b'Roofing Contractors May Becanbeobtainedbycontactingthe appropriate state agency.Both EPA and Subjectto S Waterstate regulations should be evaluated in torm ordertodeterminewhetherapermit DischargePermit Applicationapplication must be filed. Requirements by Parthenia B. Evans, Thomas J.Wilcox,ADifferent and Alice J. Fischer Spencer Fane Britt & BrowneLight. Auorneys at Law byMRCA Director New regulations promulgated byJohn Drew, theU.S.EnvironmentalProtection Agency(EPA)requireroofingRoofingSometimeswhen theyathe going is tough contractors to evaluate whethermustcontractors fall, at minimum, within SICandproblems apply for a permit to discharge the stormtheof water falling on certain portions of theircode 1761 for roofing,the business seem facilities.siding, and sheet metaloverwhelming,I to stop work. EPA\' s storm waterforce myself The federalClean Water Act and stateregulations do not requireand think of all of water pollution control laws authorize EPAstormwaterdischargetheopportunities and state agencies to issue permits to controlpermit applications from SICthattheroofing ofwater containingindustry in general, some dischargesstormcodegroup17,includingJohn Drew, pollutants.EPA\'sfirstroundof storm1761.EPA\'sregulationsrequireandourroofingMRCA Director waterdischargepermitapplicationapplicationsfromSICcodegroups10companyin regulations was promulgated onthrough14and20 through45.Someparticular, have afforded our employees, November 16, 1990, establishing the entities thatactivitiesat roofingcontractor facilitiesmy family, and myself. must apply for storm water discharge permitscould cause the facility toof fall within one andManytheseSICcode groupsaswell.CodeI thinkthe challengesthe occupation the application deadlines.statesofof theManagementand the satisfaction ofjob well done.I a have alsci\'established storm water dischargedescriptions inOffice of permitapplicationrequirements.andBudget"StandardIndustrialthink of our standard of living and the Substantial penalties may be imposed forClassification Manual" should be evaluatededucation of our children; of the wages failure to timely apply for a storm water in conjunction with the appropriate stateand earnings that contribute to the wellofthe discharge permit.DepartmentLabor guidance to determinebeing ofarea economy; and finally, I whetheranyactivitiesataroofingthink of all of the friends that we have Roofing contractors must evaluate EPAcontractorf acility are coveredonethemade in the roofing industry - friends byof and state regulations to determine whetherSICcodessubjecttoEPAorstatethat can becounted on when problems regulations.arise. Whenis lookedin this light, the some or all ofwater dischargeditat the storm from their facilitiesis subject to permitproblems shrink in the face of all of the Ifofbenefits. applicationrequirements.Theprimarythe activitiesa roofing contractor fall onetheare questionsthatroofingcontractors mustwithinofcovered SIC codes or evaluate inotherwise covered under the regulations,The decade of the\'90s will be one of making this determination are: (1) whether activities at the contractor\'sthecontractormustdeterminewhetherextremechallengetoourindustry. facility fall within standard industrial codestorm water falling onbyEscalatinginsurancecosts,increased the areas covered (SIC) groups which EPA or astate hasthe regulations contains pollutants and isfederal regulations which are sometimes determined must apply for a storm waterdischarged from a point source into watersill-advised, and problems finding qualified whetherfacilityhelp name only a few such obstacles we discharge permit; (2)theisof the United States.Theterm "point is otherwisesubjecttopermit applicationsource" is broadly defined under the federalare facing today. Butthis any different requirements because the facility alreadyClean Water Act and has been interpretedfrom the problemsthe \'80s? How ofabout is subject to effluent limitations guidelinesbroadlybythecourts.EPA has takenthe \'70s and late \'60s with the two-ply is a facility regulated under the Resourceproblems? oraggressivepositionsregardingwhat ConservationandRecoveryActasaconstitutes a point source.Waters of the hazardouswastetreatment,storage,orUnited States include all surface watersDiversitychallengeno strangers to andare disposal facility;and (3) whether stormand, in many states, subsurface waters.the roofing industry, and this will probably waterassociatedwithactivitiesfallingwe continue forever, buthave survived the within those SICgroups,activitiesEPAstorm water regulations canfoundpast problems and are sure to come to codeorsbe otherwisesubjecttotheregulations,interms with the future. the November 16, 1990 Federal Register. contains pollutants and isState water pollution control regulations discharged from a point source into waters of the UnitedIthinkl\'llquitfeelingsorryformyselfand States.help. Page3'