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Don’t Expose Yourself! Can you be excluded from stormwater permitting? Bill Lindsey, P.E.
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Transcript of Bill Lindsey, Midwest Environmental Consultants, Don't expose yourself, Missouri Water Seminar,...
Don’t Expose Yourself! Can you be excluded from stormwater
permitting?
Bill Lindsey, P.E.
•General Permits
•No SWPPP
•No Quarterly Sampling
• Fees - $300 for 5 years = $60 per year
Old Stormwater Permits = Fun!
• SWPPP & Monthly Inspections
• Quarterly Sampling - # of Outfalls?
• Benchmarks/Limits
• BMP’s – Tweaking/Repairing
• Fees = $200 year
• Losing Stream = Individual Permit! (old fees - $1,350 Yr, new - $1,800)
New SW Permits = Not Fun!
• EPA Conditional No Exposure Exclusion for Industrial Activity – January 2000
• Who can qualify?
• Conditions?
• Definitions and Details?
• Industrial Materials
• No Exposure/Cover
Can you be excluded for a stormwater permit?
• EPA Guidance – All industrial categories
• Excluded:
• “Construction Sites”
• “Junk cars & stockpiled train rails”
• MDNR – 28 MOG General Permits – Process Water = Difficult - None really eligible.
• MOG49 - Quarries, Asphalt, Redi-Mix
• MDNR – 17 MOR General Stormwater Permits
• Facility Wide – Not Outfall Specific
Who Can Qualify?
• MOR13 – Textiles & Printing
• MOR203 Fab. Metal & Light Industry
• MOR80C–Motor Freight Transportation
• Individual Permit -due to Losing Stream
MDNR General Stormwater Permits Potentially Eligible – YES!
• MO-RA – Land Disturbance
• MO-R04 – MS4
• MOR100 – City Land Disturbance
• MOR22 – Wood & Lumber
• MOR23 – Chemicals, Plastics, Biodiesel
• MOR240, 241 – Agrichemicals
• MOR60 – Vehicle Salvage
• MOR80 – Airports & Trans. Stations
MDNR General Stormwater Permits Probably Not!
• No Exposure – All industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff.
Conditions to be Excluded
• Material handling equipment or activities
• Industrial machinery
• Raw materials
• Intermediate products
• By-products & waste products
• Final products
Industrial Materials?
• Completely roofed and walled buildings or structures
• Structures with a top but no sides – providing not subject to run-on /run-off of stormwater
• Temporary cover = tarpaulins
Storm-Resistant Shelter?
• Drums, barrels, tanks and containers that are “sealed.”
• Above Ground Tanks (AST’s)
• Lidded Dumpsters – waste materials
• Plant Vehicles – not leaking
• Final products – intended for outdoor use (i.e. “new cars”)
• Containers, racks, pallets to store or move final products – if clean.
No Shelter Required!
• Drums - valves that are used in field
• Containers & materials – open, deteriorated, leaking
• Outdoor vehicle & equipment maintenance
• Leaking pipes and pumps
• Open dumpsters
• Mobilized by rain – rock salt
• Particles or residue – roof stacks or vents
• Particles or residue – track out
Stuff that won’t fly!
• Final products that are “intermediate” products
• Intermediate products:
• Used in the composition of another product
• Sheet metal, tubing, and paint
• Chemically treated or not impervious to weathering
More stuff that won’t fly!
• EPA NPDES Form 3510-11
• 11 Questions – answer No!
• Submit to MDNR
• Good for 5 years
• Maintain all conditions of no exposure
How do you apply to be excluded for a stormwater permit?
