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Managing Stormwater at Industrial Facilities in Arizona

2/23/2014

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Photo by Michael Trimble on Unsplash
In Arizona, there are three regulatory paths for stormwater discharge at industrial facilities:
  1. Tribal lands, where all stormwater discharges are regulated by USEPA under their federal permit system.
  2. Stormwater discharges into municipal separate stormwater systems – either large or small.  These discharges must meet the multi-sector industrial permit programs, which are implemented by the state, but they are also subject to pollution prevention programs and reporting as required by various municipal codes.
  3. Stormwater discharges into other receiving bodies.  These discharges must meet only the state multi-sector industrial general permit requirements.

This program falls under the National Pollutant Discharge Elimination System (NPDES) stormwater program of the national Clean Water Act, as applicable to the state and local jurisdiction where the subject property is located.  States adopt general permits that cover a wide range of industrial and business activities.

A permit must be obtained for facilities where stormwater is considered “contact stormwater”, from either the state or the city, depending on where the stormwater is discharged.  However, some industrial activities are not covered or exempted under general permit standards.

Non-contact stormwater flows on an industrial property means stormwater that does not come into contact with industrial operations or loading/unloading activities.  

For facilities that are not planning discharge pollutants into the stormwater system, there are two ways to proceed:

  1. The No Exposure Certification.  This certifies that all industrial activities are protected by a storm resistant shelter and that no pollutants are being discharged due to no exposure. The certification is signed by the facility owner and is supported by answering 11 questions, all of which must be answered “no” in order to qualify for the exemption, typically by inspecting the facility and documenting the outfall configuration, facility activities, potential sources of regulated pollutants, and any protections that exist on site.  It’s also important to check the state regulations to ensure that the facility is covered under the Limitations of Coverage section of the general industrial permit.
  2. Zero Discharge.  There is a concept called “zero discharge,” which is not in the regulations but is used to support the case to the regulatory agency that an industrial facility is not subject to any of the stormwater regulatory requirements.  The Zero Discharge concept does not have any regulatory definition, but essentially certifies that the facility doesn’t meet the criteria for discharge of a pollutant. Some of the city stormwater management plans have requirements that apply to a claim of zero discharge, including having it certified by a registered professional engineer or professional geologist.  A zero discharge certification should be supported by inspecting the facility and documenting the outfall configuration, facility activities, potential sources of regulated pollutants, and any protections that exist on site.
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Nuclear Power to Offset Climate Change:  Can China Make Nuclear Power Work?

2/21/2014

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Photo by Johannes Daleng on Unsplash
Our children will enjoy in their homes electrical energy too cheap to meter... It is not too much to expect that our children will know of great periodic regional famines in the world only as matters of history, will travel effortlessly over the seas and under them and through the air with a minimum of danger and at great speeds, and will experience a lifespan far longer than ours, as disease yields and man comes to understand what causes him to age.
Lewis Strauss, chair of the Atomic Energy Commission

Even if you build the perfect reactor, you're still saddled with a people problem and an equipment problem.
David R. Brower, environmental activist and founder of the Sierra Club

I just started following The National Interest’s blog, and I’m enjoying the international perspective and diversity of contributors.  I’m always interested in alternatives to carbon-based energy, and recently John Quiggin, an Australian economist, wrote about why he thinks that China’s nuclear program could work for them (Link:  http://nationalinterest.org/commentary/china-can-make-nuclear-power-work-9815).

I grew up in a time when nuclear power was going to solve all our energy problems, making electricity too cheap to meter.  But Quiggin points out that even by the time the Three Mile Island meltdown occurred 1979, the nuclear plant building boom in the United States was nearing an end.  Long delays, cost overruns, and public opposition resulted in no new nuclear plants being completed after 1980. In contrast, the French were successful at building a large number of nuclear reactors, in an effort to convert completely to nuclear energy in the wake of the 1970s energy crises.  Arnulf Grubler, one of my favorite professors at Yale, pointed to four key factors in the success of the French:
  • strong political support
  • a state-owned electricity monopoly endowed with [substantial] engineering resources
  • high regulatory stability
  • efficient coordination resulting from long-term organizational arrangements.
Since the 1970s, these factors have changed in France, and their more efforts to build new reactors have run into the same kinds of problems we’ve seen in the United States.
Could China, which seems to have a lot in common with 1970s France, make nuclear power work for them to reduce the amount of coal they are burning?  Quiggin seems to think it’s a good possibility and would be beneficial for everyone on our planet. He points out that “China is ruled by a modernising elite that’s procapitalist but happy to exercise state control over the economy, and to ignore or crush public opposition. Like France, China seems likely to standardize on a single Westinghouse model, the AP1000. So, it’s unsurprising to see Chinese nuclear projects being completed on time and on budget while similar projects in the US and Europe are floundering.”  Of course, it might be difficult for those conditions to be sustained in China into the future, and if renewables become economically competitive, nuclear could be less attractive.
I’ve spent a lot of time at all kinds of factories in China, including a number of coal fired power plants, biowaste facilities, and co-generation plants at large industrial plants.  I’ve audited solar panel fabrication plants, transformer factories, and all kinds of factories making manufactured goods like CAT scan machines, escalators, and refrigerators. What worries me about nuclear power in China are the two things I see in common with all these facilities:  not one of them had bothered going through the effort to get all their environmental permits in place, and not one of them had an appropriate operations and maintenance program to ensure that conditions at the factory when it was built would be sustained for more than a year or two after completion.  And that brings me back to David Brower’s quote. Given the complexity and inherent risks associated with nuclear power, its success rests on the people and their ability to understand and maintain the equipment they are working with. I’m not sure any government or company can manage that for nuclear power over the lifetime of the plant and the waste it produces.
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Optimism

2/4/2014

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My optimism wears heavy boots and is loud.

Henry Rollins, heavy metal rocker, civil rights activist, and actor

Linky:  http://en.wikipedia.org/wiki/Henry_rollins
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Photo by Syd Wachs on Unsplash
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    Marty Walters

    Environmental Scientist

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