Thursday, May 23, 2013

New Industrial Permit Requirements For Kentucky Storm Water Dichargers

Kentucky Division of Water (DOW) reissued the Kentucky Pollutant Discharge Elimination System (KPDES) General Permit for Stormwater Discharges Associated with Industrial Activity- Other Facilities (KYR000000) on May 1, 2013, with an effective date of June 1, 2013. Facilities that are subject to a promulgated national effluent guideline and those facilities that discharge to a receiving water that is subject to a TMDL for suspended solids are not eligible for coverage under the general permit. Facilities seeking new coverage, modification of existing coverage, or renewal of existing coverage are required to submit an updated eN0I-KYROO:
  1. Operators seeking initial coverage for an existing facility that has commenced discharge must electronically submit the eN0I-KYROO by June 16, 2013.
  2. Operators seeking modification of an existing coverage to address facility modifications must electronically submit an updated eN0I-KYROO a minimum of 15 days prior to the modification of the facility.
  3. For existing coverage granted prior to September 30, 2007 the operator must electronically submit an updated eN0I-KYROO by August 29, 2013 to renew the coverage.
If a facility does not submit the updated eN0I-KYROO by the deadline, DOW will terminate of coverage, even if a facility has been permitted in the past. Facilities can seek a conditional exclusion for no exposure by filing an electronic No Exposure Certification (eNoExposure). This certification is time limited and must be resubmitted upon each reissuance of KYR000000 or every 5 years, whichever is first, in order to continue the exclusion for the next permit term.

Some of the key changes from the previous permit include:
  1. Specific effluent limits for Total Suspended Solids (TSS), Oil and Grease (O&G), and pH are in place of the previous requirement to monitor and report the results of monitoring for these parameters. Monitoring is no longer required for Chemical Oxygen Demand (COD).
  2. The Stormwater Best Management Practices (SWBMP) Plan will now be refered to as a “Stormwater Pollution Prevention Plan (SWPPP).”
  3. Inspections with subsequent written reports to document the findings of the inspections would be required on a minimum weekly basis and in response to 2-year, 24-hour storm events that occur.
  4. The SWPPP Site Map must include additional features to be shown including directions of stormwater flow, locations of impaired waters and any TMD’s associated with them, and locations of stormwater monitoring points.
  5. The SWPPP must include procedures for preventing and responding to spills, and schedules for inspections, preventive maintenance, and employee training required.
  6. The SWPPP must contain a daily precipitation log, incident reports in response to spills, employee training records, and control measure maintenance and repair logs.
Caltha LLP maintains a library of SWPPP templates to meet general permit requirements for individual States, including Kentucky. Caltha has revised our Kentucky SWPPP template to meet new permit requirements and is using this SWPPP Template to support our clients located in Kentucky.
 For further information contact Caltha LLP at or Caltha LLP Website