Industrial Storm Water Permits. Summit County Safety Council Meeting Nov 15, 2018

Transcription

1 Industrial Storm Water Permits Summit County Safety Council Meeting Nov 15, 2018

2 Why regulate storm water runoff? It can wash pollutants off your site!

3 Storm sewers drain to surface waters

4 How Ohio EPA Regulates Runoff National Pollutant Discharge Elimination System (NPDES) Permits Established 1972 Sect 402 of Federal CWA Ohio Revised Code 6111 Applied to Storm Water in 1992

5 NPDES Program for Storm Water Includes discharges to Waters of the State Municipal Separate Storm Sewer Systems (MS4s) Does not include discharges to Sanitary sewers Combined sewer systems Caution: Not all discharges within the combined sewer area are to combined sewers!

6 NPDES Program for Storm Water Industrial Wide-ranging application Based on SIC Codes NPDES Storm Water Program Construction Land Disturbances 1 acre Municipal Communities in Urban Area Includes public entities such as ODOT & State Universities

7 Definition of Industrial Activity OAC (B)(15) Identifies 11 categories of industrial dischargers Most are based on Standard Industrial Classification (SIC) Code Transportation facilities only if fueling, equipment washing, vehicle maintenance or deicing activities Regulated codes fall within Group 10 45, plus 5015, 5093 & 5171 Others include WWTPs 1 MGD and those w/pretreatment Programs Hazardous waste TSDs Landfills that have received waste from an industrial site Steam electric power plants Director may designate any facility where runoff is causing a violation of WQS

8 Industrial Storm Water Permits Two options for permitting General Permit Submit Notice of Intent (NOI) Fee is $350 Only addresses storm water discharge Individual Permit Submit Form 1 and 2F Fee is $200 Are facility-specific Can include more than one type of discharge

9 Ohio EPA May Not Allow General Permit If more than one type of discharge exists One document to manage vs two or more If facility has a history of noncompliance with General Permit Requires action by Director per OAC

10 Submitting NOI

11 STREAMS

12 Complying with the General NPDES Permit for Industrial Storm Water Storm Water Pollution Prevention Plans (SWPPPs) and Best Management Practices (BMPs)

13 General NPDES Permit OHR00006 Renewed on June 1, 2017 We are in Year 2 of the 5-year permit cycle Parts 1-7 apply to everybody (pages 1 36) Sector and subsector codes determine which subparts of Part 8 apply to your facility (pages ) Use Appendix D of General Permit OHR to determine sector and subsector code You must comply with all subparts that describe industrial activities at your facility More than one subsector may apply to your facility Contains sector-specific control measures, benchmark monitoring & effluent limitation guideline monitoring requirements, as applicable

14 Develop and implement a Storm Water Pollution Prevention Plan (SWPPP) Pollution Prevention Team Signatory requirements in Appendix B.11 General Permit Requirements Conduct inspections to ensure SWPPP is being implemented and is effective Routine Facility Inspections Quarterly Visual Assessments Conduct storm water monitoring, if applicable Benchmark Monitoring Effluent Limitation Guideline Monitoring Train Employees on SWPPP and permit requirements Complete an Annual Report

15 Storm Water Pollution Prevention Plan Facility Description & Contact Information Description of Industrial Activities Pollution Prevention Team Site Map Location of pollutant sources and control measures Drainage patterns Direction arrows Delineate drainage watersheds Storm water conveyance systems and outfall locations Outfall ID and location should match what was submitted on NOI

16 Storm Water Pollution Prevention Plan Summary of Potential Pollutant Sources List of specific activities exposed to storm water List of pollutants associated with each activity Areas where leaks or spills could occur Salt storage areas Existing sampling data, if any

17 Storm Water Pollution Prevention Plan Description of Control Measures Minimize Exposure Good Housekeeping Preventative Maintenance Spill Prevention and Response Procedures Can use SPCC plan for oil Erosion & Sediment Control Runoff Management Enclosed Salt Storage Sector-Specific Practices Controls for Waste, Garbage & Floatable Debris Dust Generation & Vehicle Tracking

18 Control Measures - ASTs Dike provides containment Plug in drain hole Spill kit available No dike Stains on ground Oily rag left out & nozzle dripping

19 Control Measures Trash Compactors Overloading results in spillage Fed from building interior No spillage

20 Control Measures - Scrap Metal Storage No Lid, Tarp or other Cover Residual oils mobilized by storm water Is container leakproof? Lid Container in good condition

21 Control Measures - Vents/Roofs Is this just rooftop runoff? What s causing the staining? Inspect and replace filters per preventative maintenance schedule

22 Non-Storm Water Discharge Evaluation SWPPP should identify all nonstorm discharges from your facility Describe how evaluation was conducted Must eliminate unauthorized nonstorm water discharges Identify actions taken in the SWPPP Options typically include: holding tank or containment with recycle/reuse or hauling off-site for disposal, re-routing to sanitary, sealing floor drains, obtaining a different NPDES permit to authorize the discharge See Part for non-storm water discharges authorized by general permit

23 Inspections Routine Facility Inspection Facility walk-through At least once per quarter, every quarter Some sectors more frequent Only twice per year for Ohio EPA E3 Gold & Platinum levels Not if inactive and unstaffed and materials/activities not exposed At least once per year when storm water discharge is occurring Quarterly Visual Assessment Observation of storm water discharge Collect sample 30 minutes of discharge in clear container First discharge within 72 hours Assess color, turbidity, foam, floatables, suspended solids, etc. Once per quarter, every quarter Not if inactive and unstaffed Only twice per year for Ohio EPA E3 Gold & Platinum levels Only one within a set of substantially-identical outfalls But, must rotate outfall observed amongst the set At least one snowmelt discharge Corrective actions required when problems are identified

24 Monitoring Not applicable to all facilities If applicable, requirements will be found in Part 8 Even within the same sector, some subsectors are subject to monitoring and others are not Three Types Benchmark Monitoring Effluent Limitation Guidelines Monitoring Other, as Specified by Ohio EPA Samples must be taken in accordance with procedures in 40 CFR Part 136, analyzed in a lab and results reported to Ohio EPA Use e-dmr at the Ohio EPA e-business Center Must be reported within 30 days of discharge

25 Benchmark Monitoring At least 4 times within the first 12 quarters of permit coverage At least one per each quarter of the calendar year Samples collected 30 minutes of discharge First discharge 72 hours If hardness dependent, use hardness of receiving stream, not the sample Only one outfall within set of substantially-identical outfalls Sample same outfall for the entire permit term

26 Benchmark Monitoring After completing benchmark monitoring, compare the average of all your results to the benchmark concentration If over benchmark, Must take corrective actions or Document why no further reduction is technologically available or economically practicable in light of best industry practice Do not need to take more samples, but can to demonstrate effectiveness of corrective actions Being over benchmark is not a violation failing to take corrective action is Document discovery within 24 hours of discovery Document corrective actions taken within 30 days of discovery Changes to control measures should be made before the next storm event, if possible Keep documentation in the SWPPP

27 Effluent Limitation Monitoring Only applicable to Sector A, D, E, J and O Only applicable if the specified activity occurs at your facility Sampling required once per year at each outfall that discharges runoff from specified activity Exceedance is a violation Must conduct follow-up monitoring < 30 days or next qualifying runoff event If follow-up sample exceeds, submit Exceedance Report < 30 days after receive lab results and continue quarterly monitoring until in compliance

28 Other Monitoring, as Specified by Ohio EPA Notice, in writing, by Ohio EPA if additional monitoring is required of your facility Reason for the monitoring Locations (outfalls) Parameters Frequency Period of monitoring Sample types Reporting requirements Examples: oil and grease at a salvage yard, ph at a ready-mix concrete facility

29 Other Requirements Employee Training At least once per year, but more frequent if employee turnover is high Annual Report Use form in Appendix I of the NPDES permit Keep with SWPPP

30 For Further Guidance on SWPPPs Ohio EPA Guidance documents, record keeping templates, sampling guidance StormWater.aspx US EPA SWPPP documents and sector-specific fact sheets Webcasts Check with trade association

31 No Exposure Exclusion Exclusion from Industrial Storm Water Permitting

32 No Exposure (NOE) Exclusion Definition All industrial activity is protected from rain, snow, run off, run on or snow melt In storm-resistant shelter, with some exception Must look at materials, activities and material handling operations Raw, intermediate, by-products, waste products and finished products Material handling equipment, loading/unloading activities, transportation, disposal areas or conveyance systems Past sources of surface contamination that remain on site cause a condition of exposure to exist

33 What is a storm resistant shelter? Completely roofed and walled buildings or structures Structures with only a top cover but no side covers Provided that materials do not otherwise come in contact with run-on or snowmelt and subsequently run off

34 Waste Dumpsters Exposed Not Exposed As long as no material is lost in transfer to truck Not Exposed As long as dumpster is lidded and in good condition (no leaks)

35 Other Exceptions to Storm Resistant Shelters Tanks, drums or barrels Must be sealed with no operational valves Are in good condition No transfer of material to/from container outdoors Above Ground Storage Tanks If separate from vehicle maintenance activities In good condition Secondary containment recommended Adequately Maintained Vehicles Includes non-leaking forklifts, trucks, trailers, etc

36 Determining Exposure Tarps are temporary. To be eligible for NOE, only allowed during renovations/construction Available on a facility-wide basis only Products intended for outdoor use can be exposed Not salt piles or erodible/dissolvable materials For further guidance, see US EPA No Exposure Guidance

37 Exposure or No Exposure? YES MAYBE NO if all loading and mixing occurs under canopy YES

38 No Exposure Certification Must be submitted to Ohio EPA and renewed once every 5 years Certification terminates if conditions or operations change such that pollutants become exposed to storm water

39 Potential Discharge to Surface Water or Storm Sewer System? YES NO Facility falls under the SIC codes or narratives in 40 CFR or OAC (B)(15)? YES No further action NO Exposure of industrial materials or activities to storm water? Submit No Exposure Certification (NOE) Maintain condition of no exposure & resubmit every 5 years YES NO Submit NPDES Permit Application NPDES Application or NOE?

40 For More Information Websites Ohio EPA US EPA NEDO Ohio EPA Contacts Summit, Medina, Portage, Wayne & Ashtabula Dan Bogoevski (330) Cuyahoga, Lake, Lorain, Geauga & Holmes Laura Shriver (330) Stark, Mahoning, Trumbull, Columbiana & Carroll Molly Sunkle (330)