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Ohio EPA: Draft Industrial Storm Water General Permit (OHR000006) Noteworthy Changes

Friday, March 31, 2017

Ohio EPA’s draft Industrial Storm Water General Permit (OHR000006) has been public noticed for comment, and is expected to be issued May 1, 2017. See below for the key renewal/coverage information, noteworth changes, and additional information.

Renewal of Coverage

Within 90 days of being notified:

  • Submit NOI application through the Ohio EPA eBusiness center and $350 fee
  • Revise SWP3 within 180 days of OHR000006 effective date

Initial Coverage (new)

Within 180 days of commencing discharge

  • Develop SWP3
  • Submit NOI Application and $350 fee

Noteworthy Changes

1. Part 1.1.3.  More specific language has been added for conditions when pavement wash waters and routine external building washdown are an allowable non-storm water discharge authorized by the permit.  This language is consistent with USEPA’s current 2015 MSGP.

2. Part 1.1.4.4. There is no change to this part of the permit; however, language was added which clearly lists the storm water discharges subject to effluent limitation guidelines under 40 CFR, Subchapter N that are not eligible for coverage under this general permit and would require authorization to discharge under an individual NPDES permit.  OHR000005 did not specifically list these discharges and USEPA requested that Ohio EPA clearly list these discharges as not eligible for coverage with this permit renewal. 

3. Part 1.3.1, Part 1.4.1 and Part 1.5.  This general permit renewal will require Notice of Intent (NOI), Notice of Termination (NOT) and No Exposure Certifications to be submitted electronically using Ohio EPA’s electronic application forms which are available through the Ohio EPA eBusiness Center at https://ebiz.epa.ohio.gov/. 

Submission through the Ohio EPA eBusiness Center will require establishing an Ohio EPA eBusiness Center account and obtaining a unique Personal Identification Number (PIN) for final submission of the applications.  Existing eBusiness Center account holders can access the applications through their existing account and submit using their existing PIN.  Please see the following link for guidance: http://epa.ohio.gov/portals/35/edmr/doc/STREAMSGuide(Dashboard).pdf

The general permit does provide that an entity which is unable to access the forms through the agency eBusiness Center; due to a demonstrated hardship, may submit the applications via paper applications provided by Ohio EPA.

4. Part 4.1.3 and Part 4.2.3.  Language has been added which allows the reduction of the required frequency for routine facility inspections and quarterly visual assessments for facilities that are recognized under the Gold and Platinum levels by Ohio EPA’s Encouraging Environmental Excellence (E3) Program.  For additional information on Ohio EPA’s E3 Program, please see the following link: http://epa.ohio.gov/ocapp/ohioe3.aspx.

5. Part 4.3.  USEPA’s 2015 federal MSGP consolidated the comprehensive site inspection and routine facility inspection procedures into one set of procedures to eliminate redundancies and reduce burden.  This draft general permit has mirrored this approach and Part 4.3 (Comprehensive Site Inspections) has been removed from the general permit.

6. Part 5.3.  Language has been added requiring permittees to make available to the public their SWPPP when requested, excluding any confidential business information (CBI) or restricted information.

7. Part 6.2.1.2.  The general permit provides permittees the first 3 years of their permit coverage under the general permit to complete the benchmark monitoring requirements which is consistent with OHR000005.  Language has been added to clarify that permittees obtaining coverage in years 4 and 5 of the general permit must complete benchmark monitoring requirements to the extent of remaining monitoring periods available before the general permit expires.

8. Part 6.2.1.2.  Language was added to provide permittees that may be exceeding a benchmark; due to, a neighboring facility’s storm water run-on a procedure to document and account for this situation.

9. Part 7.2 and Appendix I.  The annual report has been modified to be consistent with USEPA’s current federal MSGP Annual Report. Consistent with OHR000005, the annual report is to be completed on an annual basis and maintained with the permittee’s SWPPP. 

10. Part 8.C.2.1.  Language was added to more clearly identify that the discharge of leachate, as defined by Ohio Administrative Code (OAC) 3745-27-01(L)(1), is not authorized by this general permit.

11. Table 8.C-1 and Appendix D, Sector C.  Compost facilities (SIC 2875) were originally located in Subsector C1.  Compost facilities have been removed from Subsector C1 and located in a newly created Subsector C6 which provides more appropriate benchmark monitoring parameters for this industry.

12. Part 8, Subpart Q –Sector Q –Water Transportation. Marinas have been added to Sector Q of the general permit.  Currently, Ohio EPA has a specific general permit for marinas (OHRM00002) which expires on January 21, 2018.  Ohio EPA will not be renewing the Marina Storm Water general permit when it expires.  Marinas with coverage under OHRM00002 will remain covered under that general permit until it expires.  Once the Marina Storm Water general permit expires on January 21, 2018, these currently permitted marinas will be instructed to renew their coverage under this general permit renewal (OHR000006) and be subject to this general permit’s conditions at that time. 

The current Marina Storm Water general permit authorizes the discharge of boat wash water if no detergents or other chemical cleaning agents are used.  This general permit renewal does not authorize boat wash water.  Such discharges would require proper collection and disposal (i.e., sanitary sewer) or be permitted by a separate NPDES permit.

13. Appendix B. Standard Permit Conditions.  Appendix B has been updated to reflect the “Standard Permit Conditions” language found within Ohio EPA general permits.  OHR000005’s “Standard Permit Conditions” language was from USEPA’s federal MSGP and required updating to be consistent with Ohio’s other NPDES general permits. 

 

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