NPDES Industrial Stormwater General Permit Case Study: ConGlobal Industries



Similar documents
NPDES Industrial Stormwater Inspection Worksheet

Chapter 2 Stormwater Pollution Prevention Plan (SWPPP) for Park Operations

How To Get A Stormwater Discharge Permit In A City Of Scottsdale

Improper storage of fuel on construction sites will increase the risk of water pollution that may occur as a result of leaks or spills.

NPDES Phase II Small MS4 Permit Program

Exhibit A-7.III. Water Quality Management Plan (WQMP) Checklist

Lessons Learned from the Expert BMP Panel Process That May Apply to MTDs. Tom Schueler Chesapeake Stormwater Network

Standard Operating Procedures Storm Drain System Maintenance

Final Draft Prepublication Copy

Industrial Storm Water Best Management Practices. Restoring, maintaining, and enhancing the quality of Oregon's water.

Best Management Practices (BMPs) Ideas for School Districts. Presented by: Donald Lussier

Outdoor Storage of Raw Materials SC-33

Spill Prevention, Control & Cleanup SC-11

BUSINESS INSPECTION PROGRAM

Waste Handling & Disposal

City of Paso Robles Community Development Department Construction Site Storm Water Quality Requirements

Watershed-Wide Modeling for TMDL/MS4 Permit Compliance. Greg Wilson, Barr Engineering

IC24. DISPOSAL OF WASTEWATER GENERATED BY MOBILE BUSINESSES AND OUTDOOR ACTIVITIES

POLLUTION PREVENTION FACT SHEET: AUTOMOBILE MAINTENANCE

Good Housekeeping BMP

Stormwater Pollution Prevention Guidance

Appendix C3: Response Plan for Investigations of Illegal Discharges, 2016

POLLUTION PREVENTION FACT SHEETS: CATCH BASINS. Description

Anne Arundel County s Watershed Protection and Restoration Program STORMWATER REMEDIATION FEE CREDIT POLICY AND GUIDANCE (Multi-Family,

Flood Control District Best Management Practices

Final Report of the Town Owned Lands Improvement Project for the Town of Brentwood, NH

Use of Regional Detention Basins for Stormwater Quality Management

DRAFT Public Outreach Document for What s an SSMP?

NPDES Permit No. IL Notice No bwc. Public Notice Beginning Date: June 6, Public Notice Ending Date: July 8, 2013

Applicable Rules - Air 30 TAC Permits All facilities must be authorized by a permit, a standard permit, or a permit by rule. Small mixers unde

P-23 - DEVELOPMENT OF DELAWARE DEPARTMENT OF TRANSPORTATION STORMWATER BEST MANAGEMENT PRACTICE INSPECTION PROGRAM

TCEQ TPDES CGP EPA NPDES GCP Inspection of Controls Report

Appendix VIII: Spill Prevention, Control and Countermeasure (SPCC) Plans

New Jersey Department of Environmental Protection. Municipal Stormwater Regulation Program- Public Complexes

Critical Regulations SUMMARY OF. Stormwater Management Regulations (National Pollutant Discharge Elimination System or "NPDES ) 40 CFR 122.

City of San Diego Urban Runoff Management Program. Appendix XI. Minimum BMPs for Mobile Businesses

Required BMPs for All Commercial Properties

PNWS-AWWA PRESENTATION May 9, 2013 Spokane, Washington. Water Operations Stormwater Best Management Practices

Evaluating Drain Inlet Cleaning as a Storm Water Best Management Practice

Biofiltra on: West Hylebos Log Yard

Storm Drain System Operation and Maintenance

DESCRIPTION OF STORMWATER STRUCTURAL CONTROLS IN MS4 PERMITS

Spill Plan Reviewer s Guidance

Clean Water Activites Services - Suggestions from Stakeholders. Federal Statute or Regulation Change? State Regulation Change? Policy Change?

Table 2: State Agency Recommendations Agency of Agriculture, Food and Markets

Good Housekeeping Practices for DPW/Fleet Maintenance Facilities

Field Performance of Two Stormwater Bioretention Filtration Design Configurations

Stormwater Pollution Prevention Plan for: SWPPP Contact(s): SWPPP Preparation Date:

Guidance Document. Jennifer M. Granholm, Governor Steven E. Chester, DEQ Director

1.A Why Should You Use This Guide? B What Is Stormwater Runoff and What Are Its Impacts?... 1

Permeable Paving System with StormAbsorb Technology

10/4/ slide sample of Presentation. Key Principles to Current Stormwater Management

SPILL RESPONSE PLAN. What is the Issue? Regulatory Requirements. General Information

Construction Site Monitoring Program Guidance Manual

GUIDELINE FOR MUNICIPAL MANAGEMENT PRACTICES FOR STREET SWEEPINGS & CATCH BASIN CLEANINGS

AquaShield Stormwater Treatment Systems

Contech Engineered Solutions LLC Subject: Comments on Tentative Order R XXXX, NPDES No. CAS612008

Maine Department of Environmental Protection Program Guidance On Combined Sewer Overflow Facility Plans

Public Notice Draft Expiration Date: 1/31/09 Permit Numbers: , , , & MS4 Page 1 of 72 Pages

Is the General Industrial Permit for Stormwater Discharges Applicable to Your Facility and Property?

Seattle Public Utilities Green Stormwater Infrastructure: O&M Program

Official OPP Overall Penn State Stormwater Program Latest Revision/Review: 5/28/2015

Improper storage of potential pollutants will increase the risk of water pollution that may occur because of spills.

Spill Control Prevention Plan (SCPP)

Florida Department of Environmental Protection

WATER EFFLUENT AND SOLID WASTE CHARACTERISTICS IN THE PROFESSIONAL CAR WASH INDUSTRY. A Report for the International Carwash Association

III. Relying on another Governmental Entity

BEST MANAGEMENT PRACTICES (BMPs)... What are They? GOOD HOUSEKEEPING PRACTICES Your Business Should Employ

Use of Green Roofs to Meet New Development Runoff Requirements. Greg Davis Nov. 8, 2007

A San Antonio Case Study on the Water Quantity and Quality Benefits of LID Development

Tier 1 General Permit for the Discharge of Storm Water Associated with Industrial Activity. Table of Contents

LOS ANGELES UNIFIED SCHOOL DISTRICT INDUSTRIAL WASTEWATER MANAGEMENT PROCEDURES

GENESEE COUNTY DRAIN COMMISSIONER S OFFICE

Temporary Batch Plants

Lak ecount y D epart m ent of Public W ork s

State Water Resources Control Board

CREATING A GREEN FUTURE THROUGH WATER REMEDIATION

User s Manual for the BMPTRAINS Model

GOVERNMENT OF THE DISTRICT OF COLUMBIA District Department of the Environment *** MS4 LETTER AGREEMENT

Best Management Practices For Industrial Storm Water Pollution Control

CHAPTER MUNICIPAL SEPARATE STORM SEWER SYSTEMS

C. Storm Water Pollution Prevention Plan (SWPPP) Yes No Response / Comment. D. Good Site Management Housekeeping Yes No Response / Comment

Compost-Based Stormwater Best Management Practices Using Compost to Improve Stormwater Management and Erosion Control On Roadsides

Application for Controlled Trade Waste Discharge Approval

THE CITY OF EDGEWOOD STORMWATER MANAGEMENT PROGRAM

Operations and Maintenance Plan The Residences at Johnson Farm 189 Landham Road Sudbury, Massachusetts. Submitted to: Town of Sudbury

VEHICLE SERVICE FACILITIES. Best Management Practices

NPDES Profile: West Virginia

Accounting for Uncertainty in Offset and Trading Programs

Waukesha County. Municipal Separate Storm Sewer System (MS4) Permit Annual Report to the Land Use Parks & Environment Committee


Sanitary Sewer Overflows Response to EPA Rule Making

CITY OF PUYALLUP STORMWATER POLLUTION PREVENTION PLAN (SWPPP) PUBLIC WORKS FACILITY

Stormwater Pollution Prevention Plan for Luther Burbank and I-90 Lid Parks. City of Mercer Island

Clean Water Services. Ecosystems Services Case Study: Tualatin River, Washington

Certification and Verification of Offset and Trading Credits in the Chesapeake Bay Watershed

What is a CSO / SSO? Sewer Overflows. Prevalence of CSOs in the US. Magnitude of Problem (Local)

NPDES Permit No. IL Notice No. JAR: jar. Public Notice Beginning Date: February 21, Public Notice Ending Date: March 25, 2013

Impacts of Water Pollution- Lessons Learned

Transcription:

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

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

Industrial Stormwater General Permits Permit coverage: Determined by the Standard Industrial Classification (SIC) code Defined by 40 CFR 122.26 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

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

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 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

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

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

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

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

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

More Information on Stormwater Contacts: Craig Heimbucher (503) 943-3629 (Portland, OR) cheimbucher@integral-corp.com Eric Pilcher (206) 230-9600 (Seattle, WA) epilcher@integral-corp.com Matt Hillyard (707) 443-3105 (Eureka, CA) mhillyard@integral-corp.com 12