Construction Site TPDES Inspector Workshop. Erik Hobson EPSIII/Resource Protection and Compliance

Transcription

1 Construction Site TPDES Inspector Workshop Erik Hobson EPSIII/Resource Protection and Compliance

2 Page 1 Topics Changes to TXR Inspections Edwards Aquifer Program

3 Changes to the Permit Page 2 Revisions to the application fee & the annual fee $325 for paper NOIs - 7 days from the postmark $225 for electronic NOIs - Immediate coverage after confirmation of receipt No Annual billing

4 Page 3 Changes to the Permit Revisions to the definition of Operator primary operators secondary operators

5 Page 4 Changes to the Permit Concrete truck wash out water from off-site production facilities. allowed on-site where suitable controls have been established minimize wash outs during storm events discharge of wash outs shall not cause or contribute to groundwater contamination wash out areas must be identified on SWP3 Map

6 Page 5 epermits State of Texas Environmental Electronic Reporting System (STEERS) Must sign up with STEERS

7 Page 6 SWPPP The Storm Water Pollution Prevention Plan (SWPPP) is a working, dynamic document. The SWPPP describes to you: What to do How to do it When to do it

8 SWPPP Definitions Page 7 TPDES Construction General Permit TXR Common Plan of Development Final Stabilization Municipal Separate Storm Sewer System (MS4) Permit Coverage (NOI, CSN size) Notice of Termination * Operator * Primary Secondary Temporary Stabilization Transfer of Operational Control *

9 SWPPP SWPPP must contain information that meets the requirements of the TPDES Construction General Permit TXR150000: Page 8 Site Description Erosion and Sedimentation Controls Stabilization Practices Structural Control Practices Permanent Storm Water Controls Other Controls

10 Page 9 SWPPP SWPPP must contain information that meets the requirements of the TPDES Construction General Permit TXR150000: Approved State and Local Plans Maintenance INSPECTION OF CONTROLS Non-Storm Water Discharges

11 Page 10 SWPPP Reporting Inspections must be conducted: At least once every fourteen (14) calendar days AND within twenty four (24) hours of the end of a storm event of 0.5 inches or greater. OR At least once every seven (7) calendar days, on a specifically defined day, regardless of whether or not there has been a rainfall event since the previous inspection.

12 Page 11 SWPPP Reporting Inspection reports must: Summarize the scope of the inspection Include the minimum required information Meet signatory requirements in the manner required by 30 TAC Action taken as a result of the inspection

13 Page 12 SWPPP Reporting Summarize the scope of the inspection: Name of the inspector Qualification of the personnel making the inspection Date of the inspection Major observations

14 Page 13 SWPPP Reporting Major Observations: Areas of inspection Location of discharges Location of BMPs that require maintenance Location of BMPs that failed Location where additional BMPs are needed

15 SWPPP Inspection Report Page 14

16 SWPPP Reporting Page 15 General Information

17 Inspection Report Page 16

18 SWPPP Reporting Page 17 Area of Inspection

19 Inspection Report Page 18

20 SWPPP Reporting Page 19 Location of Discharges

21 Inspection Report Page 20

22 SWPPP Reporting Page 21 BMP Inspection

23 Inspection Report Page 22

24 Inspection Report Page 23

25 SWPPP Reporting Page 24 Additional BMPs

26 Inspection Report Page 25

27 SWPPP Reporting Page 26 Inspector Qualifications

28 Inspection Report Page 27 This section will be checked ONLY if the inspectors qualifications have been included with the SWPPP.

29 Inspector Qualifications Page 28 John Doe has worked with ABC General Contracting for 10 years and has installed and maintained storm water controls for 5 years. He has attended several storm water workshops and will be implementing the SWPPP for this project. He has read the SWPPP and is familiar with the TPDES Construction General Permit TXR and its requirements.

30 SWPPP Reporting Page 29 Compliance Certification

31 Inspection Report Page 30 This section will be checked ONLY if the site does not have any non-compliant issues. In other words, the site is completely compliant at the time of the inspection.

32 SWPPP Reporting Page 31 Inspector s Signature

33 Inspection Report Page 32 Inspectors that meet signatory requirements must sign the inspection report.

34 SWPPP Reporting If the inspector does not meet signatory requirements, the inspector can be delegated this authority through a letter of delegation. Page 33 The letter of delegation, signed by a company official that meets signatory authority, authorizes the inspector to sign the inspection reports.

35 SWPPP Reporting Page 34 Include the Letter of Delegation with the SWPPP

36 Page 35 Completed Inspection Report

37 Page 36 SAN ANTONIO ORDINANCE STORM WATER COMPLIANCE FOR CONSTRUCTION ACTIVITY

38 Page 37 Ordinance Purpose: To reduce pollutants introduced into the MS4 as required by the State Permit (TPDES Construction General Permit TXR150000)

39 Page 38 Ordinance SAWS designated as enforcement staff Directs use of BMPs on construction sites Requires SWPPPs to be available onsite for inspection No size limit on construction activity SAWS has authority to enforce within City Limits and 5,000 feet beyond Provides penalties

40 Page 39 Ordinance Field Correction Notice

41 Ordinance Field Correction Notice Page 40

42 Page 41 Ordinance Enforcement A violation may result in a Field Corrective Notice 1st 24 hour period to remove and remediate offending material or comply with compliance action 2nd 24 hour period to install or repair corrective BMPs or ensure action If no action is taken

43 Ordinance Enforcement Page 42 Stop Work Order Results when FCN corrections are not made in a timely manner ALL WORK STOPS

44 Page 43 Edwards Aquifer Primary source of drinking water for San Antonio and the surrounding region Serving approximately 1.7 million people Extends from Williamson County, north of Austin through Kinney County, west of San Antonio

45 Edwards Aquifer Page 44

46 Page 45 Edwards Aquifer Protection Program Regulates activities over the Recharge, Transition and Contributing Zone of the Edwards Aquifer

47 Page 46 What are Regulated Activities Construction & post construction most soil disturbing activity Installation of aboveground or underground storage tanks Any other activity that may pose a potential for contaminating the Edwards Aquifer and hydrologically connected surface streams

48 Edwards Plans Page 47 All plans are required to be developed in accordance with the Edwards Aquifer Protection Program rules and Guidance Documents Portions of the plans need to be signed and sealed by Professional Engineers and Geologists licensed by the State of Texas

49 Edwards Plans Page 48 Each operator covered by an Edwards Plan must maintain a copy of the approved plan and the approval letter for that plan on-site

50 Page 49 Geologic Features When found during construction, the TCEQ regional office must be notified SAWS notified Define BMPs for the protection of geologic features BMPs must be consistent with the Edwards Aquifer Technical Guidance Manual BMPS for geologic features need to be included during routine inspections of the site

51 Inspection Frequency Page 50 Every 7 days and after each ½ inch rain fall Daily inspections may be warranted when sensitive features are located on or adjacent to the site

52 Page 51 Rules & Guidance 30 Texas Administrative Code (TAC) Chapter 213 Regulatory Guidance Document 348 Complying with the Edwards Aquifer Rules; Technical Guidance on Best Management Practices

53 Page 52 Construction Site TPDES Inspector Workshop Erik Hobson EPSIII/Resource Protection and Compliance