Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the Environmental Protection Agency (EPA) or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random and infrequent.Continue reading “Staying in Compliance with Air Quality Regulations”
Industrial Stormwater Permitting requirements have been in place for over 20 years. Facilities that fall under one of eleven industry categories identified by the US Environmental Protection Agency (USEPA) and have material handling and storage, equipment maintenance and cleaning, and other activities exposed to stormwater are required to have a permit to discharge their stormwater runoff. Stormwater runoff is generated from rain and snowmelt events that flow over land or impervious surfaces, such as paved streets, parking lots, and building rooftops, and does not soak into the ground. The runoff picks up pollutants like trash, chemicals, oils, and dirt/sediment that can harm our rivers, streams, lakes, and coastal waters. Most often, industrial facilities are covered under General Permits issued by the State, but some facilities have individual permits. Continue reading “Industrial Stormwater Compliance – Increased Focus from Regulators”
After two rounds of public comments, the final version of Georgia’s General Multi-Sector Industrial Storm Water Permit (GAR050000) renewal has been issued. The permit will become effective on June 1, 2017. Covered industrial facilities will need to meet the following compliance deadlines:
All NOI’s and Annual Reports must now be submitted via Georgia EPD’s Online System (GEOS). Below are links to the final permit and to the GEOS website. If you have any questions or need assistance with submitting an NOI or updating or developing your SWPPP, please contact us.
New Georgia Multi-Sector Industrial Stormwater Permit – http://epd.georgia.gov/sites/epd.georgia.gov/files/related_files/site_page/FinalSigned2017IGP-20170306.pdf
GEOS Website – http://epd.georgia.gov/geos/
Georgia EPD’s NPDES Industrial Storm Water General Permits website – http://epd.georgia.gov/npdes-industrial-storm-water-general-permits
One environmental reporting requirement that is often overlooked, but enforced regularly by the Environmental Protection Agency (EPA), the Georgia Environmental Protection Division (GA EPD), and other state agencies is Tier II Reporting under the Superfund Amendments and Recovery Act (SARA).
If your facility stores any chemical or product on site that requires a Safety Data Sheet (SDS) (e.g. petroleum products, grains, paints, lead-acid batteries, liquid oxygen, etc.) in amounts over 10,000 pounds, your facility is required to notify the state, your local emergency planning committee, and the local fire department of these materials on an annual basis. Additionally, if you store any extremely hazardous substances (e.g. sulfuric acid) above its reportable quantity, usually 500 or 1,000 pounds, your facility is also required to report under the SARA Tier II requirements. The annual deadline to submit Tier II reports is March 1.
If you would like assistance determining whether or not your facility is required to report under the SARA Tier II requirements, or need assistance completing the reports, please give me a call at (770) 363-6330, x.113 or email me at firstname.lastname@example.org.
Under the Georgia Industrial Storm Water Permit, all covered facilities are required to conduct a smoke, dye, or equivalent test of all floor drains and sinks in industrial areas. These tests are to ensure that these sinks and floor drains do not discharge to storm water conveyances, and must be conducted by the end of the permit, May 31, 2017.
As we reported in an earlier blog post, the Georgia Environmental Protection Division (GAEPD) has posted a draft of the 2017 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity. The current (2012) version of the permit is set to expire on May 31, 2017, and this revision will replace it. The GAEPD has held three stakeholder meetings that were open to the public, and representatives from CTI were in attendance. There are a few obvious trends that we can see from the direction the GAEPD is heading. Most notably, there is an increased focus on erosion and sedimentation control, and there is a push for higher accountability in completing corrective actions. We will discuss both of these below, but keep in mind that the permit is in an early draft phase. The GAEPD will be issuing a second draft based on input received during the stakeholder meetings and the preliminary comment period, and there will be a second opportunity for the public to comment before the final permit is issued. Continue reading “Update on Georgia’s Draft Industrial Stormwater General Permit”
The Georgia Environmental Protection Division (GAEPD) has posted a draft of the 2017 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity. The current (2012) version of the permit is set to expire on May 31, 2017, and this revision will replace it. Most facilities with industrial activities exposed to stormwater are required to have a permit to allow the stormwater to discharge. Some facilities have individual permits, but the majority of industrial facilities are able to obtain coverage under this General Permit, which establishes requirements that are applicable to all covered facilities. Continue reading “Georgia Issues Draft Industrial Stormwater Permit”
Permittees under the Georgia Industrial Storm Water General Permit must document, on the annual report, that they have evaluated for the presence of non-storm water discharges annually and that all unauthorized discharges have been eliminated. Continue reading “Smoke and Dye Test for Permittees under the Georgia General Storm Water Permit”
Storm Water Violations Associated with Vehicle Washing
A common source of storm water pollution at industrial facilities is vehicle wash water. Any vehicle wash water that discharges from the facility to the outside would be in violation under the Storm Water Permit. In fact, Georgia Environmental Protection Division (EPD) has specifically mentioned that they will evaluate vehicle washing activities while conducting site inspections. Additionally, the U.S. EPA and the U.S. Justice Department have issued citations to several ready-mix concrete plants for failure to maintain best management practices associated with vehicle washing activities. Monetary penalties for these vehicle washing citations totaled $360,000. Continue reading “HANDLING OF VEHICLE WASH WATER”
The first compliance deadline for the Boiler GACT Rule is September 17, 2011 – when the Initial Notification of Applicability is due. This rule applies to facilities with boilers fueled by any fuel except natural gas, and who are not major sources of Hazardous Air Pollutants (HAPs). Some state agencies have already acted, with North Carolina DENR having recently mailed out letters to potentially affected facilities. Others, such as the Georgia EPD, will be sending out similar letters soon. Whether or not you receive a letter, you will have to submit your initial notification by Sept. 17 if this rule applies to your facility.
The Boiler MACT rule, which applies to facilities that are major sources of HAPs, has been placed on legal hold. This means the large facilities have some breathing room, but the small facilities covered by the GACT rule must act now.
More information is available at CTI’s Boiler MACT and GACT website – www.boilermactcompliance.com.