In our previous blog, we explained, in simple terms, who is required to obtain a stormwater discharge permit. If your facility is covered by the Industrial Stormwater Program in Michigan, there are new requirements that you must address when you renew your permit. Under the new permits, a certified stormwater operator must not only perform quarterly comprehensive inspections, but must also personally and visually inspect samples of the outfall collected during a storm event once each quarter.
What are the new industrial stormwater discharge permit requirements?
The new requirements by the Michigan Department of Environmental Quality (MDEQ) include simple visual inspections of stormwater runoff – but, of course, it’s never that simple. Here are some of the important elements of this new requirement.
- You must develop written procedures within six months of the Certificate of Coverage or individual permit being issued.
- Quarterly, the certified stormwater operator for the facility must perform a “comprehensive inspection.” In addition, a sample from the stormwater outfall must be collected once per quarter, within one month of the comprehensive inspection. Samples are to be collected within the first 30 minutes of a discharge event, provided it has been at least 72 hours from the previous discharge event. Samples must be visually inspected within 48 hours, and the inspection must be conducted by a certified operator.
- Annually, by January 10th, you are required to submit annual review forms to the MDEQ.
Also, new discharge quality limits are being included in many stormwater discharge permits due to concerns about the state of the receiving waters. It is the permittee’s (your) obligation to determine if the receiving water for your discharge is subject to Total Maximum Daily Load (TMDL) requirements.
There are new Industrial Stormwater permitting requirements in Michigan (Photo Credit: Dragun Corporation).
Considerations as your permit renewal approaches
There are many concerns and considerations about the actual implementation of this new outfall sampling and inspection requirement, such as:
- Is your outfall accessible? For many facilities, stormwater discharges to a municipal storm sewer. Sampling in these situations could involve consideration of a confined-space entry.
- If the outfall is not on your property, do you need a permit or an access agreement to collect the samples?
- Depending on the location of the outfall, are there traffic control and safety considerations for the sample collection?
- Mother Nature doesn’t work the day shift. If the storm occurs during off hours, who will collect the sample?
- How can you ensure that your samples are not being impacted by upstream sources or non-regulated activities (employee parking lots, for example)?
With the Environmental Protection Agency’s continued focus on reducing point and non-point source runoff into rivers, lakes, and streams, we suspect there will be increased focus on water-related issues.
If you need assistance with a stormwater discharge permit or have a question about the applicability regarding this or other environmental compliance issues, please feel free to contact me (mschroeder@dragun.com) at 248-932-0228, ext 117.