Department of Ecology Industrial Stormwater Permit Site Inspections: What to expect How to stay in c

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Department of Ecology Industrial Stormwater
Permit Site InspectionsWhat to expect How
to stay in compliance

• Andrew Craig, Megan Darrow and Paul Stasch
• Department of Ecology Inspectors
• June 12, 2008

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Main Points

• What inspectors look for and review during
  inspections
• Practical tips and BMPs - Best Management
  Practices for permit compliance
• Recordkeeping and Reporting
• (Guidance and Forms)

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Ecology Site Inspections
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Ecology Site Inspections

• Announced
• Unannounced
• Complaint driven
• Sampling driven
• Purpose Assess compliance with permit
  requirements and RCW 90.48.

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Ecology Site Inspections - Inspectors will
review discuss

• What is the Permit?
• Permit focus (source control) and requirements
• Sampling results (DMRs)
• Site conditions
• Pollutant sources, Sampling locations, BMP
  status G, F, P
• Permit violations
• Recommendations for compliance

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What is the Industrial SW General Permit?

• Stormwater pollution control permit
• Required by Federal Clean Water Act
• Allows a facility to legally discharge stormwater
  into waters of the US and Washington State,
  according to permit terms and conditions.
  CONTRACT

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Permit Requirements What do inspectors check
for?

• Stormwater Pollution Prevention Plan (SWPPP)
• On-site?
• Complete?
• Implemented over time? - records
• Monitoring
• - Visual site inspections (Outfalls and BMPs)
  
• completed quarterly and tracked?
• - Stormwater sampling completed quarterly?
• - Sampling location and methods representative?

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Permit requirements What do inspectors check
for?

• Adaptive Management
• Level 1, 2 and 3 responses completed?
• BMP scope/frequency modified or increased?
• Additional BMPs implemented?
• Did actions taken on site reduce pollutant levels
  in stormwater discharges?
• Source control vs. Treatment response?

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Permit requirements What do inspectors check
for?

• Reporting and Recordkeeping
• - Quarterly (on Ecology forms DMRs)
• - Level 1 reports kept in SWPPP?
• - Level 2 and 3 reports submitted to Ecology?
• - Spills and other incidents of noncompliance
• recorded?
• - Inspections and BMP modifications recorded?

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Permit requirementsWhat do inspectors check
for?

• Stormwater discharges from site must meet WA
  State Water Quality and Sediment Standards and
  receive AKART
• Photographs and Sampling
• BMP scope and frequency

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SWPPP Requirements
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SWPPP Requirements Inspectors check for

• Pollution Prevention Team
• Facility Site Assessment
• Monitoring Plan must cover inspections,
  sampling point(s) and procedures

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SWPPP Requirements Inspectors check for

• Good Housekeeping and Preventative Maintenance
  Actions
• Spill Clean Up Procedures, Equipment and
• Personnel
• Training employees annually on SWPPP
• requirements

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SWPPP Requirements Inspectors check for

• Enhanced/Additional BMP requirements
• (Based on self-inspection or notice from
  Ecology)
• Recordkeeping and Reporting
• Inspections
• BMPs scope/frequency
• Sampling results and DMRs

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Monitoring Requirements
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Monitoring Requirements Inspectors check for

• Monitoring Plan
• Describes how and why sampling location(s)
  selected?
• Describe where, why and how often areas are
  inspected?
• Visual Inspections (outfalls and BMPs)
• Quarterly and additional dry season frequency?
• Inspection records kept and up to date?
• Sampling (compare to benchmarks)
• Completed Quarterly?
• Data trends?
• Response to sampling results completed? Tracked?

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Industrial SW General Permit Benchmarks How
inspectors evaluate water sample results
BM AL
Benchmark Action Level
Increasing Concentration
Increasing Risk for violating WQS
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Industrial SW General Permit Benchmarks
BM AL
Benchmark Action Level
When sample results are frequently greater than
Action Level values. . .
Increasing risk for violating WQS
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Site Conditions Focus

• ID pollutant sources and activities
• Do BMPs prevent pollutants from entering
  stormwater drainage system
• Sampling locations and outfalls

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Site Conditions What Inspectors look for?

• Potential sources of pollution
• Common outdoor activities
• Materials stored outside that can wash into
  surface waters
• Fueling or vehicle maintenance areas
• Spills, leaks and other discharges
• Gravel, dirt or muddy areas
• - Indoor drains that discharge to stormwater
  system

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What Inspectors look for?

• Materials stored outside that can wash into
  surface waters
• Chemicals, fuels and metals (e.g., copper lead)
• Oil and grease products
• Fertilizers and Pesticides
• Soaps and other cleaners
• Raw materials (e.g., dust, sand, soil and bark)
• Waste products or containers

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What Inspectors look for?

• Spills, Leaks and other discharges
• Equipment maintenance and parking areas
• Fueling areas
• Storm drain maintenance
• Washing and cleaning areas
• Material stockpiles
• Equipment leaks
• Load and Unload Areas

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Spills and Leaks Stormwater pollution
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What Inspectors look for?

• Housekeeping BMPs
• Sweeping, absorbent materials, vacuuming,
  washing, pumping
• Preventative Maintenance BMPs
• Stormwater drainage and treatment devices
• Spill Cleanup procedures, equipment and personnel
• Structural or Operational BMPs
• Covered areas, move activity inside, cleaning,
  washing, chemical and fertilizer use, load and
  unload areas, erosion control
• Train employees on BMPs annually

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What Inspectors look for?

• Prevent pollutants from entering stormwater
  drainage system
• Move activity, equipment or materials inside or
  under cover
• Schedule activity during dry weather periods
• Clean work, material storage areas and structures
  during and after shifts
• Examples regularly inspect, sweep, absorb,
  vacuum, pump to vegetated areas, catch basin
  inserts, clean out catch basins.

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Cover materials stored outside
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Cover materials stored outside
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Cover / Enclose outdoor activity
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Absorb liquids, sweep up solids
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Sweep and clean up solids
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Absorb liquids, sweep up solids
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Cover Drums and Designate liquid waste collection
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Sweep up solids vac sweeper
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Catch Basin Inserts
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Catch Basin Inserts oil absorbing pads change
often
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Inspect and clean out catch basins periodically
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Pressure washing work areas
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Pressure washing collect liquids and solids
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Pressure washing infiltrate liquids and solid
disposal
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Pressure washing proper solids disposal
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Collect washwater to sanitary sewer permission
needed
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Collect washwater to sanitary sewer
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Collect washwater to sanitary sewer
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What Inspectors look for?

• Prevent pollutants from entering stormwater
  drainage system
• Clean vehicles and equipment at
• Commercial car wash
• Designated areas that go to sanitary sewer
  (Permission)
• Designated collection / infiltration areas
• Repair or refuel vehicles/equipment inside, under
  storm resistant shelter or designated area
• Store liquids in covered areas or containers
• Shipping containers
• Secondary containment

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Covered wash and maintenance area
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Covered wash and maintenance area
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Covered fuel area secondary containment fuel
tank
To OWS
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Shipping container rain shelter
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What Inspectors look for?

• Prevent pollutants from entering stormwater
  drainage system
• Use drip pans and absorbent materials
• Designate specific containers/areas for liquids
• Reduce, reuse and recycle fluids or other wastes
• Create and maintain spill stations nearby
  vehicle repair, load and unload or other areas
  where spills are likely
• Ensure employees can locate and use spill station

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Drip Pan and absorbent pad
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Kitty Litter absorb liquids
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Oil absorbent booms
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Covered/Designated Liquid Waste Collection and
Recycling area
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Covered Storage for Fuels, Paints and other
liquids
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Secondary Containment within covered storage
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Spill station next to load/unload or refueling
area
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Spill Station outdoor maintenance area
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Spill Station- next to load/unload or refueling
area
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What Inspectors look for?

• Prevent pollutants from entering stormwater
  drainage system
• Use tarps to catch solids, chips, dusts
• Use other structures to prevent SW contact
• Routinely check and clean out sediments from
  stormdrains or other stormwater treatment
  (ponds/vaults)
• Maintain Oil Water Separators or other SW
  treatment systems
• Dispose of oil or storm drain wastes properly

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BMP examples - tarps
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BMP examples - tarps
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Use tarps and shop vac to collect solids daily
or more often
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Structural BMP Speed bumps
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Waste Container Lids
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Inspect and clean out catch basins periodically
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SW treatment BMP maintain oil water separators
and other oil BMPs
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SW Treatment BMP Filter Cartridges
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What Inspectors look for - Proper Waste Disposal

• Three Waste Types
• Solid Waste
• Hazardous Waste
• Dangerous Waste
• Small, Medium and Large Quantity Generators
• Who do you call for help?
• Local (City/County Health Dept)
• State (Dept of Ecology Hazardous Waste staff)
• Electronic and Fluorescent Tube Recycling
• Contractors (catch basins, oil, antifreeze, etc)
• More info available from Ecology Haz Waste, Port
  or Health Dept

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What Inspectors look for?

• Evaluate BMP program performance
• Inspect outfalls or storm drains nearby work
  areas
• ID possible Stormwater Violations
• ID poor Housekeeping and Maintenance
• ID poor Spill Control or Response
• Check Inspection, Housekeeping and Maintenance
  logs
• Are BMPs reviewed and revised based upon
  inspection and sampling results?

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Inspect Outfalls
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Inspect Stormdrains(Note sheens and muddy water)
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Inspect Stormdrains (Note outdoor activities,
materials muddy water)
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Possible Stormwater Violations
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Possible Stormwater Violations poor housekeeping
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Possible Stormwater Violations poor maintenance
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Possible Stormwater Violations Equipment
/materials outside uncovered oil spills
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Possible Stormwater Violations Materials
outside uncovered
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Possible Stormwater Violations Equipment spills
and leaks
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Possible Stormwater Violations Spills and leaks
poor spill response
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Stormwater Violations Discharge to surface
waters
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Stormwater Violations Discharge to surface
waters
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Stormwater ViolationsDischarge to surface waters
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Stormwater Violations Discharge to surface
waters
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Questions?
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Ecology Guidance and Formsfor Recordkeeping
and Discharge Monitoring Reports
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Ecology Guidance and Forms

• SWPPP
• Visual Inspections
• Sampling
• DMRs
• Level 1, 2 and 3 Report examples

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SWPPP Guidance and Forms

• SWPPP Guidance Manual
• http//www.ecy.wa.gov/biblio/0410030.html
• SWPPP Forms
• http//www.ecy.wa.gov/programs/wq/stormwater/swppp
  _forms.doc
• Guidance for Industrial Stormwater Discharges
  http//www.ecy.wa.gov/biblio/9938.html

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Monitoring Visual Inspection Guidance and Forms

• Visual Inspection Forms http//www.ecy.wa.gov/pro
  grams/wq/stormwater/industrial/vis_mntrg.xls
• Visual inspection instructions
  http//www.ecy.wa.gov/programs/wq/stormwater/indus
  trial/vis_mntrg_instr.doc
• Contact Ecology inspector by phone or email

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Monitoring Water Sampling Guidance

• Sampling Guidance
• http//www.ecy.wa.gov/pubs/0210071.pdf
• Finding a Lab to analyze samples
• http//www.ecy.wa.gov/programs/wq/stormwater/indus
  trial/labs.html
• Contact Ecology inspector by phone or email

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Sampling Table example - Track Results
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Discharge Monitoring Reports common problems

• Not submitted
• Not signed
• Discharge Point change
• Multiple discharge points
• Units incorrect (mg/L vs. ug/L)
• All required sampling parameters not analyzed or
  submitted
• Level 1 summary not included with DMR

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Ecology DMR
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Level 1 Report Form - example
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Level 2 Report Form - example
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Level 3 Report Form - example
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Ecology Web Site links

• What is Stormwater? http//www.ecy.wa.gov/programs
  /wq/stormwater/municipal/about_stormwater.html
• Muni, Industrial and Construction SW Permit Focus
  Sheets
• http//www.ecy.wa.gov/programs/wq/stormwater/perm
  it_focus_sheets.html
• Industrial SW NPDES Permit
• http//www.ecy.wa.gov/programs/wq/stormwater/indu
  strial/index.html

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Questions?