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Many industrial facilities have existing General Permits for NPDES (National Pollutant Discharge Elimination System) stormwater discharges, along with established programs for compliance with the permit requirements. When these permits come up for renewal, the tendency is to place a copy of the renewed permit in the file with the Stormwater Pollution Prevention Plan (SWPPP), stick it back on the shelf and continue business as usual. However, it is advisable for permittees to carefully review their renewed permits for changes and new requirements.
Many permit renewals in 2014 are coming out with changes that significantly affect monitoring requirements and needs to recertify items of compliance. Some are requiring that SWPPPs be updated to reflect permit changes within a duration of days from the effective date of the updated General Permit, and in some cases, these renewals are received after that effective date.
A qualified stormwater compliance specialist can assist in sifting through the permitting language to identify facility specific requirements that may have changed upon permit renewal.
In some cases, General Permit updates may streamline or simplify previous requirements, such as:
- Changing from visual monitoring of stormwater and/or sampling stormwater during a “Representative Storm Event” definition considering a minimum amount of rainfall to a “Measurable Storm Event” definition based on rainfall producing any actual discharge;
- Decreases in required monitoring frequency;
- Decreases in parameters required for analysis.
In other cases, new requirements for monitoring, recordkeeping and recertification may be included that require increased efforts for compliance, such as:
- Requirements to recertify evaluations of non-stormwater discharges annually;
- Requirements to recertify effectiveness of Best Management Practices (BMPs) annually;
- Changes to benchmark monitoring for the applicable industrial sector(s);
- Changes to impaired waters classifications affecting agency development of or monitoring for compliance with approved Total Maximum Daily Load (TMDL) allocations;
- Revisions to analytical parameters associated with benchmark and/or TMDL monitoring;
- Addition of outfalls previously not required to be included in quantitative monitoring;
- Increases in monitoring frequency.
A qualified stormwater compliance specialist can assist in sifting through the permitting language to identify facility specific requirements that may have changed upon permit renewal and refine outdated monitoring/recordkeeping programs into streamlined efforts to ensure compliance with applicable requirements in a cost effective and time efficient manner.
EI can assist owners and operators with the following services:
- General Permit compliance review/audit;
- Develop and update SWPPPs, creating a concise, working document understandable to those who are responsible for implementation;
- Develop revised registration statements and negotiate changes to stormwater permit conditions where appropriate;
- Stormwater monitoring programs;
- Site-specific training.