Georgia EPD has reissued general permits for stormwater discharge from construction sites. As background, NPDES General Permit No. GAR100000 for storm water discharges associated with construction activity was issued in 2000 and regulated construction activities that disturbed five (5) or more acres. In 2003, the permit was reissued as three general permits that regulate construction activities that disturb one (1) or more acres:
NPDES Permit No. GAR100001 – regulates stand-alone construction sites,
NPDES Permit No. GAR100002 – regulates infrastructure construction sites, and
NPDES Permit No. GAR100003 – regulates common development construction sites.
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Summary of Changes to Permit
- The term “projects” has been changed to “sites” for consistency with the permit definitions.
- The draft permits contain changes as a result of EPD’s implementation of the NPDES Electronic Reporting Rule. Beginning on the effective date of the permit, All Notices of Intent (NOI), Modifications and Notices of Terminations (NOT) must be submitted through EPD’s electronic submittal portal. EPD is preparing an electronic method for submitting sampling reports. ES&PC Plans required to be submitted to the EPD District Offices must now be submitted electronically through EPD’s electronic submittal portal or as a PDF on CD-ROM or other storage device.
- All references to anionic polyacrylamide (PAM) have been replaced by “flocculants or coagulants”, and “matting or blankets” has been replaced with “slope stabilization” to be consistent with the most recent Manual for Erosion and Sediment Control.
- BMP options which were no longer “over and beyond” have been removed from the options to address impaired waters.
- The permit now requires a large sign (minimum 4 feet x 8 feet) must be posted on site by the actual start date of construction. The sign must be visible from a public roadway. The sign must identify : (1) the construction site, (2) the permittee(s), (3) the contact person(s) along with their telephone number(s), and (4) the permittee-hosted website where the ES&PC Plan can be viewed. The sign must remain on site and the ES&PC Plan must be available on the provided website until a NOT has been submitted.
- EPD has added a BMP option to address impaired waters, to conduct inspections during the intermediate grading and drainage BMP phase and during the final BMP phase of the project by a certified Level II design professional to
improve overall site management quality control, and to install Post Construction BMPs which remove 80% TSS - EPD has clarified that Whenever a permittee finds that a BMP has failed or is deficient (beyond routine maintenance) and has resulted in sediment deposition into waters of the State, the permittee shall submit a summary of the violations to EPD correct such BMP as follows:
a. When the repair does not require a new or replacement BMP or
significant repair, the BMP failure or deficiency must be repaired by
the close of the next business day from the time of discovery;
b. When the repair requires a new or replacement BMP or significant
repair, the installation of the new or modified BMP must be completed
and the BMP must be operational by no later than seven (7) days from
the time of discovery. If it is infeasible to complete the installation or
repair within seven (7) days, the permittee must document why it is
infeasible to complete the installation or repair within the seven (7)
day timeframe and document the schedule for installing or repairing
the BMPs and making the BMPs operational as soon as feasible after
the seven (7) day timeframe.
Summary of Changes to Erosion, Sedimentation and Pollution Control Plans
Revisions to the requirements for Erosion, Sedimentation and Pollution Control Plans include:
- For building materials, building products, construction wastes, trash, landscape materials, fertilizers, pesticides, herbicides, detergents, sanitary waste and other materials present on the site, provide cover (e.g. plastic sheeting, temporary roofs) to minimize the exposure of these products to precipitation and to stormwater, or a similarly effective means designed to minimize the discharge of pollutants from these areas. Minimization of exposure is not required in cases where exposure to precipitation and to stormwater will not result in a discharge of pollutants, or where exposure of a specific material or product poses little risk to stormwater contamination (such as final products and materials intended for outdoor use).
- The permit requires permittees to measure and record rainfall within disturbed areas of the site that have not met final stabilization once every 24 hours except any non-working Saturday, non-working Sunday and non-working
Federal holiday.
Construction Activities Not Requiring Permit Coverage
EDP has also clarified that permit coverage is not required for discharge of storm water associated with infrastructure road construction sites that consist solely of the installation of cable barriers and guard rail for an existing facility within the existing rights-of-way. The construction activity shall, as a minimum, implement and maintain best management practices, including sound conservation and engineering practices to prevent and minimize erosion and resultant sedimentation, which are consistent with, and no less stringent than, those in the “Manual for Erosion and Sediment Control in Georgia”. In order to be eligible for this exemption the project must comply with the following conditions: (1) no mass grading shall occur on the project, (2) the project shall be stabilized by the end of each day with temporary or permanent stabilization measures, (3) final stabilization must be implemented at the end of the project.
Permit coverage is also not required for discharge of storm water associated with infrastructure construction sites that consist of the installation of buried utility lines and comply with the following conditions: (1) solely installed via vibratory plow, (2) the conduit does not exceed 4 inches in diameter, and (3) occurs within an existing stabilized right-of-way. The construction activity shall, as a minimum, implement and maintain best management practices, and the following conditions: (1) no mass grading shall occur on the project, (2) no tree clearing, (3) no change in grade, (4) the project shall be stabilized by the end of each day with temporary or permanent stabilization measures, and (5) final stabilization must be implemented at the end of the project.
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