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