Monday, February 1, 2010

Arizona ADEQ Draft Industrial Multi Sector General Stormwater Permit

The Arizona Department of Environmental Quality (ADEQ) recently posted an updated draft of its proposed multisector industrial stormwater discharge general permit for informal stakeholder review and input. This permit “AZPDES MSGP 2010”, once promulgated, will replace the existing industrial stormwater permit, which expired in 2005. ADEQ anticipates the MSGP to be public noticed sometime during the winter of 2010.

The AZPDES MSGP 2010 contains 8 parts and 5 appendices. Parts 1 through 7 describe the requirements that all operators must meet when seeking coverage under this permit. Part 8 describes the additional sector-specific requirements for industrial activities, sub-divided into 30 industry sectors.

Much of the ADEQ permit is based on the US EPA Multi-Sector General Permit (MSGP 2008) that became effective on Sept. 29, 2008. Some of the Arizona-specific changes from the MSGP 2008 include:

  • The NOI must include the well registration number if stormwater associated with industrial activity is discharged to a dry well or an injection well.
  • Facilities with liquid storage areas for SARA Section 313 water priority chemicals must be operated to minimize discharges of such chemicals.
  • All facilities or any portion of a facility that is located at or within the 100-year floodplain must be delineated on the site map.
  • Facilities subject to monitoring and reporting requirements must submit a discharge monitoring report form(s) and other required monitoring information.
  • The term "significant sources of non-stormwater" includes, but is not limited to, discharges that could cause or contribute to violations of Arizona water quality standards, and discharges that could include releases of oil or hazardous substances in excess of reportable quantities under section 311 of the Clean Water Act (CWA) (See 40 CFR 110.10 and 40 CFR 117.21) or section 102 of CERCLA (See 40 CFR 302.4).

All facilities covered under the permit will need to comply with Parts 1 through 7. Some of the key requirements that all permittees will meet include:

Each site will need to prepare and maintain a stormwater pollution prevention plan (SWPPP). The SWPPP will need to include:

Good Housekeeping.
Spill Prevention and Response Procedures.
Erosion and Sediment Controls.
Management of Runoff
Management of Salt Storage Piles or Piles Containing Salt.
Sector Specific Control Measures.
Employee Training.
Elimination of Non-Stormwater Discharges.
Litter, Garbage and Floatable Debris
Dust Generation and Vehicle Tracking of Industrial Materials.

Routine Facility Inspection Procedures.
Every site will conduct routine quarterly inspections of all areas of the facility where industrial
materials or activities are exposed to stormwater with the potential to discharge from the facility, and of all stormwater control measures used to comply with this permit.

Visual Assessment of Stormwater Discharges.
Every site will also perform two visual assessments during the summer wet season and two during the winter wet season when the facility is discharging. The visual assessment is be made collecting a sample in a clean, clear glass, or plastic container, and examining it in a well-lit area.

Comprehensive Facility Inspection.
Once each year the qualified person or persons will conduct an annual comprehensive facility inspection (CFSI). A member of the facility’s stormwater pollution prevention team must conduct or participate in the inspection.

To review a summary Section 8 - Sector Specific Requirements, go to:

Summary of ADEQ Industrial Sector Requirements Under Draft MSGP 2010

[Read how ADEQ proposes to address new and expanded discharges to impaired waters and Outstanding Arizona Waters]

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
Caltha LLP Website

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