During our February webinar there were several questions asked by attendees; we were able to answer many, but we ran out of time before getting to all of them. As promised, our presenters have drafted answers to all of your questions. Please see the full Q & A below.
Our next webinar will be on April 10, 2019 at 12:00 pm. We will update our webinar page once the details are finalized.
Our next webinar will be on April 10, 2019 at 12:00 pm. We will update our webinar page once the details are finalized.
- Do the discharge requirements include PFA's and PFO's?
In general, discharge requirements for storm water permits currently do not include PFAs or PFOs. The facility’s permit should be checked to determine the discharge requirements as these compounds, or others, may be incorporated to more recent updated permits. - Is a City DPW garage considered an Industrial Site where you need and Industrial Site Operator?
It depends, if the DPW garage performs vehicle maintenance including fueling activities, and is located in an area with separate storm sewers then yes the facility would be considered an industrial site and would meet the applicability for a stormwater permit; therefore, the facility would need an industrial stormwater operator. If these activities do not occur at the DPW garage it would not be considered an industrial site and would not meet the applicability for a storm water permit. So, depending on the activities on-site and the presence of separate storm sewers, would determine if the facility requires an industrial stormwater discharge permit. - How often does the storm water need to be tested for maintenance?
Storm water visual assessments are required on a quarterly basis, as stipulated in your permit. If you have engineered stormwater controls that require maintenance (oil water separators, sedimentation basins, etc.) inspections of these structures should occur on a regular basis. Depending on the structure and on-site activities, quarterly maintenance may not be frequent enough, and for the control to operate properly it may need to be inspected and have maintenance performed on a more frequent basis. - Who establishes the impervious acre/month fee in the various localities?
The various entities establish the fee themselves. It is likely connected to their own expenses related to the temporary storage and treatment of the local stormwater. Some locales are more expensive than others, it just depends on where your site happens to be. - Are there specific states that establish these fees or is this a local requirement?
As of now, the fees are a local requirement. Some entities don’t have any stormwater fees, but many of these programs are getting rolled out as weather gets more unpredictable and cities become more urbanized. As they start to have more problems with flooding or uncontrolled/untreated releases, they establish stormwater fees in an attempt to reduce the stormwater flows entering the system. - Do sites that stockpile excess excavated materials like soil, shale, topsoil, asphalt, etc. for eventual reuse in other construction projects need an Industrial SW Permit?
The requirement to obtain an industrial storm water permit is based on the facility’s SIC code, as such, the facility may not need to obtain an industrial storm water permit. The facility may need to obtain a construction storm water permit (an SESC permit from the appropriate Part 91(in Michigan) permitting agency) if disturbing greater than an acre and/or is located within 500 feet of a water of the state. Please check with your permitting agency to confirm the need for a SESC permit. - If our SPCC/SWPPP is off of the old NPDES permit, do we need an update for the new required SIC code changes or change we wait till it expires in 5 years?
Your SPCC/SWPPP are “living documents” and should be updated with changes to your facility, incorporating the requirements of your current NPDES permit. If your current NDPES permit does not have a requirement to perform visual assessments or benchmark monitoring, it is OK to wait to update your plan until a new permit is issued. - What is the benchmark testing requirement for storm water discharges? As there are so many chemicals used at industrial facilities, how are the primary parameters determined?
The benchmark monitoring requirements are generally state dependent and tend to focus on specific industries. While the federal multi-sector general permit has specific parameters for benchmark monitoring, some states have opted to add additional parameters, while other states have put the burden on the specific industry to determine what parameters to include in their benchmark monitoring plan. - If my site discharges to a sanitary or combined sewer, do I need a stormwater permit?
Storm water discharges to a combined sewer do not require a storm water permit. There may be instances where a municipality may inquire about pollution prevention practices, but generally, a permit is not required. - I have a discharge permit, how do I know I need a SWPP?
The requirement to develop a SWPPP is permit dependent and generally included in the facility’s permit. Most discharge permits that have a storm water component will require a SWPPP if the facility falls within specific SIC code categories. - I have an SPCC plan for my stormwater facility, do I need a SWPP?
Regardless of whether a facility has a SPCC in place, a SWPPP may be required depending on your SIC code and/or permit requirements. The requirements of a SWPPP are differenct than those of an SPCC. The two documents can be combined or the procedures in the SPCC can be incorporated into the SWPPP, or the SPCC incorporated into the SWPPP as an attachment or by reference. - What is the level of effort required to get credits?
It depends on both the site and the entity. If the site is large and has a lot of potential for different green infrastructure solutions, then the design and the review of the design will take longer. Also many of these stormwater credit programs are new, and sometimes the entities need longer to review because they’re still structuring the review process. - If I get credits, how long do they last?
Again, it depends on the entity. NEORSD is 1 year. DWSD is 3 years. You can ask the entity or your engineer and they will know. You will need to maintain your stormwater management practices to continue receiving credits when their time is up. Renewal of stormwater credits will require an stormwater credit renewal application. - Are there underground retention options?
Yes, underground detention is an option for stormwater credits, but will only generate peak flow credits for your site, no credits related to volume.
- Do you have some examples of applications. Some examples can be found at these links:
DWSD Drainage Charge Adjustment Application
https://detroitmi.gov/document/drainage-charge-adjustment-application
DWSD Drainage Charge Credit Application
https://detroitmi.gov/forms/drainage-charge-credit-application
NEORSD Stormwater Credit Applications
https://www.neorsd.org/fee-credit/
If you were not able to attend the webinar, you can view it here:
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