Water Permitting & Enforcement Trends in Compliance Monitoring · Water Permitting & Enforcement Trends in Compliance Monitoring June 16, 2016 Kim Hudak, Assistant Director Nancy

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Connecticut Department of Energy and Environmental Protection


Water Permitting & Enforcement Trends in Compliance Monitoring

June 16, 2016 Kim Hudak, Assistant Director Nancy Wollenberg, Environmental Analyst 2 CBIA Energy and Environment Conference

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Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

Overview

Wastewater Discharge Permits

• NetDMR

• Quarterly Non-Compliance Review (QNCR)

• Common Wastewater Violations


NetDMR

• Allows direct interface with US EPA’s national database.

• Reduces time to submit DMRs, and is accessible 24/7.

• Encourages accurate reporting and timely submission.

• Provides email confirmation of DMR submission.

www.ct.gov/deep/netdmr

http://www.ct.gov/deep/netdmr

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NetDMR

• Mandatory upon permit renewal/modification since 2012

• Monitoring under new general permit registrations will require NetDMR reporting

• Not currently required for Industrial Stormwater GP – permittees must submit SMRs


Quarterly Non-Compliance Review (QNCR)

NPDES and SIUs (Pretreatment) Permittees:

• DEEP staff review reports on a quarterly basis

• Information in ECHO (EPA’s Enforcement and Compliance History Online) creates the report

• The report identifies facilities that are in Significant Non-Compliance (based on data in ECHO)

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ECHO link - https://echo.epa.gov/?redirect=echo


ECHO Data

• ECHO is populated by data submitted on Discharge Monitoring Reports by permittees.

• The data submitted into the EPA DMR system does not include monitoring that takes place more than monthly.

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Quarterly Non-Compliance Review (QNCR)

• DEEP staff confirm/disprove SNC categorization by checking permittees DMR submittals for accuracy and by including any monitoring data for samples collected more than monthly (ex. weekly, twice per month)


Important Feature in NetDMR

• Coverletters, results of monitoring required more than monthly, TTO Certification need to be attached to each monthly DMR submittal, as required

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Significant Non-Compliance (SNC)

• Chronic Violations – 66% or more of all measurements taken for one parameter exceed a permit limit.

• Technical Review Criteria – 33% or more of all measurements taken for one parameter exceed permit limit x multiplier. Multiplier either 1.4 or 1.2 (NPDES – 40CFR123.45 Appendix A; Pretreatment – 40CFR403.8(vii)(B))

• Non-submittal of entire DMR


Confirmed SNC

• Annually posting all SIUs in SNC on the Department’s website beginning July 1, 2017 (for 2016 calendar year)

• DEEP Staff will decide what type of Enforcement Action will be taken:

– NOV, Consent Order, Referral to AGs

Depending on the severity of the violations

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Common Permit Violations

Failure to Notify the Department:

– Permit limit violations

– Monitoring Equipment Malfunction or Failure

– Changes to Treatment System/Processes


Notification Requirements in Permits

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Notification Requirements on DEEP Website

• On our homepage, click on “Programs & Services” on the blue tab at the top of the page.

• Select “Industrial Wastewater”

• Scroll down to the bottom and just above the links to Related Information, click on “Learn more about how to comply with your permit” in the blue box

• On the Compliance Assistance topics page, click on “Notification Requirements”


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In Summary

• NetDMR is required with new permit issuance (since 2012)

• SIUs in SNC in calendar year 2016 will be listed on the DEEP website (by July 1, 2017)

• Communication is key


Water Permitting & Enforcement Contacts:

INDIVIDUAL PERMIT CONTACTS

INDUSTRIAL NPDES

COMPLIANCE ASSURANCE

Melissa Blais, Supervising Sanitary Engineer

E-mail: [email protected]

Phone 860-424-3834

INDUSTRIAL PRETREATMENT


(Categorical General Permit)

Peter Ploch, Supervising Sanitary Engineer


Phone 860 424-3280

GENERAL PERMIT CONTACTS

STORMWATER


(Stormwater General Permits)

Kim Hudak, Assistant Director


Phone: 860 424-3021

PROGRAM SUPPORT

& COMPLIANCE MONITORING

(Industrial General Permits)

Program Support & Outreach

Art Mauger, Supervising Sanitary Engineer


Phone: 860 424-3829

mailto:[email protected]




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Air Inspection and Monitoring Priorities

June 16, 2016 Robert W. Girard, Assistant Director, Air Enforcement Mark Potash, Supervising Air Pollution Control Engineer CBIA Energy and Environment Conference


Air Inspection and Monitoring Priorities

• Title V and GPLPE Sources

• Citizen Complaint Response

• Miscellaneous Metal Parts Coaters

• Gasoline Storage Facilities

• Stationary Source Emissions Testing

• Continuous Emissions Monitor Certifications

• Prompt Report Reviews

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Common Areas of Air Non-Compliance

• Failure to apply for necessary permits

• Failure to properly decommission Stage II Systems

• Non-compliant coating use

• Inadequate control of fugitive dust

• Failure to conduct required emissions testing

• Failure to maintain and submit required records

• Changes in personnel are often the cause of noncompliance with record keeping requirements as well as many other regulatory requirements


Infrared Camera

• Forms images using infrared (IR) energy

http://imagine.gsfc.nasa.gov/science/toolbox/emspectrum1.html

INFRARED

• Detects some, but not all, Volatile Organic Compounds (VOCs), depending on what IR wavelengths they absorb

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• Used for leak detection in many industries

– Chemical manufacturing plants

– Gasoline terminals – loading racks, storage tanks

– Landfills

• Scans large areas in a short time

• Documents findings in photographs or videos


• IR camera only gives qualitative information – proves a leak is present

• Cannot determine what VOC the leak is comprised of

• Cannot determine the amount or concentration of the VOC leaking

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Gasoline tank truck loading – observed leak in the area of the vapor recovery hose


VOC’s leaking from ductwork prior to a catalytic oxidizer

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Contact Information Robert W. Girard Assistant Director, Air Enforcement CT DEEP 79 Elm Street Hartford, CT 06106 [email protected] 860-424-3461 Mark Potash Supervising Air Pollution Control Engineer [email protected] 860-424-3547


Recycling Compliance Efforts

June 16, 2016 Robert Isner, Director CBIA Energy & Environmental Conference



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Connecticut’s Solid Waste Vision

• P.A. 14-94 - Divert 60% by 2024

• Implement through - Solid Waste Management Plan

- update by 7/1/2016 as the Comprehensive Materials Management Strategy

• Solid Waste Advisory Committee

- standing meeting, 4th Tues. 9:30 @ DEEP

- join listserv - [email protected]


CT List of Designated Recyclables • Designated by CGS 22a-241b & adopted regulations:

• Glass & metal food containers

• Scrap metal

• PET (#1 plastic) and HDPE (#2 plastic) containers

• Paper - white office paper & colored

• Cardboard & Boxboard (e.g., cereal boxes)

• Newspapers & Magazines

• Waste oil

• Leaves & grass

• Lead-acid batteries & Ni-Cd rechargeable batteries

• Covered electronic devices

• Organics from certain large sources 2 ton/wk

• (CGS 22a-226e, wholesaler, distributor, grocery, resort, etc.)

http://www.ct.gov/deep/cwp/view.asp?a=2718&q=325482&deepNav_GID=1646



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• CGS Sec 22a-241b Everyone must separate designated recyclables and trash

• CGS 22a-241b(e): cannot combine previously segregated designated recyclables with trash

• CGS 22a-241l: solid waste/hauler contracts must cause separation

Provide for Separation of Designated Recyclable Items

TRASH ONLY

Recycling Compliance Priorities • Increase awareness about law, old & new

• Transformation of Solid Waste Management Plan to the “Comprehensive Materials Management Strategy”

(recover more value from discards)

• Targeted recycling law enforcement

Source Reduction & Reuse

Recycling Composting and

Organics Recycling

Energy Recovery

Landfill & Incineration

Greater Environmental Benefits (e.g., GHG reductions) & Economic Benefits (e.g., jobs)

Fewer Environmental Benefits & Economic Benefits

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Recycling Enforcement Tools

Two tools DEEP will use to expand recycling inspection and enforcement efforts:

1. Multi-media enforcement coordination & checklist

- training completed & in use

2. WEED: Business Recycling Checklist

- updated & in use


Multi-media Enforcement Coordination: Roll-out

DEEP field staff from all media, will observe:

1. Is the business lacking an established Recycling Program?

2. Is the business lacking separate containers to segregate Designated Recyclables from trash?

3. Is there more than an incidental amount of Designated Recyclables in trash containers or dumpsters?

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WEED: Business Recycling Checklist

Comprehensive checklist: All items covered by multi-media observations, plus the following:

– Does the company have a “recycling or green team”?

– Adequate recycling collection areas internal to the facility?

– Are there proper Recycling contracts in place?

– Identification of haulers utilized by the facility to pick up trash

and recyclable items.

– Itemized list of Designated Recyclables generated at the facility

and identification of whether or not they are recycled.


Recycling Enforcement Status

• Multi-media field focus - more trained eyes in the field

• Recycling enforcement team provides internal oversight

• Dozens of completed WEED Checklists since April

• Resulting NONs & NOVs drafted or issued

• Common Violations: – No recycling program in place

– No internal recycling containers (desk-side/break-room)

– No external recycling containers (“back of the building”)

– Recycling cardboard only, other recyclable items mixed in with trash

– Deficient contracts for solid waste and recycling services

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Recycling Compliance Tips

• Know what’s a mandatory/Designated Recyclable

• Know what’s in your dumpster

• Know what’s in your solid waste contracts

• Do a recycling audit

- DEEP Inspection Checklist & Profile

- Contact the Business Sustainability Challenge

• Use the Reuse Marketplace

• Be S.M.A.R.T. , US EPA (Save Money And Reduce Trash)


Questions?

Robert Isner, Director

Waste Engineering and Enforcement Division

Bureau of Materials Management and Compliance Assurance

(860) 424-3264

[email protected]

Business Recycling Assistance

www.ct.gov/deep

www.ct.gov/deep/recycle

www.ct.gov/deep/compass

•

http://www.ct.gov/deep/lib/deep/reduce_reuse_recycle/brochures/general_recycling_reminder_brochure.pdf

http://www.ct.gov/deep/lib/deep/reduce_reuse_recycle/forms/business_recycling_inspection_checklist.pdf

http://www.ct.gov/deep/lib/deep/reduce_reuse_recycle/forms/businessrecyclingprofile.pdf

http://www.energizect.com/nonprofits/programs/business-sustainability-challenge

http://www2.epa.gov/recycle



http://www.ct.gov/deep

http://www.ct.gov/deep/recycle

http://www.ct.gov/deep/compass