1. REGULATORY COMPLIANCE GROUP
November 2011

2. Regulatory Compliance Group
Who we are
What we do
What we can do for you
What we need from you

3. Who We Are Robin Halperin Manager of Regulatory Compliance
Beth Toot-Levy
Senior Environmental Specialist
Sarah Rehner
Environmental Specialist
(Back-up RSO)
Vacant
(RSO)

4. What we do
Ensure the District’s compliance with all environmental rules and regulations
NPDES Permits
Air Permits
Wetland Permits
HW/UW Rules
Asbestos & Lead
Part 503 Rules (Biosolids)
Current & Future Regulations

5. More about what we do
Provide a consistent voice to regulatory agencies
Review and interpret rules, regulations and permits to understand the District’s obligations for compliance
Provide assistance/consultation to management, engineering, operations, analytical services, WQIS, etc. to achieve and maintain compliance

6. More specifically… Prepare and review permit applications
Monitor NPDES permit compliance
Review draft rules and regulations
Prepare the District’s comments on draft rules and permits
Assist in letter and report writing
Develop environmental policies and programs
Assess environmental conditions and make recommendations
Determine proper disposal methods
Manage the District’s Radiation Protection Program
Manage the District’s Industrial SWPPPs

7. Our Goals
Achieve and maintain environmental compliance 100% of the time.
NACWA Gold & Platinum Awards
Anticipate new rules and permit requirements to stay ahead of the game
Provide the necessary support to you our “customers”
Ensure all District activities are covered by the necessary permits

8. Robin Halperin Manager of Regulatory Compliance
Areas of Focus:
Wetlands
Delineations
401/404 Permits
Wetland Mitigation Projects
Radiation Protection Program Management
License compliance
Reducing license footprint & simplifying program
Standard contract language

9. Robin Halperin NPDES Permits ODNR RCAT Chair Construction Projects
Affecting plant operations
Incident Reporting
Power Failure, Flooding, etc.
Permit Renewals
ODNR
Shore Structure Permits
RCAT Chair

10. Robin Halperin Call me:
With questions about Wetlands, permits and compliance/mitigation activities
If you need to assess a property for wetlands and/or environmental contamination (Phase I and Phase II)
With questions about implementation of the Radiation Program
If you don’t know who else to call about a regulatory compliance problem/question

11. Beth Toot-Levy Senior Environmental Specialist
NPDES Permits
Permit renewals
Permit compliance assistance
Water quality issues
Concerns with meeting permit limits
Trends in NPDES permitting
Stormwater Permits (Plants)
SWPPP Maintenance
Annual inspections
New stormwater permits are on the horizon

12. Beth Toot-Levy Biosolids Management Beneficial Reuse of Ash
Part 503 Reports
Beneficial Reuse of Ash
Pilot Project underway at Southerly WWTP
Working with Emerald Environmental and Ohio EPA to beneficially reuse Southerly ash.
Currently conducting Field Test Plots for Blended Topsoil
Other options include bricks, concrete, flowable fill, etc.
Westerly ash next?

13. Beth Toot-Levy Call me:
If it went down the drain and didn’t fall from the sky CALL ME
If it almost went down the drain and didn’t fall from the sky CALL ME
To evaluate water quality trends and potential NPDES compliance issues
Plant/Facility stormwater management questions
Emerging pollutant questions
Nutrient issues
A request is received for residuals info

14. Sarah Rehner Environmental Specialist
Air Emissions
Permits
Permit to Install
Permit to Operate
Permit by Rule
Reporting Requirements
Title V Reports - Southerly
Synthetic Minor Report - Westerly
Non Title V Reports - Easterly (once every two years)
Quarterly Deviation Reports
Miscellaneous Reports

15. Sarah Rehner New SSI MACT Standards Radiation Protection Program
Compliance Required in March 2016
Determining Impacts on Southerly and Westerly
Working with NACWA on Petition for Reconsideration and Legal Challenges
Radiation Protection Program
RSO-In-training
USACE Nationwide Permits
Developing flowchart and checklists

16. Sarah Rehner Call me when:
Considering new air emissions units to be installed (e.g., boilers, emergency generators, etc.)
A deviation of an air permit occurs (e.g., opacity, scrubber water flow rates, scrubber pressure drops, etc.)
A request is received for air emissions data
Air emissions related visits from U.S. EPA, Ohio EPA or Cleveland Division of Air Quality
A project may impacts wetlands or waters of the state
You have Red Tag or Permit to Dig Questions

17. Vacant Environmental Specialist
Waste Management
Hazardous Waste
Obsolete chemicals…
Universal Waste
Light Bulbs, Batteries, etc…
Radiation Protection Program
RSO-In-Training

18. Environmental Specialist
Hazardous Substance Permits
Asbestos
Lead
Call me:
To schedule hazardous and universal waste pick-ups
To determine how a waste should be disposed of
Questions about the Radiation Program

19. Current Engineering-Related Projects
401/404 Permit for Nine Mile Creek
Radiation Control Plan Revisions
NPDES Plant & CSO Permits Renewal
Beneficial Reuse of Ash
Kerriush Park – Nationwide Permit
CSO 036 Contaminated Debris Disposal
SWPPP Annual Inspections
E. 55th Floatables Control
Doan Brook Stream Enhancement Project – Section 106
Environmental Compliance Sharepoint Site
West Creek Confluence Project

20. What we need from you Keep us informed of EPA communications
Phone Calls
Letters
Site Visits
Opportunity to be involved in projects early on the planning/design phase to determine environmental compliance needs
Opportunity to participate in ALL EPA site visits (announced and unannounced)

21. More…
Opportunity to review and provide comments on letters/reports/documents BEFORE they are sent to a Regulatory Agency
To be informed of potential or actual permit or other regulatory issues
If you have a question…just ask!

22. How to contact us
Robin Halperin (Wetlands, CSOs, NPDES, Radiation, RCAT) Office: x6465 Cell: Beth Toot-Levy (NPDES, Stormwater, Residuals) Office: x2236 Cell: Sarah Rehner (Air Permits, Nationwide Permits, Radiation) Office: x6405 Vacant (Hazardous Waste, Universal Waste, Radiation) Office: x