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Industrial General Industrial General Permit Notice of Non-Permit Notice of Non-

ApplicabilityApplicabilityPresented By:Presented By:

Conestoga-Rovers & AssociatesConestoga-Rovers & AssociatesFred Blickle and Michael BeerendsFred Blickle and Michael Beerends

Air & Waste Management Association Air & Waste Management Association (AWMA)(AWMA)

Golden Empire ChapterGolden Empire Chapter

September 16, 2014September 16, 2014

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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 9001:2008

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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.

• CRA’s 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)

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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 Board’s division of water quality

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Industrial Storm Water General Permit Updates•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/stormwater/industrial.shtml

Regulatory Update

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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

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Three Options for General Permit Coverage:1.File Notice of Intent (NOI):

a. Site Mapb. Storm Water Pollution Prevention Plan

2.No Exposure Certification (NEC)3.Notice of Non-Applicability (NONA)

General Permit Coverage

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It Does Rain in Bakersfield

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

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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)

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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

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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

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Facilities claiming “No Discharge” must:

1. Be engineered and constructed to contain the maximum historic precipitation event; or

2. Located in basins or physical locations not hydrologically connected to water of the United States; and

3. Submit and certify via SMARTS both the NONA and a No Discharge Technical Report if requested by the Regional Board

Notice of Non-Applicability (NONA)

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No Discharge Technical Report

Facility Containment Design including:1. Survey of existing stormwater retention systems2. Hydrologic analysis of tributary watershed3. Stormwater retention system capacity analysis4. Soil permeability analysis5. Soil stability analysis6. Receiving water evaluation (above- and below-

ground)7. Safety factor considerations (freeboard)8. Certified by California Licensed Professional

Engineer

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Capacity and Drainage Survey

Survey:1. To determine capacity of retention basin2. To determine storm water flow patterns and

directions

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Hydraulic Calculations

Calculations:1. Hydrologic modeling of watershed:

a. Determination of total tributary area (facility and run-on)b. Evaluation of watershed (land uses and soil types)c. Maximum Historic Precipitation Event (MHPE) values based

on NOAA dataa. Recommend to default to local standards if more stringent than MHPE

d. Design storm event volumes

2. Retention System Capacity Analysis1. Stage-Storage of existing or proposed retention system

based on survey2. Comparison against design storm event volumes

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Soil Determination

Soil Permeability and Stability:1. Retention system soil types2. Retention system infiltration rates3. Basin plan limitations4. Depth to groundwater5. Potential impacts to groundwater

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Reporting Requirements

NONA and No Discharge Technical Report:1. Certified and submitted via SMARTS by facility

LRP within 60-days of being requested by the Regional Board

2. Signed by a California Professional Engineer

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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

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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

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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)

Facility Controls

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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• AST’s• Fueling areas

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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)

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Industrial Storm Water Permit

• Q&A / Thank you for having us AWMA!

• Fred Blickle 313-506-9799• Mike Beerends 559-286-9999