Does My Facility Need a Stormwater Permit?

Does my facility need a stormwater permit? This video describes why stormwater runoff from industrial sites is a problem and the types of facilities that need coverage under a stormwater permit. So let’s get started! Why is stormwater runoff a problem? Runoff from rainstorms and snowmelt picks up pollutants like sediment, oil and grease, nitrogen, phosphorus, and other chemicals and carries them into storm drains or directly into nearby rivers, lakes, or coastal waters. Because most storm drain systems do not provide any treatment to the water they collect, preventing contamination of stormwater is critically important. Otherwise, polluted runoff will end up in the waterbodies we use for swimming, fishing, and drinking. EPA’s National Pollutant Discharge Elimination System (NPDES) program regulates stormwater runoff from industrial facilities. Federal regulations require stormwater discharges associated with specific categories of industrial activity to be covered under NPDES permits (unless otherwise excluded). The 11 categories of regulated industrial activities are: 1. Facilities subject to federal stormwater effluent discharge standards 2. Heavy manufacturing (e.g., paper mills, chemical plants, petroleum refineries, steel mills and foundries) 3. Coal and mineral mining and oil and gas exploration and processing. 4. Hazardous waste treatment, storage, and disposal facilities 5. Landfills, land application sites, and open dumps with industrial wastes 6. Metal scrapyards, salvage yards, automobile junkyards, and battery reclaimers 7. Steam electric power generating plants 8. Transportation facilities that have vehicle maintenance, equipment cleaning, or airport deicing operations. 9. Treatment works treating domestic sewage with a design flow of 1 million gallons a day or more 10. Construction sites that disturb 5 acres or more 11. Light manufacturing (e.g., food processing, printing and publishing, electronic and other electrical equipment manufacturing, public warehousing and storage) Of these 11 categories, construction sites that disturb five acres or more are generally permitted separately because of the significant differences between those activities and other types of industrial activities. So, how is coverage initiated and who has responsibility? Most states are authorized by the EPA to administer the NPDES stormwater permitting program, and most industrial facilities will need to obtain NPDES permit coverage through their state. The operator is the entity (generally the company, corporation, etc.) that has operational control over the industrial activities or has day-to-day operational control of activities at the facility necessary to implement a plan to control pollutants in stormwater runoff. First, the “operator” submits a Notice of Intent (NOI) application which includes the plan to control pollutants in stormwater, called a Stormwater Pollution Prevention Plan (SWPPP). It is a written document that identifies the sources of pollution and industrial activities conducted at the site, and outlines stormwater control practices which the operator will use to prevent pollutants from making their way into stormwater runoff. The operator is responsible for developing, implementing, and maintaining the “best management practices,” or stormwater control measures, outlined in the SWPPP. These include swales, silt fences, detention ponds, spill protection equipment, schedules of activities, prohibited practices, and maintenance procedures that you use to prevent or reduce the discharge of pollutants. The SWPPP must also be updated as any time practices or conditions at the industrial facility change. In Summary: Determine whether your facility is eligible for coverage under an NPDES permit for stormwater. Develop a Stormwater Pollution Prevention Control Plan. Submit a Notice of Intent application with the State authorized regulatory authority. Once you receive coverage, it is crucial that you thoroughly read and understand your permit and implement your SWPPP. For help getting started, or for questions about stormwater permits, contact us at UA SafeState. We're here to help!