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Nine Minimum Controls (NMC)
NMC No. 3 -
Review and Modification of Pretreatment Requirements to Ensure that CSO Impacts
are Minimized
The
objective of NMC
No. 3 is to control and/or minimize the impact of discharges into the CSS from
commercial and industrial users of the system during wet weather events.
This objective can be met by modifying inspection, reporting, and oversight
procedures for these entities. WWMA is not currently required to implement
and maintain a formal industrial pretreatment program. The Authority does,
however, have a set of industrial user regulations that are a part of the
existing intermunicipal agreement between the Authority and its member
communities.
PaDEP
requires documentation that a diligent effort has been made to address these CSO
impacts. Documentation may include, but not be limited to:
-
An
inventory of non-domestic dischargers.
-
Descriptions
of modifications made to the pretreatment program and/or regulations.
-
A
schedule for implementing modifications, including amending sewer use and
ordinances.
WWMA RESPONSE: As
previously reported in the "SYSTEM INVENTORY AND CHARACTERIZATION
REPORT", there are no significant industrial users in the WWMA service
area. The following list represents the ten largest non-industrial users
tributary to the WWMA system:
- VALLEY LANDFILL
- CONLEY'S COURT MOTEL
- DENNY'S RESTAURANT
- L & B LAUNDRY
- PENN-TRAFFORD HIGH
SCHOOL
- STONEBROOK MANOR
- BALDOCK NURSING HOME
- PBM, INC.
- NORWIN ATHLETIC CLUB
- TEDDY'S RESTAURANT
As stated in the
general objective for NMC No. 3, the Authority's goal is to control and/or
minimize the impact of discharges into the CSS from commercial and industrial
users of the system during wet-weather events. A copy of the rules and
regulations are presented at the end of this document for additional review.
In addition to current
intermunicipal regulations and agreements in place between the Authority and its
member communities, the Authority shall make an effort to develop and distribute
guidelines for "temporary" non-domestic dischargers into the WWMA
service system, that is, guidelines intended for contractors associated with
residential and commercial short-term renovation and new construction projects.
The following
information shall be provided to contractors to be used towards the goal of
preventing pollution of surface water run-off from construction projects by
keeping pollution out of storm drains. The intent is to reduce the
exposure and discharge of materials and wastes to stormwater, and by reducing
erosion and sedimentation. The manner of information distribution shall be
determined by the Authority.
-
Defining areas on
project sites that are suitable for material delivery, storage, and waste
collection shall include areas that are near construction entrances and far
from catch basins, gutters, swales, and drainage channels.
- Granular material
shall be stored at least ten feet away from catch basins and curb
returns. Additionally, granular material shall also be kept clear of
gutters, swales, and drainage channels.
- Granular material
shall not be allowed to enter storm drains or creeks. Contractors
shall cover granular material with tarpaulin or plastic sheeting with
sandbags or other securing mechanisms during wet weather or if rain is
forecast within 24 hours.
- Contractor shall use
non-potable water for dust control on a daily basis or as directed by the
owner or client.
- Materials such as
aggregate base material, asphalt concrete, and Portland cement concrete
shall be recycled (to the maximum extent practicable) when required by
project specifications or construction drawings.
- Contractor shall reuse or recycle useful construction materials generated
during the project subject to approval by the owner or client.
- Contractor shall
collect and dispose of waste and debris material in an appropriate manner on
a daily basis or as directed by the owner or client.
- Contractor shall
inspect dumpsters for leaks and contact dumpster supplier to replace or
repair leaking dumpsters.
- Contractor shall not
discharge water on-site from cleaning dumpsters.
- Contractor shall
arrange for regular waste collection to avoid dumpster overflow.
- Contractor shall
label and store all hazardous construction materials and all hazardous
wastes in accordance with client/owners' specifications and applicable
federal, state, and county regulations.
- Contractor shall
abide by all secondary containment regulations, necessary to avoid potential
management of collected rainwater as a hazardous waste.
- Contractor shall
keep an up-to-date inventory, including MATERIAL SAFETY DATA SHEETS (MSDS),
of all hazardous construction materials and all hazardous wastes stored
on-site in the event of a hazardous materials incident.
- During wet weather
or when rain is forecast within 24 hours, contractor may be prohibited from
applying chemicals in outside areas.
- Contractor shall
follow manufacturer's instructions regarding usage, use of protective
equipment, ventilation, flammability, and mixing of hazardous construction
materials. Over-application of a hazardous product shall also
constitute a violation of product usage.
- Contractor shall
arrange for regular hazardous waste collection to comply with time limits on
the storage of hazardous wastes.
- Contractor shall
maintain a stockpile of readily-accessible on-site spill clean-up material.
- Contractor shall
immediately contain and prevent leaks and spills from entering drains with
appropriate clean-up and disposal of materials immediately following the
incident.
- Contractor shall not
wash any spilled material into streets, gutters and drains, or creeks.
- Contractor shall not
bury any spilled hazardous material.
- Contractor shall
immediately report any hazardous materials spills to the owner/client.
- Contractor shall not
perform vehicle or equipment cleaning on-site or in the street using soaps,
solvents, degreasers, steam cleaning or equivalent methods.
- Contractor is
allowed to perform vehicle or equipment cleaning, with water only, in areas
that will not allow rinse water to run off-site or into streets, gutters and
drains, or creeks.
- Contractor shall
inspect vehicles and equipment arriving on-site for leaking fluids and shall
promptly initiate any necessary repairs.
- Contractor shall
comply with federal, state, and county requirements for above-ground storage
tanks.
- Contractor shall
inform all employees and sub-contractors on water pollution prevention
methods contained in project specifications.
- Contractor shall
include appropriate subcontract provisions to ensure that pollution control
requirements are met.
- Contractor shall
post warning signs in areas treated with chemicals.
Additionally, the
Authority would like to note that as stated by the United States Environmental
Protection Agency (Office of Water Management):
...Any construction
activity, including grading, clearing, excavation, or other earth-moving process
may require an NPDES Storm Water Permit for construction under the NPDES Storm
Water Program.....
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