Florida National Pollutant Discharge Elimination System Stormwater Requirements

The U.S. Environmental Protection Agency (EPA, www.epa.gov) established the National Pollutant Discharge Elimination System (NPDES) program back in the 1970’s to meet the requirements of the federal Clean Water Act.  The initial focus was on point source discharges from industrial facilities.  In the early 1990’s, EPA was forced to address nonpoint sources which was stormwater runoff from certain municipalities, industrial plants, and construction sites.  After several years the Florida Department of Environmental Protection (FDEP, www.myflorida.com) took over the program from EPA.  The focus of the rest of this article will be on the requirements for stormwater runoff for industrial facilities.

Industrial facilities included are manufacturers and those with Standard Industrial Classifications (SIC) 20 through 45, 50, and 51, plus power plants, mining operations, recycling facilities, and transportation facilities.  Others include landfills, mines, hazardous waste facilities, and junkyard facilities.  Industrial areas or operations which could impact stormwater include material storage, access roads, and rail lines, manufactured and intermediate product storage, material handling equipment storage, and maintenance areas.  Drums or tanks of solvents, oils, and chemicals are included as are open dumpsters, air compressors, and material handling areas outside.  Facilities are covered if their stormwater runoff discharges directly or ultimately to navigable waters of the U.S.  In Florida, this applies to most sites.

So if you have any sources of pollutants which could be entrained in the stormwater runoff, what do you do?  First, file a Notice of Intent to be covered under the General Permit.  A fee of $500.00 must accompany the form, which is for the five years of permit coverage.  Next, you must prepare a Storm Water Pollution Prevention Plan (SWPPP) and implement it.

Finally, quarterly visual monitoring of the stormwater runoff will have to be completed for the life of the permit.  Additionally, for certain SIC Codes, in years 2 and 4 of the permit, samples will have to be analyzed in an analytical laboratory.  Analytical results must be reported to FDEP by March 1st of the year following monitoring.  In certain cases when the analytical results for year 2 of the monitoring are in compliance, the FDEP may waive entirely or partially the year 4 analytical monitoring requirements.

A side note is that monitoring is required twenty-four hours a day, seven days a week.  The regulations do not stipulate that it is only required during normal business hours.  It is imperative that you make every reasonable effort to complete monitoring during each calendar quarter.  The FDEP has access to rainfall records for your area.

Like a lot of environmental regulatory programs, documentation is key.  That includes your Notice of Intent, payment of the fee, Storm Water Pollution Prevention Plan, Training, monitoring, and reporting.  Included in the monitoring is logging rainfall measurements daily which is key to monitoring stormwater runoff.

So now you know what the requirements are for Florida’s NPDES Stormwater program for industrial facilities.  If you need any more information, Environmental Safety Consultants (www.escflorida.com) can assist.  We have the credentials and experience to answer your questions and steer you in the right direction.  We are a Florida-licensed Engineering business with over thirty-five years of stormwater experience.  We are just a telephone call (800-226-1735) or an e-mail away ([email protected]).  Contact us today!

Industrial Wastewater Permits

Industrial Wastewater PermitsFlorida Department of Environmental Protection (FDEP) regulates wastewater discharges in Florida.  There are two types of wastewater, domestic and industrial.  Domestic wastewater is sanitary wastewater or sewage, while industrial wastewater is generally everything else.  Industrial wastewater can come from various sources.  These include manufacturing plants, industrial operations, construction, agricultural production and processing, commercial businesses, car washes, food processing facilities, ready mix concrete plants, boat repair yards, marinas, petroleum and solvent cleanup sites, mines, and more.

 

To be regulated, the discharges must have pollutants in them and be discharged to waters of the State (or to groundwater, which is not the focus of this article) or have a reasonable expectation to be a source of water pollution.  Waters of the state include rivers, streams, lakes, ponds, estuaries, bays, the gulf, and oceans.  Ditches that flow into these waters are included.

 

The pollutants are identified in 62-302, Florida Administrative Code (F.A.C.).  They include organic matter and chemicals, metals, nutrients, solvents, petroleum hydrocarbons, particulates, pesticides, radioactive materials, and more.

 

All industrial wastewater permits stem from the federal Clean Water Act enacted by the U.S. Congress in the 1970’s and implemented by the U.S. Environmental Protection Agency (EPA, www.epa.gov) under its National Pollutant Discharge Elimination System (NPDES).  In Florida, the NPDES regulations are implemented by FDEP (www.flwaterpermits.com).   Usually, the local FDEP District Office is the permitting authority.  Sometimes, it is a county environmental office and for a couple of permit types, it is the State FDEP Office in Tallahassee.

 

There are NPDES permits for point sources (e.g., discharge pipe from a manufacturing plant) and nonpoint sources (i.e., stormwater runoff).  In this article, we are focusing on point sources.  Regardless of that, FDEP issues one NPDES permit for the facility which serves as both the state and the federal permit.

 

Not every facility needs an individual industrial wastewater permit.  There are general or generic permits which cover common facilities with similar operations, pollutants, controls, and discharges.  These are available for concrete ready mix facilities, tomato wash operations, laundromats, fish farms, sand and limestone mines, fresh citrus wash water, and car wash systems.

 

The first step is to determine if you are discharging to waters of the State and if the discharge contains pollutants.  After that, you will need to calculate volumes and concentrations of pollutants in the discharge.  Testing may be required to determine the concentrations.  The testing may require a simple grab sample or may require a sample composited over 24 hours or more.  A state certified lab will be required to analyze the samples.  A Chain-of-Custody form will be required to follow the sample bottles from the laboratory shipping the empty bottles through sample collection, transportation, and submission to the laboratory.  While you may save money collecting the sample yourself, it pays great dividends to have a trained environmental scientist or engineer collect it.

 

Whatever your needs are, Environmental Safety Consultants (www.escflorida.com) can help you evaluate your operation, test your discharge, and apply for your industrial wastewater permit.  We are a Florida-licensed Engineering business with a Professional Engineer (P.E.) on staff.  We are just a telephone call (800-226-1735) or an e-mail away ([email protected]).  Contact us today!