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Agenda - 03-20-1991
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Agenda - 03-20-1991
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BOCC
Date
3/20/1991
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Regular Meeting
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Agenda
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4 <br />for ten percent-of the group's facility sites, as opposed to <br />undertaking an individual environmental study for every site <br />belonging to a member of the group. The group environmental <br />study process is used to determine existing stormwater <br />quality and contaminant levels for those individual sites <br />which are investigated. The information that is obtained <br />from the studies is then used by EPA to develop a set of <br />requirements for the maximum allowable contaminant levels <br />that will be allowed in the stormwater runoff from a <br />particular type of site. The maximum contaminate level and <br />other permitting requirements will then be applied to the <br />stormwater discharges of all of the facilities of the type <br />covered by the group permit. The environmental consultant <br />costs would still be in the $25- $35,000 range for individual <br />sites, but the costs would be incurred by only ten percent of <br />the total number of the group's sites and would then be <br />evenly divided among all of the group sites. An example of <br />group formation for site permitting is where forty counties, <br />each of which operates a motor pool facility, form a group to <br />apply for a joint permit for motor pool facilities. Four <br />sites (ten percent of the group) would incur environmental <br />consultant expenses of $35,000 each, for a total cost of <br />$140,000. This expense would then be evenly divided among <br />the forty participants in the group, with each incurring a <br />cost of $3500. This geRKOsents-a ninety ercent savin s from <br />the costs for an individual site industrial stormwater <br />permit.- The process would work the same way for groups <br />operating landfills, waste treatment plants, etc. <br />Group permitting is a two part process. The first part of <br />the process involves the submission of an application to the <br />EPA listing and describing the sites proposed for inclusion <br />into a group. This part is, in effect, requesting EPA <br />approval of the group composition and permission to proceed <br />with the second part of the group permitting process. The <br />second part of the group permitting process involves the <br />individual site studies for the ten percent of the sites. <br />The first part of the group permit application must be <br />submitted to the EPA by March 18, 1991. The second part of <br />the group permit must be submitted to the EPA by May, 1992. <br />In order to facilitate the formation of groups interested in <br />group permitting process for each of EPA's categories of <br />industrial uses, NCACC and NCLM contacted their respective <br />memberships to determine the extent of the interest and the <br />willingness to participate in the group permitting process. <br />In early February, 1991, NCACC and NCLM distributed <br />
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