Presentation on theme: "Storm Water Permit Compliance Susan Murphy. Storm Water: To See or Not To See… We submit a Notice of Intent for Coverage (NOI) Prepare and Implement a."— Presentation transcript:
Storm Water Permit Compliance Susan Murphy
Storm Water: To See or Not To See… We submit a Notice of Intent for Coverage (NOI) Prepare and Implement a 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