General Permit for Storm Water Discharges

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
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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 . . .
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NEW Requirements /Changes
Effective July 1, 2015
HOWEVER preparation ahead of time is required!
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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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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).
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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))
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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.
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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
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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.
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Numeric Action Limits
TABLE 5: Parameter NAL Values, Test Methods, Detection Limits, and Reporting Units
PARAMETER
pH*
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
Nitrate + Nitrite Nitrogen
Total Phosphorus
EPA 200.7
0.005
mg/L
1.0
SM 4500-NO3- E
0.01
mg/L as N
0.68
SM 4500-P B+E
0.05
mg/L as P
2.0
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
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Ammonia
SM – Standard Methods for the Examination of Water and Wastewater, 18th 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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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 15th)
•ERA Demonstrations
•Demonstration Technical Reports
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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
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