Navigating the renewal of ILR00: Updates and concerns

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June 22, 2023 - The Illinois General National Pollutant Discharge Elimination System (NPDES) Permit for Industrial Activity (ILR00) is a vital regulatory framework designed to protect water quality in the state and is set to be renewed before the end of June 2023. The renewal brings about new requirements and revisions that industries should be aware of. However, there are some concerns regarding the draft renewal, particularly regarding indicator monitoring and baseline monitoring for certain industry subsectors.

Stormwater runoff from industrial sites can carry various pollutants, such as sediment, heavy metals, and chemicals, into all bodies of water, resulting in adverse environmental impacts. The renewed ILR00 will introduce enhanced stormwater control monitoring to mitigate these risks.

Additional stormwater monitoring may require companies ultimately to implement advanced stormwater best management practices (BMPs) and controls, including the installation of infrastructure improvements such as sedimentation/retention ponds and filtration systems.

However, there are some concerns with the draft renewal, particularly regarding the applicability and implementation of indicator monitoring and baseline monitoring for certain industry subsectors.

New requirements

These renewal strategies will encourage companies to adopt practices that go beyond mere compliance and include pollution prevention plans tailored to their specific operations:

Enhanced stormwater control measures: Permittees will need to consider additional measures to address major storm events and ensure effective stormwater management
Modified Indicator Monitoring: The renewal introduces changes to indicator monitoring for pH, Total Suspended Solids (TSS), and Chemical Oxygen Demand (COD) across various industry subsectors
Addition of Polyaromatic Hydrocarbons (PAHs) Monitoring: PAHs monitoring is now required for many industry subsectors under the ILR00
Updated Benchmark Threshold Values: The benchmark threshold values for aluminum, copper, selenium, cadmium, magnesium, and iron have been updated for specific subsectors
Revised benchmark monitoring schedule: The renewal includes updates to the benchmark monitoring schedule for several subsectors
Additional implementation measures: some industry subsectors will have revised implementation measures as part of the renewed ILR00.
Stormwater permit coverage signage: a new requirement mandates the posting of a sign indicating stormwater permit coverage, including the NPDES ID Number, information on requesting the facility's Stormwater Pollution Prevention Plan (SWPPP), and contact details for both the facility and the EPA in case of observed stormwater pollution in the discharge.

Concerns & ambiguities

While the renewal of ILR00 presents new opportunities for environmental sustainability, it is essential for companies to navigate the potential ambiguities and complexities in the draft permit. Two of the biggest concerns organizations face include:

Indicator monitoring frequency: while the frequency of benchmark monitoring is specified, the frequency of indicator monitoring is not clearly defined in the draft renewal.
Reference to federal MSGP: the draft renewal refers to Section 4.2.1 of the Federal Multi Sector General Permit (MSGP), which describes indicator monitoring requirements. Illinois has its own delegated NPDES, and it is unclear if the reference is intended to align with the Federal MSGP.

Stay informed

To ensure seamless compliance, companies should consider the following:

Cost considerations: companies should assess whether they fall under industry categories requiring PAH monitoring twice per year. The expense for PAH analysis typically ranges from $200 to $270 per sample, according to a leading analytical testing service.
Determining industry-specific requirements: organizations are encouraged to review the draft renewal to identify any additional monitoring or implementation measures relevant to their industry subsector.
Seeking expert guidance given the complexities and potential ambiguities in the renewal, it is advisable for targeted industries to consult with reputable environmental firms well-versed in NPDES permit compliance.
Monitoring schedule compliance: ensure that the necessary sampling and monitoring activities are conducted in accordance with the permit requirements to maintain compliance.
Stay updated on permit issuance: regularly check for the issuance of the renewed ILR00 permit and be prepared to submit a Notice of Intent (NOI) within the designated timeframe of 150 days.

The impending renewal of the Illinois General NPDES Permit for Industrial Activity (ILR00) introduces new requirements and updates that industries need to be aware of. While there are concerns and ambiguities in the draft, particularly regarding indicator monitoring and baseline monitoring for certain industry subsectors, seeking clarification and professional guidance is crucial for compliance. By staying informed and taking the necessary steps to meet the permit requirements, companies can proactively address stormwater management and pollution prevention, ensuring environmental sustainability in their operations.

Read more from BSI’s environmental experts in EPA approves new ASTM E1527-21 standard and EPA proposes TRI reporting changes surrounding PFAS. For more insights on environmental, health, safety and well-being, digital trust, privacy and information security, supply chain and sustainability topics that should be at the top of your organization's list, visit BSI's Experts Corner.