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ILTA Submits Comments to Help Improve Industrial Stormwater Fact Sheet Series

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On March 28, ILTA submitted comments to EPA regarding the National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Fact Sheet Series (Environmental Protection Agency Docket No. EPA-HQ-OW-2022-0097).

The ILTA comments specifically addressed documents related to Sector P — Motor Freight Transportation Facilities, Passenger Transportation Facilities, Petroleum Bulk Oil Stations and Terminals, Rail Transportation Facilities, and United States Postal Service Transportation Facilities (as applies to LP terminals within SIC 5171). ILTA expressed support for the goal of proper management of industrial stormwater and offered suggested improvements to the fact sheet series in hopes of further improving the transparency of the NPDES program and the usability of the fact sheets.

ILTA addressed the Sector P factsheet, noting that it could be more helpful by providing insight into which activities occurring at a petroleum terminal could trigger the need for industrial stormwater permitting. A fundamental problem noted in the comments is that the fact sheet does not state how to determine if a petroleum terminal requires an industrial stormwater permit. ILTA recommended that the fact sheet be amended to clearly explain that — by the terms of the National Pollutant Discharge Elimination System (NPDES) rule itself — the requirement for an industrial stormwater permit is limited to portions of an applicable facility involved in vehicle maintenance, equipment cleaning operations, airport deicing operations, or that otherwise is the location of activities identified as an industrial.

To see the full ILTA comments as well as the complete docket, please visit Regulations.gov. For more information, please contact Kathryn Clay at kclay@ilta.org.

 

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