By John Pierson, P.E.
The approaching summer of 2017 marks 24 years since the first issued Georgia National Pollution Discharge Elimination System (NPDES) General Permit No. GAR050000 for industrial stormwater (2017 IGP or industrial general permit). Permittees are required to implement appropriate management practices to control discharged stormwater pollutants associated with facility industrial activity.
A site-specific stormwater pollution prevention plan (SWPPP) is still required for each facility covered by the permit. The SWPPP must include a detailed site map that shows stormwater drainage and proximity to identified materials and areas exposed to stormwater. As a result, best management practices (BMPs) are established followed by compliance training and monitoring on a recurring basis.
The 2017 IGP becomes effective June 1, 2017, and expires May 31, 2022. Patterned after the U.S. Environmental Protection Agency (EPA) MultiSector General NPDES Permit (2015 MSGP) for industrial stormwater issued June 4, 2016, it contains general permit information applicable to all industrial sectors. Detailed by facility Standard Industry Code (SIC), the permit has more specific requirements for each of 28 industrial sectors (e.g., Sector U: Food and Kindred Products). An Impaired Stream Segment Sampling remains as Appendix C.
Appendix C revisions include a change to the impaired stream benchmark for bacteria (fecal coliform) to 4,000 colony forming units (CFU) for winter or summer with a removal of the requirement for using the geometric mean for sampling outfalls. Also, scientific testing can be used to document that bacteriological constituents found in stormwater are not due to industrial activity (Part C.2.4.2). In addition, a Modified Optional Composite Sampling is available to allow the permittee to propose a sampling method to the Georgia Environmental Protection Division (EPD) for approval instead of the more specific requirements stated in the 2012 IGP (Part C.4).
More information is available at the EPD website (NPDES Industrial Storm Water General Permits – http://epd.georgia.gov/npdes-industrial-storm-water-general-permits). Of particular note is the EPD’s Industrial Facility Inspection Form, an Excel spreadsheet that provides a summary of the areas an inspector will review if the facility is visited.
Environmental managers should particularly note the importance of recording and documenting all activities conducted under the permit including control measures and procedures to prevent pollution. Similarly, the availability of data (date and time indicated) including analytical sampling performed during the 2012 IGP should be readily available.
Strategies to demonstrate that the SWPPP is an active document thought about often will go a long way toward a successful inspection during the 2017 IGP permitting period. Questions can be directed to Mike Giles at the Georgia Poultry Federation (email: firstname.lastname@example.org) or John Pierson at the Georgia Tech Research Institute (email: email@example.com).
John Pierson, P.E., is a principal research engineer in the Georgia Tech Research Institute’s Food Processing Technology Division. He leads the division’s environmental technical assistance program.
Key major changes in the revised 2017 IGP require that:
• A summary of all analytical sampling performed during the term of the previous permit (2012 IGP) be included in the SWPPP and retained until the end of the next permit term (Part 22.214.171.124).
• At least once during the term of the 2017 IGP, a dye, smoke, or equivalent test must be conducted to determine the presence of non-stormwater discharges into the storm sewer system, but only if alterations that impact stormwater were performed since the last test (Part 126.96.36.199.f.). Equivalent test methods include TV surveillance and analysis of as-built drawings and schematics.
• eReporting will be required during the term of the 2017 IGP. This will require electronic submittal of all forms, including the Annual Report (AR). Any required sampling results must be submitted by attaching a spreadsheet with the required data to the AR.