Workshop Q New & Emerging Water Management Issues Best - PDF document

Workshop Q New & Emerging Water Management Issues … Best Practices for Storm Water Permitting, Pollution Prevention Plans and Spill Prevention Control & Countermeasures Tuesday, March 26, 2019 2 p.m. to 3:15 p.m.

Biographical Information Jeffrey A. Miller, P.E., BCEE, Sr. Regulatory Expert, August Mack Environmental 7830 North Central Drive, Lewis Center, Ohio 43035 (614) 561-8030 Jmiller@augustmack.com Mr. Miller recently retired from White Castle System, Inc., a food service and manufacturer based in Columbus, Ohio. Mr. Miller was responsible for environmental due diligence for developing new restaurant locations, managing environmental challenges discovered during redevelopment, and environmental compliance for eight manufacturing plants (3 meat packing plants, 2 bakeries, and 3 frozen food plants). Environmental regulations include air, PSM/RMP, water, storm water, wastewater, and solid waste. Mr Miller is a part time Senior Regulatory Expert with August Mack Environmental. Mr. Miller has over 29 years of experience in environmental engineering and has presented and published on such topics as wastewater treatment, site remediation, storm water pollution prevention, sustainability, and overall industrial compliance. Mr. Miller holds a Bachelor’s of Science degree in Petroleum Engineering from Marietta College (1983), and a Master’s of Science degree in Petroleum Engineering from West Virginia University (1986). He is a registered professional engineer in Indiana, Kentucky, Michigan, Ohio, and Pennsylvania; and an American Academy of Environmental Engineers Board Certified Environmental Engineer. Stephanie A. Miller, Senior Consultant Trinity Consultants, 110 Polaris Parkway, Suite 200, Westerville, OH, 43081 614-433-0733 SMiller@trinityconsultants.com Stephanie Miller is a senior environmental consultant with Trinity Consultants’ Columbus, Ohio office. She began her career with Trinity in Pittsburgh in 2014, where she served a number of industry sectors throughout Pennsylvania, West Virginia, and Ohio. Stephanie’s experience includes air permitting and compliance, air dispersion modeling, Environmental Management Information Systems (EMIS), Spill Prevention Control and Countermeasure (SPCC), Toxic Release Inventory (TRI), and a number of other environmental specialties. Her work encompasses a wide variety of industries, including oil & gas, metal manufacturing, chemical manufacturing, among other manufacturing industries. Stephanie earned a Master of Science degree in Environmental Science from the University of Cincinnati, where she conducted research on drinking water treatment at the U.S. EPA. She earned a Bachelor of Science degree in Biology from Kent State University. James C. Albertz, Senior Environmental Engineer Albertz Engineering, LLC, 3621 Vineyard Ridge, Cincinnati, OH 45241 513-368-9791 jim@albertzengineering.com Jim is a Professional Engineer with over 25 years of experience in feasibility study, design, construction, operation and improvement of municipal and industrial water and wastewater treatment, stormwater management, green infrastructure, and soil and groundwater remediation. He has designed and installed treatment systems that use gravity separation, filtration, pH neutralization, adsorption, and oxidation, chemical, and biological processes. Mr. Albertz has designed landfill gas, leachate collection, and stormwater management systems. Using creative problem solving, Mr. Albertz has developed robotic manufacturing systems, integrated machine guarding, and designed automated process control systems. A member of the Construction Specifications Institute, Mr. Albertz has prepared specifications for large-scale construction projects including treatment, remediation, and maintenance facilities. Jim is a graduate of University of Cincinnati with a M.S. in Civil and Environmental Engineering. He teaches Engineering Project Management at UC.

Best Practices for Storm Water Permitting, Pollution Prevention Plans and Spill Prevention Control & Countermeasures ymposium  March 26, 2019 MEC EHS S S tephanie Miller –Trinity Consultants Jeff Miller –August Mack Environmental Jim Albertz –Albertz Engineering Albertz Engineering, LLC

Introduction and Topics ˃ Jeff Miller: Multi-S ector General Permit and No Exposure Exemption ˃ Stephanie Miller: Best Management Practices for S PCC ˃ Jim Albertz: Innovative Best Management Practices

General Permits Since 1992  Original Group General and General Permits were Best Management Practices (BMP)-Based  Focus not on sampling results but on BMP’s  Compliance driven by SWP3 and implementation of BMP’s  Non-compliance driven by lack of BMP maintenance and attention to BMP details  Manageable compliance  Length of permit manageable

Indiana and Kentucky  Indiana 327 IAC 15-6 (Rule 6)  File NOI  File Annual Report  Checklist for QA on facility SWP3  Kentucky General Storm Water Permit 34 pages  Expires July 31, 2023  File NOI

5 400 General Permit Pages 350 300 250 Pages 200 150 100 50 0 OHG000001 (Group) OHR000002 OHR000003 OHR000004 OHR000005 OHR000006 Multi‐Sector GP

2015 USEPA MSGP  Effective July 21, 2015 @ 376 pages  Benchmarks the same except for saltwater discharges  Additional sector requirements  A (Timber Products)  G, H & J (Mining)  S (Air Transportation)

2015 USEPA MSGP  Combined comprehensive site inspections & routine facility inspections  Updated corrective actions section including new deadlines  SWPPP must be provided with NOI to be available to EPA & public

2015 USEPA MSGP  New Endangered Species evaluation requirements prior to receiving permit coverage  Dischargers must ensure Water Quality Standards will be met  Additional monitoring  Possible treatment prior to discharge

2015 USEPA MSGP  New requirements for minimizing exposure, good housekeeping, spill prevention & response, and employee training  Clean catch basins when debris reaches 2/3 of the sump depth & keep debris at least 6” below the outlet pipe

2015 USEPA MSGP  Treatment of pavement wash water prior to discharge (filtering or other treatment)  More specific annual training requirements

General Permits Since 1992  Multi-Sector General Permit push by Director Korleski at end of Strickland Administration  Director Nally pushed for Ohio EPA to implement Multi- Sector General Permit  Director Nally at meeting specifically told me he did not know why it was so difficult to visually observe outfall during precipitation event  Former Director Butler approved current version OHR000006 or Sixth Generation which is just an extension of OHR000005 or Fifth Generation  Multi-Sector included full enforcement strength of CWA and extended to No Exposure Exemption (note 18 substantial improvements identified)

Costs Associated with Multi-Sector General Permit  Original estimation of cost to Ohio Industry approximately $8,400 additional per year  Just included sampling and did not include extra events for lack of sufficient rainwater intensity calling for another sample event  Did not include annual compliance evaluation  2019 estimate of an additional $10k per facility  2019 estimate of $31,000,000 for Ohio Industry over life of permit (assumes no Benchmark exceedances)

Benchmark Comments  Benchmarks not ambient water quality criteria  Some Benchmarks lower than acute and chronic water quality criteria  Result is chronic water quality criteria applied to acute zone!

Benchmark Comments

Benchmark Survival  Don’t over-sample  “Problematic” benchmarks  Zinc  TSS  Copper  Nitrite+Nitrate  30 days to correct if exceed benchmark

“No Exposure” Basics  Conditional, not an exemption  Criteria somewhat subjective  Evaluate modifications to qualify  Use EPA Guidance Document (Published 2000)  Update/re-submit every 5 years  Facility list available on-line

“No Exposure” Data  3,031 facilities certified since 2007  4,913 facilities certified 2/11/2019  22 sectors as “primary”  16 sectors as “secondary”  Facilities in all 88 counties

No Exposure Certification  Indiana, Kentucky and Ohio file electronically  Reiterate the risk associated with compliance to management  Enforcement force of CWA available to agencies

No Exposure Certification (NEC)  NEC = No storm water NPDES permit  “All industrial materials & activities are protected by a storm resistant shelter to prevent exposure to rain … and/or runoff”  Renew NEC every 5 years

No Exposure Certification  Continuous compliance (not periodic)  NEC is within the CWA - meaning full teeth of CWA can be applied for mishandling No Exposure  You WILL BE inspected

No Exposure Certification  11 questions must be answered NO!  MS4 discharges - provide NEC to them

NEC Assessment Criteria  Does industrial activity meet definition for storm water?  Does regulated activity meet definition of “No Exposure” & qualify for permitting exclusion?  Completed & submit NEC

No Exposure Strategies  Move items under roof  Cover  “Shelter” can mean fixed or temporary  Common sense interpretations of the USEPA Guidance manual & Particulate Emissions