Document O1dR8zD30pQ90RzEQNL1Xv4oj

To: Environmental Coordinators From: Joe Ledvina Date: December 26, 1990 Subject: New Storm Water Permit Application Rules EPA promulgated new storm water discharge permit application rules on November 16, 1990. A copy of the rule is attached. As you can see it is lengthy. However, much of the language concerns group permits and general permits as well as rules for municipalities. As I read it, since we already have storm water permits, we are not eligible for the group or general permit programs. As a result, much of that language doesn't apply to us. Following are some points 1 have picked out of the rule along with some observations where appropriate: 1. As I said above, since we already have storm water permits at our facilities, we are not eligible for group or general permits. 2. Section 122.26(e)(6) states that facilities with existing NPDES permits for storm water discharges associated with industrial activity shall maintain existing permits. Facilities with permits due to expire before May 18, 1992 must reapply as specified in 122.26(e)(1), that is, by November 11, 1991. 1 believe LCCC must meet the 11/11/91 application deadline. However, since the LCCC NPDES permit will expire in September, 1991, I suggest you ask EPA Region IV under which rules the stormwater application should be submitted. 3. These rules and application forms apply in states where EPA runs the water program. In states that have designated authority, such as Mississippi, it is uncertain which forms should be submitted with the application. The instructions suggest you talk to the state agency. 4. Forms 1 and 2F are required for storm water only outfalls. Outfalls where th re could b a mixture of storm wat r and proc as wat r, such as LCCC outfalls 002, 018, and 031, must submit Forms 1, 2C, and 2F. VEO 000108247 b. Each outfall must be sampled at least once during the first 30 minutes of discharge and then on a flow-weighted basis throughout the discharge and analyzed for priority pollutants and all other pollutants limited in the process wastewater discharge permit. This could be a very significant sampling and analytical burden at LCCC. I believe there is a provision allowing grouping of outfalls discharging comparable storm water under one sample set. I will continue to look into this and will pass along pertinent information as I get it. If any of you have information on the storm water permit application process that I missed or have misinterpreted please let me know. At a minimum, you should review the permit application forms and the instructions and read section 122.26(e). cc:(cover letter only) Plant Managers, DLC, VEM, CRW, TWH VEV 000108248