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Industrial Stormwater Discharges - Regulatory Developments and
Technical Considerations
April 30, 2014
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Panel
Ryan Janoch, PE Mapistry
Wendy Manley, Esq. Wendel Rosen Black & Dean
Jarrod Yoder, PG, LSP Woodard & Curran
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Overview New California Industrial General
Permit Highlights Draft Multi-Sector General Permit
Highlights Case Study #1 - Naturally Occurring
Metals in Stormwater Discharges (MA) Case Study #2 - Infiltration to Eliminate
MSGP Requirements (MA) Case Study #3 - Source Tracking (CA) Regulatory Developments/Trends
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California Industrial General Permit
Adopted April 2014 Starts July 2015 Numeric Action Levels (NALs) Exceedance Response Actions (ERAs) Minimum BMPs Sampling requirements
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Draft Multi Sector General PermitWho is affected? Facilities operating within the 29 regulated industrial sectors listed in the 2008 MSGP and located where the EPA is the NPDES permitting authority. Streamlining the SWPPP and eliminating generic language Public accessibility to the SWPPP Reduced requirements for inspections Specific deadlines for taking corrective actions Electronic submission for the NOI, NOT, annual report and monitoring reports
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Draft Multi Sector General Permit
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Requirement for pavement wash water discharges to be treated by control measures Additional notification for discharges to Federal Superfund Sites Inclusion of airport deicing effluent limitation guideline Inclusion of saltwater benchmark values for metals and Additional clarity for technology based effluent limits
Case Study #1 - Naturally Occurring Metals in Stormwater Discharges
Project Location: Lakeville, MassachusettsIndustrial Activity: Concrete Ready MixMSGP Sector: EStormwater Contaminants: pH, TSS, metals including iron
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Client and their attorney requested assistance with an Administrative Consent Order with Penalty for multiple violations including stormwater management and illicit discharges to a natural resource.
Case Study #1 - Naturally Occurring Metals in Stormwater Discharges
Pollutant source evaluation Eliminated pollutant sources
but still had an iron problem Identified other discharges
during extended dry periods Hydrogeological evaluation Results
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Case Study #2 - Infiltration to Eliminate MSGP Requirements
Project Location: Everett, Massachusetts Industrial Activity: Metal Collection Facility MSGP Sector: N Stormwater Contaminants: metals, petroleum, PCBs,
solvents, TSS
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Client and their attorney requested assistance with a Settlement Agreement with the Conservation Law Foundation (CLF) relative to stormwater management
Settlement Agreement outlined a Performance Design Standard
Case Study #2 - Infiltration to Eliminate MSGP Requirements
Preconstruction activities identified historical contamination from metals scrapping/recylcing and coal gasification wastes
Hydrogeological studies were necessary An alternatives analysis was performed and a design
was prepared.
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The design was accepted by the CLF and construction activities were implemented
A soil management plan and Licensed Site Professional were needed to manage contaminated soil.
Case Study #2 - Infiltration to Eliminate MSGP Requirements
Benefits– Low maintenance– Moderate costs mostly due to managing contaminated
soil and the impacts to the overall design– No discharges to surface water and therefore no potential
for exceedances of water quality standards– No MSGP reporting requirements– Owner experienced more customer traffic after
improvements
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Case Study #3 - Copper Source Tracking
Suisun Bay Reserve Fleet Background on the Problem Investigation BMPs Next Steps Applications to new CA IGP
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Suisun Bay Reserve Fleet
aka “Mothball Fleet” or “Ghost Ships”
Benicia, CA Operated by US DOT
Maritime Administration (MARAD)
Retention and non-retention vessels (USCG, Navy, MARAD)
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Background
54 vessels Water quality concern (metals)
in discharges to Suisun Bay Site specific target
concentrations
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Exceedance
Mt. Washington November 2012 sampling
event Total Copper 3,000 ug/L Dissolved Copper 2,600 ug/L
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Historical Data
Target (ug/L)
Sampling Results (ug/L)
Mar 2011
Mar 2012
Oct 2012
Nov 2012
210 1,100 2,800 2,900 3,000
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Current BMPs
Sweeping (non-structural) Structural
–Coconut mats–Perlite wattle–Walnut shell wattle–Scupper screens
Focus–Solids–Petroleum–Metals
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Investigation
Previous potential sources: grease, lubricants
Screen using X-Ray Fluorescence (XRF)
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Results 19 surfaces screened non-detect to 10,000
ppm 75,000 ppm on deck
leading to scupper 840,000 ppm on
SALM
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Single Anchor Leg Mooring (SALM)
Underwater anchor for fueling operations
Mt. Washington was off-shore fuel tanker
SALM is 55’ by 140’ Mt. Washington is
100’ by 700’
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Remedial Options
Source Control - painting, shrink wrap
Treatment - BMPs Considerations Environment Cost Human health Applicability Feasibility Scraping schedule 21
Customized BMPs
Two media types for metal removal
Configurations–filter bags (top of
scupper)–filter socks (check dams)
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Application to CA IGP
Exceedance Response Action (ERA) Level 2 Technical Report
Pollutant source tracking
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Regulatory Developments Issues/Trends
California Industrial General Permit Lengthy Adoption Process Key Issues
–Numeric Effluent Limits–Group Monitoring–More prescriptive requirements
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Regulatory Developments Issues/Trends
Ongoing California Regulatory Issues Numeric Effluent Limits TMDLs
–Implementation–Permit Modification
Sector-specific permits Receiving Water Limitations
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Enforcement Agency Enforcement
–Non-filers
Citizen Enforcement–Multiple organizations–Industry targets
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Additional Resources Multi-Sector General Permit
–http://cfpub.epa.gov/npdes/stormwater/msgp.cfm–http://www.epa.gov/npdes/pubs/msgp2013_proposedshortfs.pdf–http://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf–http://www.epa.gov/npdes/pubs/msgp_monitoring_guide.pdf
California’s Industrial General Permit–http://
www.waterboards.ca.gov/water_issues/programs/stormwater/industrial.shtml–http://
www.waterboards.ca.gov/water_issues/programs/stormwater/indusfaq.shtml–http://
www.waterboards.ca.gov/water_issues/programs/stormwater/gen_indus.shtml#indus
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