NPDES Industrial Stormwater General Permit Case Study: ConGlobal Industries

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Chad Harrison
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1 NPDES Industrial Stormwater General Permit Case Study: ConGlobal Industries Craig Heimbucher, P.E. Integral Consulting Inc. December 9, 2014 National Pollutant Discharge Elimination System (NPDES) Stormwater Permit Program Clean Water Act (1972) NPDES Stormwater Permit Program (1990) Environmental Protection Agency Oregon Department of Environmental Quality Local Agent 1

December 9, 2014 National Pollutant Discharge Elimination System (NPDES) Stormwater Permit

2 NPDES Permits The Goal: Control pollutant point source discharges that may impair or threaten navigable waters NPDES Permits Stormwater Wastewater (e.g., POTW) Municipal (MS4) Industrial Construction Individual General Permit NPDES Industrial Stormwater General Permit (ISGP) NPDES ISGPs are based on a 5-year cycle Current permits issued by the State of Oregon in 2011and 2012 Permittees must develop a site-specific Stormwater Pollution Control Plan (SWPCP) 2

, POTW) Municipal (MS4) Industrial Construction Individual General Permit NPDES Industrial Stormwater General

3 Industrial Stormwater General Permits Permit coverage: Determined by the Standard Industrial Classification (SIC) code Defined by 40 CFR Who the permit affects: About 900 facilities throughout the state that discharge stormwater to waters of the U.S. Types of NPDES ISGPs 1200-Z Permit Statewide, most common permit 1200-COLS Permit Issued to Columbia Slough dischargers Impaired water body: more pollutant monitoring required than 1200-Z 3

26 Who the permit affects: About 900 facilities throughout the state that discharge stormwater to waters of the

4 ISGP Montoring Requirements Statewide Benchmarks: Copper, lead, zinc, TSS, ph, oil and grease (also: BOD5, E. coli, total phosphorus for 1200-COLS) Additional Pollutants: Cadmium, nickel, chromium Impairment Pollutants: Site specific Sector-Specific Benchmarks: From EPA Multi-sector General Permit NPDES ISGP Corrective Actions Tiered approach for exceeding benchmarks: Tier I Corrective action based on review of SWPCP Tier II Additional engineered stormwater treatment measures Pushing permittees toward more expensive treatment solutions 4

Sector-Specific Benchmarks: From EPA Multi-sector General Permit NPDES ISGP Corrective Actions Tiered approach for exceeding

Definition: Best Management Practice (BMP) General Cost Low 1. Operational BMP (e.g., sweeping, employee training) Moderate 2. Structural BMP (e.g., covered operation, painting) High 3.

5 Definition: Best Management Practice (BMP) General Cost Low 1. Operational BMP (e.g., sweeping, employee training) Moderate 2. Structural BMP (e.g., covered operation, painting) High 3. Treatment BMP (e.g., sand filtration, bioswales) Case Study: ConGlobal Industries National intermodal shipping container storage and repair facility Portland Facility: 10-acre site on N. Rivergate Blvd. Located in Columbia Slough watershed 1200-COLS ISGP 5

Stormwater Compliance: Pre-2012 Location Unpaved Two monitoring locations Benchmark exceedances: Copper Zinc Total Phosphorus Evaluated cost of paving and end-of-pipe stormwater treatment Moved to

6 Stormwater Compliance: Pre-2012 Location Unpaved Two monitoring locations Benchmark exceedances: Copper Zinc Total Phosphorus Evaluated cost of paving and end-of-pipe stormwater treatment Moved to new location, partially due to stormwater compliance issues and related costs New Location May 2012: ConGlobal moved to new location on Rivergate Blvd. The Rivergate facility is a fully paved site 6

to new location, partially due to stormwater compliance issues and related costs New Location May

7 New Location A forensic evaluation was conducted to determine sewer system layout New Site, New Challenges Potential contaminant sources Run-on from adjacent properties Tracking from truck tires Potential galvanized roofing material 7

Potential contaminant sources Run-on from adjacent

New Site, New (and Old) Challenges ConGlobal s goal for the new facility was to stay on top of stormwater BMPs Frequent change-out of catch basin inserts Cleaning of catch basins Street sweeper for

8 New Site, New (and Old) Challenges ConGlobal s goal for the new facility was to stay on top of stormwater BMPs Frequent change-out of catch basin inserts Cleaning of catch basins Street sweeper for frequent sweeping Monthly inspection program Designated onsite stormwater personnel Photo courtesy of: Ultratech International, Inc. First Year Monitoring Results Some permit benchmarks were difficult to consistently meet during the first year Geometric mean exceeded for TSS and total phosphorus during first year Potential sources include erosion/run-on from adjacent property, tire tracking, self-contained wash system?? Ongoing Strategy: Continued implementation of operational BMPs, catch basin cleaning, and insert replacement with increased frequency Diligent follow-up on Tier I corrective actions and monthly inspection action items 8

First Year Monitoring Results Some permit benchmarks were difficult to consistently meet during the first year Geometric mean exceeded for TSS and total phosphorus during first year Potential sources

9 Second Year Monitoring Results The geometric mean of all parameters met permit benchmarks during the second year No Tier II Corrective Action! Monitoring waiver received for the remainder of the permit cycle for all permit parameters Continued monthly inspection and employee training programs Monitoring Results 9

Monitoring waiver received for the remainder of the permit cycle for all

Incorporating Stormwater into Business ConGlobal incorporated stormwater management into their business strategy Move to a new location prompted ConGlobal to tackle stormwater issues head on Source

10 Incorporating Stormwater into Business ConGlobal incorporated stormwater management into their business strategy Move to a new location prompted ConGlobal to tackle stormwater issues head on Source control, operational BMPs, and low-tech treatment BMPs have resulted in meeting permit benchmarks Moral of the Story Simple solutions are often the most effective: Continued diligence with simple BMPs (i.e., sweeping, catch basin maintenance, employee awareness) Effective stormwater program that is easy to implement 10

have resulted in meeting permit benchmarks Moral of the Story Simple solutions are often the most effective: Continued diligence

11 Industrial Stormwater Do s Document Proof of written records can keep you in permit compliance Inspect Stay on top of monthly inspections (and in-between inspections) Monitor - Begin sampling early in the monitoring period Implement Corrective actions, inspection program, training Coverage Develop SWPCP to only cover areas of industrial activity What s Next: The Future for Industrial Stormwater Many industries are struggling to meet low permit benchmarks of the ISGP Operational BMPs: usually the least costly and potentially the most effective More parameters likely in next general permit Running out of BMP options? End-of-pipe treatment Onsite low-impact development strategies Cost of doing business continues to increase from a stormwater perspective Upfront planning can control costs 11

Many industries are struggling to meet low permit benchmarks of the ISGP Operational BMPs: usually the least costly and potentially the most effective More parameters likely in next general permit

com Eric Pilcher (206) 230-9600 (Seattle, WA)

12 More Information on Stormwater Contacts: Craig Heimbucher (503) (Portland, OR) Eric Pilcher (206) (Seattle, WA) Matt Hillyard (707) (Eureka, CA) 12

NPDES Industrial Stormwater Inspection Worksheet

NPDES Industrial Stormwater Inspection Worksheet General Information Inspection Type 1200-Z DEQ Inspector Name Mark Riedel, Bob Schwarz DEQ Permit No. 106959 Entry Time 10:00 AM Inspection Date 1/8/15