Tuesday, December 16, 2008

EPCRA 313 Facility Requirements Under Stormwater Discharge Permits

When initially drafted, the US EPA general discharge permit for industrial stormwater discharges contained additional requirements which applied to selected facilities that stored and used larger quantities of chemicals. These requirements applied to a subset of EPCRA (also referred to as SARA) Section 313 reporting facilities; because a facility was required to submit a Toxic Release Inventory (TRI) report did not necessarily mean that these additional requirements had to be met under their stormwater discharge permit. The additional requirements included:

  • Specific containment/diversion requirements
  • Additional inspections
  • Material compatibility requirements
  • Site security

Over time, as “sector specific” or “multi-sector” general permits became more common, the need for additional requirements for Section 313 facilities became less critical. These requirements could be inserted into the requirements for individual industrial sector that typically used Section 313 chemicals.

Currently, only about one-third of States have general industrial permits that include additional requirements for EPCRA 313 facilities.

Caltha LLP provides technical support to facilities nationwide to meet their State-specific stormwater permitting requirements. Caltha maintains a library of SWPPP templates, Monitoring Plan templates, and SPCC templates to meet individual State requirements.

For further information contact Caltha LLP at
Caltha LLP Website

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