Georgia's Industrial Storm Water Permit: Is Your Plant in Compliance?

Research Intern Arnaud Escoffier tests the prototype Intelligent Deboning System, which researchers believe will allow automated deboning systems to match if not exceed the yield and quality performance of the best manual deboning processes.

John Pierson, GTRI principal research engineer, inspects outdoor equipment for solids and other contaminants. As part of Appendix C of the General Permit (Tier I BMPs), poultry processors should remove solids and other contaminants on vehicles and equipment prior to long-term storage in outdoor areas (e.g., bone yards). See Appendix C for the complete BMP List for Animal Processing Plants.

This past June marked the third anniversary of the reissued State of Georgia (GAR000000) general permit for storm water discharges from industrial activities. As expected, during these three years, the U.S. Environmental Protection Agency (EPA) approved Georgia's 2006 305(b)/303(d) List of Waters (impaired stream segments). With two years remaining until the general permit is set to expire, analysis of the data collected by facilities regarding the impact of animal processing activities on impaired streams is expected to begin. For the poultry industry, these milestones are a reminder to review existing storm water pollution prevention plans (SWP3) to ensure that monitoring requirements are up-to-date and that best management practices (BMPs) are working.

In past years, a reminder such as this might have involved dusting off the binder holding the SWP3, especially given the recent dry weather patterns. However, the return of more normal rainfall patterns combined with the new general permit has created extra requirements that impact all animal handling/meat processors. Processors located within the proximity of any impaired streams also have additional sampling requirements if the pollutant of concern for the stream segment is fecal coliform.

All poultry processors require some storm water sampling that must begin no later than 90 days after the effective date of the permit or the date the facility becomes subject to the sampling requirements in Part III.C of the permit. However, with proper notification to the state, a facility may delay initiation of its sampling program for no more than 12 months if time is needed to design and implement new or improved BMPs, specifically for the pollutant(s) of concern as determined from the review of the existing SWP3.

As such, poultry processing facilities should conduct an annual sampling of their storm water discharges associated with industrial activity. Analytical testing is also required for five-day biochemical oxygen demand (BOD5) (mg/l), oil and grease (mg/l), total suspended solids (TSS) (mg/l), total kjeldahl nitrogen (TKN) (mg/l), total phosphorus (mg/l), pH, and fecal coliform (colony forming units or CFU per 100 ml). This includes facilities with storm water discharges from animal handling areas, manure management (or storage) areas, and production waste management (or storage) areas that are exposed to precipitation at meat packing plants, poultry packing plants, and facilities that manufacture animal and marine fats and oils.

Facilities should revisit Georgia's 2006 305(b)/303(d) List of Waters to establish which locations are impacted by the impaired stream segment requirements. If a location meets the permit's Part III.C.1 criteria, storm water discharge sampling for TSS twice per quarter for a period of 12 months should be underway. Two of the sampling events must include simultaneous testing of TSS and fecal coliform. The sampling will only be required for those outfalls at the facility that have the potential to discharge storm water associated with industrial activity where industrial materials or activities that are potential sources of fecal coliform (as defined in Part IV.D.9 of the permit) are, or may be, exposed to storm water at the facility during the term of the permit.

If a facility is unable to conduct one or both of the Part III.C sampling event(s) during a certain quarter due to adverse climatic conditions (i.e., no qualifying rainfall event occurs), then the facility shall include a written explanation for the absence of the sampling event in the next Annual Report submitted to the Georgia Environmental Protection Division (EPD). A summary of the sampling results for TSS and fecal coliform must be submitted to EPD's Watershed Protection Branch with the Annual Report (see Appendix B of the permit). The report must also identify the applicable benchmark value(s) and state whether the facility has passed or failed the benchmark requirement for the 12-month sampling period.

Finally, facilities should revisit the BMP List for Animal Processing Plants listed in Appendix C of the permit. These individual or combined BMPs serve as part of an iterative process established in the permit that allows permittees to implement new BMPs and test the performance of these BMPs against the benchmark. Analyzing your results in terms of the BMPs you have in place provides a valuable final check of how well your SWP3 is working. Georgia Tech researchers anticipate sending out a survey asking which practices are being used by animal processing facilities to minimize discharges into impaired streams so that once data collected regarding TSS and fecal coliform is analyzed, the most effective BMPs can be shared.

Reporting of Required Sampling Results

Except as provided in Part III.C, Part IV.D.4.c, Part IV.D.4.d, Part V, and Part VI.C.2, the permittee is not to submit sampling results or certifications to the Georgia Environmental Protection Division (EPD), unless required in writing by EPD. The following summarizes reporting requirements.

Permit Reference

 

Required Sampling Results Reporting

Part III.C: Discharges into Impaired Streams

 

Submit to EPD with Annual Report. Due at the end of 14th month, then annually (after the beginning of the first quarter in which sampling is required).

Part IV.D.4.c: Annual Report

 

Due at the end of 26th month, then annually (after the beginning of the first quarter in which sampling is required).

Part IV.D.4.d: Noncompliance with the Permit

 

As needed by permittee within 30 days; oral report within 24 hours and written within 5 days if an incident endangers health or the environment.

Part V

 

Not applicable to poultry processing.

Part VI.C.2: Animal Handling/Meat Processing Annual Sampling and Reporting

 

At least annually (once per calendar year); see general permit for sampling waivers and multiple outfalls.

 

PoultryTech is published by the Agricultural Technology Research Program,
Food Processing Technology Division
of the Georgia Tech Research Institute.
Agricultural Technology Research Program – GTRI/FPTD, Atlanta, GA 30332-0823
Phone: (404) 894-3412 • FAX: (404) 894-8051
Angela Colar - Editor - angela.colar@gtri.gatech.edu