On October 30, 2016, the Illinois Environmental Protection Agency (Illinois EPA) issued a draft of the Renewal of the Illinois General National Pollutant Discharge Elimination System (NPDES) Permit for Storm Water Discharges from Industrial Activities (General Permit).  (Many of the changes to the draft permit are to align the permit with USEPA's 2015 Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity.)  The public notice period ended on November 30th, and Illinois EPA has since been reviewing comments received on the draft.  It is expected that the final permit will be issued early this year.  There are a number of changes proposed in this draft permit, which include the following.

  • New quarterly facility inspections – The new quarterly inspections "must be conducted during a period when a storm water discharge is occurring."  The facility inspections would include identifying any areas where material could have come into contact with storm water and determining if any control measures need replacement, maintenance, or repair.  The findings must be documented and summarized in the facility's annual report.
  • New "benchmark" performance standards for certain industry sectors – The industry sectors are classified based on standard industrial classification (SIC) code.  Facilities that are subject to these benchmarks will need to perform sampling during the first four (4) full quarters of permit coverage (commencing no earlier than 180 days after the effective date of the renewed General Permit) to demonstrate that the facility is in compliance with the benchmarks.  If the benchmarks are not met, corrective action and additional sampling would be required until the benchmarks are met.  Prior to sampling, a facility must document the sampling procedures in its Storm Water Pollution Prevention Plan (SWPPP).
  • New Total Maximum Daily Load (TMDL) discharge requirements – The draft General Permit includes new requirements for facilities that discharge to an impaired waterbody with a US EPA-approved TMDL with waste load allocations (WLA).  The facility must determine its current waste loading and establish Best Management Practices (BMPs) in its SWPPP to achieve/maintain the waste loading.
  • Modified employee training – The draft renewed General Permit requires facilities to provide annual training for all pollution prevention personnel as well as all employees who work in areas where industrial materials or activities are exposed to storm water.  The permit includes some sector-specific employee training requirements.
  • Modified SWPPP contents – The draft renewed General Permit requires additional information and documentation to be included in the SWPPP.  This includes additional items to show on the site map and additional documents to maintain with the SWPPP, sampling procedures (mentioned above), and BMPs for the waste loading (also mentioned above).

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