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MDE issues permits for a variety of activities that affect everything from dry cleaners and restaurants to developers and manufacturing plants. Permittees must adhere to the conditions and requirements contained in these permits to remain in compliance. While most larger facilities that receive major, complicated permits monitored by in-house environmental staff are aware of this, smaller facilities or places that are subject to a general permit may not be.
Read Your Permit
One of the first steps for compliance is to carefully read the permit. That simple form you filled out to receive a general permit was actually an agreement to do all the things that the permit says. Permitees receiving individual permits, those created for a specific facility, also must comply with conditions and requirements contained in their permits. Many permits contain requirements to submit reports or sample analyses on a regular basis. The only way to know the requirements for sure is to read the permit.
One example is the “General Discharge Permit for Industrial Sources that Discharge Storm Water Only”, also known as the “General Storm Water Permit”. This permit requires the permittee to develop a written storm water pollution prevention plan and implement controls to prevent the contamination of storm water that falls on the site. The permit even spells out the minimum contents that need to be covered by the plan. The written plan is something that a MDE inspector will want to see, and failing to have one is a violation. However, you have to read your permit to know this information.
Other permits will specify the particular recordkeeping you need to demonstrate compliance with permit conditions. The “Air Quality General Permit to Construct for Vehicle Refinishing” requires you to keep monthly records of hours of operation and materials purchased. Keep these records on hand for two years. The requirements of what records to keep and how long to keep them may differ depending on permit type, so read the permits to find your applicable requirements. An inspector will want to see that you are keeping the required records. Your permit will also indicate what information you need to report, how often, and where you need to send the information.
Customer Service – We Can Help You Understand Your Permits!
MDE has resources available to help you understand the requirements. The first contact should be directly with the program that issued the permit. That information is on the cover letter. Click here to download the permit text for many of the general permits from MDE’s website. It is better to determine what you are supposed to do before you get into trouble for non-compliance. In many cases, permit non-compliance results from failure to adhere to a simple requirement in the permit. Failure to read your permit is not an excuse. MDE’s Customer Service Center is another resource that is available to help you with permit questions. MDE’s Customer Service Center can be reached at (410) 537-3772.
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