Slug Discharge Control and Spill Containment Policy

PURPOSE AND SCOPE

The County Sanitation Districts of Los Angeles County (Districts) hereby establish this Slug Discharge Control and Spill Containment Policy under regulation 40 CFR 403.8(f)(2)(v) of the Environmental Protection Agency and provisions of sections 406 and 412 of the Districts' Wastewater Ordinance. The general purpose of this policy is to provide guidance to Industrial Users (IUs) to develop and implement plans to prevent the accidental or inappropriate discharge of RESTRICTED materials to the sanitary sewer system. This is to protect public health and safety from hazardous conditions resulting from solvent fumes or the mixing of incompatible materials such as acid and cyanide and slug discharges that may cause collection system or treatment plant problems such as fire or explosion, corrosion, obstruction, interference, pass-through or excessive heat. Additional EPA guidance on spill containment and slug discharge control can be found at www.epa.gov/npdes/pubs/owm021.pdf.

SPILL CONTAINMENT PROGRAM REQUIREMENT

Any Industrial User (IU) with a significant potential to discharge RESTRICTED[2] materials is required to install and maintain an adequate spill containment system.

SLUG DISCHARGE CONTROL PLAN REQUIREMENT

Any Significant Industrial User (SIU) that may batch discharge any wastewater (including that from spill containment areas), treated or otherwise, AND that discharge may potentially cause adverse impacts to the collection system or treatment plant must complete and implement a Slug Discharge Control (SDC) Plan. All SIUs deemed to require a SDC Plan by the Districts must do so in accordance with these guidelines.

GENERAL SPILL CONTAINMENT REQUIREMENTS

All spill containment systems must be approved by the Districts prior to construction. If construction is completed prior to approval, the Districts may require modifications to the system. All systems must conform to the following general requirements:

  • Process, storage, holding, or treatment tanks containing RESTRICTED materials as well as the associated piping, pumps, and other appurtenances must be contained if a spill or leak could enter the sewer. This includes tanks used for short-duration mixing, processing, or storage.

  • All tanks containing incompatible materials such as acid and cyanide must be contained separately if mixing could occur in the event of a spill.
  • The Districts and the County Department of Public Works prohibit floor drains with direct connections to the public sewer in facilities that store toxic or flammable materials. In addition, the County Department of Public Works and the Regional Water Quality Control Board may require containment to prevent spills from entering the groundwater or storm drain systems. More specific information on these spill containment requirements can be obtained by contacting these agencies.

  • The Districts discourage the discharge of rainwater from spill containment areas to the sewerage system. Rainwater that falls directly on spill containment areas should be discharged to the storm drain in accordance with the requirements set by the Regional Water Quality Control Board or the local agency. However, the Districts recognize that there may be situations where discharge to the sewer is the only feasible alternative. When these situations occur, the Districts may accept the controlled discharge of rainwater from spill containment areas to the sewerage system after all other alternatives have been demonstrated to be infeasible. Restrictions may be imposed on wastewater quality, flow rate, and time of discharge to the sewerage system. Proposals for the discharge of rainwater from spill containment areas to the sewerage system must include sufficient documentation to demonstrate that no other alternatives are feasible. Alternatives that must be considered include treatment and discharge to the storm sewer, reuse, on-site storage/evaporation, and roofing of the spill containment area. Additional information can be found in the Districts' Guidelines for the Discharge of Rainwater, Stormwater, Groundwater and Other Water Discharges.

  • The spill containment system must be capable of containing 100 percent of the volume of the largest tank of RESTRICTED material. If a portion of the containment volume is occupied by other tanks, equipment, and/or standing liquids, this displaced volume must be subtracted from the total spill containment volume. Spill containment systems exposed to rainfall or runoff must be capable of storing an additional six inches of rainfall over the exposed area.

ACCEPTABLE CONTAINMENT SYSTEMS

Diking

Diking may be used to spill contain single shell tanks. Diking usually consists of concrete blocks, concrete berming, or other materials that form a permanent structural barrier. Portable spill containment trays/pallets are also acceptable. Concrete or mortar surfaces must be coated or otherwise protected against corrosion if corrosive substances are contained. No openings, manual or electrical gates, or valves of any kind are allowed in the containment structure. Utility pipes through the diking may be approved if an effective sealant is used to keep the containment watertight.

Self-Containment

Tanks of double shell construction are considered to be self-contained and do not require additional spill containment features unless there is a significant likelihood of overflowing. These tanks consist of two independent structural shells with the outer shell capable of containing any leakage from the inner one. An air gap of at least one-inch must be provided between the inner and outer shells; the top of the inner shell must be at least one inch lower than the top of the outer shell. No valves are allowed in the outer shell, and the area between the two shells must remain dry.

Pits

Pits constructed under or around tanks are acceptable as spill containment. No openings, manual or electric gates, or valves are allowed. The surfaces of the pit must be protected against corrosion if corrosive materials are contained.



REQUIREMENTS FOR SPILL MITIGATION

Emergency Response

A spill contingency plan must be developed. If an uncontrolled release of a RESTRICTED material reaches the sewer, the Districts must be notified immediately. During business hours, the Joint Administration Office should be notified at
(562) 699-7411, ext. 2907; for non-business hours, the Long Beach Pumping Plant should be notified at (562) 437-6520. Spills of flammable or explosive materials should also be referred to the local Fire Department. A written report must also be submitted within five days of the slug discharges resulting from fire or explosion for the Districts’ review containing the following items:

  • Date and time of discharge
  • Discharge location
  • Concentration, volume, waste type, chemical name and harmful characteristics or effects of the material (e.g. explosive, flammable)
  • Response measures being taken
  • Name of agencies or contractors contacted
  • Cause of the incident
  • Specific details of the incident
  • Remedial measures taken
  • Preventive mechanism to avoid reoccurrence of similar incidents

Treatment

Pumps used for conveying materials from containment areas to pretreatment systems prior to discharge must be manually activated. Each transfer of material from the spill containment area must be logged according to the Log Book Requirements described below.

Waste Hauling

The disposition of spills that are treated off-site must be logged according to the Log Book Requirements described below. In addition, waste hauler reports must be kept on file at the permittee's situs address for at least four years.


LOG BOOK REQUIREMENTS

Each IU required to install and maintain a spill containment system must keep a logbook that is available to Districts' employees upon request or during inspections. All impounded materials removed from spill containment areas, whether RESTRICTED or non-RESTRICTED, must be included in the logbook. This includes rainwater and process wastewater that results from "normal" operations. The logbook must contain the following information:

  • Date and time material is removed from spill containment area
  • Identity of material (an analysis is required if the spill is of unknown origin to determine the type of treatment or remediation required for proper disposal)
  • Quantity (volume)
  • Cause of spill
  • Method of disposal (includes transfer to off-site treatment system)
  • Corrective action implemented to prevent spills from reoccurring

SDC PLAN REQUIREMENTS

The revised Environmental Protection Agency (EPA) regulations (40 CFR 403.8 (f)) that took effect on August 23, 1990, require that the Districts evaluate each significant industrial user (SIU) at least once every two years to determine whether such SIUs need a plan to prevent and control slug discharges (accidental spills or non-routine batch discharges).

If such a plan is needed, the SIU will be placed into the Districts' Slug Discharge Control/Spill Containment Program and will be required to maintain a written plan containing the following elements:

  • Description of discharge practices, including non-routine discharges. Dischargers of wastewater resulting from non-routine operations are prohibited unless prior approval is obtained.

  • Description of stored chemicals. Include Tank Schedule.

  • Procedures for promptly notifying the Districts of slug discharges (defined as any discharge that would contribute to a violation under 40 CFR 403.5 (b)), with procedures for follow-up written notification within 5 days. An example of a Notification Form is provided in Appendix B and may be used for notification purposes.

  • Procedures to prevent adverse impact from accidental spills, including maintenance and inspection of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site run-off, worker training, building of containment structures or equipment, and measures and equipment for emergency response. Include drawing(s) that show spill containment dimensions and the locations of all floor drains, wastewater piping, and pretreatment equipment.

  • Follow-up practices to prevent damage to the treatment plant or the environment.

If approval of slug discharges could not be obtained due to emergency reasons, the Districts must be notified in writing within five days of such discharges. The written report shall contain all information as described in the Emergency Response item of the REQUIREMENTS FOR SPILL MITIGATION SECTION of this document.

The SDC plan must be maintained at the discharge location and made available to staff from the Districts, Regional Board or EPA upon request.

The SDC plan must contain a certification statement with the specific following language:

Based on my inquiry of the person or persons directly responsible for managing compliance with the slug discharge control measures identified in the Slug Discharge Control Plan, I certify that this facility, to the best of my knowledge and belief, is fully implementing the Slug Discharge Control Plan.

Signature of Responsible Company

Official:

________________________________________________

Print Name of Official:

________________________________________________

Title of Person Certifying Report:

________________________________________________

Date:

________________________________________________

VIOLATIONS

Failure to submit plans or install and maintain an adequate spill containment system or maintain a required SDC plan is a violation of the Districts' Wastewater Ordinance and may be subject to criminal and civil penalties as provided by law.

Every person or permittee violating any provision of this Industrial Wastewater Discharge Permit (permit) or the Districts’ Wastewater Ordinance (Ordinance) is guilty of a misdemeanor, and upon conviction is punishable as provided by law (California Health & Safety Code Section 4766 currently allows for a fine not to exceed $1000, or imprisonment for not more than thirty (30) days, or both. Misdemeanor violations of California Health & Safety Code Section 25189.5 currently allow for a fine not to exceed $100,000 and imprisonment not to exceed one year. Misdemeanor violations of the Clean Water Act, 33 USC 1319(c) currently allow for a fine not to exceed $25,000 and imprisonment not to exceed one year.) Each day during which any violation continues shall constitute a separate offense. The Chief Engineer is authorized to seek, through the office of the District Attorney of Los Angeles County or other appropriate authority, prosecution of criminal charges against any person violating any provision of the permit or the Ordinance. Violations of discharge limitations established under this permit or the Ordinance may also be violations of state and federal environmental laws which may be punishable as felonies and which may also carry substantial fines and penalties (California Health & Safety Code 25189.5 currently allows for a fine not to exceed $100,000 (except the fine can be up to $250,000 for great bodily injury or substantial probability of death) and imprisonment up to 3 years and 33 USC Section 13.19(c) currently allows for a fine not to exceed $1,000,000 for a first conviction and imprisonment of up to 15 years.)

In addition, any person or permittee who violates any provision of the Ordinance or any term or condition of any permit issued pursuant to the Ordinance or plan approval that prohibits or limits the discharge of any waste or imposes any pretreatment requirement shall be civilly liable to the Districts in the maximum sum provided by law for each day in which such violation occurs (California Government Code Section 54740 currently allows for civil penalties which include, but are not limited to, a fine of up to $25,000 per day of violation.)

APPENDIX A: DEFINITIONS

RESTRICTED Materials:

  • 10 lbs. or more of cyanide, arsenic, cadmium, chromium, copper, lead, mercury, nickel, silver or zinc in solution
  • More than 1 gallon of a concentrated toxic organic
  • More than 10 gallons of a liquid with a closed cup flash point less than 60o C
  • 60 gallons or more of a solution with a pH below 6.0 OR above an applicable upper pH limit (spill containment is NOT required in cases where a release of this material has no reasonable potential to cause a violation of pH permit limits)
  • Any other liquid material that upon evaluation with respect to point of discharge, volume, and concentration is determined to have potentially adverse effects on the sewerage system. These materials include but are not limited to alkalies or alkaline substances, oils, foam generating wastes, highly colored wastes, pesticides, high COD wastes, high total solids wastes, and solvents.

SIGNIFICANT INDUSTRIAL USER

A Significant Industrial User (SIU) is defined as an IU that is subject to USEPA’s categorical pretreatment regulations or an IU that has the reasonable potential to adversely affect the collection system or treatment plant.

SLUG DISCHARGE

“…A slug discharge is any discharge of a non-routine, episodic nature, including but not limited to an accidental spill or a non-customary batch discharge…”


TOXIC ORGANICS

Base/Neutral Extractables

4-Bromophenyl Phenyl Ether

Benzidine

Fluoranthene

2-Chloronaphthalene

Benzo (A) Anthracene

Fluorene

4-Chlorophenyl Phenyl Ether

Benzo (A) Pyrene

Hexachlorobenzene

1,2,5,6-Dibenzanthracene

Benzo (K) Fluoranthene

Hexachlorobutadiene

1,2-Dichlorobenzene

Benzo (GHI) Perylene

Hexachloroethane

1,3-Dichlorobenzene

Bis (2-Chloroethyl) Ether

Hexachloropentadiene

1,4-Dichlorobenzene

Bis (2-Chloroisopropyl) Ether

Indeno (1,2,3-CD) Pyrene

3,3-Dichlorobenzidine

Bis (2-Chloroethoxy) Methane

Isophorone

2,4-Dinitrotoluene

Bis (2-ethylhexyl) Phthalate

Naphthalene

2,6-Dinitrotoluene

Butyl Benzyl Phthalate

Nitrobenzene

1,2-Diphenylhydrazine

Chrysene

N-Nitrosodimethylamine

2,3,7,8-TCDD

Diethyl Phthalate

N-Nitrosodi-M-Proplyamine

1,2,4-Trichlorobenzene

Dimethyl Phthalate

N-Nitrosodiphenylamine

Acenaphthene

Di-N-Butyl Phthalate

Phenanthrene

Acenaphthylene

Di-N-Octyl Phthalate

Pyrene

Anthracene


Acid Extractables

2-Chlorophenol

2-Nitrophenol

P-Chloro-M-Cresol

2,4-Dichlorophenol

4-Nitrophenol

Pentachlorophenol

2,4-Dimethylphenol

2,4,6-Trichlorophenol

Phenol

2,4-Dinitrophenol

2,4-Dinitro-O-Cresol



Volatile Organics 

1,1-Dichloroethane

Acrolein

Dibromochloromethane

1,2-Dichloroethane

Acrylonitrile

Dichlorobromomethane

1,1-Dichloroethylene

Benzene

Ethylbenzene

1,2-Dichloropropane

Bromoform

Methylene Chloride

1,3-Dichloropropane

Bromodichloromethane

Methyl Chloride

1,1,2,2-Tetrachloroethane

Carbon Tetrachloride

Tetrachloroethylene

1,2-Trans-dichloroethylene

Chlorobenzene

Toluene

1,1,1-Trichloroethane

Chloroethane

Trichloroethylene

1,1,2-Trichloroethane

Chloroform

Vinyl Chloride

2-Chloroethyl Vinyl Ether





Pesticides

4,4-DDT

Chlordane

PCB 1016

4,4-DDE

Beta-endosulfan

PCB 1221

4,4-DDD

Dieldrin

PCB 1232

Aldrin

Endosulfan sulfate

PCB 1242

Alpha-endosulfan

Endrin

PCB 1248

Alpha BHC

Endrin aldehyde

PCB 1254

Beta BHC

Heptachlor

PCB 1260

Delta BHC

Heptachlor epoxide

Gamma BHC

Toxaphene



APPENDIX B: SLUG DISCHARGE NOTIFICATION FORM
[3]

Company Name:

____________________________

Phone Number: ______________

Address:

_____________________________________________________________

Type of Slug:

_____________________________________________________________

Reported By:

_____________________________________________________________

Comments:

_____________________________________________________________


Descriptions of Slug Loading

Time/Date:

_____________________________________________________

Discharge Material:

Amount: _______________

Discharged To:

_____________________________________________________

Containment in Place:

_____________________________________________________

Current Response Efforts:

_____________________________________________________

Comments:

_____________________________________________________


Hazard Evaluation:

Fire Hazard: _____________

Explosive: ___________

Fumes:___________________

Corrosive: _______________

Personal Safety Concerns:

_________

Exposure: ___________

Structural Danger: _________

Comments:______________________________________________________________________________

Initiation of Response

Report By:

_____________________________________________________________

Date/Time:

_____________________________________________________________

Agencies Contacted:

_____________________________________________________________

 

_____________________________________________________________

 

_____________________________________________________________

Date/Time:

_____________________________________________________________

 

_____________________________________________________________