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Storm Water Permits. The Problem of Phasing In Potentially have every industrial facility in the U.S. needing a permit at the same time at the same time agencies are trying to write the regs and figure out what the issues will be

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Presentation Transcript
Storm water permits
Storm Water Permits

  • The Problem of Phasing In

    • Potentially have every industrial facility in the U.S. needing a permit at the same time at the same time agencies are trying to write the regs and figure out what the issues will be

  • Approach used was to create general permits along with regulations

    • Published permits in Fed. Register

    • Industries could apply for coverage under general permit


Primacy and phase in
Primacy and Phase In

  • States also created general permits - often largely copied the Feds and added several of their own

  • Could go for 3 types of permits

    • A General Permit for an entire sector of industries

    • An Industry Specific Permit where an industry collectively tried to organize for a permit

    • Individual Facility Permit


Where we are at now
Where We Are At Now

  • Initial Shock is through system

    • Moving away from general permits

    • Some stabilizing on Industry specific permits

    • Many are moving toward individual permits just like individual NPDES

  • One Problems in transition is anti- back slide provision

    • If a general permit put some restriction that didn’t fit - it becomes hard to alter going to individual


Basic features of storm water
Basic Features of Storm Water

  • Storm Water Permits are built around two ideas

    • Every facility needs a Storm Water Pollution Prevention Plan (SWPPP)

    • Facilities should use Best Management Practices to avoid contact of storm water with contaminants


Permit dangers
Permit Dangers

  • May not want to volunteer to do too much

    • watch out for numerical effluent limits

    • monitoring requirements

    • Problem is backslide provisions - if you have homes built up drainage and they spill into storm water the limits could nail you

  • Watch specifics with sensitive information

    • your permit must be on site for inspectors

    • considered a public document - may allow tree huggers and NIMBYs to demand access


Creating a swppp
Creating a SWPPP

  • Step #1 - Formulate Your Team

    • Need to have someone who is ultimately responsible

      • Tempting to get a consultant - helpful but you can be surprise inspected and need to have someone on site who can answer questions and ferry inspectors around

    • Larger facility may use a division manager

    • Smaller may have chief engineer


Step 2 existing plans
Step #2 Existing Plans

  • Look at contents of existing permits - may tell you what the issues are - also helps to prevent contradicting yourself

    • Oil Drums probably already have a spill prevention and countermeasures plan

    • Toxic Substances already have plans

    • May be community emergency response plans

    • OSHA Emergency Action Plans


Check what discharges covered
Check What Discharges Covered

  • Process Waters have NPDES permit

    • some commingled waters have to be treated as process waters and are NPDES

      • don’t duplicate coverage

  • Check for restrictions and discharges to municipal sewer cover certain discharges or impose specific conditions


Step 3 site assessment
Step #3 - Site Assessment

  • Obtain a Base Map of Property - don’t go out for a custom survey

    • A good enlarged topo

    • Ariel Photos from IDOT or USDA

    • Tax Maps

    • U.S. Soil Conservation Service Mapping

    • U.S. Fish and Wildlife Service National Wetlands Inventory Mapping


Add to the base map
Add to the Base Map

  • Drainage Patterns and Flow Directions

    • Surface Water Bodies including wetlands

      • Any water bodies receiving points for storm water

      • Any place receiving storm water from a storm sewer

    • Any Storm Water discharges from property

    • Any Non Storm Water Discharges

      • Locate NPDES discharges and give permit number

      • Check in dry season when run-off and water bodies more obvious

      • State how things were established

      • Company Official must certify no unpermitted discharges


Add location of process activ
Add Location of Process Activ.

  • Stock Piles

  • Crushers

  • Feed bins

  • Conveyors

  • Fueling Stations and Fuel Tanks

  • Loading Areas

  • Equipment Maint Areas

  • Storage areas


More additions
More Additions

  • Add all existing storm water management features and structures


Source materials inventory
Source Materials Inventory

  • A Source Material is Something you handle in your trade or business that could be construed to contaminate material

    • The fact that many mining operations handle mostly natural materials is irrelevant (many laws are built on the premise that anything touched by a human process is a sinister environmental contaminant)


Likely source materials
Likely Source Materials

  • Raw Materials for Trade

    • All handled inventories or in process inventories of stone and aggregate materials for a quarry

  • All Intermediate Materials and Finished Products

    • May include asphaults or cements

  • All waste or byproduct materials including decantation ponds


More likely sources
More Likely Sources

  • Industrial Machinery and Machinery Yards

    • Conveyors

    • Crushers

    • Screens

    • Equipment Yards and Facilities

    • Your Parking Lot


More sources
More Sources

  • Fuels Solvents and Detergents

    • Fueling Stations

    • Fueling Storage

    • Plant Yards and Repair Stations

    • The Janitorial Closet

  • Locations of Previous Spills or Leaks

    • Any reportable amount of hazardous or non-hazardous from past 3 years (maybe more)


Unsources
Unsources

  • Some States have Created Guidelines on “Inactive” Materials that cannot be contaminants

    • Washed Stone (has no fines)

    • Broken Concrete (recycle is good)

    • Rip Rap

      • Rip Rapping of Channels is considered a best management practice so calling it a contaminant is embarrassing to regulators


Water quality data
Water Quality Data

  • Inventory and include any water quality data pertaining to storm water

    • May be little initially but likely to grow with time


Write a narrative description
Write a Narrative Description

  • Mining is a minor source compared to what many regulators are used to

  • Many know little about mining except for some negative comments from stories and movies where mining companies are the villains

  • Politely explain how each process works - replace fear of the unknown with understanding


Step 4 best management pract
Step #4 Best Management Pract.

  • Identify areas where storm water may contact contaminant materials

  • Select Best Management Practices for those areas


Types of best management pr
Types of Best Management Pr.

  • Baseline Practices

    • Involve operations and handling practices

      • usually cheaper

  • Structural Practices

    • Involve building something to control

    • Problems with

      • Building Structures in Wetlands

      • Impoundment may be considered discharge to groundwater

      • Erosion control may overlap soil conservation

      • Construction permits may get into Zoning Issues


Baseline management pract
Baseline Management Pract.

  • Good Housekeeping

    • Round up Crud before it contacts storm water

    • Keep Floors and Ground Surfaces Clean

    • Sweeping Shoveling and Vacuuming are major accepted removal practices

      • Don’t hose it down - you just contaminated water

      • Don’t wait till after it has rained - use a schedule

    • Front end loaders and bobcats may clean up larger spills - hand shoveling can be labor intensive

    • Vacuum equipment may produce recycle


Operations and maintenance
Operations and Maintenance

  • Have regular trash pick-up and debris removal

  • Use Rapid Recycling Collection

  • Inspections for leaks in chemicals and fuel storage or even rock bins

    • Try to search and fix during regular maintenance

    • Lots of people try short-cuts here

  • Store in Proper Durable Containers

  • Train Crews in Spill Clean-up Methods


Materials storage practices
Materials Storage Practices

  • Provide Adequate Isle and Maneuver Space for Handling (so they don’t bash in all the drums trying to handle them)

  • Maintain an Inventory of What You Have

    • Often can save money on inventory

    • Walk Through and See What you have

    • Check Last Years Invoices

    • Keep up Labels - people toss mystery stuff

    • Keep MS Data Sheets file for everything


Chemical lube fuel drums
Chemical, Lube, Fuel Drums

  • Keep in contained or curbed areas so leaks can’t go anywhere

  • Keep out of direct traffic routes to reduce accidents from people unable to drive

  • Store off of ground to avoid corrosion around base

  • Have a lot of people trained in clean up - but only a few responsible for inventory


General source materials
General Source Materials

  • Store Indoors - works for chemicals but probably not aggregate piles

  • Cover the pile and put diversion berm around to route storm water away from the evil contaminant

  • Look for Guidelines that may exempt your coarser rock from being an evil contaminant

    • You may not be able to cover everything but maybe you only need to guard your finer material


Other cover applications
Other Cover Applications

  • Often feasible to have covered refueling depots - your employees may actually think you were setting up a convenience for them

  • Look at use of tarps for things temporarily outside


Include employee participation
Include Employee Participation

  • Have Regular Training and Review

  • Put up Bulletin Boards and Posters

  • Include Treatment in Meeting Agendas


Dust control
Dust Control

  • Settled Dust may get you out of Clean Air Regs but it can get you nailed in Storm Water

  • Avoid Denuded Areas - vegitation makes you look more environmental friendly anyway

  • Use Wind Breaks Like Trees

  • Have coarser material at surface so water can’t run off with fines


More dust control
More Dust Control

  • Do look at wetting down but not enough to produce run-off

  • Do consider surfactants

    • don’t use oils because they are evil contaminants of soils

    • use in drier areas where water cannot carry off

    • keep away from traffic so tires can’t spread

  • Look at Dry Collection

    • especially if a recycle opportunity exists


Use preventative maintenance
Use Preventative Maintenance

  • Regularly Inspect and Maintain Storm Water Handling Facilities

    • Keep onsite records of own - not necessarily sent in

    • Be careful with sensitive information - public access not well defined

  • Regular Maintenance of Things that could release contaminants

    • Hydraulics on Equipment


More preventive maintenance
More Preventive Maintenance

  • Have a list of everything that needs inspection

  • Have a schedule for those inspections

  • Have records of Results of Inspections

  • Have records of Timely Corrective Actions taken as result of those inspections

  • Maintenance may save you down time on production

    • Accident could trigger prosecution from unexpected statutes


Epa itemizes for inspection
EPA Itemizes for Inspection

  • Pipes

  • Pumps

  • Storage Tanks and Bins

  • Pressure Vessels

  • Pressure Related Valves

  • Pressure Release Valves

  • Process and Materials Handling Equipment

  • Storm Water Management


Have facilities inspections
Have Facilities Inspections

  • Look for things that could cause discharge of priority chemicals

  • Things that could cause contact with finished or unfinished goods (rock in a quarry)

  • Bins and related dust patterns

  • Lot of things can be added to inspections to avoid equipment failures


Lots of inspections
Lots of Inspections

  • Most inspections can be visual

  • Need to have “qualified personnel” do inspections

    • Should be a responsible person who keeps a record of finding and response actions

    • Need to be familiar with SWPPP

    • Some have suggested surveillance and security people

  • Occasionally need chemical and acoustic weld tests


Formulate spill prevention
Formulate Spill Prevention

  • Need Spill Prevention and Response Plan

  • Look at previous spill records to determine what areas are spill prone

  • Look at whether recycling can reduce inventories available to spill

  • See what a regular inspection program can do to reduce incidents


Spill prevention strategies
Spill Prevention Strategies

  • Have standard filling procedures and set ups

    • jury-rigged filling from drums causes spills

  • Have a spill response plan

    • employees must be aware of what plan is

    • need to have a spill response team

    • have a plan for notifying authorities if necessary including assignments of who will do


Helping spill response
Helping Spill Response

  • If spillable chemicals are bermed or in containment structures the spill impact will be localized and potentially not contactable by storm water

  • Need to make sure that clean up equipment can get access to area

    • Don’t hose spill into the drain

    • EPA likes putting down sorbants to soak up


Sucking up spills
Sucking Up Spills

  • Variety of materials available

    • Clays straws and fly ash are common and effective sorbants

    • polymers and beads are pricey

    • Don’t use ammonium nitrate and wood chips for diesel fuel

  • There are gelling agents to solidify many larger spills for mechanical clean up


Have a waste management plan
Have a Waste Management Plan

  • Minimize handling and inventories

  • Check incoming vehicles for leaks

  • On Vehicles used for disposal

    • Include spill baffles for liquid wastes

    • use sealed gates and tarps for solids

    • include tire washes to limit tracking around site

  • Try to keep wastes separated to improve the chances of recycling


More waste management
More Waste Management

  • Work on loading system efficiency to avoid spills during loading

    • Try to minimize fugitive emissions that may settle and become an issue

  • Set up land fill like areas to minimize run-off

    • keep slopes under 6%

    • look for areas of low water table

    • try to avoid getting a groundwater issue out of it


Control vehicle washing
Control Vehicle Washing

  • Maintain well but wash only when absolutely needed

  • Wash in designated areas only

  • Use environmentally friendly phosphate free detergents


Structural control practices
Structural Control Practices

  • Storm water conveyance (ditches or channels)

    • line ditches to prevent sediment

    • actually size the ditch for the run off expected - don’t just go out for a digging party

      • its easier to do it right the first time than retrofit

  • Use conveyances to keep process waters away from and separate from storm water


Structural controls
Structural Controls

  • Use Diversion Dikes to block storm waters out of process areas

    • larger areas may require something more simple like ditches and berms

  • Build up industrial areas above the grade of surrounding ground

    • Use paving to funnel process waters to receiving points

    • Check for cracks to prevent discharges to groundwater


More structural controls
More Structural Controls

  • Pave over spill areas and surround with containment barriers

  • Use Drip Pans for Minor Spills

    • Create structural depressions to channel spills to discrete areas for easy clean up with sorbants

  • Build covering structures for materials


Erosion prevention programs
Erosion Prevention Programs

  • Try to maintain lines of vegetation even when disturbance is necessary

    • Vegetation spreads back easier from established strips

    • Established strips help to break run-off and erosion

    • Use increase planning needed to work around to reduce confinements that can cause spills and other problems


More erosion prevention
More Erosion Prevention

  • Leave buffers around sensitive or problem areas

    • leave buffer zones around wetlands

    • put buffer zones around parking lots so that run-off can infiltrate before it goes some place

  • Stabilize stream banks so that erosion is reduced

  • Put down mulching matting and netting on erosion prone areas


Still more on erosion
Still More on Erosion

  • Establish temporary seeding with fast growing species to stabilize soil

  • Resort to chemical stabilization

    • vinyls , rubbers, asphaultic materials to hold what can’t be vegetated

      • be aware this can promote rapid run-off

      • make sure your stabilizer is not a contaminant

  • Use grids of dikes and swells to break the speed of run-off


Erosion controls
Erosion Controls

  • Use pipe slope drains to collect and run water down sensitive slopes that could be eroded by run-off from other areas

  • Install Filter and Silt Fences

  • Can use staked straw bales as barriers

  • Use gravel or stone filter berms (since the material is a best management practice it usually can’t be a contaminant when used this way)


Erosion control
Erosion Control

  • Higher gravel barrier that creates small water impoundment is a check dam

    • These can settle sediment out of water

  • Build inlet protection for storm water drains

    • These will have to be regularly inspected


Use sediment basins
Use Sediment Basins

  • Often serve areas over 5 acres in size

  • Regular structure or mini-dam requires special features

    • dewatering outlet above sediment line

      • has a finite sediment storage capacity before clean out is required

      • capacity may be sized using Universal Soil Loss Equation

    • emergency overflow rip-raped discharge that spreads over an area

    • has set free board requirements

    • May need fences to handle liability problems with dumb kids drowning


Infiltration promotion
Infiltration Promotion

  • Many erosion control practices automatically promote infiltration of uncontacted waters

  • Porous pavements

  • Vegetation strips and grass swales

  • Infiltration Trenches

    • gravel filled trench to take water down

      • may have to check hydrologic balance issues


Finishing out the program
Finishing Out the Program

  • When all else fails consider water treatment

  • After the plan is developed use operating history and review of results to fine tune and repair busts in your plan


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