NEWEA 2014 Spring Conference
•Download as PPT, PDF•
1 like•484 views
This document summarizes a presentation on industrial stormwater discharge and regulatory requirements. It discusses the Clean Water Act and how it regulates point source and non-point source pollution. It outlines the Multi-Sector General Permit that regulates industrial stormwater dischargers, including permit requirements, exemptions, sectors, sampling, and the 2013 proposed permit changes. It also reviews stormwater data and sector-specific monitoring requirements for metals.
Recommended
More Related Content
What's hot
What's hot (17)
Similar to NEWEA 2014 Spring Conference
Similar to NEWEA 2014 Spring Conference (20)
More from David Horowitz
More from David Horowitz (20)
Recently uploaded
Recently uploaded (20)
NEWEA 2014 Spring Conference
- 1. NEWEA 2014 Spring Conference Industrial Stormwater Discharge – It’s a Piece of the Stormwater Puzzle! Tuesday, June 3, 2014 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
- 3. Acronyms ■ BMP – Best Management Practice ■ ICP – Integrated Contingency Plan ■ LID – Low Impact Development ■ MSGP – Multi-Sector General Permit ■ NOI – Notice of Intent ■ 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 ■ WLA – Waste Load Allocation
- 4. General ■ What is stormwater? – Storm water is rainfall runoff, snow melt runoff, and surface runoff and drainage
- 5. Why Do We Care About Stormwater? ■ Contaminated stormwater is a significant source of surface water pollution ■ Pollution on the land can end up in stormwater runoff and into our water bodies
- 6. Regulatory Background ■ Point Source 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
- 7. Regulatory Background ■ Industrial Stormwater Dischargers – 1995 Multi-Sector General Permit – 2000 Multi-Sector General Permit » Renewed – 2008 Multi-Sector General Permit » Renewed three years after expiration – 2013 Draft Multi-Sector General Permit » Awaiting renewal
- 8. Storm Water Discharges – What do these states have in common?
- 9. Delegated States ■ Most states 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
- 10. New England States State General Permit - Effective Date General Permit - Expiration Date Comment Massachusetts September 29, 2008 September 29, 2013 Federal Permit New Hampshire September 29, 2008 September 30, 2013 Federal Permit Maine April 26, 2011 April 25, 2016 State Permit Connecticut October 1, 2011 September 30, 2016 State Permit Rhode Island August 15, 2013 August 14, 2018 State Permit Vermont August 4, 2011 August 4, 2016 State Permit
- 11. NPDES - Industrial ■ Permitting Options? – Multi-Sector General Permit (MSGP) – Federal or state – Meant to be easy – No Exposure Certification (NEC) – Still need to file! – Individual Wastewater Discharge Permit – Don’t need these for stormwater
- 12. 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.
- 13. 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)
- 14. Sectors & SIC
- 16. NPDES - Industrial ■ Breaking News …. – EPA’s MSGP expired on September 29, 2013 – The more things change ….
- 18. Stormwater ■ 2013 MSGP (Proposed) – Improve permit clarity – Address errors – Streamline the permit – Added NAICS code cross-reference
- 19. ■ 2013 MSGP (Proposed) – Added specificity for effluent limits – Superfund Site Protection – Improved public accessibility » Post plan » Provide plan elements in NOI Stormwater
- 20. ■ 2013 MSGP (Proposed) – Electronic filing – Pavement wash water – Reduced inspections – Specific deadlines – Saltwater benchmark – Airport deicing effluent limits Stormwater
- 21. General ■ Are There Exemptions? – Industrial » Physically impossible for storm water to discharge from the site » Recycling of storm water with no resulting discharges » Pumping and hauling of storm water to an authorized disposal facility » Discharging of storm water to a publicly owned treatment works (POTW) » Injecting storm water underground » Containing of all storm water within property boundaries
- 22. General ■ No Exposure Certification (NEC) – 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.
- 23. Multi-Sector General Permit (MSGP) Implementation ■ SWPPP Contents ■ Discharges to Water Quality Impaired Waters ■ Quarterly Visual Inspections ■ Annual Comprehensive Inspections ■ Benchmark/Numeric Effluent Monitoring ■ Electronic Reporting To EPA – Sample Results (<30 days) – Inspection Reports (<45 days) ■ Employee Annual Training
- 24. 2000 - 2008 MSGP Comparison
- 25. 2000 - 2008 MSGP Comparison
- 26. Data Review ■ Shift to No Exposure ■ Less Sites Covered – 21% ■ Site closures? ■ Re-evaluation of regulated discharges?
- 27. 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
- 29. Sampling & Monitoring ■ What is a Representative Rain Event? – 0.1” of measured precipitation – Occurs at least 72 hours from the last 0.1 inch or more of measurable precipitation – Sufficient enough discharge from the outfall to obtain a sample
- 30. Objectives/Takeways ■ Industrial Stormwater Introduction ■ Stormwater requirements ■ Potential pollutant sources ■ New England framework THANK YOU!!!!!
Editor's Notes
- 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!
- So weather you call it Storm Water – with 2 words – as in MA or Stormwater with one word – as EPA does – it is defined as rainfall runoff, snow melt runoff, and surface runoff and drainage.
- 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.
- 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.
- Permitting options…. MSGP No esposure NPDES permit First – for MSGP……
- Permitting options…. MSGP No esposure NPDES permit First – for MSGP……
- Permitting options…. MSGP No esposure NPDES permit First – for MSGP……
- Are there exemption – Yes some!
- 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.
- 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.
- 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.