Georgia Industrial Stormwater – Change is Coming!

Federal regulation 40 CFR §122.26 requires facilities with industrial stormwater discharges to apply for a National Pollutant Discharge Elimination System (NPDES) permit; either an individual permit or a general permit from an authorized state, such as Georgia, that has promulgated NPDES authority. In Georgia, facilities that wish to seek general permit coverage do so through the Georgia Environmental Protection Division (GAEPD) NPDES General Permit No. GAR050000 for Stormwater Discharges Associated with Industrial Activities.

Most general permits are issued for a five-year period, and GAEPD’s GAR050000 General Permit is no exception.  The current version of the GAR050000 General Permit was issued on June 1, 2017, and will expire on May 31, 2022. On February 8, 2022, GAEPD posted a public notice for the proposed reissuance of the GAR050000 General Permit along with a draft version of the new GAR050000 General Permit that is expected to go into effect on June 1, 2022.

So, what’s changing?

There are four sizable differences in the new draft permit. Keep in mind that this is still a draft – the permit has not yet been finalized – but the proposed updates are in alignment with EPA’s Multi-sector General Permit.

• Signage posting requirements,
• Electronic form submittals,
• Electronic discharge monitoring reports (DMR), and
• Indicator monitoring requirements.

GAEPD is requiring that all permittees post signage indicating permit coverage at a publicly accessible location near the activity. This signage must include not only facility and GAEPD contact information, but also stormwater pollution prevention plan (SWPPP) access information.

Notifications and reports are going digital. GAPED is requiring all Notice of Intent (NOI), Notice of Termination (NOT), No Exposure Exclusion (NEE), and Annual Reports be completed using the GAEPD Online System (GEOS). Electronic submittal was highly encouraged in the past but will now be required.

All stormwater monitoring data collected under the General Permit is to be submitted to GAEPD using NetDMR, EPA’s electronic DMR system, on a quarterly basis. This will be a significant change for facilities since in the past monitoring data was only reported as a part of the Annual Report. Failure to submit DMRs timely will result in an automatic Notice of Violation (NOV). GAEPD has addressed many comments and concerns regarding this change in their response to stakeholder comments on the GAEPD NPDES Industrial Storm Water General Permits site.

Indicator monitoring has been added, in addition to existing benchmark monitoring requirements, for all permittees. All sectors are now required to sample and analyze stormwater for pH, total suspended solids (TSS), and chemical oxygen demand (COD) on a quarterly basis. Certain industrial sectors and activities will also be required to conduct indicator monitoring for polycyclic aromatic hydrocarbons (PAHs). There are no proposed limits or thresholds for indicator monitoring.

What do I need to do?

Upon issuance of the new permit, existing GAR050000 permittees will need to re-apply for coverage by electronically submitting a NOI within 30 days of the effective date. The window for submitting a new NOI for sites seeking new coverage will re-open at that time as well. All SWPPP plans should also be updated to demonstrate compliance with the new General Permit.

If you have questions about how the draft GAR050000 General Permit could affect your NPDES stormwater compliance, or what your next steps should be when the GAR050000 General Permit is renewed, please reach out to me at mdabrowski@all4inc.com or Anna Richardson at arichardson@all4inc.com. ALL4 is monitoring all updates published by GAEPD on this topic, and we are here to answer your questions and assist your facility with any aspects of industrial stormwater compliance.