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Written By: Chris Ruhlin | Mar 2, 2017
Time to Read 7 Minutes
Running an industrial operation in New York (city, county, or state) all means one thing - stormwater permits. Having a stormwater permit often means that you need training, or to hire an outside lab, since part of your permit requires stormwater sampling.
For many operations, this is a tricky thing to stay ahead of, especially if you've gotten a bad sample. But what does a bad sample actually mean? What should you do if you have an exceedance? Regardless of if you're in Brooklyn or Buffalo, you need to treat an exceedance in your stormwater sample the same way.
Most people think stormwater results fall into a black hole never to be seen again, but this couldn't be further from the truth. Many people think that their SPDES stormwater permit requires only that a stormwater sample be taken, and nothing else, but again, this couldn't be further from the truth.
Let me just say this right now: if you screw this up you could be facing enforcement from a multitude of people, and I like to describe it like this:
Just to be crystal clear, I'm only talking about your stormwater sample. Your New York SPDES stormwater discharge permit (more technically called the New York Multi-Sector General Permit or MSGP for short) requires a lot of things in addition to a stormwater sample. This includes:
So your stormwater sample, whether it's one annual sample or more, isn't all you have to do. If you don't get your sample, you darn well better be able to document why you couldn't get one, which better be because you haven't had a discharge and you have the records to prove it! Anything less than that and expect enforcement action.
I know what I have to test it for, and when to get it. But once I get it, that's it, right? I can forget about it for another year? Yes, and no - but it all comes down to the results you get.
Suppose you got a stormwater sample, sent it off to your testing lab, and then got the results back. You checked the results against the applicable benchmark for your type of facility in your SPDES permit, and you were under all of the applicable required benchmarks. What else is there for you to do?
Well first off, celebrate, you're doing a great job! Your stormwater BMPs are working, you have your act together, whatever. Pop the champagne, you're done for the year. Bear in mind that you'll have to report the results to NYSDEC on the required reporting forms, known as Discharge Monitoring Reports (or "DMRs") along with your Annual Certification Report. But that's a given, right?
But here's the million dollar question. What if you exceeded the applicable benchmark values? What do you do? Let's use an example.
Suppose your facility is required to do annual benchmark monitoring for parameters TSS, Y, and Z. You take your sample. What do you do next?
First and foremost, you need to compare your results to the benchmark values for your facility. That means know them. Write them down. Get a tattoo of them for your arm (okay, maybe not really). Regardless, you have to know them, live them, understand them.
So for this example, you took your sample, and back comes your lab result. What you need to do is read that lab report carefully, and compare your results to your benchmarks. In this example, let's assume your results "passed" (i.e., were under) the benchmark levels for Y and Z, whatever that might be. Great news! But, your benchmark level for TSS was 100 mg/L, and your result got a 250 mg/L. That's a problem...
So what do we do?
Well, here's where permit requirements kick in. Turns out, you have to act. You have additional responsibilities:
In short, if you have an exceedance, you have a lot to do.
Let's go back to our example above.
Got that? I know, it's a lot of work and takes a lot of time, but if you proceed through it step by step it's not that hard to deal with. It might sound a bit confusing, but follow this guidance and you should be all set.
The bottom line is that you have to review your sample results and do something about them. You can't file them into that black hole of results, you have to review them and maybe do some corrective action to get good results from then on.
And really, that's the whole goal of this exercise; to produce a cleaner stormwater runoff that is then discharged into our waterways. By engaging in this exercise, you'll start to learn what works, and what doesn't. Not only will you then be in compliance, you'll also be doing your part to keep our waterways clean.
To learn more about stormwater sampling, or how to deal with bad stormwater results, click here to contact us or call us at 609-693-8301 to learn more.
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