Bill Lindsey, Midwest Environmental Consultants, Don't expose yourself, Missouri Water Seminar, September 10-11, 2015, Columbia, MO
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Missouri Water Seminar, September 10-11, 2015, Columbia, MO
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Bill Lindsey, Midwest Environmental Consultants, Don't expose yourself, Missouri Water Seminar, September 10-11, 2015, Columbia, MO
- 1. Don’t Expose Yourself! Can you be excluded from stormwater permitting? Bill Lindsey, P.E.
- 2. •General Permits •No SWPPP •No Quarterly Sampling •Fees - $300 for 5 years = $60 per year Old Stormwater Permits = Fun!
- 3. • SWPPP & Monthly Inspections • Quarterly Sampling - # of Outfalls? • Benchmarks/Limits • BMP’s – Tweaking/Repairing • Fees = $200 year • Losing Stream = Individual Permit! (old fees - $1,350 Yr, new - $1,800) New SW Permits = Not Fun!
- 4. • EPA Conditional No Exposure Exclusion for Industrial Activity – January 2000 • Who can qualify? • Conditions? • Definitions and Details? • Industrial Materials • No Exposure/Cover Can you be excluded for a stormwater permit?
- 5. • EPA Guidance – All industrial categories • Excluded: • “Construction Sites” • “Junk cars & stockpiled train rails” • MDNR – 28 MOG General Permits – Process Water = Difficult - None really eligible. • MOG49 - Quarries, Asphalt, Redi-Mix • MDNR – 17 MOR General Stormwater Permits • Facility Wide – Not Outfall Specific Who Can Qualify?
- 6. • MOR13 – Textiles & Printing • MOR203 Fab. Metal & Light Industry • MOR80C–Motor Freight Transportation • Individual Permit -due to Losing Stream MDNR General Stormwater Permits Potentially Eligible – YES!
- 7. • MO-RA – Land Disturbance • MO-R04 – MS4 • MOR100 – City Land Disturbance • MOR22 – Wood & Lumber • MOR23 – Chemicals, Plastics, Biodiesel • MOR240, 241 – Agrichemicals • MOR60 – Vehicle Salvage • MOR80 – Airports & Trans. Stations MDNR General Stormwater Permits Probably Not!
- 8. • No Exposure – All industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Conditions to be Excluded
- 9. • Material handling equipment or activities • Industrial machinery • Raw materials • Intermediate products • By-products & waste products • Final products Industrial Materials?
- 10. • Completely roofed and walled buildings or structures • Structures with a top but no sides – providing not subject to run-on /run-off of stormwater • Temporary cover = tarpaulins Storm-Resistant Shelter?
- 11. • Drums, barrels, tanks and containers that are “sealed.” • Above Ground Tanks (AST’s) • Lidded Dumpsters – waste materials • Plant Vehicles – not leaking • Final products – intended for outdoor use (i.e. “new cars”) • Containers, racks, pallets to store or move final products – if clean. No Shelter Required!
- 12. • Drums - valves that are used in field • Containers & materials – open, deteriorated, leaking • Outdoor vehicle & equipment maintenance • Leaking pipes and pumps • Open dumpsters • Mobilized by rain – rock salt • Particles or residue – roof stacks or vents • Particles or residue – track out Stuff that won’t fly!
- 13. • Final products that are “intermediate” products • Intermediate products: • Used in the composition of another product • Sheet metal, tubing, and paint • Chemically treated or not impervious to weathering More stuff that won’t fly!
- 14. • EPA NPDES Form 3510-11 • 11 Questions – answer No! • Submit to MDNR • Good for 5 years • Maintain all conditions of no exposure How do you apply to be excluded for a stormwater permit?