Why Do We Monitor Storm Water? As you recall from grade school, the hydrologic cycle is the movement of water from air to soil and back to lakes, streams and oceans. The sun evaporates the water and the process begins again. In order to protect our drinking water, the Environmental Protection Agency and other Governmental groups write and enforce laws that protect the environment by regulating what industry discharges to the air, soil and water. The Clean Water Act prompted regulations that require that only rain go into storm drains and that all other industrial water discharges be reduced or eliminated to protect our water from contamination. While other regulations look specifically at air and soil contamination, the Storm Water Pollution Prevention Program looks to regulate only storm water.
General Industry Requirements If you are an industry required to participate in the Storm Water Program, then you must file for a Notice of Intent (NOI) with the Regional Water Quality Control Board that documents your efforts to comply with the States measures to assure that all industrial generators meet the Federal clean water standards. Basically this means if you manufacture, store or transfer products outdoors that could produce contaminants by having rain fall upon them, or if you could possibly have an accidental spill, or other industrial process that could cause these contaminants to flow off your property during a rain event and enter the storm drain then you must participate in the program.
What is a company’s responsibility? You must identify all industrial activities that could potentially cause pollutants to leave the property and enter the storm drain. You must take measures to reduce these contaminants by putting in place policies and procedures as well as physical barriers, if necessary, to minimize or eliminate contaminants from leaving the property and you must document that your methods are working by taking samples of storm events and comparing the results to national standards and your previous storm events.
Program Components A written Storm Water Pollution Prevention Plan (SWPPP) is required to be specifically tailored for each participating company. This plan is to be used to assist in identifying and documenting efforts you have made to eliminate or reduce contaminants. A monitoring program requires you to physically walk your yard and make observations during dry and wet weather to identify if any approved or non-approved discharges have occurred.
Laboratory Testing You must sample at least two storm events capturing runoff water and analyzing for required contaminants. Typically a company must test for pH, suspended solids, specific conductance and either total organic carbon or oil and grease. Additionally, if your company has other contaminants of concern (e.g. a scrap metal yard may have metals and gasoline as possible contaminants) then you must test for those as well.
Documentation Forms are to be completed annually and submitted to the State certifying that you have met your obligation to conduct the site audits, update your SWPPP, perform the required monitoring and lab testing and that your plan works. If it does not show improvement or your levels of contaminants are higher than national benchmarks, then you must certify that you will improve your best management practices and alter your program to achieve the desired levels.
Penalties for Non-Compliance The local administering agencies, normally the water board, will review your documents annually and if not filled out properly or sent in incomplete, has the authority to access fines. Inspectors do regularly visit sites to audit industrial compliance and are very critical of companies that have submitted no documents or have falsified reports, etc. Penalties can be thousands of dollars and can lead to referrals to State environmental departments that can impose civil and criminal actions if the circumstance warrants.
