Double Compliance: Implementing Construction Stormwater Compliance During Industrial Facility Expansions

As industrial facilities flourish and expand to meet market demands, the construction of new buildings and paved areas becomes inevitable. This presentation will offer invaluable insights into industrial and construction permitting, shedding light on how industrial facilities can successfully navigate compliance with both permits concurrently. Learn how effective communication among personnel, project management, contractors, and compliance inspectors can streamline the compliance journey and safeguard your industrial facility's environmental responsibilities.

Full Abstract: The National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) and corresponding state industrial stormwater general permits regulate the discharge of stormwater associated with industrial activities at a wide variety of facilities based on Standard Industrial Classification Code or Industrial Activity Code. As industrial facilities thrive and grow within their marketplace, often, the need for facility expansion arises in order to keep up with customer demand. Facility expansion can often mean the construction of new buildings and paved areas on-site. Construction activities involve disturbance of existing ground cover and have the potential to introduce a new suite of pollutants to the existing on-site stormwater drainage system. Furthermore, stormwater discharges from construction activities are not covered under industrial stormwater general permits, a common misconception for industrial facility personnel who may not be aware that additional coverage is required.

The NPDES Construction Stormwater General Permit and corresponding state construction stormwater general permits regulate the discharge of stormwater from construction activities involving one or more acres of ground disturbance and those within a larger common plan of development with less than one acre of ground disturbance. Often, construction activities related to industrial facility expansion result in at least one acre of disturbance, necessitating construction stormwater general permit coverage. This presents a compliance challenge for industrial facilities: how to simultaneously and successfully comply with both the industrial and construction stormwater general permit for the duration of the construction activity?

This presentation will explore the common compliance requirements of industrial and construction stormwater general permits and will discuss a series of strategies to aid successful compliance with both permitting programs simultaneously. The strategies to be discussed will include elements of staff training for compliance under both general permits, construction stormwater best management practice selection to protect or, as needed, enhance, the existing industrial facility drainage system, and perhaps most importantly, stakeholder engagement in maintaining compliance. Effective communication among industrial facility personnel, project management, contractors, and stormwater compliance inspectors is vital for implementing a successful stormwater compliance program at industrial facilities undergoing construction.