Dust Off Your Plan
Having an environmental management information system in place can help you to smoothly implement your company's stormwater pollution prevention plan
Has your stormwater pollution prevention plan been shelved along with the best intentions of your best management practices? If so, you are not alone. Leaner environmental, health and safety (EHS) staffs may appear more productive to management, but oftentimes these lean staffs inadvertently ignore aspects of their jobs, completing the activities with reporting deadlines and letting less-defined requirements gather dust in notebooks on the shelf.
The Phase I National Pollutant Discharge Elimination System (NPDES) stormwater requirements have been in effect for more than eight years. As part of the permit process, a stormwater pollution prevention plan must be prepared to identify structural and nonstructural controls that will be implemented to prevent contamination of stormwater and reduce erosion. The controls to be implemented are typically low cost and low technology, including housekeeping, spill prevention and response, preventative maintenance, employee training and proper material handling. Even though the controls included in the plans are low cost, the U.S. Environmental Protection Agency (EPA) has found widespread noncompliance with these requirements.
Emphasis on Enforcement
In recognition of the low compliance rates, EPA began to emphasize enforcement in its 2000 Storm Water Enforcement Strategy and continues to include compliance with section 402 as a national enforcement priority.
The current EPA water enforcement national priorities include, among other things, to ensure Clean Water Act (CWA) compliance in many wet weather areas. Specifically for stormwater, the 1987 amendments to the CWA included the addition of paragraph (p) under section 402 that established phased NPDES permit requirements for municipal and industrial stormwater discharges. Stormwater discharges are nationwide occurrences. The total number of stormwater dischargers is unknown, but expected to be several hundred thousand. Stormwater runoff poses a significant threat to public health and the environment, and remains a leading cause of water-quality impairment. Pollutants in stormwater discharges can cause a variety of diseases in humans, ranging from dysentery to hepatitis. They can also contaminate fish, shellfish and drinking-water sources, create harmful algal blooms and impair water quality.
The enforcement and compliance assurance program selects national program priorities by considering patterns of noncompliance and environmental or public health risk associated with regulated sectors, particular pollutants or specific regulatory requirements. Priorities are usually national in scope and must be appropriate for federal attention and response. EPA regions support national priorities, although they may be exempted if there is justification. EPA also recognizes the need for and the importance of establishing regional and state priorities, with the commitment to provide the resource flexibility necessary to implement those priorities.
The Effects of Stormwater Runoff
According to the Report to Congress on the Phase I Storm Water Regulations,
February 2000, urban stormwater runoff contributes to 13 percent of impaired rivers and streams, 21 percent of impaired lakes, 4 percent of the impaired Great Lakes Shoreline, 55 percent of impaired ocean shorelines and 46 percent of impaired estuaries. Stormwater runoff not only poses a threat to ecological health (e.g., shellfish bed closures, elimination of habitat, stream bank erosion, flooding, channelization), but can also substantially affect human health.
In 1998, more than 1,500 beach closings and advisories were associated with stormwater runoff (Natural Resource Defense Council, 1999, A Guide to Water Quality at Vacation Beaches). A study conducted in Santa Monica Bay, Calif., concluded that there is a 57 percent higher rate of illness in swimmers who swim adjacent to storm drains than in swimmers who swim more than 400 yards away from storm drains. In addition, the study documented a relationship between gastrointestinal illness in swimmers and water quality (Haile, R.W., et al 1996, An Epidemiological Study of Possible Adverse Health Effects of Swimming in Santa Monica Bay).
Using Technology to Refine the Management Process
So how does an overworked wastewater engineer breathe life into these plans and assure compliance? One possibility is to use technology to distribute the workflow because compliance, like safety, is everyone's responsibility. Since compliance is not an intermittent, irregular occurrence, you need to continually monitor, collect, analyze and report information and data. You can choose to do this using piecemeal tools, such as your personal calendar, e-mail and spreadsheets, or you can choose to use an environmental management information system (EMIS). Simply put, an EMIS systematically gathers, analyzes and reports business information related to EHS management -- allowing a company to track, refine and methodically improve its processes and performance.
An EMIS is configured to map to your current work processes, including your stormwater pollution prevention plan. You then provide specific access to each and every person that is part of the process -- from lab technicians to plant personnel. Because all your water-management information and data (including calculations, reference documents, etc.) are in one place, you don't need to spend any time searching for them.
Another important capability of an EMIS is task management. Without systematic reminders, others in your organization won't know what they are failing to do. With an EMIS, you can automatically send reminders and specific instructions based on the requirements. Create the reminders and specific instructions once in EMIS, and then the system will distribute the reminders with your instructions. If they don't complete their assignments, they will receive additional reminders. You can also have preset escalation notifications to their supervisors. Now the work has been distributed with built-in accountability to the appropriate staff; you are out of the loop and notified only if the tasks are not completed.
An Example of One Company's Plan
Typically a stormwater pollution prevention plan includes a number of annual activities. In the example illustrated below this company is required by their plan to conduct and prepare the following:
- Annual comprehensive compliance site evaluation
- Annual refresher training
- An annual report
- An annual inspection
Their permit requires observations and sampling during storm events that exceed a threshold of rain within a 24-hour period. This particular site is located in a desert climate and rainfall occurs intermittently so sampling and observations triggered by a 1/2 inch rainfall can be easily forgotten. At this location, they are using a rain gauge to trigger reminders to conduct the sampling and observations. Now they have a record of the potential days when sampling is required and a record of the sampling completed. This facility is prepared to address questions raised during a stormwater inspection.
Applications at Your Facility
Does your facility employ contractors to empty sumps or assist with maintenance activities? How do you assure that the contents of the vacuum truck do not end up in the stormwater sewer?
Do you have secondary containment surrounding your tanks? How do you document the procedures for releasing the rainwater from the secondary containment area?
Does the shelf hold other dusty notebooks? The following example includes automation of reminders for a Spill Emergency and Response Plan. The example below shows a few of the requirements detailed in the Spill Emergency and Response Plan. At this facility, reminders are sent to check the inventory of absorbent pads to assure that the amounts required by the plan are available if an emergency occurs. The EMIS also sends reminders to assure that the chlorine leak detection kits and the chlorine repair kits are stocked with sufficient supplies.
These notifications/tasks are typically sent to personnel in the field. This is not creating additional work for the EHS professional, but is providing the EHS professional with the assurance that the requirements are being met.
Don't forget to brag about the improvements to compliance at your next performance appraisal. Companies often evaluate EHS performance on lagging indicators like the number of spills or violations. This can frustrate EHS professionals who realize they often have little control over the basis by which they are evaluated. However, with an EMIS, you can provide "statistics" to demonstrate the implementation of a proactive and growing process to prevent spills or violations.
Measuring While the Process Happens
"If you can't measure it, you can't manage it," says quality guru Edward Demming. Pilko & Associates fine-tunes this statement by saying, "If you can't measure the process while it is happening, you can't manage it." This concept is the heart -- and teeth -- of all successful EHS management systems. When you drill down into these successful systems (at the few companies with truly enviable EHS records), you will find EHS Performance Measurement tools track processes. The simple truth is that you can't control events by measuring the outcome. Counting bodies after the battle will not help you fight better.
With an EMIS the data is readily available to measure the in process metrics and provide leading, instead of lagging, indicators. Run a report to provide substantiation of the number of compliance activities that have been systematically distributed with accountability. Track the closure of corrective action and audit findings. The data within an EMIS can also be used to report performance metrics for all compliance activities.
After setting up the structure of an EHS program, a company can set targets for expansion of the compliance assurance process and continue to document improvements in compliance assurance, productivity and performance enhancements. Pilko & Associates have found that companies with integrated EHS management systems that incorporate comprehensive performance management with in-process performance metrics reduce the overall cost of EHS. Prevention and appraisal costs drop as prevention becomes part of the normal way of doing business. Failure costs drop sharply because activities that might lead to failure are no longer taking place. Overall costs drop significantly, meeting the expectations of management, shareholders, the community and the environmental watchdogs.
These principals of performance management can be expanded from stormwater management throughout EHS and into other aspects of your company where compliance is critical. The next time someone wants to create another notebook for the shelf, save the company's money and go directly to a solution that will result in enhanced performance and greater accountability, not another dust collector and burden for EHS staff members.
This article originally appeared in the 04/01/2004 issue of Environmental Protection.