In California, the Stormwater Multi-Application, Reporting and Tracking System (SMARTS) issue the Industrial Stormwater General Permit (IGP) and the Construction Stormwater General Permit (CGP) in accordance with the EPA’s National Discharge Elimination System Permits (NPDES). Both permits are designed to reduce pollution entering into stormwater runoff. Failure to obtain the required permit as well as unpermitted discharges are two obvious and direct violations, but other violation of state stormwater permits may be less obvious.
The unlawful and intentional discharge of contaminants into stormwater drains, the failure to adequately sample and analyze stormwater events, the failure to develop, implement and revise Stormwater Pollution Prevention Plans, and the failure to file true and timely annual reports can all lead to a Notice of Violation (NoV). However, the most common violation of NPDES, as observed by CloudCompli users, are also the easiest to avoid. Good housekeeping habits, as opposed to letting work sites grow messy and disorganized, will go a long way towards ensuring compliance. If for some reason general housekeeping falls in your list of priorities, here is list of the most common violations to look out for:
1. Dirty trucks that regularly enter and exit unpaved worksites and introduce dirt and debris onto the public streets are among the most commonly observed and easily avoidable violation. Vehicle operators must take steps to prevent sediment from contaminating public streets, especially during the rainy season. Installing wheel wash stations at exit points may be necessary to clean off tires from vehicles and equipment that are departing a work site. However, it is important to note that wastewater from wheel washing stations must also be properly disposed of. Unlawful discharges of wastewater from wheel washes, pressure washers and surface cleaning activity is a related violation that is often observed.
2. The second most common violation is the spillage of automotive fluids and polluted car parts that are exposed to rainwater. If oily automotive parts are stored outside, they should be palletized, placed on a spill plate and covered to avoid unmitigated stormwater pollution. Effective BMPs such as these must be implemented to prevent stormwater contact with pollutants and avoid a prohibited stormwater discharge. Otherwise, storing things outside can introduce contaminants into stormwater runoff and could lead to a NoV and a hefty fine.
3. At both construction and industrial sites, CloudCompli users often see the improper handling of stone-related slurry that results in prohibited discharges. Stone cutting business that discharge stone-cutting slurry into the stormwater drain system results in a similar environmental impact as mixing and pouring cement. Toxic metals like copper and zinc could find there way into the watershed. Although it may seem harmless to wash rock and stone down a stormwater drain, slurry can very negatively impact the environment and must be properly managed and disposed of.
4. Ineffective spill response that results in the release in stormwater pollution is yet another common violation. Generally, permit holders seek to do right by the permit but sometimes do not go far enough when it comes to spill cleanup. Management protocols related to spill response are designed to prevent the furtherance of pollutants entering into the environment. If a spill response is inadequate, a violation may be issued, so be on the lookout for this.
5. Finally, discharges of waste from sweeping, cleaning, vacuuming and maintenance equipment is a frequent violation because it may be the least obvious source of pollutants. Equipment as power washers and HVAC cleaning and maintenance equipment that are used outside often result in stormwater pollution. Effective BMPs must be implemented to prevent the discharge of wastewater to the storm drain system could also result in a NoV.
CloudCompli users see a lot of potential violation, but with the use of the CloudCompli software, they are able to avoid them and remain in compliance with General Permits and National Discharge Elimination System Permits. To learn more about CloudCompli, contact us, below.