EPA's Storm Water Program Training Course - Clean Water Clear

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The NPDES Industrial
Storm Water Program
        What Does the Industrial
           Program Cover?

 “Storm Water Discharges Associated with
  Industrial Activity”
      Storm Water - includes storm water runoff,
       snow melt runoff, surface runoff and drainage
      Discharge - a point source discharge from any
       conveyance to a municipal separate storm
       sewer system (MS4) or Waters of the U.S.
Storm Water Discharge Associated
     with Industrial Activity

  Definition found at 40 CFR
  11 categories of industrial activities
  Related to manufacturing, processing, or
   materials storage areas
  Includes Federal, State, and municipally-
   owned and operated facilities
 Regulated Industrial Activities

 Facilities Subject      Recycling
    to Standards (i)       Facilities (vi)
   Heavy                 Steam Electric
    Manufacturing (ii)     Power Plants (vii)
   Mining/Oil and        Transportation
    Gas (iii)              Industries (viii)
   Hazardous Waste       Sewage Treatment
    Facilities (iv)        Plants (ix)
   Landfills (v)
  Regulated Industrial Activities:

 Found under Category (x)
 Land Disturbance of five or more acres
      Clearing, grading or excavation
 Activities part of a larger common plan
  of development
      Multiple activities within a contiguous area
      Includes activities taking place on different
Regulated Industrial Activities:
    Light Manufacturing

 Found in Category xi

 Identified by SIC code

 Was the original “No Exposure”
  category that got challenged
What is the “No Exposure” Provision?

  Original no exposure exemption
       Only available to Category (xi) facilities with
        no exposure
       No certification required
  9th Circuit Court Decision
       Remanded for further rulemaking
  Final Phase II Rule
       No exposure provision
         – Applies to all Categories, except construction
         – Requires certification of no exposure
  How Does the No Exposure
    Certification Work?

 EPA’s No Exposure Form asks a series
  of Yes/No questions to help determine
  if no exposure exists
      May submit only if answer “no” to all
      Applies in States where EPA is the
       permitting authority

 NPDES-authorized States will adopt
  own form after updating State rules
 How Do I Determine If an Industrial
Facility Needs a Storm Water Permit?

 Does the facility have a storm water
  discharge to Waters of the U.S. or an

 Is the industrial activity described in
  the regulations?

 Does the facility qualify for a
  conditional exemption?
     ISTEA Exempted Municipally
      Operated Industrial Sources

 Intermodal Surface Transportation Efficiency
  Act of 1991

 Delayed permitting for industrial activities
  operated by municipalities with populations less
  than 100,000

 Phase II set the deadline to obtain permit
  coverage to be no later than 3 years and 90 days
  from publication of the rule – March 2003
  What Industrial Permit Options
    are Currently Available?
 Individual Permit
      Depends on the state in which a facility is

 General Permit
      EPA permitted states:
        – Multi-Sector General Permit (MSGP)
        – Submit a Notice of Intent (NOI) for coverage
      Authorized NPDES states:
        – Applicable general permit
 EPA’s Multi-Sector General Permit
 Developed using industry-specific data from
  previous permit application process

 Consolidated industry data into 29 industry
  sectors with tailored requirements

 Focuses on development and implementation of
  storm water pollution prevention plans

 Should get reissued late summer 2006
  What Facilities are Eligible for
  Coverage Under the MSGP?

 Facilities with a storm water discharge
  associated with industrial activity
  (Categories i-ix, xi)
 Eligibility restrictions regarding adverse
  impact on Endangered Species or Historic
         Contents of the MSGP

 Notification requirements
 Special conditions and requirements
 Storm Water Pollution Prevention Plan
 Numeric effluent limitations
 Monitoring and reporting
 Specific requirements for industrial
       Endangered Species Act
          and the MSGP

 Permittees must certify on the NOI
  that no impacts to endangered
  species are likely or have previous
  ESA authorization for adverse

 Addendum of MSGP
      ESA certification instructions
      County-by-county list of species
National Historic Preservation Act and
             the MSGP

 Must certify:
      That discharges do not affect property that is
       listed, or eligible for listing, under the NHPA;
      That facility can obtain, and maintain
       compliance with, a written agreement with the
       State or Tribal Historic Preservation Officer
 Addendum contains guidance
Storm Water Pollution Prevention
       Plans (SWPPPs)

  Common requirements
       Planning and organization
       Site evaluation
       BMP identification
       Implementation
       Evaluation and monitoring
  Sector-specific requirements
  Remains onsite at facility
MSGP Monitoring Requirements

 Three types of monitoring
      Visual examinations
      Analytical (chemical) monitoring
      Compliance monitoring

 Basic Regulatory Requirements
      40 CFR Part 136 methods
      Representative storm event
          Visual Monitoring

 Quarterly examination of discharges
      Color
      Odor
      Solids
      Foam
      Sheen
 No analytical tests
 Results submitted only if requested
Analytical “Benchmark” Monitoring
 Required only for certain industry
 Quarterly sampling required in years
  two and four of the permit
 Required to submit results
 Not “limitations”
          Compliance Monitoring

 Required annually for facilities subject to
  numeric effluent limitations

 Grab samples within the first hour of
      Prior to mixing with other discharges

 Required to submit results
          Alternate Certification

 Exempts facilities from analytical
  monitoring requirements
      If no sources of a pollutant are exposed to
       storm water
      Pollutant-by-pollutant and outfall-by-outfall
      Not available for compliance monitoring

 Certification retained onsite and submitted
  to the permitting authority
Representative Discharge Provision

  Applicable to analytical and visual
   monitoring requirements
       Compliance monitoring not eligible
  Discharge from one outfall may
   represent discharge from other outfalls
       Consideration of several factors
       Quantitative data applies to other outfalls
  Required to document in SWPPP
          Sampling Waivers

 Adverse Weather Conditions/
      Allows substitute samples
      No prior approval required
 Unstaffed and Inactive Sites
      Analytical Monitoring Waiver
      Visual Examination Waiver
      No prior approval required
 No Representative Storm Event
       How Does a Facility Apply for
       Coverage Under the MSGP?

 SWPPP in place prior to NOI submittal
 Complete ESA and NHPA screening
 Complete and submit NOI form
      Facility information and certifications
      MS4 notification
      Deadlines
 Use a Notice of Termination (NOT) to
  discontinue coverage

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