SWPPP

SWPPP - Inspections - Record Keeping

SWPPP - Routine, Quarterly Visual, and Comprehensive Inspection Schedule

SWPPP - Annual Report - Corrective Actions - Revisions

SWPPP - 5.3 Annual Comprehensive Inspections

Annual Comprehensive Inspection procedures follow requirements listed in Part 6.3.1 of the 2020 MSGP and are described in detail in the ADEC MSGP Annual Reporting Form provided in Appendix D, Attachment 6. The form is also available in Appendix F of the MSGP.  Comprehensive inspections are performed annually. The schedule for performing comprehensive inspections is provided in Section 5

Comprehensive inspections are conducted by members of the ATI PPT team and include examination of the following areas and inspection items:

If discharge locations are inaccessible, nearby downstream locations must be inspected. The annual comprehensive site inspection may also be used as one of the routine inspections, as long as all components of both types of inspections are included.

The annual comprehensive site inspection report must be submitted to the ADEC as part of the annual report. Copies of the report must be sent within 45 days(postmark date) after conducting the comprehensive site inspection to the following address.  A copy of the completed form must be filed in Appendix F. Forms must be kept on file for the life of the permit as discussed in Section 6.

SWPPP - 6.4 Corrective Action (msgp part 8)

If any of the following conditions occur, ATI must review and revise the selection, design, installation, and implementation of control measures to ensure the condition is eliminated and will not be repeated in the future:

If any of the following conditions occur, ATI must review the selection, design, installation, and implementation of the control measures to determine if modifications are necessary to meet the effluent limits in this permit:

•  Construction or a change in design, operation, or maintenance at the facility changes the nature of pollutants discharged in storm water from the facility or significantly increases the quantity of pollutants discharged.

SWPPP - Release to Water

Spill Response (section 3.4.1, msgp part 6.3)
If a release of oil to water occurs that may threaten navigable Waters of the United States the following immediate notifications are required:

SWPPP - Spill Response Notifications

SWPPP - Release to Water

The permittee is required to report any noncompliance which “may endanger health or the environment”. Once a reportable release of pollutants to water has actually occurred, this is likely to be considered “noncompliance”. Under these conditions, the permittee must, at minimum, provide an oral report to the APDES program within 24 hours from the time that the “permittee becomes aware of the circumstances”. Further, a written report must be provided within 5 days and meet the informational requirements of Appendix A, Section 3.4 of the permit.

SWPPP - Release to Land

If a release to the ground should occur that does not threaten Waters of the United States, notification to the ADEC is required as follows:

3.4.2 Release to Land

Spill response materials are stored in the Connex beneath the Checker Shack near the barge ramp and in three (3) spill response kits around the yard. Spill response materials include hand tools, absorbent pads, spill booms, basic spill response equipment, and personal protective equipment. These materials should be replaced if they are used and are not to be used as working stock.

SWPPP - Employee Trainings

It is the intention of ATI to increase awareness of the cost of pollution and reinforce ATI’s commitment to a safe work environment.  Employee storm water training is provided once a year to ATI employees who work in the areas where industrial activities are exposed to storm water, or those who are responsible for the implementing activities necessary to meet the conditions of the permit. Specific topics addressed in ATI’s stormwater discharge training include the following:

SWPPP - Maintenance

3.3.1 Equipment Maintenance
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Preventive equipment maintenance is important for the prevention of pollution caused by improperly functioning equipment. Equipment that is maintained in good working condition is less likely to drip or spill fluids onto areas where these pollutants could be mobilized in storm water runoff and transported off-site. Preventive maintenance activities at the ATI Sitka Facility include the following:

• Inspecting and maintaining vehicles, the 500-gallon AST, fuel hoses and connections,secondary containments, and heavy equipment for leaks as needed;
• Conducting repair and maintenance activities under the covered maintenance area as possible;
• Conducting repair and maintenance activities on/near the concrete pad with the OWS when it is not possible to conduct it under the covered maintenance area;
• Exposure of vehicles and equipment awaiting maintenance to storm water is minimized bystoring equipment under covered areas if possible, use of drip pans, absorbents, and by cleaningpaved surfaces to remove any drips, spill, or leaks; and,
• Documenting maintenance and repairs of vehicles and equipment. Vehicle and equipment maintenance records are kept by ATI staff in a digital version, as the records are quite lengthy.These records can be made available for review upon request with some notice.

3.3.2 Control Measure Maintenance

All BMPs and control measures will be inspected as part of the quarterly routine inspected, including the catch basins and the OWS. If they are found to have debris that is more than half the capacity, or have less than 6 inches of free head space, they will be pumped/cleaned out. BMPs and control measures found to be failed during routine inspections will be addressed as a corrective action and recorded within 24 hours and fixed within 14 days, or as expeditiously as possible, of the observed failure. The corrective action will be documented in the SWPPP and the failed control measure or BMP will be re-inspected within 7 days of the corrective action to ensure that it is in good working order. Completed corrective action reports will be stored in Appendix F.

SWPPP - Annual Reports, MSGP Discharge Monitoring Reports, Noncompliance Notification Forms and Corrective Action Reports are all submitted to DEC at the following address: