On April 5, 2017, the Illinois Environmental Protection Agency (Illinois EPA) issued a final version of the Renewal of the Illinois General National Pollutant Discharge Elimination System (NPDES) Permit for Storm Water Discharges from Industrial Activities (General Permit). The permit became effective on April 5, 2017 and expires on March 31, 2022. There are a number of changes from the previous version of ILR00, many of which trigger action items for subject facilities. Applicable deadlines and action items are listed below:

  • By June 30, 2017:  Complete first quarterly facility inspection (details in next section);
  • In 3rd Quarter of 2017 (July-September 2017):  Begin benchmark monitoring (details in next section);
  • By October 2, 2017 (i.e., within 180 days of the effective date of the permit):  Update Storm Water Pollution Prevention Plans (SWPPPs) to comply with new permit requirements. Submit a copy of the updated SWPPP to the Illinois EPA with the next annual inspection report; and
  • In 2018:  Submit annual inspection report to the Illinois EPA (For existing permittees, the due date is 60 days after the original date of effective coverage under a general storm water permit. For new permittees, this annual inspection report is due within 60 days of the anniversary of the initial effective date of coverage under this permit).

Notable changes to the General Permit include the following. Note that not all changes are included here; permittees should closely review the final General Permit to determine the requirements that are applicable to them.

  • New quarterly facility inspections – Facility inspections must be conducted at least quarterly, and at least one of the "routine inspections must be conducted during a period when a storm water discharge is occurring within 72 hours of the beginning of a storm water event equal to or greater than 0.25 inches in 24 hours." 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 later than 180 days after the effective date of the final General Permit) to demonstrate that the facility meets the benchmarks.  If the benchmarks are not met, corrective action and additional sampling would be required until the benchmarks are met. No corrective action is required if the permittee can prove that benchmark exceedances are solely due to natural background pollutant levels. Prior to sampling, a facility must document the sampling procedures in its SWPPP.
  • New Total Maximum Daily Load (TMDL) discharge requirements – The final General Permit includes new requirements for facilities that discharge to impaired waterbodies with and without US EPA-approved TMDLs. A facility discharging to an impaired waterbody with US EPA-approved TMDL, the permittee must determine if there is an applicable waste load allocation (WLA) for its discharges to the waterbody, and it must establish Best Management Practices (BMPs) in its SWPPP to achieve/maintain the waste loading. A facility discharging to an impaired waterbody without an approved TMDL is required to annually monitor at each outfall (except substantially identical outfalls) all pollutants for which the receiving water body is impaired and are associated with industrial site activity for which a standard analytical method exists (see 40 CFR 136).
  • Modified employee training – The final 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.
  • Dumpsters and rolloffs – The final General Permit requires the permittee to minimize dust and offsite tracking of raw, final, and waste materials. Trash disposal areas where dumpsters and rolloffs are located shall have lids which shall remain closed when not in use. For dumpsters and rolloffs without lids, BMPs need to be used to prevent any contaminated storm water runoff.
  • Modified SWPPP contents – The final General Permit requires additional information and documentation to be included in the SWPPP. This includes additional items to be shown 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). The final General Permit requires an update of the SWPPP within 180 days of the effective date of the permit (i.e., changes must be made by October 2, 2017).

For more information on how Trinity Consultants can help, please contact Anna Aumann at aaumann@trinityconsultants.com or (630) 495-1470.