Permits Overview – Industrial Stormwater/Municipal Separate Storm Sewer System/Individual NPDES: Bryan Leamons P.E. (Arkansas Department of Environmental Quality) Arkansas Water Works and Water Environment Association Presentation

Bryan Leamons, P.E., undertook a presentation at the Arkansas Water Works and Water Environment Association titled:

Permits Overview: Industrial Stormwater (IGP), Municipal Separate Storm Sewer System (MS4), Individual NPDES (“Presentation”)

Mr. Leamons is a Senior Operation Manager in the Arkansas Department of Environmental Quality (“ADEQ”) Office of Water.

The Presentation included a discussion of Clean Water Act General Permit – 40 CFR 124.1 which authorizes:

. . . a category of dischargers or activities under the Clean Water Act within a geographical area. . .

General Permits include Industrial Stormwater Permits (General Permit ARR000000) encompassing industrial activities such as:

• Timber, Paper, and Chemical Products
• Metal, Coal, and Mineral Mining
• Transportation Facilities
• Textile Mills
• Others

Mr. Leamons discussed the application procedures for AR000000:

• Notice of Intent
• Stormwater Pollution Prevention Plan
• Site Map
• $200.00 Application Fee

The No-Exposure Certification was also referenced.

As to the Stormwater Pollution Prevention Plan, the contents were listed such as:

• Responsible Parties and Employee Training
• Facility Information and Description
• Potential Pollutant Sources
• Impaired Waterbodies (303(d) list and TMDLs)
• Best Management Practices (BMPs)
• Outfalls and Monitoring Requirements
• Schedules and Procedures
• Signature

The Municipal Separate Storm Sewer System (“MS4”)was addressed (ARR040000).

MS4 is applicable to urbanized areas.

The application procedures were stated to include:

• Notice of Intent
• Stormwater Management Plan
• Small MS4 Site Map
• Application Fee

The Stormwater Management Plan Contents were stated to include:

• Part 3 of the General Permit

  • BMPs the MS4 will implement

  • Table of Organization

  • 6 Minimum Control Measures

    • Public Involvement/Participation

    • Illicit Discharge Detection and Elimination

    • Construction Site Stormwater Runoff Control

    • Post-Construction Stormwater Management

    • Pollution Prevention (Good Housekeeping)

    • Public Education

The Presentation included a chart comparing stormwater permits and MS4.

As to the “IGP” it was noted:

• Regulates Stormwater Discharge on Numerous Industrial Sectors
• Many facilities make self-monitoring and self-implemented corrective measures
• ADEQ retains full compliance monitoring and enforcement oversight

As to MS4s it was noted:

• Cities, counties, “urbanized areas”
• Non traditional – Campuses and Prisons
• ADEQ performs inspections and audits over 5-year term
• Much reliance on self-monitoring and self-implemented activities
• ADEQ retains full compliance monitoring and enforcement oversight

The final portion of the Presentation addressed the Clean Water Act National Pollution Discharge Elimination System (“NPDES”) individual permitting/renewals.

Mr. Leamons states submissions for NPDES Permits and renewals can be made as follows:

• By mail to:

  NPDES Permits Section

  Office of Water Quality

  Arkansas Department of Environmental Quality

  5301 Northshore Drive

  North Little Rock, AR 72118

• Or by electronic mail (Complete documents must be submitted in Adobe Acrobat format (.pdf) to:

  Water.permit.application@adeq.state.ar.us.

• ePortal: https://eportal.adeq.state.ar.us/

A copy of Mr. Leamons Presentation can be downloaded here.