UIC Stormwater Monitoring Plan - Department of Environmental

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Underground Injection Control Stormwater Monitoring Plan
Individual WPCF Permit for Class V Stormwater Underground Injection Control Systems
Applicant:
Applicant
Street Address
City, State ZIP
Permit Number:
XXXXXX
WQ File Number:
XXXXXX
Date:
MM/DD/YYYY
Prepared By:
Consultant Company or Applicant
Instructions (do not include in final document):
1. This document is a template for a UIC Stormwater Monitoring Plan that meets
Schedule B, condition 2 of an individual UIC WPCF permit issued by the Oregon
Department of Environmental Quality. The document does not meet requirements for
MS4 stormwater monitoring, and should not be used by permittees planning to use a
combined MS4/UIC monitoring approach. This document should be modified so it is
customized to the applicant.
2. The YELLOW TEXT needs to be updated by the permittee.
3. Comment bubbles provide instruction to the permittee.
CERTIFICATION
“I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.”
Signature
Name
Title
Signature
Date
Page | 2
Table of Contents
1 Introduction .................................................................................................................. 3
2 Sampling Procedures ................................................................................................... 3
3 Quality Assurance / Quality Control .............................................................................. 7
4 Reporting ..................................................................................................................... 7
Tables
Table 2-1
Analytical Methods, Reporting Limits and Action levels
Table 2-2
UIC Sampling Locations
Table 2-3
Sample Containers, Preservatives and Holding Times
Page | 3
1 Introduction
Permitee owns and operates approximately X Underground Injection Control (UIC) devices that
manage stormwater runoff by infiltrating it into the subsurface. The UICs drain stormwater from
X. Information about the permittee’s UIC inventory is presented in its System-Wide Assessment
(author, date).
Permittee applied for a UIC Water Pollution Control Facilities (WPCF) permit for its UICs on
date, and expects to receive its permit on date. Schedule B, condition 2 of the permit requires
that the permittee develop a UIC Stormwater Monitoring Plan that describes how the permittee
will monitor stormwater.
The goal of the UIC Stormwater Monitoring Plan is to ensure that stormwater infiltration occurs
in a manner that is protective of human health and the environment. The objectives of the UIC
Stormwater Monitoring Plan are:



Demonstrate compliance with the action levels in Table 1, Schedule A of the permittee’s
UIC WPCF permit;
Develop a dataset that can be used to evaluate the environmental risk of stormwater
pollutants in permittee’s jurisdiction; and
Develop a dataset that can be used to adaptively manage permittee’s stormwater
monitoring program.
This UIC Stormwater Monitoring Plan is organized into the following sections:




Section 1: Introduction.
Section 2: Sampling Procedures. Summarizes procedures used to during stormwater
quality sampling.
Section 3: Quality Assurance/Quality Control. Discusses procedures to ensure data
quality achieves monitoring plan objectives.
Section 4: Reporting. Discusses reporting of data collected as a part of the monitoring
plan.
2 Sampling Procedures
This section discusses the pollutants that will be monitored (Section 2.1), UICs that will be
sampled (Section 2.2), schedule for sampling (Section 2.3), and field methods (Section 2.4).
2.1 Monitored Pollutants
Table 2-1 shows the pollutants that will be monitored, the analytical methods that will be used
by the subcontracted laboratory to analyze the pollutants, the method reporting limit for each
pollutant, and the action level for each pollutant.
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Table 2-1
Analytical Methods, Reporting Limits and Action Levels
Permittee
Monitoring Parameter
Analytical Method
Benzo(a)pyrene
PCP
DEHP
Lead (Total)
Zinc (Total)
Copper (Total)
Other
X
X
X
X
X
X
X
Method Reporting Limit
(µg/L)
X
X
X
X
X
X
X
Action Level
(µg/L)
X
X
X
X
X
X
X
Notes:
PCP = Pentachlorophenol
DEHP = di(2-ethylhexyl)phthalate
ug/L=micrograms per liter
The pollutants in Table 2-1 were selected for monitoring on the basis of stormwater quality data
and pollutants that are likely to be present with a UIC drainage basin. The following pollutants
were selected on the basis of stormwater data in Oregon indicating that these pollutants exceed
regulatory screening levels1 more than one percent of the time2:



Lead. Used in car batteries and ubiquitous in the environment.
Pentachlorophenol (PCP). Used as a wood preservative on utility poles.
Di(2-ethylhexyl)phthalate (DEHP). The most common of phthalates used as
plasticizers; present in PVC, hydraulic fluid, and capacitors.
In addition to the pollutants that exceed regulatory screening levels at a relatively higher
frequency, the following pollutants are identified as likely to be present in stormwater on the
basis of the UIC drainage basin type:




Benzo(a)pyrene. Detected as a result of incomplete combustion of hydrocarbons (i.e.,
exhaust fumes).
Copper. Detected as a result of its use in automobile brakes.
Zinc. Detected as a result of its use in automobile brakes and tires.
Other. Rationale.
Sampling for these pollutants will be re-evaluated after two years of sampling and four samples,
in accordance with Schedule A, condition 2 of the permittee’s permit.
1
2
Maximum Contaminant Levels or Reference Levels in OAR 340-040-0020
Kennedy/Jenks, 2009
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2.2 Sampling Locations
Sampling locations were selected using a risk-based approach, meaning that the UICs that
were selected for sampling pose a higher risk of adverse environmental impact because they
are more likely to contain higher pollutant concentrations. The relative risk posed by UICs was
identified on the basis of information presented in the System-Wide Assessment (author, date).
The following risk factors were used to select UICs for sampling:




Sampled UICs are located on streets and parking lots with over 1,000 vehicle trips per
day;
Sampled UICs are not equipped with pretreatment;
Sampled UICs have relatively less vertical separation distance between the bottom of
the UIC and groundwater; and
Sampled UICs have relatively less horizontal separation distance between the UIC and a
water well.
UICs that will be sampled are shown in Table 2-2 and Figure 2-1.
Table 2-2
UIC Sampling Locations
Permittee
ID
Latitude / Longitude
TPD
X
X
X
X
X
X
X
X
X
Drainage
Basin
Type
X
X
X
Pretreatment
X
X
X
Separation Distance
Vertical
Horizontal
(feet)
(feet)
X
X
X
X
X
X
Notes:
TPD = Vehicle trips per day
2.3 Sampling Schedule
The UICs that will be sampled are listed in Table 2-2. The UICs will be sampled twice annually
during two separate storm events. The annual sampling year extends from July 1 to June 30 of
the following year. Additional samples may be collected in the event of an action level
exceedence, in accordance with Schedule A, condition 6.d of the permittee’s permit.
If the permittee is unable to collect the required samples due to drought or other conditions, the
permittee will include a discussion of the missed samples in the annual UIC Stormwater Report.
2.4 Sample Collection Methods
This section discusses the methods used to collect stormwater samples, including criteria for
mobilizing to the field, sampling equipment that is used, health and safety considerations, and
sampling techniques.
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Sample Collection Criteria
Sample collection criteria are established because the permittee needs to target a storm that is
likely to produce sufficient runoff for sampling. The following criteria will be used to target storms
for sampling:




Antecedent dry period is at least 6 hours (defined as <0.1 inches of precipitation over the
previous 6 hours);
Predicted rainfall duration is at least 3 hours;
Predicted rainfall amount is over 0.1 inches within a 12 hour period; and
Precipitation potential for rain is over 70%
The permittee will attempt to sample the first predicted storm in late summer/early fall that
meets the conditions above in order to characterize “first flush” runoff.
Sampling Equipment
The following equipment will be taken into the field to collect samples:
 Item 1
 Item 2
 Etc.
Health and Safety
X
Sample Containers, Preservatives and Holding Times
Sample containers will be obtained from the analytical laboratory, pre-cleaned and (if
necessary) pre-preserved. Table 2-3 lists the sampling containers, preservatives, and sample
holding times that will be used for each pollutant.
Table 2-3
Sample Containers, Preservatives and Holding Times
Permittee
Pollutant
Benzo(a)pyrene
PCP
DEHP
Lead (Total)
Zinc (Total)
Copper (Total)
Other
Sample Container
X
X
X
X
X
X
X
Preservative
X
X
X
X
X
X
X
Holding Time
X
X
X
X
X
X
X
Notes:
PCP = Pentachlorophenol
Page | 7
DEHP = di(2-ethylhexyl)phthalate
Sampling Techniques
Stormwater grab samples will be collected from the end-of-pipe (i.e., the pipe where the
stormwater enters the UIC). Stormwater will be collected by lowering a decontaminated
stainless steel container into the UIC, and allowing water from the end-of-pipe to fill the
container. The stainless steel container will then be raised to ground surface, and stormwater in
the stainless steel container will then be transferred to laboratory-supplied containers listed in
Table 2-3. When lowering and raising the stainless steel container, care will be taken to
minimize contact between the container and the UIC and ground.
After collection, stormwater samples will be labeled using the following format: U-SW-IDdate(D), where:





U indicates that the sample is from a UIC,
SW indicates that the sample is a stormwater sample,
ID is the UIC identification number,
Date is the date the sample was collected
D indicates whether the sample is a duplicate (see Section 3.2).
For example, the stormwater sample collected from UIC 39 on April 13, 2015 will be labeled USW-39-04.13.15. If a duplicate sample is collected, the sample will be labeled U-SW-3904.13.15(D). X. Samples will be placed in an ice-chilled cooler, and transferred to the analytical
laboratory under chain of custody procedures.
3 Quality Assurance / Quality Control
Quality Assurance/Quality Control are protocols that are followed by field personnel to ensure
that the field procedures produce reliable data that is of sufficient quality to achieve the
monitoring plan goals.
3.1 Subcontracted Laboratory
Stormwater quality samples will be submitted to an Oregon Laboratory Accreditation Program
(ORELAP) accredited laboratory. The laboratory will perform its internal Quality
Assurance/Quality Control (QA/QC) procedures which are available to DEQ upon request.
3.2 Duplicates, Blanks and Indicators
Field Duplicates
A field duplicate is an additional stormwater sample collected by the same sampling team, at the
same time and place. A field duplicate will be collected once each year. If pollutant
concentrations in the duplicate sample and original sample are significantly different, the
permittee will recheck data validity with the laboratory.
Temperature Indicator
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Temperature indicators are water-filled volatile organic analysis (VOA) vials provided by the
laboratory. When the laboratory receives sample bottles, it measures the temperature of the
water in the indicator vial to ensure that samples were transported under the appropriate
temperature conditions, which is between 2 and 6 degrees Celsius. The temperature blank will
be transported to the field along with sample bottles, and will be shipped to the laboratory in the
cooler along with stormwater samples.
Equipment Blank
Equipment blanks are indicators of the effectiveness of equipment decontamination. An
equipment blank will be collected by pouring pollutant-free water into the stainless-steel
container, and transferring the water into laboratory-supplied bottles for analysis. The pollutantfree water will be provided by the laboratory or will be distilled de-ionized water purchased from
a store. One equipment blank will be collected for each sampling event.
4 Reporting
Stormwater quality data will be submitted in the permittee’s annual UIC Stormwater Report, in
accordance with Schedule B, condition 4.a of the permit, including:

A table showing stormwater quality results, including detected concentrations, method
reporting limits, and exceedences of action levels in Table 1, Schedule A.

Samples that could not be collected and reason(s) why the sample could not be
collected.
In accordance with Schedule B, condition 4.i of the permit, copies of laboratory analytical
reports will not be submitted with the annual UIC Stormwater Report, and will be retained as
described in Schedule F, condition 3.
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References
Author, date. Title.
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