Have you ever wanted to ask a regulator about his top enforcement priorities for the year? Alta’s President, Lisa Kay spoke with Eric Becker, PE of the San Diego Regional Water Quality Control Board for a Q&A session to learn more. Eric is a Senior Water Resource Control Engineer and responsible for leading the Storm Water Management Unit. The San Diego Regional Water Quality Control Board (Region 9) encompasses San Diego, southern Riverside and the southern portion of Orange Counties. His team is responsible for regulating storm water discharges from construction, industrial, and municipal activities.
What is your team’s top priority for 2015? Construction storm water compliance is one of our highest priorities. Last year we went into the field and found a large number of construction projects with various compliance problems. We are continuing a significant field presence to verify construction project storm water compliance.
How do you prioritize where to conduct your field investigations? First we look at the areas in the region with sediment impairment or high threat to water quality for sediment. Those are the first geographic watershed areas where we focus. We also revisit sites with prior compliance issues to follow up and ensure proper steps have been taken toward compliance.
We are really focused on evaluating both the MS4 Permit and the Construction General Permit. Municipalities under the MS4 Permit (Copermittees) have a responsibility to inspect, require Best Management Practices (BMPs), and enforce construction activities within their jurisdictions. Any construction project, whether by a private company or a public agency, is required to comply with the Construction General Permit (CGP) during construction. We have had issues with lack of enforcement by the in the City of San Diego over the past few years and we will continue to look at this dual compliance between the Copermittees) and the CGP holders (construction sites).
What are the top three non-compliance issues you see? The number one thing we find is a lack of erosion control BMPs. Some sites will have their sediment control BMPs in place, but fail to have erosion control BMPs, and these are two separate things. The second issue we see most often is a lack of maintenance of those BMPs. BMPs are there, but not well maintained to ensure they function during a storm event. The final and a very important issue we find is a real disconnect between the Construction General Permit Qualified SWPPP Practitioner (QSP) or Qualified SWPPP Developer (QSD) and the site superintendent on construction projects. What I mean, we see many instances where the QSP will have documented issues that need to be corrected and he or she will have informed the superintendent, but nothing was done to correct the problem. The CGP requires trained QSPs and QSDs specifically such that there will be trained storm water quality folks with separate responsibilities and focus from the site superintendent to identify issues and solutions, but it’s up to the site superintendent (or site manager) to make sure those issues are corrected, BMPs are implemented and maintained.
Because your team is really focused on field investigations, particularly at construction sites, can we expect to see an increase in enforcement actions in 2015?Absolutely. While I can’t talk about specifics because some are already in the works there will be more… many more, Administrative Civil Liability Assessments (ACLs) made this year. In particular, expect to see more ACLs where we assess penalties or fines against both the Copermittees and construction projects site., because in these instances there is non-compliance with both the MS4 Permit and the Construction General Permit.
What advice can you give a construction project team who’s reading this article?Make sure you follow up in a timely fashion with the recommendations your QSP/QSD makes. The CGP requires you to do so within 72 hours. Focus on erosion control, make sure you have that in place. Remember, if you are actually trying your best, you have BMPs in place, but they fail during a storm event we can deal with it. But if you fail to implement your BMPs or fail to maintain them expect us to take a hard look at your site and you are highly likely to see ACLs from us.
It is Annual emissions inventory reporting time again for South Coast AQMD. However, this year there are going to be some changes.
The South Coast Air Quality Management District (SCAQMD) has completely overhauled their Annual Emissions Reporting (AER) program. The system was available last year on a voluntary basis but its use is mandatory starting this year for the 2014 reports. The new system will require the entry of a large amount of data that wasn’t previously necessary. In addition, the new program requires uploads of all supporting documents such as source tests, TANKS data, and emission factor documentation which will require additional time to gather and submit. Due to this increased data entry and the time involved, the SCAQMD has extended the AER deadline to June 4th (as opposed to the March 3rd date that would have been typical). It is important to get your report started as early as possible to take advantage of the extension particularly if your facility is required to report under AB2588 (Air Toxics update required every four years for certain facilities) this year.
Alta has participated in both the training opportunities provided by SCAQMD in preparation for assisting clients in reporting or with issues that will come up as a result of the changes. If you need assistance please contact Susana Perez or Kimba Spenser of our Air Compliance Services team (562) 489-5777.
There is a new General Industrial Storm Water Permit as of 2014. The new permit eliminates the conditional exemptions from the prior (1997) Permit. Many California facilities that did not have to register under the 1997 Permit now must register under the 2014 Permit. The new General Industrial Storm Water Permit is complicated and requires preparation for a required facility to ensure you are in compliance and meet all deadlines. To help you start preparing ahead of time, there are some simple steps you can take now to prepare.
This is article is the second of a series in which our experts identify a few simple steps you can take each month as the deadline for compliance swiftly approaches. We like to think of it as helping you eat the elephant one bite at a time. For our first article on the series click
In California, the activities that take place at a facility determine whether the facility is required to obtain coverage under the Industrial General Permit (IGP). Standard Industrial Classification Codes (SIC) associated with the primary business of the facility owner as well as auxiliary activities and associated SIC codes will determine whether the facility is required to obtain coverage under the General Permit. For example, a school district must obtain coverage under the General Permit for its bus maintenance facility, even though the primary business of the district is education.
If a facility is subject to the IGP based on the facility activities, there are two possible compliance options. For facilities at which there is exposure of industrial activities or materials to storm water that may run off the site, the facility will be required to obtain coverage by filing Permit Registration Documents (PRDs), and prepare and implement a Storm Water Pollution Prevention Plan (SWPPP). The steps required for these sites are:
Check with us next month for information on the preparation of a Storm Water Pollution Prevention Plan.
If you have questions or for more information please contact our experts.
David Renfrew, Director of Water Resources at (760) 908-5749
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