As many of you have heard, after years of deliberation the California State Water Resources Control Board adopted a new stormwater “Industrial General Permit (IGP) on April 1, 2014. This new general permit will replace the current IGP effective July 1, 2015. Even though the effective date is almost a year away, the new IGP significantly expands the scope of the current IGP and also establishes a variety of new requirements and it’s not too soon to start preparing!
Significant changes include:
- Regulation of more industries
- Minimum BMPs (as opposed to “suggested”)
- Specific Monitoring and Sampling Requirements and Associated “Numeric Action Levels” (NALs)
- Requirements for “Qualified Industrial Stormwater Practitioners” (QISP)
- Compliance Groups (as opposed to Group Monitoring)
Who is Covered
The new IGP prohibits all “non-stormwater discharges” (NSWDs), subject to some conditions, except:
- Fire-hydrant or response system flushing;
- Water related to the operation, maintenance, or testing of potable water systems;
- Drinking fountain water and atmospheric condensate (refrigeration, A/C, compressors)
- Irrigation drainage and landscape water;
- Uncontaminated groundwater, drainage, footing drainage;
- Seawater infiltration,
- Cooling towers mist (not blowdown or intentional discharges).
Light industry facility Dischargers that were previously excluded may now be covered, however companies that do not contaminate stormwater can qualify for a “No Exposure Certification” (NEC). Dischargers that meet NEC requirements are exempt from the SWPPP requirements, sampling requirements, and visual observation requirements. Dischargers seeking NEC coverage must certify and submit registration documents as well as annual inspections, re-certifications and fees in subsequent years.
Current SWPPPs issued under the previous IGP can remain in effect until July 1, 2015, however companies must submit a “Notice of Intent” by that date. Dischargers must prepare a SWPPP for each industrial facility, including
- “Pollution Prevention Team” an contact information
- Site Map,
- Description and assessment of Potential Pollution Sources
- Advanced BMPs, if applicable
- Observation and Monitoring Plan
- Annual Comprehensive Facility Compliance Evaluation (Annual Evaluation);
Mandatory Minimum BMPs
One very significant change in this new IGP are mandatory minimum “Best Management Practices” (BMPs) for dischargers. Previously, facilities had some flexibility with respect to “suggested” BMPs. Under the new plan, all dischargers must implement minimum BMPs as well as applicable advanced BMPs. These minimum BMPs will be familiar to most of us and include Good Housekeeping, Preventive Maintenance, Spill and Leak Prevention and Response, Material Handling and Waste Management, Erosion and Sediment Controls. Additional, advanced BMPs may also be required, based on industrial activities and effectiveness of other controls.
Monitoring and Sampling
In addition to mandatory BMPs, there are significant changes to the monitoring and sampling requirements. Dischargers must perform visual observations to identify pollutants in industrial storm water discharges and must collect samples from 2 Qualifying Storm Events (QSEs) within the first half of each reporting year (July 1 to December 31), and 2 QSEs within the second half of each reporting year (January 1 to June 30). Sampling frequency can be reduced if results from 4 consecutive QSEs (including multiple reporting years) do not exceed any of the new instantaneous or annual “Numeric Action Levels” (NALs) and the company is otherwise in compliance.
The IGP also creates “Compliance Groups” - groups of Dischargers with similar industrial activities and types of pollutions. Compliance Groups can develop consolidated Level 1 ERA Reports, appropriate BMPs for implementation in response to Level 2 status ERA requirements that are representative of the entire Compliance Group.
New Dischargers that will be discharging to an impaired water body as well as facilities that are required to prepare “Exceedance Response Actions” (ERA) must use Qualified Industrial Storm Water Practitioners (QISP). The QISP is a newly-created certification – procedures are still being developed, however in order to receive QISP certification, individuals must complete an approved training course, pass a comprehensive examination and register with the Water Board.
Many of the details are still be worked out and procedures are being developed, but ACT is available to help!
If you have any questions, comments or concerns regarding the new Stormwater IGP, or if you would like assistance preparing or updating your SWPPP, please contact Jim Kapin, Manager of EH&S Consulting for ACT, at 619-990-5955 or [email protected]