California State Water Resources Control Board New General Permit For Storm Water Discharges Associated with Industrial Activities Order NPDES No. CAS000001 Effective July 1, 2015 How will the new changes affect Solid Waste Companies? By 1
Current Storm Water Requirements for Industrial Sites (Under Water Quality Order No. 97-03-DWQ effective since 1997) 1. Submit NOI & site map and receive a WDID (waste discharge identification) number 2. Storm Water Pollution Prevention Plan (SWPPP) & Monitoring Plan kept at site 3. Collect 2 storm water samples per year (if qualified storm event) 4. Conduct 8 monthly & 4 quarterly visual observations 5. Submit an Annual Report and conduct annual site inspection 6. Conduct Annual Training The NEW General Permit For Storm Water Discharges Associated with Industrial Activities (IGP) Order NPDES No. CAS000001 includes significant changes... 2
NEW Requirements /Changes Effective July 1, 2015 HOWEVER preparation ahead of time is required! 3
Online Submittal Requirements All Permit Registration Documents (PRDs) & submittals are required electronically via SMARTS https://smarts.waterboards.ca.gov/ by a Legally Responsible Person (LRP) or their Duly Authorized Representative 4
Online Submittal Requirements This includes: Notice of Intent (NOI) All applicable sites must submit either an NOI by July 1, 2015 or a No Exposure Certification (NEC) by October 1, 2015. SWPPP & map - Applicable sites must submit online by July 1, 2015. Upload future revisions to the SWPPP within 30 days. SWPPPs must be revised if Discharger s status changes due to annual Numeric Action Level (NAL) exceedance. Monitoring Results submit analytical data within 30 days of receipt Exceedance Response Action (ERA) Reports For annual NAL exceedances. Annual Reports 5
Qualified Industrial Storm Water Practitioner (QISP) New Dischargers that discharge to a water body with a 303(d) listed impairment must submit data and/or information, prepared by a QISP, when applying for IGP coverage QISP Description of Requirements: A QISP must complete a SWRCB approved training course or be a CA licensed PE, PG, or CEG. A competency exam may be required for certification as a QISP (similar to Construction QSP/QSD). Only QISPs can prepare the following documents: The SWPPPs for Level 1 & Level 2 dischargers. Level 1 status Exceedance Response Action Evaluation and Reports Level 2 status Exceedance Response Action Technical Reports / Plans and Level 2 status Exceedance Response Action Extension. 6
Minimum Best Management Practices (BMPs) Sites must implement the following BMPs or document why they are inapplicable, infeasible, inappropriate, etc.: Observe outdoor industrial activity areas and clean up debris, waste, spills, tracked, or leaking materials. Implement BMPs to minimize or prevent tracking. Cover all stored industrial materials that can be readily mobilized by contact with storm water. 7
Minimum Best Management Practices (BMPs) Continued: Contain all stored non-solid industrial materials (e.g., liquid, powder, etc.) that can be dispersed via wind or contact with storm water. Implement BMPs to ensure that facility areas impacted by rinse/wash waters are cleaned as soon as possible. Minimize authorized (NSWDs) Non-Storm Water Discharges (e.g., potable water, fire Hydrant testing, etc.) and prevent from contacting Industrial areas of the facility. Minimize storm water discharges from non-industrial areas (e.g., employee parking areas) from contact with industrial areas of the facility. 8
Minimum Best Management Practices (BMPs) Continued: Prevent or minimize handling of industrial materials or wastes that can be mobilized by contact with storm water during a storm event. Cover waste disposal containers & material storage containers when not in use. <<These may need covers unless they can be stored inside Direct run-on away from stock piled materials. 9
Minimum Best Management Practices (BMPs) Continued: Observe and clean outdoor material/waste handling equipment or containers that can be contaminated by contact with industrial materials or wastes. Establish a maintenance schedule for outdoor equipment that may spill or leak. Establish procedures for prompt maintenance and repair of equipment when conditions exist that may result in spills or leaks. 10
EROSION CONTROL BMPs Provide stabilization for inactive areas, slopes, and erodible areas prior to a forecasted storm event. Implement wind erosion controls. Direct run-on away from erodible materials. Maintain effective perimeter controls to control discharges of erodible materials offsite. Design sediment basins to ensure compliance with design storm standards. Maintain sediment and erosion control BMPs to comply with the General Permit during all times. 11
More Detailed BMP Information Required in SWPPP The SWPPP must include a narrative describing each BMP including: The pollutant the BMP is designed to reduce/prevent in storm water discharges. The frequency, time of day, or conditions when the BMP is implemented. The BMP implementation location within each area of industrial activity or pollutant source. The individual and/or position responsible for implementing the BMP. Procedures (including maintenance) to implement the BMP effectively. Equipment and tools required to implement the BMP effectively. 12
Increased Monitoring Requirements Monthly Daylight Visual Observations on days without precipitation (previously was Quarterly) Each month, the Discharger shall observe each drainage area for the following: i. Prior, current, or potential unauthorized NSWDs (Non-Storm Water Discharges) and their sources; ii. Authorized NSWDs, the sources, and associated BMPs; and, iii. Outdoor industrial equipment and storage areas, outdoor industrial activities areas, BMPs, and all other potential source of industrial pollutants. The Discharger shall provide an explanation in the Annual Report for uncompleted monthly visual observations. 13
Qualifying Storm Event (QSE) New Definition for a Qualifying Storm Event A Qualifying Storm Event (QSE) is a precipitation event that: a. Produces a discharge for at least one drainage area; and, b. Is preceded by 48 hours with no discharge from any drainage area. 14
Sample Frequency Requirements Increased Sample Frequency Requirements: Dischargers shall collect storm water samples from all locations that discharge storm water associated with industrial activity for 2 QSEs within the first half of each reporting year (July 1 to December 31) and 2 QSEs within the second half of each reporting year (January 1 to June 30). No More Excuses for Not Collecting Samples: Samples from each discharge location shall be collected within 4 hours of: a. The start of the discharge; or b. The start of facility operations, if the QSE occurs within the previous 12-hour period (e.g., for storms with discharges that begin during the night for facilities with day-time operating hours). 15
Sampling Parameter Selection Total Suspended Solids (TSS), ph, and Oil & Grease (O&G) required for all plus... Additional Standard Industrial Classification (SIC) Code Required Parameters Additional Parameters identified in a required site-specific pollutant source assessment Additional Parameters related to nearby 303(d) listed impaired water bodies Additional Parameters required by the Regional Water Board. Additional Parameters required by Subchapter N (Dischargers subject to Effluent Limitations Guidelines (ELG)) 16
SIC Additional Parameters Standard Industrial Classification (SIC) Code Required Parameters for Waste Handlers: 4953 Landfills & Land Application Facilities = Iron (Fe) 4953 Hazardous Waste Facilities = Ammonia (NH3), Chemical Oxygen Demand (COD), Cyanide (Cn), Arsenic (As), Lead (Pb), Magnesium (Mg), Mercury (Hg), Selenium (Se), & Silver (Ag). 5093 Scrap & Waste Materials = COD, Aluminum (Al), Iron (Fe), Lead (Pb), and Zinc (Zn). 5015 Dismantling or Wrecking Yards = Aluminum (Al), Iron (Fe), & Lead (Pb). NOTE: Copper (Cu) is no longer required for 5093. 17
Additional Parameters for 303(d) Impaired water bodies with Total Maximum Daily Loads (TMDL) Regional Water Board adopted and/or U.S. EPA established/approved TMDLs, as of the adoption date of this General Permit, that are applicable to industrial storm water Dischargers. Subject to change in future as more are added. Example.. San Diego Regional Water Quality Control Board Water Body Pollutant Chollas Creek Diazinon, Copper, Lead, and Zinc Los Peñasquitos Lagoon Sediment Rainbow Creek Total Nitrogen and Total Phosphorus Shelter Island Yacht Basin Dissolved Copper Baby Beach in Dana Point Harbor Indicator Bacteria Shelter Island Shoreline Park in SD Bay Indicator Bacteria Twenty Beaches and Creeks Indicator Bacteria 18
Field Measurements Field Measurements: Specific Conductance (SC) is no longer required Due to the 15 minute holding time, measurements for ph usually are made in the field. This can be done using a wide range ph litmus paper. However, if the discharger exceeds Numeric Action Levels (NALs), then the permit requires the use of a calibrated ph meter. This device must meet minimum standards for this type of field sampling and must be calibrated in accordance with the manufacturers specifications. 19
Numeric Action Limits TABLE 5: Parameter NAL Values, Test Methods, Detection Limits, and Reporting Units ph* PARAMETER TEST METHOD MDL*** field test with calibrated portable instrument, or lab sample per 40CFR 136. REPORTING UNITS ph units ANNUAL NAL INSTANTANEOUS MAXIMUM NAL 6.0-9.0 6.0-9.0 Total Suspended Solids (TSS)* SM 2540-D 1.0 mg/l 100 400 Oil & Grease (O&G)* EPA 1664A 1.0 mg/l 15 25 Zinc, Total (H) EPA 200.8 0.0005 mg/l 0.26** Copper, Total (H) EPA 200.8 0.0005 mg/l 0.0332** Cyanide, Total EPA 3135.2I 0.003 mg/l 0.022 Lead, Total (H) EPA 200.8 0.0005 mg/l 0.262** Chemical Oxygen Demand (COD) SM 5220C 1.0 mg/l 120 Aluminum, Total EPA 200.8 0.0005 mg/l 0.75 Iron, Total EPA 200.7 0.005 mg/l 1.0 Nitrate + Nitrite Nitrogen SM 4500-NO3- E 0.01 mg/l as N 0.68 Total Phosphorus SM 4500-P B+E 0.05 mg/l as P 2.0 Ammonia SM 4500-NH3 B+C or E 0.1 mg/l 2.14 Magnesium, total EPA 200.7 0.0005 mg/l 0.064 Arsenic, Total (c) EPA 200.8 0.0005 mg/l 0.15 Cadmium, Total (H) EPA 200.8 0.0002 mg/l 0.0053** Nickel, Total (H) EPA 200.8 0.0005 mg/l 1.02** Mercury, Total EPA 245.1 0.0001 mg/l 0.0014 Selenium, Total EPA 200.8 0.0005 mg/l 0.005 Silver, Total (H) EPA 200.8 0.0002 mg/l 0.0183** Biochemical Oxygen Demand (BOD) SM 5210B 3.0 mg/l 30 SM Standard Methods for the Examination of Water and Wastewater, 18 th edition EPA EPA test methods *Minimum parameters required by this General Permit **The NAL is the highest value used by EPA based on their hardness table in the 2008 MSGP. ***More stringent test methods with lower detection limits may be used. 20
Numeric Action Limits Exceedances Two Types of Numeric Action Limits (NAL) Exceedances: 1) Annual NAL Exceedance When the average of the annual sample results for a parameter are exceeded (refer to Annual NAL on Table 5). Note: Sites can take additional samples (>4 per year) if they want to try and lower the annual average for a parameter. 2) Instantaneous Maximum NAL Exceedance - when two or more results in a reporting year exceed (for TSS or O&G) or are outside the ph range per Table 5. 21
Exceedance Response Actions (ERAs) Baseline Status No Exceedance All Dischargers start NOI Coverage at Baseline Status. Level 1 Status - NAL Exceedance immediately triggers Level 1 status for parameters exceeded. Within 60 days discharger shall evaluate the SWPPP and pollutant sources. ASAP, or by October 1 following the reporting year, dischargers shall implement additional operational and/or source control BMPs, revise the SWPPP, and submit via SMARTS a QISP prepared Level 1 ERA evaluation. 22
Exceedance Response Actions (ERAs) Level 2 Status Structural/Treatment Control A Level 1 status immediately changes to Level 2 for parameters that have an NAL exceedance in any subsequent reporting year. Within 120 days discharger shall: a. Evaluate the SWPPP and pollutant sources and identify whether additional structural and/or treatment control BMPs are necessary. b. Submit via SMARTS a QISP prepared Level 2 ERA Technical Report including implementation schedule for design & construction of treatment and/or structural source control BMPs or a schedule to submit a Demonstration Technical Report. ASAP, or within one year discharger shall: implement structural and/or treatment control BMPs, revise the SWPPP, and (if applicable) submit Demonstration Technical Report. 23
Demonstration Technical Reports BAT/BCT Compliance Demonstration Technical Report: Evaluate cost of technology in relation to effluent reduction benefits, age of equipment & facilities involved, process employed, engineering aspects of the various types of control techniques, process changes, and non-water quality environmental impact (i.e. energy requirements) Non-Industrial Source Pollutant Demonstration Technical Report: Discharger must demonstrate that the pollutants causing the exceedances are solely attributable to storm water run-on from adjacent properties or from non-industrial portions of the Discharger s property, or from aerial deposition. Requires a quantification of the relative contributions of the pollutant from run-on, non-industrial sources, or aerial deposition. 24
Demonstration Technical Reports Natural Background Demonstration Technical Report includes: A summary of all data previously collected by the Discharger or others that describe the levels of natural background pollutants in the storm water discharge A summary of any research and published literature that relates the pollutants evaluated at the facility; A map showing the reference site location in relation to facility along with available land cover information; Reference site and test site elevation; Available geology and soil information for reference and test sites; Photographs showing site vegetation; Site reconnaissance survey data regarding presence of roads, outfalls, or other human-made structures; and Records from relevant state or federal agencies indicating no known mining, forestry, or other human activities upstream of the proposed reference site. 25
COMPLIANCE GROUPS & LEADERS Baseline/Level 1 Compliance Group (CG1) and Baseline/Level 1 Compliance Group Leader (CGL1) Requirements A group of Dischargers of the same industry type (facilities with similar types of industrial activities, pollutant sources, and pollutant characteristics) may form a CG1. The CG1 shall select a CGL1 to assist with all compliance activities in this General Permit other than Level 2 ERA compliance activities. For example SWPPP development, monitoring, visual observations and inspections. The number of samples required per year is reduced from four to two. 26
COMPLIANCE GROUPS & LEADERS A CGL1 must prepare a Consolidated Level 1 ERA Report, which provide a description of the common industrial pollutant sources, BMPs & ERAs, and also the industrial pollutant sources, BMPs & ERAs that are not common between the CG1 Participants. The CGL1 shall revise the Consolidated Level 1 ERA Report in accordance with any comments received from the Water Boards The CGL1 shall inspect all the facilities of the CG1 Participants at a minimum of once per reporting year (July 1 to June 30). The CGL1 shall update the Consolidated Level 1 ERA Report as needed to address additional CG1 Participants that trigger the ERA Level 1 reporting requirements 27
Quality Assurance & Record Keeping Records must be kept for a minimum of 5 years including: Records of BMP implementation (dates of implementation/maintenance) Training Records Spill & Clean-up related response activity records Sampling Data Inspection/Observation Records Annual Reports (due July 15 th ) ERA Demonstrations Demonstration Technical Reports 28
Conclusions Major changes from the current program Requires a Qualified professional to do the work More Chemical testing and Analysis of Data More Sampling & Monitoring Events are Required Field ph Measurements are required More Reporting and Electronic Submittals required Must meet Discharge Limits More Stringent Corrective Action Requirements 29