The Georgia Environmental Protection Division (EPD) has revised the 2006 NPDES General Stormwater Permit for Industrial Activity. This permit expired on July 31, 2011. According to the Georgia EPD, the 2012 Industrial Stormwater General Permit No. GAR050000 (IGP) was signed on April 16, 2012 and is going to become effective on June 1, 2012. All facilities that are currently operating under the 2006 IGP are required to continue compliance under that permit’s specification until the new permit is in effect.
Upon issuance of this new permit, the Notice of Intent (NOI), and No Exposure Exclusion (NEE) are due to the EPD no more than 30 days after the effective date of the permit. Due to the extended holdup of the permit, the next Annual Report deadline has been pushed back until January 31, 2013. This Annual Report will include the rest of 2012 and all of 2013.
A Stormwater Pollution Prevention Plan (SWP3) must be prepared before submitting the NOI for new dischargers. Existing permitted facilities must have an updated SWP3 within 90 days of the effective date of the 2012 IGP. Any proposed modifications need to be implemented within 180 days of the effective date of the 2012 IGP.
Under this permit, site inspections and evaluations are required to be conducted quarterly, at a minimum. These inspections should be conducted for all areas of the facility where industrial materials are exposed to stormwater, and there should be added focus on control measures during these inspections. An inspection must be conducted at least once per calendar year when stormwater discharges are occurring.
Among many changes from the 2006 IGP, there are significant modifications to monitoring and sampling requirements. Specifically, the permit will now have sector specific benchmarks, which are target values set for stormwater sampling results. Permitted facilities must monitor for any benchmark parameter specified for their industrial sector. This benchmark data is primarily for facilities to determine the effectiveness of control measures.
In addition to sector specific benchmarks, Impaired Stream benchmarks are included in the permit. Every facility needs to evaluate if their receiving water, within 1 mile of each outfall, is impaired, even if it was not classified as impaired in the previous permit. An exceedence of these sector or impaired stream benchmark values is not a violation; however, the facility will be required to evaluate administrative and physical controls used to reduce stormwater pollution and take feasible corrective actions.
If, during a site inspection, unauthorized discharges are observed, or a facility determines that control measures need to be added or modified, the need for corrective actions must be reviewed. Within 24 hours of discovery of these unauthorized discharges or incidents of non-compliance, a facility must identify and document any triggering conditions, descriptions of the problems, and the date the problem was identified. Within 30 days of discovery, facilities must document a summary of the corrective actions to be taken, the date(s) the corrective actions are initiated, and the date(s) the corrective actions are expected to be completed. Modifications must be made no more than 90 days after discovery.
There are several other important aspects of the new permit that will affect industrial activities. A few of these components are:
- Vehicle and equipment wash water is considered an unauthorized non-stormwater discharge. If a facility is currently washing vehicles and equipment outside, that is not approved under this permit, and the facility will have to come up with a course of action for disposal.
- Waste pile leachate, over de minimus amounts, is also considered an unauthorized non-stormwater discharge and is not eligible for coverage under this permit.
- All employees who work in the areas where industrial materials or activities are exposed to stormwater must be properly trained. It is required that training be conducted at time of hire and refreshed annually for existing employees.
- Smoke/Dye testing must be performed at least once during the permit cycle to evaluate for the presence of non-storm water discharges into the storm sewer system from all floor drains, and from all sinks in industrial areas (excluding eye wash stations) that were installed prior to January 2006.
We have already begun updating the SWP3s for a number of our clients.
Please contact CTI if you have any questions or would like assistance in bringing your SWP3 and facility into compliance with the new permit.