Top Industrial Compliance Tips for Summer
Compliance at industrial facilities is important 365 days a year, and each season comes with its own compliance challenges. As we head into the summer season, here are our top tips to ensure your facility remains compliant.
Stormwater Permit Inspections
1. Continue doing your monthly stormwater inspections! Even though Pacific Northwest summers are dry and you might not have stormwater discharge, inspections are required each month. Make sure you document the inspection findings as well as corrective actions you may have implemented.
2. If it rains within business hours, you will need to conduct visual monitoring of stormwater discharging at the monitoring location(s) each month. Make sure you keep a record of this. If no rain occurs during business hours, report “no discharge” on the last workday of each month.
Sweeping and Dust Control
3. Does your air permit or Stormwater Pollution Control/Prevention Plan (SWPCP/SWPPP) require pavement sweeping? Do you notice sediment tracking from your site onto public streets? Sweeping keeps dust from becoming airborne and contributing to fugitive emissions and reduces sediment in stormwater runoff. Make sure you continue to sweep over the summer at the required frequency or more often if the pavement appears dusty or muddy. Besides complying with your permit, municipalities often issue citations for sediment tracking onto city streets.
4. Does your gravel lot or stockpile generate dust that blows onto neighboring streets or properties? Contact MFA or follow this guidance to control dust generation and avoid citations or conflicts with your neighbors.
5. While the weather is dry, inspect your roofs to assess if you have dust accumulation or staining around stacks or vents that might indicate maintenance or corrective actions are needed.
Stormwater System Maintenance
6. Do you perform annual maintenance on your stormwater system? Summer is a good time to clean out your treatment system, tanks/ponds, and catch basins! Make sure you document the maintenance activities and proper disposal of removed water or sludge.
7. Don’t forget to maintain your bioswales. If you plant new plants, you will need to water them regularly throughout the summer to ensure proper plant establishment. Remember to remove invasive species, such as blackberries, using mechanical means only (herbicide use is not allowed inside water quality facilities).
Air Permit Reporting
8. Toxic Release Inventory due July 1. Have you performed a threshold evaluation to determine if you exceed the reporting thresholds? If not, make sure you get this on your summer to-do list!
Stormwater Permit Reporting
9. Oregon and Washington stormwater discharge monitoring reports are due August 15.
10. If you have triggered a Tier II corrective action under Oregon’s stormwater permit, be sure to start working with an engineer on evaluating/selecting treatment options this summer. MFA’s stormwater engineers are here to help. The quicker we start, the more time you will have to make this important and costly decision.
Health & Safety
11. Ensure that your safety data sheets are up-to-date and in the correct format to keep your OSHA hazard communication plan in compliance.
12. Check your emergency action plan and consider a conversation with the local fire department and/or local emergency planning committee to confirm everything is up to date.
13. Ensure you have appropriate programs in place to manage work-related heat stress. There are several resources available to help people develop such programs, such as the Federal OSHA website, the OSHA technical manual, National Institute for Occupational Safety and Health, and the guidelines published by the American Conference of Governmental Industrial Hygienists.
Do you have an industrial compliance question or challenge keeping you up at night? Do you need help preparing a discharge monitoring report or Tier II report? Get in touch with our compliance specialists.
HEALTH AND SAFETY COMPLIANCE