Stormwater Compliance Training

South County Regional Wastewater Authority

July 2015

Jack RosenburgCH2M / Oakland

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Why are we here?

• Plant discharges stormwater from areas that are exposed to industrial activity

•Wastewater treatment plants are required to obtain coverage under the Industrial General Stormwater Permit (IGP)

• Plant has had IGP coverage since early 1990s

• New permit took effect on July 1, 2015

•We have new:– Stormwater Pollution Prevention Plan (SWPPP)

– Stormwater Pollution Prevention Team

– Stormwater monitoring program

– Numeric action levels

• Permit and SWPPP require periodic stormwater training

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What will we cover?

• Background on new permit

• Overview of Stormwater Pollution Prevention Plan

• Stormwater Pollution Prevention Team

• Best Management Practices to keep pollutants out of stormwater

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Purpose of IGP: keep industrial pollutants out of stormwater

• Identification of potential pollutants and how they might reach stormwater

• Prevention through Best Management Practices

• Inspections and monitoring to verify effectiveness

• Numeric Action Levels (NALs) to measure effectiveness

• Corrective measures if action levels are exceeded

• Online reporting

• Leadership from the Stormwater Pollution Prevention Team

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IGP is an NPDES Permit issued under the Federal Clean Water Act

• Enforced by Regional Water Board• Can be enforced by third party lawsuits• SWPPP and monitoring data publicly

available online

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Scope of the permit

• Permit covers discharges to waters of the US of:– Stormwater from industrial activities

– Certain authorized non-stormwater discharges

• Permit does not cover:– Construction activities

– Discharges of treated wastewater

– Unauthorized non-stormwater discharges

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Focus of stormwater management program

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Treatment Plant Area

Stormwater discharge to

retention pond

Included in SWPPP to:• Prevent

pollution of groundwater

• In case discharge from retention pond occurs

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Influent Pump Station

Stormwater from northern portion of IPS flows to storm drain inlets, which flow to Llagas Creek

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Stormwater Pollution Prevention Team• Thom Vinson: Plant Manager– Provides overall direction and allocates resources for stormwater

compliance; reviews stormwater documents and submittals; Legally Responsible Person for certifying stormwater submittals

• Jack Rosenburg: Team Leader– Oversees SWPPP implementation; performs stormwater inspections,

sampling; and annual compliance evaluation; reviews stormwater sampling data

• Garon Goularte: Team Member– Performs stormwater inspections, sampling; and annual compliance

evaluation; reviews stormwater sampling data

• Operators– Perform stormwater sample collection when necessary

Everyone: use best management practices to prevent stormwater pollution

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Dick’s new stormwater role

Thanks, Dick

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Stormwater Pollution Prevention Plan (SWPPP)

• Introduction

• Facility Description & Maps

• Potential Stormwater Pollution Sources

• Stormwater Best Management Practices

•Monitoring Implementation Plan

• Annual Comprehensive Site Compliance Evaluation & Annual Report

• Recordkeeping and Compliance Calendar

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Industrial materials: potential stormwater pollutants

• Diesel Fuel

• Transformer oil

•Waste oil

• Sodium hypochlorite

• Liquid polymer

• Sodium bisulfite

• Aluminum sulfate (liquid alum)

• Sodium hydroxide

• Raw wastewater

• Secondary treated wastewater

• Grit

• Solids (sewage sludge)

• Hauled septage

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Potential stormwater pollution sources

• Industrial processes– Wastewater treatment

– Vehicle & equipment cleaning

– Maintenance

– Waste disposal

•Materials loading & unloading– Raw septage delivery

– Bulk chemical & fuel delivery

– Used oil pickup

– Solids loading and transportation

• Storage– Bulk chemicals & fuel

– Used oil

– Grit

– Oil-filled electrical equipment

• Spills & Leaks

• Erosion of unpaved surfaces

• Unauthorized non-stormwater discharges

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Best management practices (BMPs) to prevent stormwater pollution

• Containment– Secondary containment for bulk chemical and fuel tanks, containers, and

fuel piping

– Plant drain system

– Stormwater retention pond

• Erosion control– Surfacing (pavement, gravel, vegetation, mulch)

– No driving on dirt levees when raining

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Best management practices (BMPs) to prevent stormwater pollution

• Good housekeeping– All staff have housekeeping responsibilities per Equipment Operating

Procedure #19: Plant Coordination

– Littering prohibited

– Keep materials away from storm drains

– Septage hauler cleanup restricted to area that drains to plant

• Inspections– SWPP Team performs IGP-required inspections (monthly; during

stormwater sampling; annual compliance inspection)

– Regular inspections scheduled by computerized maintenance management system

– Supervisors review inspection reports

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Best management practices (BMPs) to prevent stormwater pollution

•Maintenance– Automated scheduling; corrective maintenance work orders for

unplanned events

– Maintenance verification by supervisors

– Vehicle washing restricted to areas that drain to plant drain system

– Equipment cleaning restricted to areas that drain to plant drain system or ponds

– All catch basins in the storm drain system are cleaned out and storm drain lines are jetted annually

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Best management practices (BMPs) to prevent stormwater pollution• Chemical & fuel deliveries– Driver reports to plant office before offloading material

– Must be supervised by plant staff

– Position vehicle within contained area

– Chock wheels; place vehicle in N or P; set parking brake

– Verify receiving tank’s capacity before offloading

– Cover storm drain inlets with rubber mats

– Have spill kit available nearby

– Use drip pans or buckets under hose connection points

– Secure quick connections properly before transfer

– Blow out or drain transfer lines before breaking connection

– Inspect and secure drain outlets on truck before departing

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Best management practices (BMPs) to prevent stormwater pollution

• Biosolids and grit truck loading– Truck loading and cleaning activities take place in designated areas that

drain to plant drain system

– Trucks must be covered and cleaned prior to leaving facility

• Industrial materials handling– Industrial materials not in ASTs are stored in covered areas or indoors

– All materials are labeled

– Industrial materials that could be mobilized by contact with stormwater not handled outdoors during a rain event

– Pesticide preparation, mixing, and filling only performed in areas that do not drain to storm drain system

– Do not accept delivery of leaking or damaged packaged industrial materials

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Best management practices (BMPs) to prevent stormwater pollution

• Alarms– Alarms system monitored by plant operators

• Equipment Operating Procedure #18: Plant Alarms

• Equipment Operating Procedure #19: Plant Coordination

• Spill Response Procedures– Emergency Response and Hazardous Waste Contingency Plan

– Spill kits located in key locations throughout plant; annual restocking in November

• Training– Periodic training on the IGP, SWPPP, and BMPs

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Non-Stormwater Discharges

• Authorized non-stormwater discharges identified in the SWPPP– Fire hydrant flushing

– Electrical vault dewatering

– Clarifier dewatering

• All other non-stormwater discharges are prohibited; if observed, should be reported to SWPP Team

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Evaluating Stormwater Program Effectiveness (SWPP Team)

•Monthly inspections to check for unauthorized non-stormwater discharges, potential sources of pollution, BMP implementation

• Sample stormwater discharges twice during each half-year– Visual observation of stormwater discharge for evidence of contamination

– Compare results to Numeric Action Levels (NALs) for pH, total suspended solids, oil and grease

– Plant enters Level 1 status if NALs exceeded; must evaluate potential pollutant sources and implement additional BMPs

• Annual comprehensive site compliance evaluation

• Annual reporting via online SMARTS system

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Who is responsible for keeping pollutants out of stormwater?

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Who is responsible for keeping pollutants out of stormwater?

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