February 11, 2011

Industrial Stormwater Permit and Annual Report PreparationInstructor: George Caamano

Lecture Outline

• SWPPP General Program Requirements• Annual Reporting Forms• Sampling/ Monitoring

Stormwater management can be grouped into three distinct sections, one administrative at a facility level, one, records at an agency level, another is sampling to access your successes. This outline has three distinct presentations that address each of these topic areas.

Run on is your problem!

The 5 keys to establishing a functional and effective stormwater program:nning & Organization

• Assessment• BMP• Implementation• Evaluation and Monitoring

As an administrator, ensuring these functions are complete, thorough and verifiable is paramount to achieving compliance

Planning and OrganizationForm Pollution Prevention

Team

Review Other Plans

The formation of a team to evaluate your facility and perform inspections and complete corrective actions is critical to a program’s success.

In development stages of preparing the SWPPP, it is recommended that you study other facility plans and take from them ideas, BMP and other helpful sections.

Develop site mapIdentify pollution sources

Inventory of chemicals and materialsList significant spills and leaks

Identify non-stormwater dischargesAssess pollutant potential/ risks

The next series of slides address the gathering of information required under the General Permit. Before we can correct and reduce/ eliminate stormwater pollution, we need to know how much of it we have, what are the loads to the stormwater and what types of contaminants are in our water. Only then can we improve discharge.

The Assessment Phase addresses the following:

The site map is vital to a functioning SWPPP. Specifically, it helps identify these key elements:

•How many outfalls•Which industrial areas drain to each outfall (drainage pattern)•What is the GPM for a 1” storm per outfall•What is the TMDL per outfall (5, 25 year storm)•What structural and non-structural measures are taken per outfall

The map is the easiest means to convey this information and is a simple way to grasp

As simple as this may sound, it may be difficult to find the source of stormwater pollution.

The purpose of laboratory data (your monitoring program) is to provide you with hard facts as to what is in your water.

It is up to you to be clever and resourceful to follow the contaminants upstream to their source. Once you have done this- write it down and do something about it.

Obviously we will list all chemicals and materials that could generate pollution during a rain event on our SWPPP.

Hazmat items should come right from your Contingency / Business Plan. Non-hazardous materials in quantities that can affect your discharge must be listed too.

Each item listed must be addressed on your SWPPP as a potential pollution source (if it is) and measures taken to contain the materials as well.

There are two types of best management practices that need to be included in your SWPPP;

•Non-Structural BMP- those that are procedural or policy•Structural BMP- physical things that you can touch

An easy means to cover your BMP requirements is to select an activity and site specific BMP you will use to ensure contaminants are not released. The General Permit provides Table “B” as an example.

Now that you have assessed the various contaminants at your site, found them on a map, identified the sources of hazardous materials and potential pollution sources and written them all into a plan, now what?

•Conduct training to ensure that all facility personnel know and understand that stormwater pollution is a serious problem and that they need to be vigilant

•Implement BMP the structural and non-structural BMP

•Record and Monitor progress (to be discussed in detail)

Every SWPPP has a monitoring component. It is essential that you perform the following:

Note: THIS IS THE CRITICAL PART OF ANY SWPPP!

•Conduct annual site evaluation•Review monitoring information•Evaluate BMPs•Review and revise SWPPP

If you do not make small incremental changes your plan will fail.

There are 5 forms and an annual report that must be turned in by June 30th of every year. These forms track your progress and fulfill the State’s requirement under their agreement with the EPA.

If used correctly, they are helpful and provide a simple method of tracking progress. If used for evil, they are a waste of time and a means for you to commit perjury.

This section covers the 5 forms and annual report.

Annual Report

The annual report is only a few pages long and asks about 30 questions. All of them are easy to answer- if you have been doing your monthly observations and keeping notes as you were instructed. The purpose of the annual report is to provide the State with a legal document that says you have complied with the NOI as you said you would.

You can find the current 2010-2011 version here:

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

Form 1- Lab

Every year you must submit two lab reports, one, the first qualifying storm event, and the second, any subsequent qualifying event. Form 1 helps you track your progress.

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

The form has time of sample, time of discharge, time storm began- all to determine if the event was qualifying.

It has test methods, sampled by whom, tested by whom, etc.

Many companies provide sampling kits

These are used to document any unauthorized or authorized stormwater discharged during the year.

Specifically, did anything leave your property with or without your permission. If it did, then you document what happened and why and what you will do to prevent it in the future. If it didn’t, then say so.

The backbone of the SWPPP is the use of the monthly inspection. During the wet season months, you need to audit your site and ensure that your BMP are working effectively, If not, then you make corrections. This form keeps track of those inspections and corrective actions.

Form 5 is used to document if all the BMP you thought would work did. If you had areas that needed improvements, BMP that were not effective or you needed new BMP for the coming year, this is the form you use.

In essence- you document failure.

Be careful what you write because it can be used against you!

This is the most difficult part of the SWPPP facility tasks. Collecting samples, in a legal manner and interpreting the results is sometimes beyond the means of many.

This module will cover basic procedures in sample collection and provides guidance in fulfilling your NOI requirements

SAMPLINGQUALIFIED

• A sample must be taken within

the first 60min of discharge.• 2 qualified samples are

required annually• Samples are sent to state

certified lab.• Started discharging during

operating hours• Three days of dry weather prior

to rain storm

NON-QUALIFIED

• A sample that are taken 60min after discharge.

• Samples are sent to Todd Peterson at Remedy Environmental

• Started discharge during non-operating hours

Sampling Kit

Kits are purchase from retailer, supplied by lab or parts collected at home depot. :O)

SAMPLING KIT• Instructions• Chain of Custody• Glass Jar with

bubble wrap bag• Plastic Jar• Tin• Ziploc

Taking a Sample

There are many means to collect water. Each one has it’s advantages and problems. Inadvertently taking a skewed sample may hurt.

Sampling

Pour all contents into collectionjars. Be careful if a preservative

isused (strong acid).

DO NOT ADD WATER or FILTER OUT SEDIMENT/DIRT

Sampling

CHAIN OF CUSTODY

BE CAREFUL• Legal Document• Make a copy• Outfall should

always have the same name