Stormwater Permitting for Oil and Gas Support Facilities ROBERT BEARD, P.G. SENIOR PROJECT MANAGER, LEIDOS
Stormwater Stormwater: water from precipitation and snow/ice melt. Stormwater can soak into the soil (infiltrate), be held on the surface and evaporate, or runoff and end up in nearby streams, rivers, or other water bodies (surface water). Stormwater can also be spelled as storm water, but most regulators now use stormwater.
Stormwater Runoff Stormwater runoff is from rain and snowmelt that flows over land or impervious surfaces, such as paved streets, parking lots, and building rooftops, and does not soak into the ground. Runoff picks up pollutants: trash, chemicals, oils, and dirt/sediment. Polluted stormwater goes into rivers, streams, lakes, and coastal waters.
Stormwater and Development In natural landscapes, the soil absorbs much of the stormwater. Plants hold stormwater close to where it falls. In developed environments, water flows off the surface Two major issues: Flooding Contamination
Stormwater as a Resource Stormwater is also a resource. It is important for aquifer recharge and becomes more important as groundwater and surface water sources are depleted.
StormwaterOil and Gas Drilling Exploration, production, processing, treatment, and transmission facilities exempt from NPDES requirements for stormwater discharges. Drilling Sites Waste Management Pits Access Roads Pipelines Compressor Stations Crude Oil Pumping Stations Unfortunately, this has led to misinterpretation by some managers that all oil and gas activity is exempt from stormwater permitting.
StormwaterOil and Gas Support Facilities Support facilities are not exempt. These are typically downstream from exploration/production. Equipment maintenance and storage facilities owned by operators and service companies not contiguous to an exempt facility; and Support Industries-metal fabrication, sand suppliers, concrete suppliers, trucking companies, barge terminals, etc.
So, do you need a stormwater permit? EPA, in most cases, delegated stormwater permitting to states. Check your state regulations Many states use Standard Industrial Classification (SIC) codes to determine if you need to have coverage under their stormwater permit Correct application of primary SIC code is critical Many oil and gas support activities are under SIC 1389
Types of NPDES Stormwater Permits Multi-Sector General Permit for Stormwater Discharge Individual Permit for Stormwater Discharge No Exposure Certification Construction Permit for Stormwater Discharge
Multi-Sector General Permit for Stormwater Discharge Usually referred to as simply the General Permit This is the preferred permit, if you qualify for coverage This typically requires the minimal amount of sampling Most states now require water sampling as opposed to only visual inspections
No Exposure Certification This the best option if the facility qualifies for No Exposure to Stormwater All activities, except for new equipment (such as for sale) and vehicles, must be under roof Oil and chemical storage tanks and raw materials must be under roof and not exposed to stormwater Often not practical for facilities under SIC 1389
Individual Stormwater Permit The individual permit is more complex It is required in the following circumstances: Discharge into a high-quality waterway Facility subject to an Effluent Limitation Guideline Regulator requires an individual permit
Stormwater Permit for Construction This permit is issued for construction activities only Required if more than one acre is affected by your project Must look at acreage of entire project. Do not try to piece meal project to avoid permit by doing smaller sections. May result in NOV. Must coordinate efforts with other local, state, and federal agencies
Practical Considerations for Preparing Your Permit Regulators want permits that are both defendable and enforceable Owner decisions about outfalls and inspections are critical Selecting your outfall(s) for monitoring is a key for a successful permit Best to select one representative outfall for sampling You may still have other outfalls that must be visually monitored and evaluated during your required inspections
Stormwater Pollution Prevention Plan (SWP3) This is a requirement for most stormwater permits. EPA has an outline that can be followed if state does not have own format. For instance, New Jersey has a series of forms. Pennsylvania requires a Preparedness, Prevention, and Contingency (PPC) plan, not a SWP3 Integrate Best Management Practices (BMPs) into your Plan While some owners integrate the SWP3/PPC plan with their SPCC plan (if needed) it is generally best to keep them separate as the state regulators often like their own format
Your Permit is issued Congratulations! Now you have to comply with it Get samples early in quarter/half/year. You may become faced with a drought situation later in year Follow inspection schedule outlined in your SWP3 or equivalent plan Complete and document the annual training required under your plan
Qualifying Rain Events Stormwater samples must be taken during rain events that qualify for sampling. Requirements vary from state to state This is often a 0.1 inch rain event that occurred at least 72 hours from previous 0.1 inch rain event Sample must generally be collected within 0.5 hours of the beginning of the discharge. Use smart phone radar data to monitor approaching storms A good source of weather data is Weather Underground http://www.wunderground.com By Ce radar est opéré par Environnement Canada. La sortie radar est produite par le logiciel développé par l'observatoire radar J.S. Marshall de l'université McGill en collaboration avec EC. Meteorological Service of Canada (Environment Canada). Redistribution allowed if source mentioned, Copyrighted free use, https://commons.wikimedia.org/w/index.php?curid=768327
Sampling Methods Stormwater sampling can be challenging-do not take it for granted. Make sure you have site staff or a consultant collect the samples Make sure you clearly understand how you are going to collect your sample Water at an inlet can sometimes be collected with a small hand pump, but it can result in sucking up debris Sheet flow can be collected with a dust pan. Do not use sheet flow as an excuse to not sample Can put water into small buckets/containers for later transferring to sample bottles. Can also measure ph and temperature in these containers
Reporting Like all permits, make sure you submit results when required by your permit Many states now require electronic reporting of results. Some, such as Pennsylvania, issued NOVs for not signing up for e-permit submittal Be aware of permit renewal dates. Permits usually last for five years. Permit renewal applications are required 180 days before expiration.
Conclusions Stormwater permitting can be confusing but is straightforward if you follow this strategy: 1) Select the correct permit; 2) Select the correct outfall(s) for the permit; 3) Follow the commitments made in your SWP3 plan; 4) Have a dedicated person or consultant that is committed to collect the samples; and 5) Vigilant reporting and attention to permit deadlines to maintain coverage under your permit.