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HomeMy WebLinkAboutNC0020656_Inspection_20080128O`=: (Dwo s< January 28, 2008 City of Laurinburg Attn: Robert Ellis, Treatment Plants Director P.O.Box249 Laurinburg, NC 28353 rvlicnaei r. nasiey, governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources SUBJECT: January 15, 2008 Compliance Evaluation Inspection City of Laurinburg WWTP Permit No: NC0020656 Scotland County Dear Mr. Ellis: Coleen H. Sullins, Director Division of Water Quality Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on January 15, 2008. The Compliance Evaluation Inspection was conducted by Mark Brantley, Environmental Chemist, of the Fayetteville Regional Office. The cooperation of Ricky Odom, Grade IV ORC, was greatly appreciated. The facility was found to be in Compliance with permit NC0020656. As a reminder, preservation of the Waters of the State can only be achieved through consistent NPDES Permit compliance. COMMENTS • The WWTP was clean and neat in appearance at the time of the inspection. • It was noted during the inspection this facility is not covered under a NPDES General Stormwater Permit (NCG110000 series). Since this facility is permitted for more than a million gallons per day flow and it has a point source discharge for stormwater it is necessary to apply for a NPDES General Stormwater Permit. Enclosed is an application for the permit along with its technical bulletin that contains some useful information. Please submit a completed application no later than February 22, 2008. • The Leith Creek WWTP analyzes a large number of the required NPDES parameters. Due to the large amount of laboratory work that is done by Mr. Ricky Odum, Chief Operator, the city may find it beneficial to hire someone to run the required laboratory tests. This staff member would also be available to run a variety of process control tests that would generate data in a timely manner that would assist the plant operators in running the plant. This would allow Mr. Ricky Odum to spend more time doing his operational duties. • Alarms at the influent pump station werenot tested during the inspection. A log of test dates and times of testing the alarms are kept by plant staff. • During the walk through part of the inspection it was noted several areas on the banks of the equalization basin have some erosion. Please repair and establish permanent grass cover to prevent erosion and sedimentation runoff. • It was also noted during the inspection that the brackets that hold the baffles in the aeration basins were being replaced. The Fayetteville Regional Office would like to encourage the city to replace the baffles at the same time since they are beginning to age and fail. This would aid in the operation of the aeration basin. North Carolina Division of Water Quality/Aquifer Protection Section 225 Green St./ Suite 714 Fayetteville, NC 28301 Phone (910) 433-3300 FAX (910) 486-0707 Internet: h2o.enr.state.nc.us . Customer Service 1-877-623-6748 Nne orthCarolina 2atarra!!i An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper • Laboratory bench sheets for the month of November 2007 were compared to the November DMR. All data appeared to be reported correctly. Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any questions, please call me at 910-433-3327. Sincerely, Mark Brantley Environmental Chemist Surface Water Protection Section Fayetteville Regional Office cc: Ricky Odum, ORC Central Files Fayetteville Files United States Environmental Protection Agency .E PA Washington, D.C. 20460 Water Compliance Inspection • Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 • Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection 1 I NI 2 1 51 31 NC0020656 111 121 08/01/15 117 Type . Inspector Fac Type. 1811 c1 191 s1 201 11 I I I I I I •III I I I I I I I66 Remarks 21I I I I I I 1 I I I I I I I I I I I I I I I I I I. I� I II I • I Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved I, 671 169 701 31 • 7.1 1 NI 721 NI 73 11 174 751 1 1 1 1 1 1. 1 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Leith Creek WWTP Hall St Extension Laurinburg NC 28352 Entry Time/Date 09:30 AM 08/01/15 Permit Effective Date 04/11/01 Exit Time/Date - 12:00 PM 08/01/15 Permit Expiration Date 09/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Robert A. Ellis/ORC/910-277-0214/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert A. Ellis,PO Box 249 Laurinburg NC 28353//910-277-0214/ No Section C:_ Areas Evaluated During Inspection (Check only those areas evaluated) Permit • Flow Measurement • Operations & Maintenance • Records/Reports Self -Monitoring Program Sludge Handling Disposal • Facility Site Review •.Efuent/Receiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Mark Brantley FRO WQ//910-433-3300 Ext.727/ /WOK -- ei 1-'8' -G g . Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Belinda S Henson FRO WQ//910-433-3300 Ext.726/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 31 NPDES NC0020656 I11 12I yr/mo/day 08/01/15 17 Inspection Type 18ICI (cont._) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) COMMENTS • The WWTP was clean and neat in appearance at the time of the inspection. • The Leith Creek WWTP analyzes a large number of the required NPDES parameters. Due to the large •amount of laboratory work that is done by Mr. Ricky Odum, Chief Operator, the city may find it beneficial to hire someone to run the required laboratory tests. This staff member would also be available to run a variety of process control tests that would generate data in a timely manner that would assist the plant operators in running the plant. This would allow Mr. Ricky Odum to spend more time doing his operational duties. • Alarms at the influent pump station were not tested during the inspection. A log of test dates and times of testing the alarms are kept by plant staff. • During the walk through part of the inspection it was noted several areas on the banks of the equalization basin have some erosion. Please repair and establish permanent grass cover to prevent erosion and sedimentation runoff. • It was also noted during the inspection that the brackets that hold the baffles in the aeration basins were being replaced. The Fayetteville Regional Office would like to encourage the city to replace the baffles at the same time since they are beginning to age and fail. This would aid in the operation of the aeration basin. • Laboratory bench sheets for the month of November 2007 were compared to the November DMR. All data appeared to be reported correctly. Page # 2 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ n n n Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n Judge, and other that are applicable? Comment: Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit, parameters? Has the facility submitted its annual compliance report to users and. DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification?. Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Yes No NA NE n n■n ■ nnn n n■n ■ nnn ■ nnn Yes No NA NE ■ nnn ■ nnn ■ nnn ■ nnn ■ nnn ■ ■ ■ ■ ■ ■ ■ nnn ■ nnn n n■n ■ nnn ■ nnn ■ nnn ■ nnn Page # 3 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Record Keeping Facility has copy of previous year's Annual Report on file for review? Comment: Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Flow Measurement - Influent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: The effluent flow meter was last calibrated on March 7, 2007. Aerobic Digester Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Comment: Drying Beds Is there adequate drying bed space? Is the sludge distribution on drying beds appropriate? Are the drying beds free of vegetation? Yes No NA NE ■ nnn Yes No NA NE ■ n n n n nn■ n nn ■ Yes No NA NE n n■n ■ n n n ■ n n n ■ n n n Yes No NA NE ■ n n n ■ nnn ■ nnn ■ n n n Yes No NA NE n nn■ n nn ■ n nn ■ ■ n n n ■ n n n Yes No NA NE ■ ono ■ n n n ■ nnn Page # 4 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Drying Beds Yes No ;NA NE # Is the site free of dry sludge remaining in beds? ■ n n n Is the site free of stockpiled sludge? ■ ❑ n n Is the filtrate from sludge drying beds returned to the front of the plant? ■ ❑ ❑ # Is the sludge disposed of through county landfill? n n ■ n # Is the sludge land applied? Ennn (Vacuum filters) Is polymer mixing adequate? n n ■ ❑ Comment: Approximately 800,000 gallons of sludge were land applied in Dec. 2007. Two drying beds have been rebuilt. The retaining wall on one of the drying beds needs to be repaired. Pump Station - Influent Is the pump wet well free of bypass lines or structures? •nnn Is the wet well free of excessive grease? Ennn Are all pumps present? ❑ ■ n n Are all pumps operable? E n ❑ n Are float controls operable? ■ ❑ ❑ ❑ Is SCADA telemetry available and operational? • n n n Is audible and visual alarm available and operational? ■ ❑ n n Comment: One influent pump is out for repair. The other three pumps are in working order. Bar Screens Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good.condition? Comment: Grit Removal Type of grit removal a.Manual Yes No NA NE Yes No NA NE ■ ■ n n 11 ■ nnn ■ nnn ■ nnn Yes ,No NA NE n Page # , 5 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Grit Removal Yes No NA NE b.Mechanical • . Is the grit free of excessive organic matter? • n n n Is the grit free of excessive odor? • n n n # Is disposal of grit in compliance? I. ❑ n n Comment: Auger screw is out for repair. Equalization Basins Yes No NA NE Is the basin aerated? • n n n Is the basin free of bypass lines or structures to the natural environment? • n n 11 Is the basin free of excessive grease? ■ n n n Are all pumps present? • n El .n Are all pumps operable? ■ n n n Are float controls operable? ■ El n n Are audible and visual alarms operable? n n n ■ # Is basin size/volume adequate? n n ❑ • Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? • n n n Is the site free of excessive buildup of solids in center well of circular clarifier? • n n n Are weirs level? • n n n Is the site free of weir blockage? ■ n n n Is the site free of evidence of short-circuiting? • n ❑ n Is scum removal adequate? • El 11 n Is the site free of excessive floating sludge? ■ ❑ ❑ ❑ Is the drive unit operational? • n ❑ n Is the return rate acceptable (low turbulence)? ■ n n n Is the overflow clear of excessive solids/pin floc? ■ n ❑ n Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) • n n n Comment: Clarifiers 1 and 3 had a sludge blanket of 7 feet. Clarifier number 2 was not dischargeing at the time of the inspection due to an operational change that had been made so some maintenance work could be performed on the aeration basin. Page # 6 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Fixed Is the basin free of dead spots? • ❑ 0 ❑ Are surface aerators and mixers operational? I. n n. n Are the diffusers operational? n n ■ ❑ Is the foam the proper color for the treatment process? ■ n n n Does the foam cover less than 25% of the basin's surface? ■ n n n Is the DO level acceptable? ■ n n n Is the DO level acceptable?(1.0 to 3.0 mg/I) ■ n ❑ n Comment: Oxidation Ditches Yes No NA NE Are the aerators operational? • n ❑ n Are the aerators free of excessive solids build up? • n n n # Is the foam the proper color for the treatment process? • n n n Does the foam cover less than 25% of the basin's surface? ■ n n n Is the DO level acceptable? ■ n ❑ n Are settleometer results acceptable (> 30 minutes)? n n n ■ Is the DO level acceptable?(1.0 to 3.0 mg/I) • n n n Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes) n n n ■ Comment: Disinfection -Gas Yes No NA NE Are cylinders secured adequately? ■ n n n Are cylinders protected from direct sunlight? • fl n n Is there adequate reserve supply of disinfectant? ■ n n n Is the level of chlorine residual acceptable? • n n fl Is the contact chamber free of growth, or sludge buildup? ❑ ■ n n. Is there chlorine residual prior to de -chlorination? • n ❑ 11 Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? n n ■ El If yes, then is there a Risk Management Plan on site? n n ■ n Page # 7 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Disinfection -Gas If yes, then what is the EPA twelve digit ID Number? (1000- - ) If yes, then when was the RMP last updated? Comment: One side of the chlorine contact chamber was being cleaned at the time of the inspection. The other side of the chamber had 18 inches of sludge and was scheduled to be cleaned as soon as the other side was back in service. De -chlorination Type of system ? Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # Is de -chlorination substance stored away from chlorine containers? Comment: Are the tablets the proper size and type? Are tablet de -chlorinators operational? Number of tubes in use? Comment: Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: Pumps-RAS-WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: One return pump was out for repair but the other pumps were in working order. Laboratory Yes No NA NE Yes No NA NE Gas ■ nnn ■ nnn ■ nnn n n■n n n■n Yes No NA NE ■ nnn ■ nnn. ■ nnn n n■n ■ nnn ■ nnn ■ nnn Yes No NA NE ■ nnn ■ nnn ■ nnn Yes No NA NE Page # 8 Permit: NC0020656 Owner - Facility: Leith Creek WWTP Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Comment: Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Is sampling performed according to the permit? Comment: The influent sampler was at 3degrees Celsius. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: The effluent sampler was at 2 degrees celsius. Upstream / Downstream Sampling Yes No NA NE •nnn ■ nnn ■ nnn ■ nnn ■ nnn ■ nnn Yes No NA NE nn■n ■ nnn ■ nnn ■ nnn En El ■ nnn Yes No NA NE ■ nnn ■ nnn ■ nnn ■ nnn ■ nnn ■ nnn Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ 0 0 n Comment: Page # 9 FOR AGENCY USE ONLY ATI NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Division of Water Quality /Water Quality Section National Pollutant Discharge Elimination System NCG110000 NIClGl Date Received Year Month Day Certificate ofCoverage Check # Amount Permit Assigned to NOTICE OF INTENT National Pollutant Discharge Elimination System application for coverage under General Permit NCG110000: STORMWATER DISCHARGES associated with activities classified as: Treatment Works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, with a design flow of 1.0 million gallons per day or more, or required to have an approved pretreatment program under Title 40 Code of Federal Regulations (CFR) Part 403, including lands dedicated to the disposal of sewage sludge that is located within the confines of the facility. 1) Mailing address* of owner/operator: Name Street Address (Please print or type) City State ZIP Code Telephone No. Fax: Address to which all permit correspondence will be mailed 2) Location of facility producing discharge: Facility Name Facility Contact Street Address City State ZIP Code County Telephone No. Fax: 3) Physical Location Information: Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). (A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application) 4) This NPDES Permit Application applies to which of the following : ❑ New or Proposed Facility Date operation is to begin ❑ Existing 5) Standard Industrial Classification: Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial activity at this facility SIC Code: Page 1 of 3 SWU-226-101701 NCG110000 N.O.I. 6) Provide a brief narrative description of the types of industrial activities and products manufactured at this facility: 7) Discharge points / Receiving waters: How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater discharges end up in? If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm sewer system (e.g. City of Raleigh municipal storm sewer). 8) Does this facility have any other NPDES permits? ❑ No ❑ Yes If yes, list the permit numbers for all current NPDES permits for this facility: 9) Does this facility have any Non -Discharge permits (ex: recycle permits)? ❑ No ❑ Yes If yes, list the permit numbers for all current Non -Discharge permits for this facility: 10) Does this facility employ any best management practices for stormwater control? ❑ No ❑ Yes If yes, please briefly describe: 11) Does this facility have a Stormwater Pollution Prevention Plan? ❑ No El Yes If yes, when was it implemented? 12) Are vehicle maintenance activities occurring at this facility? ❑ No ❑ Yes 13) Hazardous Waste: a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑No ❑Yes b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of hazardous waste? ❑ No ❑ Yes c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of hazardous waste? El No ID Yes d) If you answered yes to questions b. or c., please provide the following information: Type(s) of waste: Page2of3 S W U-226-101701 NCG110000 N.O.I. 4 S W U-226-101701 How is material stored: Where is material stored: How many disposal shipments per year: Name of transport / disposal vendor: Vendor address: 14) Certification: North Carolina General Statute 143-215.6 b (i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.) I hereby request coverage under the referenced General Permit. I understand that coverage under this permit will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as an individual permit. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Title: (Signature of Applicant) (Date Signed) Notice of Intent must be accompanied by a check or money order for $100.00 made payable to: NCDENR Final Checklist This application will be returned as incomplete unless all of the following items have been included: ❑ Check for $100 made payable to NCDENR ❑ This completed application and all supporting documents ❑ Copy of county map or USGS quad sheet with location of facility clearly marked on map Mail the entire package to: Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Note The submission of this document does not guarantee the issuance of an NPDES permit. Page3of3 Technical Bulletin For STORMWATER GENERAL PERMITS AA �r NCDENR NORTH CAROLINA DIVISION OF WATER QUALITY April 16, 2003, rev. 1/9/08 NCG050000, NCG070000, NCG110000, NCG130000, NCG170000, and NCG210000 The stormwater permitting program's objective is to reduce the pollutant load in stormwater runoff 1- Educating the permitted community about stormwater pollutants, 2- Encouraging the use of Best Management Practices (BMPs) to minimize the entry of pollutants into stormwater, and 3- Using collected analytical data to assess stormwater's contribution to water pollution to help prioritize controls in problem areas. Key Permit Requirements ❑ Implementation of a Stormwater Pollution Prevention Plan (SPPP) (Part II, Section A). O Provide secondary containment for all bulk storage of liquid materials. (Part II, Section A: 2. (b)). O Perform and document semi- annual qualitative monitoring. (Part II, Section B). ❑ Perform annual analytical monitoring for vehicle maintenance area, if present, and submit the results on the monitoring report forms provided with the permit. (Part II, Section C). Obtaining Representative Outfall Status If a facility has more than one stormwater outfall from the vehicle maintenance area(s) then the permit requires that all such outfalls be monitored. However, the permit also allows for the facility to request "Representative Outfall Status". Representative outfall status allows the facility to perform analytical monitoring at a reduced number of outfalls. Application is made by a letter to the Stormwater and General Permits Unit clearly explaining which outfall(s) is/are to be considered representative of other discharges from the site. A copy of the site map used in the SPPP that delineates drainage areas, industrial activities, and any other potential stormwater pollutant exposures shall be included with the letter to support the application. BMP's The Stormwater Pollution Prevention Plan should include the use of Best Management Practices (BMP's) to control the discharge of pollutants" from a facility's stormwater outfalls. BMP's include a variety of things that the industrial facility can do in order to minimize the potential for pollutants to get into the stormwater draining from a facility. The following outlines some potential types of BMP's. Non -Structural BMP's Some examples of non-structural (practices or activities) BMP's are as follows: • Eliminate exposure of materials and equipment wherever possible by moving materials and equipment to indoor locations. • A very effective and cost effective BMP is to practice good housekeeping on -site. Keep materials handled and stored at the facility in an orderly fashion. • Examine process and exchange hazardous materials for non- hazardous ones wherever possible. • Establish routine leak and maintenance checks to minimize the chance of spills before they occur. When spills do occur, clean them up immediately. • Establish bulk storage tank protocols that minimize the risk of spills during loading and unloading procedures. • Store used pallets and process waste dumpsters inside or under a roof where water cannot flow on or around them. Structural BMP's Some examples of structural (equipment or devices) BMP's are as follows: • Build containment dikes around the loading areas of bulk liquid storage containers. • Where practical, change painting operations from liquid systems to powdered systems that don't generate solvent wastes. • Build roofs and secondary containment around any materials stored outside so that stormwater doesn't run onto them and carry pollutants away with it. No Exposure Certification A facility with an industrial activity subject to the NPDES Stormwater regulations that eliminates all potential stormwater exposure on site is now eligible for a No Exposure Exclusion from a stormwater permit (the exemption is no longer restricted to Category 11 activities). A facility that meets these conditions may fill out a No Exposure Certification application form (see NC DWQ's Stormwater Permitting Unit's website: http://h2o.enr.state.nc.us/su. ) to apply for a No Exposure Exclusion and to request recission of the existing permit (if applicable). If approved, the facility must re- certify No Exposure every five (5) years. J Other sources of information on North Carolina's Stormwater Permitting Program The following documents are available through the stormwater permitting group by calling (919)733- 5083. • Summary of Federal National Pollutant Discharge Application Regulations for Stormwater Discharges Associated with Industrial Activities. • Stormwater Pollution Prevention Plans for Stormwater Runoff at Industrial Activities. • Stormwater Pollution Prevention Plan Guidance Document. • Stormwater Management Guidance Manual. The Unit can be found on the World Wide Web at 1-1ttn:l/h2o.enrst ate.nc.us/su/storm water.html. Another source of information is the DENR Customer Service Center. They may be reached at 1-877-NC ENR 4 U (1-877-623- 6748) or http://www.envhelp.org/. An additional source of information is the Division of Pollution Prevention and Environmental Assistance. They have lots of specific information on how to minimize pollutants at various types of industries. They may be reached at (919) 571-4100 or http://www.p2pays.org/. Commonly asked questions 1) Do all stormwater outfalls need to be analytically monitored? Only those outfalls that drain areas of the facility where vehicle maintenance activities using over 55 gallons of new motor oil per month need to be analytically monitored. Also, see previous discussion on representative outfall status. 2) What happens if when I pull samples for my annual analytical monitoring I'm unable to get a sample for one of the parameters? If this happens it is fine to go ahead and just sample for the missing parameter during the next representative storm event, just be sure to note the total rainfall, event duration, and totalflow apart from the initial monitoring data. 3) Does a certified lab need to be used to analyze stormwater samples? Monitoring under all NPDES permits must be conducted in accordance to test procedures approved under federal regulations in 40 CFR § 136. All labs certified by North Carolina perform analysis in accordance with those procedures. So, while facilities that are not considered Water Pollution Control Systems under T15A NCAC 8G .0306 do not need to meet and maintain certification requirements, any data gathered under an NPDES permit must conform to federal requirements. Using a North Carolina certified lab is often the easiest way to ensure compliance with NPDES Program requirements. Note that pH is a special case (a field parameter) and must be measured within 15 minutes. You must either train on -site staff to conduct pH measurements in accordance with approved methods or contract with commercial services that can monitor pH properly at your site. All labs with N.C. wastewater field parameter certification as per 15A NCAC 2H .0800 can perform pH analysis in accordance with federal procedures. A list of labs with field parameter certification is available from DWQ's Laboratory Certification Branch at: http://h2o.enr.state.nc.us/lab/cert.htrn 4) How do you average the first year's analytical monitoring results? The measured concentration of a particular pollutant collected during the first year's analytical monitoring is the average value for that parameter since dividing it by one gives the same value for cut-off purposes. 5) What If I Sell My Business Or The Name of My Business Changes ? The Division views changes of name or ownership as a minor modification and requires the Director's approval. Name and ownership changes require you to complete a Name/Ownership Change Form SWU-239. The form is downloadable from our website. Changes in Reissued General Permits These permits include some clarifying and updated language throughout the permit. In addition language has been added to address coverage under these permits for discharges to waters with approved TMDLs (Part I Section A). Language has also been added to Part I Section B in reference to water quality standards. Other Information Additional Technical Bulletins will be available in the future from the Division. Contact us at: http://h2o.enr.state.nc.us/su/stor mwater.html N.C. Division of Water Quality Water Quality Section Stormwater and General Permits Unit 1617 Mail Service Center Raleigh, N.C. 27699-1617 Phone 919-733-5083 Fax 919-733-0719 Please make us aware of any issues you feel should be addressed in future Technical Bulletins.