Why it matters: This requirement is also being applied to other NPDES permit holders – specifically the Municipal Separate Storm Sewer System (MS4) permits that are issued to municipalities (counties and cities) in the Chesapeake Bay watershed. For the first time, industrial permit holders will be required to “restore” at least 20% of the existing impervious area (buildings, roads, parking lots, etc.) on their site. Restore means to either eliminate the impervious area (not likely in most cases) or to provide water quality treatment for it. So if a site has no stormwater management, a plan to address at least 20% of the site will be required. If there is already existing stormwater treatment, the permitee will need to make sure it meets current (2007) standards.
What we do: SMC is helping many permit holders as our specialization in existing infrastructure and experience on industrial sites uniquely qualifies us for this work. We have the expertise to assess these unique sites and find the most cost efficient way to implement stormwater improvements.
With over 25 years of stormwater design experience and in-house construction capabilities, we have a practical understanding of stormwater infrastructure that instantly adds value for our clients. Our in-house design-build services will yield savings for our industrial clients as they address this permit requirement.
Revised Stormwater Pollution Prevention Plans (SWPPP)
Why it matters: SWPPPs are living documents that identify potential pollutant sources, set forth pollution prevention practices and operational procedures, identify pollution prevention team members and responsibilities, and set the course for operating in a manner that minimizes the potential for discharging pollutants in stormwater. While they have been required for many years on a trust basis, the new permit requires applying an updated EPA template to any existing SWPPPs.
What we do: Our SWPPP experience allows us to help clients transition to the new template at minimal cost and disruption. For operators who prefer to author their own SWPPPs, we can provide a third party review to make suggestions, provide expert quality control, and ensure compliance. We can also provide third party training of stormwater pollution prevention teams one time or on an ongoing basis.
Quarterly visual monitoring and annual assessment
Why it matters: As part of the revised SWPPP, many industry sectors will now be required to perform quarterly monitoring of stormwater discharges, benchmark testing for at least a year, and a formal annual re-assessment of the site and SWPPP. For many operators, this will be the first time that they will be required to capture grab samples during storm events and perform testing procedures.
What we do: We have performed stormwater grab sampling for many years. Our engineers and team of seasoned inspectors can help permit holders meet these new requirements with monitoring and related advice that can help maintain compliance.
As existing infrastructure specialists with a sole focus on stormwater, the SMC team has already begun to assist industrial clients with these new permitting requirements and will be increasing our capacity as needed to help our clients meet the new requirements. Whether it is a simple SWPPP review or developing a strategy to address the restoration requirements, we are here to help.
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