NDEQ Industrial Storm Water

General Discharge PermitPresentation for: Nebraska Aviation Symposium

January 27, 2011

By: Bill Imig, Environmental Scientist – Olsson Associates

Permit Applicability• Sector S- Air Transportation Facilities

• SIC codes 4512-4581

451 Air Transportation, Scheduled, and Air Courier Services

4512 Air Transportation, Scheduled

4513 Air Courier Service

4522 Air Transportation, Non-scheduled

4581 Airports, Flying Fields, and Airport Terminal Services

Covered ActivitiesStorm water discharges from those portions of the air

transportation facility that are involved in: • Aircraft maintenance – includes rehabilitation, mechanical

repairs, painting, fueling• Equipment cleaning• Deicing operations

Activities Not Allowed under the Permit

• Discharges of wash water

• Discharges of deicing chemicals during dry weather

No Exposure Certification• All industrial materials and activities are protected from

exposure to rain, snow, or runoff• Industrial materials or activities include:

– Material handling equipment– Industrial machinery– Raw Materials– Products (Fuel, Oil, etc)– Waste Products

• Exceptions– Drums, Barrels, Tanks that are sealed and not leaking– Adequately maintained vehicles used for material handling

No Exposure Checklist• Using, storing or cleaning industrial machinery or

equipment or areas where residuals from industrial machinery or equipment remain and are exposed to storm water

• Materials or residuals from spills exposed to storm water• Materials or products from past industrial activities• Material handling equipment (except adequately

maintained vehicles)• Materials or products during loading/unloading or

transporting activities

No Exposure Checklist• Materials or products stored outdoors (except products

intended for outdoor use where exposure to storm water does not result in discharge of pollutants

• Materials contained in open, deteriorated or leaking storage drums, barrels, tanks and similar containers

• Materials or products handled/stored on roads or railways owned or maintained by the permittee

No Exposure Checklist• Waste materials (except waste in covered, non-leaking

containers (dumpsters)

• Application or disposal of process wastewater

• Particulate matter or visible deposits of residuals from roof stacks and or vents not otherwise regulated (under an air quality permit) and evident in storm water

2011 Draft Permit

• Replaces existing permit first issued 1997

• NDEQ will hold a public hearing February 22, 2011

• Final permit target date is April 1, 2011

• Most Significant Changes– T&E Species Impact Evaluation for New or Expanded

Dischargers– Impaired Waters, Class A, Class B– Discharge Monitoring (Visual and Benchmark)

Implementation Timeline

Will be pushed back pending issuance of the permit

Source: NDEQ

Limitations on Coverage

• Non-storm water discharges

• T&E Species and Critical Habitat Protection

• New or Expanded discharges to Impaired Waters, Class A

and B Resource Waters, Drinking Water Supplies

Allowable Non-Storm Water • Allowable non-storm water discharges

– Fire fighting– Fire suppression system flushing– Potable water line flushing except chlorination– Condensate from air conditioners, coolers, etc.– Irrigation drainage from agricultural lands– Landscape irrigation w/ approved application of fertilizer, etc.– External building wash down without detergents– Groundwater and spring water– Foundation drains if not contaminated with process water– Windblown mist from cooling towers

T&E Species Evaluation

• If you are a new or expanded discharger coverage

under general permit is only available if storm

water does not adversely impact listed species and

habitat.

• NDEQ has prepared a 9 point checklist to

determine if discharge has potential to impact

T and E Species.

Impaired, Class A &B, and Drinking Water Supply• New or Expanded Discharge to Impaired Water

– Meet TMDLs if established

• New or Expanded discharge to class A – not eligible under the general permit

• New or Expanded discharge to class B – prior written approval from NDEQ

• New or Expanded discharge to Drinking Water – prior written approval from NDEQ

Source: NDEQ

Impaired Waters

Class A & B State Resource Waters and Drinking Water

Source: NDEQ

Benchmark Monitoring

• Deicing Season- Collect samples during timeframe under which deicing activities occur (usually October – April)• At all Outfalls that collect runoff from deicing areas• Collect 4 separate samples during deicing season

Source: NDEQ

Benchmark Monitoring Results• If average of first 4 values < benchmark – done sampling

for permit term

• If average > benchmark need to reevaluate BMPs &

controls. Make revisions and continue monitoring

• Or determine no further reductions are economically

practicable or achievable and notify NDEQ

Contents of SWPPP

• Pollution Prevention Team

• Site Description – locations, activities, drainage, outfalls, etc.

• Site Map – submit copy to NDEQ with NOI

• Identify Potential Pollutants – Materials storage, Operational

Activities that are exposed to storm water

• Control Measures

• Schedules and Procedures

• Documentation

Schedules and Procedures - Controls

• Good housekeeping schedule

• Maintenance procedures schedule

• Spill prevention and response

• Training

Schedules and Procedures – Monitoring and Inspections

• Benchmark Monitoring – Seasonal during deicing operations

• Visual Assessment of Storm Water discharge– At least Quarterly

• Routine Inspections – Monthly during deicing season (usually

October – April)

• Comprehensive Inspection – Annual (during periods of deicing

operations if possible)

Documentation• T&E species evaluation

• Discharge to Impaired or State Resource Water authorization

• NOI

• NDEQ acknowledgment letter

• Best Management Practices

• Inspections

• Reports

• Corrective Action

• Monitoring Results (visual , benchmark)

Reporting• Non-compliance which may endanger health or

environment within 24-hours.

• Corrective Action – record within 24 hours, document

actions within 14 days, report to NDEQ in 30 days

• Spill / Release reporting (per Title 126, Ch. 18)

• Upon NDEQ request

Questions?