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Industrial General Permit Key Updates and Dates

12/12/2017

 
By: David S. Renfrew, CPSWQ, QISP/TOR, QSD, PMP
Vice President, Director of Water Resources at Alta Environmental


Key Permit Updates

California’s 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) will be re-opened and revised to incorporate Total Maximum Daily Loads, Exceedance Response Action Level 2 Options, and the incorporation of Sufficiently Sensitive Methods. The State Water Resources Control Board Industrial Team process includes the following:
State Water Resources Control Board
  1. Releasing the Draft Revised Permit-December 15, 2017
  2. Hosting three public workshops:
    a. Sacramento-December 18, 2017; 10:00 a.m. - 2:00 p.m.
    b. Los Angeles-December 21, 2017; 10:00 a.m. – 2:00 p.m.
    c. San Diego-December 22, 2017; 10:00 a.m. – 2:00 p.m.
  3. Public comment period-January 31, 2018; until 12:00 noon.

​Information on the Permit revision process can be found at https://www.waterboards.ca.gov/water_issues/programs/stormwater/tmdl_igp.shtml

Key Compliance Dates for ERA Level 1 and ERA Level 2

If you have an Industrial Permit, did you know that your facility may be in multiple statuses during the Permit year? If you are in ERA Level 1 or 2 Status, you need to be aware of the reporting requirements and deadlines. ERA Level 1 Status requires an ERA Level 1 Evaluation be conducted by a Qualified Industrial Stormwater Practitioner (QISP) by October 1 followed by the ERA Level 1 Report submitted by January 1. Facilities in ERA Level 2 require an ERA Level 2 Action Plan be submitted by January 1 followed by an ERA Level 2 Technical Report the following year. Both statuses require that BMPs be implemented to resolve the numeric action level (NAL) exceedances that are occurring.

We have been noticing that the Stormwater Multiple Application and Report Tracking System (SMARTS) may not reflect the current or accurate status for a given facility. To find your current status, log into your facilities SMARTS account, navigate to the Requirements Tab, and observe the current status of each required parameter. We recommend that any facility manager or owner review their current status in SMARTS and correct any inconsistencies if observed. If the status is accurate, you’ll need to plan on implementing the required actions prescribed in the Permit. Remember, January 1 is the compliance date for report uploads and certification. We are advising that facility managers get a jump on this date to avoid any headaches during the holidays.

For any questions or for needed support with your Industrial Permit compliance program, please contact David Renfrew, Vice President/Water Resources Director at David.Renfrew@altaenviron.com or 760-908-5749.

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