Landing Safely with Stormwater Compliance Presented by: Mary A. Larsen, QSP/QSD, TOR, CPSWQ Stormwater Specialists, Inc.

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1 Association of CA Airports Landing Safely with Stormwater Compliance Presented by: Mary A. Larsen, QSP/QSD, TOR, CPSWQ Stormwater Specialists, Inc. 1

2 It s all about Water Quality Let s Prevent Polluted Discharges 2

3 No worries - This Construction General Permit Overview will keep you signing in the Rain 3

4 GOAL OF THE CLEAN WATER ACT: Make our waters fishable, drinkable & swimmable

5 Recreation Wildlife Freshwater Habitat Industrial Processess Drinking Water Fish Migration & Spawning Marine Habitat Agricultural Supply Commercial & Sport Fishing Estuarine Habitat Groundwater Recharge

6 CA Construction General Permit (CGP) Order # DWQ Adopted September 2, 2009 Effective July 1, 2010 State Water Resources Control Board (2010), Order DWQ, NPDES General Permit No. CAS Stormwater Year: July 1 June 30 6

7 FACILITIES COVERED BY NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) GENERAL PERMIT FOR STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITIES (GENERAL PERMIT) Transportation Facilities: Facilities with SICs 40XX through 45XX (except ) and 5171 with vehicle maintenance shops, equipment cleaning operations, or airport deicing operations. Only those portions of the facility involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication) or other operations identified under this Permit as associated with industrial activity. 7

8 Permit Discharge Prohibitions 8

9 Discharge Prohibitions Sediment & Pollutants Material Waste & Trash 9

10 Discharge Prohibitions Prohibits the discharge of any discharge of oil, grease or sediment from a construction site. 10

11 Discharge Prohibitions This permit authorizes certain discharges provided they meet the following conditions: Comply with BMPs as described in the SWPPP Filter or treat, using appropriate technology, all dewatering discharges from sedimentation basins Meet the NALs for ph and turbidity Not cause or contribute to a violation of water quality standards Authorized non-storm water dewatering discharges may require a dewatering discharge permit (Low Threat Discharge Permit may be required). May be flushing of water or fire lines 11

12 Summary of Significant Changes Effluent Standards ph from Concrete Washouts Turbidity in runoff 12

13 Summary of Significant Changes Sampling for Risk Levels/Types 2 & 3 Technology-Based Numeric Action Levels (NALs) The General Permit includes NALs for ph and Turbidity ph NAL = Turbidity NAL = 250 NTU 13

14 ph Measure of the acidity/basicity of water Measured on a scale of 0 14 Expressed in ph units Receiving waters tend to be in the range of 5 9 Field of Lab measurement 14

15 Turbidity An expression of the optical properties of a liquid that causes light rays to be scattered and absorbed rather than transmitted in straight lines through a sample Expressed in Nephelometric Turbidity Units (NTUs) Field or Lab measurement 15

16 Training for QSPs & QSDs Qualified SWPPP Practitioner (QSP) Qualified SWPPP Developer (QSD) 16

17 Risk Determination - Combined LOW MED HIGH LOW Level 1 Level 2 HIGH Level 2 Level 3 17

18 Post-Construction Storm Water Specifies runoff reduction requirements for all sites not covered by a Phase I or Phase II MS4 NPDES Permit. One of the goals of the CGP is to match the Pre & Post Development runoff. Pre-Development Post-Development 18

19 Summary of Significant Changes Rainfall Erosivity Waiver Allows small construction site (>1 and <5 acres) to self-certify if the rainfall erosivity value (R value) for their site's given location and time frame compute to be less than or equal to 5. Minimum Requirements Specified This Construction General Permit (CGP) imposes more minimum BMPs and requirements than the previous Permit. 19

20 Summary of Significant Changes Emergency Construction In the case of a public emergency that requires immediate construction activities, a discharger shall submit a brief description of the emergency construction activity within 5 days of the onset of construction, and then shall submit all Permit Registration Documents within 30 days. 20

21 Annual Reporting All dischargers shall prepare and electronically submit an Annual Report no later than September 1st of each year Includes storm water monitoring information A summary of all violations All corrective actions taken during the compliance year An evaluation of all sampling and analysis results Employee Training Documentation 21

22 Activities Covered Under the Permit Any construction or demolition activity, including, but not limited to, clearing, grading, grubbing, or excavation, or any other activity that results in a land disturbance of equal to or greater than one acre. Construction activity that results in land surface disturbances of less than one acre if the construction activity is part of a larger common plan of development or sale of one or more acres of disturbed land. May require a Storm Water Pollution Prevention Plan (SWPPP) 22

23 Construction disturbing 1 acre or more 23

24 Activities Not Covered Under the Permit Routine maintenance to maintain original line and grade, hydraulic capacity, or original purpose of the facility. Disturbances to land surfaces solely related to agricultural operations. Discharges of storm water from areas on tribal lands. Construction activity that disturbs less than one acre of land surface (unless it is part of a larger common plan of development). Best solution may be a Water Pollution Control Program (WPCP) 24

25 Obtaining Permit Coverage The Legally Responsible Person (LRP) must obtain coverage under this Construction General Permit. Typically the LRP is the Property Owner, except in limited circumstances: Where the construction of pipelines, utility lines, fiber-optic cables, or other linear underground/overhead projects will occur across several properties, the utility company, municipality, or other public or private company or agency that owns or operates the linear underground/overhead project is responsible. USACE can designate their Prime Contractor as the LRP. And where there is a lease of a mineral estate (oil, gas, geothermal, aggregate, precious metals, and/or industrial metals), the lessee is responsible for obtaining coverage under the General Permit. 25

26 Legally Responsible Person (LRP) Property Owners Municipalities 26

27 CA Construction General Permit Stormwater Training Program Permit Enforcement #2 27

28 Our chief goal is compliance, not enforcement. But what we have found is that without a strong enforcement program, we cannot reasonably expect compliance. 28

29 State Administrative Penalties Maximum State Penalties $10,000 per day per violation, plus $10/gallon of sediment - laden or polluted water discharged for each violation Minimum Amount is the economic savings of the violation 29

30 Recent $1.3 Million Dollar Non-Discharge Good Site Management / Housekeeping Violation 30

31 $10, Per Day Per Violation 31

32 The Water Boards have a number of enforcement options to address storm water violations Informal Enforcement Verbal Warning (Rare) Staff Enforcement Letter Notice of Violation All violations compel action within a specific time frame. 32

33 Related Laws and Considerations Section Clean Water Act Issued by United States Army Corps of Engineers (USACE) Individual Permits & Nationwide Permits Section Clean Water Act Issued by CA Regional Water Quality Control Boards 33

34 Fish & Game (not too happy) 34

35 Beware of Air Quality Violations 35

36 CA Construction General Permit Stormwater Training Program Erosion Control - #3 36

37 What is Erosion? Soil erosion is the process by which soil particles become detached by water, wind, or gravity and are transported from their original location 37

38 Just Remember Splash Erosion Each raindrop in a storm event strikes the ground at a speed of 5-20 miles per hour, dislodging far greater than its own weight in soil, depending on the type of ground it strikes.

39 Erosion & Sedimentation Process

40 Construction Company September October October October Novembe r SR4 Bypass Authority - Marsh Creek RHMA S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S BY DESCRIPTION Job Start-Up Award CCC Contracts CCC / Teichert X X X Submittals Teichert/CCC X X X X X Railroad Permit???? Teichert X X X X X X X Caltrans Permit???? Teichert X X X X X Water Pollution Control WPCP Submittal & Approval SWS/CCC X X X X X X X Implement BMP's / WPCP Teichert X X Maintain BMP's Teichert X X X X X X X X X X X X X X X X X X X X X X Street Sweeping Teichert X X X X X X X X X X X X X X X X X Remove BMP's Teichert Paving Preparations Construction Area Signs Teichert X X Grind Conforms Teichert X X X Grind WV's, MH's,...etc. Teichert X X X Paving Pave Section 1 Teichert X X X X Pave Section 2 Teichert X X X X Pave Section 3 Teichert X X X X Pave Section 4 Teichert X X X X X X Job Finishing's Shoulder Backing Teichert X X Raise Iron Teichert X X X Lift MBGR PC&N X X X Stripe / Markers Chris 40

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42 BMP Toolbox Erosion Control SOIL STABILIZATION Control Raindrop, Sheet and Rill Erosion Graded Areas Slopes Protect Surface Strengthen Subsurface Vegetative Soil Cover Non-Vegetative Cover Structural Bio Technical Temporary Seeding Permanent Seeding Topsoiling Sodding Protecting Vegetation Rec. Area Improvement Mulching Riprap Slope Protection Retaining Wall Land Grading Surface Roughening Streambank Protection Wattling Brush Matting Streambank Protection Dune Stabilization 42

43 For inactive areas per Permit: Inactive areas of construction are areas of construction activity that have been disturbed and are not scheduled to be re-distributed for at least 14 days Finished slopes Open space Utility backfill Completed lots 43

44 Control the air deposition of site materials & from site operations. Such particulates can include: Sediment Nutrients Trash Metals Bacteria Oils, grease, fuels Organics 44

45 Water for dust suppression DUST CONTROL IS ALSO REGULATED BY AIR QUALITY DISTRICTS 45

46 CA Construction General Permit Stormwater Training Program Sediment Control - #4 46

47 What Is Sedimentation? Sedimentation is the deposition of eroded materials 47

48 Sedimentation Impact on Creeks & Rivers

49 BMP Toolbox Sediment Control SEDIMENT CONTROL Protect Off-Site Areas Large Areas Small Areas Convey Sediment Retain Sediment Sediment Basins/Traps Filter Sediment Sediment Filters Mud and Dust Control Rock Dam Check Dam Debris Basin Portable Sediment Tank Embankment Sediment Basin Straw Bale Dike Storm Drain Inlet Filter Silt Fence Stabilized Construction Entrance Dust Control Fill/Excavated Sediment Traps Pipe Outlet Sediment Trap Waterway Crossing Construction Road Stabilization 49

50 These things are illegal to discharge to Waters of the State Soil, Dirt and Sediment Paints and Solvents Pesticides and Herbicides Fertilizers Detergents Plaster or related products Concrete compounds Asphalt compounds Petroleum products fuel, oil, and grease Hazardous chemicals acids, lime, glues, adhesives and curing compounds *** Remember, sediment can be a carrier for other construction site pollutants

51 Goal: An Effective Combination of Erosion & Sediment Controls Erosion control: Is the Primary BMP Practice that keeps the soil from dislodging & migrating from it s original place Sediment control: Is the Secondary BMP Practice that traps soil particles after they have been dislodged by wind or runoff

52 CA Construction General Permit Stormwater Training Program #5 - Construction Inspections 52

53 Visual Inspections All Projects 53

54 Visual Monitoring by Risk Traditional Projects BMP Inspections Weekly (Level 1, 2, 3) Storm event triggered Inspections 48-Hour Pre and 48-Hour Post Inspections (Level 1, 2, 3) 24-Hour Inspections during extended rain events (Level 1, 2, 3) Quarterly Non-Stormwater Inspections (Level 1, 2, 3) 54

55 BMP Inspection Response Initiate correction of deficiencies within 72 hours of identification Complete corrective actions as soon as possible 55

56 Traditional Projects: Inspections & Visual Site Monitoring Requirements are the same for all Risk Levels Qualifying Rain Event Triggered Inspections Pre-Rain Event; within 48 hours in advance of predicted event Implement when NOAA predicts a probability of precipitation of 50% or more in the project area Post-Rain Event; within 48 hours following an actual event Required during normal construction site business hours * Per NOAA a minimum of 48 hours of dry weather will be used to distinguish between separate rain events Qualifying Rain Event Rain event that produces ½ inch or more of precipitation within a period of 48 hours or more between rain events. 56

57 All Risk Levels have the same 5 minimum requirements: Dischargers shall ensure that all inspection, maintenance repair and sampling activities at the project location shall be performed or supervised by a Qualified SWPPP Practitioner (QSP) representing the discharger. The QSP may delegate any or all of these activities to an employee trained to do the task(s) appropriately, but shall ensure adequate deployment. 57

58 Monitoring Safety Exception Monitoring is not required during dangerous weather conditions (flooding, electrical storm) When the site/sampling locations are unsafe to access due to the storm event Outside of normal construction site operation hours Sampling locations need to be selected with due consideration of safe wetweather access Monitoring not completed due to safety factors must be documented and reported 58

59 For Traditional Risk Level 2 & 3 Projects We are all Weather People 59

60 The discharger shall ensure a QSP develop a Rain Event Action Plan (REAP) 48 hours prior to any likely precipitation event. A likely precipitation event is any weather pattern that is forecasted to have a 50% or greater probability of producing precipitation in the project area. The discharger shall ensure a QSP obtain a printed copy of precipitation forecast information from the National Weather Service Forecast Office (e.g. by entering the zip code of the project s location at 60

61 Inspections & Sampling - Traditional Projects Risk Level Visual Non-Visible Pollutant Effluent Receiving Water Level 1 Yes As needed Where applicable Not required Level 2 Yes As needed ph, turbidity Not required Level 3 Yes As needed ph, turbidity May need to sample 61

62 CA Construction General Permit Stormwater Training Program #6 -Pollution Prevention 62

63 The discharger shall ensure that the Storm Water Pollution Prevention Plans (SWPPPs) for all Project sites are developed and amended or revised by a QSD. The SWPPP is designed to address the following objectives: All pollutants and their sources, including sources of sediment associated with construction, construction site erosion and all other activities associated with construction activity are controlled. 63

64 By Risk/Type Level The Permit identifies 5 categories of year-round minimum BMPs: 1) Good site management/ housekeeping 2) Non-Stormwater Management 3) Erosion Control 4) Sediment Controls 5) Run-on/ Run-off controls And there can sometimes be a 6 th category 6) Unique Situations 64

65 This active stockpile will be covered with plastic prior to rain event and may need perimeter controls to prevent discharges Cover materials to protect from rain remember no exposure no sampling! 65

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67 Install and maintain a good construction entry. Don t stage materials where accessing them results in tracking. 67

68 Waste Management A. Prevent rinse water or materials on impervious or previous site surfaces into storm drain B. Ensure the containment of sanitary facilities to prevent discharge C. Clean or replace sanitation facilities to prevent discharge D. Cover waste disposal containers at the end of every day & prior to rain event E. Prevent discharges from waste disposal containers F. Contain & securely protect stockpiled waste materials from wind & rain at all times unless actively being used G. Implement procedures that effectively address hazardous materials H. Develop a spill response element of SWPPP I. Ensure the containment of concrete washout areas & other washout areas to prevent discharge to underlying soil 68

69 Or materials on impervious or pervious site surfaces or into storm drain system. 69

70 Sited appropriately site away from an inlet or drainage way Anchored down Provide Secondary Containment 70

71 Use designated area Proper BMPs 71

72 No Sediment No Oil No Concrete, Stucco and Mortar Wastes No Septic Wastes No Petroleum Products No Paint Residues No Litter/ Trash/ Solid Waste Only Rain in the Drain 72

73 Mechanically and/or manually sweep all streets, runways and adjacent roadways. 73

74 CA Construction General Permit Stormwater Training Program #7 - State SMARTS Reporting & Notice of Termination (NOT) 74

75 SMARTS Stormwater Multi-Application Reporting & Tracking System Reporting Acronyms PRD Permit Registration Documents NOI Notice of Intent LRP Legally Responsible Person NAL Numeric Action Level 75

76 What is SMARTS? Purpose: Provide a platform where dischargers, regulators, and the public can enter, regulate, and/or comment on storm water data including NOIs, NOTs, compliance, and monitoring data. Internet-based Available 24/7 Reports SWRCB/RWQCB prioritize regulatory tasks (i.e. inspections, view trends in compliance, provide data to the Legislature) Public reports NOI, Inspections, Violations, and Enforcement data 76

77 SMARTS Users State & Regional Water Board Staff External Users Legally Responsible Person (LRP) Approved Signatory Data Submitters General Public 77

78 LRP Primary Account Holder Approved Signatory Enter & Certify Data Data Submitter Enter data only General Public Download & Print 78

79 SMARTS PRD Process Register for SMARTS account Link Approved Signatories/Data Submitters File new NOIs Upload attachments Enter Sampling/Monitoring Data Notice of Termination 79

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81 NOT Photos 81

82 NOT Final Site Plan/As-Built 82

83 70% Vegetative Coverage Project applicant must demonstrate 70% vegetative coverage based on pre-project conditions Example: If pre-project vegetative coverage equals 50%, standard equals 0.7 x 50%, or 35% 83

84 Landing Safely Questions & Discussion 84