What To Do When the Rain Comes Down Meeting the Requirements of Washington States New Industrial General Stormwater Permit

Transcription

1 What To Do When the Rain Comes Down Meeting the Requirements of Washington States New Industrial General Stormwater Permit Dave Meyer Senior Consultant June 5, 2014

2 Webinar Logistics Session Format All participants are muted 45 minute presentation 15 minutes Q&A Session» Use the question/chat feature on your sidebar to submit questions» We ll respond to as many as we can in the Q&A session so we can end on time! Web/Phone Conference Issues or Concerns If you are having difficulty seeing/hearing the presentation, please submit a question using the chat feature or Call Presentation materials will be available after the session 2

3 Who We Are History Founded in 1990 by Environmental, Health and Safety (EHS) managers to offer comprehensive EHS management and technical consulting services to the high tech industry In late 90s, successfully diversified our client base into multiple regional and vertical markets across the US and beyond Today 180 employees supporting 450 customers from 5 regional offices in US Portland office with diverse environmental and safety capability Multidisciplinary EHS and Sustainability consulting team Well-established partners allow for cost-effective and highly responsive international support ISO and OHSAS Certified 3

4 Our Presenter- Dave R. Meyer Over 30 year of experience with industrial, construction and commercial stormwater compliance permitting and compliance for public agencies and private industry Experience in effective design and implementation of best management practices, stormwater pollution prevention planning, reporting/documentation, and training He currently provides client support in maintaining compliance with stormwater programs to meet local, state (Oregon, Washington, California) and Federal reporting requirements Contact Info:

5 Agenda EPA and WA Industrial Permit Overview Why stormwater is regulated Overview of regulatory structure New Requirements in WA (Changes to Stormwater Permits) Who is affected by new requirements Summary of new requirements Sampling / Monitoring Overview 5

6 What is stormwater? Rain that falls on streets, parking areas, sports fields, gravel lots, rooftops or other developed land and flows directly into nearby lakes, rivers and streams 6

7 Why is Stormwater regulated? Rain run-off transports pollutants to streams, rivers, lakes, and the ocean Stormwater is the leading cause of water impairment in the U.S. It is estimated that 4 billion tons of sediment are eroded annually from construction sites into U.S. waterways Typical pollutants in industrial sites Metals, solids (sediment or debris), oil and grease, nutrients, and solvents 7

8 Who Enforces These Laws? US EPA Washington State Department of Ecology Washington State Pollution Control Hearing Board Other Agencies Private Citizens NRDC Riverkeeper and Other Non- Governmental Organizations 8

9 When to Apply for the ISGP Need to apply for permit if answer YES to both questions: 1. Industrial activities identified in permit, based on primary SIC code 2. Point source discharge of stormwater to surface waters or conveyance systems that discharge to surface waters May not need permit if you meet No Exposure Certificate requirements 9

10 How to Comply File Notice of Intent Prepare a SWPPP / Monitoring Program Plan Participate in training SWPPP covers: Elimination of unauthorized non-stormwater discharges Implementation of Best Management Practices (BMPs) Record of significant leaks and spills Records for inspection, sampling, reporting (5 years worth) Inspection, monitoring, sampling, and reporting 10

11 What if We Don t Comply? Fines to $32,500 Per Day Per CWA Fines to $ 10,000 Per Day WA DOE Current Regulatory Atmosphere Violators will be held accountable Moving toward more publicly available information Regulations being updated Online submittal via WQWebDMR 11

12 Washington Industrial General Stormwater Permit (ISGP) Changes 12

13 Summary of Changes The 2015 version of the ISGP will mean little or minor changes for some permittees, but will have significant changes for others in certain industrial sectors and geographies Few changes to the benchmark threshold concentrations (i.e., pollutant concentrations) Sampling changes 13

14 Sampling Changes First fall storm event means the first time on or after October 1st of each year that precipitation occurs and results in a stormwater discharge from a facility. New Requirement: If Permittees collect more than one sample during a 24-hour period, they must first calculate the daily average of the individual grab sample results collected during that 24-hour period; then use the daily average to calculate a quarterly average. 14

15 No Changes to Benchmarks changes to petroleum concentrations (TPH-Dx fraction 10mg/L) Some changes to analytical test methods -- work with your lab directly! 15

16 New Airfield Effluent Limits Airfield Pavement Deicing. Existing and new primary airports with >1,000 annual jet departures (annual non-propeller aircraft departures) that discharge wastewater associated with airfield pavement deicing commingled with stormwater must either use non-urea-containing deicers or meet the effluent limit in Table 5 at every discharge point, prior to any dilution or any commingling with any non-deicing discharge. 16

17 Additional Sampling & Effluent Limit Changes Additional Sampling Requirements and Effluent Limits for Discharges to Certain Impaired Waters and Puget Sound Cleanup Sites If an outfall is subject to an impaired waterbody effluent limit (Condition S6.C) for a parameter that also has a benchmark (Condition S5), the effluent limit supersedes the benchmark Permittees discharging to a Puget Sound Sediment Cleanup Site shall implement additional storm drain line cleaning BMPs, solids sampling, and reporting 17

18 Critical Deadlines Close Public Comment Period Permit Renewal Applications Issue Final Permit Final Permit Effective Public June 20, 2014 July 5, 2014 November 19, 2014 January 1, 2015 comments must be postmarked or ed by midnight. Permittees must reapply for the new Industrial Permit (on line submittal) Copies mailed to all permit holders Old permit expires, new permit effective 18

19 Permit Requirements Overview 19

20 Unauthorized Non-Stormwater Discharges (NSWDs) Water from the rinsing or washing of vehicles, equipment, buildings, or pavement Water or liquid materials that have been improperly disposed of, dumped, spilled, or leaked From surface spills, interior floor drains, or loading dock sumps Atmospheric condensates with contaminants BMPs to control spills, leakage, and dumping should be implemented GOAL = Eliminate these DISCHARGES 20

21 Authorized NSWDs fire hydrant flushing potable water sources, including drinking fountain water, atmospheric condensates, refrigeration, air conditioning, and compressor condensate irrigation drainage, landscape watering, springs, ground water foundation or footing drainage AUTHORIZED ONLY IF... 21

22 Authorized NSWD Caveats Comply with Washington Dept. of Ecology requirements BMPs specified in Site s SWPPP BMPs prevent or reduce contact of NSWD with significant materials or equipment BMPs minimize the flow or volume of the NSWD discharges. BMPs implemented so NSWD does not contain significant quantities of pollutants. Quarterly visual observations of each NSWD and its sources to ensure that BMPs are implemented/effective 22

23 Source Areas / Activities Vehicle and Equipment Maintenance Onsite Waste Treatment, Storage and Disposal Loading / Unloading of Materials Roof Exhaust Discharges Rooftop and Roof Drains Compactors What are materials and equipment in these areas process that could come into contact with rain water? What can be done to minimize this contact? 23

24 Structural BMPs- New Requirements New Requirement: Maintain ponds, tanks/vaults, catch basins, swales, filters, oil/water separators, drains, and other stormwater drainage/treatment facilities in accordance with the Maintenance Standards set forth in the applicable Stormwater Management Manual (SWMM) or other guidance documents or manuals approved in accordance with S3.A.3.c. 24

25 Tier 1 Operational BMP s Corrective Actions - Examples Good housekeeping Sweeping Cover dumpsters Identify and control sources of dust, other materials Preventative Maintenance Spill Prevention and Clean up--goal: Minimize impact of spills Stop, Contain, Clean-up Annual employee training (w/in 30 days of hire) Inspections, Reporting, and Recordkeeping Illicit Discharge Detection 25

26 Structural Source Control BMP s Tier 2 Corrective Actions - Examples Physical cover to prevent stormwater contamination (cover, enclose, or move operations inside) Painting or resealing metal roof Secondary containment 26

27 Tier 3 Corrective Actions - Examples Detention or retention basins or vaults Detention: short-term storage of stormwater Retention: permanent storing of stormwater (until lost through percolation or evaporation) Oil/Water separators Infiltration Basins Infiltration trenches or bio-infiltration swales (bioswale) Biofiltration (Phyto-Remediation) Sand Filters MANY Others! 27

28 BMPs Summary Stormwater Management Manuals for Eastern and Western Washington Western:» Eastern:» Make sure potential pollutant sources are: Cleaned-up Covered Contained Make sure BMPs are: Installed properly Maintained and Monitored 28

29 Record Keeping & Internal Reporting Permittee is responsible for record keeping including: Spill reporting Inspections/visual observations Maintenance activities Corrective actions Use internal check sheet monthly Look at sources of pollution, discharge areas Retain records for at least 5 years 29

30 SWPPP Training For all permanent employees/upon new hire TOPICS: Objectives and requirements of the SWPPP Spill prevention, response, and reporting procedures Good housekeeping practices Prohibited practices Materials management practices Waste storage and removal 30

31 Sampling / Monitoring Overview 31

32 Sampling / Monitoring Overview Intent: To determine if BMPs implemented on the industrial site are effective for preventing pollutants from impacting water quality Total Suspended Solids (TSS) Send sample to lab (turbidity has only 48 hour holding time!) EPA Method Quantification of suspended particles in water sample» Reported as nephelometric turbidity units (NTU) 32

33 Sampling / Monitoring Overview ph Use field ph meter ph paper can be used if subject to a benchmark limit Metals Required Analytical Methods» EPA 200.8» Ensure lab can adequately detect / report to required levels» Ensure lab s Minimum Reporting Limit (MRL) is at least 10x lower than the benchmark to prevent false positives and negative results 33

34 Monitoring and Reporting Requirements Quarterly Discharge Monitoring Monthly Visual Monitoring Annual Reporting New Requirement: If Permittees collect more than one sample during a 24-hour period, they must first calculate the daily average of the individual grab sample results collected during that 24-hour period; then use the daily average to calculate a quarterly average. 34

35 Quarterly Discharge Monitoring Reports (DMRs) DMRs shall be submitted using Ecology s WebDMR system unless a waiver from electronic reporting has been granted Reporting Dates and DMR Due Dates Reporting Period Months DMR Due Date 1st January-March May 15 2nd April-June August 14 (new permit = August 15 th ) 3rd July-Sept November 14 (new permit= November 15 th ) 4th October-December February 14 (new permit = February 15 th ) 35

36 Discharge Monitoring Reports (DMRs) WQWebDMR 36

37 Monthly Visual Monitoring Industrial Stormwater Monthly Visual Inspection Report Parameters: Storm events» presence of floating materials» visible sheen» discoloration» turbidity and odor Dry Season» If water is present, identify source of water 37

38 Monthly Visual Monitoring INDUSTRIAL STORMWATER MONTHLY INSPECTION REPORT Inspections must be conducted by a person with the knowledge and skills to assess conditions and activities that could impact stormwater quality at the facility, and evaluate the effectiveness of best management practices required by this permit. Retain a copy of the completed and signed form in accordance with Permit Condition S9.C. FACILITY NAME: WEATHER INFORMATION: INSPECTION TIME: Description of Weather Conditions (e.g., sunny, cloudy, raining, snowing, etc.): Was stormwater (e.g., runoff from rain or snowmelt) flowing at outfalls and/or discharge areas shown on the Site Map during the inspection: Yes No Comments: DATE: 38

39 Annual Report (AR) Due May 15 th for previous year 39

40 EORM Stormwater Services Stormwater Permitting/ No-Exposure Certification Support Stormwater Pollution Prevention Plans Best Management Practice Design and Implementation Support Sampling Coordination Discharge Monitoring Reporting Training Compliance Inspections 40

41 Thank you! Questions? Dave R. Meyer Senior Consultant, EORM