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Now That You Completed the eNOI, Have You Updated the SWPPP?
WRITTEN BYKaren Thompson, P.G.
Have you looked at your SWPPP (Stormwater Pollution Prevention Plan) lately? The new Kentucky General Stormwater Permit associated with Industrial Activities became effective August 1, 2018. Facilities that operate under the General Stormwater Permit must reapply by October 30, 2018 by filing the eNOI online. In addition to re-applying, the facility must also have their SWPPP updated. The requirement is to have a copy the effective permit in the SWPPP.
Now that you have your SWPPP out to review, what other information should be there? Section 4.6 Additional Documentation Requirements, lists other documents that need to be available with your SWPPP, including:
- A copy of the NOI-KYR00 submitted to DOW along with any correspondence specific to coverage under this permit;
- A copy of the coverage letter issued by DOW;
- A copy of this permit (electronic or paper);
- The daily precipitation log;
- A summarization of all stormwater discharge sampling data collected at your facility during the previous permit term;
- Incident Reports
- Employee Training Records – Including dates, names of employees, and subject matter;
- Control Measure Maintenance and Repairs Logs – Including date(s) of regular maintenance, date(s) of discovery of areas in need of repair/replacement, and for repairs, date(s) that the
control measure(s) returned to full function, and the justification for any extended maintenance/repair schedules;
- Inspection reports; and
- Corrective Reports
Section 4 of the General Stormwater Permit provides the requirements of the SWPPP and information to be included. Now is a good time to review that section to make sure your SWPPP is update and compliant. One of the changes in the new permit is the addition of a Total Suspended Solids (TSS) Best Management Practice (BMP) trigger. The daily maximum discharge concentrations for TSS of 100 mg/l is a trigger that once exceeded for two consecutive reporting periods, requires an evaluation of current BMPs.
If you have questions or require assistance with your SWPPP or other compliance plans, contact us. Karen Thompson is the Manager of Environmental Services at Smith Management Group. Karen can be reached at firstname.lastname@example.org.
New Facility Permitting
A large alcoholic beverage company was planning to construct a distillery along a lake in Kentucky and use the fresh limestone water for bourbon production. The proposed site was a former farm with historic activities dating back to the 1880s. A water intake structure was required in the lake and along the adjacent shoreline which was owned by others. Several ephemeral and intermittent streams would be impacted by the construction. The client needed a US Army Corps of Engineers (USACE) Clean Water Act (CWA) Section 404 Permit, a Kentucky Division of Water 401 Water Quality Certification, a water withdrawal permit, a permit for construction in and along a stream, and a construction stormwater permit. Additionally, an air permit was required prior to construction for the aging warehouses, distillery equipment, and other emission units. Evaluation for cultural and historic resources and endangered species evaluations were required under the National Environmental Policy Act (NEPA) and Endangered Species Act (ESA).
As the construction proceeded and operations began, a number of operating permits and environmental and hazardous materials compliance plans were required. The project required coordination with the nearby city for drinking water use and industrial wastewater pretreatment and discharge. Recordkeeping and reporting were needed prior to facility personnel being mobilized to the site. Set up and management of environmental systems during the transition to full operations was needed.
During the planning and initial construction phases, SMG managed the environmental permitting and environmental compliance for the site. The process involved application preparation and coordination with multiple regulatory agencies including the USACE, Kentucky Division of Water, Kentucky Division of Air Quality, US Fish and Wildlife Services, Kentucky Department of Fish and Wildlife Resources, Kentucky Heritage Council, and local agencies. Permits included stream mitigation, cultural and historic resources investigation, coordination with state and federal Fish and Wildlife agencies, and State 401 water quality certification, and the Section 404 permit, which required wetland and stream delineation. SMG coordinated with the client’s project team to minimize stream impacts and to adhere to the schedule by expediting the permit processing. State stream construction, water withdrawal, and air permits were also obtained. SMG provided onsite observation to assess contractor compliance with the stormwater permit and managed environmental permit reporting.
During the later construction phase, SMG managed the environmental permitting and compliance for the new distillery. The initial environmental and hazardous material compliance plans (GPP, HMPC, and SWPPP) were prepared and applications for operating permits, such as industrial wastewater pretreatment and discharge and industrial stormwater discharge, were readied and submitted. SMG provided training to the initial employees regarding hazardous material management and groundwater/stormwater protection. SMG worked with the new Risk Manager for the site to transition responsibility for environmental and hazardous material compliance.
SMG’s management of the environmental planning and permitting for the facility, successfully supported the construction schedule and managed environmental compliance for the initial site operations. SMG continued to work with the owner to obtain remaining operational permits and to transition environmental compliance responsibilities to the new facility staff to support startup and initial operations. The facility was completed on schedule and provides a significant economic benefit to the surrounding community.