UPDATE: INDUSTRIAL GENERAL PERMIT FOR STORMWATER

The long-awaited 2014 Final Draft NPDES Permit for the Discharge of Storm Water Associated with Industrial Activities (the “Final Draft IGP”), proposes significant changes in the regulation of storm water discharges from industrial facilities. After 10 years of analysis and public input on numerous prior drafts, the State Water Board now proposes an Industrial General Permit to replace the current permit issued in 1997.

The 2014 final draft of the industrial general permit (IGP) was issued on February 19, 2014.  Final stake holder comments regarding the specific revisions of the July 2013 version of the permit were due on March 4, 2014.  The State Board intends to hold an adoption hearing for the final draft permit on April 1, 2014.

The Draft IGP is proposed for adoption on April 1, 2014 and complete implementation on or before July 1, 2015 for Notices of Intent (NOI) and October 1, 2015 for No Exposure Certifications (NEC).  This permit will vastly increase the number of industries affected and impose new and increased compliance requirements on currently regulated facilities.

This General Permit is significantly different from the previous permit in the following areas:

1. Minimum and Advanced Best Management Practices (BMPs)
2. Conditional Exclusion – No Exposure Certification (NEC) for previously unregulated light manufacturing.
3. Mandatory Electronic Reporting Requirements permitting easy public access to data.
4. Numeric Action Levels (NALs)
5. Exceedance Response Actions (ERA)
6. Training Expectations and Roles for Compliance Group Leaders and Qualified Industrial Practitioners.
7. CWA section 303(d) Impairment
8. New Dischargers to listed stormwater impaired waterbodies must have a QISP determine permit coverage eligibility
9. Design Storm Standards for Treatment Control BMPs
10. Qualifying Storm Event (QSE)
11. Sampling Protocols
12. Sampling Frequency
13. Compliance Groups

Overall, the draft permit contains far more detail than before. Alta can assist dischargers with the extensive record keeping, reporting, certification, and training requirements as well as Storm Water Pollution Prevention Plan (SWPPP) preparation or revision and implementation.   In addition, we can assist dischargers with preparation of monitoring and implementation plans that will maximize opportunities for sampling and analysis reduction and assist them with cost effective and efficient use of resources.

Industrial dischargers will be required to submit permit registration documents and reports electronically.  The result is that far more facility-specific information will be publically available than ever before.  We can assist dischargers with electronic reporting to ensure data accuracy and compliance with deadlines.

Finally, the State Water Board has created a new “compliance group” option in this draft.  Participating dischargers of the same industry with similar types of industrial activities, pollutant sources and pollutant characteristics, may join together to receive assistance with permit compliance from a compliance group leader.  Under this arrangement, they may benefit from economies of scale in such tasks as SWPPP preparation, training, sampling and exceedance response reporting.  Alta personnel hold the necessary credentials with the depth of experience necessary to all industry sectors with the support and guidance to efficiently navigate the new requirements.

Please contact David Renfrew, Director of Water Resources at (760) 9085749-5777, or david.renfrew@altaenviron.com.