Monday, November 24, 2008

Local Stormwater Requirements - Additional Stormwater Compliance Requirements

One of the challenges many facilities face is complying with local stormwater requirements. These requirements are beyond those requirements specified in an NPDES permit. In fact, many local requirements apply to all properties, regardless of SIC code or whether or not a facility is required to obtain a discharge permit.

One of the most challenging aspects of complying with local requirements is the fact that different jurisdictions can have widely different requirements. Cities, Counties or other jurisdictions can range from very generic requirements, or very detailed requirements. For example, the City of Tampa Bay, Florida has general requirements:

Sec. 21-9. Protection of public drainage systems. •It is unlawful to introduce any foreign matter (including, but not limited to, trash, leaves, grass clippings, debris, garbage, fill, construction materials, organic or inorganic pollutants, acids, and petroleum products), whether by action or inaction, to any public drainage system including but not limited to streets.

In contrast, the City of Fremont, CA, for example, has very prescriptive requirements. Here is a small sample of the City's requirements:

I.K. Vehicle/Equipment Repair and Maintenance –1) Vehicle/equipment repair and maintenance shall be performed in a designated area indoors, or if such services must be performed outdoors, in an area designed to prevent the run-on and runoff of stormwater. 2) Secondary containment shall be provided for exterior work areas where motor oil, brake fluid, gasoline, diesel fuel, radiator fluid, acid-containing batteries or other hazardous materials or hazardous wastes are used or stored. Drains shall not be installed within the secondary containment areas.

Whether the local requirements are general or specific, in most cases, NPDES permits require compliance with local requirements in addition to permit conditions. In preparing SWPPPs, local requirements need to be considered in addition to the permit requirements.

For further information contact Caltha LLP at
Caltha LLP Website

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