Erler & Kalinowski, Inc. helped numerous wineries prepare for complying with the new National Pollutant Discharge Elimination System (“NPDES”) General Permit for Storm Water Discharges Associated with Industrial Activities, Order NPDES No. CAS000001 (“General Permit”), effective 1 July 2015. Many wineries previously did not have coverage under the General Permit and EKI provided education regarding the General Permit requirements, assistance preparing Stormwater Pollution Prevention Plans (“SWPPPs”), and guidance on how to comply with the General Permit.
Many wineries who were used to managing wash and wastewater from their facility did not have adequate controls for stormwater or, in some cases, the two were mixed and discharged to the same location. In such cases, EKI recommended operational changes or improvements in stormwater management infrastructure, if necessary. Generally, with some modifications to operational practices, wineries were able to substantially decrease the work effort that would be required to comply with the General Permit.
Additionally, some wineries discharged into waters considered impaired under Section 303(d) of the Clean Water Act (33 U.S.C. §1251 et seq. (1972)) for nutrients, which is prevalent at wineries in the form of organic and inorganic nitrogen from juice, must, and wine. In these situations, it was imperative that wineries immediately apply for coverage under the old permit in order to avoid being considered a “New Discharger” under the General Permit. In these cases, New Discharger status would have required retaining a Qualified Industrial Stormwater Practitioner to certify the winery was compliant with the General Permit.