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Appendix D Spill Response Plan

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Appendix D Spill Response Plan Appendix D Spill Response Plan Intentionally Left Blank City of El Centro Spill Response Plan 1. Introduction Spills and illicit discharges can be a significant source of pollutants to the City of El Centro’s (City) municipal separate storm sewer system (MS4). In accordance with the State Water Resources Control Board (SWRCB) Order No. 2013-0001-DWQ (Phase II Small MS4 General Permit), this Spill Response Plan includes a comprehensive plan for detecting, responding to, investigating, and eliminating spills or illicit discharges to the City’s MS4. The City coordinates with spill response teams to prevent entry of spills into the MS4 to prevent the contamination of surface water, ground water, and soil to the maximum extent practicable. Where necessary, the City will coordinate with other agencies to prevent spills and illicit discharges from upstream sources into the City’s MS4. The general process in which City staff respond to illicit discharges and spills is displayed in the flow chart included as Attachment 1. 2. Sewage Spills The City maintains and implements a Sewer System Management Plan (SSMP) in response to the SWRCB Order No. 2006-003-DWQ. The City also maintains a Sanitary Sewer Overflow Prevention Plan (SSOPP), which is included within the SSMP. The SSMP describes the City’s sewer system and addresses the organization and major activities of the City’s wastewater operations. Specific guidance for sewage spill overflow (SSO) response, clean-up, and reporting is included in the SSMP. The SSOPP has been specifically designed to prevent and minimize the potential for SSOs. Consistent with SWRCB Order No. WQ-2008-0002-EXEC, all publicly owned treatment plants are required to report all spills and other unauthorized discharges to the Colorado River Basin Regional Water Quality Control Board (RWQCB). 3. Hazardous Material Spills Incidents involving hazardous materials are documented by City staff using the Illicit Discharge and Non-SSO Spill Report form (Attachment 2) and a standard California Hazardous Material Incident Report form. The City’s Fire Department Hazardous Materials Team responds directly to spills or illegal dumping of hazardous materials, and provides support services to other agencies that encounter hazardous materials in their routine duties. The Hazardous Materials Team operates 24 hours a day, seven (7) days a week. The team’s duties include, but are not limited to, directing the containment and clean-up of spills that may enter surface waters or flow directly to the MS4. Additionally, the Imperial County Public Health Department (ICPHD) participates on the Imperial County Hazardous Emergency Assistance Team, which assists in the containment and clean-up of accidental hazardous material spills. Specific information regarding the response, clean-up, and reporting procedures for hazardous materials spills can be found in the Imperial County Hazardous Material Area Plan (Attachment 3) and the City of El Centro Fire Department Standard Operating Procedure Number 160 for Hazardous Materials Incident Management (Attachment 4). City of El Centro Spill Response Plan June 2014 1 4. Spill Prevention and Mitigation Procedures The City coordinates spill prevention, containment, and response activities throughout all appropriate departments, programs, and agencies so that maximum water quality protection is available at all times. Public Works staff, such as building inspectors, fire department personnel, and community service staff are trained to report illicit discharges or spill incidents while in the field performing their specific duties. 5. Responding to Complaints The public is encouraged to contact the City’s Public Works Department to report spills, illicit discharges, or other violations to (760) 337-4505 or to (760) 352-2113 after business hours. The City validates, investigates, inspects, and appropriately follows-up on spills and illicit discharges that are reported to identify the source(s) of the discharge. Complaints are typically validated through field reconnaissance. Spills or illicit discharges potentially harming human health are placed at the highest priority, with spills or discharges potentially threatening aquatic health or reaching a receiving water body as the next most important priority for investigation. The City has developed an Illicit Discharge and Non-SSO Spill Report form (Attachment 2) to document reports of illicit discharges and spills occurring within the City’s jurisdiction. The criteria listed below will be used to determine the human or environmental health threats of a spill or illicit discharge, either from storm water or non-storm water discharges, where applicable: Estimated pollutant load discharged from site Estimated volume of discharge Types of pollutants discharged, including if toxic materials were discharged Sensitivity of the receiving water body, including if it is 303(d) listed for any of the pollutants in the discharge Proximity of site to sensitive habitat/endangered species Proximity of site to public water supply (well head, monitoring wells) How much, if any of the discharge reached the receiving water body Beneficial uses for affected water bodies 6. Field and Laboratory Sampling In order to verify a source of an a discharge/spill to the City’s MS4, the City can perform field or laboratory sampling for any of the parameters identified in Table 1, or any others that may provide useful data in identifying the discharge. For example, elevated ammonia levels measured in a storm water sample can indicate a sewage spill or leak to the MS4. City of El Centro Spill Response Plan June 2014 2 Table 1. Parameter Action Levels and Methods Action Level Laboratory Analysis Parameter Example Field Test Kit/Method2 Concentration1 Method Ammonia (mg/L) ≥ 50 mg/L CHEMetrics test kit K-1410 or K-1403 SM 4500-NH3 B, C Hanna Instruments HI 727 CheckerHC Color ≥ 500 unit EPA 110.2 Handheld Colorimeter Conductivity (µS/cm) ≥ 2,000 µS/cm Conductivity meter SM 2510 B Fluoride (mg/L) N/A CHEMetrics test kit K-4009 or I-2021 EPA 9214 or SM 4500 F C Hardness ≤ 10 mg/L CaCO3 or ≥ CHEMetrics test kit K-4502 and K-4530 SM 2340B or EPA 200.7 (CaCO3 mg/L) 2,000 mg/L CaCO3 MBAS (Detergents) N/A CHEMetrics test kit K-9400 or I-2017 SM 5540 C (mg/L) pH (pH units) ≤ 5 or ≥ 9 pH meter or pH paper SM4500-H+ B Potassium (mg/L) ≥ 20 mg/L La Motte Test Kit 3138-01 EPA 258.1 Turbidity (NTU) ≥ 1,000 NTU Turbidity meter SM 2130 B Notes: 1. If an action level is exceeded, an illicit discharge investigation is required during routine outfall monitoring (Section E.9.c.ii.(b). of the Phase II Small MS4 General Permit). For the purposes of this document, these action levels are used solely as guidance for identifying pollutant concentrations that may be indicative of an illicit discharge. 2. The listed test kits/methods are included as examples only; other equivalent methods may be used. mg/L = milligrams per Liter; µS/cm = microsiemens per centimeter; MBAS = methylene blue active substances; mg/L CaCO3 = milligrams per Liter as calcium carbonate; ppm = parts per million; NTU = Nephelometric Turbidity Unit 7. Spill and Illicit Discharge Clean-Up In the event of a spill, leak, or illicit discharge to the City’s MS4, the City initiates an investigation as soon as possible after becoming aware of the spill. If investigators find evidence of a violation with the potential to release pollutants or an actual illicit discharge or spill, every effort is made to find the responsible party and inform them of the complaint or implement enforcement. Parties found to be responsible for a violation or illicit discharge/spill are required to clean-up or remove pollutants to the maximum extent practicable. Any refusal by the responsible party to perform clean up of a violation or discharge will be handled by the City’s Code Enforcement staff and appropriate enforcement actions will be taken. Public Works department personnel will respond to and commence the clean-up of minor spills to the City’s MS4 when spills are of non-hazardous materials. Otherwise, the clean-up will be deferred to the next most appropriate agency depending on the spill such as the City’s Fire Department Hazardous Materials Team or the ICPHD. Specific procedures for containing and cleaning up a spill resulting from an SSO can be found in the City’s SSMP. Procedures for containing and clean up of a hazardous material spill or discharge are included in Attachment 3 and 4 of this spill response plan. The City of El Centro Public Works Department also has specific procedures for responding to both small and large spills. 8. Spill Reporting For each reported illicit discharge or spill the City records information on the Non-SSO Spill and Illicit Discharge Report form, included as Attachment 2. City of El Centro Spill Response Plan June 2014 3 The City follows additional reporting requirements specific to discharges resulting in an immediate threat to human health or the environment, or spills of hazardous materials or sewage, including sewage spills from private laterals and failing septic systems, which are summarized below and in the illicit discharge and non-SSO spill response flow chart included as Attachment 1. State Office of Emergency Services (OES) Consistent with SWRCB Order No. WQ-2008-0002-EXEC, and California Water Code Sections 13267, 13271, and 13383, the State OES will be notified of any significant hazardous material spill or any sewage spill of 1,000 gallons or more that resulted in, or will probably result in, a discharge to any waters of the state by telephone at (800) 852-7550 or (916) 845-8911 and by fax at (916) 262-1677 (follow-up only). The complete procedure for SSO response is included in the City’s SSMP. In order to determine if a substance is considered to be hazardous or to determine what constitutes a “significant” spill, please refer to the Code of Federal Regulations List of Hazardous Substances and Reportable Quantities included in Attachment 5.
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