The NPDES Permit Program and its applications on a local industry

1. The NPDES Permit Program and its applications on a local industry

2. What is NPDES? • Part of the Clean Water Act (CWA) • National Pollution Discharge Elimination System 40 CFR 122 • The Program’s purpose is to help prevent and remove pollutants from our Nation’s rivers, lakes, and costal waters.

3. Why NPDES? • Complex piece of legislation to understand • Required to complete a Storm Water Pollution Prevention Plan (SWP3) for a Genzyme site in Framingham

4. Evolution of NPDES • 1970 Refuse Act Permit Program (RAPP) • Developed form the Rivers and Harbors Act of 1899 • Under the direction of the Army Corps of Engineers • Recodified in 1972 to the Federal Water Pollution Control Act (FWPCA) • Water quality based and technology based control strategies • First goals and principles were set regarding clean waters

5. Evolution of NPDES • From 1973-1976 the first NPDES permits were issued • Focus was on • Best Available Technology (BAT) • Best Practical Control Technology (BPT) • Best Management Practices (BMP) • 1977 – Amendments to the FWPCA provided the framework for the CWA • CWA was amended in 1987 to meet water quality standards set by states

6. Evolution of NPDES • CWA highlights • Priority pollutants • Schedules and Programs for industrial and municipal stormwater discharges • Toxics • Conventional • Toxic • Non-conventional • Vectors • Point – Discharge directly into water bodies • Non-point – Goes through POTW

7. NPDES Permitting • Two Types of permits • Individual – Tailor to the facility • General – Cover multiple facilities in a particular group (Multi-Sector General Permit) • All permitted facilities are required to create and maintain a Storm Water Pollution Prevention Plan • MA is a non-delegated NPDES permit state • EPA and DEP jointly issue and enforce the permit

8. Applicability for the Genzyme Framingham site • Genzyme is required to have a permit because: • Manufacturing designation under the Standard Industrial Codes (SIC) • Discharges stormwater from the site to surface waters (Foss Reservoir)

9. Genzyme Framingham Site

10. Stormwater Pollution Prevention Plan Overview • Genzyme has a Multi-Sector General Permit (MSGP) • Blanket permit issued to facilities that don’t require an individual permit. • Issued Oct. 30th 2000 – Exp. Oct 30th 2005

11. Stormwater Pollution Prevention Plan Requirements • Requirements include: • Prohibited discharges of point source pollution • Best Management Practices (BMP’s) - PM’s etc. • Risk assessments of pollutant sources • Quarterly inspections • Annual site inspection

12. Stormwater Pollution Prevention Plan Requirements • Annual Training • Review and revise plan every three years or as needed. • Pollution Prevention Team

13. Pollution Prevention Team • Must implement the following • All general permit and pollution prevention plan requirements • Defining and agreeing on goals for the program • Being aware of any changes that could impact stormwater discharge

14. Inspection Schedule • Quarterly • Wet weather inspections - 2nd & 3rd quarters • Sample taken from each drainage area • Visual monitoring record • Dry weather inspections - 1st and 4th quarters • Emergency Generators & Fire Pump • Site Drainage Ditches/Swales

15. Inspection Schedule • Semi-Annually • Catch Basins & Storm Drain Manholes • Annually • Site Assessment • Training

16. QUESTIONS?