Hydrostatic Testing Draft General Permit Draft Permit Stakeholder Outreach Meeting April 23, 2015 Moderated by: Lillian Gonzalez, Unit Manager, Permits Section Presented by: Maureen Egan, Environmental Protection Specialist

Desired Outcomes for Today’s Meeting Build an understanding of the draft permit Provide opportunity for clarification and dialogue

Agenda Discuss revisions/clarifications Present next steps and timeframes Time for questions

Agenda Discuss revisions/clarifications Present next steps and timeframes Time for questions

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling Control Plan

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling & Reporting requirements for all permittees Control Plan

Provides coverage for: Oil and gas activities AND Hydrostatic testing and flushing from other activities *May cover discharges from potable water distribution systems* Permit Scope

Permit Scope (continued) Does not provide coverage for: Ongoing maintenance of fire suppression systems o Discharge from Water-based fire suppression systems (CW5) Reclaimed water

Questions

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling Control Plan

Limits Sets ADMINISTRATIVELY CONTINUED PERMIT

Limits Sets (continued) 1. Discharges from New equipment 1. Discharges from New equipment to Surface Water (NS) 2. Discharges from Used equipment 2. Discharges from New equipment to Groundwater (NG) 3. Discharges from Used equipment to Surface Water (US) 4. Discharges from Used equipment to Groundwater (UG) 5. Discharges from New or Used equipment to the Colorado River Basin (CR)

Limits Sets (continued)

For example, if a permittee requested: 2 discharge locations (permitted features/outfalls) from testing of Used (U) equipment to Surface (S) Water The certification would include 001-US and 002-US &

Limits Sets (continued)

Questions?

Numeric Effluent Limitations Included for all certifications: o Technology based  pH  Oil and Grease  Total Suspended Solids (for discharges to surface water) o Water Quality Based  Flow  Total Dissolved Solids (for discharges to groundwater) Site specific parameters may be added

Numeric Effluent Limitations Changes Dissolved Iron For all discharges: 300 μg/l (0.3 mg/l) Where there is an applicable water quality standard (WQS) and reasonable potential (RP), then: o For discharges to groundwater:  300 μg/l For discharges to surface water classified as a water supply:  300 μg/l; or  Existing quality as of January 1, 2000 Total Recoverable Iron For all discharges from used equipment: 1,000 μg/l (1 mg/l) Where there is a WQS and RP; For discharges to surface water: o 1,000 μg/l

Numeric Effluent Limitations Changes (continued) Total Dissolved Solids (TDS) Discharges to the Colorado River Basin, Reporting Discharges to the Colorado River Basin – Reporting o Limits set CR Discharges to groundwater mg/l FlowReport Daily Maximum (MGD) – limit o Based on information provided with permit application Monthly Total (MG) Discharge duration (# of days/month) Quarterly total (MG) – report o Limits set CR Estimates allowed

Numeric Effluent Limitations Changes (continued) Total Suspended Solids, mg/l Total Recoverable Iron, μg/l 1, Dissolved Iron, μg/l300---

Benzene and Total BTEX Limits EPA’s Model NPDES Permit for Discharges Resulting from the Cleanup of Gasoline Released from Underground Storage Tanks (June 1989) Technology based limits (Best Professional Judgment) o Benzene - 5 μg/l (daily maximum) o Total BTEX – 100 μg/l (daily maximum)

Questions?

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling Control Plan

Number of Outfalls per Certification Limit of 30 outfalls per certification Options for projects with >30 outfalls / 5 year permit term o Project may be split across multiple certifications o Permit applicant may apply for blanket coverage  Latitudes and longitudes (if known) should still be provided with the permit application

Questions?

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling Control Plan

Blanket Coverage - Reporting Updated reporting requirements for permittees granted blanket coverage ADMINISTRATIVELY CONTINUED PERMIT Permittee requested blanket coverage (statewide) Outfalls included in the certification Based on activity performed (testing of new/used)

Blanket Coverage – Reporting (continued) DRAFT PERMIT Permittee requests blanket coverage Permittee determines for each activity (new/used) for the 5-year permit term: o Maximum # of discharges to surface water in 1 month o Maximum # of discharges to groundwater in 1 month New limits sets will indicate activity/receiving stream: o NS – New/surface waters o US – Used/surface waters o NG – New/groundwater o UG – Used/groundwater

Blanket Coverage – Reporting (continued) January0102 February1100 March2111 April1301 May0101 June0104 July0331 August5321 September2321 October0000 November1100 December1200 Total # (annual) Max # in any given month (for 5 year permit term) 5334 Outfalls in certification 001-NS through 005-NS 001-NG through 003-NG 001-US through 003-US 001-UG through 004-UG

Blanket Coverage – Reporting (continued) 002-NS (April) 001-NS (April) 003-NS (April)

Blanket Coverage – Reporting (continued) 002-NS (April) 001-NS (April) 001-NS (May) 002-NS (May) 001-NS (June)

Questions

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling Control Plan

Sampling ADMINISTRATIVELY CONTINUED PERMIT Samples had to be taken in the 1 st and last hour of discharge OR For discharges <1 hour, taken during 1 st and last 15 minutes

Sampling (continued) DRAFT PERMIT Permittee determines when to collect samples Permittee must collect a minimum of 2 samples per discharge Samples must be representative of the volume and nature of the discharge o Additional samples shall be collected as necessary to ensure representativeness

Questions?

Proposed Revisions/Clarifications Will discuss proposed changes to: Permit scope Limits sets/Numeric effluent limitations Number of outfalls per certification Reporting for permittees authorized under blanket coverage Sampling Control Plan

Control (BMP) Plan ADMINISTRATIVELY CONTINUED PERMIT Optional Best Management Practices (BMP) Management Plan o Specific conditions must be met (Part I.B.3) o BMP plan could be developed in lieu of effluent limits Option was not exercised by permittees during permit cycle

Control Plan Must be developed by all permittees Control Plan shall document: o Control Measures (BMPs) o Spill prevention, response and reporting:  Environmental Release and Incident Reporting Line (See Policy WQE-10) Examples of Control Measures incorporated into Fact Sheet (including from survey)

Questions

Agenda Discuss proposed revisions/clarifications Present next steps and timeframes Time for questions

How to Provide Comments FIRST: Read the Draft General Permit and Fact Sheet written comments to the division at: Mail written comments to the division at: Colorado Dept. of Public Health and Environment Water Quality Control Division 4300 Cherry Creek Drive South WQCD-P-B2 Denver, CO 80246

How to Write Great Comments Tell what don’t like AND what you would prefer Be specific. Cite specific text whenever possible Comment on the permit and fact sheet Don’t hesitate to offer new insight and information

Agenda Discuss revisions/clarifications Present next steps and timeframes Time for questions

Maureen Egan, Environmental Protection Specialist Phone: Website: commerce-and-industry-permits-0 commerce-and-industry-permits-0