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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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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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