Storm Water Management for Harbors

Alaska Association of Harbormasters and Port Administrators

Wrangell, AlaskaOctober 26, 2010

Shane Serrano ADEC

Alaska Harbors come in different shapes, sizes and ownerships

Alaska Harbors come in different shapes, sizes and ownerships

Clean Water ActPassed by Congress in 1972 and amended

several timesAct addresses water pollution from point

sources and nonpoint sourcesPoint sources are addressed through NPDES

permitting ProgramNonpoint sources are addressed through

grants to implement Best Management Practices

National Pollutant Discharge Elimination System (NPDES)Individual Permits

Typically Domestic Wastewater DisposalGeneral Permits

Construction GPMulti-Sector GPVessel GP

Four QuestionsWhat is the MSGP?Are You covered by the MSGP?What do You have to do to comply with the

MSGP?When does ADEC assume the storm water

program from EPA?

What is the MSGP?Section 402(p) of the Clean Water Act directs

EPA to develop permit application requirements for “stormwater discharges associated with industrial activity”

EPA developed the NPDES Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Sources

The previous version, the MSGP 2000, expired in October 30, 2005

In early 2009 MSGP is reissued in Alaska

Am I covered by the MSGP?One of 29 Industrial Sectors Water Transportation – Sector Q

Water Transportation of FreightFerriesMarine CargoTowing and Tugboat ServicesMarinas

Ship and Boat Building and Repairing Yards – Sector R

Covered DischargesStorm water discharge associated with

industrial activity means the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing, processing or raw materials storage areas at an industrial plant. 40 CFR 122.26 (b)(14)

Coverage Required for Facilities that Perform one or more of the Following

Blasting and PaintingMaterial StorageEngine Maintenance and Repair AreasMaterial HandlingDrydock ActivitiesPressure Washing (May need another NPDES

permit)

Need to Meet All Three ConditionsYour Facility is included in the regulated SIC

CodesYour Facility has regulated activities on your

propertyThere is a discharge of the runoff through a

point source

What do I have to do to comply with the MSGP?Read the permit Develop a SWPPP or Revise Existing SWPPPImplement SWPPP and Control MeasuresSubmit Notice of Intent Conduct InspectionsConduct MonitoringImplement Corrective ActionMaintain Reporting & Recordkeeping

Read the PermitRead Sections 1-7 & 9 and section 8-sector Q

or RRead Appendices A-KFor details read the Fact SheetAvailable at

www.epa.gov/npdes/stormwater/msgpRead permit with your facility in mindRead Sector Q or R Fact Sheet

Developing Your SWPPPEPA GuidanceSpecific to Industrial

FacilitiesWhat to Include in

SWPPPCommon

Compliance Problems

Elements of SWPPPListing of Pollution Prevention TeamDescription of SiteSummary of Potential Pollutant SourcesDescription of Control MeasuresList of Schedules and ProceduresDocument Eligibility ConsiderationsSignature RequirementsAdditional Documentation

Additional Documentation for SWPPPCopy of Notice of IntentDescription of significant spills or leaksRecords of employee trainingDocumentation of maintenance of control

measuresCopies of inspection reportsDescription of corrective actions takenDocumentation of any benchmark

exceedancesDocumentation of status change from active

to inactive

Control MeasuresMust select, design, install and implement

control measures (including BMPs) to address* Selection and design considerations* Meet the non-numeric effluent limits* Meet limits contained in applicable effluent limitations guidelines

Non-Numeric Technology-Based Effluent LimitsMinimize ExposureGood HousekeepingMaintenanceSpill Prevention and Response Procedures

Erosion and Sediment ControlManagement of Runoff

Non-Numeric Technology-Based Effluent LimitsSalt Storage PilesSector Specific Non-Numeric

Effluent LimitsEmployee TrainingNon-Stormwater DischargesWaste, Garbage and Floatable

DebrisDust Generation and Vehicle

Tracking of Industrial Materials

Erosion and Sediment ControlAlaska Storm Water Guide

http://dec.alaska.gov/water/wnpspc/stormwater/Guidance.html

ADOT&PF SWPPP Guide www.dot.state.ak.us/stwddes/dcsenviron/resource

s2.shtml#EPA SWPPP Guidehttp://cfpub.epa.gov/npdes/stormwater/swpp

p.cfmEPA Menu of Stormwater BMPswww.epa.gov/npdes/stormwater/menuofbmps

NOI Submittal to EPA (ADEC after Oct 31, 2009)Existing Dischargers – In operation prior to

Oct 30, 2005 and authorized under MSGP 2000

New Dischargers – In operation in between Oct 30, 2005 and date in AK MSGP

New Dischargers – In operation after date in AK MSGP

Other Eligible Dischargers – In operation prior to October 30, 2005, but not covered under the MSGP 2000 or other NPDES permit

InspectionsRoutine Facility InspectionsQuarterly Visual Assessment of Stormwater

DischargesComprehensive Site Inspections

MonitoringMonitoring ProceduresBenchmark MonitoringEffluent Limitations Monitoring

Monitoring and Sampling EPA GuidanceHow to Prepare for

MonitoringHow to Conduct

MonitoringHow to Evaluate

Monitoring ResultsRecord-Keeping

Corrective ActionReview and Revision to Eliminate ProblemReview to Determine if Modifications are

NecessaryCorrective Action ReportEffect of Corrective Action

Reporting and RecordkeepingReport Monitoring Data to ADEC (after Oct

31, 2009)Send Annual Report to ADEC (after Oct 31,

2009)Exceedance Report for Numeric Effluent

LimitsAdditional ReportingRecordkeeping

When Does ADEC Assume the Storm Water Program?Transfer of NPDES Program started October

31, 2008Phase 1

Domestic WastewaterSeafood ProcessorsLog Transfer Facilities

Phase 2 October 31, 2009Stormwater

Phase 3 October 31, 2010Mining

Changes to MSGP under ADECThe permit will stay the same until 2013Monitoring data and Annual Reports sent to

ADECCompliance and Enforcement Inspections by

ADEC

Tidal Grid Usage SurveyWhat information is available and tracked

(size, duration, activities, wasteload, etc.)What activities are allowed (type of

maintenance)What measures have been employed (collect &

treat)