ALTA PROVIDES INDUSTRIAL STORM WATER PERMIT SEMINAR FOR SOUTHERN CALIFORNIA BUSINESSES AT THE CITY OF OCEANSIDE
Alta Environmental (Alta) hosted a seminar for industrial businesses in the Southern California region. The meeting was held at the City of Oceanside Library’s Community Room on August 20, 2014 from 1:00 pm – 3:30 pm. The intent of the seminar was to provide industrial businesses with a comprehensive understanding of the requirements associated with California’s new National Pollutant Discharge Elimination System (NPDES) Permit for the Discharge of Storm Water Associated with Industrial Activities, also known as the Industrial General Permit (Permit). David Renfrew, CPSWQ, QSD, PMP, with Alta, provided in depth review of the Permit requirements. The meeting was well attended by a good representation of small and large industrial businesses alike, as well as members of the City of Oceanside’s Clean Water Program and the County of San Diego. City of Oceanside’s Environmental Officer, Mo Lahsai, PhD introduced the seminar and explained the role of the City in supporting its’ local businesses as they navigate these new requirements. City of Oceanside Environmental Specialist’s Justin Gamble and Katie Greenwood were also present to help answer questions.
While the new Permit allows required filers one year to comply with the new requirements, it is really clear that very few industrial business managers realize the level of effort and costs associated with complying. Several questions that were raised during the seminar brought to light the issues many small businesses face with complying with the new regulations. Many “light industry” facilities that were previously exempt from the requirements to obtain coverage under the old Permit are now coming to grips with the level of effort required. The biggest change and impact to everyone are the annual fees for new enrollees, the development of new or revised storm water pollution prevention plans, monitoring implementation plans, new monitoring requirements, and the likely potential exceedance response action follow-up requirements. These new elements will require long-term budget planning and future operational adjustments to meet the new requirements over the next few years as the Permit progresses. Additionally, with the new requirement for all information to be uploaded to the State’s on-line database allows for facility-specific information to be publically available, presenting a risk for third-party lawsuits for those who don’t file on time or provide the required documents.
There are two general means of complying with the Permit which include the No Exposure Certification (NEC) (the least expensive route) or the Notice of Intent (NOI) to obtain coverage (the more expensive route). Although possible, very few facilities would qualify for the third route which is the Notice of Non Applicability/No Discharge route. One of the biggest issues with the NEC route is the level scrutiny and interpretation of the intended meaning of “no exposure”. Two big issues for businesses with indoor operations seeking to go the NEC route that would potentially make them ineligible include (1) those facilities with particulate emissions from roof stacks and/or vents that may disperse pollutants to the atmosphere and (2) those facilities with current contamination from historic industrial practices. These two conditions would potentially force a company into the more expensive NOI route.
As with all new regulations pertaining to small-businesses, it was not uncommon to hear participant comments suggesting California is becoming ever more unfriendly to small-businesses. The two biggest concerns were the costs and the level of education needed just to interpret the Permit requirements and to understand which options exist. Alta has had numerous conversations with the State Water Resources Control Board which have required legal interpretations on the SWRCBs part and resulted in clarifications of the permit. The regulatory agency has acknowledged that there is still room for improvement in their Permit as it still has some ambiguities or gray areas in interpretation that were not identified and clarified prior to final adoption.
It is evident that each business is slightly different and essentially needs their Permit Registration Documents tailored to their specific facility. Key compliance dates to be aware of are July 1, 2015 when all NOI filers are required to be enrolled, and October 1, 2015 which applies to those seeking NEC coverage.
Alta Environmental provides comprehensive low cost business planning solutions associated with navigating the new Permit. We are advising our clients and customers to take steps now to bring storm water pollution prevention plans (SWPPPs), best management practices (BMPs), employee training, and storm water management into compliance by July 1, 2015. Both Dave and Kathy will be presenting on elements of the new Permit at the California Stormwater Quality Association (CASQA) on September 15-17, 2014. Additionally, we plan to host at least two more Permit Seminars in Southern California over the next six months.
Stay tuned for future announcements. For more information or to schedule a Seminar for your specific facility, please contact David Renfrew, Director of Water Resources at (760) 908-5749.