What’s Your Status…Under the Industrial General Permit? Make Sure You are Meeting All Reporting Guidelines
Do you have an Industrial General Permit or are you required to get one?
Does your facility require coverage under 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)? Many industrial manufacturing facilities may not be aware that the Permit has been renewed or that their facility is even required to obtain permit coverage. While the State Water Resources Control Board and Regional Boards have been trying to get the word out for the past three years, facilities are still falling through the cracks and are deemed out of compliance if found. The local city and county agencies are also required to identify these facilities and report them to the SWRCB if found. Facilities that fail to respond to SWRCB notices may face the mandatory minimum penalty of $5,000 under Section 13399.33(a)(1) of the California Water Code if the Regional Water Quality Board decides to take early action. Furthermore, continued violations of the General Permit may result in the imposition of administrative civil liability in an amount of up to $10,000 for each day of violation under Section 13385 of the California Water Code.
How do you know if you need Permit coverage under the IGP? It is specifically related to your Standard Industrial Classification (SIC) Code. The link to the SWRCBs website to look at the SIC code requirements can be found at under the Permit Coverage tab on the SWRCB Industrial Permit website at: https://www.waterboards.ca.gov/water_issues/programs/stormwater/industrial.shtml#
What’s your Status? Baseline? ERA Level 1, ERA Level 2, or all three?
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 the 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.
With decades of experience, we understand the importance of efficient and effective compliance for your business. As requirements and enforcement have increased, Alta has taken steps towards having the most educated and experienced staff in the industry. Our experts are QISPs, Certified Professionals in Storm Water Quality (CPSWQ), and Qualified SWPPP Practitioners (QSP), and Qualified SWPPP Developers (QSD). Our mission is to help keep your operation in compliance with the extensive record keeping, reporting, certification, and training requirements, as well as ERA Level 1 Evaluations and Reports, ERA Level 2 Action Plans and Technical Reports, and Storm Water Pollution Prevention Plan (SWPPP) preparation, revision, and implementation. Through strategic use of sound science, we prepare and implement compliance monitoring to be cost effective as well as manage and limit your risk.
Have questions or need support with your compliance program? Contact David Renfrew, Vice President/Water Resources Director at David.Renfrew@altaenviron.com or 760-908-5749.
Article post by David S. Renfrew, CPSWQ, QISP/TOR, QSD, PMP
Vice President, Director of Water Resources at Alta Environmental