Staying in Compliance with Your General Stormwater Permit

What is the General Stormwater Permit?

Most facilities that conduct industrial activity exposed to stormwater are familiar with the NPDES Industrial Storm Water General Permit and are aware that it is issued by the Georgia Environmental Protection Division (EPD). The current General Stormwater Permit was issued in March 2017 and will continue through May 2022. This is the earliest effective date for reissuance of the permit. Facilities with a permit are authorized to discharge stormwater associated with industrial activity to the waters of the state of Georgia in accordance with the limitations, monitoring requirements and other conditions set forth in the permit.

What is the Storm Water Pollution Prevention Plan?

The Storm Water Pollution Prevention Plan (SWP3) is intended to document the selection, design, and installation of control measures. Facilities must implement and maintain provisions of the SWP3 as a condition of the permit. The SWP3 must be prepared in accordance with good engineering practices, to industry standards, and must be certified by an individual with the education, experience, and accountability necessary for its implementation. This plan includes the facility’s Pollution Prevention Team, a site drainage map, a summary of potential pollutant sources, descriptions of control measures, schedules and procedures, and signature requirements. The SWP3 should be updated with any facility changes and include any ongoing new inspections, corrective action reports, and sampling results.

Routine Facility Inspections

At least once per quarter, the facility must undergo a routine facility inspection in accordance with the general permit. Inspections should be conducted in all areas of the facility where industrial materials or activities are exposed to stormwater. The inspections should also examine all stormwater control measures used to comply with the effluent limits. Routine inspections must be conducted at least quarterly, although in many instances, more frequent inspections may be appropriate for some types of equipment, processes, or areas of the facility with significant activities and materials exposed to stormwater. According to the current version of the permit, at least one inspection must be completed while stormwater is discharging.

During the inspection, the following should be examined:

  • Is there any visible sheen in containment areas or discharging from Oil/Water Separators?
  • Industrial materials, residue or trash that may come in contact with stormwater
  • Leaks or spills from equipment, drums, tanks or other containers
  • Offsite tracking of industrial or waste materials, or sediment
  • Weather information and description of any discharges
  • Any control measures needing maintenance or repairs
  • Any failed control measures that need replacement
  • Any additional control measures needed to comply with the permit

The findings of each routine facility inspection performed needs to be documented and maintained onsite with the SWP3, for at least the period of the permit. Routine facility inspections are not submitted to the EPD, unless specifically requested to do so.

At a minimum, the documentation of each routine facility inspection should include:

  • The inspection date and time
  • The name(s) and signature(s) of the inspector(s)
  • Weather information and a description of any discharges occurring at the time of the inspection
  • Any previously unidentified discharges of pollutants from the facility for the previous three years
  • Any control measures needing maintenance or repairs
  • Any failed control measures that need replacement
  • Any incidents of noncompliance observed
  • Any additional control measures needed to comply with the permit requirements

Exceptions for Routine Facility Inspections

The requirement to conduct routine facility inspections on a quarterly basis does not apply at a facility that is inactive and unstaffed, as long as there are no industrial materials or activities exposed to stormwater. Such a facility is only required to conduct an annual comprehensive site inspection. To invoke this exception, permittees must maintain a statement in the SWP3 indicating that the site is inactive and unstaffed, and that there are no industrial materials or activities exposed to precipitation. The statement must be signed and certified. If circumstances change and industrial materials or activities become exposed to stormwater or the facility becomes active and/or staffed, this exception no longer applies, and the permittee must resume periodic (at least quarterly) facility inspections as soon as possible.

Quarterly Visual Inspections

An “Outfall” is the most downstream point on an industrial property where stormwater discharges to waters of the State. It does not include cross-drain structures or culverts installed under a road that function only to maintain the natural flow of surface waters and drainage. However, a structure that collects or diverts drainage that has contacted road surfaces for discharge into waters of the State is considered an outfall.

Once each quarter for the entire permit term, a stormwater sample must be collected from each outfall and a visual assessment must be conducted. The visual assessment must be made:

  • Of a sample in a clean, clear glass or plastic container and examined in a well-lit area.
  • On samples collected within the first 30 minutes of a qualifying rain event. If it is not possible to collect the sample within the first 30 minutes, the sample must be collected as soon as possible after the first 30 minutes, and the permittee must document why it was not possible to take a sample within the first 30 minutes.
  • For storm events, on discharges that occur at least 72 hours from the previous discharge

The permittees must visually inspect the sample for the following water quality characteristics:

  • Color
  • Odor
  • Turbidity
  • Oil Sheen
  • -Settled Solids
  • Suspended Solids
  • Foam or Scum
  • Floating Solids
  • Any other indicator of stormwater pollution

If you see any of the above contaminates or characteristics, corrective actions should be taken and documented and maintained onsite with the SWP3. At minimum, documentation of the visual assessment must include:

  • Sample location(s);
  • Sample collection date and time, and visual assessment date and time for each sample;
  • The name(s) and signature(s) of the inspector(s) collecting the sample and performing the visual assessment;
  • Nature of the discharge (i.e., runoff or snowmelt);
  • Results of observations of the stormwater discharge;
  • Probable sources of any observed stormwater contamination;
  • If applicable, why it was not possible to take samples within the first 30 minutes.

Exceptions for Quarterly Visual Assessments

If adverse weather conditions prevent the collection of samples during the quarter, a sample must be taken during the next qualifying storm event. Documentation of the rationale for not making a visual assessment for the quarter needs to be filed with the SWP3 records. Adverse weather conditions are those that are dangerous or create inaccessibility for personnel.

Quarterly visual assessments are not required for facilities that are inactive or unstaffed, as long as there are no industrial materials or activities exposed to stormwater.

If a facility has two or more outfalls that the permittee believes to discharge substantially identical material, the permittee may conduct quarterly visual assessments of the discharge at just one of the outfalls and report that the results also apply to the substantially identical outfall(s). This is provided that a visual assessment is performed on a rotating basis of each substantially identical outfall throughout the period of coverage under the permit.

Annual Comprehensive Site Inspection

These annual inspections differ from the quarterly inspection in that they review and consider previous years visual and analytical results. The comprehensive inspection includes all of the items in the routine inspections in addition to the determination if erosion and sediment control measures are adequate and if additional control measures are required. The inspection ensures control measures (Best Management Practices) required by the permit are functioning correctly. During the inspection, all the outfalls are visually evaluated for the presence of non-stormwater discharges and a certification is completed detailing the evaluation.

Permittees must document the findings of each annual comprehensive site inspection and maintain this documentation onsite with the SWP3 as required in the permit. At a minimum, the annual comprehensive site inspection must include:

  • The date of the inspection
  • The name(s) and title(s) of the personnel making the inspection
  • Observations related to implementing control measures including:
    • previously unidentified discharges from the site
    • previously unidentified pollutants in existing discharges
    • evidence of, or the potential for, pollutants entering the drainage system
    • The condition of and around the outfall
    • additional control measures needed to address any conditions requiring corrective action identified during the inspection
  • Any required revisions to the SWP3 resulting from the inspection
  • Any incidents of noncompliance observed or a certification stating the facility is in compliance with this permit
  • A statement signed and certified in accordance with Appendix B.7 of the permit

Corrective Actions

If any of the following conditions occur, the selection, design, installation, and implementation of control measures should be reviewed and revised to eliminate the adverse condition as well as ensure that it will not be repeated in the future:

  • An unauthorized release or discharge occurs at the facility
  • A discharge violates a numeric effluent limit
  • A permittee becomes aware or the EPD notifies that existing control measures are not sufficient
  • An inspection or evaluation of the facility by an EPD representative or a representative of the MS4 (if applicable) determines modifications are necessary
  • Any inspection finds that control measures are not being properly operated or maintained

If a corrective action is required, the following must be completed:

  • Document discovery of corrective action conditions within 24 hours.
  • Document any corrective actions that are implemented or why corrective action is not needed.
  • Initial Action – As soon as practicable and take reasonable steps to minimize or prevent discharge of pollutants until the corrective action is complete.
  • Subsequent Actions – If additional actions are needed, they must be implemented by the first storm event, and within 30 days of discovering the condition.
  • If it is not possible to complete a corrective action within 30 days, you must document why in your Storm Water Plan. If the corrective action takes longer than 90 days to implement, you must notify the EPD.

Reporting:

The EPD uses an electronic method of reporting called the Georgia EPD Online System (GEOS). This allows for the submittals of Notice of Intents (NOIs), No Exposure Exclusions (NEEs), Annual Reports (ARs), and Notice of Terminations (NOTs) electronically. Failure to submit reports and notifications is considered a violation of the permit. Annual reports must be submitted annually by January 31st.

Additional Required Reporting:

 24-hour reporting – Permittees must report any noncompliance which may endanger health or the environment. Any information must be provided orally to Georgia’s Emergency Response Network (ERN) at 1-800-241-4113 within 24 hours from the time the permittee become aware of the circumstances.

  • Five-day follow-up reporting – A written submission must also be provided within five business days of the time the permittee becomes aware of the circumstances.
  • Reportable quantity spills – The permittee must provide notification, as soon as the permittee has knowledge of a leak, spill, or other release containing a hazardous substance or oil in an amount equal to or in excess of a reportable quantity.
  • Other information – The permittee must promptly submit facts or information if they become aware that they failed to submit relevant facts in an NOI or that they submitted incorrect information in the NOI or in any report.
  • The permittee must submit, within 30 days after the request, results of required monitoring when specifically requested by EPD.

 Recordkeeping

Retain the SWP3 and all related documents for a period of at least three years after the date that coverage under the permit expires. The following are a summary of the compliance activities that are ongoing and need to be maintained with the SWP3:

  • Implemented administrative controls (minimize exposure, good housekeeping, employee training, etc.)
  • Installed and maintained engineering controls (pollution, erosion, and sedimentation controls)
  • Routine facility inspections
  • Quarterly visual assessments
  • Stormwater monitoring based on industry-specific and impaired stream sampling requirements
  • Completed corrective actions
  • Completed Annual Comprehensive Site Inspections
  • Annual Reports

How can CTI help?

Conversion Technology Inc. (CTI) has decades of experience in Stormwater Permitting conducting Stormwater Inspections with our staff of knowledgeable engineers with expertise in the field. Additionally, we will be reviewing the 2022 General Stormwater Permit as soon as it is released, as well as are on the committee discussing the permit changes, to determine if there are any major changes to the Stormwater Permit requirements.

We offer the following, and many more, consulting services for Stormwater:

  • Design, Implementation, and Installation of Storm Water Pollution Prevention Plans
  • Routine Facility Stormwater Inspections
  • Annual Comprehensive Site Inspections
  • Storm Water Sampling and Analysis
  • Annual Reporting

Please feel free to contact us if your facility is in need of Stormwater consulting to discuss the aforementioned services or if you have any questions regarding the Storm Water Permit or Inspections at your facility.

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