Solving Your Stormwater Compliance Challenges

Transcription

1 Solving Your Stormwater Compliance Challenges Presented by: Tory R. Walker, PE, CFM, LEED GA, QISP Alex J. Smith, MS, EIT, QISP 11/03/2017

2 Welcome & Introductions Tory R. Walker, PE, CFM, LEED GA, QISP

3 The Basics, The Not-So-Basic Basics & Monitoring Madness Alex J. Smith, MS, EIT, QISP

4 The Basics

5 The Big Picture

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9 The Framework

10 The Water Boards

11 You re from where? Industrial General Permit Municipal Stormwater Permit YOUR BUSINESS City Ordinances

12 The Industrial General Permit (IGP)

13 The IGP California Industrial General Permit (IGP) Regulates operators of facilities (Dischargers) that discharge storm water associated with industrial activity (industrial storm water discharges) Evolution pages pages pages Effective July 1, 2015

14 Standard Industrial Classification (SIC)

15 The SIC Code Standard Industrial Classification (SIC) 4-digit code Classifies your industrial activities

16 { The SIC Code Standard Industrial Classification (SIC) Example: Major Group 3272 { Industry Group 32XX = Stone, Clay, Glass, And Concrete Products 327X = Concrete, Gypsum, And Plaster Products 3272 = Concrete Products, Except Block and Brick

17 The Not-So-Basic Basics

18 Filing for Coverage Nuanced Process SMARTS Tax ID Imperviousness Receiving Water TMDLs Pay the Fee

19 SMARTS

20 Permit Registration Documents (PRDs)

21 PRDs Permit Registration Documents (PRDs) 1. NOI 2. Signed Electronic Authorization Form 3. Site Map 4. Storm Water Pollution Prevention Plan (SWPPP) Must be electronically submitted by LRP $1,691 Annual Fee

22 Site Map

23 Site Map facility boundary storm water drainage areas within the facility boundary portions of any drainage area impacted by discharges from surrounding areas and flow direction of each drainage area on-facility surface water bodies areas of soil erosion location(s) of nearby water bodies (such as rivers, lakes, wetlands, etc.) location(s) of municipal storm drain inlets that may receive the facility s industrial storm water discharges and Authorized NSWDs locations of storm water collection and conveyance systems and associated points of discharge, and direction of flow any structural control measures (that affect industrial storm water discharges, authorized NSWDs, and run-on) all impervious areas of the facility, including paved areas, buildings, covered storage areas, or other roofed structures locations where materials are directly exposed to precipitation locations where significant spills or leaks identified have occurred; areas of industrial activity subject to this General Permit all storage areas and storage tanks; shipping and receiving areas fueling areas vehicle and equipment storage/maintenance areas material handling and processing areas; waste treatment and disposal areas; dust or particulate generating areas; cleaning and material reuse areas; and, any other areas of industrial activity which may have potential pollutant sources

24 Site Map

25 Site Map

26 Site Map

27 Site Map

28 What s Next? Remain compliant Await inspection SMARTS is public

29 Stormwater Pollution Prevention Plan (SWPPP)

30 The Big Idea

31 SWPPP Contents Site Map List of Industrial Materials Description of Potential Pollution Sources Assessment of Potential Pollution Sources Minimum BMPs Advanced BMPs (if applicable) Monitoring Implementation Plan Annual Evaluation

32 SWPPP Performance Standards 1. Identify & Evaluate: o o All sources of pollutants Minimum BMPs 2. Keep & Maintain hard copy on-site

33 SWPPP Performance Standards

34 Pollution Prevention Team Established & Responsible for assisting with IGP implementation (SWPPP) 1. Team Members 2. Responsibilities, Duties, and Activities 3. Alternates

35 Best Management Practices (BMPs)

36 Best Management Practices BMPs include: Scheduling of activities Prohibitions of practices Maintenance procedures Other management practices to prevent or reduce the discharge of pollutants.

37 7 Minimum BMPs Good Housekeeping Preventive Maintenance Spill and Leak Prevention and Response Material Handling and Waste Management Erosion and Sediment Controls Employee Training Program Quality Assurance and Record Keeping

38 Advanced BMPs Exposure Minimization BMPs Containment and Discharge Reduction BMPs Treatment Control BMPs Other Advanced BMPs

39 Advanced BMPs Exposure Minimization BMPs Containment and Discharge Reduction BMPs Treatment Control BMPs Other Advanced BMPs

40 Who Cares?

41 The Stormwater Elite 1. State Water Resources Control Board 2. Regional Water Quality Control Board 3. Municipalities 4. Environmental Groups 5. Attorneys 6. Citizens Failure to enroll Mandatory minimum $5,000 penalty RB enforcement up to $10,000 per violation, per day Citizen suit up to $34,500 per violation, per day

42 Monitoring Madness

43 The Routine 1. BMPs daily 2. Adjust accordingly 3. Observe monthly 4. Sample eventually 5. Report annually

44 Monitoring Within each drainage area o o o Your Responsibilities Monthly Visual Observation Log BMP Inspection Report Sampling Event Observation Log Sampling During QSEs at each discharge location o o o Sampling Technique Chain of Custody (CoC) Laboratory Data

45 Site Scenario

46 Precious Precast

47 Weather Forecast

48 NOAA Weather Report

49 Visual Observations

50 Visual 11/6/17 Observations 8:00 a.m. 11/6/17 Precious Precast Cloudy, ~60-65 F Cloudy, 67 F Silted ribbon drain; sediment was disposed by staff. Open dumpster; lid closed. Alex Smith Environmental Compliance Alex Smith 11/6/17

51 11/6/17 9:00 a.m. 11/6/17 Precious Precast Pechanga Parkway, Temecula, CA Libraries\Pictures\BMP_ Months Alex Smith Environmental Compliance Alex Smith 11/6/17

52 Clean ground cover Covered materials Covered waste bins Y N Y Y N Y Motorized equipment serviced N N Stocked spill kit N N Clean dumpster area Y Y Stabilized erodible areas N N

53 N/A N/A N/A N/A

54 Ribbon drain silted Y Disposed of sediment on 11/6/17 Uncovered waste bins Y Closed immediately on 11/6/17 Trash on ground Y Disposed trash on 11/6/17 Staff trained on noted deficiencies 11/6/17

55 Sampling Events

56 Laboratory Standards ELAP Certified Test Methods Lab-Issued Containers ph Communication Customer Service

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58 Pollutant Source Assessment 1. Standard Pollutants TSS, ph, Oil & Grease 2. SIC Code 3272 Iron 3. Facility-Specific Industrial Pollutants 4. Watershed 303(d) Impairments o Chlorpyrifos, Copper, Phosphorus, TDS, Toxicity 5. Regional Board Requirements 6. Additional parameters subject to Subchapter N

59 QSE Definition During regular business hours No discharge during preceding 48 hours At least one drainage area discharges Within four hours of storm beginning Four Sampling Events Twice between July 1 st to December 30 th Twice between January 1 st to June 30 th

60 Precious Precast

61 Technique & Prep IGP Appendix H Supplies o o o o Lab-Issued Containers Chain of Custody Assistance Mechanisms Cooler Technique o o Grab samples (fairly easy) Sheet flow (very difficult)

62 EPA Fe SM-2540-D 1 1 Precious Precast Alex Smith Alex Smith Somewhere in Temecula PRECAST alex@preciousprecast.com Somewhere Else in Temecula x x POC-1 11/6/17 12:15 SW 3 x x x POC-2 11/6/17 12:15 SW 3 x x x Alex Smith Alex Smith Precious Precast 11/6/17 1:00 p.m.

63 Precious Precast 11/6/17 1:00 p.m. 11/7/17 Cloudy; no rain Light rain; 58 F NOAA.gov Cloudy; no rain 11/6/17 12:00 p.m. 0.5 Months 60% N/A Sediment from unpaved areas in DA 1 Sheen in runoff from parking area in DA 1 N/A Drainage Area 1 Drainage Area 2 none none

64 N/A Alex Smith Environmental Compliance Alex Smith 11/6/17

65 Precious Precast 11/6/17 12:15 p.m. Alex Smith N/A Litmus Paper POC-1 POC :15 p.m. 12:25 p.m. POC-1 POC-2 Oil & Grease, TSS, Fe 12:15 p.m. 12:25 p.m. Photos of litmus paper at time of sample acquisition: 11/6/17_pH_POC-1 11/6/17_pH_POC-2 12:30 p.m.

66 After the Sample Transport to lab Acquire new supplies Await sample results Internally assess data then address cause(s) Upload data to SMARTS within 30 days Ad Hoc reporting Repeat process at least three more times

67 The Results Are In Parameter POC-1 POC-2 ph TSS 328 mg/l 295 mg/l O&G 12 mg/l 9 mg/l Fe 0.89 mg/l 0.92 mg/l Parameter Annual NAL Instantaneous Max NAL ph N/A <6.0 or >9.0 TSS 100 mg/l 400 mg/l O&G 15 mg/l 25 mg/l Fe 1.0 mg/l N/A

68 The Results Are In Parameter POC-1 POC-2 ph TSS 328 mg/l 295 mg/l O&G 12 mg/l 9 mg/l Fe 0.89 mg/l 0.92 mg/l Parameter Annual NAL Instantaneous Max NAL ph N/A <6.0 or >9.0 TSS 100 mg/l 400 mg/l O&G 15 mg/l 25 mg/l Fe 1.0 mg/l N/A

69 Closing out the Year Internally assess data then address cause(s) Upload data to SMARTS within 30 days Ad Hoc reporting Repeat process at least three more times Annual Comprehensive Facility Compliance Evaluation (Annual Evaluation) Annual Report due July 15 th Exceedance Response Actions Pay annual fee

70 Hot Tips 1. Know your pollutants 2. Understand your site drainage patterns 3. Build trust-based relationship with lab 4. Assign sampling responsibilities 5. Learn how to sample properly 6. Collect your samples at the right time 7. Get help if you're overwhelmed

71 Closing Thoughts

72 Questions Tory Walker (760) Alex Smith (760)