NPDES Erosion and Sediment Control

Northwest District Office
NPDES Stormwater
Overview
November 3, 2014
NPDES Stormwater Program
e
Required by the Clean Water Act (1972). The
program regulates stormwater discharges into
surface waters from certain:
Municipal Separate Storm Sewer Systems
(MS4)
Construction Activities
Industrial Facilities
The NPDES Stormwater Program
is not ERP.
The Environmental
Resource Permitting
ERP) Program is
authorized under
Chapter 373, Florida
Statutes (F.S.).
The NPDES
Stormwater Program is
authorized under
Chapter 403, F.S.
Why is Stormwater a Problem?
Sediment
Bacteria
Oil and Grease
Nutrients
Trace Metals
Pesticides
GP – Large & Small
onstruction Activities
gulated by the NPDES
ormwater Program
Stormwater Erosion and
Sediment Control
Minimize the extent of the area
exposed at one time and the
duration of exposure.
Keep runoff velocities low and
retain runoff onsite.
NPDES Stormwater
Construction Activities
Regulate construction
activities that
ultimately disturb >1
acre
Currently processes
~3,000 Notices of
Intent (construction
permits) each year
How do you apply for coverage
under the CGP?
Develop a Stormwater Pollution Prevention
Plan (SWPPP)
Submit a Notice of Intent (NOI)
NOIs can be submitted electronically at:
www.dep.state.fl.us/water/stormwater/npdes/index.htm
Current application fees:
$250 (small construction >1 to <5 acres)
$400 (large construction > 5 acres)
Construction Generic Permit (CGP)
April
April
May
May
June
June
Coverage is effective two days following the submittal of a
mplete application and fee.
The generic permit (CGP) is effective for five years.
NPDES Stormwater Construction
Activity Permit Requirements
Develop a Stormwater
Pollution Prevention
Plan (SWPPP) to
prevent the discharge
of pollutants
(sediment)
Conduct weekly/ 0.5”
rain event inspections
Correct noncompliance issues
within 7 days
Map Direct Check Boxes
Stormwater, Erosion, & Sedimentation Control
Inspector Training Program
Course Content:
Impacts of Erosion and
Sedimentation
BMPs for Erosion and
Sedimentation Control
BMPs for Stormwater
Management Systems
Class Schedule:
http://www.dep.state.fl.us/wat
Qualified Stormwater
Inspector
MSGP - Industrial Activities
Regulated by the NPDES
Stormwater Program
NPDES Stormwater Industrial Activities
Regulate over 2,700
industrial facilities.
Facilities are required to
implement appropriate
pollution prevention
techniques to reduce the
contamination of
stormwater runoff.
What Industrial Activities are regulated?
(simplified descriptions)
Heavy
Manufacturing
Mining/oil gas
exploration
Hazardous Waste
Facilities
Landfills
Recycling Facilities
(automotive
salvage yards,
recycling facilities)
5. Steam Electric
Power Plants
6. Transportation
Industries
(Trucking, Airports,
Marinas)
7. Light Industry
(printing,
warehousing)
8. Treatment works
Regulated Industrial Activities by
Industrial Sector
Sector A: Timber Products
Sector B: Paper Products Manufacturing
Sector C: Chemical Manufacturing
Sector D: Asphalt Paving
Sector E: Glass, Clay, Cement, Man.
Sector F: Primary Metals
Sector G: Metal Mining
Sector H: Coal Mines
Sector I: Oil and Gas Extraction
Sector J: Mineral Mining & Dressing
Sector K: Hazardous Waste Facilities
Sector L: Landfills
Sector M: Auto Salvage Yards
Sector N: Recycling Facilities
Sector O: Power Plants (Steam)
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Sector P: Land Transportation
Sector Q: Water Transportation
Sector R: Ship & Boat Building
Sector S: Air Transportation
Sector T: Treatment Works
Sector U: Food & Kindred Products
Sector V: Textile Mills
Sector W: Furniture & Fixtures
Sector X: Printing & Publishing
Sector Y: Plastics Manufacturing
Sector Z: Leather Tanning & Finishing
Sector AA: Fabricated Metal Products
Sector AB: Transportation Equip.
Sector AC: Electronic Goods
Sector AD: Additional Activities…..
Does my facility need NPDES
Stormwater Permit Coverage?
s your facility a regulated “industrial activity”
as defined in 40 CFR 122.26(b)(14)?
Does your facility discharge stormwater to
waters of the state or into an MS4?
f the answer is yes to both questions, the
acility needs NPDES Stormwater Permit
coverage.
NPDES Stormwater Permitting Options
Multi-Sector
Generic Permit
(MSGP)
 Most facilities are
eligible for coverage
under the MSGP
~2,303 active MSGP’s
“No Exposure
Exclusion” (NEX)
 All industrial processes
and materials are not
exposed to stormwater
~798 active NEX’s
Individual Permit
 Issued by the FDEP
District Offices
 ~20 individual stormwater
permits statewide
How do you apply for coverage
under the MSGP?
Develop a Stormwater Pollution Prevention
Plan (SWPPP)
Complete and submit a Notice of Intent (NOI)
 NOIs can be submitted electronically or by mail at:
www.dep.state.fl.us/water/stormwater/npdes/index.htm
Current application fee is $500
MSGP Permit Coverage
April
April
May
May
June
June
 Permit coverage is effective two days following the
submittal of a complete application and fee.
The MSGP permit is effective for five years.
What is a Stormwater Pollution
Prevention Plan (SWPPP)?
Identifies controls to reduce stormwater
pollution
Includes a maintenance and inspection
schedule
Monitoring and reporting requirements
A SWPPP is a road map that helps you
comply with your permit.
MSGP BMP’s
What BMP’s are Currently Employed at the
facility
Are the BMP’s Maintained consistently with the
SWPPP?
Do BMP’s appear to be sufficient to protect
surface waters?
MSGP SWPPP Checklist
MSGP Site review
Annual Comprehensive
Evaluation
MSGP Common Issues
No SWPPP
No Quarterly Visual Inspections
No Analytical Monitoring Done
No Annual Comprehensive Evaluation
MSGP Monitoring Types
Determined by MSGP Sector
Three types of monitoring
 Visual
 Analytical
 Compliance
Visual Monitoring
Quarterly visual
xamination of
tormwater discharges
 Color
 Odor
 Solids / Foam
 Sheen
o analytical tests
equired
Analytical Monitoring
Required in the 2nd & 4th
ear of permit coverage
or certain industrial
ectors
ab results help gauge
he effectiveness of the
WPPP
Results are compared to
cutoff” or “benchmark
alues”
Compliance Monitoring
MSGP Sector
SIC Code
Activity A
2411
Wet deck storage
C
287X
Ag chemicals –P Fertilizer
D
2951
Asphalt/roofing emulsions
E
327X
Concrete Products
All Sectors
(Primarily O)
Varies
Coal Pile Runoff
 Compliance monitoring is required for certain types of
stormwater discharges. The discharges are subject to
numeric stormwater effluent limitations.
Wet Deck Storage
Wet Deck Storage
CONDITIONAL EXCLUSION FOR
“NO EXPOSURE”
No Exposure (NEX)
o Exposure ertification For xclusion From PDES Stormwater
ermitting
RULE 62‐
20.910(17), F.A.C.)
Industrial “No Exposure” Exclusion
“No exposure” means
that all materials and
activities are protected
by shelter that prevents
exposure to
precipitation.
 Application includes 11
yes/no questions to
determine if no exposure
exists
 Application fee is
currently $200
 Coverage is effective for
five years
Benefits of NEX Permit
No visual quarterly monitoring is required
No annual comprehensive evaluation is required
No SWPPP is required.
ote: Compliance inspections are still done by the
epartment.
CGP BMP’s
What BMP’s are currently employed at the
construction site
Are the BMP’s maintained consistently with the
SWPPP?
Do BMP’s appear to be sufficient to protect
surface waters?
CGP SWPPP Common Issues
Locations of surface waters, wetlands, MS4
Latitude and longitude of each discharge point
Soil data
Waste disposal
Fertilizers, herbicides and pesticides
Toxic substances
Non-stormwater discharges
Contractor subcontractor certification
Responsible Authority Certification
CGP Commom Construction
Site Issues
Silt fence maintenance
Stormwater infrastructure not completed first
Improper inspections (do the entire site)
Improper site assessment (wetland flow)
No staged construction (leave vegetation)
No Responsible Authority Certification signature
Weak BMP’s (stronger aggressive measures)
Failure to do BMP maintenance (fix problems)
No additional BMP devices onsite for emergency
Additional BMP Devices Onsite
Real World Scenarios
NPDES Stormwater Contacts
PDES Stormwater Notices Center HotlineRequest permits, forms & files- call toll free
 (866) 336-6312
d Smith-Program Administrator-(850) 245-8568
Borja Crane Amores-Env. Manager-(850) 245-7520
Kevin Hargett-NPDES Stormwater Compliance
oordinator NWD-(850) 595-0687