1. NDEQ Industrial Storm Water General Discharge Permit Presentation for: Nebraska Aviation Symposium January 27, 2011 By: Bill Imig, Environmental Scientist – Olsson Associates

2. Permit Applicability Sector S- Air Transportation Facilities SIC codes 4512-4581 451 Air Transportation, Scheduled, and Air Courier Services 4512 Air Transportation, Scheduled 4513 Air Courier Service 4522 Air Transportation, Non-scheduled 4581 Airports, Flying Fields, and Airport Terminal Services

3. Covered Activities Storm water discharges from those portions of the air transportation facility that are involved in: Aircraft maintenance – includes rehabilitation, mechanical repairs, painting, fueling Equipment cleaning Deicing operations

4. Activities Not Allowed under the Permit Discharges of wash water Discharges of deicing chemicals during dry weather

5. No Exposure Certification All industrial materials and activities are protected from exposure to rain, snow, or runoff Industrial materials or activities include: – Material handling equipment – Industrial machinery – Raw Materials – Products (Fuel, Oil, etc) – Waste Products Exceptions – Drums, Barrels, Tanks that are sealed and not leaking – Adequately maintained vehicles used for material handling

6. No Exposure Checklist Using, storing or cleaning industrial machinery or equipment or areas where residuals from industrial machinery or equipment remain and are exposed to storm water Materials or residuals from spills exposed to storm water Materials or products from past industrial activities Material handling equipment (except adequately maintained vehicles) Materials or products during loading/unloading or transporting activities

7. No Exposure Checklist Materials or products stored outdoors (except products intended for outdoor use where exposure to storm water does not result in discharge of pollutants Materials contained in open, deteriorated or leaking storage drums, barrels, tanks and similar containers Materials or products handled/stored on roads or railways owned or maintained by the permittee

8. No Exposure Checklist Waste materials (except waste in covered, non-leaking containers (dumpsters) Application or disposal of process wastewater Particulate matter or visible deposits of residuals from roof stacks and or vents not otherwise regulated (under an air quality permit) and evident in storm water

9. 2011 Draft Permit Replaces existing permit first issued 1997 NDEQ will hold a public hearing February 22, 2011 Final permit target date is April 1, 2011 Most Significant Changes – T&E Species Impact Evaluation for New or Expanded Dischargers – Impaired Waters, Class A, Class B – Discharge Monitoring (Visual and Benchmark)

10. Implementation Timeline Will be pushed back pending issuance of the permit Source: NDEQ

11. Limitations on Coverage Non-storm water discharges T&E Species and Critical Habitat Protection New or Expanded discharges to Impaired Waters, Class A and B Resource Waters, Drinking Water Supplies

12. Allowable Non-Storm Water Allowable non-storm water discharges – Fire fighting – Fire suppression system flushing – Potable water line flushing except chlorination – Condensate from air conditioners, coolers, etc. – Irrigation drainage from agricultural lands – Landscape irrigation w/ approved application of fertilizer, etc. – External building wash down without detergents – Groundwater and spring water – Foundation drains if not contaminated with process water – Windblown mist from cooling towers

13. T&E Species Evaluation If you are a new or expanded discharger coverage under general permit is only available if storm water does not adversely impact listed species and habitat. NDEQ has prepared a 9 point checklist to determine if discharge has potential to impact T and E Species.

14. Impaired, Class A &B, and Drinking Water Supply New or Expanded Discharge to Impaired Water – Meet TMDLs if established New or Expanded discharge to class A – not eligible under the general permit New or Expanded discharge to class B – prior written approval from NDEQ New or Expanded discharge to Drinking Water – prior written approval from NDEQ

15. Source: NDEQ Impaired Waters

16. Class A & B State Resource Waters and Drinking Water Source: NDEQ

17. Benchmark Monitoring Deicing Season- Collect samples during timeframe under which deicing activities occur (usually October – April) At all Outfalls that collect runoff from deicing areas Collect 4 separate samples during deicing season Source: NDEQ

18. Benchmark Monitoring Results If average of first 4 values < benchmark – done sampling for permit term If average > benchmark need to reevaluate BMPs & controls. Make revisions and continue monitoring Or determine no further reductions are economically practicable or achievable and notify NDEQ

19. Contents of SWPPP Pollution Prevention Team Site Description – locations, activities, drainage, outfalls, etc. Site Map – submit copy to NDEQ with NOI Identify Potential Pollutants – Materials storage, Operational Activities that are exposed to storm water Control Measures Schedules and Procedures Documentation

20. Schedules and Procedures - Controls Good housekeeping schedule Maintenance procedures schedule Spill prevention and response Training

21. Schedules and Procedures – Monitoring and Inspections Benchmark Monitoring – Seasonal during deicing operations Visual Assessment of Storm Water discharge– At least Quarterly Routine Inspections – Monthly during deicing season (usually October – April) Comprehensive Inspection – Annual (during periods of deicing operations if possible)

22. Documentation T&E species evaluation Discharge to Impaired or State Resource Water authorization NOI NDEQ acknowledgment letter Best Management Practices Inspections Reports Corrective Action Monitoring Results (visual, benchmark)

23. Reporting Non-compliance which may endanger health or environment within 24-hours. Corrective Action – record within 24 hours, document actions within 14 days, report to NDEQ in 30 days Spill / Release reporting (per Title 126, Ch. 18) Upon NDEQ request

24. Questions?