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Welcome to the Frog Environmental Winery Compliance Association
Storm Water Permitting Workshop 800 E. Ocean Blvd, Suite | Long Beach, CA | (310) 241 – 0866o
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Winery Compliance Association
Storm Water Permitting Workshop Welcome: Background and Experience New Permit Regulations: SMARTS and SWPPPs New Permit Regulations: Monitoring and Mandatory BMPs New Permit Regulations: Maintaining Baseline Status How Are Wineries Covered? NOI, NEC, NoNA Winery Ponds and Storm Water Steps to Evaluate Wineries for Coverage Benefits of Joining Our Winery Compliance Association Costs Water Reuse System Q & A
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Welcome: Background and Experience
Qualifications and Background 16 Years in Business Over 950 Clients in California – Largest Boots on the Ground Company in California Our Winery Clients have Clean Records – Years with No Lawsuits, No Violations, No Penalties Industrial Storm Water Trainer of Record (ToR) Trained Staff with CPSWQ, QSD and QSP Certifications
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New Permit Regulations
SMARTS Mandatory recertification of NOI Updated SWPPP on SMARTS at all times Facility site map on SMARTS All sample results uploaded to SMARTS within 30 days of receipt Annual Reports on SMARTS SWPPP SWPPP Requirements: Site Map, Industrial Materials List, Detailed Pollutant Source Info, BMP descriptions and Monitoring Implementation Plan (MIP) Changes to operations documented in SWPPP and uploaded to SMARTS SWPPP Team
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New Permit Regulations (continued)
Monitoring Qualifying Storm Event (QSE): Produces discharge in at least one drainage area, preceded by 48 hours with no discharge Sample 4 times per storm water year (only 2 times if you join a compliance group; 1 time between July–Dec. 31, and 1 time between Jan.– June 30) Samples from each discharge location shall be collected within 4 hours of: The start of discharge The start of facility operating hours if the QSE occurs in the previous 12 hours Mandatory BMPs Minimum BMPs Now REQUIRED Good Housekeeping Preventive Maintenance Spill and Leak Prevention Response Material Handling/ Waste Mgmt. Erosion Control Employee Training Program Advanced BMPs necessary if pollutants exceed Numeric Action Levels (NALs)
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New Permit Regulations (continued) Maintaining Baseline Status
Every industrial facility has the opportunity to start with a clean slate as of July 1st, 2015. Once you go to Level 1 or Level 2 it is difficult to return to baseline status . By fully utilizing BMPs now, you can avoid the additional costs and requirements of Level 1 or Level 2 Status. Level 1 Status If a facility has an exceedance (Annual or Instantaneous) in , it will result in a status change to Level 1 for any given parameter in Level 1 requirements: QISP oversight of activities, QISP prepared Exceedance Response Action (ERA) Report completed by Oct. 1 and uploaded to SMARTS by Jan. 1 following status change, and additional BMPs to address exceedances. Level 2 Status If an NAL exceedance for the same parameter takes place in the subsequent reporting year ( ), a facility will change to Level 2 Status the following year ( ). Level 2 requirements: QISP prepared Level 2 ERA Action Plan and Level 2 ERA Technical Report submitted via SMARTS by Jan. 1 following status change, additional BMPs to address exceedances.
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NEC NOI NoNA How Are Wineries Covered? Notice of Intent
No Exposure Certification Partial coverage – Eligible if all areas of industrial activities, materials and wastes have no exposure to storm water Notice of Intent Full Coverage – Required if you have areas of industrial activity exposed to storm water discharge Notice of Non-Applicability Exemption – Eligible if facility is not hydrologically connected to the waters of the US, or built to contain a 100 year maximum precipitation event or series of events.
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Winery Ponds and Storm Water
No discharge of wastes to surface waters and surface water drainage courses. No bypass or overflow of untreated or partially treated wastes from anywhere within the collection, treatment, or disposal system. No application of treated process wastewater or processing solids 48 hours before, during, or after rainfall, or when soils are saturated. Treatment and disposal to be designed for the maximum daily flow and organic loading generated, including flows from precipitation. Ponds designed to contain all wastewater flows and rainfall during the rainy season and be operated and maintained to prevent inundation or washout due to floods with a 100-year return frequency. Ponds required to maintain at least 2 feet of freeboard at all times. Infiltration considerations. Individual NPDES instead of General NPDES.
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Steps to Evaluate Wineries for Coverage
By joining the Frog Environmental Winery Compliance Association, you will be placed in the correct Compliance Group based on the type of coverage your facility qualifies for. Site Visit Perform site walk to determine eligibility for NEC, NOI or NoNA NEC Our expert storm water professionals will determine eligibility and applicability based on industrial activity, materials or waste being exposed to storm water run-off, or the potential to retain enough storm water. NOI NoNA
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Breakdown of Steps NEC NOI NoNA
Can you certify that no exposure exists? Avoid industrial activity exposed to storm water including processing areas, equipment or vehicle tracking, outdoor storage in open or leaking containers, material handling, or partially covered dumpsters. NEC Do you have areas where industrial activity Is exposed to storm water? Membership in the Winery Compliance Association makes it simple to avoid liability by letting Frog do all the work for you. From uploading your NOI into SMARTS, to monitoring and filing your reports, we make it all easy for you. NOI Can you certify that your site is not hydrologically connected to waters of the U.S. or can hold a precipitation event greater than historic maximum levels? If you qualify for the NoNA exemption, Frog will help you obtain NoNA coverage. NoNA
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Benefits of Joining Our Winery Compliance Association
Winery Compliance Association Benefits Reduced sampling – only required to sample 2 times a year. Consolidated Level 1 ERA Reporting for all Level 1 group members prepared by Frog Environmental Level 2 ERA Action Plans and Technical Reports for all Level 2 group members prepared by Frog Environmental Shared costs by group seminars and group Qualified Industrial Stormwater Practitioner (QISP) training lead by an Industrial Trainer of Record (ToR). Frog Environmental takes care of the application process, your SWPPP, monitoring, reporting, and we make sure you have the proper BMPs implemented on your site.
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Costs Coverage Cost NEC Coverage $925 per year (with 3 year contract)
NOI Coverage (Monitoring Contract) $2,000 per year NoNA Coverage Site Dependent SWPPP $3,000 per SWPPP Additional Services – Sampling and Lab Services; Environmental Audits; SWPPP Training Site Dependent If you request NEC coverage, but do not qualify for an NEC after a Site walk, Frog Environmental will apply your NEC Contract cost to An NOI Monitoring Contract.
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Water Reuse System Benefits: Reduce water use
Release less water into septic Eliminate discharges into local waterways Eliminate/reduce water hauling costs Features: Solids removal down to 5 microns Remove oil/grease, organics and metals Oil absorbents and flocculants included for pretreatment Simple to set up, use, and maintain Air driver pumps, 10 horsepower/30 SCFM air compressor Available Upgrades: Systems are fully customizable and can be expanded to treat for additional pollutants Various medias available to treat multiple pollutants Electric pumps available
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Q & A Thank you for attending our seminar.
We look forward to answering your questions.
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