Workshop Q New & Emerging Water Management Issues Best - - PDF document

Workshop Q

New & Emerging Water Management Issues … Best Practices for Storm Water Permitting, Pollution Prevention Plans and Spill Prevention Control & Countermeasures

Tuesday, March 26, 2019 2 p.m. to 3:15 p.m.

Biographical Information

Jeffrey A. Miller, P.E., BCEE, Sr. Regulatory Expert, August Mack Environmental 7830 North Central Drive, Lewis Center, Ohio 43035 (614) 561-8030 Jmiller@augustmack.com

• Mr. Miller recently retired from White Castle System, Inc., a food service and manufacturer

based in Columbus, Ohio. Mr. Miller was responsible for environmental due diligence for developing new restaurant locations, managing environmental challenges discovered during redevelopment, and environmental compliance for eight manufacturing plants (3 meat packing plants, 2 bakeries, and 3 frozen food plants). Environmental regulations include air, PSM/RMP, water, storm water, wastewater, and solid waste. Mr Miller is a part time Senior Regulatory Expert with August Mack Environmental. Mr. Miller has over 29 years of experience in environmental engineering and has presented and published on such topics as wastewater treatment, site remediation, storm water pollution prevention, sustainability, and overall industrial compliance. Mr. Miller holds a Bachelor’s of Science degree in Petroleum Engineering from Marietta College (1983), and a Master’s of Science degree in Petroleum Engineering from West Virginia University (1986). He is a registered professional engineer in Indiana, Kentucky, Michigan, Ohio, and Pennsylvania; and an American Academy of Environmental Engineers Board Certified Environmental Engineer. Stephanie A. Miller, Senior Consultant Trinity Consultants, 110 Polaris Parkway, Suite 200, Westerville, OH, 43081 614-433-0733 SMiller@trinityconsultants.com Stephanie Miller is a senior environmental consultant with Trinity Consultants’ Columbus, Ohio

• ffice. She began her career with Trinity in Pittsburgh in 2014, where she served a number of

industry sectors throughout Pennsylvania, West Virginia, and Ohio. Stephanie’s experience includes air permitting and compliance, air dispersion modeling, Environmental Management Information Systems (EMIS), Spill Prevention Control and Countermeasure (SPCC), Toxic Release Inventory (TRI), and a number of other environmental specialties. Her work encompasses a wide variety of industries, including oil & gas, metal manufacturing, chemical manufacturing, among other manufacturing industries. Stephanie earned a Master of Science degree in Environmental Science from the University of Cincinnati, where she conducted research on drinking water treatment at the U.S. EPA. She earned a Bachelor of Science degree in Biology from Kent State University. James C. Albertz, Senior Environmental Engineer Albertz Engineering, LLC, 3621 Vineyard Ridge, Cincinnati, OH 45241 513-368-9791 jim@albertzengineering.com Jim is a Professional Engineer with over 25 years of experience in feasibility study, design, construction, operation and improvement of municipal and industrial water and wastewater treatment, stormwater management, green infrastructure, and soil and groundwater

• remediation. He has designed and installed treatment systems that use gravity separation,

filtration, pH neutralization, adsorption, and oxidation, chemical, and biological processes. Mr. Albertz has designed landfill gas, leachate collection, and stormwater management systems. Using creative problem solving, Mr. Albertz has developed robotic manufacturing systems, integrated machine guarding, and designed automated process control systems. A member of the Construction Specifications Institute, Mr. Albertz has prepared specifications for large-scale construction projects including treatment, remediation, and maintenance facilities. Jim is a graduate of University of Cincinnati with a M.S. in Civil and Environmental Engineering. He teaches Engineering Project Management at UC.

Best Practices for Storm Water Permitting, Pollution Prevention Plans and Spill Prevention Control & Countermeasures

MEC EHS S ymposium  March 26, 2019

S tephanie Miller –Trinity Consultants Jeff Miller –August Mack Environmental Jim Albertz –Albertz Engineering

Albertz Engineering, LLC

Introduction and Topics

˃ Jeff Miller: Multi-S

ector General Permit and No Exposure Exemption

˃ Stephanie Miller: Best Management

Practices for S PCC

˃ Jim Albertz: Innovative Best Management

Practices

General Permits Since 1992

 Original Group General and General Permits were Best Management Practices (BMP)-Based  Focus not on sampling results but on BMP’s  Compliance driven by SWP3 and implementation of BMP’s  Non-compliance driven by lack of BMP maintenance and attention to BMP details  Manageable compliance  Length of permit manageable

Indiana and Kentucky

 Indiana 327 IAC 15-6 (Rule 6)

• File NOI
• File Annual Report
• Checklist for QA on facility SWP3

 Kentucky General Storm Water Permit 34 pages

• Expires July 31, 2023
• File NOI

5

50 100 150 200 250 300 350 400

OHG000001 (Group) OHR000002 OHR000003 OHR000004 OHR000005 OHR000006 Multi‐Sector GP

Pages

General Permit Pages

2015 USEPA MSGP

Effective July 21, 2015 @ 376 pages Benchmarks the same except for saltwater discharges Additional sector requirements

• A (Timber Products)
• G, H & J (Mining)
• S (Air Transportation)

2015 USEPA MSGP

Combined comprehensive site inspections & routine facility inspections Updated corrective actions section including new deadlines SWPPP must be provided with NOI to be available to EPA & public

2015 USEPA MSGP

New Endangered Species evaluation requirements prior to receiving permit coverage Dischargers must ensure Water Quality Standards will be met

• Additional monitoring
• Possible treatment prior to discharge

2015 USEPA MSGP

New requirements for minimizing exposure, good housekeeping, spill prevention & response, and employee training Clean catch basins when debris reaches 2/3 of the sump depth & keep debris at least 6” below the outlet pipe

2015 USEPA MSGP

Treatment of pavement wash water prior to discharge (filtering or other treatment) More specific annual training requirements

General Permits Since 1992

 Multi-Sector General Permit push by Director Korleski at end

• f Strickland Administration

 Director Nally pushed for Ohio EPA to implement Multi- Sector General Permit

• Director Nally at meeting specifically told me he did not

know why it was so difficult to visually observe outfall during precipitation event  Former Director Butler approved current version OHR000006

• r Sixth Generation which is just an extension of OHR000005
• r Fifth Generation

 Multi-Sector included full enforcement strength of CWA and extended to No Exposure Exemption (note 18 substantial improvements identified)

Costs Associated with Multi-Sector General Permit

 Original estimation of cost to Ohio Industry approximately $8,400 additional per year  Just included sampling and did not include extra events for lack of sufficient rainwater intensity calling for another sample event  Did not include annual compliance evaluation  2019 estimate of an additional $10k per facility  2019 estimate of $31,000,000 for Ohio Industry over life of permit (assumes no Benchmark exceedances)

Benchmark Comments

 Benchmarks not ambient water quality criteria  Some Benchmarks lower than acute and chronic water quality criteria  Result is chronic water quality criteria applied to acute zone!

Benchmark Comments

Benchmark Survival

Don’t over-sample “Problematic” benchmarks

• Zinc
• TSS
• Copper
• Nitrite+Nitrate

30 days to correct if exceed benchmark

“No Exposure” Basics

Conditional, not an exemption Criteria somewhat subjective Evaluate modifications to qualify Use EPA Guidance Document (Published 2000) Update/re-submit every 5 years

• Facility list available on-line

“No Exposure” Data 3,031 facilities certified since 2007 4,913 facilities certified 2/11/2019 22 sectors as “primary” 16 sectors as “secondary” Facilities in all 88 counties

No Exposure Certification

 Indiana, Kentucky and Ohio file electronically  Reiterate the risk associated with compliance to management  Enforcement force of CWA available to agencies

No Exposure Certification (NEC)

NEC = No storm water NPDES permit “All industrial materials & activities are protected by a storm resistant shelter to prevent exposure to rain … and/or runoff” Renew NEC every 5 years

No Exposure Certification

Continuous compliance (not periodic) NEC is within the CWA - meaning full teeth of CWA can be applied for mishandling No Exposure You WILL BE inspected

No Exposure Certification

11 questions must be answered NO! MS4 discharges - provide NEC to them

NEC Assessment Criteria

Does industrial activity meet definition for storm water? Does regulated activity meet definition

• f “No Exposure” & qualify for

permitting exclusion? Completed & submit NEC

No Exposure Strategies

Move items under roof Cover “Shelter” can mean fixed or temporary Common sense interpretations of the USEPA Guidance manual & Particulate Emissions

Permit Renewal “Wish List”

Recognition into perpetuity that “Benchmarks” are for BMP progress & not compliance point Unrealistic sampling expectation must be balanced with safety of samplers under storm & other difficult conditions

The Future…

Increased frequency of sampling Lower benchmarks TMDL and/or WQL (Section 6.2.4) Stricter “minimum BMPs” Benchmarks today…NELs tomorrow

The Future…

More rigorous sample Benchmarks becoming de facto limits SWPPP more wordy & less functional Proliferation of One Size Fits All

The Future…

Inspections still driven by complaints Ohio EPA inspection issues:

• Outfall locations
• Benchmark data
• Non-storm water discharges
• BMPs
• Contents of SWP3
• Employee training records

Compliance Strategies

 Make sure SWP3 fits the facility (update as needed)  Make sure to address Benchmark value exceedances through BMP’s and sampling  Housekeeping, Housekeeping Housekeeping  Boneyard (cover with tarps or put inside)  Check BMP’s after storm event and take ap  propriate measures

The Future…

Elevated benchmark data or lack of benchmark data will likely result in inspections Ohio EPA DSW does not appear to target facilities without permits Compliance is not getting easier in the future

Final Thoughts

Look at your benchmark data and decide if work is needed Be prepared to spend money as the fix may not be easy or cheap. Make sure your SWP3 is updated and all parts are being implemented

Final Thoughts

Return & creep of ONE SIZE FITS ALL!

• More EPA control
• Tighter TMDLs & increased cleanup
• f “impaired waters”

Will polluted runoff be interpreted as RCRA waste?

Final Thoughts

Compliance paper-driven, NOT storm water quality Intentions getting ahead of technical capabilities Landscaping vs. storm water control Keep your employers in compliance

Final Thoughts

“Menu” with a bite… “Tied-to” USEPA MSGPs Increased liability to enforcement The future promises to be BRUTAL…

Best Management Practices for SPCC

SPCC Overview

˃ Federal regulation under 40 CFR 112 ˃ S

pill Prevention Control and Countermeasure plan is required for:

 Facilities with aggregate aboveground oil storage >

1,320 gallons or underground storage > 42,000 gallons

♦Considers containers with capacity of at least 55 gallons ♦Includes storage containers, oil-filled operational

equipment, and oil-filled manufacturing equipment

 There is reasonable expectation of discharge into

navigable waters or adj oining shorelines

♦Includes indirect discharge via POTW or storm water

runoff conveyances

SPCC Contents

˃ S

PCC Plans must follow the sequence of 40 CFR 112; otherwise, a cross-reference table must be prepared [40 CFR 112.7]

 S

trongly recommend following EP A ’s sequence

˃ Addressing applicable requirements j ust

as important as non-applicable requirements

SPCC Plan Maintenance

˃ Requires review and update at least once

every 5 years, or any time there is a change at the facility that impacts the potential for oil discharge

 Keep an appendix review log

Oil Inventory

˃

Bulk S torage Containers

˃

Mobile/ Portable S torage Containers



Drums



Totes

˃

Oil-filled Operational Equipment



Transformers



Hydraulic equipment



Heat transfer systems

˃

Oil-filled Manufacturing Equipment



Flow-through process vessels



Reactors

˃

Oil-handling Areas



Bulk oil loading/ unloading operations

˃

“ OIL” includes petroleum oils, vegetable oils, animal fats, etc.

Must be 55 gallons

• r larger

Secondary Containment

˃ S

econdary containment requirements are separated into two categories: general and sized

˃ “ General” secondary containment must be designed

to prevent an offsite discharge of oil – 40 CFR 112.7(c)



Applies to all S PCC-regulated containers and oil-handling areas (e.g., oil inventory list), except Qualified OFOE

˃ “ S

ized” secondary containment must be designed to hold the entire capacity of the largest single container and sufficient freeboard to contain precipitation – 40 CFR 112.7(h)(1), 112.8(c)(2), 112.8/ 12(c)(11)



Applies only to loading/ unloading racks, bulk storage containers, and mobile/ portable containers

Common Containment Issues

˃ Insufficient secondary containment



Not aware of requirements



Not understanding “ General” vs. “ S ized”

˃ No means of monitoring interstitial spaces of double-

walled tanks

˃ S

ufficient freeboard not adequately addressed

˃ Issues with containment area



Containment valves left open



Cracks in containment walls



Oil present in containment area



S torm water in containment area



Containment area used as “ storage” for portable containers or other debris

Spill Prevention - Inspections

˃ Keep a cheat sheet or short list of routine

inspection requirements

˃ Regular inspections required for:

 Aboveground storage containers  Aboveground valves, piping

˃ Check for leaks and signs of container

damage

˃ Check containment areas for pollutant

accumulation, cracks, holes

 Ensure valves in containment are CLOS

ED

Spill Prevention - Inspections

˃ Inspect spill kits regularly to re-stock

sorbent materials that have been used

˃ Inspect loading/ unloading areas to ensure

are remains neat and free of obstacles

˃ Check perimeter security to ensure

lighting and security measures are adequate

˃ Maintain records of inspections

Good Housekeeping

˃ Keep secondary containment structures

free of debris and accumulated liquids

˃ Promptly clean up spills of all sizes

 Remove contaminated soil/ dust/ gravel

˃ LABEL all containers with the current

contents

 RCRA consideration for Used Oil containers

˃ S

tore containers in proper location (which must be identified in the S PCC)

Integrity Testing Requirements

˃ 40 CFR 112.8(c)(6) ˃ Test or inspect each aboveground container

for integrity on a regular schedule and whenever you make material repairs.

˃ Y

• u must determine, in accordance with

industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design.

Integrity Testing – Common Standards

˃ S

teel Tank Institute S tandard S P001,

S tandard for the Inspection of Aboveground S torage Tanks

 Typically shop-fabricated steel tanks storing

stable, flammable and combustible liquids at atmospheric pressure (e.g., diesel, gasoline, etc.)

˃ American Petroleum Institute S

tandard 653,

Tank Inspection, Repair, Alteration, and Reconstruction

 Typically for larger tanks built to API 650 or 12C

Integrity Testing – Common Concerns

˃ Not understanding the inspection

frequencies

 “ ACME Company follows the integrity testing

requirements of S TI S P001 for all AS Ts”

♦S

TI requires monthly and annual visual inspections

˃ Assuming the inspection requirements of

40 CFR 112.7(e) meets the integrity requirements

Spill Response

˃ S

pill response procedures can often get buried within the content of the plan

 Create a “ cheat sheet” for maj or and minor

spill response with key internal and external contact info

 Post in areas where oil is stored/ handled or

maintain an easily accessible copy

Critical Response Elements

˃ Proper communication ˃ Assessment of a situation



S mall spill (one you can safely clean up yourself)



Maj or spill (one you can’ t safely clean up yourself)

˃ Awareness of worker safety ˃ Proper use of spill kits & equipment ˃ Prompt notification/ reporting ˃ Recordkeeping and follow-up review (root-cause

analysis)

˃ Measures to prevent recurrence

Employee Training

˃ Required annually

 Include hands-on “ spill scenario” examples

˃ Keep records of all employee training

 Extends to contractors responsible for oil

handling or transfer

˃ Post signage in loading/ transfer areas

Key Takeaways for Compliance

˃ Understand the difference between sized

and general secondary containment requirements

˃ Practice good housekeping ˃ Understand integrity testing requirements ˃ Conduct (and keep records of!) routine

inspections

˃ Ensure employee familiarity with spill

response procedures

Classic BMPs

• Good Housekeeping
• Covered areas
• Containment
• Preventative Maintenance
• Management of Runoff and Run‐on
• Employee Training
• Inspections
• Monitoring
• Record Keeping

Engineered Solutions

• Detention and Retention Basins
• Surface water control
• Underground piping and culverts
• Stream diversion

Green Infrastructure

• Filter strips
• Vegetated swales
• Stream daylighting
• Rain gardens
• Rain barrels and cisterns
• Porous pavement
• Green roofs

Good Housekeeping

• Aw, Mom, do I have to?
• Clean up
• Organize
• Have a plan

Covered areas

• Keep contaminants and stormwater separate!
• Add a roof or tarp or shed.
• Provide a floor drain inside or a trench drain

around.

Containment

• Double‐walled tanks
• Concrete walls
• Earth berms

Preventative Maintenance

• Seal pavement
• Clear drains
• Keep dry
• Repair leaks
• Replace corroded parts
• Inspect

Management of Run‐on and Runoff

• Divert run‐on
• Collect runoff

Employee Training

• SPCC and SWP2 Plans
• Regular and Annual classes
• Signage

Detention and Retention Basins

Q = Flow Rate (cu.ft./sec.) V = Volume of basin (cu.ft.) T = Time (sec.)

Rainfall Intensity: inches/hour 25-year 24-hour storm

Rational Method

Q = CiA

Q = flow (cfs) C = coefficient of runoff (unitless) i = rainfall intensity (feet per second) A = area of watershed (square feet)

Storm Hydrograph

Manning’s Equation

Q = vA = (1.49AR2/3 √S)/n

Q = Flow Rate, (ft3/s) v = Velocity, (ft/s) A = Flow Area, (ft2) n = Manning’s Roughness Coefficient R = Hydraulic Radius, (ft) S = Channel Slope, (ft/ft)

Weir Equation

Q = 3.33LH2/3 Q = Flow Rate (cuft/sec) L = Breadth of the weir (ft) H = Height of water over weir (ft)

Green Infrastructure

• Permeable pavement
• Filter strips
• Bio‐infiltration
• Stream daylighting
• Stormwater harvesting and reuse
• Reuse for air scrubbers
• Green Roofs
• Rain gardens

Filter Strips

Vegetated Swale

Lick Run

Stormwater harvesting and reuse

Green Roof

Stormwater Reuse