American Public Works Association May 3, 2010 Southern California Chapter

Transcription

1 American Public Works Association New Construction General Permit Overview Presented by Jason Uhley, P.E. Riverside County Flood Control and Water Conservation District and Jeff Endicott, P.E., BCEE, CPESC AEI-CASC Consulting Purpose of Today s Presentation To discuss storm water management options for public works construction by MS4 Permittees in the Whitewater River Watershed To introduce the newest incarnation of the California General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities This is a brief introduction! The SWRCB approved training is looking to be 3 full days! To highlight hli ht significant ifi differences between the current and new Construction General Permits (CGP) 2 1

2 Whitewater River Watershed Stormwater and Urban Runoff Permit The California Regional Water Quality Control Board Colorado River Region issued a Permit to the following operators of municipal storm drain systems in the Whitewater River Watershed. Includes the following Permittees : Banning Cathedral City Coachella Coachella Valley Water District Desert Hot Springs Indian Wells Indio do La Quinta Palm Desert Palm Springs Rancho Mirage Riverside County Riverside County Flood Control and Water Conservation District 3 Whitewater River Watershed Stormwater and Urban Runoff Permit The Permit Regulates Discharge of stormwater containing pollutants Non-Storm water discharges Requires Permittees to Minimize impacts of urban runoff on receiving waters to the Maximum Extent Practicable (MEP) Specifically implement a program to control water pollution associated with Permittee construction projects And many other things 4 2

3 Whitewater River Watershed Stormwater and Urban Runoff Permit Permittee Construction Projects and Activities Permittees must report to the Regional Board public works construction and activities that would otherwise require coverage under the Construction General Permit Permittees must prepare and implement a SWPPP in accordance with the Construction General Permit The Permit defines the Construction General Permit as General Permit for Storm Water Discharges Associated with Construction Activity; State Board Order No DWQ (NPDES No. CAS000002) The Permittees public works construction and activities are covered by the MS4 Permit. The Permittees may continue with their existing program until the expiration of the Municipal Permit. Effectively, this delays the date when the Permittees must obtain coverage under the new CGP. 5 Construction General Permit History Nominal 5 year terms ~8 years average to reissue DWQ 5 Ac and BMPs DWQ 1 Ac and added Non Visible Pollutant Monitoring DWQ Added Risk Assessment, Online Submittals, Certifications and Training, Numeric Action Level and Effluent Limits 6 3

4 Important Dates! CGP DWQ Permit adopted September 2, 2009 Adoption date is key to several future deadlines Permit effective date is July 1, 2010 CGP DWQ Compliance with this permit is required until effective date of new CGP Coverage terminated automatically on July 1, 2010! Dischargers must file for coverage under the new CGP no later than July 1, 2010 Enforcement activities may continue under the terminated permit 7 Grandfathering Exception Sites with coverage under CGP DWQ are eligible to take advantage of a Grandfathering Exception The Grandfathering Exception Dischargers are not required to complete a Risk Assessment Dischargers obtain coverage under CGP DWQ as Risk Level 1 sites All other provisions of CGP DWQ apply Exception continues until September 2, 2011 The Grandfathering Exception Fine Print Regional Boards retain authority to require a Risk Assessment For sites with a history of non-compliance For sites posing a significant risk of causing or contributing to an exceedance of a water quality standard 8 4

5 Obtaining CGP Coverage Permit Registration Documents (PRDs) must be filed PRDs are filed via a combination of Internet submittal SMARTS - Storm Water Multi-Application Reporting and Tracking System Mail CAUTION SMARTS is not yet available SWRCB FAQ says will be available by July 1, 2010 and may be sooner Coverage commences when a Waste Discharge Identification Number (WDID) has been assigned and sent by SMARTS CAUTION Covered construction activities may not occur prior to obtaining coverage under the CGP! 9 Permit Registration Documents (PRDs) Items filed electronically Notice of Intent (NOI) Risk Assessment Site Map Storm Water Pollution Prevention Plan (SWPPP) Certification Items filed by mail Annual Fee 10 5

6 Notice of Intent (NOI) NOI includes a lot of information About the discharger Name, Taxpayer ID Contact information Physical address, electronic address About the project Size and location Start date About the people involved NOI is completed On-line via SMARTS Legally Responsible Person (LRP) Approved Signatory Data Submitter We won t know all the information required until SMARTS is available! 11 Risk Assessment CGP DWQ mandates a Risk Based Approach Requirements are more stringent for riskier sites Risk Factors Sediment Risk Soil Loss based Revised Universal Soil Loss Equation Map Option Manual Option Receiving Water Risk Sediment sensitivity per the 303(d) list Beneficial uses per the Basin Plan 12 6

7 Risk Assessment Sediment Risk Low: < 15 tons/acre Medium: 15 tons/acre and < 75 tons/acre High: 75 tons/acre Receiving Water Risk High: Disturbed area discharges to A sediment impaired waterbody OR A waterbody with SPAWN & COLD & MIGRATORY beneficial uses Low: All others Medium 13 Site Map(s) Project and vicinity Site layout Boundaries Drainage areas Areas of soil disturbance Temporary and permanent Active areas (cut and fill) Much Site Map more than submitted the Vicinity via Map SMARTS filed with 70 the MB old Limit! paper NOI Locations of Discharges from site Sampling points BMPs Runoff BMPs Erosion Controls Sediment Controls Post-construction BMPs Active Treatment Systems Sensitive habitats, watercourses, etc. not to be disturbed Areas for vehicle, waste, and material storage and servicing Egress and ingress points 14 7

8 Storm Water Pollution Prevention Plan (SWPPP) SWPPP objectives: Control all construction site and construction activity pollutants and their sources Identify and either eliminate, control, or treat non-storm water discharges Present BMPs that are effective and result in the reduction or elimination of pollutants in storm water and non-storm water discharges from construction activity to the BAT/BCT standard Present BMPs, supported by calculations and design details, for control of site run-on Present stabilization BMPs to reduce or eliminate pollutants after construction is completed Present information that supports the conclusions, selections, use, and maintenance of BMPs SWPPP objectives differ from those in CGP DWQ! 15 Storm Water Pollution Prevention Plan (SWPPP) SWPPP must be written, amended, and certified by a Qualified SWPPP Developer SWPPP content is informed by Risk Level Risk Level affects BMPs required Monitoring and reporting Rain event response SWPPPs for Grandfathered projects must fully comply with CGP DWQ for Risk Level 1 SWPPPs prepared under CGP DWQ will likely require some updates SWPPP submitted SWPPPs are Via available SMARTS to the 70 Public MB Limit! via the Internet 16 8

9 Certification PRDs must be electronically signed and certified after submittal to SMARTS Certification must be by: Legally Responsible Person (LRP) OR Approved Signatory (Designated by LRP) SWPPPs must be certified Certification must be made by: Qualified SWPPP Developer Permit is silent on where the Qualified SWPPP Developer certifies the SWPPP (Inside SWPPP? Via SMARTS?) Watch for a future SWRCB FAQ 17 Annual Fee Grandfathered Fees are required to projects obtain submit permit no coverage fee. Submit via mail to the They SWRCB will be invoiced on their current There is currently no option to pay electronically invoice cycle. Mail fee at least 7 days prior to commencement of construction LRP will be invoiced annually until A Notice of Termination (NOT) is filed via SMARTS and, The NOT is approved by the Regional Board CAUTION SMARTS will not generate a WDID until the fee payment is received by the SWRCB CAUTION Covered construction may not commence until after a WDID is generated by SMARTS Allowing extra time for payment processing is a good idea! 18 9

10 Training Qualifications and Certification Requirements Qualified SWPPP Developer (QSD) SWPPPs must be written, amended, and certified by a QSD A QSD must be one of the following (applies immediately) California Professional Civil Engineer California Professional Geologist or Engineering Geologist California Registered Landscape Architect Professional Hydrologist (AIH) Certified Professional in Erosion and Sediment Control Certified Professional in Storm Water Quality Professional in Erosion and Sediment Control (NICET) Effective September 2, 2011, a QSD must have attend a SWRCB approved QSD training SWRCB is entering into an MOU with CASQA for the training 19 Training Qualifications and Certification Requirements Qualified SWPPP Practitioner (QSP) BMPs must be implemented by a QSP A QSP is a person responsible for non-storm water and storm water visual observations, sampling, and analysis A QSP must be one of the following (effective September 2, 2011) QSD Certified Erosion, Sediment and Storm Water Inspector Certified Inspector of Sediment and Erosion Control Effective September 2, 2011, A QSP must have attended a SWRCB approved QSP training SWRCB is entering into an MOU with CASQA for the training 20 10

11 l American Public Works Association May 3, 2010 Monitoring Program Risk Level informs Monitoring Program Projects with higher risks have more required monitoring Sampling not required outside of scheduled business hours and during dangerous weather conditions Risk Level Quarterly Non-Storm Water Disc charge Visual Inspections Pre-Storm Event Baseline (W Weekly) t Action P) Rain Event Plan (REAP m BMP ry 24 hrs ended events) Daily Storm (Once ever during exte Post Storm ( 48 hrs after qualify ying rain event) s Sample Collection y g Non llutants Discharge Potentially Containing Visible Po ter s Storm Wat Discharge 1 X X X X X 2 X X X X X X X 3 X X X X X X X X Water Receiving 21 Rain Event Action Plan (REAP) Required for Risk Level 2 and Risk Level 3 sites Triggered by NWS forecast of rain 50% probability of rain in the project area, 48 hours out Must document forecast with a printed copy QSP to develop and implement the REAP REAP to contain Site information, including Risk Level 24 hr contact information for Site Storm Water Manager Erosion and sediment control Sampling Agents Phase information, including Activities, active trades, trade contactor information Suggested actions [to maintain compliance with the CGP] 22 11

12 Rain Event Action Plan (REAP) At least 24 hours before forecasted rain ( 50% chance) REAP must be on site Paper copy required REAP implementation to begin CAUTION A REAP is even required for sites where activities are indefinitely halted or postponed! 23 Water Quality Sampling Risk Level 2 and Risk Level 3 Triggered by qualifying rain event of ½ or more Must sample at all points where storm water is discharged d off site Collect a minimum of 3 samples per day Analyze samples for ph and Turbidity Both lend themselves to field analysis Other parameters required by the Regional Board Reporting Risk Level 2 retain sampling and analysis records If NAL exceeded, submit NAL Exceedance Report via SMARTS Risk Level 3 retain and submit sampling results via SMARTS If NAL/NEL exceeded, submit Exceedance Report and NEL Violation Report via SMARTS 24 12

13 Other Monitoring Risk Level 3 Some Risk Level 3 sites require Receiving Water Monitoring Triggered by exceedance of NEL during Water Quality Sampling and Site has a direct discharge into a receiving water 25 American Public Works Association Presenter Contact Information Jason Uhley, P.E. Riverside County Flood Control and Water Conservation District 1995 Market Street, Riverside, CA JUHLEY@rcflood.org Jeff Endicott, P.E., BCEE, CPESC AEI-CASC Consulting 937 S. Via Lata, Suite 500, Colton, CA JEndicott@aei-casc.com 13