Presentation on theme: "September 23 rd, 2014. Welcome! Sally Anson, San Diego County Office of Education (SDCOE) Annika Kubischta & John Quenzer, D-M AX Engineering, Inc. (D-M."— Presentation transcript:
September 23 rd, 2014
Welcome! Sally Anson, San Diego County Office of Education (SDCOE) Annika Kubischta & John Quenzer, D-M AX Engineering, Inc. (D-M AX )
Outline New Industrial Permit requirements Compliance strategies Sample collection protocols Districts selected for sample collection
New Permit Requirements Minimum BMPs Visual observations Monthly When Sampling Sampling Events Numeric Action Levels
Generally should already be implemented Good Housekeeping (Cleaning/Storage) Preventive Maintenance Spill and Leak Prevention & Response Material & Waste Management Erosion & Sediment Controls Employee Training Quality Assurance & Record Keeping Will be detailed in the new SWPPPs New Permit: Minimum BMPs
New Permit: Visual Observations: Monthly When do I complete observations? All Districts, Every Year, Every Month Once a month, every month of the year. Even months when you had a sample event. Within daytime operating hours On days without precipitation What do I need to look at? “Outdoor industrial equipment and storage areas, outdoor industrial activities areas, BMPs, and all other potential source of industrial pollutants.”
Treat as a monthly site inspection Ensure that nothing is entering the storm drain system during dry weather. If a discharge is found, describe how it was discontinued. Ensure all outdoor areas are clean and maintained. What next? Send copy of form to Sally and Annika New Permit: Visual Observations: Monthly
New Permit: Visual Observations: Sampling Event When do I complete sampling event visual observations? All Districts, Every Year Complete at the time of sampling. Complete at every sample point. Measure pH using test strips, and include value on form.
New Permit: Visual Observations: Sampling Event What am I looking for? Ensure only rain water enters the storm drains If visual pollutants are present, find and abate the source Floating/suspended materials Oil and grease Discolorations Turbidity Odors Trash/debris What next? Send copy of form to Sally and Annika
New Permit: Sampling Events When do I collect a sample? All Districts, Twice Every Year: First sample: July-December Second sample: January-June During a qualified storm event (QSE): No runoff for 48 hours prior to the event Generates runoff during operating hours Within 4 hours of: The start of runoff, OR: The start of facility operations (if runoff started within the prior 12 hours) Within daytime operating hours under safe conditions
Instantaneous NAL pH: 9 Total Suspended Solids: 400 mg/L Oil & Grease: 25 mg/L If 2 or more samples exceed the numbers above, an NAL is triggered New Permit: Numeric Action Levels (NALs)
Annual Average NAL Cadmium: mg/L Copper: mg/L Lead: mg/L Nickel: 1.02 mg/L Zinc: 0.26 mg/L Oil & Grease: 15 mg/L Total Suspended Solids: 100 mg/L If the average of values for the samples taken over the year exceed the numbers above, an NAL is triggered New Permit: Numeric Action Levels (NALs)
What happens if I have an NAL Exceedance? Enter Level 1 for that pollutant: Complete evaluation by Qualified Industrial Storm Water Practitioner (QISP) Identify BMPs and SWPPP revisions Submit Report Takes 4 QSEs without NALs to return to baseline Continued NAL exceedances will result in Level 2: Involves preparing an action plan, technical report, BMP demonstration, etc. New Permit: Numeric Action Levels (NALs)
Answer: All of the above Answer: All of the above New Permit Pop quiz: What conditions are required for me to sample? No rain for 48 hours prior to the storm event The storm began less than 12 hours ago It is during regular facility hours It is within 4 hours of the start of runoff OR the start of business hours
Answer: A & C Answer: A & C Every month When it is not raining When Annika calls at the end of the year When taking a sample New Permit Pop quiz: When do I complete monthly visual observations? Extra Credit: What else? Answer: During regular business hours
Answer: A, C, D = False; B= True Answer: A, C, D = False; B= True New Permit pop quiz: True or False? My district only needs to complete storm water tasks during the wet season (Oct-May) If I take a sample in September, 2015 and it rains in December, I need to take a sample. If I don’t sample during July-December, 2015, then I need to take 2 samples in January-June If there is a qualifying rain event on July 1, 2015, I need to take a sample.
No industrial exposure = no permit coverage! All activities and materials protected from contact with rainfall or runoff No runoff = no sampling! Consider redirecting flows to infiltration basins, or to irrigation reservoirs, etc. Transition year opportunities The exceedance you know is better than the one you don’t. Test now! Compliance Strategies
Selected for full, old Permit Sampling: Alpine Union (001) Jamul-Dulzura Union (001) Borrego Springs Unified (001) Ramona Unified (001) Brawley Elementary (001) San Marcos Unified (001, 002) Cajon Valley Union (001) San Ysidro (001) El Centro Elementary (001) Valley Center-Pauma Unified (001) Escondido Union High (001, 002) Vista Unified (001, 002) Fallbrook Union Elementary (001, 002) Warner Unified (001, 002)
Potential for supplemental new Permit sampling: Capistrano Unified - Aliso Viejo Oceanside Unified School District Capistrano Unified - Capistrano Beach Poway Unified School District Grossmont Union High School District San Dieguito Union High School District La Mesa-Spring Valley School District Santee School District Lakeside Union School District South Bay Union School District Mountain Empire Unified School District Recommended especially for Zinc, Copper, and TSS if you have had high sample results, or have never sampled. Small kits provided by EMA: $52.50 for analysis
Pollutant Identification Activity Many pollutants can be identified without lab work Group exercise: 15 minutes Sample 1: Sample 2: Sample 3: Sample 4: Sample 5:
Sample result improvement: Zinc & Copper Common Sources: Engine, brake, and tire wear dust Galvanized items Residues end up in oil drips Solutions: Increased/strategic sweeping, steam cleaning, spot cleaning Cover storage and work areas or move indoors Stabilize unpaved parking and driveway areas Protect storm drain inlets Install treatment/redirect Compliance Strategies
Sample result improvement: TSS Common Sources: Engine, brake, and tire wear dust Landscape erosion Unpaved parking and driveway areas Solutions: Increased/strategic sweeping Stabilize unpaved parking and driveway areas Protect storm drain inlets Install treatment/redirect Compliance Strategies
Sample result improvement: Oil & Grease Common Sources: Motor oil drips and leaks Oily/greasy equipment Solutions: Increased spill prevention and cleanup Cover equipment storage and work areas Protect storm drain inlets with an oil absorbent boom Install treatment Compliance Strategies
Install treatment/Redirect Mimic natural processes by working to keep rainwater from running off site altogether, or filter out the pollutants on its way downstream Compliance Strategies
Filtration options Biological (direct flow to landscaping or manufactured inserts) Filter inserts/fabric Booms/wattles, sandbags Separators Compliance Strategies
Storm Water Sample Collection How do I collect a sample? What’s in the EMA cooler? How do I use what’s in the cooler? How do I fill out the Chain of Custody form? I’ve collected the sample, what now?
How do I collect a sample? 1.Do a pH paper test 2.Wherever possible, use the sample bottle to collect water directly 3.If another container is used, ensure the container is clean, and rinse with sample water before collecting
How do I collect a sample? 3.Avoid collecting leaves or debris 4.Sample flowing, not pooled, water 5.Sample AFTER any installed treatment device 6. Call EMA ASAP to notify of drop-off time
What’s in the EMA cooler? 1.One (1) Liter Amber glass jar with HCl – Blue Dot (marked #1) 2.One (1) 125 mL Amber glass jar with HCl – Blue Dot 3. Two (2) VOA glass Vials with HCl – Blue Dots & Bubble Wrap 4. One (1) 250 mL plastic with HNO3 – Green Dot 5. One (1) 250 ml plastic (no preservative) 6. One (1) Liter plastic (no preservative)
How do I use what’s in the cooler? 1.Fill One (1) Liter Amber glass jar with HCl – Blue Dot (marked #1) – FIRST! 2.Fill the other glass bottles with Blue Dot & Bubble Wrap 2 nd (3 total) zero headspace! 3.Fill 250 mL plastic with HNO3 – Green Dot, 3 rd 4.Fill 25o mL plastic unpreserved 4 th 5.If sample remaining, fill last bottle.
How do I use what’s in the cooler? Zero Headspace? This means that the bottle must not have bubbles inside: 1.Fill bottles all the way 2.Screw on the lid 3.Turn bottle upside down to check for bubbles 4.If pea-sized or smaller bubble exists, you are done 5.If larger bubble exists, add more sample and check again
How do I use what’s in the cooler? Wear gloves! Wear gloves! Fill bottles with preservatives first! Fill bottles with preservatives first! Label bottles with discharge point, date, and time of sample Label bottles with discharge point, date, and time of sample Place bottles in cooler with ice Place bottles in cooler with ice Over-fill bottles that contain preservatives DO NOT: DO:
How do I fill out the chain of custody? Your Name District Name Discharge point # Sample date & time #glass/#plastic (ex: 4g/2-3p) Your info Date & time given/sent to lab personnel
I’ve collected the sample, what now? Pack samples carefully using cushion Pack samples carefully using cushion Samples must be sent to EMA (address on COC) Samples must be sent to EMA (address on COC) If shipping, complete “Relinquished by” section If shipping, complete “Relinquished by” section If delivering, wait until arrival at EMA If delivering, wait until arrival at EMA
Answer: D Answer: D Pop quiz: Where to sample? = Flowing water = Puddled water = Boom / Wattle
Answer: B & C Answer: B & C Pop quiz: Which bottles require zero headspace?
What’s in store for ? Continue procedures under the old Permit until July 1, 2015 SWPPP revisions Make changes now if you can! Review facility layout Review facility storage Review BMPs in place Site visits Effort to reduce pollutant levels
What else do I need to do? For : Annual Employee Training (Retain log) SWPPP Implementation Monitoring and Observations Annual Report (Due July 1 st ) Provide observation worksheets, and signed ACSCE, to Sally & Annika via After notification that it’s ready, log on to SMARTS to download and review report. Request changes, or certify report as-is. Save copy of confirmation page for your records.
Questions? Thank you for keeping storm water clean!
Contacts Sally Anson (858) 292–3598 Annika Kubischta (858) ext. 20 You did it! Thanks for being storm water super- stars! See you next time!