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Storm WaterInstructor: George Caamano
SWPPP Training Outline
Regulatory Background Facility Information BMPs Monitoring
Inspections Sampling
Regulatory Background Module
• Historically, why do we find a need for monitoring storm water?
• What are the Regulations that drive the program?
• Why should we abide by them?
Background - Social Contract
View that morality is based on social agreements that serve the interests of those who make the agreement
Background – Agency, Regulations, Programs, Permits
CWA
The Clean
Water Act
1972
EPA
The Environmental Protection Agency
1970
NPDES Program
(Section 402
of the CWA)
1972
California
General Permit
The Federal Water Act
1948
The Refuse Act
1899
Background - Clean Water and Federal Regulations
In 1899 The federal government took its first action with The Refuse Act, prohibiting the dumping of waste into Navigable Waters.
In 1972 it became the Clean Water Act (CWA).
Section 402 of the CWA details the National Pollution Discharge System (NPDES).
Background - National Pollutant Discharge Elimination System (NPDES)
The NPDES is a permit.
It is giving an individual the permission to discharge. The individual is agreeing to abide by specific rules outlined in Section 402 of the CWA and there by completing their end.
It works like a drivers license that the possession of it implies acknowledgement of the law.
Background - Our Goal
Regulatory Compliance Benchmark Levels (EPA) California Toxics Rule Best Available Technology (BAT or
BACT)
Background - State Water Resource Control Board (SWRCB)
http://www.swrcb.ca.gov/regions.html
Background – NGOs
Non-Governmental Organizations can sue us for neglecting to comply with the regulations.
Community Based Organization’s
•Santa Monica Bay Keeper•OC Coast Keeper•Hudson Bay Keeper•CA Sport Fishing Assoc.•Heal the Bay
National Environmental
•Sierra Club•NRDC•Audubon Society•Greenpeace•The Nature Conservatory•Surf rider Foundation
Storm Water Resources Control Board (SWRCB)
General Permit
California’s General Permit is Outlined based on the Federal Requirements
Background – TERMS you should know… BMP – Best Managements Practices EPA – Environmental Protection Agency BAT – Best Available Technology CWA – Clean Water Act SIC – Standard Industrial Classification NOI – Notice of Intent SWPPP – Storm Water Pollution
Prevention Plan
Background - RunoffIndustrial Runoff
can contain… Oil and
Grease Metals Sediment
(dirt) Other
Hazardous Materials
Background -Discharge & Outfalls
Discharge:Water that ponds up or accumulates to become surface runoff and then leaves the site.
Discharge Point:Are usually the end point of a pipe, culvert, channel, swale, or ditch that discharges from the right-of-way into a stormwater conveyance system, manholes, junction boxes or inlet that connects downstream to a storm sewer system. Where the water leaves the yard.
Outfall:Area where water collects in your yard prior to discharge.
This is a violation!
Facility Information Module -Storm Water Work Chart
General Manager
Storm Water Coordinator
Sampling
Record-Keeping
Structural/NS BMP
Training(Sec. 1.0 & 2.0)
Facility Information – Contact Information
• Ensure that the contact information is up to date
Facility Information - Maps
Ensure maps are current All components of Sec. 2.2 must
appear on map. Outfalls are clearly delineated
Facility Information - Training
Each employee has overall general knowledge of the Storm Water Plan
Each employee must have department knowledge of BMPs in their area
Training Logs must be in the Storm Water Plan for each employee in the yard.
Facility Information – SWPPP Changes
• Update changes to SWPPP or land/structure changes that affect Storm Water
• Plan is updated immediately following any change. (Example: map, storage area, training etc.)
BMP Module
(Sec. 6.0)
BMPs are things that we do, buy or install that will help reduce Storm Water contamination.
There is no regulation that tells us which BMPs we need, but we need to make sure that whatever we pick is adequate to lower contaminant levels.
BMPs must be continually evaluated after every storm and monthly.
BMP – Structural/NS Structural
Roofs Speed Bumps Filtration Devices
Non-Structural Sweeping Regular Vehicle
Maintenance Hay Bales
Example: BMPs for Loading/Unloading
Objects containing liquids such as appliances and automobiles must be processed ordisassembled over containment.
No visibly leaking object is to be offloaded into the general receiving area.
Objects with excessive dirt may not be able to be offloaded in the general work area.
Any object that is breached during the offloading or loading for offsite processing that is leaking a fluid must be isolated and fluids drained prior to placement in storage or readied for offsite transport.
Recovered fluids will be stored appropriately.
Dirt or dust created by this operation must be recovered and reprocessed through the ASR treatment system. Acceptable methods are to sweep, vacuum or blow dusts to a central area and then physically remove and dispose of according to State and Federal law. The use of leaf blowers, brooms, riding sweepers and vacuums are all used by SA-Anaheim to accomplish this task.
Dirt and dusts should be recovered sufficiently to greatly reduce “drag out” of particulates when trucks leave the property.
Loading of trucks with dusty material will only be done if a water mist spray assists in keeping dust suppressed. If overuse of water causes run off, then the run-off will be captured and shipped offsite or re-used.
BMPs for Storage If metals are placed in bins, the bins must be of sufficient integrity to not allow metal or liquids
to fall or escape onto pavement.
If bins are to be stored outdoors, they must be covered with metal or plastic if a forecasted event is known so as to not allow rain to enter.
Any hazardous liquid being stored must be kept in a DOT or appropriate container and be covered when not actively being filled or drained.
Labels will be placed on these containers to inform employees of the hazards associated with the material.
When room is available, containers will be undercover or stored indoors.
Non-Ferrous and wire metal piles are covered with tarps prior to a storm event and are boomed with oil absorbent socks to prevent any oil release.
Sand bags are used to divert storm water towards appropriate treatment systems and to prevent flow to inappropriate locations. Booms are also used to prevent oil release.
Sweeping - All secondary process areas (driveways and street) are swept daily and Main Yard is to be swept consistently during metal processing.
BMPs for Liquid Handling
The draining or transferring of liquids from any machine, vehicle or apparatus must be performed on secondary containment or a drip pad as appropriate.
The secondary containment must be large enough to hold the liquid contents of the item being drained and hold volume from a 25 year storm if containment is not under cover or not cleaned prior to the storm event.
For transfers, the containment must hold the volume of the hose and be able to contain accidental drips, etc.
For equipment that leaks hydraulic fluid or oil, a drip pan will be used if the equipment stops for more than 30 minutes. Equipment identified as needing the drip pan will be placed first on scheduled maintenance repair lists. All spills will be cleanup up immediately.
BMPs for Material Processing
Torch cutting practices will be reviewed and written procedures established to control dust for employee benefit, for environmental and air quality benefit and to the best extent possible, metal dust and fume will be recovered from ground or pavement. Metal cutting is performed in contained area only.
Conveyors will have fine water mist spray at key points to minimize dusts
Shredder will capture all water from reaching pavement. Recovered water will be re-used, if possible, or shipped off site for treatment.
Shredder air emissions will be reduced by using air filters and control devices.
BMPs for SW Devices All storm water devices will be cleaned and maintained to manufacturer’s
specifications. If none exist, then general industry practices will be employed.
Pressure washing or cleaning retention ponds and washing of sumps and other devices prior to storm event are required.
No standing water is to be left in storm water control devices for more than 2 days after a storm. Settled water is to be discharged as an authorized non-storm water discharge when appropriate. If water is discharged within the same day as the storm, then it will be considered an authorized storm water discharge.
All Storminator 6000 water filtration units are to be checked prior to a storm to assure all hoses, fittings, valves and filters are operational. The DE Filter portion of the unit is to be re-circulated to assure proper adhesion of the DE to the filter prior to use.
All storm water device repairs, including painting, welding, new parts, etc are to be performed during dry weather months or several weeks prior to a storm event.
BMP –Installing Track out Devices
Structural BMP
Insert Absorbent Booms
Prior to a storm - Structural BMP
Green Infrastructure
Reduce runoff by incorporating Green BMPs
Non-Structural BMPs
Covering potential pollutants and using Secondary Containment
Storm Data Sheet & Action Plan
A recordkeeping means to track visual observations. Not required, but strongly recommend.
Sec 7.4 Storm Water Plan
Monitoring and StormWater Sampling (Sec. 8 & 9)
MonitorCollect Samples
EvaluateNeeded Changes
Update SWPPP BMP’s
Once we decide on the new BMP’s we have to update our SWPPP to reflect them.
If BMP’s are not working (lab results)then we need to evaluate what needs to be changed.
We monitor our BMP’s and collect Samples to verify that that our BMP’s are working.
Storm Water Program Elements
SWPPP
SAMPLING
BMP
REPORTING
MONTHLY
STRUCTURAL(PHYSICAL)
NON-STRUCTURAL(POLICY)
2 QUALIFYING STORM REQUIREMENT
QUARTERLY ANNUALLY
SAMPLINGQUALIFIED
A sample must be taken
within the first 60min of discharge.
2 qualified samples are required annually
Samples are sent to state certified lab.
Started discharging during operating hours
Three days of dry weather prior to rain storm
NON-QUALIFIED
A sample that are taken 60min after discharge.
Samples are sent to Todd Peterson at Remedy Environmental
Started discharge during non-operating hours
Sampling Kit
Kits can be re-used 6-7 times.
SAMPLING KIT Instructions Chain of
Custody Glass Jar with
bubble wrap bag
Plastic Jar Tin Ziploc
Sampling
Safety First Hard Hat Steel Toe Safety Vest Gloves Safety
Glasses
Taking a SampleUse Ziploc to collect stormwater
Sampling
Pour all contents into both jars.
DO NOT ADD WATER or FILTER OUT SEDIMENT/DIRT
Sampling Labeling
Qualifying Samples
- “Discharge Point Name” “Date”
- Ex. “Main 10-20-09”
Non-Qualifying Samples
- “NQ” “Outfall Name” “Hour following start of discharge”
- Ex. “NQ Main 2”
Sampling
Place jars in tin
Sampling
Insert Chain of Custody
SamplingCHAIN OF
CUSTODY
BE CAREFUL- - Legal
Document- - Make a copy- - Outfall should
always have the
- same name
Reviewing Laboratory Data
Expected Results
0
0.5
1
1.5
2
2.5
0 1 2 3 4 5
Hour(s) Follow ing Discharge
pp
m
Dissolved Metals in Runoff (Bins)
0
0.5
1
1.5
2
2.5
0 1 2 3 4 5
Hour(s) Follow ing Discharge
pp
m
Too Many Contaminants (BMPs Need Improvement)
00.5
11.5
22.5
3
0 1 2 3 4 5
Hour(s) Following Discharge
pp
m
Metals Introduced (Customer or Pond Overflow)
0
0.5
1
1.5
2
2.5
0 1 2 3 4 5
Hour(s) Following Discharge
pp
m
QUIZ
CATEGORIES:
- Equipment
- Chain of Custody
- Ordering Kits
- Outfalls/Discharge Points
- Defining a Storm
- Sampling Q vs NQ Storms
Record Keeping (Sec. 10.0)
Storm Data and Action Plan forms Laboratory Data Training Records Visual Observations Meeting Minutes BMP Reviews All Records Maintained for 5 years
StormWater Reports
Are required by LAW Are submitted directly to the
Regional Water Board. Become public record and subject
to scrutiny by Non-Governmental Agencies (NGO)
Must be filled out carefully
StormWater Reports
Monthly Reports Due before the last day of the Month
Quarterly Reports Due September, December, March,
June Annual Reports
Due July 1
Team Effort
Our Roles1. What we do can affect storm water2. Be aware (BMPs)3. Evaluations4. Record Keeping
(Training, Documents, etc.)