Industrial Stormwater Management

Pika has provided stormwater compliance services to a variety of operations, including municipal transit maintenance facilities, refrigerated glass door manufacturers, fertilizer plants and metal foundries. Our stormwater management programs begin with a compliance audit to determine whether a storm water program is necessary. Following that determination, a Storm Water Pollution Plan (SWPPP) and Monitoring implementation Plan (MIP) are developed for the facility. A review of activities that could potentially affect storm water quality is conducted and potential pollutants associated with those activities identified. Best Management Practices (BMPs) are then developed and implemented to minimize sources of pollutants, prevent run-on and eliminate comingling of non-contaminated and potentially contaminated run-off. The MIP identifies monitoring locations, constituents of concern, specific sampling techniques, and analytical methods specific to the facility. Checklists for sampling and analysis, observations of non-storm water and storm water discharges are customized so that the BMPs for each discharge point could be reviewed during inspections. A Sampling and Analysis checklist is also developed to ensure consistency and conformance among sampling events with IGP requirements.

Inspections of the facility are performed on an annual basis in June of each year to determine whether any needed changes to the programs document, as well as to assemble the appropriate documentation for the annual reports. If benchmark exceedances become an issue, additional pre-wet season inspections are conducted and corrective action plans implemented in an effort to continuous enhance BMP effectiveness and improve water quality. In response to local RWQCB inquiries, additional evaluation of offsite contributions to onsite pollutant concentrations can be evaluated, including aerial deposition from nearby industrial/commercial activities and contribution from natural sources in soil and drinking water.

When the new IGP was recently issued for public review and comment, the requirements applicable to each facility were summarized in a matrix and presented to our clients so they fully understand the implications of the changes and could budget additional manpower and capital expenditures to meet future compliance requirements. Subsequent activities have included revising the SWPPP and the Monitoring Implementation Plan (MIP), as well as accompanying checklists, to reflect the changing IGP requirements and evaluating existing BMPs in terms of the minimum BMPs outlined in the EPA 2008 MSGP. Detailed protocols for Exceedance Response Actions (ERAs), as well as recommendations for improvement in program elements that would avoid triggering ERAs, are also being developed. Finally, plans for additional sampling to understand the contribution of offsite sources to onsite pollutant concentrations will be implemented as part of future Qualifying Storm Events (QSEs).