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Michigan Industrial Storm Water Coverage: It’s Never Too Late

CFR Environmental

State and federal regulations require that facilities apply for permit coverage if storm water is exposed to industrial materials or activities and discharges to surface waters. This requirement also includes facilities that discharge storm water to a municipal separate storm sewer system.

Storm Water Permit Applicability: Facilities must perform a three-step process to determine if storm water permit coverage is required.

  1. Determine if the industrial activity is federally-regulated. Standard Industrial Classification (SIC) codes are used to identify regulated facilities. Major SIC Code groups that are included are: ​

  • Manufacturing (SIC 20— through 39—)

  • Public Warehousing (SIC 422-)

  • Transportation (SIC 40— through 45—)

  • Mining (SIC 10— through 14—)

  1. Determine if storm water discharges to surface waters through a point source. Storm water consists of rain, snow or any other form of precipitation. A point source discharge is any discernible, confined, and discrete conveyance that directs storm water to surface waters.

  2. Determine if industrial materials and/or activities are exposed to precipitation. Generally, if a facility stores or handles anything related to industrial activity outside without a storm-resistant shelter, the facility is considered to have exposure. Industrial materials include material handling equipment (bins, boxes, pallets, racking, etc.), machinery, raw materials, intermediates, byproducts, final products, and waste products. Industrial activities include storage, loading and unloading, and transportation of raw, intermediate, final, or waste products.

An industrial storm water permit is required If all three steps above are applicable. An existing facility that has been operating without the required permit coverage can resolve the violation by submitting a complete NOI/COE form to MDEQ. Before submitting the NOI/COE form, the facility must:

  • Obtain the services of an Industrial Storm Water Certified Operator;

  • Develop a Storm Water Pollution Prevention Plan (SWPPP);

  • Implement the nonstructural controls;

  • Complete construction and put into operation all structural controls (if necessary); and

  • Certify the facility has no unauthorized discharges.

Once the above requirements have been met, facilities can complete and submit the required NOI/COE form along with the annual permit fee of $260. The process is intended to resolve the violation of operating without industrial storm water permit coverage. It is an extremely inexpensive and easy way to come out of the shadows and obtain permit coverage.

CFR has been managing industrial storm water programs since its inception over 20 years ago. Contact us today to learn how simple and easy storm water compliance can be.

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