Alaska Association of Harbormasters and Port Administrators Wrangell, Alaska October 26, 2010 Shane Serrano ADEC

Alaska Harbors come in different shapes, sizes and ownerships

Clean Water Act Passed by Congress in 1972 and amended several times Act addresses water pollution from point sources and nonpoint sources Point sources are addressed through NPDES permitting Program Nonpoint sources are addressed through grants to implement Best Management Practices

National Pollutant Discharge Elimination System (NPDES) Individual Permits Typically Domestic Wastewater Disposal General Permits Construction GP Multi-Sector GP Vessel GP

Four Questions What is the MSGP? Are You covered by the MSGP? What do You have to do to comply with the MSGP? When does ADEC assume the storm water program from EPA?

What is the MSGP? Section 402(p) of the Clean Water Act directs EPA to develop permit application requirements for stormwater discharges associated with industrial activity EPA developed the NPDES Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Sources The previous version, the MSGP 2000, expired in October 30, 2005 In early 2009 MSGP is reissued in Alaska

Am I covered by the MSGP? One of 29 Industrial Sectors Water Transportation – Sector Q Water Transportation of Freight Ferries Marine Cargo Towing and Tugboat Services Marinas Ship and Boat Building and Repairing Yards – Sector R

Covered Discharges Storm water discharge associated with industrial activity means the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing, processing or raw materials storage areas at an industrial plant. 40 CFR (b)(14)

Coverage Required for Facilities that Perform one or more of the Following Blasting and Painting Material Storage Engine Maintenance and Repair Areas Material Handling Drydock Activities Pressure Washing (May need another NPDES permit)

Need to Meet All Three Conditions Your Facility is included in the regulated SIC Codes Your Facility has regulated activities on your property There is a discharge of the runoff through a point source

What do I have to do to comply with the MSGP? Read the permit Develop a SWPPP or Revise Existing SWPPP Implement SWPPP and Control Measures Submit Notice of Intent Conduct Inspections Conduct Monitoring Implement Corrective Action Maintain Reporting & Recordkeeping

Read the Permit Read Sections 1-7 & 9 and section 8-sector Q or R Read Appendices A-K For details read the Fact Sheet Available at Read permit with your facility in mind Read Sector Q or R Fact Sheet

Developing Your SWPPP EPA Guidance Specific to Industrial Facilities What to Include in SWPPP Common Compliance Problems

Elements of SWPPP Listing of Pollution Prevention Team Description of Site Summary of Potential Pollutant Sources Description of Control Measures List of Schedules and Procedures Document Eligibility Considerations Signature Requirements Additional Documentation

Additional Documentation for SWPPP Copy of Notice of Intent Description of significant spills or leaks Records of employee training Documentation of maintenance of control measures Copies of inspection reports Description of corrective actions taken Documentation of any benchmark exceedances Documentation of status change from active to inactive

Control Measures Must select, design, install and implement control measures (including BMPs) to address *Selection and design considerations *Meet the non-numeric effluent limits *Meet limits contained in applicable effluent limitations guidelines

Non-Numeric Technology-Based Effluent Limits Minimize Exposure Good Housekeeping Maintenance Spill Prevention and Response Procedures Erosion and Sediment Control Management of Runoff

Non-Numeric Technology-Based Effluent Limits Salt Storage Piles Sector Specific Non-Numeric Effluent Limits Employee Training Non-Stormwater Discharges Waste, Garbage and Floatable Debris Dust Generation and Vehicle Tracking of Industrial Materials

Erosion and Sediment Control Alaska Storm Water Guide ADOT&PF SWPPP Guide # # EPA SWPPP Guide EPA Menu of Stormwater BMPs

NOI Submittal to EPA (ADEC after Oct 31, 2009) Existing Dischargers – In operation prior to Oct 30, 2005 and authorized under MSGP 2000 New Dischargers – In operation in between Oct 30, 2005 and date in AK MSGP New Dischargers – In operation after date in AK MSGP Other Eligible Dischargers – In operation prior to October 30, 2005, but not covered under the MSGP 2000 or other NPDES permit

Inspections Routine Facility Inspections Quarterly Visual Assessment of Stormwater Discharges Comprehensive Site Inspections

Monitoring Monitoring Procedures Benchmark Monitoring Effluent Limitations Monitoring

Monitoring and Sampling EPA Guidance How to Prepare for Monitoring How to Conduct Monitoring How to Evaluate Monitoring Results Record-Keeping

Corrective Action Review and Revision to Eliminate Problem Review to Determine if Modifications are Necessary Corrective Action Report Effect of Corrective Action

Reporting and Recordkeeping Report Monitoring Data to ADEC (after Oct 31, 2009) Send Annual Report to ADEC (after Oct 31, 2009) Exceedance Report for Numeric Effluent Limits Additional Reporting Recordkeeping

When Does ADEC Assume the Storm Water Program? Transfer of NPDES Program started October 31, 2008 Phase 1 Domestic Wastewater Seafood Processors Log Transfer Facilities Phase 2 October 31, 2009 Stormwater Phase 3 October 31, 2010 Mining

Changes to MSGP under ADEC The permit will stay the same until 2013 Monitoring data and Annual Reports sent to ADEC Compliance and Enforcement Inspections by ADEC Tidal Grid Usage Survey What information is available and tracked (size, duration, activities, wasteload, etc.) What activities are allowed (type of maintenance) What measures have been employed (collect & treat)