6 Easy Steps to Complete before Fall 2016 to Keep Your Site in Compliance with the IGP!
By your Weather-Ready Nation Ambassadors at Alta Environmental
David Renfrew, QISP/ToR, QSD/P, CPSWQ, PMP
Garth Engelhorn, QISP/ToR, CPSWQ
The first day of Fall is September 22 and California’s rainy season is right around the corner. The Industrial General Permit (Permit) reporting year for 2016-2017 began on July 1 and industrial permitees should already be performing monthly site and best management practices (BMPs) inspections, identifying deficiencies, and performing corrective actions where needed. However, facilities also need to be preparing for the rainy season and thinking about what items are needed to ensure storm water discharges won’t convey pollutants off-site. The following list is a guide to help with your program planning and to highlight what is needed prior to the first rain of the season. Additionally, facilities that now fall into in Exceedance Response Action (ERA) Level I should complete their ERA Level I Evaluations prior to October 1.
Guidance for All Facilities
1. TRAINING – Make sure to do annual training for your staff, department leads, pollution prevention team (PPT), and the legally responsible person (LRP)/duly authorized representative (DAR) prior to the rainy season. Make sure the facility understands what the Permit is, what steps are required, and what items need to be uploaded to SMARTs and certified by the LRP or DAR throughout the season. Staff must be aware of the minimum required BMPs outlined in the Storm Water Pollution Prevention Plan (SWPPP).
2. PRE-RAINY SEASON SITE CLEANING – While all facilities should be implementing their SWPPPs on an on-going basis, it is a good idea to do a thorough facility wide cleanup prior to the rainy season. Buildup of pollutants occur between storm events, especially during the extended summer dry season. This buildup occurs on all areas, including non-industrial areas that may influence sample locations. It is a good idea to inform your teams about the concept of storm water, where it picks up pollutants, and where it may influence sample results. The cleaning should be done with respect to the drainage areas, the MS4 pipes and inlets, sample locations, rooftops, areas subject to erosion, and those areas that do not get attention during the normal course of the year. Replace any storm drain inlet filters that are torn, worn, or overwhelmed with trash and debris. In some cases, a specialty professional cleaning contractor may be needed to perform drainage cleaning (e.g., a jetting and vacuum truck). Lastly, remember that non-storm water discharges should not leave your site. Any water used to clean the site should be properly contained and disposed of in the appropriate waste stream.
3. GET YOUR SAMPLE KITS SET UP – Sample kits should be prepared and placed in a specified location where all sampling team members have easy access. Make sure to get new sample containers from your designated laboratory and discuss with them the volume and preservatives needed for each test. Have a separate sample set for each sample location if you have multiple sample locations. Pre-fill out the chain-of-custody document and pre-label the containers with the appropriate sample location. The only thing the team will need to do during an event is to fill the appropriate bottles, add the date and time the sample containers, and place them back in the sample cooler with ice.
4. CONDUCT A MOCK SAMPLING EVENT – During the training in item #1 above, it is a good idea to discuss the sampling requirements. However, class room training doesn’t really convey what obstacles might be encountered. It is a good idea to do a mock sample event with the sampling team. Have them get a sample kit and the needed equipment to collect the sample. Walk out to each sample location and run through the sampling procedures, safety concerns, contamination sources, locations, and timing. Discuss what is and what is not a qualified sampling event. A qualified sampling event is a) produces a discharge for at least one drainage area; and, b) is preceded by 48 hours with no discharge from any drainage area. Samples need to be collected during normal business hours within 4 hours¹ of the beginning of discharge.
5. GET COVERS IN PLACE WHERE NEEDED – One of the easiest methods to prevent exposure of pollutants from industrial sources is to cover the source with a water proof tarp. You should identify any sources that need to be covered. Make sure tarps are anchored securely and can withstand high winds that often occur when weather systems pass through. It is also important to divert water away from sources where possible. Make sure staff are trained on the location of the tarps, when they need to be deployed, and how to secure them. It is important to prevent conditions where the tarp may create a pool and then collapse under the weight of accumulated water. If water does accumulate, do not allow it to come in contact with the sources you are addressing. Don’t overlook your large roll-off waste bins, the Permit requires them to be covered whenever they are not in use (i.e., loading/unloading). It is a good idea to talk to your waster service or recycling provider and ask to have them replaced with a covered bin. If they don’t have them, you should look for a new provider or consider making your own covers. Just remember to make and A-frame so the water shed off the cover when deployed.
6. START TRACKING THE WEATHER – Get familiar with weather tracking resources. Start reading daily weather forecasts on the national weather service (NWS), watching the evening news, or sign up with a weather alert service. The NWS has several recommendations subscription services for alert messages such as texts or email services (http://www.weather.gov/subscribe). We have recently experimented with IfWeather.com (http://ifweather.com/) and the Darksky apps which appear to be effective but should not be your only resource. We recommend using a variety of weather tracking tools so that you aren’t surprised when it does start raining.
Additional Considerations for ERA Level I Facilities
Facilities that had sample results above the Permit’s Numeric Action Levels (NALs) during the 2015-2016 Permit year entered into ERA Level I on July 1. Facilities in ERA Level I will need to consider the following actions and deadlines.
Alta’s experts can provide your business with proactive solutions and BMP recommendations to mitigate the escalating cost of compliance and to prevent future NAL exceedances. If your facility is in ERA Level 1, Alta’s QISPs (we have five in house) can conduct your ERA Level 1 Evaluation and ERA Level 1 Report. To learn more, or for assistance keeping your business in compliance, give us a call at 562-495-5777 or email our Water Resources experts.
David Renfrew, QISP/ToR, QSD, CPSWQ, can be reached via email at firstname.lastname@example.org.
Garth Engelhorn, QISP/ToR, CPSWQ, can be reached via email at email@example.com.