“lessons learned from npdes stormwater audits and ... · within the ms4 area be informed about...

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“Lessons Learned from NPDES Stormwater Compliance Audits and Inspections”

Or“Am I ready for an Audit…….TODAY?!”

2017 INDIANA ENVIRONMENTAL CONFERENCE

The Starting Blocks

Pulling it All Together

Audit Prep Tools & Tips

Industrial Facility Stormwater Inspections

Audit Prep Resources

Construction Stormwater Permit

Municipal (MS4) Stormwater Permit

Turn over to Randy

Session Agenda

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The Starting Blocks ‐‐ Getting Ready for the Audit

“What will the audit cover??!”

TWO areas:

1. Overall permit compliance documents review and

2. Facilities & Operational Areas (that have potential stormwater contamination issues – Maintenance, Fueling, Chemical & Material Storage, etc.)

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The Starting Blocks ‐‐ Getting Ready for the Audit

“Where do I start??!”

Focus on what you may be audited on:

• Your CURRENT Facility Permit Records

• Your NPDES Industrial SWPPP & Monitoring Data; Quarterly Self‐inspection Reports

• Your last Annual Report

• Your last agency Audit Reports

• “No Exposure Exemption” Records

Pulling It All Together

This audit process is a review of your permitcompliance and the documentation that youhave to support your BMPs.

Organize your documents and your colleagues:

• Audit Prep Matrix/Binder Index

• Rule 6 Responsibility Org Chart

• Engaging Your Colleagues

• Preparing Staff for the Audit

• On the ‘Day of the Audit’

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What do I need? Is it in there somewhere?

Binder Index; Organizing Your Data

Organize Your Documents in Accordance with Rule, Regulatory, or Permit Language

Tab 1

Tab 2

Tab 3

Tab 4

Tab 5

Tab 6

Detailed Company Overview with Org Chart & NOI

Facility SWPPP Supplements & Updates

Monitoring Data

Quarterly Inspection Records

Training Records

Annual Reports

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Stormwater Permit Responsibility Chart

Engaging Your Colleagues – Make it Easy

• Make Stormwater Compliance Easy forthem

• What tools/assistance do they need?

• You are building a good workingrelationship

• Help them to “Rehearse” for Audit Day

• Make them feel engaged & importantto your overall program

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Engaging Your Colleagues – Audit Documentation

• Work Orders Example – How do we PROVEthat separate storm activities such asmaintenance of BMPs are done?

• What format?

• Electronic? Can you do screen captures?

• Do they use work codes? Are your timesheetscoded?

• Can you make up some “Case Studies” asexamples?

Preparing Your Staff for the Audit

STAFF TRAINING (Annual & On‐going)Who needs “trained”?

• Anyone dealing with the implementation of the stormwater program

Does everyone need the same training?• NO!!

What if I am behind on training?• Get something scheduled & be prepared

to submit a training schedule to your regulatory agency

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STAFF TRAINING – Sample Questions/Topics• Where does my floor drain or outside inlet drain to?• What is an illicit discharge?• Who are we supposed to call or what are we

supposed to do if we see something “weird”?• What types of BMPs are allowed/not allowed?• How do we clean up spills and leaks?• Why do we have oil/water separators?• Why should we care about fish and bugs?• How do I personally impact stormwater quality?


STAFF TRAINING (Annual & On‐going)Where can we send our staff for training?• Stormwater Consultants• Videos (You Tube, internet, DVDs, etc.)• Commercial Lunch and Learn• Field visits with more experienced staff• State/Regional meetings• Professional Organizations• Professional Certifications

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On the “Day of the Audit”

KEEP CALM!!!!• Stay Organized!• Listen carefully• Precisely answer questions• Have management stop by• Have other departmental staff attend• Use the audit as a training &

funding opportunity

Conducting Facility Inspections ‐ Forms

Inspections of Stormwater BMPs – EPA Example

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Conducting Facility Inspections ‐ Forms

Visual Inspections of Outfalls & Discharge – WDNR Example

Conducting Facility Inspections

• Four Areas of Inspections

• Inspection Photo Summaries

• Potential Audit Questions during Facility Inspections

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OUTER PERIMETER FACILITY YARD BUILDING PROCEDURES

Four Focus Areas of Quarterly Facility Inspections

FACILITY YARD BUILDING PROCEDURES


• Evidence of Possible Contaminated Runoff (Visual Outfalls Inspection)• Perimeter is Adequately Maintained• Designated Release Points Functioning Properly

OUTER PERIMETER

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OUTER PERIMETER BUILDING PROCEDURES


• Stormwater Conveyances Appear in Working Order• Refueling Areas are Properly Managed• Dumpsters are Covered & Not Leaking• Stockpiles are Properly Managed

FACILITY YARD

OUTER PERIMETER FACILITY YARD PROCEDURES


• Building Drain BMPs• Vehicle Maintenance BMPs• Liquid Material Storage• Dry Material Storage

BUILDING

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OUTER PERIMETER FACILITY YARD BUILDING


• SWPPP Available• MSDS Sheets Available• Maintenance Documents

PROCEDURES

Audit Prep Resources

Resource guides for Industrial Stormwater Audits include:

• EPA SWPPP Guidance

• EPA Sampling Guidance

• EPA No Exposure Guidance

• EPA Industrial Stormwater Fact Sheet Series

• Printers' National Environmental Assistance Center (PNEAC)

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www.epa.gov/npdes/stormwater‐discharges‐industrial‐activities

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Printers' National Environmental Assistance Center (PNEAC)

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EPA Guidance on MS4 Implementation

6 MINIMUM CONTROL MEASURES (MCMs):

MCM 1: Public Education and Outreach

MCM 2: Public Participationand Involvement

MCM 3: Illicit Discharge Detection and Elimination

MCM 4: Construction Site Runoff Control

MCM 5: Post‐Construction Runoff Control

MCM 6: Pollution Prevention and Good Housekeeping

MS4 Permit Elements Related to Industries








MCM 1 Requirements:Residents, visitors, public serviceemployees, commercial and industrial facilities, and construction site personnelwithin the MS4 area be informed about theimpacts that polluted storm water runoffcan have on water quality and ways theycan minimize their impact on storm waterquality.

MCM 2 Requirements:Opportunities are given to constituentswithin the MS4 area to participate in thestorm water management programdevelopment and implementation.


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MCM 3 Requirements:Development and implementation of astrategy to detect and eliminate illicitdischarges to the MS4 conveyance.

Typical Implementation Activities:

GIS Mapping of Stormwater Outfalls Regular Inspections of Outfalls Citizen Reports of Pollution Issues

“The plan developed under subsection (d) must identify all active industrial facilities within the MS4 area that discharge into an MS4 conveyance. This identification shall include the facility name, address, telephone number, and Standard Industrial Classification (SIC) code. Updated information regarding active industrial facilities must be submitted in each annual report.”









MCM 4 Requirements:Development of an ordinance andestablishment of a construction programthat controls polluted runoff fromconstruction activities that disturb one ormore acres of land in the MS4 area.

MCM 5 Requirements:Development of an ordinance andestablishment of a post‐constructionprogram that addresses runoff from newdevelopment and redevelopment areas.

“An MS4 operator shall submit a monthly construction site project summary to the department containing a listing of all project names associated with section 15 of this rule, the project address, project duration, and an indication of enforcement actionsundertaken.”


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How does Rule 5 work with MS4 construction & post‐construction programs?

• If your project is located within an MS4’s jurisdictional area, then you must follow local ordinance requirements

• MS4 ordinances must contain all of the Rule 5 requirements but they can also be more stringent

• Projects in MS4 areas are subject to MS4, IDEM, and EPA requirements and inspection








MCM 6 Requirements:Development and implementation of aprogram to prevent or reduce pollutedrunoff from municipal operations within theMS4 area.

Typical Implementation Activities:

Inspect & Clean Stormwater Conveyances

Street Sweeping Program Spill Prevention Training at Municipal

Facilities

“Number and location of MS4 area outfalls mapped.”


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Questions?

Lori Gates, CPESC, CPSWQ, CPMSM, CESSWI lgates@cbbel‐in.com(317) 266‐8000

Industrial Storm Water Permits and Compliance

Indiana Department of Environmental ManagementOffice of Water Quality

Surface Water, Operations, and Enforcement BranchWetlands and Storm Water Section

Randy Braun, CPESC, CPMSM, Section Chief

IDEM Storm Water Program

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Compliance• Develop and implement a storm water pollution prevention plan (SWP3)

• Manage operations and utilize pollution prevention measures as identified in the SWP3 and as dictated by sampling results

• Target pollutants of concern

• Isolate discharges associated with other pollutants

• Treat storm water run‐off prior to discharge

• Utilize a treatment train to maximize pollutant removal

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Focus of Regulatory Inspections

• Review storm water pollution prevention plan

Plan is being utilized to manage facility operations

Plan is being updated in relation to sampling, quarterly visual inspections, and operations at the facility

Facility improvements, including installation of storm water measures or a change in operational activities

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Focus of Regulatory Inspections• Review sampling data

U.S. EPA has established pollutant benchmarks for storm water discharges

IDEM recommends that these benchmarks are utilized to assess pollutant reduction goals

Discharges above the benchmarks indicate that operations at the facility warrant corrective action

• Review quarterly visual inspection reports

• Review employee training records and program implementation

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Focus of Regulatory Inspections• Assess the overall general condition and operational management of the facility:

Indicator of potential violations

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Focus of Regulatory Inspections• Assess facility drainage system, including:

Conveyance systems

Inlets

Outfalls

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Permit Requirements• Examples of outfalls

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Focus of Regulatory Inspections• Verify outfalls identified in the permit application and others associated with the facility:

Identify and characterize each outfall

Assess industrial activities within the drainage area of each outfall

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Focus of Regulatory Inspections• Assess the condition of conveyances and outfalls, specifically related to erosion and visible staining

• Identify any visible discharges

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Focus of Regulatory Inspections• Visible erosion and sediment discharges to waters of the state

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Focus of Regulatory Inspections• Evidence of past spills

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Focus of Regulatory Inspections• Management of stockpiles (salt, sand, etc.)

• Internal floor drains that are associated with industrial activities that are not sealed and do not discharge to sanitary

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Focus of Regulatory Inspections• Vehicle and equipment maintenance area:

Fueling

Maintenance bays

Vehicle wash areas and use of detergent, solvents, etc.

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Focus of Regulatory Inspections• Material handling, including loading/unloading areas:

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Focus of Regulatory Inspections• Proper containment areas for drums, tanks, containers, material storage, etc.:

Manage run‐off and eliminate run‐on

Curbing

Diking

Secondary containment

Shelter/cover

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Focus of Regulatory Inspections• Proper containment areas

• Secondary containment as required by 327 IAC 2‐10 and other regulations

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Focus of Regulatory Inspections• Spill prevention and response procedures

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Focus of Regulatory Inspections• Management of waste, garbage etc.:

Storage management and techniques

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Focus of Regulatory Inspections• Vehicle tracking of industrial materials and/or soil

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Focus of Regulatory Inspections• Maintenance of installed measures, outfalls, etc.

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Focus of Regulatory Inspections• Management of storm water run‐off:

Diversions

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Focus of Regulatory Inspections• Indication of potential problems:

Poor facility management

Significant change in facility operations that changes the quantity or nature of pollutants discharged

Exceedance of benchmarks without initiation of corrective action or a plan to take action

• Permit violations:

Storm water pollution prevention plan out of date

Failure to perform sampling and/or quarterly monitoring

Unauthorized release or discharge

Control measures are not properly operated and maintained

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Storm Water Technical Resources

• Industry publications:

Erosion Control Journal

Stormwater Journal

Storm Water Solutions

• IDEM publication:

Indiana Storm Water Quality Manual

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Indiana Storm Water Quality Manual

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Planning Principles:• Layout and Design• Resource Inventory• Plan Design Elements

Project Management:• Monitoring• Maintenance

Storm WaterQuality Measures:• Construction • Post‐construction

www.idem.IN.gov/stormwater/2363.htm

Storm Water Program StaffSection Chief

• Randy Braun, CPESC, CPMSM, (317) 234‐3980, [email protected]

Storm Water Permit Coordinator • Sara Brandau, (317) 233‐1864, [email protected]

MS4 Coordinator• Staci Goodwin, (317) 234‐1601, (317) 502‐0120, [email protected]

Storm Water Specialists (Field Staff)

• Rob Beck, CESSWI, (317) 690‐8805, [email protected]

• Ronnie Boehm, CPESC, (812) 380‐2302, [email protected]

• Alexandra (Allie) Gates, (317) 234‐3516, [email protected]

• Ericka Schmid, CESSWI, (317) 273‐9325, [email protected]

• Samantha Wickizer, (812) 358‐2027, [email protected]

• Doug Wolf, CPESC, (317) 690‐8432, [email protected]

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Storm Water Program Contact Information

Central Office Mailing Address:IDEM – Office of Water Quality100 North Senate AvenueIGCN 1255Indianapolis, Indiana 46204

Toll Free Phone:(800) 451‐6027

IDEM Storm Water Website: www.idem.IN.gov/stormwater

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The Compliance and Technical Assistance Program (CTAP) provides assistance to help Indiana businesses understand and comply with environmental regulations. CTAP is:

• Nonregulatory – CTAP staff members are not regulators and do not have regulatory authority. Therefore, businesses will not be penalized for reporting relevant environmental information to CTAP when requesting assistance.

• Free and Confidential –While CTAP staff members serve as liaisons between the regulatory programs and businesses, they do not provide any details about the company to regulators, as the informa‐tion is protected under Indiana Code 13‐28‐3‐4.

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IDEM’s Compliance and Technical Assistance Program

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• Assistance – CTAP staff members provide assistance through on‐site visits or via phone and will provide a full compliance review or just target a single issue. They also develop training programs, brochures, and webinars to help businesses understand the state and federal environmental regulations that affect them.

• Multimedia – CTAP staff members are knowledgeable in air, water, land, and Community‐Right‐to‐Know regulations and are happy to answer questions in these areas.

CTAP staff members provide assistance to businesses that contact them directly, are referred by regulatory inspectors or permit writers, or are impacted by a new U.S. Environmental Protection Agency or state regulation.

Contact CTAP if you need assistance

Hotline: (800) 988‐7901 Email: [email protected] Website: www.idem.IN.gov/ctap

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IDEM ‐ Office of Water QualitySurface Water, Operations, and Enforcement Branch

Wetlands and Storm Water SectionStorm Water Program

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Questions?