The State of Georgia Environmental Protection Division (GAEPD), through its National Pollutant Discharge Elimination System (NPDES) Stormwater Permit Program, regulates storm water discharges to waters of the state that result from activities at a multitude of industrial sector facilities. This permit is required of most industrial facilities in Georgia and is based upon the provisions of both the Georgia Water Quality Control Act and the Federal Clean Water Act.
Beginning June 1, 2012 and extending for a period of five years, the General Permit (GAR050000) associated with these activities will be re-issued, and, upon submittal of a Notice of Intent (NOI), will authorize new and existing storm water point sources within Georgia to discharge storm water associated with industrial activities to waters of the state. The new permit outlines the types of facilities and their associated Standard Industrial Classification (SIC) codes that would fall under the purview of this permit.
This law was originally written and regulated by the federal level of government and is currently regulated on the state level. However, it is being increasingly regulated on a local government level, especially where these local governments have requirements to regulate the condition of all waters in their respective jurisdictions.
Substantial changes to this new permit will impact the various sectors that it regulates in a variety of different ways. Each sector may have additional suggested best management practices specific to that sector. The requirement to implement additional practices is based in large part on the types of pollutants expected to be present in storm water from that regulated industrial sector. Amongst the newly required practices is the requirement to sample a variety of water quality parameters that may typically be present on a given industrial facility site. The new permit has assigned benchmark calculations, and in some cases numeric effluent limitations, so that it is clear to regulators which sites are in compliance, and where violations to water quality parameters and the permit may exist. Applicants may also have to conduct a dye, smoke, or equivalent test in their storm water system.
One specific and notable aspect of this new permit relates to those regulated activities that are located within one mile of an impaired stream system (303b/305b). These facilities are required to monitor for certain parameters, and corrective action will be required if the discharge exceeds the benchmark value, pollutant of concern listed in the TMDL.
Below is a matrix describing the new storm water permit changes, how these changes may affect you and your industry, and what we can do to help.
|New IGP Change
||What does this mean to me?
||How can Woodard & Curran help?
|There are now 27 Industrial sectors required to comply.
||Yours may be one of the 6 new sectors now required to comply. In addition, your local jurisdiction may be getting pressured to monitor and enforce your activity.
||Let us work together to determine if your level of compliance, if you may re-categorized, or if you may be exempt from compliance entirely.
|New additional sector-specific best management practices.
||Based on your industrial activity, you may need to sample for additional pollutants specific to your industry.
||We can identify your additional sector-specific requirements and help navigate compliance.
|Pollutant benchmarks now have target values.
||Your facility will be held to a measurable standard of maintaining clean stormwater, and will no longer be assessed on a case by case basis. You may be able to establish your own benchmarks.
||Working together we can identify any possible concerns your site may be facing and potential regulations. We can also partner to establish your own benchmarks.
|Exceeding a benchmark now requires quarterly sampling and practice modifications.
||Additional resources may need to be used if the initial sampling exceeds the benchmark.
||We can assist you in scheduling and organizing your plan to minimize exposure.
|There are now 7 types of discharges with numeric effluent limitations.
||If a pollutant you are required to sample for has a numeric effluent limitation, and your facility fails compliance, you are in violation and the requirements increase substantially.
||Let us assist you in planning and implementing practices that will prevent possible violations.
|Conduct a dye, smoke, or equivalent test for presence of non-stormwater discharges.
||This new requirement that will likely require additional resources.
||Not all facilities will have this requirement. Let us tell you if it is needed at your facility.
|New requirement for facilities discharging to impaired streams.
||New permit now requires additional compliance measures if your facility discharges to any impaired stream, not just those with a TMDL Implementation plan.
||Let us tell you exactly what, if any impaired water is located within one mile of your site and how to effectively manage that proximity to avoid considerably more sampling.
|Discharges of pollutants to impaired streams will trigger a corrective action.
||A greater number of facilities will have the potential of discharging pollutants to a stream that is impaired. Such actions will trigger enforceable regulations.
||We can work with you in planning and implementing practices and sampling that will prevent possible corrective actions.
We can work with you in planning and implementing practices and sampling that will prevent possible corrective actions.
Compliance with this permit may require substantially greater cost and effort. If you are required to renew authorization or obtain new authorization under the 2012 General Permit, you will have 30 days from June 1, 2012 to submit a Notice of Intent, 60 days to update or create a Stormwater Pollution Prevention Plan, and 180 days to implement that plan. If you aren’t sure of your plan of action, please contact us and we can assist you in making this determination. Our team of environmental scientists and engineers specialize in agency coordination and compliance. We have fulfilled storm water discharge permit requirements for industrial clients across Georgia and, under EPA’s similar Multi-Sector General Permit, across the nation.
For more information please contact Marcus Rubenstein at firstname.lastname@example.org or 770.622.6766.