Crystal Warren, TDEC-DWR-MEFO | May 16, 2019

Crystal Warren, TDEC-DWR-MEFO | May 16, 2019

TDEC exists to enhance the quality of life for citizens of Tennessee and to be stewards of our natural environment by:

• Protecting and improving the quality of Tennessee’s air, land, and water through a responsible regulatory system;

• Protecting and promoting human health and safety;

• Conserving and promoting natural, cultural and historic resources; and

• Providing a variety of quality outdoor recreational experiences.

• All new and existing point source industrial stormwater discharges associated with industrial activity require an NPDES Stormwater Permit from the Tennessee Division of Water Resources. Most common is a general permit which is available to almost any industry, but there is also an option for an individual permit,

• Based on Standard Industrial Classification Code (SIC)

• 2,265 Active permits, statewide

• 607 No Exposure certifications, statewide

Sector Activity # in TN

A Timber Products Facilities 171

B Paper and Allied Products Manufacturing Facilities 44

C Chemical and Allied Products Manufacturing Facilities 98

D Asphalt Paving, Roofing Materials, and Lubricant Manufacturing Facilities 107

E Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing

Facilities 83

F Primary Metals Facilities 69

G Metal Mines (Ore Mining and Dressing) (RESERVED) -

H Inactive Coal Mines and Inactive Coal Mining-Related Facilities 0


I Oil or Gas Extraction Facilities 1

J Construction Sand and Gravel Mining and Processing and Dimension

Stone Mining and Quarrying Facilities 87

K Hazardous Waste Treatment Storage or Disposal Facilities 10

L Landfills and Land Application Sites 65

M Automobile Salvage Yards 257

N Scrap Recycling and Waste and Recycling Facilities 112

O Steam Electric Power Generating Facilities 13

P Vehicle Main. or Equipment Cleaning areas at Motor Freight or

Passenger or Railroad Trans., Petroleum Bulk Oil Stations and Terminals, USPS Facilities

307


Q Vehicle Main. Areas and Equipment Cleaning Areas of Water

Transportation Facilities 15

R Ship or Boat Building and Repair Yards 13

S Vehicle Main. Areas, Equipment Cleaning Areas, or From Airport Deicing

Operations located at Air Transportation Facilities 19

T Wastewater Treatment Works 19

U Food and Kindred Products Facilities 86

V Textile Mills, Apparel and other Fabric Product Manufacturing Facilities 16

W Furniture and Fixture Manufacturing Facilities 20

X Printing and Platemaking Facilities 13


Y Rubber and Miscellaneous Plastic Products Facilities 112

Z Leather Tanning and Finishing Facilities 0

AA Facilities that Manufacture Metal Products including Jewelry, Silverware,

and Plated Ware 194

AB Facilities that Manufacture Transportation Equipment, Industrial or

Commercial Machinery 144

AC Facilities that Manufacture Electronic and Electrical Equipment and

Components, Photographic, and Optical Goods 49

AD Facilities Not Covered under Sectors A Thru AC (monitoring required) 48

AE Facilities Not Covered under Sectors A Thru AC (monitoring NOT required) 12

AF Stormwater Discharges Associated with Industrial Activity from Borrow

Pits, Soil Harvesting Sites, and Spoil Piles 75

• Submit a signed and completed Notice of Intent to the Division’s Central Office • For new facilities, submit at least 7 days prior to the

commencement of any industrial activity

• 30 Day Applicant Bill of Rights applies

• General permit reissued every 5 years (current version issued in 2015)

• New facilities are required to submit a copy of their Stormwater Pollution Prevention Plan (SWPPP) along with the NOI • Facilities with existing coverage are not required to submit a

SWPPP when obtaining coverage under a reissued permit

Has a SWPPP been developed?

SIC

Industrial Activities at Facility

• A SWPPP is a narrative document that basically explains what potential pollutants are located at a facility and what measures will taken to prevent pollution from occurring.

• Must be developed, maintained, and kept on-site

• Must be signed and certified by an appropriate person

Cap’s Scrap

Date of Review Changes Made Signature

6/7/16 No changes made Captain W.

6/1/17 Revised Pollution Prevention Team members Captain W.

6/30/18 Revised BMP Section to include canopy over

baghouse Captain W.

• Must include certification for testing of non-stormwater discharges

• Certification should be signed by appropriate person

Must include:

– Map identifying drainage patterns, outfalls, potential pollutant sources, and Best Management Practices

– Pollution prevention team

– List of potential pollutant sources

Cap’s Scrap

(scrap metal and paper yard covered under Sector N)

List of Potential Pollutant Sources:

• Outdoor metal and paper scrap stockpiles

• Material processing: air pollution equipment

• Material processing: baling, compacting, shredding

• Vehicle and Equipment Maintenance

Must include:




– Risk identification and detailed description of potential pollutant sources

SWPPP Elements: Risk Identification and Detailed Description

of Potential Pollutant Sources Example

Cap’s Scrap

Activity Pollutant Source Pollutants Outfall

Scrap Metal Storage

Scrap metal

Heavy metals, Accumulated

particulate matter 1, 3

Scrap Paper Storage

Scrap paper

Accumulated particulate matter

1, 3

Material Handling: Air Pollution Equip.

Bag house

Accumulated particulate matter,

Hydraulic fuels 2

Material Processing: Baler,

Shredder, Compactor

Leaks from faulty seals, pipes, hoses; Residue from scrap

Heavy metals, Hydraulic fuels,

Particulate matter 2

Outdoor Vehicle and Equipment

Storage

Leaking engines, corroding parts, galvanized parts

Oil & grease, Organics, Heavy

metals 1, 2, 3

Must include:





– Inventory of all exposed materials

– List of significant spills and leaks

– Description of good housekeeping measures

– Employee training records

• Quarterly Visual Examinations

– Frequency: each outfall on a quarterly basis

• (1st Jan-Mar; 2nd Apr-Jun; 3rd Jul-Sept; 4th Oct-Dec)

– Should be conducted within the first 30 minutes (and not to exceed 1 hour) of when runoff or snowmelt begin discharging

– Storm event must be greater than 0.1 inch in magnitude and occur at least 72 hours from the previously measurable (greater than 0.1 inch rainfall) storm event

– Records required to be maintained on-site

• Document observations of:

– Color

– Clarity

– Odor

– Floating solids

– Settled solids

– Suspended solids

– Foam

– Oil sheen

– Other obvious indicators of pollution

https://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&ved=&url=https://fortress.wa.gov/ecy/publications/documents/0610020.pdf&psig=AOvVaw24hbRNhZJVFkWaanKFXiMw&ust=1557932907541716

• Potential Pollutant Sources

– Frequency: specified in each sector (ex: quarterly, monthly, periodically, etc.,)

– Should include areas of the site containing potential pollutant sources, as listed in the SWPPP

– Records required to be maintained on-site

Potential Pollutant Source

In Compliance

In Need of Maintenance

Comments

Scrap Metal Storage

Yes

Scrap Paper Storage

Yes High winds have blown material

against fence near outfall. Material should be removed.

Material Handling: Air Pollution Equip.

Yes

Bag full. Should be properly disposed of.

Material Processing: Baler, Shredder,

Compactor

Yes

Outdoor Vehicle and Equipment Storage

Yes

• Compliance Site Evaluation Inspections

– Frequency: annually (may take the place of one inspection of potential pollutant sources)

– Shall include:

• Areas contributing to a stormwater discharge associated with industrial activity for pollutants entering drainage system

• Measures to reduce pollutant loadings to determine if measures are working adequately in accordance with terms of permit or if additional measures are needed

• Structural measures and sediment and erosion control measures (oil/water separators, sediment basins)

• Equipment needed to implement SWPPP, such as spill response equipment

• If issues observed, SWPPP shall be updated within 2 weeks to include an implementation plan for correcting issues

• Report shall include: – Scope of evaluation

– Personnel, date, time

– Major observations

– Incidents of non-compliance

• Report should be signed and maintained on-site

• Collection of a stormwater sample from at each outfall (or representative outfall) once per calendar year

• Sample collection should follow Title 40 CFR Part 136

• Should be conducted within the first 30 minutes of a rain event, but not to exceed one hour of when runoff or snowmelt begin discharging

• Storm event must be greater than 0.1 inches in magnitude and occurs at least 72 hours from the previously measurable (greater than 0.1 inch rainfall) storm event

• Records and reports submitted to EFO within 30 days of receipt of results or by March 30 of the following year, whichever comes first.

A – Timber Products B – Paper and Allied Products

C – Chemical and Allied Products

D – Asphalt Paving, Roofing, and Lubricants

E – Glass, Clay, Cement, Concrete, and Gypsum Products

F – Primary Metals H – Inactive Coal Mines and Related Activities

I – Oil and Gas Extraction

J – Construction Sand and Gravel Mining and Processing and Dimension Stone Mining and Quarrying

K – Hazardous Waste Treatment Storage or Disposal

L – Landfills and Land Application Sites

M – Automobile Salvage Yards

N – Scrap Recycling and Waste and Recycling

O – Steam Electric Power Generating

Q - Vehicle Main. Areas and Equipment Cleaning Areas of Water Transportation

U – Food and Kindred Products

AA – Manufacture Metal Products including Jewelry, Silverware, and Plated Ware

AB – Manufacture Transportation Equipment, Industrial or Commercial Machinery

AD - Not Covered under Sectors A Thru AC (monitoring required)

AF - Stormwater Discharges Associated with Industrial Activity from Borrow Pits, Soil Harvesting Sites, and Spoil Piles

• Parameters are sector and SIC code specific

• TMSP Benchmark Cut-off Concentrations

• Form CN-1115 (AMR)

• Must be submitted to the Division within 30 days of receipt of monitoring results

• Exceedance of benchmark is not a violation

• Facility must notify EFO within 30 days of receipt of results that an exceedance occurred

• Facility must update SWPPP within 60 days of receipt of results with modifications that would assist in reducing the effluent concentrations to less than the benchmarks – Must submit a brief summary of SWPPP modifications to EFO

• Submit Discharge Monitoring Reports (DMRs)

• Exceedance of numeric effluent limit is a violation

A – Timber Products

C – Chemical and Allied Products

D – Asphalt Paving, Roofing, and Lubricants

E – Glass, Clay, Cement, Concrete, and Gypsum Products

J – Construction Sand and Gravel Mining and Processing and Dimension Stone Mining and Quarrying

K – Hazardous Waste Treatment Storage or Disposal

L – Landfills and Land Application Sites

O – Steam Electric Power Generating

• Submit Discharge Monitoring Reports (DMRs)

• Exceedance of numeric effluent limit is a violation

• Benchmarks (AMR):

• Numeric Limits (DMR):

• What does the Division look for during an inspection?

• Two parts: – Document Review

– Facility Site Review

• Copy of the TMSP and applicable sector

• Notice of Coverage

• SWPPP – Updated and maintained





– Inventory of all exposed materials

– List of significant spills and leaks

– Description of good housekeeping measures

– Employee training records

• Inspections of stormwater outfalls

• Inspections of potential pollutant sources

• Comprehensive Site Compliance Evaluations

– Review reports from past 3 years

– Were outfall inspections conducted during a rain event?

– Were issues documented?

– Were repeat issues observed and documented?

– Were documented issues corrected by the following inspection?

– Were Best Management Practices implemented based on results of inspections?

• Stormwater Monitoring, if applicable – AMR/DMR

– Chains of custody

– Lab results

– Notification of exceedances

– Discussion of sampling technique

– Were Best Management Practices implemented based on results of monitoring?

• Walk the area of the site exposed to stormwater

• View outfalls and potential pollutant sources

• Look at good housekeeping measures and Best Management Practices

• Provides a one page summary of the documents required to be maintained on-site + inspection descriptions

• Available on website

• Option for facilities that have applicable SICs but no industrial activities exposed to stormwater

• Must submit signed and completed No Exposure Certification (CN-1516) to TDEC – TDEC will review the application and likely perform a site review to

verify completeness.

• Can the materials stored or activities occurring on-site cause or contribute to a condition of pollution?

Questions/Comments?

Crystal Warren

Division of Water Resources

Memphis Environmental Field Office

[email protected]

901-371-3164

Submit comments when draft permit is available for review!

President/CEO of Cap’s Scrap

mailto:[email protected]

Documents

Crystal Warren, TDEC-DWR-MEFO | May 16, 2019