ACA Fall Conference September 15, 2016 4:00 pm to 5:00 pm Industrial General Storm Water Permit requirements for fueling activities Aaron Ortiz QISP WGR Southwest Inc.

California Industrial General Storm Water Permit (General Permit) Airports operate under Standard Industrial Classification (SIC) code of 4581 for “Airports, Flying Fields, and Airport Terminal Services.” A SIC code of 4581 is listed under Category #8 of Attachment A of the Industrial General Permit requiring permit coverage

General Permit What is the General Permit? State issued permit based on the Federal Clean Water Act Requires certain types of industries (recyclers, landfills, airports, manufacturing, etc.) to have Best Management Practices (BMPs) for storm water discharges. State requirement backed and required by Federal Law.

General Permit Only for maintenance operations which include: Vehicle rehabilitation Mechanical repairs Painting, Fueling Lubrication, and Deicing (Depending)

General Permit Covered facilities are required to perform certain mandatory Best Management Practices to the extent feasible in order to be in and maintain compliance with the General Permit.

What exactly are BMPs Best Management Practices Best Management Practice (BMPs) are activities, prohibition of practices, maintenance procedures, other management practices and structures used to prevent or reduce the pollution of storm water discharge. In other words… Anything you do or practice (non-structural) and anything your build (structural) to reduce, or eliminate pollutants from coming into contact with storm water.

Minimum (Mandatory) BMPs Mostly non-structural, and now mandatory What exactly are BMPs Minimum (Mandatory) BMPs Mostly non-structural, and now mandatory (good housekeeping, preventive maintenance, spill and leak prevention and response, material handling and waste mgmt., erosion and sediment controls, employee training, quality assurance and record keeping) Advanced BMPs Mostly structural, and required to the extent feasible considering technological and economic availability (treatment control, exposure minimization, storm water containment and discharge reduction)

Fueling BMPs A prevalent theme throughout the Best Management Practices outlined in the General Permit section X is pollutant prevention/reduction through: Assessment Planning; and Procedures

Assessing Fueling Potential Pollutants Access what are the potential pollutants (Jet-A, Av-gas, diesel, Diesel Exhaust Fluid, etc.) Determine what extra storm water sampling parameters, if any, will need to be added to the required General Permit storm water monitoring (TPH-d, TPH-av, ammonia)

Planning BMP Application Now that you have determined what the potential pollutants are, the next step is to determine how to apply the minimum required BMPs

Planning BMP Application While there are 7 required minimum BMPs, lets quickly touch on how to apply the following: Good housekeeping Preventive maintenance Spill and leak prevention and response

Planning BMP Application Good Housekeeping Determine how best to clean the areas Sweeping & frequency Power washing Proper disposal of waste Minimize track out Keep what is in a contained area from escaping

Planning BMP Application Preventive Maintenance Identify all equipment and systems that may spill or leak pollutants; Make a determination as to what could happen to the equipment and systems which could cause a leak Perform appropriate scheduled maintenance

Planning BMP Application Spill and leak prevention and response Determine what spill response materials and equipment (spill kits) are appropriate to respond to spill for any potential leak or spill areas Identify where your spill kits are located

Planning BMP Application Spill and leak prevention and response Make sure the spill kits are stocked and ready for use Identify and train personnel to respond to spills and leak

BMP Application Procedures Develop procedures so if equipment maintenance issues/conditions are observed that could cause a spill or leak; if possible, address it before a leak or drip develops Develop and implement spill and leak response procedures. Spilled or leaked industrial materials need to be cleaned promptly and disposed of properly Identify which personnel need to be trained in spill prevention and response

Final Point One of America’s founding fathers , Benjamin Franklin once wrote in his famous periodical “Poor Richard’s Almanac,” “An ounce of prevention is worth a pound of cure.”