Workshop R - Emergency Plans-SPCC SWP3 Contingency · 40 CFR Part 112‐SPCC for Oil ... •Robotic...

Workshop R

Storm Water Pollution Plans (SWP3), Spill Prevention, Control, and Countermeasure (SPCC) and

Hazardous Waste Contingency Plans … How do They Interact?

Tuesday, March 22, 2016 3:30 p.m. to 4:45 p.m.

Biographical Information

Gregory A. Hemker, President EHS Technology Group, LLC

P.O. Box 0187, Miamisburg, Ohio 45343-0187 Office 937.865.3818 or 800.356.9039 Fax: 937.865.3611

[email protected] Mr. Hemker is one of the founders of EHS Technology Group, LLC located in Miamisburg, Ohio. He has over 40 years of experience in environmental engineering and management. Mr. Hemker obtained a Master’s Degree in Environmental Engineering from the University of Cincinnati and is a Certified Hazardous Materials Manager (CHMM). His principle fields of expertise are air pollution, hazardous waste, and hazardous chemical management. He has conducted numerous environmental management training seminars throughout the U.S. and China. In recent years Mr. Hemker has focused on consulting with manufacturing industries to solve problems associated with air pollution, water pollution, hazardous waste, oil and chemical spill prevention, chemical safety, and industrial hygiene. Has lead the development and implementation of Energy management Systems at manufacturing facilities in Ohio and Kentucky. Mr. Hemker is a RAB trained lead auditor and has been developing and implementing ISO 14001, 9001, 50001 and OHSAS 18001 management systems since the adoption of the Standards.

Matthew R. Scroggins, Manager, Environmental Health & Safety StandardAero, 11550 Mosteller Rd., Sharonville, OH 45241

Cell: 513.370.1838 Office:513.618.9588 Fax: 513.587.6600 [email protected]

Mr. Scroggins is currently Manager-Environmental, Health, and Safety at StandardAero- Component Services, LLC, a world class Maintenance, Repair, and Overhaul facility for aircraft engine components, located in Sharonville, Ohio. He has over 8 years of experience in the implementation and management of EHS functions and programs in a manufacturing setting; specifically focusing on hazardous waste management, air pollution, and occupational safety and health. Also, he has lead the effort to implement and become 3rd party registered for both ISO 14001-Environmental Management and OHSAS 18001-Occupational Health and Safety Management Systems at his sites of responsibility. Mr. Scroggins obtained a Master’s Degree in Safety, Security, and Emergency Management from Eastern Kentucky University and is a Certified Safety Professional (CSP).

PRESENTED BY:

GREG HEMKER, CHMMEHS TECHNOLOGY GROUP

&MATTHEW SCROGGINS, CSP

STANDARD AERO

FOR:

MEC 25TH ANNUAL SUSTAINABILITY & EHS SYMPOSIUM

MARCH , 2016

SPCC, SWP3 and Hazardous Waste Contingency Plans‐How do they interact?

40 CFR Part 112‐ SPCC for Oil

40 CFR Part 265 Subpart D‐ Hazardous Waste Contingency‐ note also include 40 CFR Part 265 Subpart C‐Emergency Preparedness

SWP3‐• OEPA – Industrial GP OHR 000005‐Part 5 : SWP3 references USEPA document EPA 833‐B‐09‐002

• IDEM – 327 IAC 15‐6‐7 : known as “Rule 6” for Industrial Storm Water Discharges‐ SWP3

• Kentucky‐ Industrial GP KYR00; USEPA Guidance above

Regulatory Requirements

General Requirements:

SPCC required when the facility has

• 1,320 gallons or more on‐site at any given time in

• 55 gallon or larger containers

• Reviewed and approved by P.E.

Qualified facilities can use a simplified template and no P.E. signature

Qualified facility‐Tier I and II

• Limited releases in last three years

• No individual container > 5,000 gallons

Oil Spill Prevention Countermeasures & Control SPCC

Specific Requirements:

Approved by top management

Cross reference table from requirements to your pages of the SPCC Plan

Discussion of compliance with requirements

Describe the facility layout and plan drawing• Topo, buildings, pavements, drains,

• oil storage, loading/unloading, type and size of containers



Describe the facility layout and plan drawing• Topo, buildings, pavements, drains,

• oil storage, loading/unloading, type and size of containers and oil

• Containment, pipes, valves, etc.

• Preventive measures

• Countermeasures, etc.



Inspections, Tests & Records‐ in plan for last 3 years

Identify responsible personnel

Perform training of responsible personnel

Appoint designated personnel for discharge prevention

Establish security measures



LQGs‐must be written plan

If have SPCC, can be combined as consolidated plan

SQGs‐Must be understood by personnel

CESQGs‐ Not required

Hazardous Waste Contingency Plan

Specific Requirements for LQG:

Written Plan

Describe actions to be taken by personnel to respond to fires, spills and explosions

Describe arrangements with local authorities and contractors; police, fire, hospitals, etc.

List names of emergency coordinators with addresses and phones; one coordinator named as primary coordinator.



List of all emergency equipment; e.g. fire extinguishers, alarms, communication, decontamination, the location and description of each item on the list

Evacuation Plan‐ description, routes and drawings of the facility

List of copies to local authorities



A description of actions that will be taken to correct an emergency; spill clean‐up, disposal of wastes, restore emergency equipment, etc.

Revision plan in the event of rule changes, failure of the prevention plan,

EC‐ after emergency‐must assure compatible of wastes, proper remediation, prevention measures of incident in future


Recommended Requirements for LQG:

Drawings of the entire property and buildings that include:

• Locations of waste management

• Types and amounts of wastes

• Number of containers

• Drainage pathways

• Location of emergency equipment



Must be developed and implemented within 365 days of the effective date of your permit

Must file Rule 6 SWP3 checklist to IDEM

Must be certified by a qualified professional

Qualified professional‐ PE, CHMM, other certified environmental professional, trained and experienced in storm water treatment techniques

SWP3‐ IDEM


Identifies individuals and responsibilities for SW Pollution Prevention Team

Copy of the NOI

Soil Maps with boundaries of property outlined

Area Maps‐ topography, building, receiving waters, wells, etc.

SWP3 Plan‐All States


Graphic representation‐ on‐site drainage, adjacent properties, water bodies, drainage areas, property lines, directions of flow, wells, structures, USTs (historic & current), snow piles, outdoor processing areas, dusty areas, outdoor waste storage, pesticide/herbicide areas, vehicular traffic areas



Narrative description of potential pollutants source areas, storage methods, type and quantity of materials, remedial actions taken, spill history, chemical exposures, etc.



Narrative description of existing and planned management practices;

• Description of existing and historical exposure areas

• Specific control measures

• Written preventive maintenance plan

• Written spill response plan

• Written non‐storm assessment

• Copies of all analytical results

• References to other related plans; e.g SPCC, Contingency


StandardAero Company Overview

FEEL FREE TO DELETE

A World Leading MRO ProviderStandardAero is one of the world’s largest independent providers of MRO services, engine and airframe repair and overhaul, engine component repair, engineering services, interior completions and paint applications. We employ nearly 4,000 team members around the world and generate $1.6B in annual sales.

We serve a diverse array of customers in the business/general aviation, airline, military, helicopter, components, energy, and VIP completions markets.

StandardAero provides a global service network of 13 primary facilities in the U.S., Canada, Europe, Singapore and Australia, plus over 50 sales and field service locations.

StandardAero Component Services’ facility, in Sharonville, covers approximately 240,000 sq ft, employs approximately 475 people, and has numerous process capabilities, including:

StandardAero Component Services Overview

NDT•Fluorescent Penetrant•Magnetic Particle•Ultrasonic•Robotic and Manual Eddy Current•Radiography

Special Processes•Heat Treating•Shot Peening•Furnace Brazing•Automated Waterjet and Wet Blast•Composite and Bonding Repairs•Balancing

Thermal Spray•Plasma•HVOF•Wire-Arc•Flame Spray

Machining•Conventional Mills/Lathes•CNC Mills and Lathes•Vertical Turret Lathes

• Up to 200 inches•Horizontal Boring Machines•ID/OD Grinding

Welding•Gas Tungsten Arc•Automated Dabber•Electron Beam

MAIN OIL USES THROUGHOUT THE FACILITY

Fluorescent Penetrant Inspection

Machine Oils/Coolants• Storage• Reservoirs

Oily wastewater collected in bulk above ground storage tanks for 3rd party disposal.

StandardAero Component Services - Site Layout

MACHINE OIL/COOLANT STORAGE AREA

FLUORESCENT PENETRANT INSPECTION

OILY WASTE STORAGE AREA (TANKS)

• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIALSeptember 19 2013 | QRM2/2013 SNECMA | Company Confidential• SNECMA 2013 APR & 2014QRM [Apr] CONFIDENTIAL Page 23

Hazardous Waste Contingency Plan-List of Emergency Equipment

EQUIPMENT LOCATION CAPABILITY VerificationFirst aid supplies Employee Meeting

RoomGeneral first aid, minor burns, eye wash, bandages

Stocking vendor

First aid supplies Maintenance Door access

General first aid, minor burns, eye wash, bandages

Stocking vendor

First aid supplies QC Lab aisle way General first aid, minor burns, eye wash, bandages

Stocking vendor

First aid supplies Employee break room General first aid, minor burns, eye wash, bandages

Stocking vendor

First aid Grab-N-Go Center N-S aisle AED, first aid supplies EHS Monthly Inspection tag on AED

Portable fire extinguishers Strategically located throughout the facility

Classes ABC, BC, & D placement determined by fire load

Monthly PM maintenance

Silent Knight Fire Alarm Phone room Building evacuation, automatic notification to 911

Building owner annually – rpt to SFD

ESFR sprinkler system 12 fire zones in the building

Static pressure 80+ psi, coverage extended to all structures within the building. Linked to fire alarm system

Building owner annually – rpt to SFD

Telephone system IT server room Phone and intercom Daily useSafety Shower/eye wash Paint booth, Large NDE

line, Rotating Cell, Main NDE, Clean Line, Chemical Storage room, Honeywell, Dabber, Honeycomb

Thorough drenching for chemical exposure, eye flush

Monthly PM maintenance

Eye wash station Met Lab, shipping Eye flush for chemical exposure Monthly PM maintenance

PPE-aprons, gloves, face shields, respirators

Central Stores Chemical exposure Supply chain inventory

5.4.4 Emergency Response ResourcesIn order to respond to various emergency situations at the facility, StandardAero is equipped with the following emergency response equipment:

Tamper Tags for quick verification


Hazardous Waste Contingency Plan-Evacuation Plan

•Headcount completed at accountability areas

•Accountability areas are determined by facility Org Chart

•Employee rosters are stored at accountability area and updated monthly.

•Emergency Coordinators are identified/trained for all shifts


Hazardous Waste Contingency Plan-Implemented due to Process Fire 8/29/2014

• Fire occurred on 2nd shift between 12:45 and 1 a.m. in our Nitric Acid stripping process.

• No injuries occurred as a result of this incident.

• 3 attempts were made by trained employees to extinguish the fire.

• Building evacuation was initiated and Contingency Plan was implemented.

• Main areas of focus were:

• Employee/life safety• Spill/Run off control due to the poly tank breeching and facility fire suppression system activating.• Clean-up• Business Recovery


Resulting Business Implications

•2nd shift on 8/29 lost about 35% of their shift productivity

•Weekend shift lost a significant amount of productivity

•The Nitric Process was destroyed requiring replacement. Also, in the meantime, the parts had to be sourced to outside vendors, which impacted customer and delivery dates.

•Approximately 7,500 of wastewater was managed and shipped offsite on 8/29.

•Hazardous Waste was generated

•Significant Costs associated Emergency Response by 3rd

party contractor

States Web sites:• www.in.gov/idem , www.water.ky.gov, www.epa.ohio.gov/dsw• Look at “Compliance”, “Hazardous waste”, Storm Water & “Guidance”

USEPA Web site:• www.epa.gov• Look at “Hazardous Waste”, “SPCC“, “SWP3”

Public Resources

Any Questions?

THANK YOU

Workshop R - Emergency Plans-SPCC SWP3 Contingency · 40 CFR Part 112‐SPCC for Oil ... •Robotic...

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Transcript of Workshop R - Emergency Plans-SPCC SWP3 Contingency · 40 CFR Part 112‐SPCC for Oil ... •Robotic...