The Nuts and Bolts of the 1200-A Permit Presented by Laura Kerr - - PowerPoint PPT Presentation

The Nuts and Bolts

• f the 1200-A Permit

Presented by Laura Kerr OCAPA Winter Workshop

What We Will Cover

• Is your facility covered under the 1200-A
• How to obtain coverage under the NPDES 1200-A

General Permit (“1200-A”)

• A general overview of the permit
• Focus on specific permit requirements
• Narrative technology-based effluent limits
• Authorized vs. non-authorized stormwater

discharges

• The Stormwater Pollution Control Plan
• Benchmarks, reference concentrations and

effluent limits

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WHO IS COVERED UNDER THE 1200-A

• If your facility is a covered facility

– Has a primary Standard Industrial Classification (SIC) code 14, Mining and Quarrying of Nonmetallic Minerals; or – Asphalt mix batch plants and concrete batch plants, including mobile operations of this type, are required to obtain coverage under the permit

AND

• May discharge stormwater or mine dewatering

water from a point source to surface waters or conveyance systems that discharge to surface waters. YOU NEED A 1200-A PERMIT

4

DISCHARGES AUTHORIZED BY THE 1200-A

• Stormwater
• Mine dewatering water

– Water that is impounded or that collects in the mine and is pumped, drained, or otherwise removed from the mine through the efforts of the mine

• perator.

– Includes wet pit overflows caused solely by direct rainfall and ground water seepage. – If co-mingled with process water, not authorized!

• Non-stormwater discharges

5

OBTAINING COVERAGE UNDER THE 1200-A

• The general permit itself specifies the

requirements for obtaining coverage

• Currently, the 1200-A requires:

– An application for coverage – Public notice and a 30-day written comment period – Written DEQ approval of coverage

• Important Caveat: On Dec. 3, 2017, the 1200-A

expired and is currently administratively extended

– DEQ prohibits new applicants from obtaining coverage under administratively extended permits

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AN OVERVIEW OF THE 1200-A PERMIT REQUIREMENTS

• Schedule A: Technology Based Limitations, Water

Quality Based Limitations, Stormwater Pollution Control Plan, Benchmarks and Corrective Action

• Schedule B: Monitoring and Reporting

Requirements

• Schedule C: Compliance Schedules
• Schedule D: Special Conditions
• Schedule E: Sector Specific Requirements
• Schedule F: General Conditions

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NARRATIVE TECHNOLOGY-BASED EFFLUENT LIMITS

• Erosion and sediment control
• Containment, Covering

Activities and Stormwater Diversion/Minimize Exposure

• Oil and Grease (eliminate or

minimize)

• Waste Chemicals and Material

Disposal

• Debris Control
• Routine housekeeping
• Spill prevention and response

procedures

• Preventative Maintenance
• Employee Education
• Non-stormwater discharges

(eliminating unauthorized discharges)

Control measures used by permit registrant to meet the narrative technology-based effluent limits must be “technologically available and economically practicable and achievable in light of best industry practice”

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AUTHORIZED VS. UNAUTHORIZED NON- STORMWATER DISCHARGES

• Authorized non-stormwater

discharges include:

– Uncontaminated condensate from air conditioners, coolers etc. – Irrigation drainage – Certain landscape watering – Certain pavement wash waters – Vehicle washing that does not use detergents or hot water – Routine external building washdown that does not use detergents or hot water. – Uncontaminated groundwater or spring water. – Foundation or footing drains where flows are not contaminated with process materials.

• Unauthorized non-stormwater

discharges include:

– All other non-stormwater discharges including process wastewater

• Note: mine dewatering

discharges composed entirely of stormwater or uncontaminated groundwater are not process wastewater

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• ADDITIONAL LIMITS OF NOTE
• Water Quality Based Effluent Limits (“The permit

registrant must not cause or contribute to a violation

• f instream water quality standards as established in

OAR 340-041.”)

• Limits for discharges to impaired waterbodies

– Impaired waterbodies in Oregon – TMDLs – Application to permit registrant

• Limit on the discharge of “significant amounts of sediment

to surface waters” (permit registrant must prevent)

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STORMWATER POLLUTION CONTROL PLANS (SWPCP)

• DOGAMI Operating Permit and Reclamation Plan may be

substituted for a SWPCP – If it contains all required SWPCP elements and information

• The SWPCP must include information such as:

– Detailed Site Description – Procedures and schedules to meet technology based effluent limits – Employee training procedures

• The SWPCP is a living, breathing document

– Must be retained on site – Must revised to reflect conditions on site (certain revisions must be submitted to DEQ or agent)

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STORMWATER POLLUTION CONTROL PLANS TIPS

• SWPCP

– should address and meet every significant applicable term of 1200-A permit – should not include non-permit-required activities or even more ambitious schedules (use separate documentation):

• “Failure to implement any of the control measures or

practices described in the SWPCP is a violation of the permit.”

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BENCHMARKS, REFERENCE CONCENTRATIONS AND EFFLUENT LIMITS

• Benchmarks, reference concentrations and effluent

limits, oh my! What is the difference?

• Benchmarks
• Reference concentrations

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BENCHMARKS, REFERENCE CONCENTRATIONS AND EFFLUENT LIMITS

• Effluent Limits

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EXCEEDANCES AND CORRECTIVE ACTION

• What happens when you have an exceedance?

– Legal significance of exceedances of a benchmark vs. reference concentration vs. effluent limit – These are permit violations if you have a benchmark or reference concentration exceedance:

• Failure to investigate and determine if corrective action is

required or if SWPCP revisions are required

• Failure to prepare correction action report
• Failure to implement the corrective action
• DOCUMENT EACH STEP!
• Corrective Action Requirements

– Tier I vs. Tier II

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ADDITIONAL PERMIT REQUIREMENTS

• To be discussed in detail this afternoon:

–Monitoring –Inspections –Reporting and recordkeeping

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Communicate It!

(Employee Education)

Do It! Inspect and Document!

(DMRs, monitoring reports, monthly inspection reports, Corrective Action Plans)

Implement Action Plans! Write It!

(SWPCP and revisions)

Stormwater Permit Continuous Improvement Cycle

What To Expect in the Next Permit

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QUESTIONS/COMMENTS?

Laura Kerr (503) 294-9176 laura.kerr@stoel.com