CT Businesses Learn About DEP’s Revised Stormwater Permit
More than 200 manufacturing facilities managers, consultants, and other business professionals attended CBIA’s 2011 Connecticut Stormwater Conference and Tradeshow on March 2 at the AquaTurf Club in Plantsville.
The program, hosted by CBIA’s Environmental Policies Council and sponsored by Arcadis/Malcolm Pirnie and Fuss & O’Neill, unveiled the specifics of Connecticut’s new General Permit for the management of stormwater from industrial sites. Provisions of the revised permit, issued by the Connecticut Department of Environmental Protection (DEP), become effective this October.
“This permit is so totally different that we stop the clock on October 1 and start the whole process over,” said Christopher Stone, stormwater permit engineer with the DEP.
[Pictured above: The DEP’s Christopher Stone (fourth from left) answers an audience question about his agency’s new General Permit at CBIA’s Stormwater Conference. Also pictured (L-R) are CBIA’s Eric Brown, Chris Escedy of Fuss & O’Neill, Sally Kruse of PSEG, DEP’s Nisha Patel (partly obscured), and Arcadis USA’s Jay Kulowiec. More photos from the event.]
Developed over three years with considerable input—and lingering concerns—from both the environmental and business communities, the permit is designed to achieve greater consistency with policies of the U.S. Environmental Protection Agency and streamline the process for authorizing industrial stormwater discharge in compliance with the Clean Water Act.
New Permit “More Prescriptive”
Before a packed room, a panel of DEP and private-sector engineers laid out the details of the new permit, providing clarification about the new language and provisions, their intent and timeline, and their impact on the regulated community.
Stone led off with an overview of public hearings, stakeholder meetings, and modifications that have shaped the new permit. In some ways, he said, it scales back on earlier requirements. (For example, new sampling protocols allow for a greater number of conditions, including less than one inch of rainwater, or sampling that includes snowmelt.) In general, however, Stone characterizes the revised permit as “more prescriptive” than the one it replaces.
Among other things, it calls for minimizing stormwater impacts on the environment using “technologically available and economically practicable/achievable control measures,” an updated stormwater pollution prevention plan, accessible inspection reports, monthly routine “walk-through” inspections in addition to more formal semiannual inspections, and stepped-up requirements for facilities to fix identified problems and document how they were corrected. The permit also incorporates features of the federal Environmental Protection Agency’s multi-sector general permit.
Significant Changes Highlighted
The biggest change to the General Permit, Stone explained, is the inclusion of effluent limits and “benchmarks” where the current general permit has less-consequential “targets.” It also identifies 10 specific sectors with additional requirements beyond those for all covered facilities. The sectors are asphalt plants, nonmetallic mines and quarries, refuse systems/solid waste (transfer stations), auto salvage, scrap recycling, steam electric generation plants, transportation/public works/airports, marinas and yacht clubs, shipbuilding/boatbuilding and repair, and small-scale composting facilities.
Other major changes include
- Semiannual vs. annual monitoring
- Quarterly visual monitoring
- Plan recertification every five years
- Increased registration fees
- Restrictions on new or expanded facilities where the discharge is to a water body classified as impaired
- Public access to every stormwater pollution prevention plan
The new General Permit process also addresses concerns raised by CBIA about facilities’ disclosure of confidential information. The revised permit allows businesses some discretion regarding information they might withhold (for security or proprietary reasons) from plans made available to the public.
Nisha Patel, supervising sanitary engineer at the DEP, led the second session of the conference, which focused on pollution control measures and monitoring requirements set forth in the revised permit. These include inspection, evaluation, and preventive maintenance of floor drains, vehicles, loading docks, roof areas, and other potential sources of contamination; covers and roof structures for temporary and permanent storage sites; waste management; dust, sediment, and erosion control; spill prevention and response; containment requirements for liquid chemical, petrol, and wastewater storage; infiltration, reuse, and treatment of runoff, where feasible; transfer activities; mechanisms for reporting and remediation; and employee training.
The program wrapped up with an in-depth Q&A in which expert panelists fielded dozens of audience questions about sector-specific controls under the new hybrid multi-sector permit. The panel comprised DEP’s Chris Stone and Nisha Patel as well as Chris Escedy, vice president of Fuss & O’Neill and leader of its Environmental, Health, and Safety Engineering Business Unit; Sally Kruse, senior environmental engineer at PSEG Power Connecticut; and Jason Kulowiec, principal engineer at Arcadis USA.
Though the new stormwater rules take effect Oct. 1, registration deadlines begin June 1. For more information about stormwater management and other environmental issues affecting Connecticut’s business community, contact CBIA’s Eric Brown or visit the EPC website. — Lesia Winiarskyj
Lesia Winiarskyj is a writer-editor at CBIA. She may be reached at firstname.lastname@example.org.
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