Industrial Storm Water Inspections Implementation

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1 Industrial Storm Water Inspections Implementation Martin Miller, Industrial Compliance Supervisor Texas Storm Water Conference September 24, 2018

2 September 24, 2018 Page 2 Four Major Key Elements to a Successful Industrial Storm Water Inspection Introduction Documentation Review Site Assessment Exit Interview

3 September 24, 2018 Page 3 Multi-Sector General Permit (MSGP) Am I regulated? If you discharge storm water associated with an industrial activity into a storm water conveyance that is part of a municipal separate storm water sewer system (MS4) or to surface water in the state; and your business activity fits into one (or more) of the regulated industrial sectors.

4 September 24, 2018 Page 4 Introduction Face to face contact with the inspector Credentials Contact information Explain type of audit being conducted Professional working relationship Focus on Water Quality

5 September 24, 2018 Page 5 Documentation Review Be prepared by researching company. Use TCEQ database to check history. If an existing file, review material. Check last inspection. Look at a satellite view of the facility. Know the material specific to the SIC!

6 September 24, 2018 Page 6 Co-Located Activities and Facilities Co-Located Activities Industrial activities at a facility that are described by more than one Code Must comply with all sector-specific requirements for each SIC representing colocated activities at site Sector-specific requirements apply only to portion of facility where that specific sector activity occurs Except where runoff from different activities combines before leaving the property Monitoring requirements and Effluent Limitations from each contributing sector must be met

7 September 24, 2018 Page 7 Co-Located Activities and Facilities Co-Located Facilities Multiple industrial facilities sharing a common property boundary Operators of each co-located facility must individually obtain authorization under the MSGP May either develop a separate Stormwater Pollution Prevention Plan (SWP3) or may participate in a shared SWP3 Site map delineate boundaries around each co-located facility AND boundaries around shared/common areas that are used by two or more facilities

8 September 24, 2018 Page 8 Multi-Sector General Permit TXR Copy of the permit Standard Industrial Classification (SIC) North American Industry Classification System (NAICS)

9 September 24, 2018 Page 9 Multi-Sector General Permit Be familiar with Parts of the MSGP Part I. Part II. Definitions Permit Applicability and Coverage Part III. Permit Requirements and Conditions Common to All Industrial Activities Part IV. Part V. Benchmark Monitoring Requirements Specific Requirements for Industrial Activities

10 September 24, 2018 Page 10 Industrial Activities SIC Code s or Standard Industrial Codes Noted within the TXRO50000 Regulations Relationship between SIC and NAICS TCEQ primarily lists Industry by SIC Code NAICS are more descriptive Listed activities specific to code

11 September 24, 2018 Page 11 NAICS NORTH AMERICAN INDUSTRIAL CLASSIFICATION SYSTEM

12 September 24, 2018 Page 12 TEXAS SALES TAX CERTIFICATE

13 September 24, 2018 Page 13 SIX-DIGIT NAICS # appears on the State Sales Tax Wood Container and Pallet Mfg. This industry comprises establishments primarily engaged in manufacturing wood pallets, wood box shook, wood boxes, other wood containers, and wood parts for pallets and containers.

14 September 24, 2018 Page 14 Definitions All definitions in Section of the Texas Water Code and 30 TAC Chapter 305 shall apply to the permit and are incorporated by reference. Grab Sample: An individual sample collected in less than 15 minutes. Notice of Intent: A written submission to the executive director from an applicant requesting coverage under a permit.

15 September 24, 2018 Page 15 No Discharge to Surface Waters Facility Does Not Discharge Stormwater to MS4 or Surface Waters May not be required to obtain coverage under MSGP Must demonstrate that facility will not discharge stormwater associated with industrial activity Facilities disposing of industrial stormwater in the following ways are not required to obtain coverage under MSGP nor under individual TPDES/NPDES permit: Recycling stormwater for use on-site Discharge to POTW Discharge to above ground storage tank Containment on site Pumping/hauling to authorized disposal facility Underground injection

16 September 24, 2018 Page 16 Permit Requirements and Common Conditions to all Industrial Sectors Section A Section B Section C Section D Section E Minimum SWP3 Requirements Inspection of SWP3 and Site Numeric Effluent Limitations General Monitoring and Records Requirement Standard Permit Conditions

17 September 24, 2018 Page 17 Benchmark Monitoring Use of Benchmark Data Sectors Subject to Benchmark Monitoring Benchmark Monitoring Requirements

18 September 24, 2018 Page 18 Specific Requirements for Industrial Activities Requirements in the MSGP are sector specific In addition to the requirements in Parts III and IV. Thirty Industrial Sectors identified in the MSGP.

19 September 24, 2018 Page 19 Site Assessment Site presentation is priceless Inspectors are looking at the obvious Keep outfall(s) clean and free of debris Material needs to be stored with Best Management Practices (BMPs) in mind: Raw Material Intermediate Products Byproducts Waste Products Final Products

20 September 24, 2018 Page 20 No Exposure Exclusion Purpose and conditions Storm resistant shelter Industrial materials & activities Allowable items & discharges Permit application Pictures

21 September 24, 2018 Page 21 Storm Resistant Shelter Structure with complete roof and walls Roof-only structure with run-on protection

22 September 24, 2018 Page 22 Storm resistant shelter Protection from run-on provided

23 September 24, 2018 Page 23 Allowable Items Drums/tanks Sealed: no operational valves Good condition: no leaks Storage only: no filling or withdrawing Aboveground Storage Tanks No leaks Containment recommended Lidded dumpsters

24 September 24, 2018 Page 24 Allowable Items Well-maintained vehicles Final products intended for outdoor use Won t mobilize or oxidize Pallets in good condition

25 September 24, 2018 Page 25 Items to work on or remove No Exposure

26 September 24, 2018 Page 26 Materials exposed

27 September 24, 2018 Page 27 Materials exposed

28 September 24, 2018 Page 28 Exposure to run-on

29 September 24, 2018 Page 29 Loading dock exposed Vs. sheltered

30 September 24, 2018 Page 30 Good practices

31 September 24, 2018 Page 31 Obtain NEC Permit Complete No Exposure Certification (TCEQ form 10383) electronically or by mail to TCEQ Submit a copy to MS4 operator Submit NOT for previous MSGP coverage Maintain condition of no exposure conditional

32 September 24, 2018 Page 32 Why Sample? Determine effectiveness of storm water management Qualitative feedback Quantitative feedback Improve quality of the states surface water Required under the permit

33 September 24, 2018 Page 33 Purpose/reasoning of sampling Determining outfalls Sampling types Reporting requirements Qualifying rain events Sample preparation

34 September 24, 2018 Page 34 Why Sample?

35 September 24, 2018 Page 35 Determining Outfalls Outfall A point source where storm water runoff associated with industrial activity discharges Finding concentrated storm water exits Sheet flow Storm drain inlets Commingling water

36 September 24, 2018 Page 36 Substantially Similar Outfalls TPDES Part III, Section C(2) Industrial Activities Control measures Amount of flow Surface similarity Written description of outfall locations

37 September 24, 2018 Page 37 Sampling Types Quarterly Visual Benchmark Numeric Effluent Limits (Hazardous Metals) Sector Specific Effluent Limits

38 September 24, 2018 Page 38 Quarterly Visuals TPDES Part III, Section A(5)(h) Required quarterly all sectors Collect grab samples in glass bottle Assess general appearance Color Settled Solids Suspended Solids Oil Sheen Odor Clarity Floating Solids Foam Other indicators

39 September 24, 2018 Page 39 Quarterly Visuals

40 September 24, 2018 Page 40

41 September 24, 2018 Page 41 Qualifying Rain Events TPDES Part III, Section C At least 0.1 of rain Discharge occurs at outfall At least 72 hours since the last qualifying event Collect samples within the first 30 minutes of discharge (within 60 minutes with documentation as to reasons why) Keep rain log for documentation purposes

42 September 24, 2018 Page 42 Sector M of Multi-Sector General Permit (MSGP) Best Management Practices (BMPs) City Code of Ordinances (Chapter 16) Qualifications for license with the City of San Antonio

43 September 24, 2018 Page 43 Multi-Sector General Permit Spill Prevention & Response Measures Sector M.3 (pg.113) states.. Vehicles shall be inspected for leaking fluids upon arrival at the facility Actions shall be immediately taken to prevent the discharge of fluids according to specific measures established

44 September 24, 2018 Page 44 Multi-Sector General Permit Employee Training Program and Employee Education Employee training shall include training on the following operations at the facility Used oil and spent solvent management Management of metal filings and dust from welding, grinding, and similar operations Lead-acid battery management

45 September 24, 2018 Page 45 Poor BMPs and Spill Response Measures (Fluid Draining)

46 September 24, 2018 Page 46 Poor BMPs and Spill Response Measures (Fluid Draining)

47 September 24, 2018 Page 47 Poor BMPs and Spill Response Measures (Fluid Draining)

48 September 24, 2018 Page 48 Poor BMPs and Spill Response Measures (Car Crushers)

49 September 24, 2018 Page 49 Poor BMPs and Spill Response Measures (Car Crushers)

50 September 24, 2018 Page 50 BMPs and Spill Response Measures (Car Crusher pad and curbing)

51 September 24, 2018 Page 51 Periodic Inspections and Good Housekeeping Measures Periodic Inspections (Sector M) Equipment containing hydraulic or other fluids shall be inspected for leaks during the periodic inspections. Good Housekeeping Measures Equipment operators must conduct inspections of equipment on a daily basis when equipment is in use.

52 September 24, 2018 Page 52 Poor BMPs and Spill Response Measures (Inspection of Equipment)

53 September 24, 2018 Page 53 Poor BMPs & Spill Response Measures (Simple Housekeeping) Open top & spillage

54 September 24, 2018 Page 54 Good BMPs and Spill Response Measures (Simple Housekeeping)

55 September 24, 2018 Page 55 Initial and Final Vehicle Break-Down Area

56 September 24, 2018 Page 56 Covered Work Area from the Elements Removal of tires, mags, batteries, mercury switches, bulbs, fluids (oil, gas, transmission and brake fluid)

57 September 24, 2018 Page 57 Recycling Activities Oil & Fuel Removal Battery Packaging Mag Rims Alternators Drains Aluminum Waste Oil Casting Aluminum and Copper Lead Lead

58 September 24, 2018 Page 58 Essential BMP: Car Lift Allows Mechanics Easy Access Removal of fluids such as Gasoline, Oil, Transmission, Brake Fluid, etc.

59 September 24, 2018 Page 59 Spill Containment & Containers Oil catch pans Fuel draining Concrete pad

60 September 24, 2018 Page 60 Vehicle Yard Placement BMP Extending the Width Between Vehicle Roles for cleaning ease

61 September 24, 2018 Page 61 BMP Yard Clean-Up Work-Cart

62 September 24, 2018 Page 62 Vehicle Crushing Unit Approximately vehicles are crushed daily

63 September 24, 2018 Page 63 Outside Final Breakdown Slab BMP Inlet for storm water and vehicle fluid spillage from dismantling activities

64 September 24, 2018 Page 64 Reuse, Recycling, Reduction Auto Salvage Facility Car parts reuse & recycling Gasoline, Oil, Antifreeze, Brake Fluid, Windshield Fluid reuse & recycling Pollutants Switches - Mercury Radiator, Rims, A/C Condenser & Evaporator Coils and Compressor- Aluminum Battery Lead Catalytic Converter, Exhaust Piping & Mufflers Alternator, Starter, Wiring - Copper A/C System Oil and Freon Engine, Transmission, Drive Shaft, Exhaust Manifold & Final Crushed Vehicle Steel Anything not sold and/or not mentioned

65 September 24, 2018 Page 65 Must obtain license with the City of San Antonio to operate salvage yard site. Sec : No dealer may operate a salvage yard, within the city limits without a valid license. Must renew license annually Cannot receive license with the City of San Antonio unless the facility has a Letter of Compliance from SAWS. Local ordinance is more stringent due to: High risk of industry Ongoing struggle to maintain compliance at Salvage Yards (historical compliance of industry)

66 September 24, 2018 Page 66 City Code of Ordinance (Chapter 16) Storage; Waste Containment; Maintenance; Fire Lane (Sec )

67 September 24, 2018 Page 67 Exit Interview Inspector will provide a summary of findings: Violations Compliance status Recommendations and tips Timelines to make necessary corrections Notification of re-inspection

68 September 24, 2018 Page 68 Conclusion Master the four keys and experience a successful storm water audit. Be positive and prepared. Ask questions if you are not certain about something. Maintain accurate records and know where you have stored these documents. Keep current with regulations.

69 Industrial Storm Water Inspections Implementation Martin Miller, Industrial Compliance Supervisor Texas Storm Water Conference September 24, 2018