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

2. 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

3. 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.

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

5. 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.

6. 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.

7. 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)

8. 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

9. 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)

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

17. 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.”