Transcript Regulatory Compliance Group

REGULATORY
COMPLIANCE GROUP
November 2011
Regulatory Compliance Group
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Who we are
What we do
What we can do for you
What we need from you
Who We Are
Robin Halperin
Manager of Regulatory
Compliance
Beth Toot-Levy
Senior Environmental
Specialist
Sarah Rehner
Environmental Specialist
(Back-up RSO)
Vacant
Environmental Specialist
(RSO)
What we do
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Ensure the District’s compliance with all
environmental rules and regulations
 NPDES
Permits
 Air Permits
 Wetland Permits
 HW/UW Rules
 Asbestos & Lead
 Part 503 Rules (Biosolids)
 Current & Future Regulations
More about what we do
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Provide a consistent voice to regulatory agencies
Review and interpret rules, regulations and permits
to understand the District’s obligations for
compliance
Provide assistance/consultation to management,
engineering, operations, analytical services, WQIS,
etc. to achieve and maintain compliance
More specifically…
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Prepare and review permit applications
Monitor NPDES permit compliance
Review draft rules and regulations
Prepare the District’s comments on draft rules and permits
Assist in letter and report writing
Develop environmental policies and programs
Assess environmental conditions and make recommendations
Determine proper disposal methods
Manage the District’s Radiation Protection Program
Manage the District’s Industrial SWPPPs
Our Goals
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Achieve and maintain environmental compliance
100% of the time.
NACWA Gold & Platinum Awards
Anticipate new rules and permit requirements to
stay ahead of the game
Provide the necessary support to you our
“customers”
Ensure all District activities are covered by the
necessary permits
Robin Halperin
Manager of Regulatory Compliance
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Areas of Focus:
 Wetlands
 Delineations
 401/404
Permits
 Wetland Mitigation Projects
 Radiation
 License
Protection Program Management
compliance
 Reducing license footprint & simplifying program
 Standard contract language
Robin Halperin
 NPDES
Permits
 Construction
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Affecting plant operations
 Incident
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Projects
Reporting
Power Failure, Flooding, etc.
 Permit
Renewals
 ODNR
 Shore
 RCAT
Structure Permits
Chair
Robin Halperin
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Call me:
 With
questions about Wetlands, permits and
compliance/mitigation activities
 If you need to assess a property for wetlands and/or
environmental contamination (Phase I and Phase II)
 With questions about implementation of the Radiation
Program
 If you don’t know who else to call about a regulatory
compliance problem/question
Beth Toot-Levy
Senior Environmental Specialist
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NPDES Permits
 Permit
renewals
 Permit compliance assistance
 Water quality issues
 Concerns with meeting permit limits
 Trends in NPDES permitting
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Stormwater Permits (Plants)
 SWPPP
Maintenance
 Annual inspections
 New stormwater permits are on the horizon
Beth Toot-Levy
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Biosolids Management
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Part 503 Reports
Beneficial Reuse of Ash
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Pilot Project underway at Southerly WWTP
 Working
with Emerald Environmental and Ohio EPA to
beneficially reuse Southerly ash.
 Currently conducting Field Test Plots for Blended Topsoil
 Other options include bricks, concrete, flowable fill, etc.
 Westerly
ash next?
Beth Toot-Levy
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Call me:
 If
it went down the drain and didn’t fall from the sky
CALL ME
 If it almost went down the drain and didn’t fall from the
sky CALL ME
 To evaluate water quality trends and potential NPDES
compliance issues
 Plant/Facility stormwater management questions
 Emerging pollutant questions
 Nutrient issues
 A request is received for residuals info
Sarah Rehner
Environmental Specialist
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Air Emissions
 Permits
 Permit
to Install
 Permit to Operate
 Permit by Rule
 Reporting
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Requirements
V Reports - Southerly
Synthetic Minor Report - Westerly
Non Title V Reports - Easterly (once every two years)
Quarterly Deviation Reports
Miscellaneous Reports
Sarah Rehner
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New SSI MACT Standards
Compliance Required in March 2016
 Determining Impacts on Southerly and Westerly
 Working with NACWA on Petition for Reconsideration
and Legal Challenges
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Radiation Protection Program
 RSO-In-training
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USACE Nationwide Permits
 Developing
flowchart and checklists
Sarah Rehner
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Call me when:
 Considering
new air emissions units to be installed (e.g.,
boilers, emergency generators, etc.)
 A deviation of an air permit occurs (e.g., opacity,
scrubber water flow rates, scrubber pressure drops, etc.)
 A request is received for air emissions data
 Air emissions related visits from U.S. EPA,
Ohio EPA or Cleveland Division of Air Quality
 A project may impacts wetlands or waters of the state
 You have Red Tag or Permit to Dig Questions
Vacant
Environmental Specialist
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Waste Management
 Hazardous
 Obsolete
 Universal
 Light
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Waste
chemicals…
Waste
Bulbs, Batteries, etc…
Radiation Protection Program
 RSO-In-Training
Environmental Specialist
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Hazardous Substance Permits
Asbestos
Lead
Call me:
 To
schedule hazardous and universal waste pick-ups
 To determine how a waste should be disposed of
 Questions about the Radiation Program
Current Engineering-Related Projects
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401/404 Permit for Nine Mile Creek
Radiation Control Plan Revisions
NPDES Plant & CSO Permits Renewal
Beneficial Reuse of Ash
Kerriush Park – Nationwide Permit
CSO 036 Contaminated Debris Disposal
SWPPP Annual Inspections
E. 55th Floatables Control
Doan Brook Stream Enhancement Project – Section 106
Environmental Compliance Sharepoint Site
West Creek Confluence Project
What we need from you
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Keep us informed of EPA communications
 Phone
Calls
 Letters
 Site
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Visits
Opportunity to be involved in projects early on the
planning/design phase to determine environmental
compliance needs
Opportunity to participate in ALL EPA site visits
(announced and unannounced)
More…
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Opportunity to review and provide comments on
letters/reports/documents BEFORE they are sent to
a Regulatory Agency
To be informed of potential or actual permit or
other regulatory issues
If you have a question…just ask!
How to contact us
Robin Halperin (Wetlands, CSOs, NPDES, Radiation, RCAT)
Office: 881-6600 x6465 Cell: 214-5006
Beth Toot-Levy (NPDES, Stormwater, Residuals)
Office: 641-6000 x2236 Cell: 216-214-8850
Sarah Rehner (Air Permits, Nationwide Permits, Radiation)
Office: 881-6600 x6405
Vacant (Hazardous Waste, Universal Waste, Radiation)
Office: 881-6600 x