DEP issues revised general permit for management of storm water at industrial sites
By DEP
New features include specific criteria for certain industry sectors, additional monitoring, protection of impaired waters and requirements for public notice
To achieve greater consistency with policies of the U.S. Environmental Protection Agency (EPA), the Connecticut Department of Environmental Protection (DEP) has revised the requirements for management of storm water runoff from industrial sites under its General Permit program.
“The revised General Permit addresses EPA’s concerns and the growing awareness within Connecticut that contaminants in storm water runoff impact the quality of our lakes, rivers, and streams,” said DEP Commissioner Amey Marrella. “In developing the revised General Permit, DEP staff worked with both the regulated community and environmental advocates to identify cost-effective steps to monitor and manage storm water runoff at industrial sites.”
Curt Spalding, regional administrator of EPA’s New England office, said, “"Across New England, EPA is increasingly focused on reducing the amount of pollutants which are carried in storm water into our rivers, lakes and other water bodies. Addressing pollution in storm water will help Connecticut to better meet the requirements of the federal Clean Water Act, thus helping to ensure a healthy environment. Cleaning our waters and keeping them clean means addressing not only major stationary sources, but also nonpoint sources like storm water."
The revised industrial storm water General Permit is scheduled to go into effect Oct. 1, 2011. DEP is in the process of reissuing the existing General Permit so that it will remain in effect until that date. Industrial facilities will automatically remain registered under the existing General Permit once it is reissued. All industrial facilities are required to register for the revised permit by June 1, 2011. This date was proposed by industry stakeholders as a timeframe by which permittees can meet the program requirements. To provide compliance assistance to permittees, DEP will conduct outreach on new permit requirements in the fall of 2010.
There are currently about 1,500 sites registered for an industrial storm water General Permit.
Information about the hearing final decision and the new General Permit can be viewed at www.ct.gov/dep/stormwater
DEP uses both individual and general permits to regulate activities. Individual permits are issued directly to an applicant for a site specific activity – such as a water discharge. General permits are issued to streamline the permitting of a category – such as discharging storm water – which exists at many sites.
Under the General Permit program for storm water discharges, industrial facilities are required to “register” for the General Permit by submitting a registration form, and preparing and implementing a Pollution Prevention Plan (PPP). The plan must include information about the site, an inventory of exposed materials, a summary of potential pollutants, a description of and schedule for implementation of storm water control methods, storm water monitoring, and site inspection.
The most significant new requirements of the General Permit for management of storm water at industrial sites include:
Sectors:
While provisions of the General Permit apply to all sites, there are now additional sector-specific requirements for monitoring and controlling contaminants that are likely to be present at specific types of industries. The sectors are: asphalt plants; non-metallic mines and quarries; refuse systems; auto salvage yards; scrap recycling facilities; steam electric power facilities; transportation and public works facilities; marinas and yacht clubs and boat dealers; ship and boat building and repair; small scale composting facilities. This approach is more consistent with EPA’s specific sector-based permit requirements.
Monitoring:
The revised permit requires all permittees to conduct visual monitoring of storm water discharges on a quarterly basis and sampling and testing of storm water for 10 common parameters on a semi-annual basis – as opposed to the current annual requirement. In addition to these standard requirements, the 10 industry sectors listed above have additional parameters that are specific to the industry type, which must be sampled. This monitoring is necessary to determine the quality of the storm water discharge and to determine if the control measures used at a site are adequate. One cost-effective change to the revised permit allows for a reduction in continued monitoring requirements for any parameter demonstrated to meet established benchmarks.
Impaired waters:
The revised permit includes specific requirements for discharges to impaired waters. For existing discharges, a permittee will monitor annually for the pollutant(s) associated with the water impairment. In certain cases, a permittee will have to install additional site controls to improve storm water quality so that the impaired water quality can be improved. New discharges to impaired water will be authorized if the storm water discharge doesn’t contain the pollutant(s) of concern, or if the site prevents the exposure of the pollutant(s) of concern to storm water. However, if the pollutant(s) are present onsite and exposed to storm water, the registrant must demonstrate that the discharge meets requirements in place to meet water quality before the discharge can occur.
Public Notice:
The General Permit creates expanded opportunities for public comment and access to information about pending registrations. PPPs can also be reviewed, with the exception of elements that are trade secrets or otherwise exempt from the disclosure requirements of the state Freedom of Information Act. Notice of pending registrations and the availability of PPPs for a site will be posted on the DEP website at www.ct.gov/dep for public review and comment. These steps are in keeping with court rulings that determined opportunities for public access and comment are required under the federal Clean Water Act.
