INDUSTRIAL STORM WATER PERMIT COMPLIANCE -- DO THIS NOW!

Do You Do Storm Water?

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. Start preparing now.

This is article is Part 1 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.

Is your facility required to register?

If your facility is required to register, you must do so, even if your facility does not expose storm water to industrial activities. Following the simple steps identified below will help you determine if your operations are regulated by the General Industrial Permit.
You need to ascertain your facility four digit Standard Industrial Classification (SIC) Code.

WHY??? The Industrial Storm Water permit is applicable only to facilities classified as either heavy industry or light industry based on the Office of Management and Budget Standard Industrial Classifications (SIC).

HOW??? The SIC code manual is located at https://www.osha.gov/pls/imis/sic_manual.html. The Manual is partitioned into 10 Divisions. Each Division provides descriptions of activities divided into Major Groups. The first two digits of the SIC Code is determined by the Major Category associated with the facility operations.

WHO??? Compare the Major Group determined from the SIC manual with the list included in Attachment A of the Permit summarized below. All facilities listed must apply for coverage under the 2014 Permit, even if they do not expose storm water to industrial activity.

• Facilities with Standard Industrial Classifications (SICs) 20XX through 39XX, 4221 through 4225
  
• Facilities classified as SICs 10XX through 14XX, including active or inactive mining operations
  
• Standard Industrial Classification 5015 and 5093.
  
• Facilities with SICs 40XX through 45XX (except 4221- 25) and 5171 with vehicle maintenance shops, equipment cleaning operations, or airport deicing operations.
  

Only those portions of the facility involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication) or other operations identified under this Permit as associated with industrial activity.

If the first two digits of your facility SIC code match the Major Groups listed in Attachment A, the Industrial General Permit is applicable to your facility. If your primary SIC Code is not included, but you have an auxiliary activity that is included in the Attachment A list, you may STILL be subject to the Industrial General Permit.   If you have questions or for more information please contact our experts.

David Renfrew, Director of Water Resources at (760) 908-5749