Does Your Business Need a Pollution Discharge Permit?

A research project I conducted as the North Sound Baykeeper at RE Sources shows that as many as 450, or two-thirds of industrial facilities in Whatcom County, do not have required coverage under Ecology’s Industrial Stormwater General Permit (ISGP). To remedy this problem, RE Sources has created educational pamphlets to help businesses get into compliance. These pamphlets detail which facilities are required to have an industrial stormwater permit and what steps are needed to come into compliance. The pamphlet also explains why it is important to be in compliance.

The purpose of the ISGP is to ensure that best management practices are being used at industrial sites, limiting the amount of pollutants entering into Washington state’s waterways. Pollutants, such as oil, grease, heavy metals and wood shavings, contribute to poor health of area waterbodies and adversely affect the animals that depend on these waterbodies. The Department of Ecology (Ecology) estimates that approximately one-third of water impairments are attributed to stormwater contamination.

Industrial facilities need to get coverage under the ISGP to be in compliance with the Clean Water Act. Facilities run a legal risk if they do not get coverage, especially if stormwater runoff from their site contains pollutants. Getting coverage under the ISGP is about protecting the health of our waterbodies; it also creates a level playing field for all businesses that are subject to the regulation. To find out if your business needs coverage under the ISGP, surf over to Ecology’s Web site: http://www.ecy.wa.gov/programs/wq/stormwater/industrial/#booklet.

The federal Clean Water Act requires businesses that have the potential to pollute to obtain a National Pollutant Discharge Elimination System (NPDES) permit. These permits are not only required for the discharge of process water, but they are also required for stormwater issuing from an industrial facility.

That means, if you have any material outdoors that may be exposed to rainwater, you may need a discharge permit. If this is the case for your facility, you may need to apply for coverage under Washington State’s Industrial Stormwater permit.

Why be in compliance? Polluted stormwater runoff is responsible for nearly one-third of the total water pollution in Washington state. Pollution ranges from pesticides and fertilizers to oil and grease and heavy metals, wood shavings and other organic materials. Pollutants affect the animals and fish and plants that depend on our precious waters by poisoning them outright, by making them less fit to survive or by decreasing the amount of oxygen in the water.

When facilities are not in compliance with the stormwater permit, the stormwater pollution coming off their site is more likely to be contributing to water quality problems in nearby waterbodies. And facility owners are at risk of legal action.

Businesses that are not in compliance have an unfair competitive advantage over those that are following the law. Working together, all businesses can have a positive impact on water quality.

You are not in compliance if:

•Your facility does not have a current industrial stormwater permit, another permit that addresses stormwater or a certificate of non-exposure, and

•The rain that falls onto your facility site goes to a storm drain, drainage ditch, creek or other waterbody, and

•The Standard Industrial Code of your facility is listed in the Federal regulations, 40 CFR Subpart 122.26(b)(14). (See above sidebar.)

To come into compliance, follow these steps to obtain an industrial stormwater permit.

•Obtain an application and fill it out: Applications are available by mail at Department of Ecology, attn: Joyce Smith, P.O. Box 47696, Olympia WA, 47696, or online at http://www.ecy.wa.gov/programs/wq/stormwater/industrial/index.html#Application. Develop and implement a stormwater prevention plan.

• Sample your stormwater quarterly and send in the results to Ecology.

Q: I don’t think the stormwater from my facility is a problem. What should I do?

A: You may apply for a Certificate of Non-Exposure, which ensures that you are in compliance but does not have the requirements of the NPDES permit.

Q: What is a stormwater prevention plan?

A: The plan consists of a map showing where the stormwater drains and a list of best management practices (BMPs) to prevent or minimize pollution of the stormwater. Often BMPs consist of commonsense placement of materials and more frequent cleaning of surfaces. Sometimes more extensive BMPs are required depending on the layout of the facility and the amount and toxicity of the pollutants. You know your facility well, so chances are you will not have too much difficulty with your plan.

Q: I don’t know how to write a plan or sample for stormwater, and I have more questions about this permit. What should I do?

A: The Department of Ecology has staff, free online publications and a useful Web site to help answer your questions. Contact http://www.ecy.wa.gov or (360) 407-7156. §