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 karent@smithmanage.com.