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HomeMy WebLinkAboutZTA201000002 Legacy Document 2012-06-25 (3)ATTACHMENT B Follow -Up to Commission Work Session Discussion Industrial Performance Standards At the Commission work session, several questions / issues were brought up for further study. These are as follows: Do any of these uses require a follow up that the condition has been met? Yes. Typically this is coordinated through the zoning clearance review which is required before a use can commence or expand. As part of the Zoning review, we conduct inspections to confirm compliance with conditions we administer. For conditions that relate to other agencies, we require something in writing from that agency to confirm compliance with a condition. 2. Do anv of these uses reauire follow -uo insoections from various aoorovin agencies? James Barber with the Fire Rescue Department informs us that they conduct inspections for compliance with applicable safety regulations. Their inspection process typically has a twenty (20) month re- inspection frequency. Businesses involving a state mandate (such as a nursing home or child care center) or a hazardous material handling /storage permit (such as a gas station or construction yard where explosives are stored) are inspected annually. They also respond to complaints from the public about a particular business. Jed Pascarella with the Virginia Department of Environmental Quality informs us that depending on the type of facility, they may or may not have required inspections. His information is very extensive and is divided into waste, air and water programs. Please see the attached email at the end of this document for his detailed response. Each major home occupation and many home occupations class B involve a preliminary and final zoning inspection prior to final approval. Industrial uses are subject to approval of a zoning clearance prior to commencing the use. This approval is given only after a zoning inspection. Once these applications are approved, we conduct follow -up inspections after receiving a complaint. 3. What potential home occupations require a certified engineer's report? Generally, the home occupations that involve machines, processes, products and by- products with emission or discharge to land, air or water are subject to some level of review by the County Engineer. Examples of home occupations that are subject to submitting information showing compliance with the performance standards are: photographer with darkroom, furniture maker or sculptor, blacksmith and taxidermist. ATTACHMENT B 4. Suaaest that a member of staff be sent to ISO 1400 Environmental Manaaement class. We have briefly looked into this and find the ISO 1400 Environmental Management standards to be very extensive. They may be more extensive than our level of expertise and /or our ability to measure. Of all the performance standards, the one that Zoning directly measures and enforces is sound. We are pursuing certified training on sound measurement. Information from DEQ regarding recurrence of site inspections: Hello Amelia, apologize for the delayed response Regarding inspection frequencies, each of the programs are a little different in the criteria for scheduling their inspections. For the Waste program. Solid and Regulated Medical Waste: -- Permitted waste management facilities — Landfills and Transfer Stations. These facilities are inspected on a Quarterly (per year) basis. We now have a risk -based program where we can add or reduce the number of inspections per year based upon performance or other factors. -- Unpermitted solid waste generators — most businesses. There are no required inspections for a facility that generates non - hazardous or non - infectious solid waste. Hazardous Waste: - -This program is set up on a tiered basis. If a facility generates less than 220 pounds of haz waste per month (Conditionally Exempt Generator), there is no requirement for them to get an EPA ID number or notify DEQ of their activity, and thus, no way for DEQ to know where they are. There is no requirement to inspect these facilities on any regular basis. Most businesses in VA are in this category — less than 220 pounds per month. - -For a facility that generates greater than 220 pounds per month and less than 2,200 pounds per month, these facilities are classified as a Small Quantity Generator. They are required to get an EPA ID #, and to notify DEQ of their activity, but there is still no required inspection frequency. - -For a facility that generates greater than 2200 pounds per month of haz waste (LQG or Large Quantity Generator), they need to notify DEQ and get an EPA ID number and they are inspected once every 5 years. - -For a facility with a permit to treat or store haz waste, they need a permit which spells out how to handle the waste and they are inspected once every year, two or three years depending on the specific type of activity. For the Air Program; These facilities are organized on a emissions (volume and type of chemicals emitted) basis and the larger emitters (or ones that emit HAPS — or hazardous air pollutants) have more frequent inspections than facilities that emit smaller quantities or less hazardous chemicals. These facilities can range from everything from the chemical companies, to landfills (emitting landfill gas), to diesel backup generators. The large emitters are the "Title V" permits and are inspected every 2 years. These are the chemical companies, etc. "Synthetic Minor" facilities emit less than 100 tons per year and are inspected every 3 years. "Minor" facilities, are low emitters and operate under a MACT (Most available control technology) permit and an example is a dry - cleaner. These facilities are inspected every 5 years. If you need more information on specific frequencies, you can contact Glenn Diehl (540 -574- 7841) — I have copied him on this email. 2 ATTACHMENT B For the Water Program; Again these facilities are organized on the volume of pollutant discharged or the toxicity of the pollutant. Most of these facilities have a permit and the frequency is based upon the category of their permit. These facilities range, again, from the chemical companies, to municipal wastewater treatment facilities, to storm -water discharges from a concrete manufacturing plant. Some facilities that discharge to the local Wastewater treatment facility (as opposed to a receiving stream) require a pre- treatment permit to discharge. This pretreatment permit is issued by the locality and overseen by DEQ. Bill Maddox, the Team leader in the Water Compliance group, provided the attached list of inspection frequencies for your information. If you need more information on the specifics of the Water inspections you can contact Bill (540- 574 -7831) — I have copied him on this email. As you can see, even without getting into exemptions, special cases, and subcategories within the major groups, it's impossible to generalize on the inspection frequency for businesses in general. A generator that is a LQG of hazardous waste may not have a water permit at all and may only be a synthetic minor in the Air Program. The above (and attached) information is a very brief summary of each of the programs. hope this helps. Please email me or the staff copied on this email if you want to get more detailed information on the Water, Air, or Waste programs. Or you can call the numbers above (or mine) and chat with us about the programs. Thanks. JED Jed Pascarella, Environmental Program Planner VA DEQ - Valley Regional Office P.O. Box 3000, Harrisonburg, VA 22801 ph: 540 - 574 -7838 fx: 540 - 574 -7878 NOTE NEW EMAIL ADDRESS ied .pascarella(aD_deg.virginia.gov From: Amelia McCulley f mailto:AM000LLE(a)albemarle.orgl Sent: Monday, August 30, 2010 11:31 AM To: Pascarella, Jonathan (DEQ) Cc: Johnathan Newberry Subject: recurring inspections for permits from DEQ Jed, Not sure who to ask and you can certainly direct me to someone else. As part of the work we're doing on industrial performance standards, the Planning Commission asked which agencies do recurring inspections after the industry is approved and opens for business. Does DEQ do regular recurring inspections for the air, water and solid waste permits? If yes, generally about how often are they reinspected? 3 ATTACHMENT B Table 1 INSPECTION FREQUENCY REQUIREMENTS Inspection Type 1 Year 2 Years 3 Years 5 Years VPDES CEI Tech /Lab Municipal Major >_1.0 MGD 1 X2 X VPDES CEI Tech /Lab Municipal Minor 4.04 and < 1.0 MGD X VPDES CEI Tech /Lab Municipal Small ?0.001 and < 0.04 MGD X VPDES CEI Tech /Lab Industrial Major (DEQ /EPA Majors list) X3 X VPDES CEI Tech /Lab Industrial Minor not a Major or Small X VPDES CEI Tech /Lab Industrial Small 4 X VPDES CEI Tech /Lab for General Permits 5 X VPDES CSI (Sampling) 6 X SSO Inspection As Necessary Pretreatment POTW Audit X SIUs in Pretreatment Program X Pretreatment SIU Inspection - No POTW Pretreatment Program X VPG (AFO) Inspections X VPA (High Priority) Inspections 7 X VPA Low Priority) Inspections 8 X Commercial Laboratory Major Inspections 9 X Commercial Laboratory Minor Inspections 10 X 1 Includes Combined Sewer Overflow facilities. 2 Major facilities that are in compliance and not contributing to Section 303(d) or 305(b) listing may have their inspection frequency reduced to once per three years. 3 Major facilities that are in compliance and not contributing to Section 303(d) or 305(b) listing may have their inspection frequency reduced to once per three years. 4 Small is an industrial facility with low environmental impact potential such as discharges of non - contact cooling water, sand and gravel operations, car washes, etc. 5 All General Permits including Industrial Stormwater permits. Includes multiple home and non - residential domestic wastewater facilities covered by General Permit (defer inspections of single family homes covered by a general permit to the local Health Department). Petroleum General Permit inspections are conducted on an as needed basis due to the short duration of activity at these sites. 6 Sampling inspections are conducted subject to the availability of effluent. 7 High priority is assigned to facilities with high environmental impact potential or high public concern and includes animal feeding operations, wood preserving operations, sludge disposal activities, and other facilities so classified by the Regional Offices. An inspection of sludge disposal permitted facilities includes, as a minimum, an inspection of the storage facilities and at least one land application site per permitted facility per year. 8 Low Priority is a VPA facility with low environmental impact potential. 9 Major Commercial Laboratories are those who serve ten or more minor VPDESNPA permittees and /or 1 major facility. 10 Minor Commercial Laboratory designation is assigned to all other facilities not considered as high priority. Inspection of out of state laboratories is at the discretion of the region. 12