Sunday, February 12, 2012

New Benchmark Monitoring Requirements For Discharges To Impaired Waters

The 2012 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity (2012 IGP) was issued as a third draft for public comment on January 17, 2012. Comments are being accepted from January 17 to March 16, 2012. Georgia Department of Natural Resources - Environmental Protection Division (EPD) anticipates the final industrial permit will be issued in April 2012.

Review a Regulatory Briefing on the Georgia 2012 IGP

The 2012 IGP has certain requirements that apply only to facilities that discharge either directly to an impaired water, or to a tributary to an impaired water, if the facility is located less than one mile from the impaired water. An impaired water is a water body, or part of a water body, that does not meet State Water Quality Standards and has been placed on the 303(d) Impaired Waters list submitted to and approved by US EPA.

If the pollutant of concern (POC), such as sediment, could be exposed and/or could be contained in the stormwater run-off, facilities are required to conduct benchmark monitoring twice each quarter, rather than once per year. In addition, the applicable benchmark concentration becomes equal to the State Water Quality Standard, and not the sector-specific benchmarks in the 2012 IGP (which are generally higher). If benchmarks are not exceeded, sampling could be reduced to twice per year.

For those facilities that conducted impaired waters monitoring under the previous permit (2006 IGP) and passed all benchmarks, the additional monitoring under the 2012 IGP is twice per year.

Some facilities may be able to certify that the POC is not present at the facility, in which case they are not required to conduct the additional impaired water monitoring. Finally, some facilities may be able to conduct studies or analyses that demonstrate that their stormwater discharge will meet applicable Water Quality Standards. In this case, the analysis must be certified by a Professional Engineer or Professional Geologist and approved by EPD.

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

For further information contact Caltha LLP at or Caltha LLP Website

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