New IGP Registration Letter

The new Industrial General Permit will go into effect on July 1, 2015. Every Permittee will receive a letter detailing the requirements for the new Permit.

Our clients and group members will not need to do anything as we will assist you through the process.

All client will be visited starting in February, 2015 to start the New Permit process which requires:

• Evaluating if a Permit is required.

• Enrolling Permittees into the SMARTS Program

• Preparing a New SWPPP

• Preparing a New Site Map

• Preparing a New Sampling and Monitoring Program

• Preparing New Permit Registration Documents (PRD)
The group will remain intact and annual sampling is reduced from the required 4 to 2, for group members.

January 29, 2015

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The Storm Water Program Agrees to Implement a Tiered Permit Fee Structure Based Upon Acreage

The Storm Water Program Fee Branch recently notified Brash Industries that it intends to implement a Tiered Permit Fee system based upon facility acreage. A smaller facility will pay less than a larger facility. This tiered fee program was proposed by Brash Industries’ SoCal Storm Water Group Monitoring Program Manager, Marvin H. Sachse, P.E., with the support of the California Auto Dismantlers and Recyclers Alliance (CADRA).

The tiered Stormwater Permit Fee concept was initially proposed by Mr. Sachse to the State Water Board three years ago and Mr. Sachse has been encouraging its adoption ever since. At the June 20, 2014, Permit Fee Branch meeting of the State Water Board Fee Branch, Mr. Marvin Sachse, again proposed consideration of an annual fee rate based upon a measure of permittee size, such as: number of employees, facility area, or gross revenue, with smaller facilities paying a lower fee than larger facilities.

The Water Board Fee Branch staff appreciated Mr. Sachse’s presentation and requested a formal submission of his request for tiered permitting along with his presentation material demonstrating Arizona and Washington State’s size-based fee programs. The backup information also demonstrated that Stormwater Permit fees for Nevada and Oregon are significantly lower, ½ to ⅛ that of the fees charged in California.

A Water Board Fee Branch staff member recently advised Mr. Sachse that the Water Board Fee Branch will endeavor to adopt the tiered fee system in FY 2015-2016, but in all likelihood it will not be fully implemented until FY 2016-2017.

Additionally, BI also received information that the Permit Fees for FY 2014-2015 have been proposed with an 8.2% fee reduction.

For a printable version of this post, click here.

August 20, 2014

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Water Board Moves Toward Sliding Scale Permit Fees

At the June 20, 2014 Permit Fee meeting, the Water Board Fee Branch staff indicated that they would consider implementation of a sliding scale Stormwater Program Permit Fee as proposed by CADRA, SoCal GMP, and Brash Industries. The Sliding Scale Proposal was presented by Mr. Marvin Sachse, the only meeting attendee representing industrial permitees. The proposed program establishes an annual fee rate based upon a measure of permitee size, such as: number of employees, facility size, or gross revenue, with smaller facilities paying a lower fee than larger facilities.

The Sliding Stormwater Permit Fee concept was proposed by Mr. Sachse to the State Water Board three years ago and Mr. Sachse has been encouraging its adoption ever since. Water Board Fee Branch staff members advised Mr. Sachse that the Water Board Fee Branch supported the concept and would be working to implement fee reductions and fee scaling when the new Industrial General Permit is implemented on July 1, 2015.

The Water Board Fee Branch staff appreciated Mr. Sachse’s presentation and requested a formal submission of his presentation along with the backup material used in the presentation that demonstrated Arizona’s utilization of a sliding fee schedule based upon acreage and Washington State’s program based upon gross sales which includes a fee reduction provision for hardship, ability to pay, and small businesses. The Stormwater Permit fees for Nevada and Oregon are, respectively, ½ to ⅛ that of the fees charged in California. Mr. Sachse pointed out that California municipalities were also charging Stormwater fees, giving the perception of double charging for the same program.

Mr. Sachse also described the overall condition of the State’s economy and the impacts the large Permit fees have on the small business operator which could result in Stormwater program abandonment which, ultimately, reduces the number of permitees and the overall level of compliance. In a conversation with one of the Water Board Fee staff members, it was mentioned that there would not be a fee increase next year.

For a printable version of this post click here.

July 1, 2014

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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.

April 16, 2014

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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

March 7, 2014

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