The Strategies and Challenges of Implementing an Industrial Stormwater Compliance Program for Multiple Facilities
The NPDES Multi-Sector General Permits (MSGP) regulate industrial activity by SIC codes and cluster industry types into groups called “Sectors.” Many different Sectors of industrial activity are covered by the MSGP and environmental objectives may change somewhat depending on the regulated sector. In addition, individual states may have specific requirements beyond those outlined in the EPA MSGP. A Stormwater Pollution Prevention Plan (SWPPP) must be prepared for a permitted facility to outline compliance obligations and to prescribe site-specific BMPs that address on-site pollutant sources and activities.
Successful stormwater compliance at an industrial facility requires consideration of many different pollutant sources and activities, effective communication with facility personnel, and detailed recordkeeping. When multiple facilities are to be managed, consistent compliance expectations must be established to achieve company-wide compliance. MSGP requirements at a facility, including such things as recordkeeping and monitoring, require support from employees outside of the environmental compliance department. Industry environmental compliance professionals are often responsible for multiple permitting programs at multiple facilities and may have a difficult time ensuring compliance when working alone. This is particularly true when a permitee operates multiple facilities across a geographically large area and has a very limited quantity of environmental compliance professionals in-house. For example, it may be very difficult for in-house environmental staff to respond to and sample a discharge from a rain event within the MSGP-required 30-minute period when they are based at a different facility. As such, facility employees in departments outside of environmental must be engaged and properly educated.
An employee training and education program is a required and important competent of MSGP compliance, however a training program alone may not be enough to encourage employees to take an active role in maintaining a facility’s compliance goals. A solid training program is a good strategy to lay the ground work for a successful compliance program, but strategy alone is often not enough to motivate year-round employee participation and involvement.
Join us for an overview of challenges and strategies associated with implementing an industrial stormwater compliance program across multiple facilities with an emphasis on establishing a strong culture of compliance. We will present an overview of permit requirements, compliance strategies, and lessons learned from their implementation. We will discuss methods of engaging staff across multiple departments, professions, and the language barrier. Participants will have the opportunity for group discussion during the presentation to promote the sharing of ideas and experiences.