Transcript EPA NPDES Multi-Sector General Permit

Alaska Association of Harbormasters and
Port Administrators
Wrangell, Alaska
October 26, 2010
Shane Serrano ADEC
Alaska Harbors come in different
shapes, sizes and ownerships
Alaska Harbors come in different
shapes, sizes and ownerships
Clean Water Act
 Passed by Congress in 1972 and amended several times
 Act addresses water pollution from point sources and
nonpoint sources
 Point sources are addressed through NPDES
permitting Program
 Nonpoint sources are addressed through grants to
implement Best Management Practices
National Pollutant Discharge
Elimination System (NPDES)
 Individual Permits
 Typically Domestic Wastewater Disposal
 General Permits
 Construction GP
 Multi-Sector GP
 Vessel GP
Four Questions
 What is the MSGP?
 Are You covered by the MSGP?
 What do You have to do to comply with the MSGP?
 When does ADEC assume the storm water program
from EPA?
What is the MSGP?
 Section 402(p) of the Clean Water Act directs EPA to
develop permit application requirements for
“stormwater discharges associated with industrial
activity”
 EPA developed the NPDES Multi-Sector General
Permit (MSGP) for Stormwater Discharges Associated
with Industrial Sources
 The previous version, the MSGP 2000, expired in
October 30, 2005
 In early 2009 MSGP is reissued in Alaska
Am I covered by the MSGP?
 One of 29 Industrial Sectors
 Water Transportation – Sector Q
 Water Transportation of Freight
 Ferries
 Marine Cargo
 Towing and Tugboat Services
 Marinas
 Ship and Boat Building and Repairing Yards – Sector R
Covered Discharges
 Storm water discharge associated with industrial
activity means the discharge from any conveyance that
is used for collecting and conveying storm water and
that is directly related to manufacturing, processing or
raw materials storage areas at an industrial plant. 40
CFR 122.26 (b)(14)
Coverage Required for Facilities that
Perform one or more of the
Following
 Blasting and Painting
 Material Storage
 Engine Maintenance and Repair Areas
 Material Handling
 Drydock Activities
 Pressure Washing (May need another NPDES permit)
Need to Meet All Three
Conditions
 Your Facility is included in the regulated SIC Codes
 Your Facility has regulated activities on your property
 There is a discharge of the runoff through a point
source
What do I have to do to comply
with the MSGP?
 Read the permit
 Develop a SWPPP or Revise Existing SWPPP
 Implement SWPPP and Control Measures
 Submit Notice of Intent
 Conduct Inspections
 Conduct Monitoring
 Implement Corrective Action
 Maintain Reporting & Recordkeeping
Read the Permit
 Read Sections 1-7 & 9 and section 8-sector Q or R
 Read Appendices A-K
 For details read the Fact Sheet
 Available at www.epa.gov/npdes/stormwater/msgp
 Read permit with your facility in mind
 Read Sector Q or R Fact Sheet
Developing Your SWPPP
 EPA Guidance
 Specific to Industrial
Facilities
 What to Include in
SWPPP
 Common Compliance
Problems
Elements of SWPPP
 Listing of Pollution Prevention Team
 Description of Site
 Summary of Potential Pollutant Sources
 Description of Control Measures
 List of Schedules and Procedures
 Document Eligibility Considerations
 Signature Requirements
 Additional Documentation
Additional Documentation for
SWPPP
 Copy of Notice of Intent
 Description of significant spills or leaks
 Records of employee training
 Documentation of maintenance of control measures
 Copies of inspection reports
 Description of corrective actions taken
 Documentation of any benchmark exceedances
 Documentation of status change from active to
inactive
Control Measures
Must select, design, install and implement control
measures (including BMPs) to address
*
Selection and design considerations
*
Meet the non-numeric effluent limits
*
Meet limits contained in applicable effluent
limitations guidelines
Non-Numeric Technology-Based
Effluent Limits
 Minimize Exposure
 Good Housekeeping
 Maintenance
 Spill Prevention and Response
Procedures
 Erosion and Sediment Control
 Management of Runoff
Non-Numeric Technology-Based
Effluent Limits
 Salt Storage Piles
 Sector Specific Non-Numeric Effluent
Limits
 Employee Training
 Non-Stormwater Discharges
 Waste, Garbage and Floatable Debris
 Dust Generation and Vehicle Tracking of
Industrial Materials
Erosion and Sediment Control
 Alaska Storm Water Guide
http://dec.alaska.gov/water/wnpspc/stormwater/Guidance
.html
 ADOT&PF SWPPP Guide
 www.dot.state.ak.us/stwddes/dcsenviron/resources2.shtml
#
 EPA SWPPP Guide
 http://cfpub.epa.gov/npdes/stormwater/swppp.cfm
 EPA Menu of Stormwater BMPs
 www.epa.gov/npdes/stormwater/menuofbmps
NOI Submittal to EPA
(ADEC after Oct 31, 2009)
 Existing Dischargers – In operation prior to Oct 30,
2005 and authorized under MSGP 2000
 New Dischargers – In operation in between Oct 30,
2005 and date in AK MSGP
 New Dischargers – In operation after date in AK MSGP
 Other Eligible Dischargers – In operation prior to
October 30, 2005, but not covered under the MSGP
2000 or other NPDES permit
Inspections
 Routine Facility Inspections
 Quarterly Visual Assessment of Stormwater
Discharges
 Comprehensive Site Inspections
Monitoring
 Monitoring Procedures
 Benchmark Monitoring
 Effluent Limitations Monitoring
Monitoring and Sampling
 EPA Guidance
 How to Prepare for
Monitoring
 How to Conduct
Monitoring
 How to Evaluate
Monitoring Results
 Record-Keeping
Corrective Action
 Review and Revision to Eliminate Problem
 Review to Determine if Modifications are Necessary
 Corrective Action Report
 Effect of Corrective Action
Reporting and Recordkeeping
 Report Monitoring Data to ADEC (after Oct 31, 2009)
 Send Annual Report to ADEC (after Oct 31, 2009)
 Exceedance Report for Numeric Effluent Limits
 Additional Reporting
 Recordkeeping
When Does ADEC Assume the
Storm Water Program?
 Transfer of NPDES Program started October 31, 2008
 Phase 1
 Domestic Wastewater
 Seafood Processors
 Log Transfer Facilities
 Phase 2 October 31, 2009
 Stormwater
 Phase 3 October 31, 2010
 Mining
Changes to MSGP under ADEC
 The permit will stay the same until 2013
 Monitoring data and Annual Reports sent to ADEC
 Compliance and Enforcement Inspections by ADEC
 Tidal Grid Usage Survey
 What information is available and tracked (size,
duration, activities, wasteload, etc.)
 What activities are allowed (type of maintenance)
 What measures have been employed (collect & treat)