Shield Engineering has studied recent changes to North Carolina's stormwater permitting requirements to help keep our clients in compliance. Our team provides comprehensive stormwater services, keeping your organization in line with the latest environmental compliance requirements and regulations. After our analysis, our team defined 9 notable changes in the updated stormwater permitting requirements that EHS leaders should be aware of.
SWPPP: Secondary Containment Plan
Going forward, all required secondary containment use must be in a documented plan. The permit describes specific elements which must be addressed in the plan. For facilities subject to the federal Spill Prevention, Control, and Countermeasure (SPCC) regulation, the SPCC Plan may be used to support compliance with this requirement.
SWPPP: Solvent Management Plan
A documented Solvent Management Plan (SMP) is now required as a separate chapter of the SWPPP. The permit describes specific elements which must be addressed in the SMP. For sites that don't store or use solvents onsite, that must be defined in the SWPPP as well.
SWPPP: Preventative Maintenance and Good Housekeeping Program
Going forward, a preventative maintenance and good housekeeping program should be developed and implemented to ensure that all best practices are being followed accordingly. Inspections shall occur quarterly at a minimum (January - March, April - June, July - September, October - December).
SWPPP: Employee Training Requirements
Annual employee training is now required to cover, at a minimum, the following: general stormwater awareness; the provisions of the current general permits for each industry; spill response training; used oil management; spent solvent management; secondary containment releases; fueling procedures; disposal of spent abrasives; sanding, painting, and blasting procedures; and used battery management. This training should be documented by the date, original or electronic signature, and printed or typed name of each employee trained.
SWPPP: Annual Online SWPPP Certifications
While not available at launch, the Division's ePermitting system will soon receive the capability to receive an online certification that the SWPPP review and update has been completed and that it meets the conditions of the permit.
While the newest permit requirements combine operation, maintenance, bypass of stormwater treatment facilities, and upsets language from previous requirements, there are new requirements for cleaning out stormwater control measures (SCMs), residuals management, and corrective actions.
Qualitative monitoring must be performed quarterly (or monthly for Tier Two/Three status) as a quick and inexpensive way to evaluate the effectiveness of the permittee's SWPPP. This is also a method to identify new sources of stormwater pollution and to prompt the permittee's response to pollution. Qualitative monitoring of stormwater discharges includes visual inspections performed at each stormwater discharge outfall (SDO) in addition to a response within 60 days if the qualitative monitoring indicates that the SWPPP and/or existing stormwater BMPs are ineffective. More details can be found in Part D of the latest permit.
Analytical monitoring must be performed quarterly (or monthly if in Tier Two/Three status). There is now a monitoring requirement for Chemical Oxygen Demand rather than Total Toxic Organics. There is no option for demonstrating pH of rainfall is below the benchmark range when outfall pH is out of range. Rainfall measured with a local rain gauge must now be located within 1 mile of the site. Tier Response Two & Three entry notification to the State is now required, along with a timeline for selecting a course of action for response. Tier Three now requires the submittal of an Action Plan for State review and approval. A permittee may exit Tier Three after 3 consecutive samples are below benchmarks.
Other Occurrences That Must Be Reported
These can be found in Table 7 in Part G of the permit requirements. The latest addition is the reporting of visible sedimentation in a stream or wetland, which should be reported orally or electronically within 24 hours in addition to in a report within 7 calendar days that contains a description of the sediment and actions taken to address the cause of the deposition. This written report may be waived on a case-by-case basis.
It is important to note that these new requirements are just a small part of the larger stormwater permitting requirements. You can find all of the General Industrial Permits from the NC Department of Environmental Quality here.
Shield Engineering is a civil and environmental engineering firm with years of experience assisting clients with industrial stormwater permit compliance. From developing and updating SWPPPs to tiered responses for benchmark exceedances including compliance actions plans and requesting relief from NCDEQ, our team has it handled. Complete the form below to get in touch with our team and learn how we can assist you in a cost-effective manner.