City of Omaha Industrial Stormwater Permit

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City of Omaha Industrial Stormwater Permit

• Presented by

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Pathways to Stormwater Permits
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MCM 7 Industrial Facilities

• 7.A Issue permits to specific sectors
• Develop priority system
• Underway
• Due September 29, 2009
• Issue permits
• Effective April 1, 2009
• No applications submitted to date
• Report number of permits issued in the Annual
  Report to NDEQ

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Permitting Priorities

• Likely
• Local watershed water quality goals
• Industrial Sector (SIC Code)
• Existing NDEQ ISW Permit
• Stormwater exposure risk assessment
• Other information about specific dischargers
• Unlikely
• State Water Quality Standards
• TE Species/Historic Properties Compliance

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Permit Applies to 29 Sectors 1

• A Timber Products
• B Paper and Allied Products
• C Chemicals and Allied Products
• D Asphalt Paving and Roofing Materials and
  Lubricants
• E Glass, Clay, Cement, Concrete, and Gypsum
  Products
• F Primary Metals
• G Metal Mining
• H Coal, Mines and Coal Mining-Related Facilities
• I Oil and Gas Extraction and Refining
• J Mineral Mining and Dressing
• K Hazardous Waste Treatment, Storage, or
  Disposal Facilities
• L Landfills, Land Application Sites, and Open
  Dumps
• M Auto Salvage Yards
• N Scrap Recycling Facilities

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Permit Applies to 29 Sectors 1

• O Steam Electric Generating Facilities
• P Land Transportation and Warehousing
• Q Water Transportation
• R Ship and Boat Building and Repairing Yards
• S Air Transportation Facilities
• T Treatment Works
• U Food and Kindred Products
• V Textile Mills, Apparel, and Other Fabric
  Product Mfg
• W Furniture and Fixtures
• X Printing and Publishing
• Y Rubber, Misc. Plastic Products, and Misc. Mfg.
  Ind.
• Z Leather Tanning and Finishing
• AA Fabricated Metal Products
• AB Transportation Equipment, Industrial or
  Commercial Machinery
• AC Electronic, Electrical, Photography
• AD Non-Classified Facilities (i.e. any other
  facility contributing pollutants)

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City Risk Assessment

• JAWRA, Feb. 2008, v.44, 1
• Lindsay Cross and L. Donald Duke
• Permit overlap
• Water quality concerns
• Facility risk rating system and prioritization

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MCM 7 Industrial Facilities

• 7.B Inspect 20 of facilities and take
  appropriate enforcement actions.
• Approximately 200 facilities in Omaha have full
  Industrial Stormwater Permits or No Exposure
  Certification from NDEQ. (40/yr.)
• A review of Department of Economic Development
  data indicates at least 800 facilities meet the
  Sector-based standard for compliance with permit.
  (160/yr.)

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MCM 7 Industrial Facilities

• 7.C Implement permit tracking system
• Permits (effective April 1, 2009)
• Inspections (started April 10, 2009)
• Compliance (assistance and enforcement)
• Priorities (water quality and risk assessment)
• Coordinate permitting through www.omahastormwater.
  org and tracking through the City GIS department.

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City ISW Permit Highlights

• Only applies to facilities w/in Omaha MS4
• Applies to discharges to MS4 and CSS
• Mirrors Federal Sector-based requirement
• Does not replace NDEQ requirements
• Acknowledges option for No Exposure
• Facility owner responsible for compliance
• Facility operator may be held responsible for
  violations in the case of a lease

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City ISW Permit Highlights (cont.)

• Identify non-stormwater discharges and validate
  non-pollution status
• Implement, maintain and update SWPPP
• Implement and maintain BMPs
• SWPPP contents similar to EPA MSGP
• Inspections and monitoring
• Records, reporting and enforcement

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City ISW Permit Highlights (cont.)

• Application
• SWPPP
• Stormwater Exposure Risk Self-evaluation
• Certification statement
• Termination
• SWPPP Amendments
• Useable SWPPP forms

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SWPPP Essentials

• No stipulations placed on credentials
• Must be signed and certified as true, accurate
  and complete
• General BMP requirements
• Inspection team, frequency, recordkeeping
• Employee training

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General BMPs

• Good Housekeeping
• Indoor access to the trash compactor
• Swept pavement
• Eliminate and Minimize Exposure
• Indoor material storage
• Indoor shipping receiving docks
• Conducting as much activity indoors as possible

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General BMPs (cont.)

• Preventative Maintenance
• Outdoor equipment
• Company fleets
• Spill Prevention and Response Procedures
• On-site spill kits
• HAZWOPER
• On-site spill response trailer

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General BMPs (cont.)

• Erosion and Sediment Control
• Vegetated drainageways reduce the occurrence of
  erosion sediment control issues.
• Management of Runoff
• Shut-off valves and holding ponds

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General BMPs (cont.)

• Salt Storage
• Indoor salt storage
• Controlled access loading unloading
• Controls on Other Specific Activities
• Litter
• Dust
• Flow velocity control

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General BMPs (cont.)

• Other Controls
• Sector 8 MSGP Guidance
• Not enforceable by Omaha
• Reference for economically reasonable and
  appropriate BMPs

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No Exposure Certification

• Does not remove State Permit requirements if
  applicable
• Separate City form
• Applicable at any time status is achieved
• Submit form every five years
• May be terminated by the City to require full ISW
  Permit compliance

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Inspections and Monitoring

• Routine Facility Inspections frequency
  indicated by facility in SWPPP
• Conducted by qualified facility personnel
• Exposed areas and stormwater BMPs
• Comprehensive Site Compliance Inspection annual
• BMPs observed during runoff event
• Monitoring not required unless specified

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City Inspections

• Pre-inspection
• Facility contact
• Information review
• Inspection
• Interview and SWPPP review
• Facility walk-through
• Exit interview

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City Inspections (cont.)
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City Inspections (cont.)

• Stormwater Exposure Risk Assessment
• Bulk and Hazardous Waste
• Vehicles (outdoor, washing, maintenance)
• Material Storage
• Outdoor Equipment/ Process Equipment
• Shipping/Receiving
• Plant Yard, Rail Line, Access Roads
• Boneyard
• Manufacturing Activity

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City Inspections (cont.)

• Post Inspection
• Complete inspection report with inspection
  findings, photolog, and conclusions
• Submit documentation to facility with letter
  indicating compliance status with City ISW permit
  requirements
• Facility makes amendments to SWPPP if required
  and submit Amendment form to City

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Summary

• Approach to permitting must comply with the
  Citys MS4 Permit
• Compliance with City ISW Permit does not provide
  compliance with State ISW Permit
• Permit approach should be consistent with future
  NDEQ ISW Permit requirements
• City will maintain a compliance assistance
  approach at this time

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Contacts

• City of OmahaPublic Works Department
• Environmental Quality Control Division
• 5600 South 10th Street
• Omaha, NE 68107
• Telephone [phone]
• Fax [phone]
• www.omahastormwater.org