The Georgia Environmental Protection Division (EPD) continues to roll out features that require the use of the Georgia EPD Online System (GEOS), their online reporting portal. As more features and updates are added to this website, the EPD is taking a more active approach to reviewing the forms and reports that are being submitted. Lately, the biggest item under review seems to be Stormwater Annual Reports from 2017 and 2018. Special attention is being made to review the annual reports for completion of required tests (e.g. Smoke & Dye, stormwater benchmarks, etc.) and other actions.
Annual Reports are a general summary of your facility’s compliance activities throughout the previous year. For example, the next round of Annual Reports is due in January 2020 to summarize the 2019 calendar year. Some of the details that are required in an Annual Report include the following: any stormwater, outfall, and discharge sampling data; corrective actions completed during the previous year; smoke, dye, or equivalent testing status; and impaired stream status. A summary of each of these, as well as what the EPD is saying about them on Annual Reports, can be read below.
Sampling data required to be reported in each Annual Report includes results from any stormwater samples collected during the calendar year. While sampling is required for most permitted facilities, it is not always a requirement – this would depend on your industry and the receiving waters of your discharge. If your facility is required to conduct stormwater sampling, you may be required to sample as often as twice-quarterly, or simply once per year. If your facility has exceedances in the sampling benchmark results or is not able not take stormwater samples during the year, the EPD could flag your Annual Report and ask for an explanation of why sampling was not conducted. If failed samples are reported, the EPD could ask what corrective actions were taken to ensure the samples will pass in the future.
Corrective actions are any fixes that the facility made regarding issues related to stormwater, or any improvements made to the facility during the calendar year that could have an impact on stormwater. This could range from small items, such as “moved a drum of oil inside”, to something large, like “constructed a new warehouse for oil storage complete with dike walls, sumps, and an oil/water separator”. Your facility should have an ongoing list of corrective actions as well as their start and completion date. It is also necessary to have a list of corrective actions taken during the previous permitted years (2012-2017) as part of your facility’s stormwater pollution prevention plan. If the facility marks that corrective actions were completed during the year, the EPD will require a written description of what those corrective actions were. One important thing to note is that the EPD is looking at the timeline for completing identified corrective action items. All corrective actions need to be addressed within 30 days of discovery, or the EPD must be notified if identified corrective actions cannot be abated within 90 days.
Smoke, dye or equivalent tests are required by 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 were required to have been conducted by the end of the previous permit, May 31, 2017. If the EPD sees on your Annual Report that one of these tests has not been conducted, they will flag your Annual Report and require that you do one or explain why it is not required at your facility.
Impaired stream status can be reviewed through the EPD’s online database of impaired streams. An impaired stream is one that is considered too polluted or otherwise degraded to meet the water quality standards set by the State. If your facility discharges to an impaired stream, you may have additional testing requirements – depending on whether you would potentially add on to what is causing the stream to be impaired.
Another thing to note with the Annual Report, is that if your Responsible Official has changed since the last submission, you will have some extra work to do. In addition to submitting your Annual Report for 2019, you will also need to submit an update to your Notice of Intent (NOI). The EPD has has updated the NOI requirements when changing any information to include filling out the entire NOI twice. At the time of writing this report, the NOI process has some bugs and can be difficult to navigate, so you should not wait until the last minute to update your account.
We are here to help. If you need any help with your facility’s submission requirements, or if you would like to discuss having CTI conduct a Smoke & Dye Test of your facility, please contact Conversion Technology Inc. at (770) 263-6330 or visit our website at www.conversiontechnology.com.
- Georgia General Permit: https://epd.georgia.gov/npdes-industrial-storm-water-general-permits
- Georgia Impaired Streams: https://epd.georgia.gov/water-quality-georgia
- Georgia Permit Update: https://www.conversiontechnology.com/new-georgia-multi-sector-industrial-storm-water-permit-issued/
- GEOS: https://geos.epd.georgia.gov/GA/GEOS/Public/GovEnt/Shared/Pages/Main/Login.aspx