NAVIGATING THE NEW FEDERAL STORMWATER PERMIT for MARINAS
- Is your marina in compliance with the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity?
- Does stormwater precipitation runoff from your marina property directly into a river, lake, pond or the ocean?
- Are you performing boat maintenance, pressure washing, painting, drydock operations, or engine maintenance and repairs in areas that are exposed to rainfall?
Rainfall may be picking up pollutants on your site and illegally discharging into adjacent waters. Does this all sound like a foreign language to you?
LET US HELP.
The United States Environmental Protection Agency (US EPA) recently reissued a 5-year general permit to regulate stormwater discharges from industrial activities. Marinas, designated by the primary use SIC code 4493, are explicitly included among “industrial activities” requiring permit coverage. By law, stormwater discharges from your marina must obtain coverage under this general permit, and certain routine activities such as pressure washing, painting, engine repairs and other boat maintenance at your marina may be in violation if they are exposed to rainfall. Perhaps you were aware of the first general permit issued back in 2000, which has since expired, or perhaps this is the first time you are learning about this. Whether or not your marina was covered under the previous 5-year general permit, the deadline for submitting application materials to the US EPA for permit coverage under the new permit is January 5, 2009.
Horsley Witten Group (HW) is a Massachusetts-based firm with unparalleled stormwater management expertise. Our engineers and regulatory specialists can help you to navigate this permit process and limit your exposure to regulatory violations that can cost you money and headaches. We have recently assisted two Cape Cod marinas by designing stormwater controls using a combination of good housekeeping and low impact development (LID) techniques. Let us help you too. We can help you prepare your permit application and manage your permit over the 5-year permit period, and help you select, design, implement and maintain cost-effective stormwater control practices at your marina to achieve compliance with the general permit.
We have prepared the following overview of the MSGP for Stormwater Discharges Associated with Industrial Activity.
Application Materials for Permit Coverage
A written Stormwater Pollution Prevention Plan (SWPPP) for your marina, including a description of the existing drainage and stormwater discharge locations on your property; the potential pollutant sources at your marina; the stormwater control measures you will use at your marina to minimize pollutants; the monitoring that you will perform in accordance with the general permit; your schedule for applying control measures and conducting required monitoring; documentation of compliance with other federal/state regulations; and your signature or that of the person responsible for implementing the SWPPP; and
A submittal form, known as a Notice of Intent (NOI), requesting permit coverage.
Application Deadline: January 5, 2009. After this date, your marina may be in violation. We recommend professional assistance to help you understand the regulatory requirements.
Permit Expiration Date: September 29, 2013.
The general permit and the authorization to discharge stormwater from your site expire on this date. EPA will then issue a new general permit.
Once you apply for coverage, then what?
There are a number of measures that you must perform on a quarterly or annual basis to comply with the permit over the 5-year permit period. These include
- Select, design, install and maintain stormwater control measures to minimize stormwater pollutants at your marina. Stormwater discharges from your site must meet effluent limits, which are stipulated based on the stormwater control practice or the actual measured water quality. These may be more stringent if your marina drains to a water body with water quality that is already impaired. Stormwater control measures at your marina may include
- Collecting and containing discharges from pressure washing areas.
- Moving all maintenance activities under a shed to avoid commingling of engine fluids, paints, paint chips, solvents, spent abrasives and other harmful materials with stormwater runoff.
- Changing cleanup operations improving drydock area cleanup procedures prior to flooding, sweeping instead of hosing down work areas, using absorbent materials to clean up spills.
- Perform regular quarterly stormwater sampling and visual assessments at the stormwater outfalls from your marina. Depending on the results, the frequency of these may be reduced over time.
- Perform annual site inspections to ensure that you are minimizing the potential for stormwater pollution.
- Submit an annual report to the US EPA, describing your annual monitoring and inspection results.
- Report any changes to the activity or layout of you marina that may affect the quality of stormwater draining from your marina.
- Follow your SWPPP. You must also update your SWPPP to incorporate any necessary corrective actions, and make the SWPPP available to the US EPA at all times.
- Maintain records for up to three years following the permit coverage term.
What Activities are NOT Covered Under this Permit, and What Can I do About Them?
The following discharges that may be occurring at your marina are not covered under this permit
- Construction-related Stormwater Discharges.
- Discharges from Pressure Washing Stations.
- Sanitary wastes.
- Bilge and ballast water.
- Cooling water from vessels.
If you have these types of discharges, we can assist you in revising your practices to avoid or meet permit requirements, or to apply for coverage under the appropriate permit program.
