Safe Operating Procedure (Revised 6/15) DEWATERING _____________________________________________________________________ Introduction Certain provisions of the Clean Water Act and related federal, state, and local regulations and ordinances are intended to protect the quality of surface waters (e.g., lakes, streams, rivers, etc.) by regulating certain activities having the potential to discharge pollutants. Dewatering has the potential to introduce contaminants into surface waters. Potential contaminants include: petroleum hydrocarbons, total suspended solids from sediment discharges, metals, organics and high or low pH based on soil and groundwater characteristics. Therefore, dewatering activities are subject to authorization by permit and compliance with permit conditions. Dewatering Activities Conducted by Contractors: If construction excavation dewatering of groundwater or groundwater mixed with stormwater is conducted by a contractor, the contractor is responsible for attaining proper permit authorization and complying with the terms of the permit. De-watering of construction excavations containing groundwater or groundwater mixed with stormwater must be authorized by NDEQ through one of the following permits: 1. NDEQ has established a General NPDES Permit for Dewatering (NEG671000), which covers both groundwater and groundwater mixed with stormwater from dewatering on construction sites, foundation drains, utility vaults, or wells. This general permit can be found on NDEQ’s web site. 2. Coverage under NEG671000 is not necessary if a site is covered by a General NPDES Permit Authorizing Storm Water Discharges Associated with Construction Sites (NPDES #NER110000) so long as specific Best Management Practices (BMPs) related to dewatering have been incorporated into the site’s Stormwater Pollution Prevention Plan (SWPPP). See EHS SOP, Construction Site NPDES Permits. Coverage under a General NPDES Permit for Dewatering (NEG671000) is not necessary for dewatering of only stormwater on construction sites less than an acre. Discharges are authorized under UNLs Small Municipal Stormwater System (SMS4) permit. The water must be void of color, turbidity, odors, surface sheens, films, or other unusual condition (e.g., off-gassing, foaming, etc.) otherwise alternative disposal measures must be in place. For sites greater than one acre, dewatering of stormwater, (Created 5/15) UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu groundwater, or groundwater mixed with stormwater must be in accordance with the site’s Stormwater Pollution Prevention Plan (SWPPP). Dewatering Activities Conducted by UNL Employees: If construction excavation dewatering of groundwater or groundwater mixed with stormwater is conducted by a UNL employee on UNL property, then EHS is responsible to obtain coverage under NDEQ’s General NPDES Permit for Dewatering (NDEG671000), by submitting to NDEQ a Notice of Intent (NOI). UNL employees intending to engage in dewatering must contact EHS before initiating dewatering actions, and implementing appropriate Best Management Practices (BMPs) during the dewatering activity. EHS will advise on the appropriate BMP selection based on sitespecific conditions. Possible BMPs include the following: • • • • • Sediment Bags: Direct the discharge flow through a sediment bag. This allows sediments to settle prior to discharging into surface waters. Flocculants: Disperse flocculant (see manufacturers recommendation on dose) over the excavation/utility vault that needs to be dewatered. Allow time for flocculant to bond to clay particles in soil. This will result in lower suspended solids. Carefully start pump and discharge. Vegetative Buffer/Land Application: Reuse water (i.e., for watering plants, or dust control) or dewater to a vegetative buffer (grassy swale), provided the following conditions are met: o Land application shall not be conducted when the ground is frozen or saturated. o Land application sites shall have a slope of 12% or less. o Land application shall not occur on sites where the water table is less than 4 feet from the surface. o The total hydraulic application rate shall not exceed 2 inches per acre (54,304 gallons) per week. o Land application sites shall be free of perennial or intermittent streams, ponds, lakes, or wetlands. o Land application is not allowed on crops that are intended for distribution in their raw form for direct human consumption (e.g., fresh produce). o Land application must cease immediately if any adverse impacts to animal or plant life is discovered or if any film, foam, color, or noxious odors occur, of if erosion, channelization, ponding, or surface runoff occurs. Drum: Dewatering into a 55-gallon drum. Allow sediments to settle prior to discharging. This is feasible when dewatering small volumes of water. Discharge Point: Ensure a BMP is utilized to address for concentrated flow. Force from discharging large amounts of water can itself result in erosion at the discharge point. Coverage under NDEQ’s General Dewatering Permit also requires sampling. EHS will collect the necessary samples or advise on appropriate sample collection based on sitespecific conditions (e.g., including physical characteristics examination, total suspended solids, pH, flow, petroleum hydrocarbons, etc.). Following sampling, EHS is responsible (Created 5/15) UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu to file Discharge Monitoring Reports, as necessary. Additional information on requirements associated with NDEQ’s General Dewatering Permit can be found in Attachment 1. Foundation Drains, Vaults, Tunnels Dewatering of uncontaminated accumulated storm and ground water from foundation drains, and utility vaults and tunnels conducted by UNL employees is covered under UNL’s Small Municipal Stormwater System (SMS4) permit rather than NDEQ’s General Dewatering permit as an allowable non-stormwater discharge (per NDEQ correspondence 5/16/12). If an illicit discharge is detected, sampling will be conducted by EHS and corrective actions will be implemented. Stormwater Dewatering At times, it may be necessary to remove flood or accumulated stormwater from areas on campus. There are three options: 1) direct the flow to a sanitary sewer; 2) direct the flow towards vegetation for land application wherein no water discharges to the storm drain; 3) direct the flow to the storm drain under the authority of UNL’s SMS4 permit. If discharged directly to the storm drain, the water must be void of color, turbidity, odors, surface sheens, films, or other unusual condition (e.g., off-gassing, foaming, etc.). No sampling is required for this type of dewatering, and the PCE does not need to be recorded. However, if the presence of pollutants are detected, water may not discharge to storm drain and alternative actions must be taken. (Created 5/15) UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu Attachment 1 NEG671000 General Dewatering Permit Notice of Intent (NOI). If dewatering under NDEQ’s General Dewatering Permit, a NOI must be submitted to NDEQ. However the NOI can be submitted after dewatering activities have been initiated. The NOI form is found in Attachment 1 of the General NPDES Dewatering Permit. The NOI requires the permittee to determine: • Whether the receiving water body is a State Resource Water (listed in Appendix B of the permit; note that discharges to a State Resource Water require prior approval from NDEQ) or listed lake or impounded water (Title 117, Chapter 6). On City and East Campuses these are not likely. • Whether there is likely impact to historic sites by consultation with Nebraska Historical Society. Again, on City and East Campuses this is unlikely. See http://www.nebraskahistory.org/histpres/nebraska/index.shtml for a map of historical places. • Whether there is likely impact to threatened or endangered species or their habitat by Consultation with Nebraska Game and Parks. On an annual basis, EHS obtains a blanket determination for City, East, and Innovation Campuses for this requirement. http://outdoornebraska.ne.gov/wildlife/programs/nongame/consultation.asp Sampling and Discharge Monitoring Reports (DMR). The General Dewatering permit requires sampling during dewatering activities. Sampling results must be reported to NDEQ on a DMR and submitted quarterly. The DMR form provided as Attachment 3 to the General Permit must be used. The DMR must be accompanied by a Physical Characteristic Examination (PCE) Form (Attachment 4 to the General Permit). NDEQ’s General Permit specifies monitoring parameters, frequency of sampling, and type of sample. Sampling parameters include PCE, flow, petroleum hydrocarbons (if a sheen is present), total suspended solids, and pH. NDEQ may also require metals and organics, but this is determined on a case-by-case basis (for ongoing discharges). Sampling must occur before the discharge mixes with or reaches a water of the state (generally at the point where it enters the storm sewer system). • Sampling Requirements; o Samples are to be delivered to the NE State Laboratory located at 3630 South 14th Street- 402-472-3935. It is advised to contact the lab prior to submittal of the samples to ensure personnel are available. o Sample requirements for lab; this includes holding time, container type and sample volume requirements: o pH: 15 minutes, glass/plastic, 100mL. o TSS: 7 days, glass/plastic, 1 liter. o Petroleum Hydrocarbons: 7 days, Glass with Teflon-lined cap, 50mL, cool to 4 C. o Metals and Organics: this is determined by NDEQs requested analysis. o Chain of Custody Form: accurately complete COC form and file with analytical results. (Created 5/15) UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu • • Non-Compliance Report (NCR). This is required if the sampling results are not within permit requirements. NCR is also used when a discharge occurs where a sample was not taken. EHS is responsible to file NCR reports with NDEQ. NDEQ must be called within 24-hours of the non-compliance action and a written NCR submitted within 5 (business) days of the event. Attachment 5 of NDEQ’s General Permit contains a NCR form. Notice of Termination: There is no termination form. The permit is discontinued by requesting termination in the DMR or cover letter to the DMR. Written notice of termination must be provided to NDEQ within 30 days after discontinuing dewatering activities. (Created 5/15) UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu