Industrial Stormwater Updates in the Southeast

2022 is an active year for industrial stormwater general permits in the Southeast United States. Current general permits in Alabama, Georgia, South Carolina, and Tennessee all expire within the next few months. Here is the ‘big picture’ overview of activity surrounding each of these permit renewals.

Alabama

Alabama Department of Environmental Management (ADEM) has several active general National Pollutant Discharge Elimination System (NPDES) permits for different industrial sectors. Permits for multiple sectors are set to expire in 2022, the majority in September. Facilities with current permit coverage should receive an email from the Alabama Environmental Permitting and Compliance System (AEPACS) notifying your facility of the permit expiration date and the requirement to submit a new Notice of Intent (NOI) to retain coverage under the new permit. NOIs and application fees must be submitted 90 days prior to the current permit expiration date. The 90-day deadline has already passed for both the Food and Lumber and Wood sectors. A list of all general NPDES permits and their expiration dates can be found on ADEM NPDES Permits website.

Georgia

Georgia Environmental Protection Division (GEPD) has issued a draft version of their NPDES Industrial Stormwater General Permit (IGP). There are significant proposed updates from the 2017 IGP. ALL4 has thoroughly reviewed the draft permit and provided a summary of the most impactful changes in our article Georgia Industrial Stormwater – Change is Coming! The new IGP is scheduled to go into effect on June 1, 2022. Facilities wishing to retain current coverage will have 30 days from the effective date to submit a new NOI and 90 days to make necessary changes to their Stormwater Pollution Prevention Plan (SWPPP). The draft permit and other pertinent information can be found on GEPD website.

South Carolina

The Industrial Stormwater General Permit (SCR000000) is currently on public notice and has already undergone both South Carolina Department of Health and Environmental Control (SCDHEC) and U.S. EPA approval. The current SCR000000 permit expired on September 30, 2021. However, language within the permit allows for the permit to remain in effect until such time that a new one is issued. Facilities with current coverage will need to submit an NOI within 90 days of the new permit’s effective date. A copy of the draft permit can be found on the SCDHEC stormwater website. The draft permit should become effective sometime within the third quarter of 2022. The most noticeable change in the draft permit from the current permit is that quarterly benchmark and impaired stream monitoring will also be required in the fourth year of permit coverage, not only in the first year. The draft permit also makes allowances for composite sampling, instead of grab sampling only, for benchmark monitoring.

Tennessee

On March 10, 2022 Tennessee Department of Environment & Conservation (TDEC) issued an update on their website regarding their NPDES Industrial Stormwater General Permit – Tennessee Multi Sector Permit (TMSP). Previously, TDEC reissued the 2015 TMSP for another two years. That reissuance became effective on July 20, 2020 and was set to expire on June 30, 2022. Due to the timing of the release of the new federal Multi Sector General Permit and ongoing challenges of the COVID-19 pandemic, TDEC has decided to reissue the current TSMP for a three-year period. Once reissued, this extension is expected to expire on June 30, 2025. Facilities with a current NOI on file with TDEC do not need to take any additional action to retain coverage throughout this three-year period.

ALL4 is continually tracking updates to stormwater permits across the Southeast and is available to assist facilities with the following:

• Site assessment to determine stormwater permit coverage requirements
• NOI submittal
• Individual NPDES stormwater permit application if a general permit is not available
• SWPPP preparation and updates
• Discharge Monitoring Report (DMR) and annual reporting submissions
• Training

Please contact Anna Richardson at arichardson@all4inc.com with any questions you may have on how these changes could affect your facility.