An NPDES permit for industrial storm water is required for certain industries or locations and allows the permittee to discharge runoff to surface waters. In order to prevent pollution from reaching these waters of the state, the permittee has responsibilities they must meet, described in the permit, set forth by EGLE and the EPA.

From time to time, EGLE officials may drop in on a facility to inspect operations. There may be advance notice in certain cases, like a pandemic, but more often than not these are surprise visits: this helps the officials achieve a candid understanding of operations. As such, to your best ability, you should follow the language and stipulations in the permit, and conduct your facility as if inspectors could show up at any moment.

There are two things EGLE officials specifically target during inspections: 1.) documents and 2.) the site. The following information is segmented accordingly and will help you ensure you are meeting the expected requirements set forth by the permits.

1.) Documentation

  • When EGLE inspects a facility, they tend to start by examining the documentation. The information should be easily accessible– all of Clean Stormwater Inc.’s clients are provided with a labeled binder, with a clearly marked table of contents, to organize all the files properly. Not only does this organization help with making the information easier to digest, but it’s also easy to see if you are missing any files.
  • The most common issue during inspections is not retaining the proper documentation. This means that the documents might not be fully filled out, signed properly, or the documents aren’t on hand for at least three years. It may help to label and segment files by year– keep extra hard copies in a filing cabinet and digital copies saved indefinitely.
  • Communicate! Know who is on the stormwater team, and the responsibilities they have. Create a system of checks and balances for them to remain accountable, and regularly have meetings to ensure all requirements are met.
  • Create a schedule to periodically review your documents in-house. It may help to do so after completing housekeeping inspections or after receiving reports; you need to file the reports anyway, and this allows you to constantly review your materials without taking time away from other duties.

2.) The Site

  • Check your containment systems. Is the air condensate puddling beneath machines, or are any lines leaking? Install secondary containment systems and use structural controlsas needed to prevent further leakages.
  • Inspect the grounds and outside storage areas. Is dirty scrap metal exposed to the weather? Are the dumpster lids broken? Tidy up where chemicals can be found and ensure there is protection from the elements.
  • Check around drains to make sure they are clear of impediments, including leaves and garbage. Look inside the drains with a flashlight to see if there are any blockages or items that can cause issues.
  • Make sure you have labeled and stocked spill kits on hand. Are drain covers near drains? Is there contact information in case of a spill? Review and resupply often.
  • Regular maintenance should be performed on vehicles and equipment. Upkeep will prevent items from breaking down and can stop oil or chemical leaks at the source. Be sure to clean up afterwards!
  • Set a schedule, and clean frequently. Sweep up debris, pick up trash, and keep your stations clear of garbage. Not only will this increase safety, but it will also help prevent pollution. If you notice things are looking in rough shape, increase the frequency of housekeeping inspections and cleaning.

If you follow your responsibilities as outlined in the permit, you will remain in good standing with EGLE; these tips should make it easier to stay in compliance.

If you have any questions, contact EGLE, or reach out to us! We can host a mobile document review, conduct meetings, or even go on-site to alleviate any anxieties that may arise; with over half the company having experience well over five years with storm water, we know how to prevent pollution.