Wednesday, December 10, 2008

Municipally-owned Industrial Facilities – Requirement for Separate Stormwater Permit

With the exception of power plants, airports, and uncontrolled sanitary landfills, stormwater discharges associated with specific industrial activities at facilities owned or operated by municipalities with populations of less than 100,000 had been temporarily exempted from the need to obtain coverage under an NPDES industrial storm water permit.

However, under the provisions of the NPDES Stormwater Program Phase II Final Rule, these industrial facilities now may require permit coverage. These permit requirements are separate, and are in addition to, the requirement for designated municipalities to obtain coverage for their storm water discharges under the general permit for stormwater discharges from regulated small Municipal Separate Storm Sewer Systems (MS4s) (i.e., Phase II or MS4 Permit).

Some municipalities may own or operate one or more industrial facilities that are likely to require permit coverage for their storm water discharges. Some examples include:

  • Sand and Gravel Operations
  • Landfills, Land Application Sites, and Open Dumps
  • Recycling Facilities
  • Steam Electric Generating Facilities
  • Marinas
  • Waste Collection and Hauling
  • Motor Freight Transportation and Warehousing
  • Municipal Airports
  • Wastewater Treatment Works

As more small municipalities become subject to MS4 permits, they are reviewing operations to determine if additional permit coverage under an industrial stormwater permit is required. Regardless of the requirement for additional coverage under an industrial permit, these municipal operations need to be evaluated and addressed under the MS4 stormwater pollution prevention program.

Caltha LLP provides technical support to MS4 permitees and/or their municipal engineers nationwide to assess operations and determine permit applicability. Contact Caltha LLP for further information on assessing municipally-owned industrial operations to determine applicability.

For further information contact Caltha LLP at
Caltha LLP Website

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