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International Low Impact Development Conference 2016
This document summarizes a presentation on industrial stormwater discharge requirements. It provides background on the Clean Water Act and the NPDES permitting program's Multi-Sector General Permit (MSGP) for industrial stormwater. It then analyzes data on the number of facilities covered by the MSGP versus the No Exposure Certification in Massachusetts from 2000 to 2016, finding a decrease in the total number of covered sites. Finally, it discusses sector-specific monitoring requirements for metals in stormwater discharges.
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International Low Impact Development Conference 2016
- 1. International Low Impact DevelopmentConference 2016 Industrial Stormwater Discharge – Covers More than You Might Think! Tuesday, August 30, 2016 David P. Horowitz, P.E., CSP, Project Manager Slideshare: dphorowitz Twitter: @dphorowitz Youtube: dphorowitz
- 2. Objectives/Takeways ■ Industrial Stormwater Introduction ■Stormwater requirements ■ Potential pollutant sources ■ New England framework – MSGP Data Review
- 3. Acronyms ■ BMP –Best Management Practice ■ ICP – Integrated Contingency Plan ■ LID – Low Impact Development ■ MSGP – Multi-Sector General Permit ■ NOI – Notice of Intent ■ NOE – No Exposure Certification ■ NOT – Notice of Termination ■ NPDES – National Pollutant Discharge Elimination System ■ SPCC – Spill Prevention Controls & Countermeasures ■ SWMP – Storm Water Management Plan ■ SWPPP (SWP3) – Storm Water Pollution Prevention Plan ■ TMDL – Total Daily Maximum Load
- 4. Regulatory Background ■ PointSource Pollution – Water Quality Act of 1965 – Federal Water Pollution Control Act Amendments of 1972 – Clean Water Act of 1977 ■ Non-Point Source Pollution – Water Quality Act of 1987 – Phase 1 (1990) » Medium and Large MS4s » Industrial Stormwater Dischargers » Construction Sites of 5+ acres – Phase II (1999) » Small MS4s » Construction Sites of 1+ acres
- 5. Regulatory Background ■ IndustrialStormwater Dischargers – 1995 Multi-Sector General Permit – 2000 Multi-Sector General Permit » Renewed – 2008 Multi-Sector General Permit » Renewed three years after expiration – 2015 Multi-Sector General Permit » Renewed two years after expiration
- 6. Storm Water Discharges– What do these states have in common?
- 7. Delegated States ■ Moststates are delegated to oversee program – 46 are delegated – States issue permits ■ Four states are not delegated – Massachusetts – New Hampshire – Idaho – New Mexico – EPA issues permits
- 8. New England States State GeneralPermit - Effective Date General Permit - Expiration Date Comment Massachusetts June 4, 2015 June 4, 2020 Federal Permit New Hampshire June 4, 2015 June 4, 2020 Federal Permit Maine April 26, 2011 April 25, 2016 (September 2016 Draft) State Permit Connecticut October 1, 2011 September 30, 2018 (Extended from 2016) State Permit Rhode Island August 15, 2013 August 14, 2018 State Permit Vermont August 4, 2011 August 4, 2016 (Administratively continued) State Permit
- 9. NPDES - Industrial ■Permitting Options? – Multi-Sector General Permit (MSGP) – Federal or state – Meant to be easy – No Exposure Certification (NOE) – Still need to file! – Individual Wastewater Discharge Permit – Don’t want these for stormwater
- 10. Sectors & SIC ■What is an SIC code? – “A Standard Industrial Classification code or SIC code is a four- digit code describing the activities taking place at a facility. Facilities conducting multiple operations may have multiple SIC codes, one describing each activity.” ■ What is a Primary SIC code? – A primary SIC code describes the activity that generates the highest net revenue at a facility.
- 11. Multi-Sector General Permit(MSGP) Applicability ■ Sectors organized by SIC Codes – Sector A: Timber Products – Sector E: Glass, Clay, Cement, Concrete and Gypsum Products – Sector M: Automobile Salvage Yards – Sector L: Landfills (Active & Closed) – Sector N: Scrap and Waste Recycling – Sector P: Land Transportation and Warehousing – Sector S: Airports – Sector T: Wastewater Treatment Plants (>1 MGD)
- 12. Stormwater Changes ■ 2015MSGP – Added NAICS code cross-reference – North American Industrial Classification System – Added specificity for effluent limits – Electronic filing required – Improved public accessibility » Post plan » Provide plan elements in NOI
- 13. General ■ No ExposureCertification (NOE) – Activities are designed to prevent exposure to rain, snow, snowmelt and/or runoff – Material handling equipment or activities – Material handling activities » Storage, loading and unloading, transportation, or conveyance – raw material, intermediate product, final product or waste product » Final products intended for outdoor use are not required to be stored indoors or in a storm-resistant shelter.
- 14. Multi-Sector General Permit(MSGP) Implementation ■ SWPPP Contents ■ Discharges to Water Quality Impaired Waters ■ Endangered Species & Historic Places Evaluation ■ Quarterly Visual Inspections ■ Annual Reporting ■ Benchmark/Numeric Effluent Monitoring ■ Electronic Reporting To EPA – Sample Results (<30 days) – Inspection Reports (<45 days) ■ Employee Annual Training
- 15. 2000, 2008 &2016 MSGP Comparison Let’s look at the data!
- 16. 2000, 2008 &2016 MSGP Comparison County 2016 MSGP 2008 MSGP 2000 MSGP Barnstable 6 22 29 Berkshire 27 20 50 Bristol 86 55 105 Dukes 7 4 4 Essex 101 56 104 Franklin 16 10 18 Hampden 71 46 97 Hampshire 31 28 38 Middlesex 82 64 193 Nantucket 2 1 1 Norfolk 64 44 94 Plymouth 59 35 55 Suffolk 44 23 38 Worcester 119 67 158 TOTALS 715 475 984
- 17. 2000, 2008 &2016 NOE Comparison County 2016 NOE 2008 NOE 2000 NOE Barnstable 0 12 6 Berkshire 5 17 7 Bristol 22 49 25 Dukes 1 0 0 Essex 25 56 21 Franklin 7 8 8 Hampden 6 29 16 Hampshire 7 13 10 Middlesex 60 143 56 Nantucket 1 2 1 Norfolk 21 46 20 Plymouth 7 24 17 Suffolk 27 9 6 Worcester 36 77 36 TOTALS 225 485 229
- 18. Data Review 2016 MSGP2008 MSGP 2000 MSGP 715 475 984 2016 NOE 2008 NOE 2000 NOE 225 485 229 940 960 1213
- 19. Data Review ■ Shiftto/away from No Exposure ■ Less Sites Covered ■ Site closures? ■ Re-evaluation of regulated discharges? ■ “Delegated” impact – “Out of sight, out of mind”? 2016 MSGP 2008 MSGP 2000 MSGP 715 475 984 2016 NOE 2008 NOE 2000 NOE 225 485 229 940 960 1213
- 20. Sector-Specific Analytical - Metals ■Metals – Cadmium, Copper, Lead, Nickel, Silver, Zinc – Provide ‘additional protection for endangered species’ – Hardness Dependent – Determine hardness of receiving water – Scaled – 25 mg/L increments ■ Three Options – Individual grab – Group grab sampling – 3rd Party Data
- 21.
- 22. Objectives/Takeways ■ Industrial Stormwater Introduction ■Stormwater requirements ■ Potential pollutant sources ■ New England framework – Data THANK YOU!!!!!
Editor's Notes
- #4 I wanted to first introduce a list of some of the acronyms that many of us will be using throughout the day….you can use this as a reference – since we often take for granted that everyone speaks ‘our’ language of Swip and NiPDES!
- #8 Well – these are states that are NOT delegated in the SW program EPA issues the SW general permits for construction activities &gt; 1 acre and for many industrial sites under the MSGP. The MS4 program was issued jointly by EPA and DEP – thus creating separate state and federal permits – providing equal regulatory and enforcement authority for both.
- #9 Well – these are states that are NOT delegated in the SW program EPA issues the SW general permits for construction activities &gt; 1 acre and for many industrial sites under the MSGP. The MS4 program was issued jointly by EPA and DEP – thus creating separate state and federal permits – providing equal regulatory and enforcement authority for both.
- #13 Permitting options…. MSGP No esposure NPDES permit First – for MSGP……
- #14 The second “Option” I mentioned was the No Exposure Certification – where you certify that activities at your site are no exposed to stormwater….There are specific conditions you must meet to be eligible. See FORM - 11 items you must fufill.
- #16 The purpose of annual training is to re-familiarize APG personnel with situations and practices which have the potential to cause storm water contamination. The purpose is also to review operation practices or best management practices to ensure that harmful materials or contaminants are not being disposed of in a manner that would allow exposure to storm water.
- #17 The purpose of annual training is to re-familiarize APG personnel with situations and practices which have the potential to cause storm water contamination. The purpose is also to review operation practices or best management practices to ensure that harmful materials or contaminants are not being disposed of in a manner that would allow exposure to storm water.
- #18 The purpose of annual training is to re-familiarize APG personnel with situations and practices which have the potential to cause storm water contamination. The purpose is also to review operation practices or best management practices to ensure that harmful materials or contaminants are not being disposed of in a manner that would allow exposure to storm water.