Defining All Known, Available, and Reasonable Methods of Prevention, Control, and Treatment (AKART) for Industrial Stormwater
The California (CA) Industrial Stormwater General Permit (General Industrial Permit) that goes into effect in 2015 has been revised for the first time in nearly two decades and includes more specific and stringent requirements. The paper to be presented will discuss the particular challenges CA industrial facilities face for compliance with ever tightening industrial stormwater permit requirements and describes stormwater management approaches relevant and useful for CA industrial permittees, consultants, regulators, and municipal stormwater program managers.
In the neighboring states of Oregon and Washington (WA), new industrial stormwater requirements have been very difficult for industry to understand and are costing more than ever to comply with. At the same time, very little stormwater management guidance has been available anywhere specifically for industrial permittees. WA State railroads, ports, and other industries have been having a particularly difficult time achieving the stringent pollutant benchmark levels included in the WA Industrial Stormwater General Permit (ISGP) due to their traffic intensive operations and operational requirements. In support of the industrial community, the WA Public Ports Association (WPPA) commissioned a recent study intended to aid marine terminals and other industries in establishing what constitutes All Known, Available, and Reasonable methods of prevention, control, and Treatment (AKART) for stormwater discharges at their facilities and to help provide certainty and protection from 3rd party Clean Water Act lawsuits. These important lessons learned from other States will prove very helpful to California industrial facilities and can be adapted locally to support businesses in meeting difficult compliance requirements.
The study identifies applicable operational, structural, and source control and treatment Best Management Practices (BMPs) specific to industrial facilities and includes the most comprehensive and relevant existing performance data for proprietary stormwater treatment technologies known to exist anywhere in the country. Program management guidelines have been defined in the WPPA WA Marine Terminal AKART & ISGP Corrective Action Guidance Manual recently issued by the WA State Department of Ecology and provide much needed resources for California Industries as they now begin to navigate similar waters with the newly adopted Industrial Stormwater General Permit. This talk will review specific case studies and lead California Industrial Program Managers through the steps and methods to manage and comply successfully with the changes in California Stormwater regulations.