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

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


1
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

2
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)

3
Ecology Site Inspections
4
Ecology Site Inspections
  • Announced
  • Unannounced
  • Complaint driven
  • Sampling driven
  • Purpose Assess compliance with permit
    requirements and RCW 90.48.

5
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

6
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

7
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?

8
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?

9
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?

10
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

11
SWPPP Requirements
12
SWPPP Requirements Inspectors check for
  • Pollution Prevention Team
  • Facility Site Assessment
  • Monitoring Plan must cover inspections,
    sampling point(s) and procedures

13
SWPPP Requirements Inspectors check for
  • Good Housekeeping and Preventative Maintenance
    Actions
  • Spill Clean Up Procedures, Equipment and
  • Personnel
  • Training employees annually on SWPPP
  • requirements

14
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

15
Monitoring Requirements
16
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?

17
Industrial SW General Permit Benchmarks How
inspectors evaluate water sample results
BM AL
Benchmark Action Level
Increasing Concentration
Increasing Risk for violating WQS
18
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
19
Site Conditions Focus
  • ID pollutant sources and activities
  • Do BMPs prevent pollutants from entering
    stormwater drainage system
  • Sampling locations and outfalls

20
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

21
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

22
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

23
Spills and Leaks Stormwater pollution
24
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

25
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.

26
Cover materials stored outside
27
Cover materials stored outside
28
Cover / Enclose outdoor activity
29
Absorb liquids, sweep up solids
30
Sweep and clean up solids
31
Absorb liquids, sweep up solids
32
Cover Drums and Designate liquid waste collection
33
Sweep up solids vac sweeper
34
Catch Basin Inserts
35
Catch Basin Inserts oil absorbing pads change
often
36
Inspect and clean out catch basins periodically
37
Pressure washing work areas
38
Pressure washing collect liquids and solids
39
Pressure washing infiltrate liquids and solid
disposal
40
Pressure washing proper solids disposal
41
Collect washwater to sanitary sewer permission
needed
42
Collect washwater to sanitary sewer
43
Collect washwater to sanitary sewer
44
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

45
Covered wash and maintenance area
46
Covered wash and maintenance area
47
Covered fuel area secondary containment fuel
tank
To OWS
48
Shipping container rain shelter
49
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

50
Drip Pan and absorbent pad
51
Kitty Litter absorb liquids
52
Oil absorbent booms
53
Covered/Designated Liquid Waste Collection and
Recycling area
54
Covered Storage for Fuels, Paints and other
liquids
55
Secondary Containment within covered storage
56
Spill station next to load/unload or refueling
area
57
Spill Station outdoor maintenance area
58
Spill Station- next to load/unload or refueling
area
59
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

60
BMP examples - tarps
61
BMP examples - tarps
62
Use tarps and shop vac to collect solids daily
or more often
63
Structural BMP Speed bumps
64
Waste Container Lids
65
Inspect and clean out catch basins periodically
66
SW treatment BMP maintain oil water separators
and other oil BMPs
67
SW Treatment BMP Filter Cartridges
68
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

69
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?

70
Inspect Outfalls
71
Inspect Stormdrains(Note sheens and muddy water)
72
Inspect Stormdrains (Note outdoor activities,
materials muddy water)
73
Possible Stormwater Violations
74
Possible Stormwater Violations poor housekeeping
75
Possible Stormwater Violations poor maintenance
76
Possible Stormwater Violations Equipment
/materials outside uncovered oil spills
77
Possible Stormwater Violations Materials
outside uncovered
78
Possible Stormwater Violations Equipment spills
and leaks
79
Possible Stormwater Violations Spills and leaks
poor spill response
80
Stormwater Violations Discharge to surface
waters
81
Stormwater Violations Discharge to surface
waters
82
Stormwater ViolationsDischarge to surface waters
83
Stormwater Violations Discharge to surface
waters
84
Questions?
85
Ecology Guidance and Formsfor Recordkeeping
and Discharge Monitoring Reports
86
Ecology Guidance and Forms
  • SWPPP
  • Visual Inspections
  • Sampling
  • DMRs
  • Level 1, 2 and 3 Report examples

87
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

88
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

89
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

90
Sampling Table example - Track Results
91
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

92
Ecology DMR
93
Level 1 Report Form - example
94
Level 2 Report Form - example
95
Level 3 Report Form - example
96
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

97
Questions?
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