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