EPA MSGP and California IGP Presentation

Industrial Stormwater Discharges - Regulatory Developments and

Technical Considerations

April 30, 2014

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Panel

Ryan Janoch, PE Mapistry

Wendy Manley, Esq. Wendel Rosen Black & Dean

Jarrod Yoder, PG, LSP Woodard & Curran

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Overview New California Industrial General

Permit Highlights Draft Multi-Sector General Permit

Highlights Case Study #1 - Naturally Occurring

Metals in Stormwater Discharges (MA) Case Study #2 - Infiltration to Eliminate

MSGP Requirements (MA) Case Study #3 - Source Tracking (CA) Regulatory Developments/Trends

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California Industrial General Permit

Adopted April 2014 Starts July 2015 Numeric Action Levels (NALs) Exceedance Response Actions (ERAs) Minimum BMPs Sampling requirements

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Draft Multi Sector General PermitWho is affected? Facilities operating within the 29 regulated industrial sectors listed in the 2008 MSGP and located where the EPA is the NPDES permitting authority. Streamlining the SWPPP and eliminating generic language Public accessibility to the SWPPP Reduced requirements for inspections Specific deadlines for taking corrective actions Electronic submission for the NOI, NOT, annual report and monitoring reports

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Draft Multi Sector General Permit

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Requirement for pavement wash water discharges to be treated by control measures Additional notification for discharges to Federal Superfund Sites Inclusion of airport deicing effluent limitation guideline Inclusion of saltwater benchmark values for metals and Additional clarity for technology based effluent limits

Case Study #1 - Naturally Occurring Metals in Stormwater Discharges

Project Location: Lakeville, MassachusettsIndustrial Activity: Concrete Ready MixMSGP Sector: EStormwater Contaminants: pH, TSS, metals including iron

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Client and their attorney requested assistance with an Administrative Consent Order with Penalty for multiple violations including stormwater management and illicit discharges to a natural resource.

Case Study #1 - Naturally Occurring Metals in Stormwater Discharges

Pollutant source evaluation Eliminated pollutant sources

but still had an iron problem Identified other discharges

during extended dry periods Hydrogeological evaluation Results

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Case Study #2 - Infiltration to Eliminate MSGP Requirements

Project Location: Everett, Massachusetts Industrial Activity: Metal Collection Facility MSGP Sector: N Stormwater Contaminants: metals, petroleum, PCBs,

solvents, TSS

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Client and their attorney requested assistance with a Settlement Agreement with the Conservation Law Foundation (CLF) relative to stormwater management

Settlement Agreement outlined a Performance Design Standard

Case Study #2 - Infiltration to Eliminate MSGP Requirements

Preconstruction activities identified historical contamination from metals scrapping/recylcing and coal gasification wastes

Hydrogeological studies were necessary An alternatives analysis was performed and a design

was prepared.

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The design was accepted by the CLF and construction activities were implemented

A soil management plan and Licensed Site Professional were needed to manage contaminated soil.

Case Study #2 - Infiltration to Eliminate MSGP Requirements

Benefits– Low maintenance– Moderate costs mostly due to managing contaminated

soil and the impacts to the overall design– No discharges to surface water and therefore no potential

for exceedances of water quality standards– No MSGP reporting requirements– Owner experienced more customer traffic after

improvements

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Case Study #3 - Copper Source Tracking

Suisun Bay Reserve Fleet Background on the Problem Investigation BMPs Next Steps Applications to new CA IGP

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Suisun Bay Reserve Fleet

aka “Mothball Fleet” or “Ghost Ships”

Benicia, CA Operated by US DOT

Maritime Administration (MARAD)

Retention and non-retention vessels (USCG, Navy, MARAD)

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Background

54 vessels Water quality concern (metals)

in discharges to Suisun Bay Site specific target

concentrations

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Exceedance

Mt. Washington November 2012 sampling

event Total Copper 3,000 ug/L Dissolved Copper 2,600 ug/L

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Historical Data

Target (ug/L)

Sampling Results (ug/L)

Mar 2011

Mar 2012

Oct 2012

Nov 2012

210 1,100 2,800 2,900 3,000

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Current BMPs

Sweeping (non-structural) Structural

–Coconut mats–Perlite wattle–Walnut shell wattle–Scupper screens

Focus–Solids–Petroleum–Metals

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Investigation

Previous potential sources: grease, lubricants

Screen using X-Ray Fluorescence (XRF)

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Results 19 surfaces screened non-detect to 10,000

ppm 75,000 ppm on deck

leading to scupper 840,000 ppm on

SALM

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Single Anchor Leg Mooring (SALM)

Underwater anchor for fueling operations

Mt. Washington was off-shore fuel tanker

SALM is 55’ by 140’ Mt. Washington is

100’ by 700’

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Remedial Options

Source Control - painting, shrink wrap

Treatment - BMPs Considerations Environment Cost Human health Applicability Feasibility Scraping schedule 21

Customized BMPs

Two media types for metal removal

Configurations–filter bags (top of

scupper)–filter socks (check dams)

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Application to CA IGP

Exceedance Response Action (ERA) Level 2 Technical Report

Pollutant source tracking

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Regulatory Developments Issues/Trends

California Industrial General Permit Lengthy Adoption Process Key Issues

–Numeric Effluent Limits–Group Monitoring–More prescriptive requirements

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Regulatory Developments Issues/Trends

Ongoing California Regulatory Issues Numeric Effluent Limits TMDLs

–Implementation–Permit Modification

Sector-specific permits Receiving Water Limitations

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Enforcement Agency Enforcement

–Non-filers

Citizen Enforcement–Multiple organizations–Industry targets

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Additional Resources Multi-Sector General Permit

–http://cfpub.epa.gov/npdes/stormwater/msgp.cfm–http://www.epa.gov/npdes/pubs/msgp2013_proposedshortfs.pdf–http://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf–http://www.epa.gov/npdes/pubs/msgp_monitoring_guide.pdf

California’s Industrial General Permit–http://

www.waterboards.ca.gov/water_issues/programs/stormwater/industrial.shtml–http://

www.waterboards.ca.gov/water_issues/programs/stormwater/indusfaq.shtml–http://

www.waterboards.ca.gov/water_issues/programs/stormwater/gen_indus.shtml#indus

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Questions

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[email protected]

[email protected]

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