Storm Water Permit Compliance

Susan Murphy

Storm Water: To See or Not To See…

We submit aNotice of Intent for Coverage

(NOI)

Prepare and Implementa SWP3

State issues a General Permit

For select industries (SIC codes)

Storm Water: To See or Not to See What does your Storm Water Pollution

Prevention Plan look like?

Storm Water: To See or Not to See-- Is there a drum or tote of material stored outside at your facility right

now, that could be moved inside?

If something is observed that could cause storm water exposure during an inspection, do you have a formal way to correct both the ‘something’ and the SWP3 within a few days?

Have you personally gone and performed a facility wide SWP3 inspection while it was raining this year?

If you were to take and hold a water hose, directing it into a storm drain (or onto the pavement), do you think someone would come question if that is ok to do?

Would plant personnel ask you first if it is O.K. to water test an empty tank and then drain the water onto the ground?

Does your facility storm water inspector look beyond the checklist and write down other things that you should consider adding to the SWP3?

The Easy Stuff

Read your permit Dates, documentation requirement,

inspection frequency, certification frequency, signatory requirements, update requirements, state general permit expiration

The Harder Stuff

SWP3 requirements

BMPs – did you inherit this Plan (so it must be ok)?

EASY

The Logic of Protecting Storm Water from an Industrial Activity

Hierarchy:

*** Move it inside, under cover****

1. Engineer the exposure away

2. Housekeeping/procedures (SOPs)

3. Inspections

Creating a BMP

Let’s do an exercise—

Industrial Activity: Used Oil Pickup

Apply the Hierarchy:

1 Engineer the Exposure Away

2 SOP

3 Inspect

A Bit about Storm Water Sampling…

Sampling Procedure

Sample Frequency

Sample Preservation/COC

Results—what they mean

What should you do with your results?

Permit Renewals May Not Be Business As Usual… EPA’s changed General Permit

requirements Construction General Permit

Some state changes are happening now What could happen if you lose your

General permit coverage (we miss a renewal, poor inspection report, no reason at all)

Georgia Example 127 page General Permit Benchmarking—By Industrial Sectors

Quarterly thorough inspection (and specific documentation!!)

Annual Report certifying whether you missed any inspection dates, and sample results must be attached

30 day corrective action after a release

Storm Water Summary

Read your state regulation, know if your local area has additional requirements

Complete all documents on time Update your SWP3, especially your

Industrial Activity List and your Inspection list (hand written changes are fine! ) Remember—your inspector may have a copy of the EPA Sector Guidance!

Storm Water Summary (cont’d) Sampling results—share results,

resample if necessary, document unusual circumstances

Construction Projects on our Site ARE our responsibility

If you need help, just Holler