With the release of the 2012 Industrial General Stormwater Permit (IGP) the Georgia Environmental Protection Division (EPD) introduced the Smoke and Dye Testing requirement for any facility with sinks and floor drains in industrial areas that were installed prior to 2006. This requirement was rolled over into the 2017 IGP when it was released in June 2017 that all applicable permittees should conduct the Smoke and Dye Testing prior to the end of the permit cycle which is schedule to be May 30, 2022.
Most permittees’ first exposure to the Smoke and Dye Test requirement is item 10 on their Annual Report that states, “Has the facility performed a smoke, dye, or equivalent test?”; however, there is not ample information from the EPD as to what is required to satisfy this condition of the IGP as well as why a permittee is required to conduct the testing in the first place.
The intent of the Smoke and Dye Testing requirement is two-fold. Firstly, it is to ensure that sinks and drains do not end in storm water drainage systems (i.e. storm water retention/detention ponds, drainage ditches, storm water drop inlets, etc.). Secondly, this requirement is to determine if old underground pipes, pits, and sumps are compromised and leaking possible process waters and other non-storm water discharges into storm water drainage systems.
A Smoke and Dye Test is conducted by either blowing non-hazardous aerosol smoke into an outlet pipe or floor drain, or dye is introduced into a sink or floor drain and mixed with water. Typically, if a permittee has floor drains in a process area where aerosol materials could negatively impact the quality of their product, dye testing is conducted in these areas. Permittees should double check industrial areas such as warehouses, process lines, maintenance areas, boiler rooms, and labs determine if there are any sinks or floor drains present. A facility can have no sinks or floor drains in industrial areas, but if there are janitorial closets that service industrial areas, the mop sink will need to be tested.
Are there exemptions?
Yes, there are several exemptions for a facility to not test specific drains and/or avoid sampling completely during this permit cycle.
- Sinks or drains that were installed after 1/1/2012
- Sinks or floor drains associated with non-industrial areas, such as bathrooms, breakrooms, and offices
- Floor drains associated with eye-wash stations
- Areas that have confirmed as-built drawing within the last 5 years
- If a test was conducted during the 2012 IGP permit cycle
If the permittee uses the first exemption, where sinks, floor drains, or even the entire facility was installed/constructed after 1/1/2012, then there is a high probability that the permittee will be required to conduct a smoke and dye test in future permit cycles.