BAT – It’s in the Numbers
While the Water Board IGP calls for Best Available Technology (BAT) to manage NAL exceedances and bring facilities into compliance, there is no definition within the Permit that defines what constitutes BAT.
Without a defined standard, the evaluation of Best Available Technology is left to the results that are realized from a repeatedly deployed system. In this case, the StormPROOF Treatment System has outperformed every other similar treatment systems by reducing pollutants as much as 99 percent in some cases, as measured using water sample data from Storm Water Systems and other treatment providers found on Storm Water Multiple Application & Report Tracking System (SMARTS) database.
With removal rates varying from 90 to 99 percent, and TSS water sample results going in at 2200 and leaving our system nearly crystal clear with TSS of 13, there’s no arguing that our data – the numbers – are the proof in the StormPROOF Treatment System.
We Guarantee Our BAT
Storm Water Systems guarantees that the StormPROOF™ Treatment System will consistently be below Numeric Action Level (NAL) values required by the Storm Water Industrial General Permit (see Benchmarks below).
Although the systems will consistently meet the referenced Benchmarks, the possibility exists for an occasional exceedance due to the numerous variables that can affect storm water. For example, a significant increase in materials on-site, a spill of some kind, or the filtration media decreasing in removal efficiency over time. However, these would be isolated occurrences that would not affect storm water compliance.
In the event the system does not achieve NAL values, after all other maintenance options have been completely exercised, Storm Water Systems (at its cost) will provide additional equipment and labor to the system in order to be below NAL values until media is exhausted.
||EPA Benchmark Value
||6.0 – 9.0
|Total Suspended Solids
|Oil and Grease
|Chemical Oxygen Demand
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