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Storm Water Management for Harbors. Alaska Association of Harbormasters and Port Administrators Wrangell, Alaska October 26, 2010 Shane Serrano ADEC. Alaska Harbors come in different shapes, sizes and ownerships. Alaska Harbors come in different shapes, sizes and ownerships.

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Storm water management for harbors

Storm Water Management for Harbors

Alaska Association of Harbormasters and

Port Administrators

Wrangell, Alaska

October 26, 2010

Shane Serrano ADEC




Clean water act
Clean Water Act ownerships

  • Passed by Congress in 1972 and amended several times

  • Act addresses water pollution from point sources and nonpoint sources

  • Point sources are addressed through NPDES permitting Program

  • Nonpoint sources are addressed through grants to implement Best Management Practices


National pollutant discharge elimination system npdes
National Pollutant Discharge Elimination System (NPDES) ownerships

  • Individual Permits

    • Typically Domestic Wastewater Disposal

  • General Permits

    • Construction GP

    • Multi-Sector GP

    • Vessel GP


Four questions
Four Questions ownerships

  • What is the MSGP?

  • Are You covered by the MSGP?

  • What do You have to do to comply with the MSGP?

  • When does ADEC assume the storm water program from EPA?


What is the msgp
What is the MSGP? ownerships

  • Section 402(p) of the Clean Water Act directs EPA to develop permit application requirements for “stormwater discharges associated with industrial activity”

  • EPA developed the NPDES Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Sources

  • The previous version, the MSGP 2000, expired in October 30, 2005

  • In early 2009 MSGP is reissued in Alaska


Am i covered by the msgp
Am I covered by the MSGP? ownerships

  • One of 29 Industrial Sectors

  • Water Transportation – Sector Q

    • Water Transportation of Freight

    • Ferries

    • Marine Cargo

    • Towing and Tugboat Services

    • Marinas

  • Ship and Boat Building and Repairing Yards – Sector R


Covered discharges
Covered Discharges ownerships

  • Storm water discharge associated with industrial activity means the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing, processing or raw materials storage areas at an industrial plant. 40 CFR 122.26 (b)(14)


Coverage required for facilities that perform one or more of the following
Coverage Required for Facilities that Perform one or more of the Following

  • Blasting and Painting

  • Material Storage

  • Engine Maintenance and Repair Areas

  • Material Handling

  • Drydock Activities

  • Pressure Washing (May need another NPDES permit)


Need to meet all three conditions
Need to Meet All Three Conditions the Following

  • Your Facility is included in the regulated SIC Codes

  • Your Facility has regulated activities on your property

  • There is a discharge of the runoff through a point source


What do i have to do to comply with the msgp
What do I have to do to comply with the MSGP? the Following

  • Read the permit

  • Develop a SWPPP or Revise Existing SWPPP

  • Implement SWPPP and Control Measures

  • Submit Notice of Intent

  • Conduct Inspections

  • Conduct Monitoring

  • Implement Corrective Action

  • Maintain Reporting & Recordkeeping


Read the permit
Read the Permit the Following

  • Read Sections 1-7 & 9 and section 8-sector Q or R

  • Read Appendices A-K

  • For details read the Fact Sheet

  • Available at www.epa.gov/npdes/stormwater/msgp

  • Read permit with your facility in mind

  • Read Sector Q or R Fact Sheet


Developing your swppp
Developing Your SWPPP the Following

  • EPA Guidance

  • Specific to Industrial Facilities

  • What to Include in SWPPP

  • Common Compliance Problems


Elements of swppp
Elements of SWPPP the Following

  • Listing of Pollution Prevention Team

  • Description of Site

  • Summary of Potential Pollutant Sources

  • Description of Control Measures

  • List of Schedules and Procedures

  • Document Eligibility Considerations

  • Signature Requirements

  • Additional Documentation


Additional documentation for swppp
Additional Documentation for SWPPP the Following

  • Copy of Notice of Intent

  • Description of significant spills or leaks

  • Records of employee training

  • Documentation of maintenance of control measures

  • Copies of inspection reports

  • Description of corrective actions taken

  • Documentation of any benchmark exceedances

  • Documentation of status change from active to inactive


Control measures
Control Measures the Following

Must select, design, install and implement control measures (including BMPs) to address

* Selection and design considerations

* Meet the non-numeric effluent limits

* Meet limits contained in applicable effluent limitations guidelines


Non numeric technology based effluent limits
Non-Numeric Technology-Based Effluent Limits the Following

  • Minimize Exposure

  • Good Housekeeping

  • Maintenance

  • Spill Prevention and Response Procedures

  • Erosion and Sediment Control

  • Management of Runoff


Non numeric technology based effluent limits1
Non-Numeric Technology-Based Effluent Limits the Following

  • Salt Storage Piles

  • Sector Specific Non-Numeric Effluent Limits

  • Employee Training

  • Non-Stormwater Discharges

  • Waste, Garbage and Floatable Debris

  • Dust Generation and Vehicle Tracking of Industrial Materials


Erosion and sediment control
Erosion and Sediment Control the Following

  • Alaska Storm Water Guide http://dec.alaska.gov/water/wnpspc/stormwater/Guidance.html

  • ADOT&PF SWPPP Guide

  • www.dot.state.ak.us/stwddes/dcsenviron/resources2.shtml#

  • EPA SWPPP Guide

  • http://cfpub.epa.gov/npdes/stormwater/swppp.cfm

  • EPA Menu of Stormwater BMPs

  • www.epa.gov/npdes/stormwater/menuofbmps


Noi submittal to epa adec after oct 31 2009
NOI Submittal to EPA the Following(ADEC after Oct 31, 2009)

  • Existing Dischargers – In operation prior to Oct 30, 2005 and authorized under MSGP 2000

  • New Dischargers – In operation in between Oct 30, 2005 and date in AK MSGP

  • New Dischargers – In operation after date in AK MSGP

  • Other Eligible Dischargers – In operation prior to October 30, 2005, but not covered under the MSGP 2000 or other NPDES permit


Inspections
Inspections the Following

  • Routine Facility Inspections

  • Quarterly Visual Assessment of Stormwater Discharges

  • Comprehensive Site Inspections


Monitoring
Monitoring the Following

  • Monitoring Procedures

  • Benchmark Monitoring

  • Effluent Limitations Monitoring


Monitoring and sampling
Monitoring and Sampling the Following

  • EPA Guidance

  • How to Prepare for Monitoring

  • How to Conduct Monitoring

  • How to Evaluate Monitoring Results

  • Record-Keeping


Corrective action
Corrective Action the Following

  • Review and Revision to Eliminate Problem

  • Review to Determine if Modifications are Necessary

  • Corrective Action Report

  • Effect of Corrective Action


Reporting and recordkeeping
Reporting and Recordkeeping the Following

  • Report Monitoring Data to ADEC (after Oct 31, 2009)

  • Send Annual Report to ADEC (after Oct 31, 2009)

  • Exceedance Report for Numeric Effluent Limits

  • Additional Reporting

  • Recordkeeping


When does adec assume the storm water program
When Does ADEC Assume the Storm Water Program? the Following

  • Transfer of NPDES Program started October 31, 2008

  • Phase 1

    • Domestic Wastewater

    • Seafood Processors

    • Log Transfer Facilities

  • Phase 2 October 31, 2009

    • Stormwater

  • Phase 3 October 31, 2010

    • Mining


Changes to msgp under adec
Changes to MSGP under ADEC the Following

  • The permit will stay the same until 2013

  • Monitoring data and Annual Reports sent to ADEC

  • Compliance and Enforcement Inspections by ADEC

  • Tidal Grid Usage Survey

    • What information is available and tracked (size, duration, activities, wasteload, etc.)

    • What activities are allowed (type of maintenance)

    • What measures have been employed (collect & treat)


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