or property and will probably require a large-scale evacuation; or an incident requiring the expertise or resources of county, state, federal, or private agencies/organizations.
1
2
3
MARTA has identified three levels of spill response.

The spill response level will determine the notification procedures and spill response actions needed.
What Response
Level is needed
I
III
Spill observed by facility personnel
Safeguard or evacuate immediate spill area
Notify supervisor/
Facility Spill Coordinator

Institute clean up
and disposal
Complete reports

Marta Pd (4911)
Incident Commander
Notify
Evacuate
Non-essential Personnel
IC Responds to the Scene
Contain spill and mitigate source if it can be done safely
Implement spill prevention and response plan

Marta Pd (4911)
Incident Commander
Notify
Incident Commander makes required notificaitons
MARTA PD
evacuates the area
Implement emergency
management plan
II
LEVEL I:
An incident, which can be controlled, cleaned up, and disposed of by the facility personnel. The incident is confined to a small area. The incident has no environmental impact. Only evacuation of the immediate area is required.

LEVEL II:
An incident beyond the facility’s capabilities involving a greater hazard or larger area that could be a potential threat to life or property and that may require a limited evacuation of the surrounding area. There has been an environmental impact.

LEVEL III:
An incident involving a severe hazard or large area that poses an extreme threat to life and/or property and will probably require a large-scale evacuation; or an incident requiring the expertise or resources of county, state, federal, or private agencies/organizations.

NOTE:
Primary responsibility
for most employees
is to notify the FSC
or Supervisor!
SPILL RESPONSE LEVELS
SPILL RESPONSE PROCEDURES
Notify Supervisor or Facility Spill Coordinator (FSC):
Give information on nature of spill, location, material spilled, amount.
Stop the spill

Contain the spill

Cleanup the spill*
Personnel Actions in the event of a spill:
* Put all used spill response material into empty drum(s); DSQA will coordinate disposal of spill materials
SPILL RESPONSE PROCEDURES
WHO TO CALL
Supervisor:
Specific Facility Spill Coordinator depends on spill location
Facility Spill Coordinators:
Gary Barrett,
Rail Car Heavy Maintenance


Calvin Sims,
Rail Car Light Maintenance


Warren Taylor,
Inspection


Ethel Williams
, Rail Car Appearance

John Bergeron,
Rail Stores


Paul Shoemaker,
B&SE – North Line
Foreman’s Office
(404) 848-3158

(404) 848-3158

(404) 848-3825

(404) 848-3248

(404) 848-3919

(404) 848-3970
(404) 848-3158
NOTE:
Work the system until you reach someone!
Review necessary steps for personnel to take in case of environmental emergencies at any MARTA maintenance facility.

Review specific information for the Armour Yard subject to State and Federal requirements.

Provides needed contact information in time of emergencies for all
types of spills.

Makes the various spill plans easier to understand and provides guidance on the correct plan(s) to be implemented for a particular situation.

Describes notification procedures and the appropriate plans to be used depending on the size (Response Levels I, II, or III) of the spill.

BACKGROUND
WHO TO CALL
In the event of a chemical spill into the industrial wastewater treatment facility (IWTP), the FSC must immediately notify
Paul Shoemaker, B&SE at (404) 848-3970
MARTA Incident Commanders:
Jeff Kowalski (DSQA)

Rail System Control Center

Bus Communications Center

MARTA Police Communications
(404) 848-6513

(404) 848-3400

(404) 848-4368

(404) 848-4911

NOTE:
Work the system until you reach someone!
SPILL KIT LOCATIONS
ARMOUR YARD
MAINTENANCE & OVERHAUL FACILITY
AREA TREATMENT BUILDING & CLEANING PLATFORM
Contact Jeff Kowalski
QUESTIONS/COMMENTS?
Acting Manager of System Safety Programs, DSQA
(404) 848-6513 (Office)

(404) 436-8993 (Cell)
SPILL RESPONSE
MODULE 1
To meet requirements of Regulatory Programs*












To make everyone aware of MARTA’s responsibilities during environmental emergencies.

To conform to Armour Yard’s Environmental Management System (EMS).
National Pollutant Discharge Elimination System (NPDES) General Permit.

Oil Storage and Hazardous Waste (40 Code of Federal Regulations [CFR] 112, 40 CFR 262, 40 CFR 265 Subpart D, Georgia Environmental Protection Division [GAEPD] Rule 391-3-11).

*Many requirements for regulatory programs overlap significantly
PURPOSE OF THIS TRAINING
The Spill Prevention, Control, and Countermeasures (SPCC) Plan has been developed to address the storage and management of petroleum products at MARTA’s maintenance facilities


PURPOSE OF THE SPCC PLAN
Fulfill the requirements of 40 CFR Part 112:
SPCC Plan required if aboveground oil storage volume exceeds 1,320 gallons for all containers that hold 55 gallons or more


Identify and evaluate potential spill sources of oil and hazardous material


Outline procedures designed to prevent the discharge of oil, or hazardous substances into the environment and to respond to releases

BACKGROUND
Spill Prevention & Response
MODULE 2
Spill Prevention – Oil/Fuel Storage Areas at Armour Yard
Running Repair Shop

Truck Shop (Back Shop)

Petroleum, Oils, and Lubricants (POL) Building

Oil/Water Separators

Aboveground Storage Tanks (ASTs)

Loading/Unloading Operations/Piping

Transformers (not MARTA-owned)

Train Washing Drag-out

Miscellaneous Equipment Storage

Industrial Wastewater Treatment Plant (IWTP)

Vehicle Fueling Island (Currently Inactive)
REPORTABLE SPILLS DEFINED
A discharge of harmful quantities of oil as defined in 40 CFR 110

A discharge of oil that is reportable under FWPCA*; that is, any discharge of oil that:
Violates water quality standards

Causes a sheen or discoloration on the water or adjoining shores, or

Causes a sludge or emulsion to be deposited beneath the water or on the adjoining shore.
RECENT REPORTABLE SPILLS AT ARMOUR YARD
One reportable spill occurred
on December 13, 2005:
16-gallon drum of gear box oil was not secured to pallet when transferred from POL Building to Maintenance/Overhaul Building.

The drum fell off forklift, dislodging the top of the drum and allowing the drum contents to spill into a storm drain leading to Peachtree Creek.

MARTA personnel used absorbents to contain some of the oil on the pavement and in the storm sewer line; a small amount of oil was discharged into Peachtree Creek. An emergency response contractor cleaned up the spill.
Previous Spills at Other MARTA Facilities
Brady Diesel Spill to Sanitary Sewer (Aug 2008)
Fueling vendor filled oil/water separator with 7,000 gallons diesel instead of diesel UST; all OWSs then labeled “DO NOT FILL”; fueling SOPs reviewed at Brady to prevent re-occurrence.
Hamilton Battery Acid Spill (October 2013)
Pallet of batteries dropped at loading dock and battery acid entered detention basin from storm drain. MARTA DSQA applied neutralizing acid absorbent and cleaned up spill, preventing acid from discharging to creek.

SPILL RESPONSE PROCEDURES
WHO TO CALL
Supervisor:
Facility Spill Coordinators: FSC is specific to area at Armour Yard where a spill occurs

Jeff Kowalski, DSQA:

Rail System Control Center

Bus Communications Center:

MARTA Police Communications:
Foreman’s Office
(404) 848-6513

(404) 848-3158

(404) 848-4368

(404) 848-4911
(404) 848-3158
NOTE:
Work the system until you reach someone!
B&SE North line (in case of chemical spill to IWTP)
MARTA Incident Commanders:
Contact Supervisor or Facility Spill Coordinator in event of a spill.
Specific Facility Spill Coordinator (FSC) depends on spill location; contact names/numbers are included in the SPCC Plan, SWPPP, and on Spill Posters, in addition to SWPP&ER Module 1.
The following slides are a summary of general initial
response actions that may be appropriate for various spill events.

The response actions are to be undertaken
ONLY
if it is
SAFE
to do so.
Initial Response Actions
SPILL RESPONSE PROCEDURES
INITIAL RESPONSE ACTIONS
Explosion or Fire
ONLY IF IT IS SAFE TO DO SO, immediately notify the MARTA PD to dispatch local Fire Department personnel. If notification cannot be made safely in the area, EVACUATE, and then notify.

The local Fire Department will bring the incident under control with the help of other emergency response agencies as needed
Appropriately trained personnel will secure the sources of discharge by appropriate means and deploy containment and control equipment to contain the spilled material.

The Incident Commander will implement other response activities as needed.

Failure of Transfer Equipment or Hoses
Shut down transfer pump
Close valves and isolate oil flow
Begin spill notification.
Under the direction of the Facility Spill Coordinator, Supervisor, or Incident Commander, begin the spill response procedures

Notify Facility Spill Coordinator or Supervisor
Tank Overfill
SPILL RESPONSE PROCEDURES
INITIAL RESPONSE ACTIONS
Shut down the transfer pump and close valves

Close containment valves

Begin spill notification


Under the direction of the Facility Spill Coordinator, Supervisor, or Incident Commander, begin the spill response procedures


Notify Facility Spill Coordinator or Supervisor
Tank Failure, Piping Leak, or Rupture
If the leak or rupture occurs during transfer, shut down the pump, halting the transfer of fuel or oil.

If safe, close the valves and isolate the oil flow. (If valves in immediate vicinity of the source cannot be closed safely, close valves from remote safe location.)

Begin spill notification (notify Facility Spill Coordinator or Supervisor).

Appropriately trained personnel will locate the source of discharge and secure the leak by appropriate means, such as by the application of a plug or patch.

Appropriately trained personnel, under the guidance of the Facility Spill Coordinator or Incident Commander, will deploy containment and control equipment and material (drain blocks, temporary dikes, or additional booms) to contain the spilled
material.

Authorized site personnel or contractors (appropriately trained) will support cleanup efforts as directed by the Incident Commander.

Spill Equipment Available
White colored absorbent booms and pads (oil only)

Gray colored absorbent booms and pads (universal)

Buckets

Gloves

Shovels

Disposable Tyvek suits

Neutralizing absorbent, safety gloves/goggles/boots

Spill Prevention & Response
2
4
INDUSTRIAL WASTE WATER TREATMENT & RECYCLING
1
SPILL RESPONSE
3
STORM
WATER POLLUTION PREVENTION

DEPARTMENT OF SAFETY AND QUALITY ASSURANCE
STORM WATER POLLUTION PREVENTION & EMERGENCY RESPONSE TRAINING
ARMOUR YARD RAIL MAINTENANCE FACILITY
*Put all used spill response material in empty drums; DSQA will coordinate disposal
SPILL KIT LOCATIONS
Maintenance and Overhaul Facility:
Running Repair Shop
Truck Shop
Compressor Room (AST1 and AST2)/ Loading Dock Area
Industrial Wastewater Treatment Plant (IWTP)

Train Wash Facility

POL Building

Storeroom
ALWAYS TRY TO PREVENT POTENTIAL SPILL HAZARDS!
DO
NOT
LET THIS SITUATION HAPPEN!
REMEMBER
Contact Jeff Kowalski
QUESTIONS/COMMENTS?
Acting Manager of System Safety Programs, DSQA
(404) 848-6513 (Office)

(404) 436-8993 (Cell)
Storm Water Pollution Prevention
MODULE 3
To meet requirements of Regulatory Programs*







To make everyone aware of MARTA’s responsibilities when discharging storm water

To conform to Armour Yard’s Environmental Management System (EMS)

Industrial Storm Water (GAEPD Rule 391-3-6-.16)

NPDES General Permit

*Many requirements for regulatory programs overlap significantly
PURPOSE OF THIS TRAINING
The Armour Yard facility discharges storm water associated with industrial activity directly to Peachtree Creek

Under both State and Federal regulations, this activity requires a Storm Water Pollution Prevention Plan (SWPPP)

PURPOSE OF THE SWPPP

Identify potential sources of storm water pollution


Establish and implement practices and structural controls (when necessary) to eliminate, minimize, and/or control the potential for contamination of storm water


Establish a Pollution Prevention Team (PPT), which is responsible for implementation, maintenance, and revision of the SWPPP
Makes the various spill plans easier to understand and provides guidance on the correct plan(s) to be implemented for a particular situation.

BACKGROUND
Storm water from Armour Yard discharges directly to Peachtree Creek

Sanitary wastewater is discharged to the City of Atlanta (CoA) Sanitary Sewer system, which ultimately flows to the R.M. Clayton Water Reclamation Center

Industrial wastewater discharged to IWTP and treated/returned for reuse or discharged to CoA with sanitary wastewater

Storm and Sanitary Sewer Discharges
Prohibited Discharges To Storm Sewer
Virtually all non-storm water discharges.

Any discharge that affects water quality.

Any discharge that causes a film, sheen, or discoloration of the water or water surface.

Any discharge that causes a sludge or emulsion to be deposited beneath the surface of the water.

Fuel Spills from Refueling Depot with Diesel Fuel AST

Exterior Train Washing Drag-out

Outdoor Storage Cage

Used Oil AST, Oil/Water Separator, Grit Chamber, and

Stormceptor Pump Out Areas

Battery Storage Areas

Industrial Wastewater Treatment Plant (IWTP)

Rail Car Maintenance Activities

Traction Power Substation (TPSS) Courtyard

Sources that
must be prevented
and controlled
Storm Water Pollutant Sources
Annual Comprehensive Site Inspection (ACSI)
Best Management Practices (BMPs) – Good Housekeeping
Store containers neatly and orderly

Keep containers sealed and closed, when not in use

Keep containers out of employee walkways

Keep containers secured to pallets during transfer activities by fork lift

Check that labels are present on all storage vessels

Promptly clean up spills, minimize accumulation

Regularly pick up/dispose of garbage/rubbish

Store material to minimize storm water contact

Indoors or within secondary containment and covered, if outdoors

Discuss with staff to solicit ideas regarding possible good housekeeping practices

Follow correct procedures during material handling and transfer operations
Process Flow for Grit Chambers & Oil/Water Separators
For heavy sediment removal via gravity, wastewater is routed first through GCs before it is sent to the OWSs

OWSs allow small oil droplets to accumulate (coalescence) and facilitate gravity separation of the lighter-weight oil from the wastewater

Some MARTA OWSs contain coalescing media (or filters) to assist process

Treated water (heavier than the floating free-phase oil) is removed though an underflow effluent drain under proper operating conditions

Avoid hosing dirt, debris, oil, or grease into drains

Use dry cleaning methods (such as dry sweep and absorbents)

Follow washing & fueling SOPs at applicable areas

OWSs are safeguards used conjunction with good
pollution prevention & housekeeping practices

OWSs are not a license for disposal

Restrict wet washing activities near OWSs

Avoid any slug releases of fuel into drains leading to OWS
Oil/Water Separator Management Practices
Spills can overload OWSs and adversely impact water systems located downstream from the effluent discharge.
The grit chamber and OWS systems are
NOT designed to remove the following:

Prohibited Material
Coolants

Physical/chemical emulsifications of oil

Detergents

Solvents

Oils with specific gravity above 0.95

Volatile organic compounds

Wastewater with oil concentrations above 1,000 parts per million
Avoid large slug releases of oil directly into upstream inlet collection drains

Sediment and Erosion Control
Significant concern in protecting surface waters

Grass / vegetation planted in open areas, and natural vegetation preserved where possible.

Silt fences and barriers used when appropriate around excavation or
construction areas
Methods employed as-needed to prevent soil erosion and sedimentation:
Management of Runoff
Majority of storm water flows into storm sewer lines, through Stormceptor® units, and discharges to Peachtree Creek

Stormceptor® units designed to remove sediment and oil from storm water

BMPs and minimization of storm water pollutant sources upgradient of the storm sewer lines prevent storm water pollution to Peachtree Creek

Regular landscape maintenance at Armour Yard allows easier access for monitoring of storm water discharges

Facility surrounded by chain-link fence.

Electronically controlled access gates to facility from Plasamour Drive and Armour Circle. Outside visitors are required to check in with facility contact to control unauthorized access.

Electronic badges to access buildings.

Security
BMPs – Aboveground Storage of
Petroleum Products

ASTs are double-walled or have secondary containment for possible spills

Visual monitoring during transfer operations

Tanks, valves, hoses, pumps, piping, and safety devices properly maintained and kept in good operating condition

Commercial carriers follow correct procedures when loading/unloading product

All used oil containers marked “USED OIL”

All empty containers marked “EMPTY”

Keep non-empty containers closed and sealed when not in use
DO
NOT

LET THIS SITUATION HAPPEN!
REMEMBER
ALWAYS TRY TO PREVENT POTENTIAL STORM WATER POLLUTANT SOURCES!
Contact Jeff Kowalski
QUESTIONS/COMMENTS?
Acting Manager of System Safety Programs, DSQA
(404) 848-6513 (Office)

(404) 436-8993 (Cell)
To meet local, state, and federal regulations for industrial wastewater; specifically the City of Atlanta (CoA) Industrial Wastewater Discharge Permit.

To make everyone aware of the Armour Yard industrial wastewater treatment plants’ (IWTPs) purpose and limitations.

To conform to the developing EMS for the Armour Yard facility.

PURPOSE OF THIS TRAINING
Armour Yard IWTPs

Provide treated wastewater that is 100% recyclable



Reduce CoA water and sewer charges to MARTA by treating and recycling some wastewater


Meet local permit discharge requirements for wastewater that is treated and discharged to CoA
Industrial Wastewater Treatment and Recycling
MODULE 4
Where Are The IWTPs?
Armour Yard has
2
IWTPs:
One IWTP dedicated to the train wash

A second IWTP treats wastewater from the Maintenance and Overhaul Facility and from the Cleaner Platform
Maintenance & Overhaul Facility Wastewater Sources
Truck Shop degreasing wastewater

Blowdown facility wastewater

Wastewater discharged to floor drains
Maintenance & Overhaul Facility
Industrial Wastewater Floor Drains
Interior train cleaning wastewater from the Cleaner Platform
Cleaner Platform Wastewater Source
Train Wash Facility Wastewater Source
Wash and rinse wastewater from the Train Wash
Train Wash IWTP Limitations
Wash and rinse water for trains are stored in tanks; upon complete use of water in tanks, IWTP personnel must manually start IWTP system to refill tanks.

Introduction of additional clean water by Armour Yard personnel to the system could create a water imbalance and non-permitted discharge to the CoA.
Train Wash IWTP:
Cleaner Platform and Main Shop IWTP Limitations
Spills of hazardous chemicals and large amounts of any substance (i.e. soap, oil) to the Maintenance and Overhaul Facility drains could result in fouling of the IWTP

Hazardous chemicals should not be discarded through the Cleaner Platform mop drains

Introduction of additional clean water by Armour Yard personnel to the system could create a water imbalance and non-permitted discharge to the CoA


Cleaner Building and Maintenance and Overhaul Facility IWTP:

BE CAREFUL!
Train Wash Best Management Practices (BMPs)


Rail Car Appearance personnel should inform B&SE when peak demands for the Train Wash will happen. This will let IWTP personnel:
Increase their weekly visits to the system
Maintain adequate amounts of wash and rinse water

Do not introduce non-recycled water into the system unless approved in advance by B&SE!

Maintenance and Overhaul Facility and Cleaner Building BMPs
If hazardous chemicals or large amounts of any substance/chemical are spilled in the Maintenance and Overhaul Facility, the following actions should be implemented to prevent fouling of the IWTP system:

Stop the spill

Contain the spill

Cleanup the spill

Notify Supervisor or Facility Spill Coordinator

*Do not introduce non-recycled water into the system unless approved in advance by B&SE!

Foaming in Train Wash
IWTP from Excessive Soap
Spill Notification Procedures
When any spill occurs at the Maintenance / Overhaul Facility, notify your Supervisor and the Facility Spill Coordinator (FSC)

In the event of a chemical spill into the wastewater system, the FSC
must immediately notify:

Paul Shoemaker (404) 848-3970
B&SE North Line
Contact Jeff Kowalski
QUESTIONS/COMMENTS?
Acting Manager of System Safety Programs, DSQA
(404) 848-6513 (Office)

(404) 436-8993 (Cell)
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