7 mistakes companies make on stormwater compliance
Whether facilities face drought or floods, they face a common challenge: stormwater compliance. The key to avoiding fines that can be as high as $37,500 per day per violation is a basic realization: Compliance is not about stopping the rain. It's about keeping the rain from running off your property.
What's in a bulletproof plan
Polly Porter, a stormwater expert with the Texas Commission on Environmental Quality (TCEQ), told attendees at its environmental trade show how to create a bulletproof stormwater plan. Consider:- No-discharge exemption. In theory, companies can avoid a stormwater permit. "But you're taking a big chance," Porter warns, because a company has to prove that it contained 100% of runoff on its property. Any trickle that leaves a property can trigger a fine for failing to obtain a stormwater permit.
- No-exposure exemption. Move materials, products, waste, storage and work areas indoors. If you put a roof over them, keep materials and equipment off the ground so any runoff won't come into contact with equipment.
- Who signs the permit? A corporate officer or designated manager must sign the permit. If turnover is an issue, list the manager's title as the designated corporate official. That way, the next manager automatically assumes responsibility for filing notices of intent and meeting other stormwater permit requirements.
- Update the stormwater plan. Perfectly prepared plans make inspectors suspicious. They like to see dog-eared pages and coffee stains that prove the plan is a work in progress. A good plan should be full of changes documenting how you modified your best management practices and replaced controls.
- Repair records. Inspectors expect controls to malfunction. A good plan will have detailed repair records and explanations of changes made. Note: You have to be in compliance 24/7, not just during storms.
- Good housekeeping. Inspectors' alarm bells ring loudly when they see a messy operation or sloppy waste storage areas. Inspectors assume that if it's a mess outside, it's a mess everywhere on a property.
- Investigate any discharges. If you bust a discharge limit, document your follow-up inspection and how you fixed the problem. Example: If zinc's in your runoff and it came from your metal roof, add a grass swale or rain garden to capture the runoff and keep it on the property.
Reprinted with permission from:
Environmental Compliance Alert 6/10/11
Wed, July 13, 2011
by Kim Bowman