In our original blog article entitled “Florida NPDES Stormwater Requirements”, we provided an overview of these regulatory requirements. In this current article, we will provide more details on the monitoring itself. These monitoring requirements apply to stormwater runoff leaving your site. This may be a single outfall or more than one outfall. If there is no outfall, you may have to construct one to collect runoff to monitor.
What is stormwater monitoring? It is the evaluation of the water leaving your site as stormwater runoff. To perform this evaluation, a sample must be collected. The evaluation may either be done visually or analytically in a laboratory. Your permit may just require visual monitoring for all five years of your permit, or it may require that in years one, three, and five, plus analytical monitoring in years two and four. Note that Florida Department of Environmental Protection (FDEP, www.myflorida.com) uses calendar years, so that if your permit is issued anytime between January 1st and December 31st in a given year, that is counted as year one. Thus, year two of your permit will start January 1st of the next year, even though a full year (i.e., 365 days) has not passed.
Regardless of the type of monitoring, you must measure and keep a log of rainfall on site. This has to be done prior to the beginning of the quarter so you can identify the last qualifying rainfall event and it continues until you monitor a qualifying event in the current quarter. A qualifying rainfall event is greater than one-tenth of an inch (0.1 in). For monitoring, the event has to be preceded by no qualifying events within 72 hours. Measuring rainfall can either be done manually or automatically with a tipping rain gauge recording unit.
Visual monitoring is done by collecting a sample in a clean glass container (clear and at least sixteen ounces is best). The sample is then examined for clarity, sediment, oily sheens, other pollutants, and foam. All information should be recorded on a form in your Storm Water Pollution Prevention Plan (SWPPP). Included with the sample evaluation data are the Sampler’s name and signature, date, time, start and stop times of the runoff event, and location of the outfall sampled. This form must be kept in the SWPPP.
Analytical monitoring will be dictated by your permit. The pollutants or parameters to be analyzed in the laboratory will be identified. Additionally, the regulatory limits for each parameter will be shown. It is important that the analyses be done in a laboratory accredited by National Laboratory Environmental Accreditation Program, NELAP (www.nelac-institute.org) and be certified by the Florida Department of Health (www.floridahealth.gov). The same information concerning the visual sampling above is recorded and a Chain-of-Custody form is completed to accompany the samples to the laboratory. This information and the lab results are kept in the SWPP.
Samples for laboratory analysis must be handled properly to insure accurate results. The samples may need to be preserved or iced or both. If they are not delivered immediately to the laboratory, they must be held in a refrigerator at no more than forty degrees Fahrenheit where the temperature is recorded on a written log daily. Samples must be analyzed before their hold time expires.
The visual and analytical results must be evaluated. If there is a problem, you must determine the likely cause and take corrective action. This should be documented in your SWPPP and, for analytical results, on your Discharge Monitoring Report (DMR) filed with the FDEP by March 1st following the monitoring year.
So now you know details on Florida NPDES Stormwater Monitoring for industrial facilities. If you need any more information, Environmental Safety Consultants (www.escflorida.com) can assist. We have the credentials and experience to answer your questions and steer you in the right direction. We are a Florida-licensed Engineering business with over thirty-five years of stormwater experience. We are just a telephone call (800-226-1735) or an e-mail away here. Contact us today!
Industrial facilities included are manufacturers and those with Standard Industrial Classifications (SIC) 20 through 45, 50, and 51, plus power plants, mining operations, recycling facilities, and transportation facilities. Others include landfills, mines, hazardous waste facilities, and junkyard facilities. Industrial areas or operations which could impact stormwater include material storage, access roads, and rail lines, manufactured and intermediate product storage, material handling equipment storage, and maintenance areas. Drums or tanks of solvents, oils, and chemicals are included as are open dumpsters, air compressors, and material handling areas outside. Facilities are covered if their stormwater runoff discharges directly or ultimately to navigable waters of the U.S. In Florida, this applies to most sites.
Finally, quarterly visual monitoring of the stormwater runoff will have to be completed for the life of the permit. Additionally, for certain SIC Codes, in years 2 and 4 of the permit, samples will have to be analyzed in an analytical laboratory. Analytical results must be reported to FDEP by March 1st of the year following monitoring. In certain cases when the analytical results for year 2 of the monitoring are in compliance, the FDEP may waive entirely or partially the year 4 analytical monitoring requirements.
Further details on the moisture content of building materials are provided here. Remember that the thermal imaging camera is used to identify materials that are cooler, perhaps due to the evaporation of water. A moisture meter is then used to confirm or refute the presence of water. These meters can be used in the survey or penetrating mode. In the survey mode, readings are taken from the surface of the build-ing material, whereas in the penetrating mode, pin holes or larger holes are made and the readings are taken at a certain depth. The readings are usually standardized to a common unit, such as wood moisture equivalent (WME). Readings of 16 to 20% WME are considered borderline moist while those exceed-ing 20% WME are usually considered excessively moist. This level of moisture is capable of supporting the growth of mold. Thus, if this level is found, mold could be present in the building material, wall cavity air, etcetera.
Another myth is concluding no mold is present in the air or on surfaces because you can’t see it. Mold is microscopic until it forms layer upon layer of organisms (a colony) and becomes visible to the unaided eye. The spores in the air and the organisms on surfaces of building materials and contents are invisible until they are put under the microscope or grown out in the lab on nutrient agar plates – otherwise known as Petri dishes.
The actual scope of work will be dictated by Chapter 72-780, Florida Administrative Code (F.A.C.) and the FDEP or county. Each CA can be unique but the common elements follow. Either manual or automated direct push soil borings will be completed and screened with an organic vapor analyzer (OVA) to determine where potential contamination exists in the soil around the source. Based on those results, soil samples will be collected and analyzed in a laboratory accredited by the National Environmental Laboratory Accreditation Program, NELAP (
That is what Contamination Assessments used to be called in Florida. But then they were renamed Site Assessments, which can be confused with Environmental Site Assessments (Phase I and II – see our other blog articles specific to those types of projects). To avoid confusion, we will stick with the name Contamination Assessment (CA). They became regulatory requirements in Florida in the 1980’s to primarily address contamination from underground and above ground fuel and oil storage tanks. These CAs are required when contaminant levels in the soil or groundwater exceed the State Cleanup Target Levels. They are designed to determine the extent of contamination in the soil and groundwater both horizontally and vertically. Often, the contamination is originally discovered during tank closure, after a leak, from a spill, etcetera.
Well, the fuss with asbestos all comes down to health risks. Some of the potential outcomes are very serious – lung cancer, mesothelioma (i.e., cancer of the lining of the chest cavity), and asbestosis (a pulmonary obstructive disease that eventually puts such a strain on the lungs and heart, that the patient dies from cardiac arrest). The primary route of entry for these extremely small asbestos fibers is inhalation. Theoretically, these diseases can be caused by one exposure episode. However, the greater the dose, the greater the disease. And, finally, the diseases do not show up for ten to thirty years after the exposure. That is a very long latency period.
banned from all materials in the United States. It has been banned in five to seven materials and it is still found in building materials being imported today. It is not always listed on the material, sometimes a label states that a product is non-asbestos when it is not, and sometimes it is labeled as asbestos free, but chrysotile (the most common type) is listed on the ingredients).
Finally, workers who install, remove, or demolish it in buildings are at risk. That is why EPA requires testing for asbestos before all renovations and demolitions of most buildings before the work is started. If asbestos is present, certain abatement procedures will be required before the construction or demolition work begins.
So you had your Phase I Environmental Site Assessment (Phase I) done and Recognized Environmental Conditions (RECs) were found. You have decided to proceed with the transaction but you now need a Phase II ESA (Phase II) to fulfill your due diligence in determining if the site is or could be contaminated from usage of the site or properties in the vicinity. On the financial end, you and the seller have decided who will pay for the Phase II. This could mean that the seller will pay for it all, you will pay for it all, or the two of you will share the expense. Many times if you are paying any part of it, there is a proviso that the seller will reimburse you in full if contamination is found and you cancel the trans-action. The specifics are provided by your attorney.
Once you have selected a firm, discuss the Scope of Work, turnaround, and terms. The Scope should be designed to specifically investigate the RECs that were found during the Phase I. This includes the media type and the contaminant types. The media may include soil, surface water, sediments, and groundwater. One or more of these media may need to be included. Types of contaminants include gasoline, diesel fuel, used oil, solvents, pesticides, heavy metals, and perc (perchloroethylene, a dry cleaning chemical), among others. There may be concerns with different contaminants in different locations on the site. These locations may have different media to be tested.
Environmental Site Assessments are conducted in phases. A Phase I ESA includes an inspection of the site and properties in the vicinity; review of environmental regulatory records, data, permits, and complaints; interviews of the buyer, seller, managers, and regulatory personnel; review of current and historical aerial photographs of the site and vicinity; review of environmental title search back to 1940; and review of nearby landfills, surface waters, and U.S. Geological Survey (USGS) topographical maps.