Storm Water Permits

1. Storm Water Permits • The Problem of Phasing In • Potentially have every industrial facility in the U.S. needing a permit at the same time at the same time agencies are trying to write the regs and figure out what the issues will be • Approach used was to create general permits along with regulations • Published permits in Fed. Register • Industries could apply for coverage under general permit

2. Primacy and Phase In • States also created general permits - often largely copied the Feds and added several of their own • Could go for 3 types of permits • A General Permit for an entire sector of industries • An Industry Specific Permit where an industry collectively tried to organize for a permit • Individual Facility Permit

3. Where We Are At Now • Initial Shock is through system • Moving away from general permits • Some stabilizing on Industry specific permits • Many are moving toward individual permits just like individual NPDES • One Problems in transition is anti- back slide provision • If a general permit put some restriction that didn’t fit - it becomes hard to alter going to individual

4. Basic Features of Storm Water • Storm Water Permits are built around two ideas • Every facility needs a Storm Water Pollution Prevention Plan (SWPPP) • Facilities should use Best Management Practices to avoid contact of storm water with contaminants

5. Permit Dangers • May not want to volunteer to do too much • watch out for numerical effluent limits • monitoring requirements • Problem is backslide provisions - if you have homes built up drainage and they spill into storm water the limits could nail you • Watch specifics with sensitive information • your permit must be on site for inspectors • considered a public document - may allow tree huggers and NIMBYs to demand access

6. Creating a SWPPP • Step #1 - Formulate Your Team • Need to have someone who is ultimately responsible • Tempting to get a consultant - helpful but you can be surprise inspected and need to have someone on site who can answer questions and ferry inspectors around • Larger facility may use a division manager • Smaller may have chief engineer

7. Step #2 Existing Plans • Look at contents of existing permits - may tell you what the issues are - also helps to prevent contradicting yourself • Oil Drums probably already have a spill prevention and countermeasures plan • Toxic Substances already have plans • May be community emergency response plans • OSHA Emergency Action Plans

8. Check What Discharges Covered • Process Waters have NPDES permit • some commingled waters have to be treated as process waters and are NPDES • don’t duplicate coverage • Check for restrictions and discharges to municipal sewer cover certain discharges or impose specific conditions

9. Step #3 - Site Assessment • Obtain a Base Map of Property - don’t go out for a custom survey • A good enlarged topo • Ariel Photos from IDOT or USDA • Tax Maps • U.S. Soil Conservation Service Mapping • U.S. Fish and Wildlife Service National Wetlands Inventory Mapping

10. Add to the Base Map • Drainage Patterns and Flow Directions • Surface Water Bodies including wetlands • Any water bodies receiving points for storm water • Any place receiving storm water from a storm sewer • Any Storm Water discharges from property • Any Non Storm Water Discharges • Locate NPDES discharges and give permit number • Check in dry season when run-off and water bodies more obvious • State how things were established • Company Official must certify no unpermitted discharges

11. Add Location of Process Activ. • Stock Piles • Crushers • Feed bins • Conveyors • Fueling Stations and Fuel Tanks • Loading Areas • Equipment Maint Areas • Storage areas

12. More Additions • Add all existing storm water management features and structures

13. Source Materials Inventory • A Source Material is Something you handle in your trade or business that could be construed to contaminate material • The fact that many mining operations handle mostly natural materials is irrelevant (many laws are built on the premise that anything touched by a human process is a sinister environmental contaminant)

14. Likely Source Materials • Raw Materials for Trade • All handled inventories or in process inventories of stone and aggregate materials for a quarry • All Intermediate Materials and Finished Products • May include asphaults or cements • All waste or byproduct materials including decantation ponds

15. More Likely Sources • Industrial Machinery and Machinery Yards • Conveyors • Crushers • Screens • Equipment Yards and Facilities • Your Parking Lot

16. More Sources • Fuels Solvents and Detergents • Fueling Stations • Fueling Storage • Plant Yards and Repair Stations • The Janitorial Closet • Locations of Previous Spills or Leaks • Any reportable amount of hazardous or non-hazardous from past 3 years (maybe more)

17. Unsources • Some States have Created Guidelines on “Inactive” Materials that cannot be contaminants • Washed Stone (has no fines) • Broken Concrete (recycle is good) • Rip Rap • Rip Rapping of Channels is considered a best management practice so calling it a contaminant is embarrassing to regulators

18. Water Quality Data • Inventory and include any water quality data pertaining to storm water • May be little initially but likely to grow with time

19. Write a Narrative Description • Mining is a minor source compared to what many regulators are used to • Many know little about mining except for some negative comments from stories and movies where mining companies are the villains • Politely explain how each process works - replace fear of the unknown with understanding

20. Step #4 Best Management Pract. • Identify areas where storm water may contact contaminant materials • Select Best Management Practices for those areas

21. Types of Best Management Pr. • Baseline Practices • Involve operations and handling practices • usually cheaper • Structural Practices • Involve building something to control • Problems with • Building Structures in Wetlands • Impoundment may be considered discharge to groundwater • Erosion control may overlap soil conservation • Construction permits may get into Zoning Issues

22. Baseline Management Pract. • Good Housekeeping • Round up Crud before it contacts storm water • Keep Floors and Ground Surfaces Clean • Sweeping Shoveling and Vacuuming are major accepted removal practices • Don’t hose it down - you just contaminated water • Don’t wait till after it has rained - use a schedule • Front end loaders and bobcats may clean up larger spills - hand shoveling can be labor intensive • Vacuum equipment may produce recycle

23. Operations and Maintenance • Have regular trash pick-up and debris removal • Use Rapid Recycling Collection • Inspections for leaks in chemicals and fuel storage or even rock bins • Try to search and fix during regular maintenance • Lots of people try short-cuts here • Store in Proper Durable Containers • Train Crews in Spill Clean-up Methods

24. Materials Storage Practices • Provide Adequate Isle and Maneuver Space for Handling (so they don’t bash in all the drums trying to handle them) • Maintain an Inventory of What You Have • Often can save money on inventory • Walk Through and See What you have • Check Last Years Invoices • Keep up Labels - people toss mystery stuff • Keep MS Data Sheets file for everything

25. Chemical, Lube, Fuel Drums • Keep in contained or curbed areas so leaks can’t go anywhere • Keep out of direct traffic routes to reduce accidents from people unable to drive • Store off of ground to avoid corrosion around base • Have a lot of people trained in clean up - but only a few responsible for inventory

26. General Source Materials • Store Indoors - works for chemicals but probably not aggregate piles • Cover the pile and put diversion berm around to route storm water away from the evil contaminant • Look for Guidelines that may exempt your coarser rock from being an evil contaminant • You may not be able to cover everything but maybe you only need to guard your finer material

27. Other Cover Applications • Often feasible to have covered refueling depots - your employees may actually think you were setting up a convenience for them • Look at use of tarps for things temporarily outside

28. Include Employee Participation • Have Regular Training and Review • Put up Bulletin Boards and Posters • Include Treatment in Meeting Agendas

29. Dust Control • Settled Dust may get you out of Clean Air Regs but it can get you nailed in Storm Water • Avoid Denuded Areas - vegitation makes you look more environmental friendly anyway • Use Wind Breaks Like Trees • Have coarser material at surface so water can’t run off with fines

30. More Dust Control • Do look at wetting down but not enough to produce run-off • Do consider surfactants • don’t use oils because they are evil contaminants of soils • use in drier areas where water cannot carry off • keep away from traffic so tires can’t spread • Look at Dry Collection • especially if a recycle opportunity exists

31. Use Preventative Maintenance • Regularly Inspect and Maintain Storm Water Handling Facilities • Keep onsite records of own - not necessarily sent in • Be careful with sensitive information - public access not well defined • Regular Maintenance of Things that could release contaminants • Hydraulics on Equipment

32. More Preventive Maintenance • Have a list of everything that needs inspection • Have a schedule for those inspections • Have records of Results of Inspections • Have records of Timely Corrective Actions taken as result of those inspections • Maintenance may save you down time on production • Accident could trigger prosecution from unexpected statutes

33. EPA Itemizes for Inspection • Pipes • Pumps • Storage Tanks and Bins • Pressure Vessels • Pressure Related Valves • Pressure Release Valves • Process and Materials Handling Equipment • Storm Water Management

34. Have Facilities Inspections • Look for things that could cause discharge of priority chemicals • Things that could cause contact with finished or unfinished goods (rock in a quarry) • Bins and related dust patterns • Lot of things can be added to inspections to avoid equipment failures

35. Lots of Inspections • Most inspections can be visual • Need to have “qualified personnel” do inspections • Should be a responsible person who keeps a record of finding and response actions • Need to be familiar with SWPPP • Some have suggested surveillance and security people • Occasionally need chemical and acoustic weld tests

36. Formulate Spill Prevention • Need Spill Prevention and Response Plan • Look at previous spill records to determine what areas are spill prone • Look at whether recycling can reduce inventories available to spill • See what a regular inspection program can do to reduce incidents

37. Spill Prevention Strategies • Have standard filling procedures and set ups • jury-rigged filling from drums causes spills • Have a spill response plan • employees must be aware of what plan is • need to have a spill response team • have a plan for notifying authorities if necessary including assignments of who will do

38. Helping Spill Response • If spillable chemicals are bermed or in containment structures the spill impact will be localized and potentially not contactable by storm water • Need to make sure that clean up equipment can get access to area • Don’t hose spill into the drain • EPA likes putting down sorbants to soak up

39. Sucking Up Spills • Variety of materials available • Clays straws and fly ash are common and effective sorbants • polymers and beads are pricey • Don’t use ammonium nitrate and wood chips for diesel fuel • There are gelling agents to solidify many larger spills for mechanical clean up

40. Have a Waste Management Plan • Minimize handling and inventories • Check incoming vehicles for leaks • On Vehicles used for disposal • Include spill baffles for liquid wastes • use sealed gates and tarps for solids • include tire washes to limit tracking around site • Try to keep wastes separated to improve the chances of recycling

41. More Waste Management • Work on loading system efficiency to avoid spills during loading • Try to minimize fugitive emissions that may settle and become an issue • Set up land fill like areas to minimize run-off • keep slopes under 6% • look for areas of low water table • try to avoid getting a groundwater issue out of it

42. Control Vehicle Washing • Maintain well but wash only when absolutely needed • Wash in designated areas only • Use environmentally friendly phosphate free detergents

43. Structural Control Practices • Storm water conveyance (ditches or channels) • line ditches to prevent sediment • actually size the ditch for the run off expected - don’t just go out for a digging party • its easier to do it right the first time than retrofit • Use conveyances to keep process waters away from and separate from storm water

44. Structural Controls • Use Diversion Dikes to block storm waters out of process areas • larger areas may require something more simple like ditches and berms • Build up industrial areas above the grade of surrounding ground • Use paving to funnel process waters to receiving points • Check for cracks to prevent discharges to groundwater

45. More Structural Controls • Pave over spill areas and surround with containment barriers • Use Drip Pans for Minor Spills • Create structural depressions to channel spills to discrete areas for easy clean up with sorbants • Build covering structures for materials

46. Erosion Prevention Programs • Try to maintain lines of vegetation even when disturbance is necessary • Vegetation spreads back easier from established strips • Established strips help to break run-off and erosion • Use increase planning needed to work around to reduce confinements that can cause spills and other problems

47. More Erosion Prevention • Leave buffers around sensitive or problem areas • leave buffer zones around wetlands • put buffer zones around parking lots so that run-off can infiltrate before it goes some place • Stabilize stream banks so that erosion is reduced • Put down mulching matting and netting on erosion prone areas

48. Still More on Erosion • Establish temporary seeding with fast growing species to stabilize soil • Resort to chemical stabilization • vinyls , rubbers, asphaultic materials to hold what can’t be vegetated • be aware this can promote rapid run-off • make sure your stabilizer is not a contaminant • Use grids of dikes and swells to break the speed of run-off

49. Erosion Controls • Use pipe slope drains to collect and run water down sensitive slopes that could be eroded by run-off from other areas • Install Filter and Silt Fences • Can use staked straw bales as barriers • Use gravel or stone filter berms (since the material is a best management practice it usually can’t be a contaminant when used this way)

50. Erosion Control • Higher gravel barrier that creates small water impoundment is a check dam • These can settle sediment out of water • Build inlet protection for storm water drains • These will have to be regularly inspected