NDEQ Industrial Storm Water General Discharge Permit Presentation for: Nebraska Aviation Symposium...
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Transcript of NDEQ Industrial Storm Water General Discharge Permit Presentation for: Nebraska Aviation Symposium...
NDEQ Industrial Storm Water
General Discharge PermitPresentation for: Nebraska Aviation Symposium
January 27, 2011
By: Bill Imig, Environmental Scientist – Olsson Associates
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
Covered ActivitiesStorm 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
Activities Not Allowed under the Permit
• Discharges of wash water
• Discharges of deicing chemicals during dry weather
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
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
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
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
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)
Implementation Timeline
Will be pushed back pending issuance of the permit
Source: NDEQ
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
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
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.
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
Source: NDEQ
Impaired Waters
Class A & B State Resource Waters and Drinking Water
Source: NDEQ
Benchmark Monitoring
• 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
Source: NDEQ
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
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
Schedules and Procedures - Controls
• Good housekeeping schedule
• Maintenance procedures schedule
• Spill prevention and response
• Training
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)
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)
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
Questions?