Welcome to the Frog Environmental New IGP BMP

Welcome to the Frog Environmental New IGP BMP Requirements 2015 Seminar 800 E. Ocean Blvd, Suite 105 | Long Beach, CA 90802 | (310) 241 – 0866 www. Frogenv. com 1

New IGP Monthly Visual Observation And BMP Requirements 2015 Seminar Ø Brief overview of New Permit requirements Ø Numeric Action Limits (NAL’s) Ø Monthly Visual Observations A. Observing Industrial Areas B. BMP Observations C. Identifying Authorized Non-Storm Water Discharges Ø BMP Requirements A. Good Housekeeping B. Preventative Maintenance C. Spill and Leak Prevention and Response D. Material Handling and Waste Management E. Erosion Control F. Employee Training Program Ø Sampling Event Visual Observations Ø Advanced BMP’s Ø Question and Answer 2

Overview of New Permit Requirements for Storm Water SMARTS • Mandatory recertification of NOI • You must have an updated SWPPP on SMARTS at all times • Facility site map must be on SMARTS • All sample results must be uploaded to SMARTS within 30 days of receiving results • Annual Reports must be on SMARTS SWPPP • SWPPP Requires: Site Map, Industrial Materials List, Description and Assessment of Potential Pollutant Sources, Description of Minimum and Advanced BMPs, and Monitoring Implementation Plan (MIP) • Any changes to operations must be documented in SWPPP and uploaded to SMARTS • SWPPP Team 3

Overview of New Permit Requirements for Storm Water Mandatory BMPs Monitoring • Qualifying Storm Event (QSE): Produces discharge in at least one drainage area, preceded by 48 hours with no discharge • Sample 4 time per storm water year, 2 within the first half of the year (July – Dec. 31) and 2 within the second half of the year (Jan. - June 30) • Samples from each discharge location shall be collected from within 4 hours of: • The start of discharge • The start of facility operating hours if the QSE occurs in the previous 12 hours • • • Minimum BMPs are now REQUIRED Good Housekeeping Preventative Maintenance Spill and Leak Prevention Response Material Handling and Waste Management • Erosion Control • Employee Training Program • Advanced BMPs will be necessary if you have pollutants exceeding Numeric Action Levels (NALs) 4

Overview of New Permit Requirements for Storm Water Baseline Status Level 1 Status Level 2 Status • Every industrial facility has the opportunity to start with a clean slate as of July 1 st, 2015. • Once you go to Level 1 or Level 2 it is difficult to return to baseline status. • By fully utilizing BMPs now, you can avoid the additional costs and requirements of Level 1 or Level 2 Status. • If a facility has an exceedance (Annual or Instantaneous) in 201516, it will result in a status change to Level 1 for any given parameter in 2016 -17. • Level 1 requirements: QISP oversight of activities, QISP prepared Exceedance Response Action (ERA) Report completed by Oct. 1 and uploaded to SMARTS by Jan. 1 following status change, and additional BMPs to address exceedances. • If an NAL exceedance for the same parameter takes place in the subsequent reporting year (2016 -17), a facility will change to Level 2 Status the following year (2017 -18). • Level 2 requirements: QISP prepared Level 2 ERA Action Plan and Level 2 ERA Technical Report submitted via SMARTS by Jan. 1 following status change, additional BMPs to address exceedances. 5

Numeric Action Levels Parameter p. H Suspended Solids (TSS) Oil & Grease Zinc Copper Cyanide Lead Chemical Oxygen Demand Aluminum Iron Nitrate + Nitrite Nitrogen Total Phosphorus Ammonia Magnesium Arsenic Cadmium Nickel Mercury Selenium Silver Biochemical Oxygen Demand Old Benchmark Values in mg/L Less than 6. 0 Greater than 9. 0 100 15 0. 117 0. 0636 0. 0816 120 0. 75 1. 0 0. 68 2. 0 19. 0 0. 0636 0. 16854 0. 0159 1. 417 0. 0024 0. 2385 0. 0318 30 New Annual NAL in mg/L N/A 100 15 0. 26 0. 0332 0. 022 0. 262 120 0. 75 1. 0 0. 68 2. 0 2. 14 0. 064 0. 15 0. 0053 1. 02 0. 0014 0. 005 0. 0183 30 Instantaneous Maximum Less than 6. 0 Greater than 9. 0 400 25 6

Monthly Visual Observations § Discharger must maintain records of all visual observations. Records shall include: - Name of person that conducted the observations - Date / Time - Locations observed - Presence and probable source of any observed pollutants - Any response actions and/or additional SWPPP revisions necessary § Must be performed once per calendar month during daylight hours of scheduled facility operating hours, and on days with NO precipitation. § Previously , monthly observations were required during rain events and only for October – May. § These records do not need to be submitted to the state, however they must be kept on record at the facility. The Annual Report will require an explanation for any non-compliance of requirements within the reporting year, such as an uncompleted observation. § Inspect Best Management Practices (BMPs) 7

Monthly Visual Observations: All industrial areas shall be visually observed for the following: Outdoor industrial equipment and storage areas, outdoor industrial activities, BMPs, and all other potential sources of industrial pollutants to identify: § That BMPs are properly implemented § Any BMPs which need maintenance to operate effectively are well maintained § Any BMPs that have failed, or that could fail to operate as intended § Any additional BMPs needed based on the findings of the Monthly Visual Observations Note: Should any pollutants be observed, it will be traced back to the source, and the problem area must be addressed. Any new Best Management Practices (BMPs) must be updated in your SWPPP and resubmitted to SMARTS. 8

Monthly Visual Observations: Mechanics of BMP Observation § Best Management Practices (BMPs) are the scheduling of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants. § BMPs also include treatment requirements, operating procedures, and practices to control site runoff, spillage or leaks, sludge or waste disposal, and drainage from raw material storage. § Under the new IGP industrial facilities are required to implement and maintain all “minimum” BMPs to the extent feasible and any applicable “advanced” BMPs. § Identify the industrial activities areas because these will be the areas of your facility you will be focusing on when you conduct the BMP inspection. You should be able to find them in your SWPPP (potential pollutant diagram and body). 9

Monthly Visual Observations: Authorized & Unauthorized Non-Storm Water Discharges (NSWDs) Each drainage area shall be visually observed for the following: The presence or indications of prior, current, or potential Unauthorized Non-Storm Water Discharges (NSWDs) and their sources, and Authorized Non-Storm Water Discharges (NSWDs), sources and BMPs to ensure compliance. Examples of Authorized NSWDs: § § Fire-hydrant and fire prevention or response system flushing ; § Drinking Fountain water and atmospheric condensate including refrigeration, air conditioning, and compressor condensate; § § Potable water sources including potable water related to the operation, maintenance or testing of potable water systems; Irrigation drainage and landscape watering provided all pesticides, herbicides and fertilizers have been applied in accordance with manufacturers label; Uncontaminated natural springs, groundwater, foundation drainage, footing drainage; Seawater infiltration where the seawater is discharged back into the source; Incidental wind blown mist from cooling towers that collects on rooftops or adjacent portions of your facility but not intentional discharges from the cooling tower. 10

Monthly Visual Observations: Authorized & Unauthorized Non-Storm Water Discharges (NSWDs) Examples of Unauthorized NSWDs: § § § Rinse / wash water; Process water; Basically any discharge not listed as Authorized. During your observation be sure to: § § Note what you observe at the time you are actually performing the observation. § If non-storm water is going into a drain that is not a discharge point, then it may not discharge and may not have to be recorded (only actual discharges must be recorded). However, even if it is not actually discharging, if it is water from an unauthorized source, it must be addressed/eliminated. Even if it does not discharge, it has the potential to discharge during a rain event. § Be clear on what storm drains/drain inlets are actually discharge points. Some may connect via underground conveyance to the actual discharge location. If a site does have authorized NSWDs, the water cannot travel through industrial areas of your site and collect/carry pollutants with it as it discharges. 11

Required Good Housekeeping BMPs: § § § § § Good Housekeeping BMPs apply in a general sense to a facility and all of its Industrial Activities. When you conduct the Monthly BMP Observation, you will note: Any pollutants observed / deficiencies, which industrial activity area they are occurring at, and what will be done to correct it. Any debris, waste, spills, tracked materials or leaked materials must be cleaned and disposed of properly. Minimize or prevent material tracking. Cover stored industrial materials and waste. Contain all stored non-solid industrial materials or wastes. Minimize dust generated from industrial activities. Prevent discharge from rinse/wash waters. Prevent non-industrial area discharges from contact with industrial areas of the facility (e. g. storm water flows from employee parking area). Prevent authorized NSWDs from non-industrial areas from contact with industrial areas of the facility. 12

Required Preventative Maintenance BMPs: § Preventative Maintenance requires regular inspection, testing, maintaining and repair of all industrial equipment to prevent leaks, spills and releases of pollutants that may be exposed to storm water discharge. § Identification or all equipment and systems that may spill or leak. § Observation of the equipment and systems to detect leaks, or identify conditions that may result in leaks. § Establish an equipment maintenance schedule to prevent any future leaks. § Establish procedures for prompt maintenance and repair of equipment to correct any spills or leaks. 13

Required Spill and Leak Prevention and Response BMPs: § Requires Dischargers to minimize the potential for leaks, spills and other releases that may be exposed to storm water. § Develop a set of procedures and controls to minimize spills or leaks. § Develop procedures to minimize and prevent the discharge of industrial materials generated through spills or leaks to the storm water conveyance system. § Identify and describe the equipment needed for spill response and where it will be located on the facility. § Identify and train appropriate spill and leak response personnel. § Spilled or leaked industrial materials should be cleaned promptly and disposed of properly. 14

Required Material Handling and Waste Management BMPs: § § Requires Dischargers to ensure waste, garbage, and floatable debris are not discharged. § § Contain all industrial materials that can be readily dispersed by wind or contact storm water. § § § Minimize handling of industrial materials or wastes that can be readily transported by contact with storm water. Cover all industrial waste disposal containers and industrial material storage containers when not in use. Divert run-on and storm water generated within the facility away from stock piled materials. Clean and manage spills of wastes or industrial materials in accordance with spill response procedures. Observe and clean any outdoor material or waste handling equipment and containers that may be contaminated by contact with industrial materials. 15

Required Erosion Control BMPs: § Requires structural and non-structural control measures to stabilize exposed areas and contain runoff. § Implementation of effective wind erosion controls. § Stabilization of erodible areas prior to forecasted storm event. § Implement perimeter controls and stabilization of site entrance and exits to prevent material tracking off-site. § Diversion of run-on and storm water generated within facility away from erodible materials. 16

Required Employee Training Program BMPs: § Ensure all relevant team members are trained to implement the requirements of the Permit. If a discharger enters Level 1 Status, all relevant team members must be trained by a Qualified Industrial Storm Water Practitioner (QISP). § Prepare or acquire appropriate training materials (e. g. Monitoring Plan/ Binder provided by Frog). § Prepare a training schedule (e. g. Annually at the beginning of the storm water year and at the time of hire). § Maintain documentation of completed training. 17

BMP Observation Example: Oil Spots on Site § Should clean it up immediately. § Is the oil spot coming from equipment that is not properly maintained? (i. e. Preventative Maintenance BMPs) § Is the oil spot not cleaned up because the site does not have the proper clean up tools and procedures in place? (i. e. Spill and Leak Prevention and Response BMPs) § Is the oil spot being caused because the containers with oil are not being stored and handled properly? (i. e. Material Handling and Waste Management BMPs) 18

BMP Observation Example: Grinding of Metal § This would fall under Good Housekeeping and Material Handling and Waste Management. § Do the grinders have dust bags attached to capture pollutants? § Is it being performed indoors or within and enclosed area? If not, is it at least in a covered area? § Is the covered area equipped with curtains or other method to contain pollutants? § Is area being swept immediately after grinding takes place? § Is the sweeping effective – Does the ground have any breaches, cracks, residue, etc. that may require an industrial vaccuum? § Does storm water flow through this area when it rains? § Do NSWDs flow through this area? 19

Sample Event Visual Observations § § § Are required to be conducted at the same time sampling occurs at a discharge location. At each discharge point where a sample is obtained, the characteristics of storm water associated with industrial activity will be observed. Know where your sample locations are located; familiarize yourself with the monitoring diagram and SWPPP. When conducting Sampling Event Visual Observations, the following shall be accounted for: 1. The Discharger shall visually observe and record the presence or absence of floating and suspended material, oil and grease, discolorations, turbidity, odors, trash/debris, and sources of any discharged pollutants. 2. In the even that a discharge location is not visually observed during the sampling event, the Discharger shall record which discharge locations were not observed during sampling or that there was no discharge from the discharge location. 3. The Discharger shall ensure that visual observations of storm water discharged from containment sources (e. g. secondary containment or storage ponds) are conducted at the time that the discharge is sampled. 20

Sample Event Visual Observations (Continued) 4. Any Discharger employing volume-based or flow-based treatment BMP’s shall sample any bypass that occurs while the visual observations and sampling of storm water discharges are conducted. 5. Should any pollutant(s) be observed, it will be traced back to the source, and the problem area will be addressed. Any new Best Management Practices will be documented in our SWPPP. 6. Any explanation for uncompleted Sampling Event Visual Observations must be provided in the Annual Report. 21

Advanced BMPs § Not generally required unless a facility cannot control pollutants with the minimum BMPs, however, many sites already have some type of Advanced BMP in place. § Based on the assessment of potential pollutant sources, Dischargers are required to identify in the SWPPP any areas of the facility where minimum BMPs will not adequately reduce or prevent pollutants in storm water discharges. § Advanced BMPs will be required if a site has pollutant exceedances and enters Level 1 and Level 2 Status. § Advanced BMPs include: 1. Exposure Minimization BMPs – Additional covered areas 2. Storm water Containment and Discharge Reduction BMPs – Diversion, Infiltration, Retainment, Reuse 3. Treatment Control BMPs – Treatment Systems 4. Other Advanced BMPs 22

Question & Answer Period: THANK YOU FOR ATTENDING OUR SEMINAR. WE LOOK FORWARD TO ANSWERING YOUR QUESTIONS. 23