Agricultural Technology
Research Program


Volume 17 | Number 2 | Summer 2005 | Environmental Issue

page 1
Researchers Use High-speed Cameras to Better Understand Fluid Flow in Taylor Vortex-based UV Disinfection System

page 2
Survey Studies Industry Pretreatment Use and SPN Handling Options

page 3
Industrial Storm Water: A Look at Georgia’s Proposed New Permit
By Jim Walsh & John Starkey

page 4
Water Reuse and Recycling News

page 5
Georgia Tech Researchers Partner with Industry to Study Alternative Uses for Eggshell Waste

page 6
Thousands of Animal Feeding Operations Sign EPA’s Air Compliance Agreement

page 7
Visit Poultry World at the 2005 Georgia National Fair


<< ATRP Publications Page

Industrial Storm Water: A Look at Georgia’s Proposed New Permit
By Jim Walsh & John Starkey

Taylor vortex-based ultraviolet disinfection system

A typical storm water first flush collection system — pumps located at the bottom of the trough transport the first flush of storm water back to the wastewater treatment system.

Since it was passed in 1972, the Clean Water Act has done much to improve our nation’s water. Areas such as the Great Lakes are now safe for fishing and recreation. However, by the mid-1980s, it was clear that there were still problems, and the primary cause was traced to storm water from both industrial and municipal sources.

Georgia and most other states addressed the problem of industrial storm water by establishing a general permit that covered all industries in the state. A facility wanting coverage under the general permit submits a notice of intent (NOI) form to the state. Most of the industries that require storm water permits are manufacturers with SIC (standard industrial classifications) codes 20 through 39.

Because storm water permits are a type of National Pollutant Discharge Elimination System (NPDES) permit established by the Clean Water Act, they must be renewed every five years. The current state of Georgia permit was due to expire on May 31, 2003, and the state was prepared to issue a new permit. Objections from several groups prevented this from happening, and the permit has yet to be issued. Facilities whose NOI form was received by May 31, 2003, are still covered by the 1998 permit. However, a facility that wants to obtain coverage under the 1998 permit cannot get it under normal circumstances.

The main objection to the new permit was that it did not address the discharge of storm water into stream segments that are classified as impaired and are put on the 303(d) listing for the state. These impairments can include fecal coliforms, metals, low pH, and low dissolved oxygen.

After reviewing and responding to these objections, the state then moved on March 18, 2005, to issue a new general storm water permit for industrial activities that would become effective on May 2, 2005. However, shortly after the permit was issued, two petitions were filed requesting a hearing. As a consequence, the process was put into limbo, and facilities continued to operate under the 1998 permit.

A major change in the current proposed new permit relates to storm water discharges to stream segments on the state of Georgia 303(d) list of impaired streams. A listing of these stream segments can be found at the Georgia Environmental Protection Division (EPD) website under industrial storm water in the TECHNICAL GUIDANCE section. A facility has special requirements if a) it is located within one linear mile of an impaired stream segment; b) its storm water flows to that stream segment; and c) the issue or substance that caused the impairment exists at the facility.

The key issue for the poultry industry is fecal coliforms that are the most common reason for putting a stream segment on the Georgia 303(d) list. The permit issued by Georgia EPD (like the federal storm water permit prepared by the U.S. Environmental Protection Agency [EPA]) does not have a fecal coliform benchmark value. The reason for this is scientific evidence that fecal coliform is a poor indicator organism and not necessarily a true indication of pathogen problems in water. Further, its ubiquitous nature makes source identification almost impossible (even storm water from subdivisions can have coliform counts in excess of water quality standards). In addition, there are natural sources of fecal coliform such as wildlife that are beyond the control of the discharger.

However, the major objection of one of the two petitions forcing the hearing is the removal of fecal coliforms. At this time, it is not clear when the issue will be resolved. However, when the permit is issued, facilities will have to submit a new NOI to be covered.

Another change in the proposed new permit is the elimination of the requirement to conduct an annual sample analysis of storm water if the facility reported a water priority chemical under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). This reporting could be either Form R or Form A. Water priority chemicals include ammonia as well as some of the chemicals at feed mills. Because the 1998 permit is still in effect and this sampling is required under this permit, it is recommended that facilities continue this sampling.

The proposed new permit still requires an annual sample analysis for animal slaughter plants. So, these plants will need to continue to sample, but, when the new permit is issued, they will not have to look for ammonia.

If a new facility requiring a permit is being built, it is recommended that the facility submit the 1998 NOI form by certified mail, return receipt requested. These forms are not available at the EPD website but can be obtained from Georgia Tech. They should then develop the Storm Water Pollution Prevention Plan (SWP3), implement best management practices, conduct annual sample analysis and quarterly visual inspections, and act as if they are covered by the permit.

Georgia Tech has recently completed web-based software for developing the SWP3 under a contract with the EPA. The software can be found at and there is no cost for the use of the software. Facilities may want to check out the software even if they already have an SWP3 in place.

Jim Walsh is a senior engineer with Georgia Tech’s Economic Development Institute/Environmental Management Team.

John Starkey is vice president of Environmental Programs for the U.S. Poultry & Egg Association.

Taylor vortex-based ultraviolet disinfection system

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PoultryTech is published by the Agricultural Technology Resarch Program (ATRP), Food Processing Technology Division (FPTD) of the Georgia Tech Research Institute. ATRP is conducted in cooperation with the Georgia Poutry Federation with funding from the Georgia Legislature.