Conducting Stormwater Applicability Assessments Across 31 Industrial Facilities

Upon completion of a fulfillment center Environmental Health & Safety (EHS) regulatory applicability assessment, Antea Group identified that the facility was not in compliance with the United States Environmental Protection Agency’s (EPA) National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity. A desktop review was completed for all client owned and operated facilities and 49 unique fulfillment and distribution centers were identified across the U.S. as being potentially subject to regulation under the MSGP.

Antea Group conducted an initial desktop review to validate Standard Industrial Classification (SIC) codes and facility activities at each location. Of the 49 facilities, 31 were identified as needing additional investigation and a formal Stormwater Applicability Assessment. The remaining 18 facilities were determined to be low risk and were not engaged in MSGP regulated activities, therefore being eligible for a reduced cost desktop applicability review.

On-site Stormwater Applicability Assessments were carried out at the remaining 31 sites where the following was assessed:

• Activities and operations regulated under the MSGP
• Other regulated activities and operations outside of MSGP coverage
• Stormwater discharge locations from regulated areas
• Receiving waters for stormwater discharges
• Potential Best Management Practices (BMP’s) for the site
• Opportunities for elimination of regulated activities
• Opportunities for a No Exposure Certification (NEC)

Site specific observations were then complied into a Stormwater Applicability Assessment Report complete with site specific information, a summary of facility activities and observations, recommendations, a comprehensive site figure, and supplemental photographs.

Antea Group utilized its Applicability Assessment tool to evaluate and reduce the overall number of potentially regulated sites, prioritize sites based on activities and risk factor, and develop cost modeling for permit compliance and implementation via Notice of Intent submittal, Stormwater Pollution Prevention Plan development, training, and implementation. 

Antea Groups Applicability Assessments ensured fulfillment and distribution center compliance with the MSGP, mitigated potential non-compliance risk, and reduced the overall lifetime compliance cost by approximately 35-40% through No Exposure Certifications and validating the absence of regulated activities.