how to perform an industrial/commercial … alex...how to perform an industrial/commercial...
TRANSCRIPT
How to perform an Industrial/Commercial Stormwater Inspection:
With help from the CASQA Ind/Comm BMP handbook and other tools.
Presentation overview: Presentation Goals and
Outline O Goals
O Cover basic definitions and important steps before, during, and after an inspection
O Cover basic BMP resources including the CASQA Ind/Comm BMP handbook
Presentation overview: Presentation Goals and
Outline O Presentation outline
O Review some standard nomenclature and Overview of BMP’s (definition/use in ordinances)
O Understand the various parts of conducting a Stormwater inspection
What is a BMP anyway? O Let’s review some terms: Catch Basin (Also known as Inlet): Box-like underground concrete structure with openings in curbs and gutters designed to collect runoff from streets and pavement.
Illicit Discharges: Any discharge to a MS4 or receiving water that is not in compliance with applicable laws and regulations, e.g. is not discharged pursuant to an NPDES permit or applicable exemption or waiver.
Gross Pollutants: Typically refers to visible pollutants such as trash, debris, and floatables, which may create an aesthetic “eye sore” in waterways. Gross pollutants also include plant debris (such as leaves and lawn-clippings), animal excrement, street litter, and other organic matter.
Non-Stormwater Discharge: Any discharge to MS4 or receiving water that is not composed entirely of stormwater.
What is a BMP anyway? O Terms cont’d: Industrial Materials: Includes, but is not limited to: raw materials, recyclable materials, intermediate products, final products, by product, waste products, fuels, materials such as solvents, detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production; hazardous substances designated under Section 101(14) of Comprehensive Environmental Response, Compensation, and Liability Act (CERLCA); any chemical the facility is required to report pursuant to Section 313 of Title III of Superfund Amendments and Reauthorization Act (SARA); fertilizers; pesticides; and waste products such as ashes, slag, and sludge and that are used, handled, stored, or disposed in relation to a facility’s industrial activity
What is a BMP anyway?
What is a BMP anyway?
O Using the CASQA Ind./Comm. BMP handbook as
a resource O www.casqa.org O Must be a subscriber to access handbook
(discounts can be given for large group subscriptions)
What is a BMP anyway? O According to the handbook in section 6, a BMP is
defined as including… “schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent, eliminate, or reduce the discharge of pollutants. BMPs also include treatment requirements, operating procedures, and practices to control runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.”
O Further, in section 2.2 of the handbook, it states: “BMPs are measures to prevent or mitigate pollution. They include a broad class of measures, many of which may already be used for reasons unrelated to stormwater pollution prevention. BMPs are commonly categorized whether they are non-structural or structural, or whether they are Source Control or Treatment Control.”
What is a BMP anyway? O What does your Ordinance say?? O City of Fremont Ord. 18.210.00 states a BMP: “shall mean schedules of activities, prohibitions of practices, general good housekeeping practices, pollution prevention practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants directly or indirectly to “waters of the United States.” BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.”
O And in the City of Hayward’s Ord. 11-5.13, a BMP means: “Schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of the waters of the United States. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.”
Why use the CASQA handbook?
O Who is the target audience?? According to section 1.1.1 of the CASQA handbook it says…
“The target audience of this handbook includes:…municipal agencies, including their business inspectors”
So what is required of your Agency?
O In Alameda Co., the MRP in the opening paragraph of section C.4 requires permittees to have an industrial and commercial site control plan with inspections that:
“confirm implementation of appropriate and effective BMPs and other pollutant controls by industrial and commercial site operators.”
Why are we so concerned with the definition of a BMP?
What are we evaluating? O In order to evaluate a facility’s stormwater BMP’s
we need to know what we’re protecting waterways and courses from. O The 8 major categories of pollutants according to the
handbook are: O Sediment O Nutrients O Bacteria/Viruses O Oil and grease O Metals O Synthetic organics O Pesticides O Gross pollutants (trash, debris, floatables, etc)
How to conduct a SW inspection
O In general the four parts can be subdivided as follows: 1. Pre-inspection 2. Inspection 3. Post-inspection 4. Follow up
O Looking at it another way, a blank inspection form
can serve as a template for the above mentioned steps.
How to conduct a SW inspection
1. Pre-inspection
2. Inspection
3/4. Post-inspection/Follow-up
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Pre-inspection
O Preparing for the inspection by gathering necessary information about the facility
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Pre-inspection
O Quick-check of tools needed would be Cameras, BMP handouts, GIS information, Google maps/aerial views of property to be inspected
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Conducting the inspection
How to conduct a SW inspection
O Section 3 of the Handbook lists four main stormwater management areas for facilities to concentrate their application of BMPs. These areas are further subdivided into 16 activity areas yielding a source control BMP fact sheet for each area.
O These activity areas should be ubiquitous across all areas of Industrial/Commercial operations.
How to conduct a SW inspection
O According to the handbook, the following minimum BMPs are required of IGP covered facilities: O Good Housekeeping O Preventive Maintenance O Spill and Leak Prevention and Response O Material Handling and Waste Management O Erosion and Sediment Control O Employee Training Program O Quality Assurance Record Keeping
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Conducting the inspection
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Conducting the inspection
O Vital tools: O Use previous inspection form to jot notes down O Cameras – a picture is worth a thousand words O Voice recorder – might need permission for this especially if
recording facility representative statements
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Conducting the inspection
O Vital tools: O Use previous inspection form to jot notes down O Cameras – a picture is worth a thousand words O Voice recorder – might need permission for this especially if
recording facility representative statements O Locate ALL outdoor activity areas:
O What’s an example of an activity that every business has no matter the type of business it is??
HINT: S/R
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Post-Inspection
O Writing your report.
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Follow-up
O Issuing enforcement O Follow your enforcement response plan O Organize evidence (pictures, samples, statements) and
document on inspection report the evidence gathered O Determine when you will re-inspect to confirm return to
compliance
How to conduct a SW inspection
O The various parts of a SW inspection can be broken down into the following subparts. O Follow-up
O Don’t forget to print and file away your report! After all, it’s only the 21st Century!
Questions
