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REGULATORY COMPLIANCE GROUP November 2011 REGULATORY COMPLIANCE GROUP November 2011

Regulatory Compliance Group Who we are What we do What we can do for Regulatory Compliance Group 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 Who We Are Robin Halperin Manager of Regulatory Compliance Beth Toot-Levy Senior Environmental Specialist Sarah Rehner Environmental Specialist Vacant Environmental Specialist (Back-up RSO) (RSO)

What we do Ensure the District’s compliance with all environmental rules and regulations NPDES What we do 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 Provide a consistent voice to regulatory agencies Review and More about what we do 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… Prepare and review permit applications Monitor NPDES permit compliance Review draft rules More specifically… 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 Achieve and maintain environmental compliance 100% of the time. NACWA Gold & Our Goals 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 Areas of Focus: Wetlands Delineations 401/404 Permits Wetland Robin Halperin Manager of Regulatory Compliance 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 Affecting plant operations Incident Projects Reporting Power Failure, Flooding, Robin Halperin NPDES Permits Construction Affecting plant operations Incident Projects Reporting Power Failure, Flooding, etc. Permit Renewals ODNR Shore RCAT Structure Permits Chair

Robin Halperin Call me: With questions about Wetlands, permits and compliance/mitigation activities If you Robin Halperin 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 NPDES Permits Permit renewals Permit compliance assistance Water quality Beth Toot-Levy Senior Environmental Specialist NPDES Permits Permit renewals Permit compliance assistance Water quality issues Concerns with meeting permit limits Trends in NPDES permitting Stormwater Permits (Plants) SWPPP Maintenance Annual inspections New stormwater permits are on the horizon

Beth Toot-Levy Biosolids Management Part 503 Reports Beneficial Reuse of Ash Pilot Project underway Beth Toot-Levy Biosolids Management Part 503 Reports Beneficial Reuse of Ash 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 Call me: If it went down the drain and didn’t fall from Beth Toot-Levy 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 Air Emissions Permit to Install Permit to Operate Permit by Sarah Rehner Environmental Specialist Air Emissions Permit to Install Permit to Operate Permit by Rule Reporting Title Requirements V Reports - Southerly Synthetic Minor Report - Westerly Non Title V Reports - Easterly (once every two years) Quarterly Deviation Reports Miscellaneous Reports

Sarah Rehner New SSI MACT Standards Compliance Required in March 2016 Determining Impacts on Sarah Rehner 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 Radiation Protection Program RSO-In-training USACE Nationwide Permits Developing flowchart and checklists

Sarah Rehner Call me when: Considering new air emissions units to be installed (e. Sarah Rehner 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 Waste Management Hazardous Obsolete Universal Light Waste chemicals… Waste Bulbs, Batteries, Vacant Environmental Specialist Waste Management Hazardous Obsolete Universal Light Waste chemicals… Waste Bulbs, Batteries, etc… Radiation Protection Program RSO-In-Training

Environmental Specialist Hazardous Substance Permits Asbestos Lead Call me: To schedule hazardous and universal Environmental Specialist 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 401/404 Permit for Nine Mile Creek Radiation Control Plan Revisions NPDES Current Engineering-Related Projects 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. 55 th Floatables Control Doan Brook Stream Enhancement Project – Section 106 Environmental Compliance Sharepoint Site West Creek Confluence Project

What we need from you Keep us informed of EPA communications Phone Calls Letters What we need from you Keep us informed of EPA communications Phone Calls Letters Site 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… Opportunity to review and provide comments on letters/reports/documents BEFORE they are sent to More… 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 How to contact us Robin Halperin (Wetlands, CSOs, NPDES, Radiation, RCAT) Office: 881 -6600 x 6465 Cell: 214 -5006 Beth Toot-Levy (NPDES, Stormwater, Residuals) Office: 641 -6000 x 2236 Cell: 216 -214 -8850 Sarah Rehner (Air Permits, Nationwide Permits, Radiation) Office: 881 -6600 x 6405 Vacant (Hazardous Waste, Universal Waste, Radiation) Office: 881 -6600 x