Monday, February 1, 2010

Electric Generation Facilities - Proposed ADEQ Requirements

The Arizona Department of Environmental Quality (ADEQ) recently released an updated draft of its proposed multisector industrial stormwater discharge general permit, known officially as the AZPDES Multi-Sector General Permit, or MSGP 2010. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in 2005.

Review a summary of the ADEQ Industrial Stormwater Permit

The proposed permit details requirements for 30 different industrial sectors. The requirements described below are proposed for the Steam Electric Generating Facilities (Sector O). Sector O covers three primary types of facilities, 1) steam electric power generation using coal, natural gas, oil, nuclear energy, etc., to produce a steam source; 3) dual fuel co-generation facilities; and 3) alternative fuel generating facilities used to produce steam.

These requirements are in addition to permit requirements that apply to all sectors.

Good Housekeeping Practices:
The SWPPP must describe and implement procedures to reduce fugitive emissions and control the tracking of coal dust. Sites must implement effective controls to minimize contamination of precipitation or surface runoff from fuel oil and chemical and other material handling areas.

Inspections must include:
a) coal handling areas,
b) delivery vehicles,
c) Fuel unloading areas,
d) areas adjacent to disposal ponds and landfills.

Monthly inspections must include all residue-hauling (i.e. ash) vehicles for proper covering over the load, adequate gate sealing, and overall integrity of the container body. Dischargers must repair, as soon as practicable, vehicles without load covering or adequate gate sealing, or with leaking containers or beds.

Preventative Maintenance:
The SWPPP must describe and implement measures that prevent or minimize stormwater from contacting fugitive dust emissions from coal handling areas and to prevent or minimize contamination of stormwater runoff from delivery vehicles carrying significant materials arriving at the facility. The SWPP must have procedures ensuring overall integrity of the body or container and procedures to deal with leakage or spillage from vehicles or containers.

The SWPPP must also describe and implement measures that prevent or minimize contamination of surface runoff from oil-bearing equipment in switchyard areas and to retard flows and limit the spread of spills from oil-bearing equipment in switchyards, or collecting runoff in perimeter ditches from these areas.

Spills and Leaks:
The SWPPP must describe and implement measures to reduce the potential for an oil or chemical spill, or reference an SPCC plan, and to visually inspect the structural integrity of all above-ground tanks, pipelines, pumps, and related equipment, and conduct any necessary repairs immediately.

Management of Runoff:
The SWPPP must describe and implement measures that prevent or minimize contamination of surface runoff from areas adjacent to disposal ponds or landfills, and must include procedures to reduce ash residue that may be tracked on to access roads traveled by residue handling vehicles, and reduce ash residue on exit roads leading into and out of residue handling areas.

SWPPP Contents:
The SWPPP must identify:
1) scrap yards, and general refuse areas;
2) short- and long-term storage of construction materials, paint equipment, oils, fuels, used and unused solvents, cleaning materials, paint, water treatment chemicals, fertilizer, and pesticides);
3) landfills and construction sites; and
4) stockpile areas (e.g., coal or limestone piles).

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values are:

All Electric Generating Facilities:
Iron 1.0 mg/L

The permit also has EFFLUENT LIMITS for pH and TSS for discharges from coal piles

[What is the difference between a “bench mark” and a permit or effluent limit?]

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
Caltha LLP Website

No comments: