Workshop I Advanced Air & NPDES Permits Best Practices & - PDF document

Workshop I Advanced Air & NPDES Permits … Best Practices & Succeeding in the Process to Obtain the Best Possible Permit Thursday, July 26, 2018 10:30 a.m. to Noon

Biographical Information Larry S. Smith, P.E., Principal Consultant GT Environmental, Inc., 635 Park Meadow Rd, Suite 112, Westerville, OH 43081 Phone: (614) 794-3570 ext. 18 Fax: (614) 899-9255 lsmith@gtenvironmental.com Larry S. Smith, P.E., is a Principal Consultant with GT Environmental, Inc.’s Westerville, Ohio office. He has 30 years of experience working for clients in the areas of environmental compliance, brownfield and RCRA evaluations, and remediation. Larry has prepared individual and general NPDES permit applications for a variety of industries and clients for wastewater and storm water discharges. He has prepared storm water pollution prevention plans (SWPPP) for multiple industries, and has developed strategies for implementing best management practices as directed in a SWPPP. Larry holds a Bachelor of Science degree in chemical engineering from the University of Cincinnati. He is a Professional Engineer (P.E.) in Ohio, a Certified Professional (CP133) under the Ohio EPA Voluntary Action Program (VAP), and a Licensed Remediation Specialist (LRS) in West Virginia. Ashley Ward, P.E., NPDES Supervisor Ohio EPA, Division of Surface Water 50 West Town Street, Suite 700, Columbus, Ohio 43215 Phone: (614) 644-4852 ashley.ward@epa.ohio.gov Ashley is the NPDES Program Supervisor in the Division of Surface Water. She has two Bachelor of Science degrees from The Ohio State University; one in Environmental Science, water specialization and one in Chemical Engineering. Prior to her current position, Ashley worked for the Division of Surface Water Chief in several different programs including enforcement, rules, NPDES and pretreatment. Before working for Ohio EPA, Ashley worked as a Microbiologist in the Research and Development Department of Lexmark. Katie Milk, CHMM, Environmental Scientist III GT Environmental, Inc., 778 McCauley Rd, Suite 120, Stow, OH 44224 Phone: (330) 687-3664 Fax: (614) 899-9255 kmilk@gtenvironmental.com Katie Milk is an Environmental Scientist III with GT Environmental, Inc.’s Northeast Ohio office, and has over ten years of environmental consulting experience. Katie’s primary focus is on Title V and minor source air permitting, air emissions inventories, synthetic minor demonstrations, air quality dispersion modeling, and state and federal rule applicability determinations, including MACT, NESHAP and NSPS. She also conducts multi-media environmental compliance audits, and provides compliance assistance for clients in a variety of industries in the areas of hazardous waste, EPCRA Sections 311/312/313, SPCC, waste water and storm water. Katie is a graduate of The Ohio State University with a Bachelor of Science degree in Atmospheric Science. Katie is a Certified Hazardous Materials Manager (CHMM), and is a member of the Air and Waste Management Association (AWMA) and the Ohio Manufacturers’ Association (OMA).

Biographical Information Kevin J. Kilroy, Safety & Environmental Manager Smithers-Oasis Company, 919 Marvin Street, P.O. Box 790, Kent, OH 44240 Phone: (330) 676-4426 kkilroy@smithersoasis.com Kevin Kilroy has almost forty years of experience in environmental, health and safety programs in a manufacturing setting. He works for Smithers-Oasis Company, a privately held company headquartered in Kent, Ohio where it has manufacturing and distribution facilities. The company manufactures and markets water-absorbing floral foams, accessories and floral mechanics to the retail floral market worldwide. They manufacture and market a complete line of post-harvest flower care products for the floral industry through its Floralife Division. They also manufacture and market products for the grower/ greenhouse industry and insulating products for temperature- controlled packing products. At Smithers-Oasis Company, Kevin has responsibility for the safety and environmental programs of the North American and Floralife Divisions in North America and provides consulting services to the other global operations of the company, particularly on product and safety related issues. Prior to joining Smithers-Oasis Company, Kevin worked nineteen years for an Ohio based Fortune 500 chemical and aerospace company, mostly at a chemical manufacturing facility where he was responsible for managing the plant’s environmental program. Over the course of seventeen years at the plant, he also worked on health and safety programs. Prior to this, he worked for two years in the chemical division environmental department conducting permit review and project environmental impact assessments. Kevin received a B.S. in both Chemical Engineering and in Plastic Technology from Lowell Technological Institute and a M.S. in Environmental Studies from the University of Lowell. He is a member of the American Institute of Chemical Engineers (AICHE), and he was a past chairman of the Akron Section of AICHE.

ADVANCED AIR AND NPDES PERMITS NPDES PERMITTING – STORM WATER JULY 26, 2018 LARRY S. SMITH, P.E. PRINCIPAL CONSULTANT

TODAY’S DISCUSSION  NPDES Permitting Overview  Ohio EPA General Permit  Triggers to Permit  Storm Water Pollution Prevention Plan (SWPPP)

NPDES OVERVIEW – STORM WATER  National Pollutant Discharge Elimination System - Clean Water Act, 1990  Storm Water  Municipal storm sewer systems  Construction activities  Industrial activities, 11 Categories of Industrial Activity  Storm Water Permit – Ohio Delegated Authority, Administrator  Industrial  Individual NPDES Permit  Multi-Sector General Permit for Industrial (OHR000006) June 2017  SIC Code  Notice of Intent (NOI)

NO EXPOSURE (NOE) All industrial materials and activities are protected by a storm resistant shelter to prevent exposure to precipitation and runoff.

WHAT TRIGGERS NEED FOR A PERMIT?  Loading/Unloading Operations  Outdoor Storage  Outdoor Process Activities  Dust or Particulate Generating Process  Illicit Connections and Non-Storm water Discharges  Waste Management

NOE? Separate from vehicle maintenance activities; good condition; secondary containment recommended.

NOE? Tanks, drums, barrels must be sealed with on operational valves, good condition, no transfer materials outside.

NOE? If cannot be mobilized by storm water runoff, and in compliance with other programs; or, if not tracked out on vehicle tires.

NOE? Loading dock – complete transfer inside. Storage of materials outside?

NOE? Final product allowed if the product is for outdoor use. Racks, wooden pallets allowed if pollutant free.

REQUIREMENTS OF A STORM WATER PERMIT  Legal  Control Measures  Inspections  Storm Water Pollution Prevention Plan  Monitoring

SWPPP DEVELOPMENT  Form SWPPP T eam  Make part of employee goals  Assess potential storm water pollution sources  Identify activities exposed to storm water  Inventory materials and pollutants  Potential areas of spills or leaks  Non storm water discharges  Salt storage  Sampling data

SWPPP DEVELOPMENT (CONT.)  S elect appropriate control measures and best practices  Minimize Exposure (AT&T Stadium)  MSGP Sector Specific non-numeric effluent limits  Good Housekeeping  Employee Training  Maintenance  Non-Storm water discharges  Spill prevention and response  Waste Garbage and floatable debris  Erosion and sediment control  Dust generation and vehicle training  Management of runoff  Salt storage piles

GOOD HOUSEKEEPING

GOOD HOUSEKEEPING

MANAGEMENT OF RUNOFF

Proximity to storm sewer. Need for spill kit.

SWPPP – DEVELOPMENT (CONT.)  Strong Site Map  Locations of significant structures, impervious surfaces  Direction of storm water flow  Receiving streams and outfalls  Potential pollutant sources  Activities (types of activities discussed above)

SWPPP SITE PLAN

SWPPP DEVELOPMENT (CONT.)  Develop inspection/monitoring program/schedule  Routine facility inspections, monthly  Quarterly Visual Assessment, benchmark sampling  Annual report certification  Benchmark  Effluent limitations guidelines monitoring  Other monitoring as required

QUARTERLY VISUAL SAMPLING  Color  Settled Solids  Odor  Suspended Solids  Clarity  Foam  Floating Solids  Oil sheen

BENCHMARK SAMPLING  Based on SIC  4 quarters within first 3-year period  One from each quarter

ROUTINE FACILITY INSPECTION REPORT

QUARTERLY MONITORING REPORT

ANNUAL REPORTING CERTIFICATION

QUESTIONS  Larry S. Smith, P.E.  Principal Consultant  GT Environmental, Inc.  (614)794-3570 x18  lsmith@gtenvironmental.com

NPDES Updates Ashley Ward, P.E. NPDES Program Supervisor

Presentation Outline • NPDES Rule updates • WQS triennial review • 316(b) • Variances • General permits • Permitting tips

NPDES Rule Updates • OAC Chapter 3745-33 • Applications not considered complete unless all required quantitative data are collected in accordance with sufficiently sensitive methods. • Treatment Additives. http://www.epa.ohio.gov/dsw/permits/individuals • Two new minor modifications. • Group 5 parameters when using discretion. • Acute toxicity limits.