Audit Preparedness for Municipalities & Industrial Facilities in Michigan Presented by: John McDonald, CHMM® Certified Stormwater Operator Manager, cleanWATER Division Arch Environmental Group National Pollutant Discharge Elimination System (NPDES) Stormwater Discharge Compliance
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National Pollutant Discharge Elimination System (NPDES) … - WWAdCon... · 2014-02-07 · Applicability •Discharges from stormwater runoff to surface waters that require a discharge
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Audit Preparedness for Municipalities
& Industrial Facilities in Michigan
Presented by:
John McDonald, CHMM®
Certified Stormwater Operator
Manager, cleanWATER Division
Arch Environmental Group
National Pollutant Discharge
Elimination System (NPDES)
Stormwater Discharge
Compliance
Applicability
• Discharges from stormwater runoff to surface waters that require a discharge permit include:
• Municipalities or other public entities located within urbanized areas through a separate storm sewer system (MS4)
• Industrial Facilities with specific Standard Industrial Classification (SIC) codes:
• Manufacturing (20- though 39-)
• Public Warehousing (422-)
• Transportation (40- though 45-)
• Mining (10- though 14-)
• Landfills
• Steam Electric Power Plants
• Recycling Facilities
• Waste Water Treatment
• Hazardous Waste Storage or Treatment
• Other industries found to be significant contributors of pollutants
Enforcement
• Although these rules are federally mandated and regulated by the USEPA under Section 402 of the Clean Water Act, in Michigan the Department of Environmental Quality (MDEQ) is responsible for enforcement under part 31 of Public Act 451 NREPA
• Fines and penalties for non-compliance can include up to $25,000 per day of violation
• Criminal penalties can be as high as 2 years imprisonment per violation
Excepted Discharges
• Discharges to surface waters from the following sources are not regulated: • Water line flushing
• Landscape irrigation
• Diverted stream flows
• Rising groundwater
• Uncontaminated groundwater infiltration
• Pumped groundwater (except from cleanups)
• Potable water
• Foundation drains
• Air conditioning condensate
• Springs
• Water from crawlspace pumps
• Footing drains
• Water from non-commercial car washing
• Flows from riparian lands or wetlands
• Residential swimming pool water (if backwash is treated)
• Residual street wash waters
Preparing for an Audit
• Have a good understanding of your Stormwater Management Program Plan (SWMP) or Stormwater Pollution Prevention Plan (SWPPP)
• Make sure that you have supporting documentation for each activity (BMP) outlined in your plan
• Review process for measurement of goals listed in the plan
• Tracking of progress toward completion of scheduled BMPs
Supporting Documentation
• It is very important to carefully and accurately document all of your compliance actions
• Each BMP and measurable goal should also include a description of the documentation you plan to use as verification
• As with many government regulations, if you do not have documentation backing up your claims, the action did not occur
INDUSTRIAL SITE PERMITS
Industrial Site Stormwater Discharge
Permit Options
• General Permit w/o Monitoring
• General Permit with Monitoring
• Individual Permit
• Consent Order
• No Exposure Certification
MDEQ Audit Expectations
• In most cases the MDEQ will NOT provide
advance notice.
• Be prepared to provide tours your facilities.
• Be prepared to interview applicable
employees
• Maintain all of the required documentation in
a ready, available, and organized manner.
Stormwater Pollution Prevention Plan (SWPPP)
• SWPPPs are required and must include each of the following: • Site Maps & Diagrams
• Evaluation of significant materials and exposure
• Identification and location of discharge points
• List of any spills and corrective actions
• Total Maximum Daily Load (TMDL) Assessment (if applicable)
• Routine inspection, repair, and maintenance schedule
• Policies and procedures for good housekeeping
• Bi-annual comprehensive site inspections
• Bi-weekly routine inspection reports
• Policies and procedures for materials handling and storage
• Identification of areas with erosion issues
• Employee Training
• Identification of significant materials expected to still present in discharges following implementation of structural and non-structural controls
Indoor & Outdoor Inspection
• Loading, unloading, & materials handling areas
• Equipment & material storage areas
• Secondary containment systems
• Outdoor processing areas
• Air emission controls and stacks
• Maintenance areas
• Point source discharges
• Internal floor drains
• Other areas where stormwater runoff could contact
significant pollutants
Documentation Review
• Copy of SWPPP
• Certificate of Coverage (COC) or Consent Agreement