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The NPDES Industrial Stormwater Program is federally mandated and covers a wide variety of industrial activities. Most industrial facilities are affected in some way and applicability to the program is dependent upon Standard Industrial Classification (SIC) code. General permits have been established that apply to numerous broad categories of industrial activities with potential stormwater discharges (also based on SIC code). Industries that are not eligible for any of the general permits are required to seek an individual permit that is more site-specific. An alternative to obtaining an individual permit or coverage under a general permit is a “no exposure certification,” which certifies the facility meets certain conditions for elimination of exposure of industrial materials to precipitation (e.g., industrial materials inside buildings, under cover, tanks provided with secondary containment, all waste dumpsters covered, no exposed residues/debris).
For facilities claiming no exposure, a no exposure application containing information certifying the no exposure conditions must be submitted to the State agency and approved. Typically, the State agency will also send an inspector to verify no exposure conditions for approval, the facility will be granted a no exposure registration number, and then the facility must recertify these conditions are continuing to be met annually.
To obtain coverage under an established general permit, a Notice of Intent (NOI) containing facility-specific discharge, potential pollutants, and receiving waters information must be submitted and approved by the State agency. The State agency will then issue a general permit registration number.
General and individual industrial stormwater permits require the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP, SPPP, or SWP3) for minimizing impacts to stormwater from industrial materials. The SWPPP identifies stormwater discharges at the facility, actual and potential sources of stormwater contamination, and requires the implementation of Best Management Practices (BMPs) to reduce the impact of stormwater runoff on the receiving stream. BMPs may include schedules of activities, practices, prohibitions of practices, structures, vegetation, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants to surface waters. The stormwater permit and SWPPP may include the following requirements, depending on SIC code:
- Routine facility inspections to ensure BMPs are being implemented and are effective;
- Qualitative (visual) stormwater discharge monitoring;
Quantitative (analytical) stormwater discharge monitoring;
Annual inspection, evaluation, and certification of outfalls for the presence of non-stormwater/unauthorized discharges;
Annual comprehensive compliance evaluations;
Annual training of certain personnel; and
Recordkeeping and reporting.
Stormwater permits are typically issued on a five (5) year cycle, and the revised permit often contains changes affecting the facility requirements. When these permits come up for renewal, there often exists a tendency within industry to place a copy of the new permit with the SWPPP back on the shelf without review and continue business as usual. This can lead to a facility missing important changes to requirements, such as monitoring frequency, new limits, changing parameters, etc., such that the facility may unknowingly be out of compliance moving forward. It is recommended that permittees carefully review their renewed permits for changes and new requirements, or consult with an expert to do so for them.
The EI Group, Inc. has a team of qualified stormwater compliance specialists that 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 industrial stormwater pollution prevention services:
- Permit compliance review/audits;
- Notice of Intent (NOI), registrations, and updated registrations for renewal;
- Development and updates to SWPPPs;
- Stormwater monitoring programs; and
- Site-specific training.
If you have stormwater consulting needs, you may contact me directly at (919) 459-5229 or firstname.lastname@example.org.