As I have reported here on the CTI’s blog in the past, the Georgia Industrial General Permit for Storm Water Discharges (GAR0500000) is in the process of being reissued. The format and requirements of the permit will be significantly modified, requiring facilities to update their Storm Water Pollution Prevention Plans (SWP3) and conduct additional actions required to comply with the new permit.
CTI has participated in the permit development since day one. This has included attending the stakeholder meetings, submitting written comments, attending the public hearing, and most importantly, staying in communication with the Georgia Environmental Protection Division (GAEPD) staff throughout the process. Through our participation, we have worked with several industry groups, including: the Treated Wood Council (TWC), Southeastern Lumber Manufacturer’s Association (SLMA), and the Institute of Scrap Recycling Industries (ISRI).
Because of CTI’s participation, we have helped reduce the burden on permitted facilities. Specifically, CTI’s comments have resulted in the follwing changes:
- The original permit did not allow discharges from material and waste piles. This was primarilly aimed at outdoor storage piles at wood products facilities (e.g. bark, sawdust and chip piles) and other industries. This has been removed from the permit, and now only discharges from "waste piles" is not allowed.
- The new permit requires smoke and dye testing of sinks and floor drains at facilities in order to verify they are not connected to the storm water system. Through CTI’s comments, exceptions and alternative options to comply with this requirement are in the permit.
- CTI’s comments during the stakeholder meetings helped the Recycling Industry succeed in removing Iron and Aluminum analysis requirements.
The most recent draft of the permit was issued on September 2nd, and a comment period was open until September 16th. I contacted the GAEPD today to inquire on the status of the permit, and they stated that based on the comments received, additional public hearings are not likely. The permit is expected to become effective this fall, with compliance dates coming by the end of the year. In my opinion, facilities can begin to update their SWP3s to be in compliance with the permit. In fact, we have already begun updating the SWP3s for a number of our clients.
Please contact me at (770) 263-6330 x 103, or bedwards@conversiontechnology.com, if you have any questions or would like assistance in bringing your SWP3 and facility into compliance with the new permit.
Brian Edwards, PE