Stormwater Compliance Training South County Regional Wastewater Authority July 2015 Jack Rosenburg CH2M / Oakland

2 Why are we here? Plant discharges stormwater from areas that are exposed to industrial activity Wastewater treatment plants are required to obtain coverage under the Industrial General Stormwater Permit (IGP) Plant has had IGP coverage since early 1990s New permit took effect on July 1, 2015 We have new: – Stormwater Pollution Prevention Plan (SWPPP) – Stormwater Pollution Prevention Team – Stormwater monitoring program – Numeric action levels Permit and SWPPP require periodic stormwater training

3 What will we cover? Background on new permit Overview of Stormwater Pollution Prevention Plan Stormwater Pollution Prevention Team Best Management Practices to keep pollutants out of stormwater

4 Purpose of IGP: keep industrial pollutants out of stormwater Identification of potential pollutants and how they might reach stormwater Prevention through Best Management Practices Inspections and monitoring to verify effectiveness Numeric Action Levels (NALs) to measure effectiveness Corrective measures if action levels are exceeded Online reporting Leadership from the Stormwater Pollution Prevention Team

5 IGP is an NPDES Permit issued under the Federal Clean Water Act Enforced by Regional Water Board Can be enforced by third party lawsuits SWPPP and monitoring data publicly available online

6 Scope of the permit Permit covers discharges to waters of the US of: – Stormwater from industrial activities – Certain authorized non-stormwater discharges Permit does not cover: – Construction activities – Discharges of treated wastewater – Unauthorized non-stormwater discharges

7 Focus of stormwater management program

8 Treatment Plant Area Stormwater discharge to retention pond Included in SWPPP to: Prevent pollution of groundwater In case discharge from retention pond occurs

9 Influent Pump Station Stormwater from northern portion of IPS flows to storm drain inlets, which flow to Llagas Creek

10 Stormwater Pollution Prevention Team Thom Vinson: Plant Manager – Provides overall direction and allocates resources for stormwater compliance; reviews stormwater documents and submittals; Legally Responsible Person for certifying stormwater submittals Jack Rosenburg: Team Leader – Oversees SWPPP implementation; performs stormwater inspections, sampling; and annual compliance evaluation; reviews stormwater sampling data Garon Goularte: Team Member – Performs stormwater inspections, sampling; and annual compliance evaluation; reviews stormwater sampling data Operators – Perform stormwater sample collection when necessary Everyone: use best management practices to prevent stormwater pollution

11 Dick’s new stormwater role Thanks, Dick

12 Stormwater Pollution Prevention Plan (SWPPP) Introduction Facility Description & Maps Potential Stormwater Pollution Sources Stormwater Best Management Practices Monitoring Implementation Plan Annual Comprehensive Site Compliance Evaluation & Annual Report Recordkeeping and Compliance Calendar

13 Industrial materials: potential stormwater pollutants Diesel Fuel Transformer oil Waste oil Sodium hypochlorite Liquid polymer Sodium bisulfite Aluminum sulfate (liquid alum) Sodium hydroxide Raw wastewater Secondary treated wastewater Grit Solids (sewage sludge) Hauled septage

14 Potential stormwater pollution sources Industrial processes – Wastewater treatment – Vehicle & equipment cleaning – Maintenance – Waste disposal Materials loading & unloading – Raw septage delivery – Bulk chemical & fuel delivery – Used oil pickup – Solids loading and transportation Storage – Bulk chemicals & fuel – Used oil – Grit – Oil-filled electrical equipment Spills & Leaks Erosion of unpaved surfaces Unauthorized non-stormwater discharges

15 Best management practices (BMPs) to prevent stormwater pollution Containment – Secondary containment for bulk chemical and fuel tanks, containers, and fuel piping – Plant drain system – Stormwater retention pond Erosion control – Surfacing (pavement, gravel, vegetation, mulch) – No driving on dirt levees when raining

16 Best management practices (BMPs) to prevent stormwater pollution Good housekeeping – All staff have housekeeping responsibilities per Equipment Operating Procedure #19: Plant Coordination – Littering prohibited – Keep materials away from storm drains – Septage hauler cleanup restricted to area that drains to plant Inspections – SWPP Team performs IGP-required inspections (monthly; during stormwater sampling; annual compliance inspection) – Regular inspections scheduled by computerized maintenance management system – Supervisors review inspection reports

17 Best management practices (BMPs) to prevent stormwater pollution Maintenance – Automated scheduling; corrective maintenance work orders for unplanned events – Maintenance verification by supervisors – Vehicle washing restricted to areas that drain to plant drain system – Equipment cleaning restricted to areas that drain to plant drain system or ponds – All catch basins in the storm drain system are cleaned out and storm drain lines are jetted annually

18 Best management practices (BMPs) to prevent stormwater pollution Chemical & fuel deliveries – Driver reports to plant office before offloading material – Must be supervised by plant staff – Position vehicle within contained area – Chock wheels; place vehicle in N or P; set parking brake – Verify receiving tank’s capacity before offloading – Cover storm drain inlets with rubber mats – Have spill kit available nearby – Use drip pans or buckets under hose connection points – Secure quick connections properly before transfer – Blow out or drain transfer lines before breaking connection – Inspect and secure drain outlets on truck before departing

19 Best management practices (BMPs) to prevent stormwater pollution Biosolids and grit truck loading – Truck loading and cleaning activities take place in designated areas that drain to plant drain system – Trucks must be covered and cleaned prior to leaving facility Industrial materials handling – Industrial materials not in ASTs are stored in covered areas or indoors – All materials are labeled – Industrial materials that could be mobilized by contact with stormwater not handled outdoors during a rain event – Pesticide preparation, mixing, and filling only performed in areas that do not drain to storm drain system – Do not accept delivery of leaking or damaged packaged industrial materials

20 Best management practices (BMPs) to prevent stormwater pollution Alarms – Alarms system monitored by plant operators Equipment Operating Procedure #18: Plant Alarms Equipment Operating Procedure #19: Plant Coordination Spill Response Procedures – Emergency Response and Hazardous Waste Contingency Plan – Spill kits located in key locations throughout plant; annual restocking in November Training – Periodic training on the IGP, SWPPP, and BMPs

21 Non-Stormwater Discharges Authorized non-stormwater discharges identified in the SWPPP – Fire hydrant flushing – Electrical vault dewatering – Clarifier dewatering All other non-stormwater discharges are prohibited; if observed, should be reported to SWPP Team

22 Evaluating Stormwater Program Effectiveness (SWPP Team) Monthly inspections to check for unauthorized non-stormwater discharges, potential sources of pollution, BMP implementation Sample stormwater discharges twice during each half-year – Visual observation of stormwater discharge for evidence of contamination – Compare results to Numeric Action Levels (NALs) for pH, total suspended solids, oil and grease – Plant enters Level 1 status if NALs exceeded; must evaluate potential pollutant sources and implement additional BMPs Annual comprehensive site compliance evaluation Annual reporting via online SMARTS system

23 Who is responsible for keeping pollutants out of stormwater?

24 Who is responsible for keeping pollutants out of stormwater?

25