L. PEYTON ADAMS
Madisonville Regional Office
KENTUCKY DIVISION OF WATER
What to expect with a General Stormwater Permit BMP
Monitoring for other facilities permits
- "Other Facilities" type general stormwater permits have a BMP requirement with monitoring.
- If you have a permit, read it, and comply with it.
- BMP: Best Management Practices
- GPP: Groundwater Protection Plan.
- SPCC: Spill Prevention, Control, and Countermeasure plan per 40 CFR Part 112.
Monitoring for other facility permits
- Flow can be by bucket and stopwatch, known surface area with rainfall data, etc.
- Chemical Oxygen Demand
- Oil and grease
- Total Suspended Solids
- Do pH twice a year by grab sample on site with a 15 minute holding time with a calibrated pH meter with calibration data recorded. Practice good QA/QC. Mailing a pH sample to a laboratory will take longer than 15 minutes and not meet 40 CFR Part 136 criteria.
Monitoring frequency and timing
- All samples must be per 40 CFR Part 136 criteria.
- Document all sampling with chain of custody records showing time, date, sampler, lab receipt date and time, and calibration data with preservation information.
- Always sample twice a year at minimum. Do not wait until the last minute to get both samples.
- Track with your laboratory to ensure both samples have been collected before you run out of the rainy season.
Records and Documentation
- Don't tell an inspector in December that its never rained at the right time to get two samples that year if you are in Kentucky with 44 inches of average annual rainfall and 42 inches of evaporation.
- Grab samples shall be taken after the first 30 minutes of discharge IF POSSIBLE.
- Samples shall be collected from a discharge from a storm event that is greater than 0.1 inches and at least 72 hours from the previously measurable storm event.
- DOW can require a greater sampling frequency.
Industrial activity and construction activity
- Keep records at least 6 years of all monitoring.
- BMP must be kept one year after coverage when permit ends.
- This can be extended by request of DOW.
- All discharges covered by a general other facilities permit shall be stormwater except for discharges from fire fighting, hydrant flushing, water line flushing, irrigation, or lawn watering, detergent free pavement washing free of spills, air conditioning condensate, natural springs, and natural groundwater sources.
Releases greater than reportable quantities
- A general stormwater permit for an other facility can only authorize storm water discharges from industrial activity that are mixed with storm water discharges from construction activity if the construction activity discharge is in compliance with a different KPDES permit.
- Report spills per 401 KAR 5:015 and 224:01-400 to 1-800-928-2380 by the most immediately available means.
- Minimize the presence of hazardous substances or oil per the BMP plan.
- Report if exceeding Reportable Quanties such as covered in 40 CFR Part 117 and 40 CFR Part 302.
Best Management Practices Part IV of other facilities KYR00 permits
- When two or more outfalls discharge substantially identical effluents, the permit holder may sample only one outfall and report those monitoring results for the substantially identical outfalls.
- For every outfall not monitored, an estimate of the size of the drainage area and determination of the runoff coefficient shall be made and recorded.
- Facilities must implement the BMP plan required by the permit.
- The BMP will be signed and kept on site.
- The plan must be made available to DOW when requested.
- When the BMP is written up as inadequate the permit holder shall modify the permit within 30 days of notification and shall submit a written certification that the requested changes have been made.
- The permit holder shall modify the BMP plan when there is a change in design, construction, operation or maintenance of the facility which has a significant effect on the potential for the discharge of pollutants to waters of the Commonwealth and shall implement the changes within 30 days.
- SPCC plans developed for 40 CFR Part 112 or under Section 311 of the Clean Water Act or other plans required by a KDPES permit may be incorporated by reference or actually incorporated into the BMP.
Any BMP shall include as a minimum Items A-F:
Potential Pollutant Sources
- A. Potential Pollutant Sources
- B. Site Map
- C. Spills and Leaks
- D. Stormwater control measures
- E. Comprehensive Compliance Evaluations
- F. Non-Stormwater Discharges
- The BMP shall include a clear description of all the potential sources which may reasonably be expected to add significant amounts of pollutants to stormwater discharges, or which may discharge pollutants during dry weather to storm sewers draining the facility.
- The BMP shall inventory all materials that are, or have been, handled, treated, stored, or disposed of in a manner to allow exposure to storm water and a summary of any existing discharge sampling data indicating the level of pollutants in storm water discharges from the facility.
Spills and Leaks
- The BMP plan shall include a site map showing each storm water outfall and its drainage area, any structural control measures and all surface water bodies.
- The site map should show fueling stations, vehicle and equipment maintenance and cleaning areas, loading and unloading areas, storage or disposal areas, liquid storage tanks, processing areas, and locations where materials are exposed to precipitation.
Stormwater Control Measures
- The BMP plan shall include a list of significant spills or leaks of toxic or hazardous materials that have occurred at the facility. The location of any major spill or leak shall be indicated on the site map.
- It is recommended that the site map show all sampling points, label them in the field, and use on the chain of custody the same label description.
- Good housekeeping
- Preventative Measures
- Spill Prevention and Response Procedures
- Employee Training Programs
- Non-Stormwater Certification
- Sediment and Erosion Control
- Management of Runoff
- Stormwater Control minimums include
- Good Housekeeping: A clean, orderly Facility shall be maintained.
Stormwater Controls Spill Response
- Preventative Maintenance: Stormwater Management Devices shall be properly maintained, such as cleaning catch basins and oil/water separators. Equipment and systems shall be inspected and tested as necessary to uncover conditions that could cause breakdowns or failures resulting in the discharge of pollutants to surface waters.
Stormwater Control: Inspections
- Spill Prevention and Response Procedures: Areas where potential spills could occur, and their discharge points, shall be identified. Clean up procedures and the necessary equipment shall be made available to the appropriate personnel.
- Report spills by the most readily available means to 1-800-928-2380 if an RQ is involved.
Stormwater control: Training
- Inspections: Qualified personnel shall inspect designated areas of the facility and equipment at the intervals specified in the BMP plan. Follow up procedures shall be used to ensure the appropriate actions are taken in response to the inspections. Records of inspections and follow up actions shall be maintained.
- A good BMP will catch a problem before a state inspection and have solutions in hand prior to that day.
- If it was not written down, it was not done. Documentation is critically important.
Stormwater Control: Certifications of Non-Stormwater
- Employee Training: Employee Training programs shall be held to inform personnel, at all levels of responsibility, of the components and goals of the BMP plan.
- Periodic training should address topics such as spill response, good housekeeping, and material management practices. Dates of employee training should be designated.
- During an inspection a roster of signatures with dates can document training held prior to the inspection.
Stormwater Control: Sediment
- Non-Stormwater Certification: A certification that all discharges have been tested or evaluated for the presence of non-stormwater flows shall be evaluated. The certification shall include a list of any potential significant sources of non-stormwater flows, the test or evaluation results, the evaluation criteria or testing method used, the date of the test or evaluation, and the outfalls that were observed during the test or evaluation.
Stormwater Control: Management of RUNOFF
- Sediment and Erosion Control: Areas that have a high potential for soil erosion due to topography, local activities, or other factors shall be identified. Measures that will limit erosion shall be implemented.
- If the Total Suspended Solids testing shows elevated numbers that can impact streams in violation of 401 KAR 5:031 document what was done to fix the source and control the erosion.
- If the stream is dying the BMP is not working.
STORMWATER CONTROLS: Evaluations
- Management of runoff: A narrative consideration of the suitability of traditional stormwater management practices to divert, infiltrate, use, or otherwise manage stormwater runoff in a manner that reduces storm water discharges from the facility shall be included.
- This can include snow management.
Stormwater Controls: Non-stormwater discharges
- Comprehensive Compliance Evaluations: Qualified personnel shall conduct a facility compliance evaluation at least once a year. (At least once every three years for remote inactive mining sites.)
- Material handling areas and other potential sources of pollution identified in the BMP plan shall be visually inspected. If there is a BMP control, it shall be inspected to ensure its working. Equipment needed to implement controls shall be inspected.
- A report summarizing the scope of the inspection, personnel making the inspection, the date, major observations, and actions taken shall be made and retained as part of the BMP for at least three years after the inspection.
Discharge Monitoring Report
- Non-stormwater discharges: The BMP plan shall identify and ensure the implementation of appropriate pollution prevention measures for any non-stormwater component of a discharge except for flows from fire fighting activities.
- Salt piles that generate a storm water discharge to Waters of the Commonwealth shall be enclosed or covered while not in use to prevent exposure to precipitation.
Notice of Intent Forms
- The KPDES General Stormwater Permit has a DMR included with the permit that is to be filled out. It can be found after the BMP section and before the Fact Sheet. It will summarize the two sampling events for the year's data.
- Fill it out correctly and completely.
- It does not have to be mailed to DOW, but it must be available to the inspector.
Notice of Termination (NOT)
- NOI must be submitted to the DOW KPDES Branch 48 hours before industrial activity begins.
- Unless notified by DOW to the contrary, it takes effect 48 hours after the NOI is postmarked, even if the permittee has not yet received a copy of the general permit from the Division of Water.
- A copy can be downloaded off the Internet at the KPDES WebPage.
Change of Ownership:
- When all stormwater discharges associated with industrial activity are eliminated the owner or operator MUST submit a signed copy of a Notice of Termination (NOT) form in order to
- END coverage under this general stormwater permit and nullify its requirements.
- NOT's are filed with the DOW KPDES Branch.
- When the owner or operator of a facility covered by this permit changes, the new owner or operator must submit a notice 48 hours before the change in order to transfer coverage under this general permit. Changes of ownership notices are to be sent to the DOW KPDES Branch.
Groundwater Protection Plans
- Facilities which discharge storm water associated with industrial activity to a municipal separate storm sewer system (MS4) shall submit a signed copy of the NOI to the operator of the MS4 48 hours before industrial activity begins.
Division of Water WebPages
- If a facility meets criteria in 401 KAR 5:037, then a groundwater protection plan may also be required.
- If so, follow the outline provided by the Groundwater Branch,” How to Write a Groundwater Protection Plan” in format.
- The Groundwater Branch number is 502-564-3410 and the plan outline can be downloaded from their WebPage.
Who has to have a storm water permit from the Division of Water
- Facilities subject to Stormwater limitations, new source performance standards, or toxic pollutants.
- Certain SIC code industries listed on the KPDES web page
- RCRA treatment, storage, & disposal sites
- Landfills,landfarms, and open dumps with industrial waste.
- Scrap yards, battery reclaimers, junkyards
- Construction sites with more than one acre disturbance.
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