37_Parks and Recreation Maintenance Facility PPP

POLLUTION
PREVENTION PLAN
REE N BORO
City of Greensboro
Parks & Recreation Maintenance Facility
Version 1.0

TABLE OF CONTENTS
1.0 Introduction......................................................................................................................... 1
1.1
Plan Amendment and Annual Review................................................................... 1
1.2
Pollution Prevention Team..................................................................................... 1
2.0 Site Overview...................................................................................................................... 2
2.1
General Information................................................................................................2
2.2
Facility Description................................................................................................. 2
2.3
Operation Descriptions........................................................................................... 2
2.3.1 Maintenance of Operational Equipment..................................................... 2
2.3.2 Hazardous Material Storage........................................................................ 3
2.3.3 Equipment and Non -Hazardous Material Storage ...................................... 3
2.3.4 The Filling of ASTs and USTs................................................................... 3
2.3.5 Dispensing of Fuel to Vehicles and Equipment .......................................... 3
2.3.6 Potential Pollutants..................................................................................... 4
2.3
Significant Spills..................................................................................................... 4
3.0 Stormwater Management Plan............................................................................................ 5
3.1
Operation Specific Management Strategies............................................................ 5
3.1.1 Maintenance of Operational Equipment..................................................... 5
3.1.2 Filling of ASTs and USTs........................................................................... 5
3.1.3 Dispensing of Fuel to Vehicles and Equipment .......................................... 5
3.1.4 Hazardous Material Storage........................................................................ 5
3.1.5 Equipment and Non -Hazardous Material Storage ...................................... 6
3.3
Pollution Prevention through Best Management Practices ..................................... 6
3.3.1 Preventative Maintenance........................................................................... 6
3.3.2 Facility Inspections and Testing................................................................. 6
3.3.3 Good Housekeeping.................................................................................... 6
3.3.4 Employee Training...................................................................................... 7
3.3.5 Handling and Disposal of Hazardous Waste .............................................. 8
3.3.6 Spill Prevention and Cleanup...................................................................... 8
3.3.7 Secondary Containment.............................................................................. 8
4.0 Spill
Response Procedures.................................................................................................. 9
4.1
Potential Pollutant Sources..................................................................................... 9
4.2
Spill Response Procedures...................................................................................... 9
4.3
Spill Response Equipment...................................................................................... 9

Figures
I General Location Map
2 Site Map
Appendices
A Pollution Prevention Plan Revisions
B Material Inventory
C Semi -Annual Facility Inspections
D Training Records

1.0 INTRODUCTION
This document is the Pollution Prevention Plan (hereinafter referred to as the "Plan") developed for the
City of Greensboro Parks and Recreation Maintenance Facility addressed at 320 E Friendly Avenue,
Greensboro, NC 27401. This Facility falls under the jurisdiction of the City of Greensboro's Municipal
Separate Storm Sewer System (MS4) National Pollution Discharge Elimination System (NPDES)
Permit (Permit # NCS000248).
The Cities Permit requires the Permittee to develop site specific pollution prevention plans for sites that
have "...been determined by the permittee to have a significant potential for generating polluted
stormwater runoff' (Part II, Section G.2.(c) of the Cities Permit). The Parks and Recreation
Maintenance Facility has been listed as one of these high risk sites.
1.1 Plan Amendment and Annual Review
The Plan shall be reviewed and updated annually. Updates will be made if there is a change in design,
construction, operation, site drainage, maintenance, or configuration of physical features which may
have a significant effect on the potential to pollute surface waters. A record of revisions made to the
Plan is located in Appendix A.
1.2 Pollution Prevention Team
Role/Position
Personnel/Phone Number
Signature/Date
Tony Royal
Superintendent of Park Services
Team Leader
[e-mail]
336-3733679
Tony Royal
Date
Matthew A. Hicks
Superintendent of Botanical Gardens
Team Member
[e-mail]
336-373-4334
Matthew Hicks
Date
Michael Moye
Superintendent of Cemeteries
Team Member
[e-mail]
336-373-2160
Michael Moye
Date
Douglas Tanis
Superintendent of Athletic Facility
Team Member
Maintenance
[e-mail]
336-373-7968
Douglas Tanis
Date
Clifton Greeson
Superintendent of Regional Parks
Team Member
[e-mail]
336-804-7214
Clifton Greeson
Date

2.0 SITE OVERVIEW
Facility Name: Parks & Recreation Maintenance Facility
Owner & Operator: City of Greensboro
Location of Facility: 320 E Friendly Ave
Greensboro, Guilford County, North Carolina 27401
Facility Phone #: [phone]
2.1 General Information
The Facility consists of three parcels located south of East Friendly Avenue and are situated directly
west of the Southern Railway Companies railroad tracks (Figure 1). The Facility is approximately 3.18
acres in size. Current operations housed at the Facility include:
• Maintenance of operational equipment;
• Hazardous material storage; and
• Equipment and non -hazardous material storage.
• The filling of Above -ground Storage Tanks (ASTs) and Under -ground Storage Tanks (USTs);
• Dispensing of fuel to vehicles and equipment;
2.2 Facility Description
The Facility lays in a relatively flat area of Guilford County, with a mean site elevation of 798 feet
above mean sea level (MSL). Stormwater from the Facility is directed north toward E Friendly Avenue
where it enters the City's stormwater conveyance system that eventually drains into Muddy Creek (a
tributary to North Buffalo Creek). The site map (Figure 2) identifies the conveyance system as well as
the property boundaries, site topography, drainage features, drainage area boundaries, direction of
stormwater flow, buildings, and best management practices (BMPs).
The Facility is comprised of a single -story structure and associated parking areas/storage lots. The
original structure was built in 1969 and has undergone numerous additions that amount to a total of
6,000 square feet (sf).
2.3 Operation Descriptions
The Facility houses operations/equipment for the City's Park Services, Botanical Gardens, Cemeteries,
and Athletic Facility Departments. More detailed information regarding the Facility's operations can be
found in the subsequent sections.
2.3.1 Maintenance of Operational Equipment
City mechanics conduct maintenance on operational equipment including lawn mowers, utility
vehicles (UTVs), tractors, and other miscellaneous tools. Maintenance is conducted inside the
bay situated along the eastern portion of the site structure. This area also houses six hydraulic
lifts formerly used to perform maintenance on busses. These lifts are no longer in use.
2

2.3.2 Hazardous Material Storage
The hazardous material storage at the Facility consists of 15 pallets of fertilizer, two oil ASTs, up
to four 55 gallon drums filled with used oil, up to 100 gallons of lubricant, one truck mounted
AST used as a mobile refueler, one diesel AST associated with the generator, one diesel UST,
and one gasoline UST. All of the fertilizer stored at the Facility is kept indoors. The two oil
ASTs are constructed using a doubled -walled steel design and are located indoors. Used oil
drums are located inside Facility's structure. Used oil generated at the Facility is deposited into
the steel drums that are kept atop drip decks. The lubricant is stored in five gallon buckets which
are stored inside. The truck mounted diesel AST is used for refueling equipment in the field. It
is a double -walled steel tank and has a capacity of 100 gallons. The diesel AST associated with
the generator is constructed using a double -walled steel design and has a capacity of 354 gallons.
The diesel UST has a capacity of 15,000 gallons and is constructed out of steel. The gasoline
UST has a capacity of 12,000 gallons and is also constructed out of steel. Both tanks are located
southwest of the Facility structure near the pumping station. A complete material inventory list
can be found in Appendix B of the Plan. The locations of these containers are depicted in Figure
2.
2.3.3 Equipment and Non -Hazardous Material Storage
The Facility utilizes various pieces of fuel/oil filled equipment (trucks, tractors, lawnmowers,
etc.). A majority of this equipment is housed outside the facilities structure with the exception
any equipment undergoing maintenance. This equipment is stored indoors until repairs have been
completed. The outdoor storage area is also used to store miscellaneous materials associated with
the Parks and Recreation maintenance operations (fencing, park benches, signage, lumber, etc.)
as well as a scrap metal pile of littered material found in the parks. The scrap metal is stored at
the Facility until enough volume has been collected to take to a recycling facility.
2.3.4 The Filling of ASTs and USTs
The oil ASTs and the USTs are filled by a third party supplier that must meet the minimum
requirements and regulations established by the United States Department of Transportation
(USDOT). The Facility mechanics notify the vendor when the oil ASTs need to be filled and a
liquid level sensor in the USTs send an alert to Equipment Services notifying them that the tanks
need to be filled.
The used oil drums are filled by Facility mechanics who notify a separate vendor when drums
are ready to be picked up. Loading of these drums is conducted undercover, inside the
maintenance garage.
2.3.5 Dispensing of Fuel to Vehicles and Equipment
The gasoline and diesel USTs are used to fill vehicles and operation equipment utilized by the
departments housed at the Facility. The filling station is located just north of where the USTs are
buried and has two pumps (one for each type of fuel) that are covered by an awning.
3

2.3.6 Potential Pollutants
Potential pollutants at the Facility include petroleum hydrocarbons, nitrogen, phosphorous, and
solids (floating and suspended).
2.3 Significant Spills
There have been no reportable discharges at the Facility identified by Facility management as of the date
of this plan. In the event that a significant spill does occur, the details of the event shall be recorded in
Table 2 of this Plan. The outcome of this event would also be included in the annual trainings in order
to help prevent future incidents from occurring
0

3.0 STORMWATER MANAGEMENT PLAN
3.1 Operation Specific Management Strategies
Where practical, operations and storage practices have been established that minimize or eliminate
exposure of materials and processes to rainfall and run-off flows.
3.1.1 Maintenance of Operational Equipment
Minor repairs performed on the Facility's equipment, as well as the maintenance oil used to
perform these repairs, is conducted and stored inside the Facility's structure atop concrete floors
without any form of drain system. If a spill occurs in this location that cannot be immediately
contained, the excess material would be confined within the Facility's structure.
3.1.2 Filling of ASTs and USTs
The oil AST and used oil drum loading area is the same location as the Maintenance area, thus
has the same potential for exposure.
The UST loading area is located southwest of the Facility's structure and is exposed to rainfall.
Should a spill occur in this location that cannot be immediately contained, the excess material
would likely collect in the paved parking area west of the building due to its natural topography.
Filling of the ASTs and USTs is handled by third party vendors. These vendors are required to
respond to an active spill should one occur during loading operations. Facility personnel are also
present during loading operations so that appropriate response procedures are initiated in the
event that a larger spill does occur.
3.1.3 Dispensing of Fuel to Vehicles and Equipment
The fuel dispensing area is the same as the UST loading area listed in section 3.1.2 and thus has
the same potential exposures. The mobile AST mounted to one of the Facility's trucks is filled at
the UST loading area but is then used to refuel operational equipment in the field. The truck is
parked in the storage lot when not in use and the AST is visually inspected for leaks every day.
3.1.4 Hazardous Material Storage
When feasible, hazardous material is stored inside, or underground, in order to prevent pollutants
entering the Facility's stormwater discharge. These materials include fertilizers, used and new
oil, lubricant, and miscellaneous cleaning supplies. Diesel fuel ASTs are the only containers that
are exposed to stormwater.
5

3.1.5 Equipment and Non -Hazardous Material Storage
Miscellaneous non -hazardous materials (i.e. building materials, fencing, trailers, brush hogs,
etc.) are stored in the lot east of the Facility structure. This area drains north towards E Friendly
St where a vegetated Swale separates the storage lot from the road. A scrap metal pile is also
located in the gravel lot on the eastern portion of the Facility. This pile is generated through city
employees picking up material that was illegally dumped in the city's parks. The scrap metal pile
is recycled once it reaches a large enough volume.
3.3 Pollution Prevention through Best Management Practices
Best management practices (BMP) for the Facility were selected based on the assessment of the
potential for sources to contribute pollutants to the Facility's stormwater discharge. These BMPs include
preventative maintenance, Facility inspections and testing, good housekeeping, employee training,
handling and disposal of hazardous waste, spill prevention and cleanup, and secondary containment.
3.3.1 Preventative Maintenance
Maintenance of storm water management devices performed as part of this program and other
routine maintenance programs includes the following:
• Cleaning of accumulated sediment and debris from conveyance systems, pipe lines, and
stormwater basin;
• Clearing of debris from drainage features such as curbs, gutters, and ditches; and
• Preventative maintenance is performed on equipment in conformance with the
manufacturer's recommendations.
3.3.2 Facility Inspections and Testing
Visual inspections of the Facility's equipment and storage containers are completed on a daily
basis by the Facility personnel. These inspections are not recorded. More detailed inspections of
the Facility and all stormwater systems will occur every six months, with one inspection during
the first half of the year and one during the second half of the year with at least 60 days
separating the inspections. Completed inspection logs are filed with the Plan in Appendix C.
Additionally, testing/inspections are conducted on both of the USTs according to industry
standards. This testing is conducted by the Equipment Services Department who maintains the
associated records.
3.3.3 Good Housekeeping
Good housekeeping is practiced at the Facility as part of standard operating procedures and is
implemented by all employees. The maintenance of a clean and orderly Facility maximizes
operational efficiency, minimizes employee safety hazards, and reduces potential pollutant
impacts to the storm water conveyance system. Employees are trained to understand the
importance of good housekeeping practices. Housekeeping activities at the Facility are
summarized below.
C

Materials Management
Responsible management of common chemicals, such as paints, cleaners, fertilizers, and
automotive products, includes selection of the products, correct use and storage, and responsible
disposal of associated wastes. Material storage and inventory controls reduce the occurrence of
overstocking hazardous materials. Routine cleaning and inspections of material storage, process,
and disposal areas reduce the likelihood of accidental spills or releases during storm events.
Vehicle and Equipment Maintenance
All maintenance activities are performed inside or under cover. Spills are cleaned up
immediately, without water whenever possible, and clean up materials are properly collected and
disposed.
The outdoor staging areas are inspected regularly for drips and spills by Parks and Recreation
personnel. Areas traversed by Facility equipment and employee vehicles are monitored as a part
of the Facility's regular operation for signs of leaks or spills.
Vehicle and Equipment Washing
The Parks and Recreation Department has an assortment of city vehicles utilized by their
personnel which are kept at the Facility when not in use. These vehicles are not washed at the
Facility. They are taken to Field Operation's truck wash located at the Patton Avenue site.
The Facility also houses various forms of equipment used to maintain the City's parks, athletic
facilities, cemeteries, and gardens. A majority of this equipment is stored in maintenance garages
or sheds at the sites they service. Some equipment is stored at the Facility or trailered by Parks
and Recreation vehicles in order to address certain maintenance needs throughout the City. This
equipment is cleaned over a pervious surface using either dry or wet methods (without soap).
Washing of any engines, brakes, paint spraying containers, or other mechanisms that have the
potential to pollute the wash water with anything other than dirt and organic debris, are taken to
the Patton Avenue truck wash.
Proper Fueling of Vehicles and ASTs
During the loading and unloading, or transfer of automotive fluids by a third party vendor,
Facility employees ensure that outside personnel understand the site layout, know the protocol
for entering the Facility and transfer of product, and have the necessary equipment to respond to
a release from the vehicle or fuel delivery hose. A Facility Manager or designee supervises oil
deliveries for all new suppliers and periodically observes deliveries for existing, approved
suppliers. Additionally, the USTs and the generator AST have high liquid level alarms that are
tested regularly.
3.3.4 Employee Training
The municipal employee training program is designed to teach staff about potential sources of
storm water contamination and ways to minimize the water quality impact of municipal
activities. The training program includes a general storm water awareness message; pollution
7

prevention/good housekeeping measures; the BMPs utilized at the Facility; and the Plan for this
Facility. Training records can be found in Appendix D.
3.3.5 Handling and Disposal of Hazardous Waste
Used oil recycling is utilized at the Facility to encourage and facilitate proper management of
used oil. This reduces the likelihood of storm water impacts by encouraging the capture of all
used oil generated at the Facility.
3.3.6 Spill Prevention and Cleanup
Active and passive spill containment measures are utilized at the Facility to prevent spilled
materials from migrating outside the industrial activity area and/or into surface waters. The
locations of the Facility's spill kits are depicted in Figure 2.
3.3.7 Secondary Containment
The two oil ASTs and the AST associated with the generator are constructed using a double
walled design. This is intended to allow for the contents of the containers to be completely
contained by the outer wall should the inner wall rupture. The used oil drums are stored atop
containment pallets that are adequately designed to contain the contents of the drums. Additional
secondary containment is provided by spill kits located near the material storage areas.

4.0 SPILL RESPONSE PROCEDURES
4.1 Potential Pollutant Sources
The Facility has limited the quantity and types of industrial activities exposed to stormwater. However,
there are several items of concern that have the potential to pollute stormwater to some degree. These
include:
The gravel storage lots potential to contribute sediment;
The degradation and corrosion of metal materials stored outside;
The filling procedures associated with the two USTs, the truck mounted AST, and the generators
AST.
4.2 Spill Response Procedures
In the event a spill of a potential storm water pollutant occurs or is found, the following steps shall be
taken:
• If a hazardous material/substance enters the storm drainage system, call 911 to report the
discharge to local authorities.
• Assess the hazards.
o Assess the quantity of substance spilled and integrity of containment.
o Stop operations if necessary.
o Secure the area.
o Determine if the spill could potentially impact waterways or leave the site.
• Eliminate potential spark sources.
• If possible and if safe to do so, identify and shut down the source of the discharge (e.g., close
open valves, deactivate pumps).
• Ensure proper PPE is used during cleanup activities.
• Use all equipment and manpower at the Facility's disposal to minimize the amount of oil
discharge and prevent it from entering any navigable waterways by containing the discharge with
sorbents, berms, fences, trenches, sandbags, or other appropriate materials.
• Contact the Plan's Team Leader, or their alternate.
• The Team Leader should contact regulatory authorities (only if a reportable instance, and/or not
contained) and the response organization. Collect and dispose of recovered product according to
regulation.
4.3 Spill Response Equipment
Spill response kits are located in close proximity to the Facility's UST loading/fueling area and the
equipment maintenance area. See Figure 2 for the locations of these spill kits.
E

FIGURES

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Figure 2 - Site Layout
Parks & Recreation Maintenance Facility
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Material Storage
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ID
Description
1
15,000gallon diesel UST
2
12,000gallon gasoline UST
3
354gallon generator AST
ik.t
4
55 gallon drums (up to 4)
5
250gal Ion oil ASTs (2)
6
5 gallon buckets of lubricant (-15)
7
100 gallon truck mounted AST
,j8
7r��_
Palletized Fertilizer (-28,8001bs)s"
{
Legend
Site Boundary Pipes
0 Curb Inlets ® Material Storage
(0 Storm Manholes Spill Kits
0 Grate Inlets Two Foot Contour Interval
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00
Notes:
-Aeiral image is from the 2018 Guilford County survey.
- Reference the material inventory table(Appendix B) for
more information regarding oil storage at the Facility.
-The truck mounted AST's location varies. The truck
also has a spill kit onboard.
Scale: 1 inch = 75 feet
Map created by the City of Greensboro Stormwater Division on January 19, 2022

APPENDIX A
Pollution Prevention Plan Revisions

Pollution Prevention Plan Revisions
City of Greensboro Transfer Station
Date Section Revised Revisions Made

APPENDIX B
Material Inventory

Material Inventory
Transfer Station
ID
Container Description
Contents
Capacity
Discharge Prevention & Containment
1
Steel UST
Diesel
15,000 gallons
Active containment (spill kits), level gauge
2
Steel UST
Gasoline
12,000 gallons
Active containment (spill kits), level gauge
3
Steel, double walled, AST fueling the
Diesel
354 gallons
Double walled construction, active containment
Generator
(spill kits), level gauge
4
55-gallon steel drums
Used oil
—220 gallons
Active containment (spill kits), containment
pallets
5
Two steel, double walled, ASTs
Oil
250 gallons
each (500
Double walled construction, active containment
gallons total)(spill
kits)
6
5 gallon buckets
Lubricant
—75 gallons
Active containment (spill kits)
7
Portable steel AST
Diesel
100 gallons
Active Containment (Spill Kits)
8
48 lb bags
Fertilizer
—28,800 lbs
Stored inside the Facility
Varies —
M
Metal/plastic containers
Various
Typically < 5
Stored inside the Facility and are ordered on an
gallons per
as needed basis
container

APPENDIX C
Semi -Annual Facility Inspections

General Information
Facility Name
City of Greensboro Parks and Recreation Maintenance Facility
Date of Inspection
Start/End Time
Inspector's Name(s)
Inspector's Title(s)
Inspector's Contact Information
Weather Information
Weather at time of this inspection?
❑ Clear ❑Cloudy ❑ Rain ❑ Sleet ❑ Fog ❑ Snow ❑ High Winds
❑ Other: Temperature:
Have any previously unidentified discharges of pollutants occurred since the last inspection? ❑Yes ❑No
If yes, describe:
Are there any discharges occurring at the time of inspection? ❑Yes ❑No
If yes, describe:
Structural Control
Control
Is maintenance or
Brief description of issue(s) and their
Date
Measure
measure is
attention needed?
severity (Identify deficiencies observed and
Corrective
operating
Proposed date?
provide a proposed date for repairs or
Action
effectively?
maintenance to take lace)
Completed
Interior Drain System
❑Yes ❑No
❑ No
❑ Yes
Exterior Stormwater
❑Yes ❑No
❑ No
Drains
❑ Yes
Vegetated Buffer
❑Yes ❑No
❑ No
❑ Yes
Spill Kits
❑Yes ❑No
❑ No
❑ Yes
NOTES
Use this space for any additional notes or observations from the inspection:

Area/Activity
Inspected?
Controls
Corrective Action Needed and Notes
Date
Adequate
Corrective
(appropriate,
Action
effective, and
Completed
o eratin ?
Refueling Area
❑Yes ❑No ❑ N/A
❑Yes ❑No
Gravel Storage Lot
❑Yes ❑No ❑ N/A
❑Yes ❑No
Generator AST
❑Yes ❑No ❑ N/A
❑Yes ❑No
Interior Maintenance
❑Yes ❑No ❑ N/A
❑Yes ❑No
Area
Interior Material Storage
❑Yes ❑No ❑ N/A
❑Yes ❑No
Area
Used Oil Drums
❑Yes ❑No ❑ N/A
❑Yes ❑No
Oil ASTs
❑Yes ❑No ❑ N/A
❑Yes ❑No
Exterior Vehicle Storage
❑Yes ❑No ❑ N/A
❑Yes ❑No
Area
New Site Conditions
Describe any new site conditions that are not currently address in the Facility's PPP (i.e. new materials, change in the site
layout/construction, additional operations being conducted, etc.):
Notes
Use this space for any additional notes or observations from the inspection:
Corrective actions completed on (if applicable):
Print name and title:
Signature: Date:

APPENDIX D
Training Records

Annual Stormwater Training
Facility Name: Parks and Recreation Maintenance Facili
Date Administered:
Name