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Stormwater Management Program Updates SWMP Updates SWIM Coalition June 8, 2017

Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

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Page 1: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Stormwater Management Program Updates

SWMP Updates – SWIM CoalitionJune 8, 2017

Page 2: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Agenda

2

1. Introductions

2. Legal Authority: Local Law & Rules

3. Stormwater Management Program (SWMP) Development

a. SWMP Plan Deliverable Timeline

b. Pollution Prevention/Good Housekeeping (PPGH) for Municipal Operations and Facilities

i. Municipal Facilities and Operations Inventory

ii. Municipal self-assessment procedures and initial assessments (started 03/17)

iii. Employee Training Program

iv. Runoff Reduction/GI Feasibility for Upgrades

c. Industrial and Commercial Stormwater Sources

i. Facility Inventory

ii. Legal Authority

iii. Unpermitted Facility Inspection

iv. MSGP Facility Inspection

v. MSGP Facility Prioritization

4. Questions

Page 3: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Legal Authority: Local Law & Rules

New York City MS4 Legislation

Intro 1346-2016 introduced by City Council on November 16, 2016

Public hearing held by Environmental Protection Committee on December

13, 2016

Intro 1346-2016, Version A approved by Environmental Protection

Committee on May 8, 2017

Intro 1346-2016, Version A passed by City Council on May 10, 2017

Local law signed by the Mayor on May 30, 2017

3

Page 4: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Legal Authority: Local Law & Rules

New York City MS4 Legislation

The version passed by the City Council and signed by the Mayor includes

several revisions from the original bill:

o New provision requiring consideration of the feasibility of green

infrastructure for certain capital projects Citywide

o Language clarifying that stop work orders apply to the work being done

in violation of applicable requirements

o Correction of a drafting error identified at the December 2016 hearing,

to clarify who is qualified to inspect post-construction stormwater

controls

o Changes to the effective date provisions to specify the range in which

DEP is allowed to set the effective dates for each program by rule

o A number of non-substantive technical edits and clarifications

4

Page 5: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Legal Authority: Local Law & Rules

Rulemaking: The local law authorizes agencies to make rules immediately

Illicit Discharge Detection & Elimination

The City is working on revisions to its existing IDDE rules to implement

provisions in the local law relating to illicit discharges to the MS4

The City expects to publish those draft revisions for public comment in

summer 2017, and to proceed with the CAPA process

The rulemaking will proceed concurrently with SWMP development;

program implementation not contingent on SWMP approval

Construction/Post-Construction and Commercial/Industrial Programs

Rules for these programs will reflect program elements currently being

developed for the SWMP

The City expects to propose draft rules in spring 2018, when these

programs will be more fully developed

The rules will be finalized in order to allow implementation of these

programs after the SWMP is approved

5

Page 6: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

6

SWMP Plan Deliverable Timeline

Task Duration Start Finish

Public Review 2 months April 2 June 1

DEP coordinates final edits 2 months June 1 July 31

Submit to DEC - August 1, 2018

Topics Stakeholder Date

Draft Work Plan to

determine Floatables

loading rate

SAG Sept 2017

TBD SAG Nov/Dec 2017

Public Comments on

SWMP DraftSAG

Spring/Summer

2018

Public Meetings Tentatively Scheduled

Page 7: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Stormwater Management Program (SWMP)

1. Introduction

2. Program Overview

3. Public Education and Outreach

4. Public Involvement /

Participation

5. Mapping

6. Illicit Discharge Detection and

Elimination (IDDE)

7. Construction Site Stormwater

Run-off Control

8. Post-Construction Stormwater

Management

9. Pollution Prevention / Good

Housekeeping for Municipal

Operations and Facilities

10. Industrial and Commercial

Stormwater Sources

11. Control of Floatable and

Settable Trash and Debris

12. Monitoring and Assessment of

Controls

13. Reliance on Third Parties

14. Recordkeeping

15. Annual Reporting and

Certification

SWMP Chapters

10

Page 8: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Pollution Prevention/Good Housekeeping Program Status

Elements covered under Pollution Prevention/Good Housekeeping (PPGH) for

Municipal Operations and Facilities:

Elements completed to date:

Municipal Facilities and Operations Inventory

Municipal Facility Prioritization Protocol and Preliminary Prioritization

Stormwater Control Measures for PPGH

Elements in working progress:

Municipal self-assessment procedures and initial assessments (started 03/17)

Employee Training Program

Third-Party Contracted Services Requirements

Runoff Reduction/GI Feasibility for Upgrades

PPGH Measurable Goals

8

Page 9: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

PP/GH Key Elements

9

MS4 SPDES Permit

Compliance for PP/GH

Inventory/ Prioritize

Facilities & Operations

Third Party Notifications

Pre-Assessment

Activities

GI Evaluation

Assessment ProceduresMSGP

Coverage

Post-Assessment

Action Planning

Annual Reporting

Requirements

Train, Implement, and Report Progress

Page 10: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

PP/GH Facilities/Onsite Operations

10PP/GH Program Requirements

Vehicle/Equipment Operations Vehicle/Equipment Maintenance and Repair

Vehicle/Equipment Cleaning

Vehicle/Equipment Fueling

Truck Bed Management

Vehicle/Equipment Storage

Other Types of Facilities Golf Courses

Animal Recreational Facilities/Stables

Swimming Pools

Marine Operations

Material Storage Facilities General Outdoor Storage

Above-Ground Storage Tanks

Underground Storage Tanks

Drum Storage and Management

Material Stockpiles

Waste Management Facilities Waste Transfer Stations

Landfills

Shooting Ranges

Drum Storage & Management

Salt Storage & Management

Page 11: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

PP/GH Off-site Operations

11PP/GH Program Requirements

Stormwater Collection System Maintenance

Catch basin/inlet cleaning and Repair

Storm sewer/underground facility cleaning

and repair

Ditch/open channel cleaning and repair

Green infrastructure/open facility

maintenance

Hydrologic habitat maintenance

Paved Surface Maintenance

Pavement Cleaning

Winter Pavement maintenance

Pavement/Sidewalk resurfacing and repair

Spill prevention and response

Bridge/elevated structure maintenance

Landscaping and Open Space Maintenance

Herbicide/pesticide/fertilizer application

Landscape/ground care

Turf management

Building Maintenance and Repair

Building Repair and Remodeling

Painting

Solid Waste Collection

Pavement/Sidewalk Resurfacing and Repair

Catch Basin/Inlet Cleaning and Repair

Page 12: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

NYC MS4 Municipal Facilities

12

Page 13: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

PP/GH Site Prioritization Preliminary Results

13

Agency Number of Sites

Low

Priority

Medium

Priority

High

Priority

DCAS 5 2 3 0

DEP 131 16 115 0

DOC 2 0 0 2

DOE 175 18 157 0

DOT 78 55 21 2

DPR 269 177 92 0

DSNY 100 47 49 4

FDNY 77 36 40 1

NYPD 68 22 44 2

Grand Total 905 373 521 11

Page 14: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Overview of PP/GH Self-Assessment Steps

14

Page 15: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Key Participants in PP/GH Program

15

Key Participants

Prepare for

Assessments

Perform

Assessment

Participate in

Assessment

Perform

SCMs Report Progress

NYCDEP Liaison P Initial

Agency PP/GH

LiaisonP P

PP/GH Contractor P Initial

Agency Assessor(s) P Subsequent Initial P

Facility Managers P P P

Operation Supervisors P P P

Staff P

PP/GH Program Requirements

Page 16: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

PP/GH Assessments Schedule

High-priority and Pilot site assessments through summer 2017

Potential modifications to the assessment process completed by fall 2017

Remaining site assessments late 2017 through 2021, with multiple teams

operating in parallel

Date: 3/1

3

3/2

0

3/2

7

4/3

4/1

0

4/1

7

4/2

4

5/1

5/8

5/1

5

5/2

2

5/2

9

6/5

6/1

2

6/1

9

6/2

6

7/3

7/1

0

7/1

7

7/2

4

7/3

1

8/7

8/1

4

8/2

1

8/2

8

9/4

9/1

1

9/1

8

9/2

5

10

/1

11

/1

12

/1

2018 2019 2020 2021High and Pilot Site AssessmentsDOC DSNY DOTFDNYNYPDDPRDOEDCASDEP

Modification of Process for AssessmentsLow and Med Priority Sites - Assessments DSNYDOTDPRDOEFDNYDCASDEPNYPD

Agency Kick-Off Meeting for High and Pilot SitesHigh Priority Site Assessments

Pilot Site AssessmentsLow and Medium Prority Site Assessments

20

Page 17: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Proposed Future PP/GH Assessments Frequencies

Initial Assessments, supported by PPGH Contractor

o High-priority facilities: By August 1, 2018

o Low-and Medium-priority facilities: By August 1, 2021 (Proposed)

Follow-up Assessments, by Agency assessors (Proposed)

o High-priority facilities: every 2 years

o Medium-priority facilities: every 5 years

o Low-priority facilities: every 7 years

o Note: effective SCMs may lower priority / assessment frequency

Progress reporting: Annually

17PP/GH Program Requirements

Page 18: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

PP/GH Training Program

Training program is a specific requirement of the MS4 Permit.

Objective: To ensure consistent implementation & tracking of PPGH permit

requirements.

Program options include:

Classroom training of site assessors regarding their role and responsibilities

o Agencies need to identify individuals responsible for site assessments

On-line training of municipal staff responsible for the proper implementation and

tracking of SCMs in municipal operations.

Optional “Train the Trainer” classroom training for facility managers or

operational supervisors of high-priority facilities. Trainers to provide on-going

messaging to their staff to ensure SCM implementation and tracking.

Program success will be measured by actual use and tracking (through

self-assessments) of the SCMs by employees in day to day operations.

22

Page 19: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Third-Party Certification and PP/GH Applicability Matrix

Part IV.G.1.h of the Permit requires any third-party entities performing

municipal operations as contracted services to meet permit requirements as

they apply to the activity performed

Part IV.K of the Permit requires the City to ensure, through signed

certification statement, contract or agreement, that third parties performing

any activities to develop or implement the SWMP will comply with permit

requirements applicable to the work performed by the third party

DEP and the Law Department have provided model certification statements

and other guidance to the interagency group to assist in compliance with

these provisions

19

Page 20: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Runoff Reduction/GI Feasibility for Upgrades

20

Runoff Reduction and Green Infrastructure Evaluation During Planned Municipal Upgrades-Simple version provided below.

Project Funding

Environmental Analysis

Hydrogeological Analysis

Expense

Does Post-Construction Generate Runoff and POCs?

PerformFeasibility Analysis

No

STOP - No

Evaluation Warranted

STOP – No Evaluation Warranted

Yes

Physical Site Conditions

If technical feasibility analysis presents no constraints

Yes Implement G.I.

No

Is implementation of G.I. Cost-Effective?

STOP (Project Not Feasible)

Capital>2MM

Public Buildings

Right of Way

This process will inform the following annual reporting items:1. Number of projects evaluated for

G.I and runoff reduction.2. Number of G.I. runoff reduction

projects completed.

Because each

project may

be different as

to which step

is more or

less labor

intensive,

agencies can

have the

flexibility to

implement

these steps in

the order they

feel is more

convenient.

Page 21: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

MSGP Programs for Municipal Operations & Facilities

s

21

Part IV.G.1.i.

Agencies must choose the type of coverage:

o NYSDEC - MSGP

o NYCDEP - MS4

Current inventory includes 4 MSGP sites:

o 3 DOT

o 1 DSNY

o Assessments may identify additional sites subject to MSGP

If NYSDEC - MSGP: Continue reporting as done currently – no other

requirements

If NYCDEP - MS4: Also subject to PPGH reporting requirements

Agencies need to decide by August 1st, 2018 the type of coverage:

Refer to handout titled, MSGP or MS4 Permit Coverage Election

Page 22: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Pollution Prevention and Good Housekeeping

22

Next Steps:

Continue assessments of high priority and pilot sites

Revise protocols based on assessment findings

Continue developing training program. Will circulate training plan among sub-

team for review and comment

Page 23: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Industrial/Commercial

Industrial/Commercial

Stormwater Sources

23

Page 24: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

2015* 2016 2017 2018 2019 2020

Aug 1, 2015

MS4 Permit

Effective Date

SWMP Plan Development

August 1, 2018

Submit SWMP plan to DECSection IV.H requires City to

develop inspection programs for

unpermitted and MSGP sites

Aug 1, 2020

MS4 Permit

Renewal

Legal Authority

Established

* - Calendar years

Interim Reports Due

August 1, 2016 and 2017

SWMP Implementation

Industrial/Commercial Timeline

Unpermitted industrial and commercial sites inspection program

plan due August 1, 2018

MSGP inspection program plan

due August 1, 2018

Facility inspections expected to

begin 45 days after SWMP approval

DEC

APPROVAL

6

Rulemaking

Expected procurement for third-party contractor

to implement inspection program

Page 25: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Inventory of Industrial/Commercial Facilities

25

MS4 Permit – Part H.1.a.ii

• DEP must prepare and maintain an inventory of all industrial and commercial

sites/sources within its jurisdiction (regardless of ownership), within three years of

2015, that could discharge POCs in stormwater to the MS4

Industrial Commercial Inventory:

• Industrial Sites/Sources

o 40 CFR § 122.26(b)(14)(i-ix and xi)

o Facilities subject to Section 313 of Title III of the Superfund Amendments and

Reauthorization Act (SARA)

o Hazardous waste treatment, disposal, storage and recovery facilities

o NYCDEP Industrial Pretreatment Program (IPP)

• Other industrial or commercial sites/sources tributary to an impaired water that

generates significant amount of POCs for which the water body is impaired

• Other industrial or commercial sites/sources that DEP determines may contribute a

significant pollutant load to the MS4

Page 26: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Unpermitted I/C Facility Inspection Screening

34

Schedule inspections based on findings of desktop/web-based evaluations performed by DEP to prepare inventory:

Locate site with DoITT Land Use database:

• Drains to MS4

• Land use category

Review aerial/street view images of site:

• Presence/significance of an “industrial activity”

• Evidence of “stormwater exposure”

ID businesses with incorrect SIC Codes/classifications

Schedule per “likelihood” of MSGP applicability

Incorporate work efficiency into schedule (proximity, travel time, seasonal, etc.)

Page 27: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

27

Examples of No Further Analysis

27

Stained glass imaging company lists SIC code under Sector E (e.g., glass, clay, cement,

concrete, and gypsum products), though there is no potential for business to impact stormwater.

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28

Example of Further Analysis

28

Facility which also has SIC code listed under Sector E with high potential

to impact stormwater.

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29

Industrial Commercial Map

29

Facility Inventory

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30

Staten Island Industrial Commercial Map

30

Page 31: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

SWMP Plan Objectives for Industrial/Commercial Businesses

Control stormwater pollution from industrial and commercial businesses

potentially engaged in “industrial activities,” as defined under EPA and DEC

regulations.

For each candidate business:

o Identify and inventory

o Inspect and assess

o Refer findings to DEC

27

BMP BMP Description

Schedule (Yrs.)Responsible

Position1 2 3 4 510.1 Provide an industrial

and commercial pollution control program

Inventory and assess businesses conducting “industrial activities” and/or determined to be significant sources of stormwater pollution.

X X X X X

10.2 Provide for staff training

Train staff/third-parties responsible for assessing inventoried businesses.

X

Educate and Train

Page 32: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Next Steps

The SWMP will be submitted on August 1, 2018 to

NYSDEC

Once the SWMP is approved, inspections will begin

immediately

32

Page 33: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

SPDES Industrial Stormwater Facility Inspection Program

33

Initial inventory: Business categories

subject to industrial stormwater

permitting

Web-based inventory screening

o Potentially Drains to MS4

o Current permitting status

Type of inspection

o None (Individual permit/NOT)

o Complaint-based

o Unpermitted facility

o MSGP permit

No Further

Action

Required by

DEP

Prioritize for

MSGP

Inspections

No

Individual Permit or

NOT Yes

Approved

NOI for MSGP

No

Yes

Schedule for

Unpermitted I/C

Inspections

A B

Determine DEC

SPDES Permit

Status

No Exposure

Certification

No

Yes

Inventory

Businesses

with MSGP SIC

Codes

Wrong SIC/

not draining to MS4Definitive

Potential

Complaint

Based

Inspections

Per Criteria in 40 CFR Part 122.26(b)(14)(i) through (ix) and (xi), using commercially-available databases

Page 34: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Industrial/Commercial Stormwater Sources

34

DEP anticipates a large number of facilities

that will need to be assessed for SPDES

DEP needs to determine how many

facilities will be part of the regular

inspection cycle, and commensurate

staffing needs

DEP has drafted an RFP to inspect

permitted and unpermitted facilities

(Anticipate advertisement June 2017)

Contractor will conduct analysis for staffing

needs once inspection program has been

fully implemented

Contractor will develop and implement

training program for DEP staff

Contractor will perform a study to

determine if any other sectors not currently

covered under MSGP need to be permitted

for next permit cycle

Initial facility inspections

by third-party contractor

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35

NYSDEC MSGP Sectors

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36

Example NYSDEC MSGP SIC Codes

Page 37: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Unpermitted I/C Facility Inspection Program

37

Notify business – one time only

Assemble background

On-site inspections

o Characterize SPDES applicability

o Characterize exposure

Post-inspection reporting

o Notify business of findings

o Notify DEC of findings

o Revise inventory

Pre-Inspection Activities• Notify business of inspection• Review available data about business• Assemble inspection equipment,

information

Quarterly Pre-Planning• Maintain I/C inventory and priorities• Quarterly identification of businesses

to inspect per priorities

On-Site Inspection Procedures• Introductions• Facility walkthrough• Wrap-up Meeting to review findings

Post-Inspection Activities• Complete inspection report • Notify facility of findings• Log findings in database• Update inventory, prioritization• Refer findings to DEC for SPDES

coverage determination

Page 38: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

What is a SWPPP?

Stormwater Pollution Prevention Plan (SWPPP)

A site specific document which identifies potential sources of stormwater

pollution and control measures to eliminate impacts to stormwater runoff.

Elements of a SWPPP:

General site description, facility information

Site map, including outfalls, drainage areas, and direction of stormwater

flow

Potential sources of pollution

History of spills and releases

Best management practices to control impacts to runoff (structural & non-

structural)

Permit-Required Controls (inspection procedures, spill response plans, etc.)

Monitoring and Sampling Data

38

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39

Example SWPPP Table of Contents

Page 40: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Examples of Potential MSGP Facilities

40

Primary Industrial Activity: Water Transportation

Potential sector this facility might be subject to: Sector Q: Water Transportation

Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Fueling

• Engine maintenance/repair

• Vessel maintenance/repair, pressure washing

• Painting/Sanding/Blasting

• Welding, Metal fabrication

• Loading/unloading areas

• Locations used for the treatment, storage or disposal of wastes

• Liquid storage tanks/areas (e.g., paint, solvents, resins)

• Material storage areas (e.g., blasting media, aluminum, steel, scrap iron)

Page 41: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Examples of Potential MSGP Facilities

41

Primary Industrial Activity: Storage and Recycling

Potential sector this facility might be subject to: Sector N: Scrap Recycling

Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Locations of haul and access roads

• Scrap and waste material storage areas

• Outdoor scrap and waste processing equipment

• Areas where materials are sorted, transferred, stockpiled

• Containment areas

Page 42: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Examples of Potential MSGP Facilities

42

Primary Industrial Activity: Timber

Potential sector this facility might be subject to: Sector A: Timber Products

Typical parameters that require monitoring under this sector: TSS, COD, Zinc, TN, Phosphorous, Arsenic, Chromium, Copper

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Processing areas

• Treatment chemical storage areas

• Treated wood and residue storage areas

• Wet decking areas

• Dry decking areas

• Untreated wood and residue storage areas

• Treatment equipment storage areas

Page 43: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Examples of Potential MSGP Facilities

43

Primary Industrial Activity: Land Transportation

Potential sector this facility might be subject to: Sector P: Land Transportation and/or Warehousing

Typical parameters that require monitoring under this sector: Oil and Grease, COD, BTEX

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Fueling stations

• Vehicle/equipment maintenance or cleaning areas

• Storage areas for vehicle/equipment with actual or potential fluid leaks

• Loading/unloading areas

• Areas where treatment, storage or disposal of wastes occur; liquid storage tanks

• Processing areas, storage areas, and all monitoring areas

Page 44: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Examples of Potential MSGP Facilities

44

Primary Industrial Activity: Waste Recycling

Potential sector this facility might be subject to: Sector N: Scrap Recycling

Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Locations of haul and access roads

• Scrap and waste material storage areas

• Outdoor scrap and waste processing equipment

• Areas where materials are sorted, transferred, stockpiled

• Containment areas

Page 45: Stormwater Management Program Updates - New York City ·  · 2017-07-07Stormwater Management Program Updates SWMP Updates –SWIM Coalition ... Municipal Facilities and Operations

Examples of Potential MSGP Facilities

45

Primary Industrial Activity: Glass, Clay, Cement

Potential sector this facility might be subject to: Sector E: Glass, Clay, Cement, Concrete, and Gypsum Products

Typical parameters that require monitoring under this sector: Aluminum, TSS, pH, Iron

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Bag house or other dust control device

• Recycle/sedimentation pond, clarifier or other device used for the treatment of process wastewater and the areas that drain to the treatment device

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Examples of Potential MSGP Facilities

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Primary Industrial Activity: Auto Salvage Yard

Potential sector this facility might be subject to: Sector M: Auto Salvage Yard

Typical parameters that require monitoring under this sector: TSS, Oil & Grease, Iron, Aluminum, Lead, BTEX

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Vehicle storage areas

• Dismantling areas

• Parts storage areas (e.g., engine blocks, tires, hub caps, batteries, hoods, mufflers)

• Liquid storage lands and drums for fuel and other fluids

• Location of each discharge and monitoring point

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Examples of Potential MSGP Facilities

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Primary Industrial Activity: Scrap and Waste Materials

Potential sector this facility might be subject to: Sector N: Scrap Recycling

Typical parameters that require monitoring under this sector: TSS, COD, Oil & Grease, Aluminum, Cadmium, Copper, Chromium, Iron, Lead, Zinc

Site Specific SWPPP should identify locations where the following activities or sources may be exposed to precipitation/surface runoff:

• Locations of haul and access roads

• Scrap and waste material storage areas

• Outdoor scrap and waste processing equipment

• Areas where materials are sorted, transferred, stockpiled

• Containment areas

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Examples of Industrial Activities and Potential Risk

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Higher Risk for Stormwater Impact: Open Vehicle Storage (Outside with Fluids Not Drained) Lower Risk for Stormwater Impact: Covered Vehicle Storage

Vehicle/Equipment Storage

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Examples of Industrial Activities and Potential Risk

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Proper StorageHigher Risk for Stormwater Impact: Drums stored without spill containment

Louisville Metropolitan Sewer District

Lower Risk for Stormwater Impact: Drums stored indoors on spill pallets

Drum Storage/Management

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Examples of Industrial Activities and Potential Risk

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Temporary Covered StorageHamilton County Public Health Department: Higher Risk for Stormwater Impact: Uncovered

salt pileLower Risk for Stormwater Impact: Covered salt pile

Material Stockpiles

Example: Salt Pile

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Improper vs. Proper Spill Response

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Higher Risk for Stormwater Impact: Unattended spill

Lower Risk for Stormwater Impact: Quick spill

response

Spill Response

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Examples of Industrial Activities and Potential Risk

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Waste Liquid Disposal Restrictions

Hamilton County Public Health

DepartmentHigher Risk for Stormwater Impact: Leaking dumpster Lower Risk for Stormwater Impact: Well-managed dumpster

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Waste Management and Disposal

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SPDES Industrial Stormwater MSGP Facility Inspection SOP

(currently 21 MSGP sites)

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Pre-inspection activities

o Maintain inventory/priorities/inspection schedule

o Assemble/assess background information

On-site inspection procedures

o Records review

o Walk-through inspection

o Characterize permit compliance

Post-inspection reporting

o Use DEC/BWT inspection criteria

o Notify business of findings

o Notify DEC of findings

o Revise inventory/priorities

Pre-Inspection Activities

• Review available data about business• Prioritization findings

• Latest facility MSGP data from DEC• 5-year violation record

• Assemble inspection equipment

Quarterly Pre-Planning

• Maintain I/C inventory, priorities

• Quarterly identification of businesses to inspect per priorities

• Request facility MSGP data from DEC

On-Site Inspection Procedures

• Introductions• On-Site Records Review

• SWPPP• Self-Inspection/Monitoring Reports

• Facility Walkthrough

• Confirm Facility Drainage to MS4• Wrap-up meeting to review findings

Post-Inspection Activities

• Complete Inspection Report• Notify facility of findings

• Log Inspection findings in database• Update I/C inventory, prioritization

• Notify DEC (as necessary)

MSGP Facility Inspection Program

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Prioritize Facilities per Potential Water

Quality Impact

A

Potential WQ

Impact?

High/ Very High

Medium

Obtain MSGP Data from DEC

Low/ Very LowHigh Priority

for InspectionLow Priority

for Inspection

Medium Priority for Inspection

Obtain MSGP data from DEC

Prioritize per potential WQ Impacts:

o Use DEC and BWT criteria

• SWPPP adequacy

• POC type/quantity/exposure

• Observed housekeeping

• Proximity to impaired water

• Violation history

Revise priority for next scheduled inspection based on inspection findings.

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Prioritize MSGP Facilities/Sites for Inspection

MSGP Facility Inspection Program

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Initial Prioritization of MSGP Sites

NYSDEC provided prioritization for 18 MSGP sites within MS4

MSGP Inspection Frequency

Once a site receives a permit, it will be ranked and inspected at the following

frequency:

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Initial DEC’s Prioritization Rating *Number of MSGP Sites

High 2

Medium 12

Low 4

Facility/Activity Priority Inspection Frequency

High Annual

Medium 3 Years

Low 5 Years

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I/C Draft Facility-Specific Information Database Framework

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I/C Draft Facility-Specific Information Database Framework

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Industrial/Commercial Inspection Staff Training

Syllabus

o MSGP applicability requirements:

• SIC Codes / SARA Title III/HazMat Facilities

• Industrial activities defined

• No Exposure Certification Criteria

o Development/Maintenance/Prioritization of City I/C Inventory

o MSGP Compliance Requirements:

• Notice of Intent/Modification/Termination

• SWPPPs (e.g., site map, BMPs, SCMs, O&M)

• Self-monitoring (e.g., annual inspections, quarterly visual monitoring, annual dry weather monitoring, impaired waterbody monitoring)

• Monitoring reports

Training Protocol:

o Staff/contractors to train

o Training methods/materials

o Training frequency

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Industrial Commercial Stormwater Sources

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Next Steps:

Continue refining inventory of industrial/commercial facilities

Complete procedures for the inspection of permitted and unpermitted

MSGP sites

Third-party contractor procurement

o Anticipated Advertising Summer 2017

o Anticipated Contract Registration Summer/Fall 2018

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For more information, visit our website: nyc.gov/dep/ms4

If you have questions or feedback, please contact the MS4 Team at:

[email protected]