Industrial General Permit
Notice of Non-Applicability
Presented By:
Conestoga-Rovers & Associates
Fred Blickle and Michael Beerends
Air & Waste Management Association (AWMA)
Golden Empire Chapter
September 16, 2014
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Overview of CRA (a GHD Company)
• CRA originally established in 1976, over 35
years of experience with more than 50,000
successfully completed projects
• CRA merged with GHD on July 2, 2014
• Now one of the largest privately held
engineering and environmental firms with
over 8,500 people in five continents
• 370 staff in 15 California locations
(Bakersfield, Concord, Emeryville, Eureka (2),
Fresno, Irvine (2), Rancho Cordova,
Sacramento, San Diego, San Francisco, San
Jose, Santa Rosa, and Sonoma)
• One of few large consulting firms registered
to ISO 9001:2008
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Health & Safety
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Safety ranks as the highest priority commitment by CRA
Our employees are our most valuable resource and
understand that all incidents are preventable.
CRA’s Safety Performance best in industry:
Year
CRA Total Recordable
Incident Ratio (TRIR)*
CRA Experience
Modification Rate
2013
0.08
0.70
2012
0.24
0.78
2011
0.22
0.79
2010
0.34
0.75
2009
0.43
0.80
2008
0.46
0.77
* Industry Average TRIR as reported by US Bureau of Statistics is 1.3 (2011)
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Regulatory Background
The Federal Clean Water Act (1987) 40 CFR part 122
requires industries with storm water discharges to
surface waters to obtain permits under the National
Pollutant Discharge Elimination System (NPDES)
California Water Code Section 13000
California NPDES Program is part of the State
Water Board’s division of water quality
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Regulatory Update
Industrial Storm Water General Permit Updates
•Current Permit – Order 97-03-DWQ has expired
•Remains in effect until new General Permit is adopted
•New Permit - Order 2014-0057-DWQ adopted April 2014
and becomes effective July 2015
•Any facility with point source storm water discharges
associated with industrial activities, as defined in the Federal
storm water regulations codified at 40 CFR 122.26 (b) (14),
must obtain permit coverage
•http://www.swrcb.ca.gov/water_issues/programs/stormwater/industrial.shtml
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Industrial Facilities Covered
Appendix A of new Industrial Permit:
• Facilities subject to 40CFR Ch I (Cement Manu., Feedlots, Fertilizer Manu.,
Petro Refining, Phosphate Manu., Steam Elect., Coal Mining, Mineral and Ore
Mining & Process., Asphalt Emulsion, Landfills, Airport Deicing)
• Manufacturing Facilities with SIC 20XX through 39XX, 4221 through
4225
• Oil & Gas/Mining Facilities
• Hazardous Waste Treatment, Storage, and Disposal Facilities
• Landfills, Land Application Sites, and Open Dumps
• Recycling Facilities
• Steam Electric Power Generating Facilities
• Transportation Facilities
• Sewage or Wastewater Treatment Works
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General Permit Coverage
Three Options for General Permit Coverage:
1. File Notice of Intent (NOI):
a. Site Map
b. Storm Water Pollution Prevention Plan
2. No Exposure Certification (NEC)
3. Notice of Non-Applicability (NONA)
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It Does Rain in Bakersfield
Avg. ~6.50” per year.
Max Month = 6.33” (December 2010)
Highest Single Day = 2.53” (2/10/1978)
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What is a Discharge???
A Discharge occurs when storm water:
• crosses the property boundary (sheet flow);
• enters Waters of the United States (lakes, ponds,
rivers, streams, tributaries and wetlands) which
can happen on the surface or below ground; or
• enters a municipal separate storm water system
(that discharges to Waters of the US)
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Storm Water Pollutants
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Hydrocarbons (e.g. fuel, oil and grease)
Toxics (e.g. pesticides, solvents, paint)
Organics (oxygen demanding substances)
Nutrients (e.g. phosphorus and ammonia)
Pathogens (e.g. bacteria and viruses)
Sediment (silt and clay colloids)
Salt (chlorides and other ions)
Accidental Spills, leaks from piping
Other related products/by products
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Sources of Storm Water Impacts
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Paved areas (roads, parking areas, etc).
Unpaved areas (highly compacted and void of vegetation)
Roofs (eaves, rain gutters)
Material handling activities exposed to storm water
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Vehicle fueling and cleaning areas
Cullet Piles
Storage of chemicals
Storage of fuels, oil
Storage of scrap metal
Transformers
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Notice of Non-Applicability (NONA)
Facilities claiming “No Discharge” must:
1. Be engineered and constructed to contain the
maximum historic precipitation event; or
2. Located in basins or physical locations not
hydrologically connected to water of the United States;
and
3. Submit and certify via SMARTS both the NONA and a
No Discharge Technical Report if requested by the
Regional Board
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No Discharge Technical Report
Facility Containment Design including:
1.
2.
3.
4.
5.
6.
7.
8.
Survey of existing stormwater retention systems
Hydrologic analysis of tributary watershed
Stormwater retention system capacity analysis
Soil permeability analysis
Soil stability analysis
Receiving water evaluation (above- and below-ground)
Safety factor considerations (freeboard)
Certified by California Licensed Professional Engineer
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Capacity and Drainage Survey
Survey:
1. To determine capacity of retention basin
2. To determine storm water flow patterns and directions
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Hydraulic Calculations
Calculations:
1. Hydrologic modeling of watershed:
a.
b.
c.
Determination of total tributary area (facility and run-on)
Evaluation of watershed (land uses and soil types)
Maximum Historic Precipitation Event (MHPE) values based
on NOAA data
a.
d.
Recommend to default to local standards if more stringent than MHPE
Design storm event volumes
2. Retention System Capacity Analysis
1.
2.
Stage-Storage of existing or proposed retention system based
on survey
Comparison against design storm event volumes
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Soil Determination
Soil Permeability and Stability:
1.
2.
3.
4.
5.
Retention system soil types
Retention system infiltration rates
Basin plan limitations
Depth to groundwater
Potential impacts to groundwater
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Reporting Requirements
NONA and No Discharge Technical Report:
1. Certified and submitted via SMARTS by facility LRP
within 60-days of being requested by the Regional
Board
2. Signed by a California Professional Engineer
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Additional Considerations
“No Discharge” determination does not cover storm
water containment systems the transfer industrial
pollutants to groundwater.
• Must determine if infiltration may discharge to and
contaminate groundwater
– Permit does not provide guidance for determination
• Facilities that have not eliminated discharges subject
to the General Permit are ineligible to submit a
NONA
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Best Management Practices
Best Management Practices (BMPs) are measures
which may be implemented to prevent or mitigate
pollution from activities performed at a facility. They
are broad measures including process, procedures,
schedule of activities, prohibitions, and other
management procedures which prevent or reduce
storm water pollution.
 Good Housekeeping
 Preventative Maintenance
 Visual Inspections
 Spill Prevention/Response
 Sediment/Erosion Control
 Training
 Record Keeping
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Facility Controls
Structural Controls
• Preventative Measures (signs, labels, and security)
• Diversions (conveyances, dikes, grading, sloping,
and pavements)
• Containment (secondary containment, curbs, and
drip pans)
• Other Controls (sumps, pumps, separators and
basins)
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Routine Inspections
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Outfalls
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Drum storage areas •
Containment areas •
Drainage
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Sediment basin
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Retention ponds
Shipping/Receiving
BMPs
Vehicle washing
Catch basins
Haz waste storage
Cullet storage
AST’s
Fueling areas
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Reporting Releases or Discharges
• Reported to Regional Water Board
• Reported within 24 hours if human health or
environment issue
• Written submission:
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Description of release
Date and time of release
Measures taken to stop, and prevent recurrence
Inspection reports (annual & routine)
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Industrial Storm Water Permit
• Q&A / Thank you for having us AWMA!
• Fred Blickle 313-506-9799
• Mike Beerends 559-286-9999
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