The Clear Choice
Issue 02-1 February 1993

To: All industry operators, designers, developers, engineers, surveyors, architects, contractors, government officials, and utilities.

This issue of "THE CLEAR CHOICE" is a part of the ongoing educational requirement of the Federally-mandated National Pollutant Discharge Elimination System (NPDES) Program. It will give you an overall review of Chattanooga's Storm Water Management Program, and provide information to industries which need to develop and secure a NPDES permit. For additional copies of an issue or for more information, contact Tom Scott , Director of Storm Water Management.

STORMWATER MANAGEMENT PROGRAM

In accordance with the Water Quality Act of 1987, Chattanooga has consistently been a pro-active leader in clean water arena. The National Urban Runoff Program collected data from a variety of municipal, residential, commercial, and industrial sources in an effort to characterize urban storm water pollution runoff (USEPA Results of the National Urban Runoff Program, 1983).

The major findings from the NURP is that the pollution sources in an urban environment fall into four major categories: (1) industrial discharges, (2) illicit discharges and dumping, (3) construction site runoff, and (4) commercial and residential properties. Therefore, these four categories are the focus of the storm water management programs as specified by the NPDES Storm Water Regulation.

The Act requires that dischargers to "Waters of the United States" be subject to the National Pollution Discharge Elimination System (NPDES) permit program. The Act, as it applies to Chattanooga, has three primary features:

1. It requires that Chattanooga implement a program that effectively prohibits and/or controls non-storm water discharges into "Waters of the United States/State" and into the municipal separate storm sewer system (MS4).

   a. The City is required to enact legal authority to enforce the Act.
   b. It requires the City to have a dedicated funding source.
   c. It also requires the City to dedicate manpower and equipment needs.

2. It requires Chattanooga in implement a program to control the storm water pollution discharge into the "Waters of the United States/State" and into the MS4 storm water system to the "maximum extent practicable" (MEP) and to exert effective regulatory control of individual discharges.

   a. Issue 01-1 dealt with pollution prevention with "Land Disturbing Activity".
   b. A citywide ongoing monitoring and field screening program is required to eliminate illicit/spill discharging and to measure the progress of the program.
   c. Source identification of drainage basins, land use, industries, superfund sites, wetlands, sink- holes, traffic volumes, TSD facilities, landfills, outfalls, recreational facilities, and soils was completed in the Part One submission. This data is all in the Storm Water Management GIS system.

3. It defines a single system-wide permit for Chattanooga to serve as a comprehensive water quality management program.

   a. A Storm Water Management Plan is in the process of being developed for the Part Two submission in May of this year.
   b. A BMP manual is also being developed to provide guidance to comply with the NPDES Program.

The regulation has enormous implications for Chattanooga and imposes a significant responsibility on the City to be an active participant in the prevention of water quality degradation.

PERMIT APPLICATION FOR STORM WATER DISCHARGES
ASSOCIATED WITH INDUSTRIAL ACTIVITY

Most industries are in the process of obtaining their NPDES permits. Any industry that has a SIC Code as listed below that has not started their permit should contact Mr. Robert L. Haley in Nashville (615)741-7883 of the Tennessee Division of Water Pollution Control. Noncompliance of the NPDES Program can result in large fines and even criminal charges.

Classes of facilities that discharge storm water associated with industrial activity are as follows:

1. Facilities subject to National effluent limitation guideline;
2. Facilities classified as Standard Industrial Codes (SIC) 24 (except 2434), 26 (except 265 and 267), 28, 29, 30, 311, 32, 33, 3441, and 37 (including lumber; paper; chemical; petroleum; rubber; leather tanning and finishing; stone, clay, glass, and concrete; metal; enameled iron and metal sanitary ware; and ship/boat manufacturers);
3. Facilities classified as SIC codes 10 through 14 (including active and inactive mining and oil and gas operations with contaminated storm water discharges, except for areas of coal mining operations which have been reclaimed and the performance bond has been released by the appropriate SMCRA authority, non-coal mining operations which have requirements 30 days after publication of the final regulation);
4. Hazardous waste treatment, storage, or disposal facilities;
5. Landfills, land application sites, and open dumps that receive industrial wastes;
6. Recycling facilities (including metal scrap yards, battery reclaimers, salvage yards, and automobile junkyards (classified as SIC codes 5015 and 5093 only));
7. Steam electric power generating facilities (including coal handling sites);
8. Transportation facilities classified as SIC codes 40, 41, 42, 44, and 45 (including vehicle maintenance, equipment cleaning, and airport de-icing areas);
9. Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the storage, treatment, recycling, and reclamation of sewage (including land used for the disposal of sludge located within the confines of the facility) with design flow of 1.0 mgd or more;
10. Construction activity (except for disturbances of less than acres of total land area which are not part of a larger common plan of development or sale);
11. For the following facilities, if materials are exposed to storm water facilities classified under SIC codes 20, 21, 22, 23, 2434, 25, 265, 267, 27, 283, 31 (except 311), 34 (except 3441), 35, 36, 37 (except 373), 38, 39, and 4221-25 (including food; tobacco; textile; apparel; wood kitchen cabinets; furniture; paperboard containers and boxes; converted paper/paperboard products; printing; drugs; leather; fabricated metal products; industrial and commercial machinery and computer equipment; electronic equipment; transportation equipment; measuring, analyzing, and controlling instruments and photographic, medical, and optical goods, and watches and clocks; miscellaneous; and certain warehousing and storage manufacturers).

Industries and/or businesses which are not listed above - and therefore not required to obtain a permit - will still be expected, by the Chattanooga Storm Water Management Program, to use "Best Management Practices" (BMP) and not discharge pollutants.