Industrial Storm Water Permits

2013-09-15 stormwater discharge pipeWith the introduction of sometimes-unrealistic toxic water quality limits, stormwater permit compliance has become a challenge for some industrial sectors.  As a State permit engineer, Guy worked with industry to write some of the first toxic water quality discharge permits in the Nation.  As a consultant, he continues to work with both regulators and industry to find practical solutions to the sometimes-challenging requirements.

Facilities that fall under listed Standard Industrial Classification (SIC) codes are subject to regulations.  A list of the regulated SIC codes is provided here. 

In rare cases, a facility can be excluded from regulation.  A point source stormwater discharge originating from industrial activity is needed to be subject to regulation.  If all runoff is sheet flow at the property line, a case can be made that the facility is excluded from regulation.

Some facilities may collect all their stormwater runoff and thus avoid permitting.  These facilities are also excluded because there is no point source discharge.  An alternative means to release collected stormwater, such as discharging to a municipal treatment system, is needed.

Facilities that are not excluded can certify that there is no significant industrial activity exposed to stormwater.  The Environmental Protection Agency (EPA) and some States have specific forms to make non-exposure certifications.  The EPA and States also have procedures to maintain the certification.  Non-exposure certifications typically need to be made every five years.  Guidance on how to make non-exposure certifications is provided here.

If your facility is not excluded and cannot make a non-exposure certification, the facility will likely desire to submit a notice of intent (NOI) to comply with the appropriate general stormwater discharge permit.  The specific requirements of general stormwater discharge permits tend to vary from State to State.  However, their framework is typically the same. 

General stormwater permits typically require development of a Stormwater Pollution Prevention Plan (sometimes SWPPP or SPPP).  These plans typically require implementing best management practices, inspections, monitoring, spill response plans and training.  EPA guidance on developing SPPPs is provided here.

Instead of general stormwater permitting, an individual stormwater discharge permit can be obtained.  This is a more expensive option and rarely used by facilities that fall under a general permit.

While with the State of Delaware, Guy drafted and issued numerous individual wastewater discharge permits and helped with the general stormwater permitting program in its infancy.  His work in industry and as a consultant has helped numerous facilities establish and maintain stormwater discharge permit compliance.  He has developed unique, low cost, sampling equipment that makes visual monitoring simple. 

If you want to comply with the Industrial Stormwater Discharge regulations in an efficient manner, call Guy.

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