Biographical Information Jason R. Fyffe Environmental Supervisor, - PDF document

Workshop E Storm Water Permitting & Compliance … Becoming More Complex & Costly Wednesday, July 25, 2018 2:45 p.m. to 4:15 p.m.

Biographical Information Timothy W. Ling, P.E., Environmental Director, Plaskolite, LLC. P.O. Box 1497, Columbus, OH 43216-1497 (614) 294-3281 tim.ling@plaskolite.com Mr. Ling is the Corporate Environmental Manager for Plaskolite LLC., a Columbus-based manufacturer of continuously processed acrylic sheet. Mr. Ling is responsible for Plaskolite’s environmental compliance at its 9 manufacturing facilities in North America. He has over 27 years of experience in environmental engineering, both as a consultant to businesses, and now as in-house environmental manager. He has spoken and written on a wide range of environmental topics. Mr. Ling graduated at the top of his class with a Bachelor of Science degree in Civil Engineering from the Florida Institute of Technology (1989), and Master of Science degree in Civil Engineering from the University of Notre Dame (1991). He is a Registered Professional Engineer in the states of Ohio and Florida, and a Qualified Industrial Storm Water Practitioner (QISP) in the state of California. Brenda VanCleave, P.E., CPESC, CFM, Water Resources Engineer Facilities Operations and Development, Energy Services & Sustainability The Ohio State University 107F Maintenance Building, 2000 Tuttle Park Place, Columbus, OH 43210 (614) 292-6826 vancleave.13@osu.edu Ms. VanCleave is the Water Resource Engineer for The Ohio State University, and is responsible for the operations and maintenance of the water, sanitary, and storm sewer systems on the Columbus campus. Before coming to Ohio State, Ms. VanCleave was a stormwater consultant assisting municipalities in stormwater planning, design, and inspection. She is a Certified Profession in Erosion and Sediment Control (CPESC), and was the sediment and erosion control inspector for the large-scale Portsmouth Bypass project, which involved constructing 16 miles of highway on a new alignment that created 20 million cubic yards of excavation. She was also the MS4 coordinator and floodplain manager for the City of Pickerington, Ohio. Ms. VanCleave holds a Bachelor of Science degree in Agricultural Engineering from The Ohio State University (1997) and a Master of Science degree in Biosystems and Agricultural Engineering from the University of Kentucky (1999). In addition to being a CPESC, she is a Certified Floodplain Manager (CFM), and is a Register Professional Engineer in the state of Ohio.

Biographical Information Jason R. Fyffe Environmental Supervisor, Storm Water Unit Division of Surface Water Ohio Environmental Protection Agency P.O. Box 1049, Columbus, OH 43216-1049 (614) 728-1793 Jason.Fyffe@epa.ohio.gov Jason joined Ohio EPA’s Storm Water Program in December 2001. His primary duties consist of developing and administering rules and permits associated with the NPDES Storm Water Program. This includes the oversight of Ohio EPA’s NPDES general permits for Construction Site Storm Water, Industrial Storm Water and Small MS4. Jason is a 2001 graduate of Shawnee State University with a Bachelor of Science in Environmental Engineering Technology. Hope Manning Project Manager, Multi-Media Compliance Team Leader Environmental Quality Management, Inc. 1800 Carillon Blvd., Cincinnati, Ohio 45240 (513) 742-7238 hmanning@eqm.com Hope joined EQM in August 2015 with over 13 years of technical and compliance management experience in the environmental field. She has been involved in a broad range of programs including air compliance and permitting, NESHAP Boiler GACT compliance, NPDES permitting and compliance, SPCC, and SWPP Plans generation, and EPCRA SARA Title III, Section 312 and 313 reporting. Prior to EQM, Hope was the Corporate Environmental Compliance Manager at Darling Ingredients, Inc., and was responsible for environmental compliance to federal, state, and local requirements for over 50 locations in over 15 states. These activities included assisting in minor and major permitting, regulatory compliance, regulatory interpretation, regulatory reporting, permit compliance and internal auditing. Prior to her time at Darling Ingredients, Inc., Hope was the Water Quality Specialist for The Seminole Tribe of Florida. She was responsible for the water quality program for all surface waters on the Seminole Tribe of Florida reservation lands. Because the Seminole Tribe of Florida is a federally recognized Indian Tribe, she dealt directly with USEPA Region 4 personnel on behalf of the Seminole program. Hope holds a Bachelor of Science Degree in Chemical Engineering from The University of Cincinnati.

1 Storm Water Permitting & Compliance Becoming More Complex & Costly Timothy W. Ling, P.E. Brenda VanCleave, P.E., CPESC, CFM Environmental Director Water Resources Engineer Plaskolite, LLC. The Ohio State University Jason R. Fyffe Hope Manning Environmental Supervisor Project Manager/ Storm Water Unit Multi-Media Compliance Team Leader Division of Surface Water Environmental Quality Management, Inc. Ohio EPA

2 Topics  Storm water permits for industries  IGP compliance  Ohio EPA perspectives  CGP compliance  The FUTURE…

3 Storm Water NPDES Permits  Individual NPDES permit  IGP = Industrial General Permit  CGP = Construction General Permit

4 Why Storm Water Permit?  Initial construction (CGP)  Operating facility (IGP) FOCUS  Renovations (CGP if ≥ 1 acre)  Expansion, demolition NOT A  “…[C]learing, grading, FOCUS excavating, grubbing and/or filling activities”

5 What Coverage Do I Need?  SIC code in list & exposure…  Now what? No Discharge, No Exposure Formal NOI No Permit Certification Needed

6 What’s “No Discharge”?  Storm water doesn’t leave property  Storm water that is discharged offsite but not to a “WOTUS” (Ohio?)  Doesn’t go into an MS4

7 Formal NOI  Submitted through STREAM  OEPA still processing NOIs from September 2017  Must identify all Outfalls  Perfect time to re-evaluate your drainage

8 Re-Evaluate Drainage  Identify all drainage locations offsite  Discrete point sources  Sheet flow sources  This not only effects NOI but also SWPPP

9 No Exposure Certification (NEC)  Eligible if:  There are no industrial materials & activities, or  All industrial materials & activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff.

No Exposure Certification Checklist 10 Any “YES” answers to questions below would cause you to not be eligible for NEC! 1. Using, storing or cleaning industrial machinery or equipment, and areas where residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to storm water 2. Materials or residuals on the ground or in storm water inlets from spills/leaks 3. Materials or products from past industrial activity 4. Material handling equipment (except adequately maintained vehicles) 5. Materials or products during loading/unloading or transporting activities 6. Materials or products stored outdoors (except final products intended for outside use [e.g., new cars] where exposure to storm water does not result in the discharge of pollutants)

No Exposure Certification Checklist 11 Any “YES” answers to questions below would cause you to not be eligible for NEC! 7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers 8. Materials or products handled/stored on roads or railways owned or maintained by the discharger 9. Waste material (except waste in covered, non leaking containers [e.g., dumpsters]) 10.Application or disposal of process wastewater (unless otherwise permitted) 11.Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under an air quality control permit) and evident in the storm water outflow

12 No Exposure Certification Checklist  NEC removes all sampling, inspection, and plan requirements. But… BE CAREFUL! It can be a double whammy.

13 IGP – How To Comply?  Major changes in recent IGP  No annual comprehensive inspection  Sheet flow outfalls clarified for monitoring  Account for run-on & building contributions  Alternate benchmarks

14 Storm Water Pollution Prevention Plans (SWPPP)  Must be updated within 180 days of renewal (November 28, 2017)  Sections to review  Narrative description of potential pollutant sources and BMPs  Site Location Map  Employee contacts are up to date  Corrective Actions

15 SWPPP (continued)  Narrative Description  Additional sheet flow outfalls  Pollutants in this area?  Are BMPS listed used? If so, are they adequate? If not, what is?

Best Management Practices (BMPs) 16

BMP – Drain Sock Filter 17

BMP - Booms 18

BMP – Hay Bales 19

Green BMPs 20 Constructed Wetlands Pervious Pavement Tree Boxes

21 SWPPP (continued)  Make sure map is up to date  Identify all outfalls (including sheet flow)  Location of all pollutant sources  Monitoring locations (if not at outfalls)

22 Corrective Action Triggers  Unauthorized release or discharge  Violation of numeric effluent limit  An inspection finds control measures not properly operated & maintained