environmental regulations primer and case studies presented to: university of arkansas at little...

ENVIRONMENTAL REGULATIONSENVIRONMENTAL REGULATIONSPrimerPrimer

andandCase StudiesCase Studies

Presented to:Presented to:

University of Arkansas at Little Rock Law SchoolUniversity of Arkansas at Little Rock Law School

March 9, 2015March 9, 2015

Presented by:Presented by:

William D. Ford, P.E.William D. Ford, P.E.

Pollution Management, Inc.Pollution Management, Inc.

Federal Regulations - EPAFederal Regulations - EPA

Water and Wastewater – Clean Water ActWater and Wastewater – Clean Water Act

Stormwater – Clean Water ActStormwater – Clean Water Act

State Regulations - ADEQState Regulations - ADEQWater, Wastewater and Stormwater – Regulation 2, 6Water, Wastewater and Stormwater – Regulation 2, 6

CLEAN WATER ACTCLEAN WATER ACT

Enacted in 1972Enacted in 1972 Major Amendments 1977 and 1982Major Amendments 1977 and 1982 Established goals of eliminating releases of high Established goals of eliminating releases of high

amounts of toxic substances into waters of the U.S.amounts of toxic substances into waters of the U.S. Set standards for surface waterSet standards for surface water Does not directly address groundwater contaminationDoes not directly address groundwater contamination Included in Safe Drinking Water Act and RCRAIncluded in Safe Drinking Water Act and RCRA

WATERS PROTECTED WATERS PROTECTED UNDER THE CWAUNDER THE CWA

All waters with a “significant nexus” to “navigable waters” are All waters with a “significant nexus” to “navigable waters” are covered under the CWAcovered under the CWA

In the 2006 case Rapanos v. United States the Supreme In the 2006 case Rapanos v. United States the Supreme Court held that the term “waters of the United States”Court held that the term “waters of the United States”

……includes only those relatively permanent, standing or includes only those relatively permanent, standing or continuously flowing bodies of water “forming geographic continuously flowing bodies of water “forming geographic features” that are described in ordinary parlance as features” that are described in ordinary parlance as “streams[,] …oceans, rivers, [and] lakes”“streams[,] …oceans, rivers, [and] lakes”

POLLUTION CONTROL POLLUTION CONTROL STRATEGY IN THE CWASTRATEGY IN THE CWA

National Pollutant Discharge Elimination System (NPDES)National Pollutant Discharge Elimination System (NPDES)

Industrial facilities (including manufacturing, mining, oil and Industrial facilities (including manufacturing, mining, oil and gas extraction, and service industries)gas extraction, and service industries)

Municipal governments and other government facilities Municipal governments and other government facilities (such as military bases), and(such as military bases), and

Some agricultural facilities, such as animal feedlotsSome agricultural facilities, such as animal feedlots


Point sources may not discharge pollutants to surface water Point sources may not discharge pollutants to surface water without a permitwithout a permit

EPA has authorized 46 states to issue permitsEPA has authorized 46 states to issue permits

In the remaining states and territories, permits are issued In the remaining states and territories, permits are issued by an EPA regional officeby an EPA regional office


Technology-based standardsTechnology-based standards Water quality standardsWater quality standards Designated usesDesignated uses Antidegradation policyAntidegradation policy Nonpoint sourcesNonpoint sources Congress exempted some water pollution sources from the Congress exempted some water pollution sources from the

point source definitionpoint source definition Agricultural stormwater discharges and irrigation return Agricultural stormwater discharges and irrigation return

flowsflows


Stormwater runoff from industrial sources, municipal Stormwater runoff from industrial sources, municipal storm drains, and other sources were not specifically storm drains, and other sources were not specifically addressed in the 1972 lawaddressed in the 1972 law

A growing body of water research during the late 1970s A growing body of water research during the late 1970s and 1980s indicated that stormwater runoff was a and 1980s indicated that stormwater runoff was a significant cause of water quality impairmentsignificant cause of water quality impairment

Water Quality Act of 1987 – Congress required industrial Water Quality Act of 1987 – Congress required industrial stormwater dischargers and municipal separate storm stormwater dischargers and municipal separate storm sewer systems obtain NPDES permitssewer systems obtain NPDES permits

MAJOR STATUTORY MAJOR STATUTORY PROVISIONSPROVISIONS

Title I – Research and Related ProgramsTitle I – Research and Related Programs

Title II – Grants for Construction of Treatment WorksTitle II – Grants for Construction of Treatment Works

Title III – Standards and EnforcementTitle III – Standards and Enforcement

TITLE III - STANDARDSTITLE III - STANDARDS Discharge permits requiredDischarge permits required Technology-Based Standards ProgramTechnology-Based Standards Program Municipal sewage treatment plants (POTW) are required to meet Municipal sewage treatment plants (POTW) are required to meet

secondary treatment standardssecondary treatment standards Effluent guidelines (for existing sources) and New Source Effluent guidelines (for existing sources) and New Source

Performance Standards (NSPS) are issued for categories of Performance Standards (NSPS) are issued for categories of industrial facilities discharging directly to surface watersindustrial facilities discharging directly to surface waters

Categorical Pretreatment Standards are issued to industrial Categorical Pretreatment Standards are issued to industrial users (also called “indirect dischargers”) contributing wastes to users (also called “indirect dischargers”) contributing wastes to POTW. There are 27 categories with pretreatment standards as POTW. There are 27 categories with pretreatment standards as of 2011.of 2011.

WATER QUALITY WATER QUALITY STANDARDS PROGRAMSTANDARDS PROGRAM

Water quality standards (WQS) set site-specific allowable pollutant Water quality standards (WQS) set site-specific allowable pollutant levels for individual water bodies, such as rivers, lakes, streams and levels for individual water bodies, such as rivers, lakes, streams and wetlandswetlands

States set WQS by designating uses for the water body (e.g., States set WQS by designating uses for the water body (e.g., recreation, water supply, aquatic life, agriculture)recreation, water supply, aquatic life, agriculture)

An antidegradation policy is also issued by each stateAn antidegradation policy is also issued by each state Water bodies that do not meet applicable water quality standards with Water bodies that do not meet applicable water quality standards with

technology-based controls alone are placed on the section 303(d) list of technology-based controls alone are placed on the section 303(d) list of water bodies not meeting standardswater bodies not meeting standards

States must submit a report every two years (even years) to EPA on States must submit a report every two years (even years) to EPA on the status of all waters of the State – 303(b) reportthe status of all waters of the State – 303(b) report

WATER QUALITY WATER QUALITY STANDARDS PROGRAMSTANDARDS PROGRAM

Water bodies on the 303(d) list require development of a Total Water bodies on the 303(d) list require development of a Total Maximum Daily Load (TMDL)Maximum Daily Load (TMDL)

A TMDL is a calculation of the maximum amount of a pollutant that a A TMDL is a calculation of the maximum amount of a pollutant that a water body can receive and still meet WQSwater body can receive and still meet WQS Streams and water bodies can have more than one TMDL, i.e. TSS, BOD, DO, Streams and water bodies can have more than one TMDL, i.e. TSS, BOD, DO,

etc.etc. Some states and local governments have TMDLs for watersheds – especially for Some states and local governments have TMDLs for watersheds – especially for

watersheds that contain drinking water sourceswatersheds that contain drinking water sources Overall goal is protection of water body or watershedOverall goal is protection of water body or watershed

TITLE IVTITLE IVPERMITS AND LICENSESPERMITS AND LICENSES

State certification of complianceState certification of compliance States are required to certify that discharges authorized by States are required to certify that discharges authorized by

federal permits will not violate the state’s water quality federal permits will not violate the state’s water quality standardsstandards

NPDES permits for point sourcesNPDES permits for point sources The NPDES permit program is authorized by CWA section The NPDES permit program is authorized by CWA section

402402 Focused on POTWs and industrial wastewater – typically Focused on POTWs and industrial wastewater – typically

“process” wastewater“process” wastewater

TITLE IVTITLE IVPERMITS AND LICENSESPERMITS AND LICENSES

The 1987 WQA expanded the program to cover The 1987 WQA expanded the program to cover stormwater discharges explicitly, both from municipal stormwater discharges explicitly, both from municipal separate storm sewer systems (MS4) and industrial separate storm sewer systems (MS4) and industrial sourcessources

Non-stormwater permits typically include numeric effluent Non-stormwater permits typically include numeric effluent limitations for specific pollutantslimitations for specific pollutants

Stormwater permits typically require facilities to prepare Stormwater permits typically require facilities to prepare a Stormwater Pollution Prevention Plan and implement a Stormwater Pollution Prevention Plan and implement best management practicesbest management practices

NPDES PERMIT STRUCTURENPDES PERMIT STRUCTUREIndustry-Specific

ComponentsComponents of All

PermitsMunicipal-Specific

Components

Effluent Limitations

Technology-Based

Water Quality-Based

•Effluent Guidelines •Secondary

Monitoring & Reporting Requirements

Special Conditions

Additional Mon. / Special Studies

Best Management Practices

Compliance Schedules

Standard Conditions

•Pretreatment•Municipal Sewage Sludge

NPDES INDIVIDUAL PERMIT NPDES INDIVIDUAL PERMIT PROCESSPROCESS

Application to ADEQApplication to ADEQ ADEQ determines the permit application is administratively ADEQ determines the permit application is administratively

completecomplete ADEQ sends letter to other state and federal agenciesADEQ sends letter to other state and federal agencies ADEQ notices the public that a NPDES permit has been ADEQ notices the public that a NPDES permit has been

requestedrequested ADEQ technical review – 90 daysADEQ technical review – 90 days Draft permit sent to EPA for review – 30 daysDraft permit sent to EPA for review – 30 days Draft permit Public Notice – 30 daysDraft permit Public Notice – 30 days Public hearing (if required) – 30 daysPublic hearing (if required) – 30 days

ADEQ REGULATION NO. 2ADEQ REGULATION NO. 2Water Quality Standards for Surface Waters Water Quality Standards for Surface Waters

in Arkansas in Arkansas

Antidegradation PolicyAntidegradation Policy Water body usesWater body uses General StandardsGeneral Standards Specific StandardsSpecific Standards

ADEQ INDUSTRIAL NPDES ADEQ INDUSTRIAL NPDES PERMITSPERMITS

NPDES PermitsNPDES Permits Individual permitsIndividual permits General permitsGeneral permits No-Discharge PermitsNo-Discharge Permits IndividualIndividual GeneralGeneral Pretreatment ProgramPretreatment Program Stormwater ProgramStormwater Program

NPDES PERMITSNPDES PERMITS Individual PermitsIndividual Permits Process water discharges to receiving streamsProcess water discharges to receiving streams General PermitsGeneral Permits LandfillsLandfills Cooling tower & boiler blowdownCooling tower & boiler blowdown Individual treatmentIndividual treatment CAFOCAFO Water treatmentWater treatment Hydrostatic testingHydrostatic testing Car/Truck washCar/Truck wash Groundwater cleanupGroundwater cleanup

NO DISCHARGE PERMITSNO DISCHARGE PERMITS Individual PermitsIndividual Permits Animal waste disposalAnimal waste disposal Land application – biosolidsLand application – biosolids Land application – oil & gas wasteLand application – oil & gas waste Subsurface disposalSubsurface disposal General PermitsGeneral Permits Septic tank for carwashSeptic tank for carwash One time land applicationOne time land application Saltwater disposalSaltwater disposal Land application of water treatment residualsLand application of water treatment residuals

PRETREATMENT PROGRAMPRETREATMENT PROGRAM

Industrial wastewater can damage POTW’sIndustrial wastewater can damage POTW’s Discharges can be toxic to POTW’s treatment processDischarges can be toxic to POTW’s treatment process Discharges can pass through POTW’s and impair Discharges can pass through POTW’s and impair

receiving streamsreceiving streams

24 cities in Arkansas have pretreatment programs24 cities in Arkansas have pretreatment programs ADEQ/EPA monitor pretreatment programsADEQ/EPA monitor pretreatment programs Categorical/non-categorical dischargesCategorical/non-categorical discharges

DREDGE AND FILL PERMITSDREDGE AND FILL PERMITS(wetlands, lakes, streams, rivers and other waters of the U.S.)(wetlands, lakes, streams, rivers and other waters of the U.S.)

Under sections 301 and 502 of the Clean Water Act, any Under sections 301 and 502 of the Clean Water Act, any discharge of dredged or fill materials into “waters of the discharge of dredged or fill materials into “waters of the United States,” including wetlands, is forbidden unless United States,” including wetlands, is forbidden unless authorized by a permit issued by the USACE pursuant to authorized by a permit issued by the USACE pursuant to section 404section 404

There are two main types of wetlands permits: general There are two main types of wetlands permits: general permits and individual permitspermits and individual permits

General permits (such as the Nationwide Permits)General permits (such as the Nationwide Permits) Individual permits are utilized for actions that are not Individual permits are utilized for actions that are not

addressed by a general permitaddressed by a general permit

CASE STUDYCASE STUDYNPDES PermitNPDES Permit

Industrial process water dischargesIndustrial process water discharges Discharges to POTWDischarges to POTW Non-categorical dischargesNon-categorical discharges Categorical dischargesCategorical discharges POTW requires pretreatmentPOTW requires pretreatment

CASE 1 – POTW discharges to stream with TMDLCASE 1 – POTW discharges to stream with TMDL CASE 2 – POTW discharges to stream with no TMDLCASE 2 – POTW discharges to stream with no TMDL

Nutrient Removal Nutrient Removal More States are/will be placing limits on More States are/will be placing limits on

certain nutrients found in wastewatercertain nutrients found in wastewater We are seeing in now in ArkansasWe are seeing in now in Arkansas Common nutrients – Nitrogen and Common nutrients – Nitrogen and

PhosporusPhosporus Most POTW’s now do not remove the Most POTW’s now do not remove the

nutrientsnutrients Nutrient removal requires additional Nutrient removal requires additional

treatment processtreatment process Can be costly and will impact smaller cities Can be costly and will impact smaller cities

as much as larger citiesas much as larger cities

Case Study 1Case Study 1

A new residential subdivision-200 homesA new residential subdivision-200 homes Location northwest Arkansas area with no sewer Location northwest Arkansas area with no sewer

serviceservice Treatment system discharges to small stream Treatment system discharges to small stream

with TMDL for Dissolved Oxygen and with TMDL for Dissolved Oxygen and PhosphorusPhosphorus

DO can be managable but Phosphorus removal DO can be managable but Phosphorus removal can be costlycan be costly

Phosphorus requires additional chemical Phosphorus requires additional chemical treatment and produces sludgetreatment and produces sludge

Case Study 2Case Study 2

Large wood processing plant plans on Large wood processing plant plans on locating in Russellville on Arkansas Riverlocating in Russellville on Arkansas River

Plans on treating wastewater and then Plans on treating wastewater and then discharging into Riverdischarging into River

Chlorides discharge will be around 200 Chlorides discharge will be around 200 mg/l-this is a dissolved solids mg/l-this is a dissolved solids

ADEQ permits this and the plant starts ADEQ permits this and the plant starts constructionconstruction

CASE STUDYCASE STUDYNPDES PermitNPDES Permit

Industrial process water dischargesIndustrial process water discharges

CASE 1 – Discharge of contaminated groundwater to a CASE 1 – Discharge of contaminated groundwater to a streamstream

CASE 2 – Discharge of contaminated stormwater to streamCASE 2 – Discharge of contaminated stormwater to stream

INDUSTRIAL STORMWATER PROGRAMINDUSTRIAL STORMWATER PROGRAM

William D. Ford, P.E.William D. Ford, P.E.

1. Permit Area. This permit includes all areas within the State of Arkansas.

Industrial Stormwater RequirementsIndustrial Stormwater Requirements


ADEQ General PermitADEQ General PermitPart of CWA 40 CFR 122.26Part of CWA 40 CFR 122.26

2. 2. EligibilityEligibility..

• GeneralGeneral. This permit may cover all new and existing discharges . This permit may cover all new and existing discharges composed entirely of stormwater associated with industrial activity.composed entirely of stormwater associated with industrial activity.

• This permit may authorize stormwater discharges associated with This permit may authorize stormwater discharges associated with industrial activity that are mixed with stormwater discharges industrial activity that are mixed with stormwater discharges associated with industrial activity from construction activities provided associated with industrial activity from construction activities provided that the stormwater discharge from construction activity is in that the stormwater discharge from construction activity is in compliance with the terms, including applicable NOI or application compliance with the terms, including applicable NOI or application requirements, of a different NPDES General Permit (ARR150000) or requirements, of a different NPDES General Permit (ARR150000) or an individual NPDES permit or an alternate general permit authorizing an individual NPDES permit or an alternate general permit authorizing the construction stormwater discharges.the construction stormwater discharges.

3. 3. Limitations on CoverageLimitations on Coverage.. The following stormwater discharges associated The following stormwater discharges associated with industrial activity with industrial activity are not are not covered by this permit:covered by this permit:

• Stormwater discharges associated with industrial activity that are mixed Stormwater discharges associated with industrial activity that are mixed with sources of non-stormwater.with sources of non-stormwater.

• Stormwater discharges associated with industrial activity from facilities Stormwater discharges associated with industrial activity from facilities which are subject to existing effluent guideline limitations addressing which are subject to existing effluent guideline limitations addressing stormwater or a combination of stormwater and process water. stormwater or a combination of stormwater and process water. Facilities currently covered by guidelines for stormwater discharges (or Facilities currently covered by guidelines for stormwater discharges (or a combination of stormwater and process water) include:a combination of stormwater and process water) include:


40 CFR 445 40 CFR 445 Landfills Landfills

40 CFR 44340 CFR 443Asphalt emulsion Asphalt emulsion

40 CFR 44040 CFR 440Ore mining and dressing Ore mining and dressing

Feedlots Feedlots

40 CFR 43640 CFR 436

40 CFR 43440 CFR 434

40 CFR 42340 CFR 423

40 CFR 42240 CFR 422

40 CFR 41940 CFR 419

40 CFR 418 40 CFR 418

40 CFR 412 40 CFR 412

40 CFR 411 40 CFR 411

Petroleum refining Petroleum refining

Fertilizer manufacturing Fertilizer manufacturing

Phosphate manufacturing Phosphate manufacturing

Mineral mining and processing Mineral mining and processing

Coal mining Coal mining

Steam electric Steam electric

Cement manufacturing Cement manufacturing


• Other stormwater discharges not subject to effluent Other stormwater discharges not subject to effluent guidelines, and not currently permitted, at the above facilities guidelines, and not currently permitted, at the above facilities may be authorized under this general permit.may be authorized under this general permit.

• Stormwater discharges associated with industrial activity from Stormwater discharges associated with industrial activity from facilities with a previous or existing NPDES individual permit that facilities with a previous or existing NPDES individual permit that contains stormwater requirements. Stormwater discharges contains stormwater requirements. Stormwater discharges associated with industrial activity from facilities where an NPDES associated with industrial activity from facilities where an NPDES permit has been denied;permit has been denied;

• Stormwater discharges associated with industrial activity from Stormwater discharges associated with industrial activity from construction activities, which may be covered under NPDES construction activities, which may be covered under NPDES general permit ARR150000, except stormwater discharges from general permit ARR150000, except stormwater discharges from portions of a construction site that can be classified as an industrial portions of a construction site that can be classified as an industrial activity;activity;

• Stormwater discharges associated with industrial activity that Stormwater discharges associated with industrial activity that would adversely affect a listed endangered or threatened species would adversely affect a listed endangered or threatened species or its critical habitat; or its critical habitat;


• Stormwater discharges associated with industrial activity that Stormwater discharges associated with industrial activity that would adversely affect property either listed on, or eligible for listing would adversely affect property either listed on, or eligible for listing on, the National Register of Historic Places;on, the National Register of Historic Places;

• Stormwater discharges associated with industrial activity that the Stormwater discharges associated with industrial activity that the Director has determined to be contributing to a violation of a water Director has determined to be contributing to a violation of a water quality standard;quality standard;

• Discharges to stream segments or waterbodies for which there is a Discharges to stream segments or waterbodies for which there is a completed and approved total maximum daily load (TMDL) completed and approved total maximum daily load (TMDL) allocation;allocation;

• Discharges that the Department, prior to authorization under this Discharges that the Department, prior to authorization under this permit, determines will cause, have the reasonable potential to permit, determines will cause, have the reasonable potential to cause, or contribute to an excursion above any applicable water cause, or contribute to an excursion above any applicable water quality standard are not eligible for coverage under this permit;quality standard are not eligible for coverage under this permit;

• Stormwater discharges associated with industrial activity which are Stormwater discharges associated with industrial activity which are authorized by this permit may be combined with other sources of authorized by this permit may be combined with other sources of stormwater (i.e., not process water) which are not classified as stormwater (i.e., not process water) which are not classified as associated with industrial activity.associated with industrial activity.


1.1. Section 313 Water Priority ChemicalsSection 313 Water Priority Chemicals

2.2. Oil and GreaseOil and Grease

3.3. MetalsMetals

4.4. Suspended SolidsSuspended Solids

5.5. Phosphorus, Nitrate, Nitrite NitrogenPhosphorus, Nitrate, Nitrite Nitrogen

6.6. pH – Acidic or Alkaline runoffpH – Acidic or Alkaline runoff

7.7. Pollutants that increase BOD and CODPollutants that increase BOD and COD

Stormwater Pollutant TypesStormwater Pollutant Types

• Pollutants are conveyed into the stormwater by spills, leaks, raw Pollutants are conveyed into the stormwater by spills, leaks, raw materials storage, finished product storage, transfer of products.materials storage, finished product storage, transfer of products.

• Minimize contact of materials with precipitation.Minimize contact of materials with precipitation.

• Clean up spills and leaks immediately.Clean up spills and leaks immediately.

• Fueling areas.Fueling areas.

• Repair areas.Repair areas.

• Product staging areas.Product staging areas.

• Unloading areas.Unloading areas.

Loading MechanismsLoading Mechanisms

1. Coverage Under This Permit.1. Coverage Under This Permit.

• Permit AreaPermit Area

• EligibilityEligibility

• Limitations on CoverageLimitations on Coverage

• Industrial Facilities which Must Submit Applications for Stormwater Industrial Facilities which Must Submit Applications for Stormwater PermitsPermits

• Requiring an Individual NPDES Permit or an Alternative General Requiring an Individual NPDES Permit or an Alternative General Permit AuthorizationPermit Authorization

• Notice of Intent RequirementsNotice of Intent Requirements

• Notice of Termination RequirementsNotice of Termination Requirements

General Permit RequirementsGeneral Permit Requirements

2.2. Business Categories and Subcategories.Business Categories and Subcategories.

• Facilities subject to stormwater effluent limitations guidelines, new Facilities subject to stormwater effluent limitations guidelines, new source performance standards, or toxic pollutants effluent standards source performance standards, or toxic pollutants effluent standards under 40 CFR, Subchapter N [except facilities which are exempt under 40 CFR, Subchapter N [except facilities which are exempt under category (xi)]. "Note that the phrase 'toxic pollutant effluent under category (xi)]. "Note that the phrase 'toxic pollutant effluent standards' refers to the standards codified at 40 CFR 129 which standards' refers to the standards codified at 40 CFR 129 which applies only to manufacturers of 6 specific pesticide products that are applies only to manufacturers of 6 specific pesticide products that are defined as toxic pollutants. The phrase does not apply to facilities defined as toxic pollutants. The phrase does not apply to facilities subject to effluent limitation guidelines for toxics under 40 CFR subject to effluent limitation guidelines for toxics under 40 CFR Subchapter N."Subchapter N."


• Facilities classified as:Facilities classified as:

SIC 24 (except 2434)SIC 24 (except 2434) LumberLumber and Wood Products and Wood Products

SIC 26 (except 265 & 267)SIC 26 (except 265 & 267) Paper and Allied ProductsPaper and Allied Products

SIC 28 (except 283 & 285)SIC 28 (except 283 & 285) Chemicals and Allied ProductsChemicals and Allied Products

SIC 29SIC 29 Petroleum and Coal ProductsPetroleum and Coal Products

SIC 311SIC 311 Leather Tanning and FinishingLeather Tanning and Finishing

SIC 32 (except 323)SIC 32 (except 323) Stone, Clay and Glass ProductsStone, Clay and Glass Products

SIC 33SIC 33 Primary Metal IndustriesPrimary Metal Industries

SIC 3441SIC 3441 Fabricated Structural MetalFabricated Structural Metal

SIC 373SIC 373 Ship & Boat Building & RepairingShip & Boat Building & Repairing


• Facilities classified as SIC 10 through 14, including active or Facilities classified as SIC 10 through 14, including active or inactive mining operations and oil and gas exploration, inactive mining operations and oil and gas exploration, production, processing, or treatment operations, or transmission production, processing, or treatment operations, or transmission facilities that discharge stormwater contaminated by contact facilities that discharge stormwater contaminated by contact with, or that has come into contact with, any overburden, raw with, or that has come into contact with, any overburden, raw material, intermediate products, finished products, byproducts, material, intermediate products, finished products, byproducts, or waste products located on the site of such operations.or waste products located on the site of such operations.

SIC 10SIC 10 Metal MiningMetal Mining

SIC 11SIC 11 Anthracite MiningAnthracite Mining

SIC 12SIC 12 Coal MiningCoal Mining

SIC 13SIC 13 Oil and Gas ExtractionOil and Gas Extraction

SIC 14SIC 14 Nonmetallic Minerals, except FuelsNonmetallic Minerals, except Fuels


• Hazardous waste treatment, storage, or disposal facilities, Hazardous waste treatment, storage, or disposal facilities, including those that are operating under interim status or a including those that are operating under interim status or a permit under Subtitle C of the Resource Conservation and permit under Subtitle C of the Resource Conservation and Recovery Act (RCRA).Recovery Act (RCRA).

• Landfills, land application sites, and open dumps that receive or Landfills, land application sites, and open dumps that receive or have received any industrial wastes including those that are have received any industrial wastes including those that are subject to regulation under subtitle D or RCRA.subject to regulation under subtitle D or RCRA.


• Facilities involved in the recycling of material, including metal Facilities involved in the recycling of material, including metal scrap yards, battery reclaimers, salvage yards, and automobile scrap yards, battery reclaimers, salvage yards, and automobile junkyards, including but limited to those classified as:junkyards, including but limited to those classified as:

SIC 5015SIC 5015 Motor Vehicle Parts, UsedMotor Vehicle Parts, Used

SIC 5093SIC 5093 Scrap and Waste MaterialsScrap and Waste Materials


• Steam electric power generating facilities, including coal handling sites.Steam electric power generating facilities, including coal handling sites.

• Transportation facilities which have vehicle maintenance shops, Transportation facilities which have vehicle maintenance shops, equipment cleaning operations, or airport de-icing operations. Only equipment cleaning operations, or airport de-icing operations. Only those portions of the facility that are either involved in vehicle those portions of the facility that are either involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication), equipment cleaning operations, or painting, fueling, and lubrication), equipment cleaning operations, or airport de-icing operations, or which are otherwise listed in another airport de-icing operations, or which are otherwise listed in another category, are included.category, are included.

SIC 40SIC 40 Railroad TransportationRailroad Transportation

SIC 41SIC 41 Local and Suburban TransitLocal and Suburban Transit

SIC 42(except 4221-25)SIC 42(except 4221-25) Motor Freight & WarehousingMotor Freight & Warehousing

SIC 43SIC 43 U.S. Postal ServiceU.S. Postal Service

SIC 44SIC 44 Water TransportationWater Transportation

SIC 45SIC 45 Transportation by AirTransportation by Air

SIC 5171SIC 5171 Petroleum Bulk Stations & TerminalsPetroleum Bulk Stations & Terminals


• Treatment works treating domestic sewage or any other sewage Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the sludge or wastewater treatment device or system, used in the storage, treatment, recycling, and reclamation of municipal or storage, treatment, recycling, and reclamation of municipal or domestic sewage, including lands dedicated to the disposal of domestic sewage, including lands dedicated to the disposal of sewage sludge that are located within the confines of the facility, sewage sludge that are located within the confines of the facility, with a design flow of 1.0 million gallons per day or more, or with a design flow of 1.0 million gallons per day or more, or required to have an approved pretreatment program under 40 required to have an approved pretreatment program under 40 CFR Part 403. Not included are farmlands, domestic gardens, or CFR Part 403. Not included are farmlands, domestic gardens, or lands used for sludge management where sludge is beneficially lands used for sludge management where sludge is beneficially reused and which are not physically located in the confines of reused and which are not physically located in the confines of the facility, or areas that are in compliance with Section 405 of the facility, or areas that are in compliance with Section 405 of the CWA.the CWA.


• Construction activity including clearing, grading, and excavation Construction activity including clearing, grading, and excavation activities that result in the disturbance of five (5) or more acres activities that result in the disturbance of five (5) or more acres of total land area or less than five (5) acres of total land area of total land area or less than five (5) acres of total land area which is part of a larger common plan of development or sale. which is part of a larger common plan of development or sale. However based on 40 CFR 122.26(b)(15), construction activity However based on 40 CFR 122.26(b)(15), construction activity that results in the disturbance of one (1) acre or more of total that results in the disturbance of one (1) acre or more of total land area or less than one (1) acre of total land area which is land area or less than one (1) acre of total land area which is part of a larger common plan of development or sale is defined part of a larger common plan of development or sale is defined as "small construction activity" and must obtain a stormwater as "small construction activity" and must obtain a stormwater permit.permit.


• Facilities under the following SICs [which are not otherwise Facilities under the following SICs [which are not otherwise included in categories ii - x], including only stormwater discharges included in categories ii - x], including only stormwater discharges where material handling equipment or activities, raw materials, where material handling equipment or activities, raw materials, intermediate products, final products, waste materials, intermediate products, final products, waste materials, byproducts, or industrial machinery are exposed to stormwater.byproducts, or industrial machinery are exposed to stormwater.


SIC 20SIC 20 Food and Kindred ProductsFood and Kindred Products

SIC 21SIC 21 Tobacco ProductsTobacco Products

SIC 22SIC 22 Textile Mill ProductsTextile Mill Products

SIC 23SIC 23 Apparel & Other Textile ProductsApparel & Other Textile Products

SIC 2434SIC 2434 Wood Kitchen CabinetsWood Kitchen Cabinets

SIC 25SIC 25 Furniture & FixturesFurniture & Fixtures

SIC 265SIC 265 Paperboard Containers & BoxesPaperboard Containers & Boxes

SIC 267SIC 267Converted Paper and Paper Board Prod. (except containers Converted Paper and Paper Board Prod. (except containers & boxes)& boxes)

SIC 27SIC 27 Printing & PublishingPrinting & Publishing

SIC 283SIC 283 DrugsDrugs


SIC 30SIC 30 Rubber &Misc. Plastic ProductsRubber &Misc. Plastic Products

SIC 31 (except 311)SIC 31 (except 311) Leather & Leather ProductsLeather & Leather Products

SIC 323SIC 323 Products of Purchases GlassProducts of Purchases Glass

SIC 34 (except 3441)SIC 34 (except 3441) Fabricated Metal ProductsFabricated Metal Products

SIC 35SIC 35 Industrial Machinery & Equipment, except ElectricalIndustrial Machinery & Equipment, except Electrical

SIC 36SIC 36 Electronic & Other Elec. Equip.Electronic & Other Elec. Equip.

SIC 37 (except 373)SIC 37 (except 373) Transportation EquipmentTransportation Equipment

SIC 38SIC 38 Instruments & Related ProductsInstruments & Related Products

SIC 39SIC 39 Misc.Misc. Manufacturing IndustriesManufacturing Industries

SIC 4221SIC 4221 Farm Prod. Warehousing & StorageFarm Prod. Warehousing & Storage

SIC 4222SIC 4222 Refrigerated Warehousing & StorageRefrigerated Warehousing & Storage

SIC 4225SIC 4225 General Warehousing & StorageGeneral Warehousing & Storage

3. Relationship to Other NPDES Permits.3. Relationship to Other NPDES Permits.

• You may have an existing individual NPDES permit for You may have an existing individual NPDES permit for some other type of discharge.some other type of discharge.

• You my need to add General Permit for Stormwater You my need to add General Permit for Stormwater requirements or modify the Individual Permit to requirements or modify the Individual Permit to incorporate stormwater requirements.incorporate stormwater requirements.

• Is stormwater one word or two?Is stormwater one word or two?


1. Planning & Organization1. Planning & Organization

• Designate a Pollution Prevention Team.Designate a Pollution Prevention Team.

• Shall be prepared with good engineering practices.Shall be prepared with good engineering practices.

• Shall identify potential sources of pollution that may Shall identify potential sources of pollution that may reasonably affect stormwater.reasonably affect stormwater.

• Shall describe and ensure implementation of Best Management Shall describe and ensure implementation of Best Management Practices.Practices.

• Determine significant materials – used, stored, treated, Determine significant materials – used, stored, treated, disposed.disposed.

**The whole idea is to stop or reduce pollution in stormwater **The whole idea is to stop or reduce pollution in stormwater discharges associated with industrial activity.**discharges associated with industrial activity.**

Stormwater Pollution Prevention Plan (SWPPP)Stormwater Pollution Prevention Plan (SWPPP)

2. Assessment2. Assessment

• Develop a site map.Develop a site map.

• Outline drainage areas.Outline drainage areas.

• Location of outfall, control structures, etc.Location of outfall, control structures, etc.

• Location where significant materials are stored.Location where significant materials are stored.

• Surface water bodies.Surface water bodies.

• Storm sewers.Storm sewers.

• Topographic map.Topographic map.



• Assess facility layout in terms of :Assess facility layout in terms of :

• Stormwater runoff – site drainage map, drainage areas, Stormwater runoff – site drainage map, drainage areas, drainage structures, etc.drainage structures, etc.

• Raw and finished materials storage areas.Raw and finished materials storage areas.

• Chemical storage areas, tanks, etc.Chemical storage areas, tanks, etc.

• Loading and unloading areas.Loading and unloading areas.

• Material transfer methods.Material transfer methods.


• Fueling areas.Fueling areas.

• Repair areas.Repair areas.

• Used equipment storage – “bone yards.”Used equipment storage – “bone yards.”

• Identify potential pollutant sources.Identify potential pollutant sources.

• Wastewater treatment facilities.Wastewater treatment facilities.

3. Contents of SWPPP3. Contents of SWPPP

• Pollution Prevention TeamPollution Prevention Team

• Site MapSite Map

• Description of potential pollutant sourcesDescription of potential pollutant sources

• Stormwater Drainage Stormwater Drainage

Prediction of the direction of flowPrediction of the direction of flow

• Inventory Of Exposed Materials Inventory Of Exposed Materials

Raw and/or unfinished productsRaw and/or unfinished products



• History Of Spills And LeaksHistory Of Spills And Leaks

Significant spills – Section 311 CWA & Section 102 CERCLASignificant spills – Section 311 CWA & Section 102 CERCLA

Reportable quantities Stormwater Sampling Data – if necessaryReportable quantities Stormwater Sampling Data – if necessary

• Risk Identification – Potential Pollutant Sources Risk Identification – Potential Pollutant Sources

High, medium, lowHigh, medium, low

Toxicity of chemicals, quantity used or produced or shipped Toxicity of chemicals, quantity used or produced or shipped offsiteoffsite

Waste productsWaste products

Likelihood of contact with stormwaterLikelihood of contact with stormwater

• Measures & Controls – Best Management Practices (BMPs)Measures & Controls – Best Management Practices (BMPs)

• Good HousekeepingGood Housekeeping

• Visual InspectionsVisual Inspections

• Preventative MaintenancePreventative Maintenance

• Spill Prevention and Response ProceduresSpill Prevention and Response Procedures

• InspectionsInspections

• Employee TrainingEmployee Training

• Recordkeeping and Internal ReportingRecordkeeping and Internal Reporting

• Non-storm Water DischargesNon-storm Water Discharges

• Sediment and Erosion Control\Sediment and Erosion Control\

• Management of RunoffManagement of Runoff


• Total Maximum Daily Load (TMDL)Total Maximum Daily Load (TMDL)

• DocumentationDocumentation

• Endangered SpeciesEndangered Species

Locate threatened & endangered species in the vicinity of Locate threatened & endangered species in the vicinity of the sitethe site

Will stormwater discharge impact the speciesWill stormwater discharge impact the species

• Historic SitesHistoric Sites

Locate historic sites in the vicinity of the siteLocate historic sites in the vicinity of the site

Will stormwater discharge impact historic sites?Will stormwater discharge impact historic sites?


Attainment of Water Quality StandardsAttainment of Water Quality Standards

Comprehensive Site Compliance EvaluationComprehensive Site Compliance Evaluation

Consistency with Other PlansConsistency with Other Plans

• SPCC – 40 CFR 112SPCC – 40 CFR 112

• Preparedness, Prevention & Contingency Plans – Preparedness, Prevention & Contingency Plans – 4040 CFR 264 & 265CFR 264 & 265

• FRP – Facility Response PlansFRP – Facility Response Plans

• NPDES Toxic Organic Management PlanNPDES Toxic Organic Management Plan40 CFR 413, 433, 46940 CFR 413, 433, 469

• OSHA – 29 CFR 1910OSHA – 29 CFR 1910


Requirements Subject to SARA III, Section 313Requirements Subject to SARA III, Section 313

• Proper storage containers – compatible containersProper storage containers – compatible containers

• Appropriate containment – secondary containmentAppropriate containment – secondary containment

• Drainage controlDrainage control

• Diversionary structuresDiversionary structures

• Roofs or coversRoofs or covers

• Loading and unloading areasLoading and unloading areas

• Material transfer methodsMaterial transfer methods

• Preventive maintenancePreventive maintenance

• SecuritySecurity

• TrainingTraining

• Engineering certificationEngineering certification


4. BMP Identification4. BMP Identification

5. BMP Implementation5. BMP Implementation

6. Monitoring and Reporting6. Monitoring and Reporting

• SARA Title III, Section 313 FacilitiesSARA Title III, Section 313 Facilities. During the period . During the period beginning on the effective date and lasting through the beginning on the effective date and lasting through the expiration date of this permit, and in addition to any expiration date of this permit, and in addition to any monitoring requirements in Parts II.B.2 through II.B. 12 for monitoring requirements in Parts II.B.2 through II.B. 12 for which the permittee may be subject, permittees subject to which the permittee may be subject, permittees subject to the requirements to the requirements to report report releases into the environment releases into the environment under Section 313 of SARA Title III for chemicals which are under Section 313 of SARA Title III for chemicals which are classified as "Section 313 water priority chemicals" are classified as "Section 313 water priority chemicals" are required to monitor stormwater that is discharged from the required to monitor stormwater that is discharged from the facility that comes into contact with: 1) any equipment, tank, facility that comes into contact with: 1) any equipment, tank, container, or other vessel used for storage or application of a container, or other vessel used for storage or application of a Section 313 water priority chemical; and/or 2) any Section 313 water priority chemical; and/or 2) any equipment, tank, container, or other vessel located at a equipment, tank, container, or other vessel located at a truck, rail car, or air strip loading or unloading area where a truck, rail car, or air strip loading or unloading area where a Section 313 water priority chemical is handled; for:Section 313 water priority chemical is handled; for:


• ParametersParameters. The parameters to be measured . The parameters to be measured include:include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Nitrate + Nitrite Nitrogen (mg/L)Nitrate + Nitrite Nitrogen (mg/L)• Five Day Biochemical Oxygen Demand (BOD5) Five Day Biochemical Oxygen Demand (BOD5)

(mg/L)(mg/L)• Total Phosphorus (mg/L)Total Phosphorus (mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)• pHpH• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)

• Frequency of MonitoringFrequency of Monitoring. Sampling shall be . Sampling shall be conducted at least annually (once per year) except conducted at least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements).16 (Removal of Sampling Requirements).


• Primary Metal IndustriesPrimary Metal Industries. . During the period beginning on the During the period beginning on the effective date and lasting through the expiration date of this permit, effective date and lasting through the expiration date of this permit, facilities classified as Standard Industrial Classification (SIC) 33 facilities classified as Standard Industrial Classification (SIC) 33 (Primary Metal Industry) are subject to the following monitoring (Primary Metal Industry) are subject to the following monitoring requirements for stormwater discharges associated with industrial requirements for stormwater discharges associated with industrial activity that are discharged from the facility:activity that are discharged from the facility:

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• Five Day Biochemical Oxygen Demand (BOD5) (mg/L)Five Day Biochemical Oxygen Demand (BOD5) (mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)• Total Cadmium (mg/L)Total Cadmium (mg/L)• Total Phosphorus (mg/L)Total Phosphorus (mg/L)• Total Arsenic (mg/L)Total Arsenic (mg/L)• Total Lead (mg/L)Total Lead (mg/L)• pHpH• Total Copper (mg/L)Total Copper (mg/L)


• Frequency of Monitoring.Frequency of Monitoring. Sampling shall be Sampling shall be conducted at least annually (once per year) except conducted at least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements).16 (Removal of Sampling Requirements).

• Land Disposal Units/Incinerators/BIFs.Land Disposal Units/Incinerators/BIFs. During the During the period beginning on the effective date and lasting through period beginning on the effective date and lasting through the expiration date of this permit, stormwater discharges the expiration date of this permit, stormwater discharges associated with industrial activity from any active or associated with industrial activity from any active or inactive landfill, land application sites, or open dump inactive landfill, land application sites, or open dump without a stabilized final cover that received any industrial without a stabilized final cover that received any industrial wastes from a facility with a Standard Industrial wastes from a facility with a Standard Industrial Classification (SIC) of 20-39 (manufacturing), and Classification (SIC) of 20-39 (manufacturing), and incinerators (including Burner Industrial Furnaces (BIF)) incinerators (including Burner Industrial Furnaces (BIF)) that burn hazardous waste and operate under interim that burn hazardous waste and operate under interim status or a permit under Subtitle C of RCRA, are subject status or a permit under Subtitle C of RCRA, are subject to the following monitoring requirements:to the following monitoring requirements:


• Parameters. Parameters. The parameters to be measured include:The parameters to be measured include:• Ammonia (as N) (mg/L) Ammonia (as N) (mg/L) • pHpH• Chemical Oxygen Demand (COD) (mg/L) Chemical Oxygen Demand (COD) (mg/L) • Total Dissolved Solids (mg/L)Total Dissolved Solids (mg/L)• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Selenium (mg/L)Total Selenium (mg/L)• Total Cyanide (mg/L)Total Cyanide (mg/L)• Total Magnesium (mg/L)Total Magnesium (mg/L)• Total Cadmium (mg/L)Total Cadmium (mg/L)• Nitrate + Nitrate Nitrogen (mg/L)Nitrate + Nitrate Nitrogen (mg/L)• Total Arsenic (mg/L)Total Arsenic (mg/L)• Total Lead (mg/L)Total Lead (mg/L)• Total Silver (mg/L)Total Silver (mg/L)• Total Barium (mg/L)Total Barium (mg/L)• Total Mercury (mg/L)Total Mercury (mg/L)

• Frequency of Monitoring.Frequency of Monitoring. Sampling shall be conducted at Sampling shall be conducted at least annually (once per year) except as provided by least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements).Sampling Requirements).


• Wood Treatment Facilities (Chlorophenolic Formulations)Wood Treatment Facilities (Chlorophenolic Formulations). . During the period beginning on the effective date and lasting During the period beginning on the effective date and lasting through the expiration date of this permit, stormwater discharges through the expiration date of this permit, stormwater discharges associated with industrial activity from areas that are used for wood associated with industrial activity from areas that are used for wood treatment, wood surface application, or storage of treated or surface treatment, wood surface application, or storage of treated or surface protected wood at any wood preserving or wood surface facilities protected wood at any wood preserving or wood surface facilities that currently use chlorophenolic formulations are subject to the that currently use chlorophenolic formulations are subject to the following monitoring requirements:following monitoring requirements:

• Parameters.Parameters. The parameters to be measured include: The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)• 5-Day Biochemical Oxygen Demand (BOD5) (mg/L) 5-Day Biochemical Oxygen Demand (BOD5) (mg/L) • pHpH• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• Total Phenols (mg/L)Total Phenols (mg/L)

• Frequency of Monitoring.Frequency of Monitoring. Sampling shall be conducted at Sampling shall be conducted at least annually (once per year) except as provided by least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements).Sampling Requirements).


• Wood Treatment Facilities (Creosote Formulations). Wood Treatment Facilities (Creosote Formulations). During During the period beginning on the effective date and lasting through the period beginning on the effective date and lasting through the expiration date of this permit, stormwater discharges the expiration date of this permit, stormwater discharges associated with industrial activity from areas that are used for associated with industrial activity from areas that are used for wood treatment or storage of treated wood at any wood wood treatment or storage of treated wood at any wood preserving facilities using creosote formulations are subject to preserving facilities using creosote formulations are subject to the following monitoring requirements:the following monitoring requirements:

• Parameters.Parameters. The parameters to be measured include: The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)• Five Day Biochemical Oxygen Demand (BOD5) Five Day Biochemical Oxygen Demand (BOD5)

(mg/L) (mg/L) • pH pH • Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)

• Frequency of Monitoring.Frequency of Monitoring. Sampling shall be conducted Sampling shall be conducted at least annually (once per year) except as provided by at least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements). Sampling Requirements).


• Wood Treatment Facilities (Chromium - Arsenic Formulations)Wood Treatment Facilities (Chromium - Arsenic Formulations). . During the period beginning on the effective date and lasting through During the period beginning on the effective date and lasting through the expiration date of this permit, stormwater discharges associated the expiration date of this permit, stormwater discharges associated with industrial activity from areas that are used for wood treatment or with industrial activity from areas that are used for wood treatment or storage of treated wood at any wood preserving facilities currently storage of treated wood at any wood preserving facilities currently using preservatives containing chromium - arsenic formulations are using preservatives containing chromium - arsenic formulations are subject to the following monitoring requirements:subject to the following monitoring requirements:

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Chemical Oxygen Demand (COD)(mg/L)Chemical Oxygen Demand (COD)(mg/L)• Five Day Biochemical Oxygen Demand (BOD5) (mg/L)Five Day Biochemical Oxygen Demand (BOD5) (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• Total Copper (mg/L)Total Copper (mg/L)• pHpH• Total Arsenic (mg/L)Total Arsenic (mg/L)

• Frequency of MonitoringFrequency of Monitoring. Sampling shall be conducted at . Sampling shall be conducted at least annually (once per year) except as provided by least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of Sampling (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements).Requirements).


• Coal Pile RunoffCoal Pile Runoff. . During the period beginning on the effective During the period beginning on the effective date and lasting through the expiration date of this permit, date and lasting through the expiration date of this permit, stormwater discharges associated with industrial activity from stormwater discharges associated with industrial activity from coal pile runoff are subject to the following monitoring coal pile runoff are subject to the following monitoring requirements:requirements:

• Parameters. Parameters. The parameters to be measured include:The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• pHpH• Total Copper (mg/L)Total Copper (mg/L)• Total Nickel (mg/L)Total Nickel (mg/L)• Total Zinc (mg/L)Total Zinc (mg/L)

• Frequency of Monitoring. Frequency of Monitoring. Sampling shall be conducted Sampling shall be conducted at least annually (once per year) except as provided by at least annually (once per year) except as provided by paragraph II.B.14 (Sampling Waiver), II.B.15 paragraph II.B.14 (Sampling Waiver), II.B.15 (Representative Discharge), or II.B.16 (Removal of (Representative Discharge), or II.B.16 (Removal of Sampling Requirements).Sampling Requirements).


• Battery ReclaimersBattery Reclaimers. . During the period beginning on the During the period beginning on the effective date and lasting through the expiration date of this effective date and lasting through the expiration date of this permit, stormwater discharges associated with industrial permit, stormwater discharges associated with industrial activity from areas used for storage of used lead acid batteries, activity from areas used for storage of used lead acid batteries, reclamation products, or waste products, and areas used for reclamation products, or waste products, and areas used for lead acid battery reclamation (including material handling lead acid battery reclamation (including material handling activities) at facilities that reclaim lead acid batteries are activities) at facilities that reclaim lead acid batteries are subject to the following monitoring requirements:subject to the following monitoring requirements:

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L) Oil and Grease (mg/L) • Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• pHpH• Total Copper (mg/L)Total Copper (mg/L)• Total Lead (mg/L)Total Lead (mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)

• Frequency of MonitoringFrequency of Monitoring. Sampling shall be conducted . Sampling shall be conducted at least annually (once per year) except as provided by at least annually (once per year) except as provided by paragraph II.B.14 (Sampling Waiver), II.B.15 paragraph II.B.14 (Sampling Waiver), II.B.15 (Representative Discharge), or II.B.16 (Removal of (Representative Discharge), or II.B.16 (Removal of Sampling Requirements).Sampling Requirements).


• AirportsAirports. During the period beginning on the effective date . During the period beginning on the effective date and lasting through the expiration date of this permit, airports and lasting through the expiration date of this permit, airports that use more than 100,000 gallons of glycol-based that use more than 100,000 gallons of glycol-based deicing/anti-icing chemicals and/or 100 tons or more of urea on deicing/anti-icing chemicals and/or 100 tons or more of urea on an average annual basis shall monitor outfalls from the facility an average annual basis shall monitor outfalls from the facility that collect runoff from areas where deicing/anti-icing activities that collect runoff from areas where deicing/anti-icing activities occur (including runways, taxiways, ramps, and dedicated occur (including runways, taxiways, ramps, and dedicated aircraft deicing stations), except as provided in paragraph aircraft deicing stations), except as provided in paragraph II.B.14(Sampling Waiver). Airports which are subject to these II.B.14(Sampling Waiver). Airports which are subject to these monitoring requirements must sample their stormwater monitoring requirements must sample their stormwater discharges for the parameters listed below when deicing discharges for the parameters listed below when deicing activities are occurring:activities are occurring:

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• Five Day Biochemical Oxygen Demand (BOD5) Five Day Biochemical Oxygen Demand (BOD5)

(mg/L)(mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)• pHpH


• Frequency of Monitoring. Frequency of Monitoring. Sampling shall be conducted Sampling shall be conducted at outfalls that collect runoff from areas where at outfalls that collect runoff from areas where deicing/anti-icing activities occur at least annually (once deicing/anti-icing activities occur at least annually (once per year) during the months of December, January, per year) during the months of December, January, and February when deicing/anti-icing activities are and February when deicing/anti-icing activities are occurring, except as provided by paragraph II.B.14 occurring, except as provided by paragraph II.B.14 (Sampling Waiver), II.B.15 (Representative Discharge), (Sampling Waiver), II.B.15 (Representative Discharge), or II.B.16 (Removal of Sampling Requirements).or II.B.16 (Removal of Sampling Requirements).


• Animal Handling/Meat PackingAnimal Handling/Meat Packing. . During the period beginning on the effective During the period beginning on the effective date and lasting through the expiration date of this permit, stormwater date and lasting through the expiration date of this permit, stormwater discharges associated with industrial activity from animal handling areas, discharges associated with industrial activity from animal handling areas, manure management (or storage) areas, and production waste management manure management (or storage) areas, and production waste management (or storage) areas that are exposed to precipitation at meat packing plants, (or storage) areas that are exposed to precipitation at meat packing plants, poultry packing plants, and facilities that manufacture animal and marine fats poultry packing plants, and facilities that manufacture animal and marine fats and oils, are subject to the following monitoring requirements:and oils, are subject to the following monitoring requirements:

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• Five Day Biochemical Oxygen Demand (BOD5) (mg/L)Five Day Biochemical Oxygen Demand (BOD5) (mg/L)• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)• pHpH• Nitrate + Nitrite NitrogenNitrate + Nitrite Nitrogen• Fecal Coliform (counts/1 00mL)Fecal Coliform (counts/1 00mL)• Total Phosphorus (mg/L)Total Phosphorus (mg/L)

• Frequency of MonitoringFrequency of Monitoring. Sampling shall be conducted at least . Sampling shall be conducted at least annually (once per year) except as provided in paragraph II.B.14 annually (once per year) except as provided in paragraph II.B.14 (Sampling Waiver), II.B.15 (Representative Discharge), or II.B.16 (Sampling Waiver), II.B.15 (Representative Discharge), or II.B.16 (Removal of Sampling Requirements).(Removal of Sampling Requirements).


• Coal-Fired Steam Electric FacilitiesCoal-Fired Steam Electric Facilities. . During the period During the period beginning on the effective date and lasting through the beginning on the effective date and lasting through the expiration date of this permit, stormwater discharges expiration date of this permit, stormwater discharges associated with industrial activity from coal handling facilities associated with industrial activity from coal handling facilities (other than discharges in whole or in part from coal piles (other than discharges in whole or in part from coal piles subject to stormwater effluent guidelines at 40 CFR Part 423 subject to stormwater effluent guidelines at 40 CFR Part 423 (which are not eligible for coverage under this permit) are (which are not eligible for coverage under this permit) are subject to the following monitoring requirements.subject to the following monitoring requirements.

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• Total Copper (mg/L)Total Copper (mg/L)• pHpH• Total Nickel (mg/L)Total Nickel (mg/L)• Total Zinc (mg/L)Total Zinc (mg/L)

• Frequency of MonitoringFrequency of Monitoring. Sampling shall be conducted . Sampling shall be conducted at least annually (once per year) except as provided by at least annually (once per year) except as provided by paragraph II.B.14 (Sampling Waiver), II.B.15 paragraph II.B.14 (Sampling Waiver), II.B.15 (Representative Discharge), or II.B.16 (Removal of (Representative Discharge), or II.B.16 (Removal of Sampling Requirements).Sampling Requirements).


• Additional FacilitiesAdditional Facilities. . During the period beginning on the effective During the period beginning on the effective date and lasting through the expiration date of this permit, stormwater date and lasting through the expiration date of this permit, stormwater discharges associated with industrial activity that:discharges associated with industrial activity that:

• come into contact with storage piles for solid chemicals used as come into contact with storage piles for solid chemicals used as raw materials that are exposed to precipitation at facilities raw materials that are exposed to precipitation at facilities classified as SIC 30 (Rubber and Miscellaneous Plastics classified as SIC 30 (Rubber and Miscellaneous Plastics Products) or SIC 28 (Chemicals and Allied Products);Products) or SIC 28 (Chemicals and Allied Products);

• are from those areas at automobile junkyards with any of the are from those areas at automobile junkyards with any of the following:following:

• over 250 auto/truck bodies with drive lines (engine, over 250 auto/truck bodies with drive lines (engine, transmission, axles, and wheels), 250 drivelines, or any transmission, axles, and wheels), 250 drivelines, or any combination thereof (in whole or in parts) which are exposed combination thereof (in whole or in parts) which are exposed to stormwater;to stormwater;

• over 250 auto/truck units (bodies with or without drivelines in over 250 auto/truck units (bodies with or without drivelines in whole or in parts) which are stored exposed to stormwater; orwhole or in parts) which are stored exposed to stormwater; or

• over 250 units per year are dismantled and drainage or over 250 units per year are dismantled and drainage or storage of automotive fluids occurs in areas exposed to storage of automotive fluids occurs in areas exposed to stormwater;stormwater;


• come into contact with lime storage piles that are exposed come into contact with lime storage piles that are exposed to stormwater at lime manufacturing facilities;to stormwater at lime manufacturing facilities;

• are from oil handling sites at oil fired steam electric power are from oil handling sites at oil fired steam electric power generating generating facilities;facilities;

• are from cement manufacturing facilities and cement kilns are from cement manufacturing facilities and cement kilns (other than discharges in whole or in part from material (other than discharges in whole or in part from material storage piles subject to stormwater effluent guidelines at 40 storage piles subject to stormwater effluent guidelines at 40 CFR Part 411, which are not eligible for coverage under this CFR Part 411, which are not eligible for coverage under this permit);permit);

• are from ready-mixed concrete facilities; orare from ready-mixed concrete facilities; or


• are from shipbuilding and repairing facilities are subject to are from shipbuilding and repairing facilities are subject to the following the following requirements:requirements:

• ParametersParameters. The parameters to be measured include:. The parameters to be measured include:• Oil and Grease (mg/L)Oil and Grease (mg/L)• Total Suspended Solids (mg/L)Total Suspended Solids (mg/L)• pHpH• Chemical Oxygen Demand (COD) (mg/L)Chemical Oxygen Demand (COD) (mg/L)

• Frequency of SamplingFrequency of Sampling. Sampling will be conducted at . Sampling will be conducted at least annually (once per year) except as provided by least annually (once per year) except as provided by paragraphs II.B. 14 (Sampling Waiver), II.B. 15 paragraphs II.B. 14 (Sampling Waiver), II.B. 15 (Representative Discharge), or II.B. 16 (Removal of (Representative Discharge), or II.B. 16 (Removal of Sampling Requirements).Sampling Requirements).


City of Little Rock Grading PermitCity of Little Rock Grading Permit

Grading permit Required If: Grading permit Required If:

Cut or fill greater than 15 vertical feet, orCut or fill greater than 15 vertical feet, or Cut or fill volume equal to or greater than 3,000 Cut or fill volume equal to or greater than 3,000

cubic yards, orcubic yards, or Clearing that exceeds 1 acre in size, andClearing that exceeds 1 acre in size, and Any land alterations on properties that are located Any land alterations on properties that are located

within the 100 year floodplan.within the 100 year floodplan.

Requirements for Grading PermitRequirements for Grading Permit

A site plan must be developed and identify the A site plan must be developed and identify the following: following: Acreage of the proposed project,Acreage of the proposed project, Land areas to be disturbed (hatching or shading)Land areas to be disturbed (hatching or shading) Stages of grading which identify the limits of Stages of grading which identify the limits of

sections to be disturbed and the approximate sections to be disturbed and the approximate order of development.order of development.

Extent of cut and fill, shown by placing a dashed Extent of cut and fill, shown by placing a dashed line at the top and toe of cut or fill slopes, and line at the top and toe of cut or fill slopes, and indicating on the Plan the height and slope of the indicating on the Plan the height and slope of the cut or fill,cut or fill,

Previsions for collecting and discharging surface Previsions for collecting and discharging surface water, andwater, and

Erosion and sediment control measures, including Erosion and sediment control measures, including structural and vegetation measures. structural and vegetation measures.

If the disturbed area is 5 acres or greater, a If the disturbed area is 5 acres or greater, a complete plan must be prepared and certified complete plan must be prepared and certified

by a Registered Professional Engineer.by a Registered Professional Engineer.

Soil Loss by ErosionSoil Loss by Erosion

City of Little Rock requires that soil loss be limited City of Little Rock requires that soil loss be limited to less than 5 tons / acre / yearto less than 5 tons / acre / year

The City has adopted the Universal Soil Loss The City has adopted the Universal Soil Loss EquationEquation

A = R K L S C P A = R K L S C P

A = soil loss potential in tons per acre per year A = soil loss potential in tons per acre per year

R = rainfall and runoff factorR = rainfall and runoff factor

K = soil erodibility factorK = soil erodibility factor

L = slope length factorL = slope length factor

S = slope steepness factorS = slope steepness factor

C = cover and management factorC = cover and management factor

P = practice factorP = practice factor

environmental regulations primer and case studies presented to: university of arkansas at little...

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water pollution sources

clean water actenacted

set standards

individual water bodies

flowing bodies of water

body of water research

industrial sources

safe drinking water