Reign Consulting Presents

Transcription

1 Reign Consulting Presents

2 COVERED TOPICS 1. Introduction and Legal 2. Small MS4 Permit 3. Risk 4. Discharges 5. What to expect 6. How to prepare 7. Conclusion

3 INTRODUCTION AND LEGAL

4 INTRODUCTION GOAL = Eliminate pollutants discharged from the MS4. AUTHORITY = MS4 authorized to regulate Industry and Construction operators with potential to discharge.

5 LEGAL Established pursuant to the Clean Water Act (CWA) 402(p)(1-2) and (3)(iii), section 208 of the CWA, 64 FR 68722, to ensure that: Pollutant discharges are reduced to the maximum extent practicable (MEP), Protect water quality, Satisfy the appropriate water quality requirements of the CWA.

6 2016 SMALL MS4 PERMIT

7 SMALL MS4 PERMIT

8 SMALL MS4 PERMIT

9

10 MUNICIPALITIES

11 SMALL MS4 COUNTIES

12 OTHER SMALL MS4S

13 NEW 2016 SMALL MS4S

14 POTENTIAL SMALL MS4S

15 RISK

16 RISK MATRIX 1.Proximity to receiving waters 2.Type of receiving water impaired, outstanding water, non-attaining, tributary 3.Site size 4.Type of pollutants on site 5.Site pollution discharge record previous violations 6.Complaints

17 RISK MATRIX Previous Violations Proximity to impaired or unique waters Proximity to surface waters < One Acre Increased Site Area Increased Pollutants Previous Complaints

18 DISCHARGES

19 DISCHARGES Storm Water Run-off from all exposed areas of site. Non Storm Water Allowed in the Multi Sector General Permit (MSGP) and the Construction General Permit (CGP).

20 DISCHARGES Non-Stormwater Discharges may be disallowed if there is a potential to contain pollutants. (Part 1.3)

21 DISCHARGES Potential for causing erosion, sedimentation, and turbidity if the velocity is not reduced

22 DISCHARGES

23 DISCHARGES

24 DISCHARGES

25 WHAT TO EXPECT

26 WHAT TO EXPECT MS4 Notice of Intent to be posted on the ADEQ website for public comment. Opportunity for industries and individuals to add comments. Key words: MS4

27 WHAT TO EXPECT Comment Period Date: Feb.13 COMMENT PERIOD BEGINS Proposed AZPDES MS4 General Permit Coverage to Maricopa County COMMENT PERIOD ENDS Proposed AZPDES MS4 General Permit Coverage to Maricopa County On March 15, 2017, the public comment period will end for the proposed issuance of Arizona Pollutant Discharge Elimination System (AZPDES) Municipal Storm Sewer Systems (MS4) General Permit coverage to Maricopa County. The public comment period began Feb. 13, 2017.

28 WHAT TO EXPECT Potential dischargers to be inventoried. Enforcement procedures. Enforcement Response Plan (ERP). Dischargers may be required to registered. Accountability. Compliance and enforcement standards.

29 WHAT TO EXPECT Storm sewer mapping to isolate illicit discharges. Illicit discharge tracking holding offenders accountable.

30 WHAT TO EXPECT Develop, implement, and enforce SWMP Describe practices to achieve compliance Abide by state and MS4 ordinances. SWMP as public record Guidance for maintaining compliance.

31 WHAT TO EXPECT Enforcement Response Plan (ERP) to be developed and enforceable by November 1, ERP Plan to include: Escalated enforcement, Severity of non-compliance, Repeated non-compliance, Proximity to receiving water or storm sewer system

32 RISK MATRIX Previous Violations Proximity to impaired or unique waters Proximity to surface waters < One Acre Increased Site Area Increased Pollutants Previous Complaints

33 HOW TO PREPARE

34 HOW TO PREPARE Establish a point of contact with the MS4 Sign up for news letters or updates Participate in public comment sessions Offer alternative options or timelines when negotiating permit details

35 HOW TO PREPARE Perform an analytical site evaluation Apply for State Permit coverage - General, Individual, No exposure Site specific Storm Water plan Install control measures to prevent pollutants from leaving site or reduce exposure to storm water Complete scheduled and rain event inspections Complete and submit reports

36 MULTI SECTOR GENERAL PERMIT (MSGP) Site specific Storm Water Management Plan (SWMP) or Storm Water Pollution Prevention Plan (SWPPP) Required inspections Discharge sampling and reporting Subject to regulatory inspections Annual permit renewal fee

37 CONSTRUCTION GENERAL PERMIT (CGP) Site specific Storm Water Pollution Prevention Plan (SWPPP) Required inspections Discharge sampling and reporting Subject to regulatory inspections Annual permit renewal fee

38 No water discharges from site. All materials, processes, and storage is contained inside or under cover of structures. Property is lower than surrounding properties. 5 year coverage NO EXPOSURE

39 HOW TO PREPARE Planning and Budgeting Technological planning Cost of doing business Preventative, structural, and administrative control measures Voluntary efforts Compliance violations

40 QUESTIONS?

41 IN CONCLUSION Everyone doing their part keeps the community a clean place to live and work. Prevention is less expensive than clean-up Storm drains do not lead to treatment plant, they flow directly to the closest MS4, surface water, or wash.

42 Thank you Deborah Schadewald-Kohler Principle Solutions Consultant Reign Consulting REIGN CONSULTING TM SOLUTIONS FOR ARIZONA STORM WATER 2017 REIGN CONSULTING TM & CATCH THE WIND, LLC

43 Deborah Schadewald-Kohler Principal Solutions Consultant Reign Consulting - Solutions for Arizona Storm Water Reigntrooper@gmail.com Deborah Schadewald-Kohler has been working in regulatory water quality with the Salt River Maricopa-Pima Indian Community and the Arizona Department of Environmental Quality and as a compliance inspector in the private sector for over 12 years. Her regulatory experience includes Municipal Separate Storm Sewer Systems (Phase 1 and 2), construction, industrial, and mining stormwater compliance, large and small drinking water system sanitary surveys, waste water treatment compliance, and pre-treatment compliance. Deborah is also well versed in the prevention planning, water system planning review, monitoring, and the reporting necessary in Arizona. Ms. Schadewald-Kohler holds a Masters degree in Environmental Science with emphasis on Green Infrastructure and Low Impact Redevelopment from Prescott College.