Georgia Industrial Stormwater General Permit Renewal Update
Posted on January 11, 2012
On January 10, 2012, Environmental 360, Inc. (Environmental 360) attended a training session held by the Georgia Department of Natural Resources Environmental Protection Division regarding the changes that will be implemented as a part of the 2012 Industrial Stormwater General Permit (IGP).
To assist you in your future planning efforts for your facility, Environmental 360 would like to take this opportunity to inform you of the anticipated timeline for coverage under this permit as well as prepare you for some of the more significant differences between the 2006 IGP and the upcoming 2012 IGP.
The following information about the 2012 IGP is only meant to inform you of what is currently being proposed and is based on the currently available proposal, which may undergo slight revisions prior to issuance. Until the 2012 IGP is officially issued, everything below should be viewed as tentative. All currently proposed documents can be found at http://www.gaepd.org/documents/industrialstorwater.html
Proposed IGP Timeline & Coverage
The new 2012 IGP will be called General Permit No. 050000. All those who have a 2006 IGP are required to continue to comply with the 2006 IGP. Those facilities that require a new permit cannot apply for a 2006 or 2012 IGP at this time. They are encouraged to follow requirements of the 2006 IGP until the 2012 IGP is issued. The following is the proposed 2012 IGP Issuance Timeline as well as some milestones that must be met after issuance.
Issue for 3rd public notice on 1/17/2012
Comment period 1/17/2012 to 2/17/2012
Review comments and issue permit (if possible) on 3/15/2012
Permit’s effective date will be 45 days after issuance.
Notice of Intent (NOI), No Exposure Exclusion (NEE), and No Discharge Exclusion (NDE) are all due 30 days after effective date.
Due to the delay in the issuance of this permit, the next Annual Report Deadline will be January 31, 2014 which will cover the rest of the 2012 reporting year and all of the 2013 reporting year.
For first time dischargers, a Storm Water Pollution Prevention Plan (SWPPP) must now be prepared prior to submitting an NOI.
For existing permitted facilities an updated SWPPP must be complete within 90 days of effective date of the 2012 IGP and any proposed modifications must be implemented within 180 days of effective date of the 2012 IGP
New Format, Forms, Checklists, and Requirements
The Permit’s format has been revised to be organized similar to EPA’s 2008 Multi-Sector General Permit (MSGP).
There are new sector specific requirements, benchmarks, and best management practices (BMPs) combining those from the 2006 IGP and the 2008 MSGP.
The NOI form has been revised to require the permittee to list the river basin where facility is located.
The NOI form has been revised to indicate SIC code that best represents the primary industrial activity of the facility.
If a facility discharges to a Municipal Separate Storm Sewer System (MS4), a copy of the NOI must be submitted to the MS4 concurrent with the submission to GA EPD.
MS4 Operators must document inspection of a minimum of 20% of the sites that discharge into their system, so be prepared and allow access to municipal inspectors if applicable.
There are new SWPPP requirements and a corresponding checklist that must be submitted with the Annual Report.
The Annual Report requires documentation of non-storm water discharges that occur on site.
There are new requirements for the SWPPP site map.
SWPPP’s are required to specifically address car, vehicle, and equipment washing as any discharge associated with these operations are not authorized and require a separate permit.
In order to document and provide absolute confidence where all existing drains discharge, a Smoke/Dye Testing will be required at least once during the permit period. All drains including floor drains and sinks in industrial areas must be tested. If a dye test or smoke test has been done at least once during the 2006 permit cycle, this requirement can be waived. This must be documented in the Annual Report. After testing, adequately updated and current “as built” drawings can be used to meet this requirement going forward.
All employees working within areas where industrial materials or activities are exposed to storm water are required to be trained at time of hire and retrained at least annually. Individual employee responsibilities must be maintained and kept current within the SWPPP. Rosters and documented training certifications are required to be maintained kept current within the SWPPP.
We hope that this summary has been helpful in keeping you informed of the upcoming changes. For additional information or assistance with complying with these requirements, please contact David Owen (David.Owen@environmental360.net) or Mitch Berkey (Mitch.Berkey@environmental360.net).
Source: E360 Old Site