Measure 6d:  Review of municipality owned or operated
 regulated industrial activities

“Conduct annual review of the industrial activities with a Phase I NPDES permit owned and operated by the permittee. Specifically review the following aspects: the Stormwater Pollution Prevention Plan where one is required, the timeliness of any monitoring reports required by the Phase I permit and the results of inspections and subsequent follow-up actions.”

Industrial facilities that fall into one of the subject ten categories are required obtain permit coverage under a general permit or an individual permit, depending upon the industrial activity occurring at the facility:

• An individual permit is a permit specifically tailored to an individual facility. Once a facility submits the appropriate application(s), the permitting authority develops a permit for that particular facility based on the information contained in the permit application (e.g., type of activity, nature of discharge, receiving water quality).
• A general permit is an NPDES permit that covers several facilities that have the same type of discharge and are located in a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit. Using a general permit to cover numerous facilities reduces paperwork for permitting authorities and permittees, and ensures consistency of permit conditions for similar facilities.

The NC Division of Water Quality maintains a list of active industrial permits. Facilities that have either a general or an individual industrial stormwater permits must have and implement a Stormwater Pollution Prevention Plan (SPPP). These plans include a comprehensive evaluation of the specific industrial site and operations to reduce pollutant sources and prevent pollutant discharge. The NC Division of Water Quality has a Guidance Document for Stormwater Pollution Prevention Plans. SPPPs include as a minimum, the following:

• Site plan.
• Stormwater management plan.
• Spill prevention and response plan.
• Preventive maintenance plan and good housekeeping plan.
• Training schedule.

Municipalities are already required to review their regulated industrial facilities for compliance with the SPPP on an annual basis. Putting this measure in the Phase II permit underscores the existing requirement. It is your responsibility to:

• Find out if your local government owns or operates any regulated industrial facilities,
• Locate the permit and the SPPP,
• Review the SPPP to make sure it is still up to date,
• Make sure that the staff responsible for the facility are implementing the SPPP correctly.