Reminder: SWP3 DMRs are due March 31st – General Industrial Stormwater Permits
John K. Carroll III
Associate Managing Director at Witt O'Brien's, LLC, Part of the Ambipar Group
This week’s article will be short — more of a reminder. March 31st is around the corner, and if you are regulated by the Environmental Protection Agency’s (EPA), or a State’s general stormwater permit, you must prepare and file, and in some cases, submit, annual Discharge Monitoring Reports (DMR) by March 31st.
What is a DMR? A DMR is a United States regulatory term for a periodic water pollution report prepared by industries, municipalities, and other facilities discharging to surface waters.
DMR is a common term in wastewater and stormwater permitting. However, based on the type of permit, there are numerous types of data sets that must be addressed. There are also permit-specific timeframes for submittal.
Today’s focus is on a common permit, with which many in the industry must comply: the General Industrial Stormwater regulations. These permits are driven by the National Pollutant Discharge Elimination System (NPDES) regulations, but most states have been delegated to administer the programs themselves. Wonder if your state has its own permit, or is regulated by the EPA? Click here.
In general, General Industrial Stormwater permits have what is referred to as Benchmark Monitoring (I’ll dive deeper into what this is in a future article). The DMRs for these permits are due on March 31st. Some states, like Texas, have additional types of sampling requirements that are also done annually, and due at this same time. An important note: not everyone who has a permit is required to sample, so ensure you are familiar with your State’s permit conditions – these permits are industry-sector specific.
What is the purpose of a DMR? Have you ever taken a water sample? If you have, the lab report generated can be very long and contain a lot of information. The DMR is generally a one to two-page summary of the analytical data from that report, that is easy to read and shows a quick comparison of what is allowed (permit limit) and what the sample contained. The report makes it easier for both regulators and you to read.
Several years back, I wrote the following article, SWP3: A couple of common misperceptions, which helped explain General Industrial stormwater permitting. The article addresses who requires the permit, the Stormwater Pollution Prevention Plan (SWP3) that must be developed, and general compliance with the regulation.
If you haven’t started yet, it is a good idea to start now, as most states have gone to electronic reporting for DMRs. These systems can be tricky to use and require prior authorization before you can enter data. If you wait until the last minute, don’t be surprised if you can’t submit your DMR in time. Lastly, many Municipal Separate Storm Sewer Systems (MS4s) entities and other local government entities require a copy of these too, even if not submitted to the State or EPA.
For a complete listing of archived articles and compliance insights, click here. Past articles cover training requirements, clarification on additional unclear elements within the above rules, and much more.
We are here to help solve your compliance questions and challenges. If you need compliance assistance or have a question, please email John K. Carroll III ([email protected]), Associate Managing Director – Compliance Services, or call +1 954-625-9373.
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