New Industrial General Storm Water Permit Now In Effect!

Facilities required to obtain coverage under the State Water Resources Control Board’s (SWRCB) General Permit for Storm Water Discharges Associated with Industrial Activities (Order No. 2014-0057-DWQ) (IGP) should now be implementing their storm water programs under the new Permit. The old permit (Order No. 97-03-DWQ) is now officially expired. Although the SWRCB has acknowledged issues with the on-line database called the Storm Water Multiple Application and Report Tracking System (SMARTS) and have extended the deadline for uploading documents, the new Permit is now effective and facilities are required to implement their programs in accordance with the new Permit. The extension does not authorize facilities to delay implementing their programs. It does grant the extension for recertifying on-line, uploading the SWPPP and site maps, and for submitting the old permit annual reports by this time. The SWRCBs expectations are that facilities required to obtain coverage have already developed their new SWPPPs and are moving forward with their programs.

If you have prepared a new SWPPP or revised your site maps to comply with the new permit, you need to do so now! If you have not re-certified your facility or uploaded the SWPPP and Site Maps, you need to do so by August 14, 2015. Facilities that have prepared their new SWPPPs should implement their programs as follows:

• Implement recommended BMPs identified as needed during the development of the SWPPP
  
• Implement your monthly inspection program on or before July 31, 2015 and then conduct the inspections monthly thereafter
  
• Train facility staff on the elements and responsibilities of the new SWPPP
  
• Order sample kits from your laboratory for this year’s sampling (at least for the first two sample events).
  
• Start monitoring weather forecasts
  
• Identify documentation requirements and start storing these records (we recommend creating a binder or folder to accompany the SWPPP and to scan and store electronic records as well)
  

Now back to SMARTS…Facilities who will be applying for No Exposure Certifications (NEC) are required to file on or before October 1, 2015. The SWRCB has indicated that roughly half of the currently covered facilities have recertified. Since there are still plenty more facilities waiting and trying to access SMARTS, the system is still experiencing delays and issues. If you are planning to file for NEC coverage, you will need to complete the on-line certification, upload the NEC certification, upload your Site Map(s), and pay an annual fee, by October 1, 2015. We anticipate there will be even more difficulties with the large number of NEC filers still planning to access SMARTS while at the same time, NOI filers are still accessing the system.  The SWRCB has acknowledged this and is apparently working to resolve the issues. If you experience issues with SMARTS, we recommend you document the issue via email and make sure you have all of you permit registration documents available if requested by a local regional water board staff member.

If you are a new facility and you discharge to a Clean Water Act Section 303(d) Impaired Water Body, you will need to retain the services of a Qualified Industrial Storm Water Practitioner (QISP). The Permit states that new dischargers applying for notice of intent (NOI) for coverage under the IGP that will be discharging to a water body with a 303(d) listed impairment are ineligible for coverage unless the Discharger submits data and/or information, prepared by a QISP, demonstrating that:

1. The Discharger has eliminated all exposure to storm water of the pollutant(s) for which the water body is impaired, has documented the procedures taken to prevent exposure onsite, and has retained such documentation with the Storm Water Pollution Prevention Plan (SWPPP) at the facility;
   
2. The pollutant for which the water body is impaired is not present at the Discharger’s facility, and the Discharger has retained documentation of this finding with the SWPPP at the facility; or,
   
3. The discharge of any listed pollutant will not cause or contribute to an exceedance of a water quality standard. This is demonstrated if: (1) the discharge complies with water quality standard at the point of discharge, or (2) if there are sufficient remaining waste load allocations in an approved total maximum daily load (TMDL) and the discharge is controlled at least as stringently as similar discharges subject to that TMDL.
   

The QISP will work with the facility to identify BMPs that address the items listed above. Facilities planning on commencement of operations should retain the QISP and plan 6 months prior to the start of operations so that adequate best management practices can be assessed and implemented, and to allow for the SWPPP to be developed. New Dischargers registering for NOI coverage on or after July 1, 2015 shall certify and submit PRDs via SMARTS at least seven (7) days prior to commencement of industrial activities.

With decades of experience, we understand the importance of efficient and effective compliance for your business. As requirements and enforcement have increased, Alta Environmental (Alta) has taken steps towards having the most educated and experienced staff in the industry. Alta’s Director of Water Resources, David Renfrew, is now a Qualified Industrial Stormwater Practitioner (QISP), as well as an Industrial General Permit Trainer of Record (IGP ToR). Renfrew is one of approximately 130 qualified individuals certified as both QISP and IGP ToR in the first round of approvals by the State Water Resource Control Board (SWRCB). Our experts have an excellent rapport with the regulators and enforcement authorities. Our mission is to help keep your operation in compliance with the extensive record keeping, reporting, certification, and training requirements as well as Storm Water Pollution Prevention Plan (SWPPP) preparation or revision and implementation. For more information on the Industrial Permit, please contact Mr. Renfrew via email at David.Renfrew@altaenviron.com or via phone at 760-908-5749.