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El Niño is Coming, Implications for Construction and Industrial Permit Compliance

8/17/2015

 
Chances are strong that a record-setting El Niño is headed toward California. The latest official forecast from NOAA’s Climate Prediction Center favors a significant El Niño to develop during the Northern Hemisphere winter. During the Pacific Ocean phenomenon called El Niño, winds shift along the equator, warming the water more than usual, changing weather patterns globally, and increasing the chances of heavy rain impacting California. Strong El Niño events tend to be reliably wet for all of California, but a weak or moderate strength El Niño can produce disappointing rain across California. However, forecasters say this one is already the second strongest on record for this time of year and could be one of the most potent weather changers in 65 years. It's been unofficially named Bruce Lee after the action hero and it’s almost a sure thing at least Southern California will see more frequent rain events this winter. What does this mean for stormwater compliance?

Any construction project, whether by a private company or a public agency, is required to comply with the Construction General Permit (CGP) during construction.  With a potentially wet winter coming to California, it will be important not only to implement the proper sediment and erosion control BMPs, but also maintain them frequently to ensure they function during storm events. Stay in compliance by ensuring a CGP Qualified SWPPP Practitioner (QSP) or Qualified SWPPP Developer (QSD) is inspecting your site and documenting issues that need to be corrected.  Also, make sure site managers are aware of the issues that need to be corrected to ensure the proper BMPs are being implemented and maintained. Curious what the regulators are looking for and noticing?  Alta recently interviewed a San Diego Water Board regulator to find out and construction stormwater compliance happens to be one of the Water Board’s highest priorities for 2015, read the complete interview here: http://www.altaenviron.com/news--media/archives/01-2015.

Are you an industrial facility covered under the Industrial General Permit (IGP) that went into effect on July 1, 2015? The new IGP includes increased sampling requirements and numerous changes that will impact the likelihood of a "Qualifying Storm Event" (QSE) falling within normal business hours. The definition of a QSE was revised to increase the number of QSEs eligible for sample collection. Under the previous IGP, samples had to be collected within the first hour of discharge, greatly limiting how many storm events could be sampled each year. Under the new IGP, sampling can be conducted within the first four hours of discharge, or the start of facility operations, if the QSE occurs within the previous 12-hour period. For example, if it starts raining on Sunday night, a discharger may have the opportunity to sample on Monday morning. In addition, a QSE is a precipitation event that produces discharge for at least one drainage area preceded by 48 (not the prior 72) consecutive hours without a discharge. Furthermore, the sampling season has been expanded and the sampling requirements have doubled. The previous IGP required two QSEs to be sampled during the wet season, defined as October through May. Under the current IGP, the season extends from July through June the following year, with sampling required during two QSEs between July 1 and December 31, and two QSEs between January 1 and June 30.

With the current prospects for a wet winter brightening, are you prepared? If you have questions or for more information please contact our experts, David Renfrew at 760-908-5749  David.Renfrew@altaenviron.com  or Garth Engelhorn at 760.644.0167  Garth.Engelhorn@altaenviron.com .
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