Martin Miller, Industrial Compliance Supervisor · •321920 -Wood Container and Pallet Mfg....

Martin Miller,

Industrial Compliance Supervisor

Industrial Storm Water Inspections

Implementation

Texas Storm Water Conference

September 24, 2018

September 24, 2018

Texas Storm Water Workshop

Four Major Key Elements to a Successful

Industrial Storm Water Inspection

• Introduction

• Documentation Review

• Site Assessment

• Exit Interview

September 24, 2018


Multi-Sector General Permit (MSGP)Am I regulated?

If you discharge storm water

associated with an industrial activity

into a storm water conveyance that is

part of a municipal separate storm

water sewer system (MS4) or to

surface water in the state; and your

business activity fits into one (or more)

of the regulated industrial sectors.

September 24, 2018


Introduction

• Face to face contact with the inspector

• Credentials

• Contact information

• Explain type of audit being conducted

• Professional working relationship

• Focus on Water Quality

September 24, 2018


Documentation Review

• Be prepared by researching company.

• Use TCEQ database to check history.

• If an existing file, review material.

• Check last inspection.

• Look at a satellite view of the facility.

• Know the material specific to the SIC!

September 24, 2018


Co-Located Activities and Facilities

• Industrial activities at a facility that are described

by more than one Code

• Must comply with all sector-specific

requirements for each SIC representing co-

located activities at site

– Sector-specific requirements apply only to portion of

facility where that specific sector activity occurs

– Except where runoff from different activities combines

before leaving the property

• Monitoring requirements and Effluent Limitations from each

contributing sector must be met

Co-Located Activities

September 24, 2018


Co-Located Activities and Facilities

• Multiple industrial facilities sharing a common property

boundary

• Operators of each co-located facility must individually obtain

authorization under the MSGP

• May either develop a separate Stormwater Pollution

Prevention Plan (SWP3) or may participate in a shared SWP3

– Site map delineate boundaries around each co-located facility AND

boundaries around shared/common areas that are used by two or

more facilities

Co-Located Facilities

September 24, 2018


Multi-Sector General Permit TXR050000

• Copy of the permit

• Standard Industrial

Classification (SIC)

• North American Industry

Classification System

(NAICS)

September 24, 2018


Multi-Sector General Permit

• Be familiar with Parts of the MSGP

Part I. Definitions

Part II. Permit Applicability and Coverage

Part III. Permit Requirements and Conditions Common to All Industrial

Activities

Part IV. Benchmark Monitoring Requirements

Part V. Specific Requirements for Industrial Activities

September 24, 2018


Industrial Activities

• SIC Code’s “or” Standard Industrial Codes

“Noted within the TXRO50000 Regulations”

• Relationship between SIC and NAICS

• TCEQ primarily lists Industry by SIC Code

• NAICS are more descriptive

• Listed activities specific to code

September 24, 2018


NAICS – NORTH AMERICAN INDUSTRIAL

CLASSIFICATION SYSTEM

www.census.gov/eos/www/naics/

http://www.census.gov/eos/www/naics/

September 24, 2018


TEXAS SALES TAX CERTIFICATE

September 24, 2018


SIX-DIGIT NAICS # appears on the State Sales Tax

• 321920 - Wood Container

and Pallet Mfg.

• This industry comprises

establishments primarily engaged in

manufacturing wood pallets, wood

box shook, wood boxes, other wood

containers, and wood parts for pallets

and containers.

September 24, 2018


Definitions• All definitions in Section 26.001 of the Texas Water Code and 30

TAC Chapter 305 shall apply to the permit and are incorporated

by reference.

• Grab Sample: An individual sample

collected in less than 15 minutes.

• Notice of Intent: A written submission

to the executive director from an

applicant requesting coverage under a

permit.

September 24, 2018


No Discharge to Surface Waters

• May not be required to obtain coverage under MSGP

– Must demonstrate that facility will not discharge stormwater

associated with industrial activity

• Facilities disposing of industrial stormwater in the

following ways are not required to obtain coverage

under MSGP nor under individual TPDES/NPDES permit:– Recycling stormwater for use on-site — Discharge to POTW

– Discharge to above ground storage tank — Containment on site

– Pumping/hauling to authorized disposal facility — Underground injection

Facility Does Not Discharge Stormwater to MS4 or Surface Waters

September 24, 2018


Permit Requirements and Common Conditions to all

Industrial Sectors

• Section A Minimum SWP3 Requirements

• Section B Inspection of SWP3 and Site

• Section C Numeric Effluent Limitations

• Section D General Monitoring and Records Requirement

• Section E Standard Permit Conditions

September 24, 2018


Benchmark Monitoring

• Use of Benchmark Data

• Sectors Subject to Benchmark

Monitoring

• Benchmark Monitoring

Requirements

September 24, 2018


Specific Requirements for Industrial Activities

• Requirements in the MSGP are sector specific

• In addition to the requirements in Parts III and IV.

• Thirty Industrial Sectors identified in the MSGP.

September 24, 2018


Site Assessment• Site presentation is priceless

• Inspectors are looking at the obvious

• Keep outfall(s) clean and free of debris

• Material needs to be stored with Best Management Practices

(BMPs) in mind:

– Raw Material

– Intermediate Products

– Byproducts

– Waste Products

– Final Products

September 24, 2018


No Exposure Exclusion

• Purpose and conditions

• Storm resistant shelter

• Industrial materials & activities

• Allowable items & discharges

• Permit application

• Pictures

September 24, 2018


Storm Resistant Shelter

• Structure with complete roof and walls

• Roof-only structure with run-on protection

September 24, 2018


Storm resistant shelter• Protection from run-on provided

September 24, 2018


Allowable Items

• Drums/tanks

– Sealed: no operational valves

– Good condition: no leaks

– Storage only: no filling or withdrawing

• Aboveground Storage Tanks

– No leaks

– Containment recommended

• Lidded dumpsters

September 24, 2018


Allowable Items

• Well-maintained vehicles

• Final products intended for outdoor use – Won’t mobilize or oxidize

• Pallets in good condition

September 24, 2018


Items to work on or removeNo Exposure

September 24, 2018


Materials exposed

September 24, 2018


Exposure to run-on

September 24, 2018


Loading dock exposed Vs. sheltered

September 24, 2018


Good practices

September 24, 2018


Obtain NEC Permit

• Complete No Exposure Certification (TCEQ form

10383) electronically or by mail to TCEQ

• Submit a copy to MS4 operator

• Submit NOT for previous MSGP coverage

• Maintain condition of no exposure – conditional

September 24, 2018


Why Sample?

• Determine effectiveness of storm water management– Qualitative feedback

– Quantitative feedback

• Improve quality of the states’ surface water

• Required under the permit

September 24, 2018


Purpose/reasoning of sampling

• Determining outfalls

• Sampling types

• Reporting requirements

• Qualifying rain events

• Sample preparation

September 24, 2018


Why Sample?

September 24, 2018


Determining Outfalls

• Outfall

– A point source where storm water runoff associated with

industrial activity discharges

• Finding concentrated storm water exits

• Sheet flow

• Storm drain inlets

• Commingling water

September 24, 2018


Substantially Similar Outfalls

• Industrial Activities

• Control measures

• Amount of flow

• Surface similarity

• Written description of outfall locations

TPDES Part III, Section C(2)

September 24, 2018


Sampling Types

• Quarterly Visual

• Benchmark

• Numeric Effluent Limits

– (Hazardous Metals)

• Sector Specific Effluent Limits

September 24, 2018


Quarterly Visuals

• Required quarterly – all sectors

• Collect grab samples in glass bottle

• Assess general appearance

TPDES Part III, Section A(5)(h)

• Color

• Settled Solids

• Suspended Solids

• Oil Sheen

• Odor

• Clarity

• Floating Solids

• Foam

• Other indicators

September 24, 2018


Quarterly Visuals

September 24, 2018


September 24, 2018


Qualifying Rain Events

• At least 0.1” of rain

• Discharge occurs at outfall

• At least 72 hours since the last qualifying event

• Collect samples within the first 30 minutes of discharge

(within 60 minutes with documentation as to reasons why)

• Keep rain log for documentation purposes

TPDES Part III, Section C

September 24, 2018


• Sector M of Multi-Sector General Permit (MSGP)

• Best Management Practices (BMPs)

• City Code of Ordinances (Chapter 16)

• Qualifications for license with the City of San Antonio

September 24, 2018



• Sector M.3 (pg.113) states….. Vehicles shall be inspected for leaking fluids upon arrival at

the facility

Actions shall be immediately taken to prevent the discharge

of fluids according to specific measures established

Spill Prevention & Response Measures

September 24, 2018



• Employee training shall include training on the

following operations at the facility Used oil and spent solvent management

Management of metal filings and dust from welding, grinding,

and similar operations

Lead-acid battery management

Employee Training Program and Employee Education

September 24, 2018


Poor BMPs and Spill Response

Measures (Fluid Draining)

September 24, 2018




•46

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•47

September 24, 2018



Measures (Car Crushers)

September 24, 2018


BMPs and Spill Response Measures

(Car Crusher pad and curbing)

•50

September 24, 2018


Periodic Inspections and Good

Housekeeping Measures

• Periodic Inspections (Sector M)

Equipment containing hydraulic or other fluids shall be inspected for

leaks during the periodic inspections.

• Good Housekeeping Measures

Equipment operators must conduct inspections of equipment on a

daily basis when equipment is in use.

•51

September 24, 2018



Measures (Inspection of Equipment)

•52

September 24, 2018


Poor BMPs & Spill Response Measures

(Simple Housekeeping)

•53

Open top &

spillage

September 24, 2018


Good BMPs and Spill Response

Measures (Simple Housekeeping)

•54

September 24, 2018


Initial and Final Vehicle Break-Down Area

September 24, 2018


Covered Work Area from the ElementsRemoval of tires, mags, batteries, mercury switches, bulbs, fluids (oil, gas, transmission and brake fluid)

September 24, 2018


Recycling ActivitiesOil & Fuel Removal Battery Packaging Mag Rims Alternators

•Casting Aluminum and Copper

•Aluminum

•Lead •Lead

•Waste Oil

•Drains

September 24, 2018


Essential BMP: Car Lift Allows Mechanics Easy AccessRemoval of fluids such as Gasoline, Oil, Transmission, Brake Fluid, etc.

September 24, 2018


Spill Containment & Containers

• Oil catch pans

• Fuel draining

• Concrete pad

September 24, 2018


BMP – Extending the Width Between Vehicle Roles for cleaning ease

Vehicle Yard Placement

September 24, 2018


BMP –Yard Clean-Up “Work-Cart”

September 24, 2018


Vehicle Crushing UnitApproximately 30 – 40 vehicles are crushed daily

September 24, 2018


Outside Final Breakdown Slab “BMP” – Inlet for storm water and vehicle fluid spillage from dismantling activities

September 24, 2018


Reuse, Recycling, ReductionAuto Salvage Facility• Car parts – reuse & recycling

• Gasoline, Oil, Antifreeze, Brake Fluid, Windshield Fluid – reuse & recycling

Pollutants

• Switches - Mercury

• Radiator, Rims, A/C Condenser & Evaporator Coils and Compressor- Aluminum

• Battery – Lead

• Catalytic Converter, Exhaust Piping & Mufflers

• Alternator, Starter, Wiring - Copper

• A/C System – Oil and Freon

• Engine, Transmission, Drive Shaft, Exhaust Manifold & Final Crushed Vehicle – Steel

• Anything not sold and/or not mentioned

September 24, 2018


Must obtain license with the City of San Antonio to

operate salvage yard site.

• Sec 16-187: “No dealer may operate a salvage yard,

within the city limits without a valid license.”

– Must renew license annually

– Cannot receive license with the City of San Antonio unless the

facility has a “Letter of Compliance” from SAWS.

• Local ordinance is more stringent due to:

• High risk of industry

• Ongoing struggle to maintain compliance at Salvage Yards

(historical compliance of industry)

•65

September 24, 2018


City Code of Ordinance (Chapter 16)

Storage; Waste Containment; Maintenance; Fire Lane (Sec. 16-194)

September 24, 2018


Exit Interview

• Inspector will provide a summary of findings:

– Violations

– Compliance status

– Recommendations and tips

– Timelines to make necessary corrections

– Notification of re-inspection

September 24, 2018


Conclusion

• Master the four keys and experience a successful

storm water audit.

• Be positive and prepared.

• Ask questions if you are not certain about something.

• Maintain accurate records and know where you have

stored these documents.

• Keep current with regulations.

Martin Miller,

Industrial Compliance Supervisor

Industrial Storm Water Inspections

Implementation

Texas Storm Water Conference

September 24, 2018

210.233.3557 [email protected]

Martin Miller, Industrial Compliance Supervisor · •321920 -Wood Container and Pallet Mfg....

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