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Stormwater Industrial Permit Training

CSSGA 2012

Maura McGovern

on 12 May 2014

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Transcript of Stormwater Industrial Permit Training

COR900000 The New Industrial Stormwater Permit
What changes does this mean for my facility?

Control Measures
Practice Based Effluent limitations
Numeric Effluent Limitations
Changes to SWMP
Inspections Frequency
Monitoring Requirements
Corrective Actions
Reporting and Record Keeping
Notification Requirements
Handout of Quick Comparison of Old vs Renewal Permit Requirements
(cc) image by anemoneprojectors on Flickr
Environmental outcome/ protect water quality
What Are The Drivers Behind The Change?
Improved consistency of permit requirements
Almost 20 years since last comprehensive review of industrial stormwater permits
Review of sampling data provided by industrial sectors required to conduct annual sampling
Division observations during compliance inspections
Part II Standard Terms and Conditions
Permit Structure
3 Permits combined into 1
Common and sector specific elements

Sector D
Asphalt Paving and Roofing Materials and Lubricant Manufacturing

Sector E
Glass, Clay, Cement, Concrete, and Gypsum Products
General Permit COR900000
Stormwater Discharges Associated with Non-Extractive Industrial Activity

Colorado Stone, Sand, and Gravel Association
Maura McGovern 303-692-3392
Water Quality Control Division -Permit Section
Colorado Department of Public Health and Environment
Colorado Ready Mixed Concrete Association

August 9, 2012
1990 EPA Issued Stormwater Regulations
11 categories of facilities associated with industrial activity
defined by Standard Industrial Classification (SIC) code and narrative descriptions
SIC 3273
Part I Requirements applicable to all Industrial Sectors
Part III Sector Specific Requirements for Industrial Activity
SIC 2951
SIC 3241
SIC 3251-3259
No exposure
What if a facility does not have a discharge?
No potential to discharge
5 Types of Monitoring
Revised monitoring schedule
Adverse weather conditions
Irregular stormwater runoff conditions
Monitoring when a plant is closed
Take sample as soon as possible and document deviation from required frequency
Monitoring at inactive sites
Must meet condition of "no exposure"
Industrial Stormwater Guidance
You Tube videos on how to collect a grab sample
You Tube video on defining sample locations
EPA Stormwater Monitoring and Sampling Guidance Document
"No Discharge" on DMR
Effluent Limitation Guideline monitoring
Impaired Waters Monitoring
Additional Monitoring Required by the Division
Specified Methods in 40 CFR Part 136
*One or more may apply to the discharge and this is identified in the permit certification
Mobile Facilities
Mobile Asphalt Batch Plants (SIC 2951)
Mobile Concrete Batch Plants (SIC 3273)
Allows a Statewide discharge
no specific receiving stream identified
most stringent requirements applied (sampling for selenium)
Notify the Division in writing each time the facility is moved
The analytical results required in the certification must be reported to the Division through the submission of Discharge Monitoring Reports (DMR EPA Form 3320-1)
Discharge Monitoring Report Guidance
located on www.coloradowaterpermits.com under "what's new" NET DMR Training
Control Measures
Selected, designed, installed, implemented, and maintained in accordance with good engineering hydrologic and pollution control practices
Defined as "any BMP or other method (including effluent limitation) used to prevent or reduce the discharge of pollutants to waters of the state"
Installation and implementation specifications
Introduce the term "Minimize" in relation to implementing control measures
Maintenance and documentation requirements
Delayed renewal of the combined sand and gravel permit COG-500000 and the stormwater only sand and gravel permit COR340000 for one year (2014)
Upcoming Permits
There will not be an " Extractive Industries" Permit
Fact Sheet
Response to Comments
Notice of Transfer
Amendments/ Modifications
Stormwater Management Plan (SWMP)
Pollution Inventories Assessment
Inspections Procedures
Monitoring Procedures
Corrective Actions
4 times per year (i.e. once per quarter)
1 inspection during a runoff event
Conduct the inspections 20 days apart
Inspection Scope
Inspection documentation (in a report or checklist)
Inactive and unstaffed sites that meet condition of no exposure can do 2 annual inspections (spring/ fall)
Monitoring requirements apply to each outfall authorized by the permit
Substantially Identical Outfalls
Corrective Actions
Unauthorized release or discharge
violation of numeric effluent limit
control measures not adequate to meet standards
modification to control measure is needed
inspections indicate control measures are not properly selected, designed, installed, operated, or maintained
Representation of monitored discharge
Establish and maintain records
Retain records for a minimum of 3 years
includes calibration and maintenance records
Document discovery
24 hour documentation requirement
5 day documentation requirements
Corrective Actions
Read the permit
Modify existing SWMP to comply with the renewal permit within 90 days of certification effective date
Review issued certification
Verify identified outfalls and modify if necessary
Contact lab to discuss sampling
Plan ahead and update schedules to include increased inspection frequency
Train additional staff to facilitate monitoring and sampling
What Happens Now?
Conditions that must be eliminated
Full transcript