Industrial Storm Water Permit and Georgia’s Poultry Industry
Definitions used to establish water quality standards
Designated uses of a water body (e.g., recreation, water supply, aquatic life, agriculture) and the difference between designed uses and existing uses. This module touches on options available to states/tribes in defining designated uses.
Water quality criteria to protect designated uses (numeric pollutant concentrations and narrative requirements). This module addresses the purpose of water quality criteria, the different types, and how they are expressed.
Antidegradation policy to maintain and protect existing uses and high-quality waters. This module considers requirements in addressing antidegradation questions and what EPA looks for in its review of a state/tribe’s antidegradation policy.
A variety of activities have been underway since November 2010, preparing for the proposed update to the general permit for storm water discharges from industrial activities. For most facilities, those activities have focused on refining storm water pollution prevention plans (SWP3), sampling, and attending industry-related meetings to discuss storm water management best practices. The result has been a concerted effort by the Georgia poultry industry to develop definitive approaches for ensuring that storm water discharges associated with poultry and allied industrial activities exceed water quality standards.
As part of this effort, researchers with the Georgia Tech Research Institute (GTRI) evaluated the possible statistical correlation between fecal coliform and total suspended solids levels in storm water discharges from poultry processing facilities; this correlation was specific to animal handling facilities. Efforts included education, on-site research, and technology assessments, culminating in a report to be considered by the Director of the Georgia Environmental Protection Division (EPD). The report was prepared sufficiently in advance for consideration during the drafting of the subsequent storm water permit for industrial activities.
The proposed National Pollutant Discharge Elimination System (NPDES) General Permit GAR050000 for storm water discharges associated with industrial activities contains significant additional requirements for animal handling facilities. These requirements are magnified for those locations that discharge into an impaired stream segment within one linear mile upstream of and in the same water shed as any portion of an impaired stream segment. Of particular note are the best management practices (BMPs) included in the language of the permit that are designed to reduce fecal coliform levels in storm water runoff from animal processing facilities that may be potential sources of fecal coliform. While specific to the animal handling industry, the permit notes that these may be beneficial for other industrial sectors.
While the industry continues to review the proposed permit and examine the best approaches for continuing its dedication to environmental stewardship, it is interesting to step back and look at the larger national storm water challenge. Here, small, medium, and large municipalities are also developing storm water management programs for their separate storm sewer systems (MS4s); construction sites are facing effluent limit guidelines (ELGs); and state Departments of Transportation (DOTs) are facing general permits similar to those faced by industry.
And as of June 2011, federal authorities are soliciting stakeholder input to assess whether existing storm water requirements should be revised, and if so, how and to what extent.
All of these requirements are NPDES-based, as the associated storm water discharges are now considered point sources. This is particularly relevant as urbanization captures many previous nonpoint sources via MS4s. The result for impaired streams is a total maximum daily loading (TMDL) water quality standard even though sources discharging under a general or individual NPDES permit are often meeting an effluent limit guideline or other numeric limit using technology-based standards.
If storm water management is to truly be an integral part of the broader “preservation of water quality” goal, a better understanding is needed regarding the maximum amount of pollutant that a water body can receive and still meet water quality standards, particularly with respect to the desired margin of safety or ambient background loads. Here, defining reference conditions seems reasonable, but that practically puts the process back to the initial definitions used to establish the water quality standards (designated use, water quality criteria, and antidegradation policy–see box). One often cited option is to change the designated use through a Use Attainability Analysis (UAA) if water quality standard targets are unattainable and then establish site-specific criteria. For impaired waters such as those that are headwaters to larger surface drinking water sources, this may not be possible even if the land uses along the stream banks are long-established low-density residential, much less industrial, municipal, or transportation. Yet, concerned citizens are monitoring streams adjacent to processing facilities long since idle, and associating coliform levels that exceed water quality standards with that facility.
Short of site-specific criteria, broader regional watershed management, or strategies based on non-numeric effluent guidelines, iterative BMPs can play a key role toward meeting water quality standards, which brings us back to the proposed, updated permit. The preliminary analysis examining the correlation of TSS and fecal coliform for storm water outfalls at poultry processing facilities in Georgia indicated that the TSS benchmark has been broadly achieved through the use of iteratively implemented BMPs. However, the original correlation between TSS and fecal coliform (r2=0.6066) was not consistently replicated over the entire set of data pairs.
Thus, moving forward, the industry must remain vigilant with regard to BMPs included in SWP3. It is also important to continue supporting on-site research, educational seminars to better understand technology assessments, and industry activities where information can be shared. The industry should also communicate poultry facility stewardship initiatives and engage the active participation of community groups truly interested in preserving water quality. This type of outreach can build the relationships needed to find technology-based solutions and drive water quality standard effluent limits needed to manage storm water in a cost-effective manner. Future university efforts include seminars, workshops, and other outreach activities related to the permit as well as research initiatives that include working with industry during the life of this next permit.
John Pierson is a principal research engineer in the Georgia Tech Research Institute’s Food Processing Technology Division. His areas of expertise are wastewater pretreatment alternatives, environmental control systems, pollution control, and biofuels. He can be contacted by email at firstname.lastname@example.org.