Thursday, September 27, at 10:00 am via YouTube. REGISTER HERE
A New ERA in Industrial Stormwater Regulation: Considerations, Strategies and Lessons Learned for NPDES Regulated Industrial Dischargers Within the Exceedance Response Action Models of Stormwater Regulation presented by Jonathan J. Meronek, QISP, IGP-ToR, CPESC, CISEC, QSP/D delves into new federal and state stormwater regulation under a “trajectory” of required compliance responsibilities that have a major impact on the permitting process.
Effluent benchmark escalation values requiring a tiered response and corrective actions are stricter in the west coast states. Under an ERA-based NPDES Industrial General Permit, dischargers are assigned a status level in their first reporting year of the Permit, usually Level-0. These are not effluent limits, but require dischargers to pursue effective BMPs for their facilities. If a facility exceeds the established benchmarks, then Level 1 status is assigned the following year, and if the same facility continues to exceed the benchmark it will continue to move into an even more stringent category, up to and including Active
Treatment. As states shift to online databases they become more proficient at identifying non-compliant permittees; exposure is costly.