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Rain, Stormwater and Company Regulatory Compliance

Posted on Thu, Jul 27, 2017

According to the National Climate Assessment’s 2014 report,  “Heavy downpours are increasing nationally.”1 That means, when it rains, it often pours. The study revealed that rain intensity in the Southwest has increased nearly 30 percent in recent decades. However, intense rain is not limited to specific areas of the country. The National Centers for Environmental Information, part of the National Oceanic and Atmospheric Administration, noted that between October 2016 and March 2017, California averaged 30.75 inches of precipitation, the second-highest average since such records began being kept in 1895.

Companies need to take notice and ensure they have compliant stormwater pollution prevention plans as required by the Environmental Protection Agency, and response plans that address responses to localized flooding.

The purpose of a Stormwater Pollution Prevention Plan (SWPPP) is to identify potential stormwater pollution sources and reduce the potential for pollutants to reach nearby waterways. The EPA issues “General Permits” for stormwater discharges associated with industrial activity under the National Pollutant Discharge Elimination System (NPDES) program (as defined in 40 CFR 122.21 and 40 CFR 122.26). Establishing procedures and controls is necessary to accomplish the following SWPPP objectives.

  • Identify pollutants that may come in contact with stormwater.
  • Establish measures to prevent pollutants from coming in contact with stormwater.
  • Establish controls to reduce or eliminate the potential for contaminated storm water being released to the environment.

Runoff that contacts industrial materials can transport pollutants into nearby water sources. When companies are not in compliance with NPDES regulations, they may be assessed fines.

For example, the Ohio Environmental Protection Agency ordered a company building a natural gas distribution pipeline to pay $431,000 for water and air pollution violations at various locations across the state. Over the course of three months, Ohio officials revealed that 18 incidents including mud spills from drilling, stormwater pollution and open burning at construction sites have been reported. The company was ordered to submit plans to address potential future releases and restore impacted wetlands which stretch from Washington County in southeastern Ohio to Defiance County in the northwest.

rain runoff.jpeg

An SWPPP and required site evaluations should be incorporated, as necessary, into a company’s enterprise-wide emergency management program. Completed site compliance evaluation checklists must be retained for a period of one year after the expiration of the General Permit.

Ensuring regulatory compliance, preparedness and employee safety requires a fundamental emergency management program. With the intensity of rainfall rising, your emergency management program should be sure to plan for extreme weather scenarios with effective and realistic response plans. Below are preparedness t concepts to guide your flood emergency response planning:

  1. Assess the flood risk potential in your area. Be aware of stream, ditches, drainage areas, and other low-lying areas on the property.
  2. Map facility and identify multiple access and egress routes.
  3. Familiarize staff with the evacuation plan and alternate routes.
  4. Ensure important documents and server(s) are not stored in basement or ground level, and review backup procedures.
  5. Update employee contact lists with alternate contact information in the event an evacuation is necessary.
  6. If evacuation is necessary, assign trained personnel to secure the premises and equipment (such as sandbagging and/or extending regulator vents and relief stacks above the level of anticipated flooding, as appropriate.).
  7. Perform continuous monitoring of the flood through various media outlets and weather tracking.
  8. Unplug all electrical devices.
  9. If flooding is probable, discuss shutting off high voltage power and natural gas lines with energy providers.
  10. Maintain hazards awareness regarding, but not limited to:
    • Structural damage
    • Downed power lines
    • Leaking natural gas, water, and sewer lines
    • Poisonous snakes and other wildlife sheltering in structures, vehicles, and furniture
    • Direct contact with flood water, mud, and animal carcasses
  11. Deploy personnel so that they will be in a position to take emergency actions, such as shutdown, isolation, or containment in the event of an emergency.
  12. Identify, contract, and communicate with water damage specialist(s).
  13. Ensure cleanup equipment is available, adequate, and ample. If clean up will be done by employees, Personal Protective Equipment (PPE) may be required. OSHA requires Personal Protective Equipment (PPE) for cleanup operations if the water source is contaminated with sewage, chemicals, or other biological pollutants.
  14. Consider obtaining portable pumps and hoses from local suppliers.
  15. If applicable, determine if flooding can expose or undermine pipelines as a result of erosion or scouring.
  16. If applicable, coordinate with emergency and spill responders on pipeline location(s) and condition, and provide maps and other relevant information to them.
  17. If applicable, advise the State Pipeline Safety Office (for intrastate lines), or RSPA's Regional Pipeline Safety Office (interstate lines) prior to returning pipelines to service, on increasing the operating pressure, or otherwise changing the operating status of the line.
  18. Conduct a post-incident review and identify mitigation opportunities to prevent future flooding impacts.

Source

1 Renault, Marion. The Columbus Dispatch. 9 May 2017. http://www.cantonrep.com/news/20170509/ohio-epa-fines-rover-pipeline-contractor-430000. 14 July 2017.
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Tags: SWPPP