Final Industrial General Permit for Stormwater

The Industrial Storm Water General Permit which has been regulating the auto recyclers and manufacturing industries since 1992 has been significantly revised. The 80 page Permit has been expanded to over 200 pages. It is very complex. The high points are listed below. Details will be provided at upcoming association meetings.

1. The Permit goes into effect July 1, 2015.
2. All data must be submitted on the internet. No paper reports.
3. All submitted data can be read by anybody with internet access.
4. The business owner must register online to be able to certify data.
5. The business owner is the only person that can certify data, although approved people can enter the data.
6. Four samples are required per year, unless the business is in a group program.
7. Group members sample twice a year.
8. If storm water discharge started overnight, samples may be taken within four hours of business opening.
9. Sample limit exceedances require an Exceedance Report, but there is no Permit violation.
10. If numeric limits are exceeded at the end of the year, the operator’s status is raised to risk level 1.
11. Second year numeric limit exceedances raise the operator to risk level 2, requiring a report and plan. No Permit violation has occurred.
12. Additional minimum BMPs are required depending on risk level. Risk level 2 can require treatment.
13. Achievement of benchmarks return risk level 1 or level 2 dischargers to the baseline starting point.
14. A Notice of Non Applicability (NONA) can be filed for Permit exemption if the facility can be certified by a Professional Engineer to not discharge storm water during the largest recorded storm.
15. A No Exposure Certification (NEC) can be prepared by the owner if the owner certified that storm water does not contact industrial material or supplies.
16. Existing SWPPPs and site maps will require rewriting to include greater detail.
17. Naturally occurring background pollutant levels can be utilized to explain exceedances.
18. Technical reports for numeric limit exceedances are to be prepared by a QISP (Qualified Industrial Stormwater Practitioner).
19. QISP certification is achieved by completing an as yet undefined training class.
20. One QISP can represent an unlimited number of facilities.
21. pH sampling is required on site with litmus paper or a pH meter.

Click here for a printable copy.

Industrial Permit

Draft Industrial Permit Comments

On February 19, 2014, the State Water Board released the final draft of the Industrial General Permit and any comments to the draft were due by March 4, 2014 at noon.  Final consideration for the adoption of the Final Draft Industrial General Permit is scheduled for Tuesday, April 1, 2014 at the regularly scheduled Board meeting.

Brash Industries submitted the following comments to be reviewed by the State Water Board:

Paragraph VII. B. New dischargers
1. What documentation is required to demonstrate all discharges to the water body have been eliminated.
2. Does this apply to direct discharges only.
3. If commingling with other storm water discharges occurs does this Permit section apply?
4. Does this apply to discharges to a municipal storm drain system.

Paragraph X.A. 3. F. Glossary – SWPPP List of Industrial Materials.
1. The term Industrial Materials appears overly broad, particularly in reading the Glossary definition of Industrial Materials.
2. Suggest revision to Potential Polluting Materials or some definition of quantity.
3. Should define production/process materials with the potential to pollute. One can of WD 40 or one piece of lumber would require listing.
4. Does intermediate products refer to manufactured sub components of subassemblies. This would be extremely difficult to inventory.

X.E.e – Site map
1. Requires identification of industrial materials storage area and tanks. Does this include storage areas within the confines of a building or the facility?

X.G.d.ii Significant Spills
1. “Spilled or leaked in significant quantity.”
2. A definition of guidance in determining what is a significant quantity would be appropriate.

X.G.2.viii – Estimating BMP Effectiveness
1. In what form would the effectiveness estimates be prepared?

X.H.4.b – Justification for not using each minimum BMP of or applicable advanced BMP.
1. As this is a case of proving the negative, greater definition should be provided, particularly as associated with advanced BMPs which are continually changing.
2. Recommended that Permit wording include the phrase, “as identified in this Permit.”

X.H.2.b.ii – BMPs Storm Water Containment and Discharge Reduction BMPs
1. Encouraged to utilize BMPs that infiltrate or reuse storm water…
2. Does the use of infiltration BMPs trigger the need for a WDR Permit.

 

To view the official letter with comments submitted by Brash Industries use this link: http://www.swrcb.ca.gov/water_issues/programs/stormwater/docs/comments_ind_permit/marvin_sachse.pdf

Industrial Permit

New Industrial Permit Fees

On September 24, 2013, the State Water Board adopted Resolution No. 2013-0030, which adjusted waste discharge permit fees to conform to the revenue levels set forth in the Budget Act for Fiscal Year 2013-2014.  This Resolution increased Industrial General Permit (IGP) storm water fees to $1,791.00/year.

State Water Board funding does not come from the General Fund and needed supplementing.  In order to cover the 2013-2014 operation costs of the State Water Board, the fee was increased.

Marvin H. Sachse, Brash Industries, is working in conjunction with trade associations to implement a sliding scale where yearly fees are based upon facility size.

If you have any questions regarding the increase, you may contact the Water Board at: fee_branch@waterbords.ca.gov or contact Brash Industries at 310-305-8637.

Industrial Permit

Draft Industrial General Permit

On August 21, 2013, the State Water Board conducted a hearing on the latest draft of the Industrial General Permit (IGP).

Most speakers considered the new Draft IGP to be a significant improvement over the previous Draft.

Time was devoted to clarification of Permit terms, the amount of sampling, and the application of ‘green’ concepts like Low Impact Development (LID).

Sampling and compliance standards were discussed as to which limits should apply and whether it should be at the property discharge point or where the discharge water contacts the receiving water (ocean, stream, lake, or river).

The Permit is scheduled to be implemented January 1, 2015. The wet season end, July 15, 2015, was preferred.

For more details on the hearing download the Storm Water Run-on Newsletter here: IGP Newsletter 8-26-2013

Industrial Permit

New Industrial Permit

Brash Industries
As most have heard, a new Industrial Permit is working its way through the bureaucratic system. This is the third draft and is likely to be adopted without a further review.

Marvin Sachse, Brash Industries, sponsored by CADRA, spoke to the State Water Board, requesting that Permit fees be reduced from the $1,359.00 for small business operators. He proposed that fees be based on a sliding scale related to facility size.

This proposed fee reduction was also formally submitted in writing to the State Water Board. Unfortunately, Mr. Sachse was the only person from industry presenting this proposal. He also pointed out that auto recyclers have over 1,000 permits in the State and represent 10% of all of the State’s 10,000 permits – the single largest group of permittees.

The new Permit is expected to be out either late February or March and will probably be adopted in time for the 2013-2014 storm season. Once adopted, additional information on the Permit will be provided.

Newsletter updates occur frequently.

If you would like to be added to the Brash Industries e-newsletter, please e-mail

newsletter@brashind.com with ADD in the subject line.

General, Industrial Permit
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