Volume 18 | Number 2 | Summer 2006 | Environmental Issue

Industrial Storm Water: A Look at Georgia’s New Permit

By Jim Walsh

A site such as this feed mill can present a challenge in controlling storm water runoff.

After years of appeals and negotiations, the Environmental Protection Division (EPD) of the Georgia Department of Natural Resources (DNR) issued its General Permit for Authorization to Discharge under the National Pollutant Discharge Elimination System (NPDES) on July 16, 2006. The permit became effective on August 1, 2006, and the Notice of Intent (NOI) form to request to be covered by the permit was due on August 31, 2006.

Facilities that have not filed a Notice of Intent (NOI) form need to do so as soon as possible and develop or modify a storm water pollution prevention plan (SWP3) that implements best management practices (BMPs).

The facilities in the poultry industry that are subject to requirements of the permit are processing plants, feed mills, rendering plants, and truck shops.

A copy of the permit, the NOI form, a list of the impaired stream segment and impairment by county, and other information can be accessed online at www.gaepd.org/Documents/techguide_wpb.html#sw.

The main issue with the new permit is the discharge of storm water to an impaired stream on the 2004 version of the 303(d) list that is currently approved by the U.S. Environmental Protection Agency (EPA). When the 2006 version of the 303(d) list is approved, facilities must refer to this list for special sampling requirements. These requirements apply to facilities that are within one linear mile of an impaired stream segment, are located in the same watershed, and have the pollutant that causes the stream impairment at the facility.

The primary impairments that impact the industry are fecal coliforms and dissolved oxygen. If a facility meets the distance criteria, it must sample at the outfall two times per quarter for one year and compare the results to benchmark values. The benchmark values are the in-stream water quality standards for the state of Georgia.

One of the key issues in the new permit is the use of fecal coliforms as a measure of bacterial problems in a stream. There are a number of individuals in the scientific community who think that E. coli is a better indicator of problems, but this issue is something that must be resolved in the future. However, there was consensus that total suspended solids (TSS) has a direct correlation to the amount of fecal coliforms. As a result, at least two of the sampling events must sample both TSS and fecal coliforms. Annual report data analysis will be conducted by Georgia Tech and the University of Georgia to verify this correlation. The applicable benchmark for TSS is 100 mg/L.

The issues for stream segments impaired for dissolved oxygen are the existence of CBOD5 and NH3. The permit provides a computation for ultimate oxygen demand (UOD) based on CBOD5 and NH3, and the benchmark value for UOD is 125 mg/L.

Facilities should indicate whether or not the pollutant(s) of concern for the impaired stream segment(s) may be exposed to storm water, as a result of current or previous industrial activity at the facility, during the term of this permit. If the facility can certify the pollutant(s) of concern cannot be discharged during a rain event, it can avoid special sampling requirements (e.g., feed mills that do not receive trucks associated with moving live birds or trucks that drive through containment areas will not have fecal coliforms).

The permit provides details on the criterion for meeting the benchmark requirements. Facilities that do not meet this criterion will have up to a year to implement changes in best management practices or make modifications to the facility before initiating another year of sampling. Facilities that do not meet the benchmark requirements after a second year of sampling will be subject to additional requirements. However, these additional requirements do not necessarily mandate an individual NPDES permit.

There is an annual certification form that must be filed by facilities with permits. This form is very simple and will only take a few minutes to prepare. This certification is a compromise to some groups that wanted facilities to submit their storm water pollution prevention plans.

The current permit expires July 31, 2011. The industry is already anticipating possible changes when the permit comes up for renewal.

Jim Walsh is a senior engineer with Georgia Tech’s Energy and Environmental Management Center, a service unit of the Enterprise Innovation Institute (formerly the Economic Development Institute). He can reached at (404) 402-3263 or jim.walsh@innovate.gatech.edu.