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Industrial General Stormwater Permit Amendments

10/29/2018

 
Weather-Ready Nation
Implications of TMDLs and What You Should Be Doing Now

By your Weather-Ready Nation Ambassadors at Alta Environmental

David Renfrew, QISP/ToR, QSD/P, CPSWQ, PMP

​California’s rainy season is upon us and there is a dark cloud on the horizon. Unfortunately, it is not in the realm of rain at this point. The dark cloud being referred to here is the pending Industrial General Permit Amendment that will likely be adopted on November 6, 2018.

https://www.waterboards.ca.gov/water_issues/programs/stormwater/tmdl_igp.html

​California’s Statewide General Permit for Storm Water Discharges Associated with Industrial Activities, Order 2014-0057-DWQ (Industrial General Permit or IGP) implements the federally required storm water regulations in California for storm water associated with industrial activities discharging to waters of the United States. During the last IGP revision in 2014, TMDLs were included but not formally amended at that time. Now, the State Water Resources Control Board (SWRCB) is formally adopting the following changes:
  1. Implementation language for TMDLs listed in Attachment E of the IGP
  2. Compliance incentives for industrial storm water capture, and
  3. Implementation of the recently promulgated US EPA sufficiently sensitive method requirements.

Implications of TMDLs


For this article, we are focusing on Item #1. Item #1 is the big concern for any facility located in, and draining to, a TMDL water body. So, just what is a TMDL? A Total Maximum Daily Loads (TMDL) can be thought of as a maximum amount of a pollutant (or load) that a water body (e.g., creek, river, bay, harbor, ocean) can handle without becoming impaired. A TMDL is then assigned by the SWRCB and a TMDL limit is then applied to those parties discharging to the water body. The issue is that most of California’s water bodies are impaired for one pollutant or another. The big issue for industrial facilities are the TMDLs that identify industrial sources will now be implemented and enforced in the IGP. For the IGP amendment, there are 36 TMDLs being assigned in the following Regional Board Areas:
IGP TMDL
In the case of the IGP, those TMDLs are assigned as TMDL Numeric Action Levels (TNALs) or Numeric Effluent Limits (NELs) which are now going to apply to dischargers in those water bodies if they have those pollutants. In most cases, the TNALs and NELs are lower than the IGPs current NALs. TNALs will be handled like the NALs in terms of the required actions. However, NELs are Permit effluent limits. According to State and Federal Regulations, exceedances of NELs come with mandatory minimum penalties of $3,000 per discharge location and per day and per discharge event and discretionary penalties of up to $10,000 per day per violation. These can add up to serious numbers. These are not assigned solely based on the two to four sample events you monitor. The results of those monitoring event data are then applied to all storm events that occurred that year. So, think about a facility with three discharge locations and all exceeding the TMDL NEL for copper and 10 storm events occurred that year. Multiplying out the locations by the number of discharge events, we could end up with a monetary penalty of $190,000 for just that year. Is this something your facility is prepared for?

What You Should be Doing Now
  1. Determine if you discharge to a TMDL water body or if your discharge is tributary to a downstream TMDL water body.
  2. Determine if you are testing for those pollutants. If you have performed a pollutant source assessment in accordance with the Permit’s requirements, you may not need to worry about this. If you do have pollutants associated with the TMDL, then you will need to implement actions to assess the impacts of the TMDL on your operations. A good example, is the following:
    1. I manufacture copper parts, I test for copper, the water body downstream has a TMDL for copper, therefore I need to be concerned about this change now.
    2. I do Concrete, Gypsum, Plaster Products, I test only for pH, Oil and Grease, total suspended solids, and iron, the water body downstream has a TMDL only for zinc, therefore I don’t need to be immediately concerned about the zinc TMDL.
    3. I am not in a TMDL water body, consider yourself lucky, and monitor future potential permit changes.
  3. Determine the impact of the TMDL on your facility by assessing the TMDLs spatial extent and the associated pollutants and the levels of the TNALs or NELs. Industrial facilities in the Los Angeles, Santa Ana, and San Diego Region (specifically Chollas Creek) are subject to the most stringent TMDLs.
  4. If you are subject to a TMDL, especially those with NELs, you need to start planning now for immediate best management practices (BMP) changes and working to get your discharge numbers below those NELs. You may be in baseline status now for being below the NALs, but you may be instantly out of compliance if your numbers are above the NELs for a specific pollutant that has a lower NEL than the current NAL once the Permit amendment is formally adopted.

​Alta’s TMDL experts and Qualified Industrial Stormwater Practitioners (QISPs) can conduct a review of your facilities IGP status and risks for the TMDLs. We can provide your business with proactive solutions and BMP recommendations to mitigate the escalating cost of compliance and to prevent future NAL/TNAL/NEL exceedances. To learn if your facility is subject to TMDLs, or if you have elevated ERA status or just compliance concerns in general, or for assistance keeping your business in compliance, give us a call at 562-495-5777 or email our Water Resources experts.

David Renfrew, QISP/ToR, QSD, CPSWQ, can be reached via email at David.Renfrew@altaenviron.com.
Jacqueline McMillen, P.E., QISP, QSD, can be reached via email at Jacqueline.McMillen@altaenviron.com.

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