Industrial General Permit Notice of Non-Applicability

1
Industrial General Permit Notice of
Non-Applicability

• Presented By
• Conestoga-Rovers Associates
• Fred Blickle and Michael Beerends
• Air Waste Management Association (AWMA)
• Golden Empire Chapter
• September 16, 2014

2
Overview of CRA (a GHD Company)

• CRA originally established in 1976, over 35 years
  of experience with more than 50,000 successfully
  completed projects
• CRA merged with GHD on July 2, 2014
• Now one of the largest privately held engineering
  and environmental firms with over 8,500 people in
  five continents
• 370 staff in 15 California locations
  (Bakersfield, Concord, Emeryville, Eureka (2),
  Fresno, Irvine (2), Rancho Cordova, Sacramento,
  San Diego, San Francisco, San Jose, Santa Rosa,
  and Sonoma)
• One of few large consulting firms registered to
  ISO 90012008

3
Health Safety

• Safety ranks as the highest priority commitment
  by CRA
• Our employees are our most valuable resource and
  understand that all incidents are preventable.
• CRAs Safety Performance best in industry

Year CRA Total Recordable Incident Ratio (TRIR) CRA Experience Modification Rate
2013 0.08 0.70
2012 0.24 0.78
2011 0.22 0.79
2010 0.34 0.75
2009 0.43 0.80
2008 0.46 0.77
Industry Average TRIR as reported by US Bureau
of Statistics is 1.3 (2011)
4
Regulatory Background

• The Federal Clean Water Act (1987) 40 CFR part
  122 requires industries with storm water
  discharges to surface waters to obtain permits
  under the National Pollutant Discharge
  Elimination System (NPDES)
• California Water Code Section 13000
• California NPDES Program is part of the State
  Water Boards division of water quality

5
Industrial Storm Water General Permit Updates
Regulatory Update

• Current Permit Order 97-03-DWQ has expired
• Remains in effect until new General Permit is
  adopted
• New Permit - Order 2014-0057-DWQ adopted April
  2014 and becomes effective July 2015
• Any facility with point source storm water
  discharges associated with industrial activities,
  as defined in the Federal storm water regulations
  codified at 40 CFR 122.26 (b) (14), must obtain
  permit coverage
• http//www.swrcb.ca.gov/water_issues/programs/stor
  mwater/industrial.shtml

6
Industrial Facilities Covered

• Appendix A of new Industrial Permit
• Facilities subject to 40CFR Ch I (Cement Manu.,
  Feedlots, Fertilizer Manu., Petro Refining,
  Phosphate Manu., Steam Elect., Coal Mining,
  Mineral and Ore Mining Process., Asphalt
  Emulsion, Landfills, Airport Deicing)
• Manufacturing Facilities with SIC 20XX through
  39XX, 4221 through 4225
• Oil Gas/Mining Facilities
• Hazardous Waste Treatment, Storage, and Disposal
  Facilities
• Landfills, Land Application Sites, and Open Dumps
• Recycling Facilities
• Steam Electric Power Generating Facilities
• Transportation Facilities
• Sewage or Wastewater Treatment Works

7
General Permit Coverage

• Three Options for General Permit Coverage
• File Notice of Intent (NOI)
• Site Map
• Storm Water Pollution Prevention Plan
• No Exposure Certification (NEC)
• Notice of Non-Applicability (NONA)

8
It Does Rain in Bakersfield

• Avg. 6.50 per year.
• Max Month 6.33 (December 2010)
• Highest Single Day 2.53 (2/10/1978)

9
What is a Discharge???

• A Discharge occurs when storm water
• crosses the property boundary (sheet flow)
• enters Waters of the United States (lakes, ponds,
  rivers, streams, tributaries and wetlands) which
  can happen on the surface or below ground or
• enters a municipal separate storm water system
  (that discharges to Waters of the US)

10
Storm Water Pollutants

• Hydrocarbons (e.g. fuel, oil and grease)
• Toxics (e.g. pesticides, solvents, paint)
• Organics (oxygen demanding substances)
• Nutrients (e.g. phosphorus and ammonia)
• Pathogens (e.g. bacteria and viruses)
• Sediment (silt and clay colloids)
• Salt (chlorides and other ions)
• Accidental Spills, leaks from piping
• Other related products/by products

11
Sources of Storm Water Impacts

• Paved areas (roads, parking areas, etc).
• Unpaved areas (highly compacted and void of
  vegetation)
• Roofs (eaves, rain gutters)
• Material handling activities exposed to storm
  water
• Vehicle fueling and cleaning areas
• Cullet Piles
• Storage of chemicals
• Storage of fuels, oil
• Storage of scrap metal
• Transformers

12
Facilities claiming No Discharge must
Notice of Non-Applicability (NONA)

• Be engineered and constructed to contain the
  maximum historic precipitation event or
• Located in basins or physical locations not
  hydrologically connected to water of the United
  States and
• Submit and certify via SMARTS both the NONA and a
  No Discharge Technical Report if requested by the
  Regional Board

13
No Discharge Technical Report

• Facility Containment Design including
• Survey of existing stormwater retention systems
• Hydrologic analysis of tributary watershed
• Stormwater retention system capacity analysis
• Soil permeability analysis
• Soil stability analysis
• Receiving water evaluation (above- and
  below-ground)
• Safety factor considerations (freeboard)
• Certified by California Licensed Professional
  Engineer

14
Capacity and Drainage Survey

• Survey
• To determine capacity of retention basin
• To determine storm water flow patterns and
  directions

15
Hydraulic Calculations

• Calculations
• Hydrologic modeling of watershed
• Determination of total tributary area (facility
  and run-on)
• Evaluation of watershed (land uses and soil
  types)
• Maximum Historic Precipitation Event (MHPE)
  values based on NOAA data
• Recommend to default to local standards if more
  stringent than MHPE
• Design storm event volumes
• Retention System Capacity Analysis
• Stage-Storage of existing or proposed retention
  system based on survey
• Comparison against design storm event volumes

16
Soil Determination

• Soil Permeability and Stability
• Retention system soil types
• Retention system infiltration rates
• Basin plan limitations
• Depth to groundwater
• Potential impacts to groundwater

17
Reporting Requirements

• NONA and No Discharge Technical Report
• Certified and submitted via SMARTS by facility
  LRP within 60-days of being requested by the
  Regional Board
• Signed by a California Professional Engineer

18
Additional Considerations

• No Discharge determination does not cover storm
  water containment systems the transfer industrial
  pollutants to groundwater.
• Must determine if infiltration may discharge to
  and contaminate groundwater
• Permit does not provide guidance for
  determination
• Facilities that have not eliminated discharges
  subject to the General Permit are ineligible to
  submit a NONA

19
Best Management Practices

• Best Management Practices (BMPs) are measures
  which may be implemented to prevent or mitigate
  pollution from activities performed at a
  facility. They are broad measures including
  process, procedures, schedule of activities,
  prohibitions, and other management procedures
  which prevent or reduce storm water pollution.
• Good Housekeeping
• Preventative Maintenance
• Visual Inspections
• Spill Prevention/Response
• Sediment/Erosion Control
• Training
• Record Keeping

20
Facility Controls

• Structural Controls
• Preventative Measures (signs, labels, and
  security)
• Diversions (conveyances, dikes, grading, sloping,
  and pavements)
• Containment (secondary containment, curbs, and
  drip pans)
• Other Controls (sumps, pumps, separators and
  basins)

21
Routine Inspections

• Outfalls
• Drum storage areas
• Containment areas
• Drainage
• Sediment basin
• Retention ponds
• Shipping/Receiving
• BMPs
• Vehicle washing

• Catch basins
• Haz waste storage
• Cullet storage
• ASTs
• Fueling areas

22
Reporting Releases or Discharges

• Reported to Regional Water Board
• Reported within 24 hours if human health or
  environment issue
• Written submission
• Description of release
• Date and time of release
• Measures taken to stop, and prevent recurrence
• Inspection reports (annual routine)

23
Industrial Storm Water Permit

• QA / Thank you for having us AWMA!
• Fred Blickle 313-506-9799
• Mike Beerends 559-286-9999