The Ohio Environmental Protection Agency's (OEPA) new industrial storm water general permit (OHR000005) will be replacing the previous industrial storm water general permit (OHR000004) which expired on May 31, 2011. In order to help industry more easily identify Storm Water Pollution Prevention Plan (SWP3) requirements and effective best management practices (BMPs) for specific operations, the OEPA has adopted framework from the federal Multi-Sector General Permit. The new OEPA general permit will provide more clarity regarding compliance responsibilities including implementation and monitoring. The intent of this article is to assist facilities and provide information showcasing the changes in the new general permit (OHR000005) and what requirements facilities seeking coverage will need to follow.
Who is Required to apply for the Permit?
Only industrial activities and/or facilities within 29 different Standard Industrial Classification (SIC) code categories are required to get an industrial storm water permit. If the SIC code associated with your facility is not eligible for coverage then that facility must apply for an individual National Pollutant Discharge Elimination System (NPDES) permit of alternative general permit from the OEPA.
Basic Requirements of the OHR000005 Permit
The main requirements of the OHR000005 Permit are similar to those of the U.S. EPA's current Multi Sector General Permit in that they require a facility to implement BMPs and to develop an SWP3 to minimize or eliminate the potential for storm water contamination from the site. The general permit has been broken down into four (4) parts which focus on certain criteria for each facility.
The permits outline is as follows:
Visual Assessments and Benchmark Monitoring
Quarterly Visual Assessments are used as a reference in which the permittee may act quickly upon the visual evaluation and inspection of the effectiveness of their control measures. On a quarterly basis, the facility will collect a sample in a clear container from each outfall (unless identified as substantially identical) in order to visually assess the appearance (color, odor, clarity, solids, oil sheen and foam).
Benchmark monitoring requirements are based off the sector specific guidelines in which the SIC code for each facility will provide the facility with a Subsector in which specific parameters and concentrations for sampling will have to be met. These concentrations are used to monitor and gauge the effectiveness of the facility's SWP3.
Comparison of Previous General Permit and New General Permit
The eligibility of certain facilities under the New General Permit allows coverage for discharges associated with industrial activities except the following, which were previously not included under the Old General Permit:
Permit OHR000005 more clearly defines the circumstances in which corrective action on the permittee's part is required.
As mentioned previously, Quarterly Visual Assessments (QVAs) are required to be performed in order to assess the discharge at each outfall. Benchmark monitoring is also required which is dependent upon the facility's SIC code. Based upon concentration limitations, if a result exceeds the benchmark for a parameter then the permittee must review their SWP3 and control measures and modify accordingly. Benchmark concentrations were not previously included to compare monitoring results. Also required is that data for benchmark monitoring and annual effluent limitation are to be submitted to the Ohio EPA using the OEPA's online electronic discharge monitoring report (eDMR) system.
With the introduction of new monitoring requirements, the New General Permit requires the completion of an annual report which will include the findings from the Annual Comprehensive Site Inspection and any corrective action documentation. Not previously provided, the New Permit includes an Annual Report Form which is to be used and is located in Appendix I of the permit. The form must be completed annually and maintained on-site.
The new requirements of the OHR000005 Permit are provided in order to help a facility implement, monitor, and prevent a discharge from their site. The requirements given in the new permit are expected to be incorporated into the facility's SWP3 by July 1, 2012.
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