Industrial General Permit Notice of Non-Applicability

1. Industrial General Permit Notice of Non-Applicability Presented By: Conestoga-Rovers & Associates Fred Blickle and Michael Beerends Air & Waste Management Association (AWMA) Golden Empire Chapter September 16, 2014

2. Overview of CRA (a GHD Company) • CRA originally established in 1976, over 35 years of experience with more than 50,000 successfully completed projects • CRA merged with GHD on July 2, 2014 • Now one of the largest privately held engineering and environmental firms with over 8,500 people in five continents • 370 staff in 15 California locations (Bakersfield, Concord, Emeryville, Eureka (2), Fresno, Irvine (2), Rancho Cordova, Sacramento, San Diego, San Francisco, San Jose, Santa Rosa, and Sonoma) • One of few large consulting firms registered to ISO 9001:2008

3. Health & Safety • Safety ranks as the highest priority commitment by CRA • Our employees are our most valuable resource and understand that all incidents are preventable. • CRA’s Safety Performance best in industry: * Industry Average TRIR as reported by US Bureau of Statistics is 1.3 (2011)

4. The Federal Clean Water Act (1987) 40 CFR part 122 requires industries with storm water discharges to surface waters to obtain permits under the National Pollutant Discharge Elimination System (NPDES) California Water Code Section 13000 California NPDES Program is part of the State Water Board’s division of water quality Regulatory Background

5. Current Permit – Order 97-03-DWQ has expired Remains in effect until new General Permit is adopted New Permit - Order 2014-0057-DWQ adopted April 2014 and becomes effective July 2015 Any facility with point source storm water discharges associated with industrial activities, as defined in the Federal storm water regulations codified at 40 CFR 122.26 (b) (14), must obtain permit coverage http://www.swrcb.ca.gov/water_issues/programs/stormwater/industrial.shtml Regulatory Update Industrial Storm Water General Permit Updates

6. Industrial Facilities Covered Appendix A of new Industrial Permit: • Facilities subject to 40CFR Ch I (Cement Manu., Feedlots, Fertilizer Manu., Petro Refining, Phosphate Manu., Steam Elect., Coal Mining, Mineral and Ore Mining & Process., Asphalt Emulsion, Landfills, Airport Deicing) • Manufacturing Facilities with SIC 20XX through 39XX, 4221 through 4225 • Oil & Gas/Mining Facilities • Hazardous Waste Treatment, Storage, and Disposal Facilities • Landfills, Land Application Sites, and Open Dumps • Recycling Facilities • Steam Electric Power Generating Facilities • Transportation Facilities • Sewage or Wastewater Treatment Works

7. Three Options for General Permit Coverage: File Notice of Intent (NOI): Site Map Storm Water Pollution Prevention Plan No Exposure Certification (NEC) Notice of Non-Applicability (NONA) General Permit Coverage

8. It Does Rain in Bakersfield • Avg. ~6.50” per year. • Max Month = 6.33” (December 2010) • Highest Single Day = 2.53” (2/10/1978)

9. A Discharge occurs when storm water: crosses the property boundary (sheet flow); enters Waters of the United States (lakes, ponds, rivers, streams, tributaries and wetlands) which can happen on the surface or below ground; or enters a municipal separate storm water system (that discharges to Waters of the US) What is a Discharge???

10. Hydrocarbons (e.g. fuel, oil and grease) Toxics (e.g. pesticides, solvents, paint) Organics (oxygen demanding substances) Nutrients (e.g. phosphorus and ammonia) Pathogens (e.g. bacteria and viruses) Sediment (silt and clay colloids) Salt (chlorides and other ions) Accidental Spills, leaks from piping Other related products/by products Storm Water Pollutants

11. Paved areas (roads, parking areas, etc). Unpaved areas (highly compacted and void of vegetation) Roofs (eaves, rain gutters) Material handling activities exposed to storm water Vehicle fueling and cleaning areas Cullet Piles Storage of chemicals Storage of fuels, oil Storage of scrap metal Transformers Sources of Storm Water Impacts

12. Be engineered and constructed to contain the maximum historic precipitation event; or Located in basins or physical locations not hydrologically connected to water of the United States; and Submit and certify via SMARTS both the NONA and a No Discharge Technical Report if requested by the Regional Board Facilities claiming “No Discharge” must: Notice of Non-Applicability (NONA)

13. Facility Containment Design including: Survey of existing stormwater retention systems Hydrologic analysis of tributary watershed Stormwater retention system capacity analysis Soil permeability analysis Soil stability analysis Receiving water evaluation (above- and below-ground) Safety factor considerations (freeboard) Certified by California Licensed Professional Engineer No Discharge Technical Report

14. Survey: To determine capacity of retention basin To determine storm water flow patterns and directions Capacity and Drainage Survey

15. Calculations: Hydrologic modeling of watershed: Determination of total tributary area (facility and run-on) Evaluation of watershed (land uses and soil types) Maximum Historic Precipitation Event (MHPE) values based on NOAA data Recommend to default to local standards if more stringent than MHPE Design storm event volumes Retention System Capacity Analysis Stage-Storage of existing or proposed retention system based on survey Comparison against design storm event volumes Hydraulic Calculations

16. Soil Permeability and Stability: Retention system soil types Retention system infiltration rates Basin plan limitations Depth to groundwater Potential impacts to groundwater Soil Determination

17. NONA and No Discharge Technical Report: Certified and submitted via SMARTS by facility LRP within 60-days of being requested by the Regional Board Signed by a California Professional Engineer Reporting Requirements

18. “No Discharge” determination does not cover storm water containment systems the transfer industrial pollutants to groundwater. Must determine if infiltration may discharge to and contaminate groundwater Permit does not provide guidance for determination Facilities that have not eliminated discharges subject to the General Permit are ineligible to submit a NONA Additional Considerations

19. Best Management Practices (BMPs) are measures which may be implemented to prevent or mitigate pollution from activities performed at a facility. They are broad measures including process, procedures, schedule of activities, prohibitions, and other management procedures which prevent or reduce storm water pollution. Good Housekeeping Preventative Maintenance Visual Inspections Spill Prevention/Response Sediment/Erosion Control Training Record Keeping Best Management Practices

20. Structural Controls Preventative Measures (signs, labels, and security) Diversions (conveyances, dikes, grading, sloping, and pavements) Containment (secondary containment, curbs, and drip pans) Other Controls (sumps, pumps, separators and basins) Facility Controls

21. Outfalls Drum storage areas Containment areas Drainage Sediment basin Retention ponds Shipping/Receiving BMPs Vehicle washing Catch basins Haz waste storage Cullet storage AST’s Fueling areas Routine Inspections

22. Reported to Regional Water Board Reported within 24 hours if human health or environment issue Written submission: Description of release Date and time of release Measures taken to stop, and prevent recurrence Inspection reports (annual & routine) Reporting Releases or Discharges

23. Industrial Storm Water Permit • Q&A / Thank you for having us AWMA! • Fred Blickle 313-506-9799 • Mike Beerends 559-286-9999