NDEQ Industrial Storm Water General Discharge Permit

1. NDEQ Industrial Storm Water General Discharge Permit Presentation for: Nebraska Aviation Symposium January 27, 2011 By: Bill Imig, Environmental Scientist – Olsson Associates

2. Permit Applicability • Sector S- Air Transportation Facilities • SIC codes 4512-4581 451 Air Transportation, Scheduled, and Air Courier Services         4512 Air Transportation, Scheduled         4513 Air Courier Service 4522 Air Transportation, Non-scheduled 4581 Airports, Flying Fields, and Airport Terminal Services

3. Covered Activities Storm water discharges from those portions of the air transportation facility that are involved in: • Aircraft maintenance – includes rehabilitation, mechanical repairs, painting, fueling • Equipment cleaning • Deicing operations

4. Activities Not Allowed under the Permit • Discharges of wash water • Discharges of deicing chemicals during dry weather

5. No Exposure Certification • All industrial materials and activities are protected from exposure to rain, snow, or runoff • Industrial materials or activities include: • Material handling equipment • Industrial machinery • Raw Materials • Products (Fuel, Oil, etc) • Waste Products • Exceptions • Drums, Barrels, Tanks that are sealed and not leaking • Adequately maintained vehicles used for material handling

6. No Exposure Checklist • Using, storing or cleaning industrial machinery or equipment or areas where residuals from industrial machinery or equipment remain and are exposed to storm water • Materials or residuals from spills exposed to storm water • Materials or products from past industrial activities • Material handling equipment (except adequately maintained vehicles) • Materials or products during loading/unloading or transporting activities

7. No Exposure Checklist • Materials or products stored outdoors (except products intended for outdoor use where exposure to storm water does not result in discharge of pollutants • Materials contained in open, deteriorated or leaking storage drums, barrels, tanks and similar containers • Materials or products handled/stored on roads or railways owned or maintained by the permittee

8. No Exposure Checklist • Waste materials (except waste in covered, non-leaking containers (dumpsters) • Application or disposal of process wastewater • Particulate matter or visible deposits of residuals from roof stacks and or vents not otherwise regulated (under an air quality permit) and evident in storm water

9. 2011 Draft Permit • Replaces existing permit first issued 1997 • NDEQ will hold a public hearing February 22, 2011 • Final permit target date is April 1, 2011 • Most Significant Changes • T&E Species Impact Evaluation for New or Expanded Dischargers • Impaired Waters, Class A, Class B • Discharge Monitoring (Visual and Benchmark)

10. Implementation Timeline Source: NDEQ Will be pushed back pending issuance of the permit

11. Limitations on Coverage • Non-storm water discharges • T&E Species and Critical Habitat Protection • New or Expanded discharges to Impaired Waters, Class A and B Resource Waters, Drinking Water Supplies

12. Allowable Non-Storm Water • Allowable non-storm water discharges • Fire fighting • Fire suppression system flushing • Potable water line flushing except chlorination • Condensate from air conditioners, coolers, etc. • Irrigation drainage from agricultural lands • Landscape irrigation w/ approved application of fertilizer, etc. • External building wash down without detergents • Groundwater and spring water • Foundation drains if not contaminated with process water • Windblown mist from cooling towers

13. T&E Species Evaluation • If you are a new or expanded discharger coverage under general permit is only available if storm water does not adversely impact listed species and habitat. • NDEQ has prepared a 9 point checklist to determine if discharge has potential to impact T and E Species.

14. Impaired, Class A &B, and Drinking Water Supply • New or Expanded Discharge to Impaired Water • Meet TMDLs if established • New or Expanded discharge to class A – not eligible under the general permit • New or Expanded discharge to class B – prior written approval from NDEQ • New or Expanded discharge to Drinking Water – prior written approval from NDEQ

15. Impaired Waters Source: NDEQ

16. Class A & B State Resource Waters and Drinking Water Source: NDEQ

17. Benchmark Monitoring Source: NDEQ • Deicing Season- Collect samples during timeframe under which deicing activities occur (usually October – April) • At all Outfalls that collect runoff from deicing areas • Collect 4 separate samples during deicing season

18. Benchmark Monitoring Results • If average of first 4 values < benchmark – done sampling for permit term • If average > benchmark need to reevaluate BMPs & controls. Make revisions and continue monitoring • Or determine no further reductions are economically practicable or achievable and notify NDEQ

19. Contents of SWPPP • Pollution Prevention Team • Site Description – locations, activities, drainage, outfalls, etc. • Site Map – submit copy to NDEQ with NOI • Identify Potential Pollutants – Materials storage, Operational Activities that are exposed to storm water • Control Measures • Schedules and Procedures • Documentation

20. Schedules and Procedures - Controls • Good housekeeping schedule • Maintenance procedures schedule • Spill prevention and response • Training

21. Schedules and Procedures – Monitoring and Inspections • Benchmark Monitoring – Seasonal during deicing operations • Visual Assessment of Storm Water discharge– At least Quarterly • Routine Inspections – Monthly during deicing season (usually October – April) • Comprehensive Inspection – Annual (during periods of deicing operations if possible)

22. Documentation • T&E species evaluation • Discharge to Impaired or State Resource Water authorization • NOI • NDEQ acknowledgment letter • Best Management Practices • Inspections • Reports • Corrective Action • Monitoring Results (visual , benchmark)

23. Reporting • Non-compliance which may endanger health or environment within 24-hours. • Corrective Action – record within 24 hours, document actions within 14 days, report to NDEQ in 30 days • Spill / Release reporting (per Title 126, Ch. 18) • Upon NDEQ request

24. Questions?