September 1997
EPA Industrial Permit Rules to Change

The Environmental Protection Agency's rules on permits for "Industrial Facilities" will change this month. The NPDES storm water baseline industrial general permit will not be renewed. Cities and counties that operate facilities that are considered to be "industrial activities" and that received a permit for stormwater discharges under the baseline general permit should consider seeking coverage under the multi-sector permit or an individual permit.

Most "industrial activities" are conducted by the private sector. However, facilities typically owned by local governments that are considered to be industrial activities include airports, wastewater treatment plants and landfills.

When the industrial activities permitting program first began, facilities that were required to obtain a permit generally had two options - obtain an individual facility permit (which could be costly) or to participate in a group application. EPA rules had allowed groups of similar facilities to jointly submit applications, thereby saving considerable sampling and testing costs. Many local governments throughout Florida had participated in one or more group permits.

After the group permit process was underway, EPA authorized the baseline general permit as a second alternative to the individual permit. Also, after many of the final group applications had been submitted to EPA and were awaiting approval, the agency dropped the group permit process and substituted the multi-sector general permit in its place. Data obtained from the many group applications (approximately 700 groups representing over 50,000 facilities) that were submitted to EPA was used to prepared the multi-sector permits. The multi-sector permits were more industry specific than the baseline general permit but compliance costs were not as burdensome as with an individual permit. Additionally, the multi-sector rule was developed based upon actual collected data as opposed to best professional judgement.

Local governments that operate industrial facilities and wish to transfer permit coverage to the multi-sector permits should submit a Notice of Intent to EPA in Washington, DC. For more information, contact Floyd Wellborn at EPA in Atlanta (404/562-9296).

The law requires persons bringing actions must prove negligence to recover damages. For the purposes of the tank law, noncompliance with this act, or any of the DEP rules is prima facie evidence of negligence.