Storm Water Dischargers (Permittees) in the Los Angeles Regional Water Board area received notification regarding TMDLs and TSOs. These new Storm Water Permit requirements are part of the current Industrial General Permit (Permit) and become effective July 1, 2020. This is not a new requirement. It has taken a long time to implement.

These additional sampling and reporting requirements are required by Federal Law and apply to all Permitted facilities. The Permit now includes (Numeric Effluent Limits) NELs and TMDL Numeric Action Levels (TNALs). When an NEL is exceeded a mandatory penalty may be imposed. The pollutants and the pollutant limits are site specific and can be obtained with the Water Board’s Mapping Tool.

The TSO is a provision that enables a discharger to delay the mandatory penalty by providing a Time Scheduled Order (TSO) explaining why compliance to the NEL cannot be met by June 30, 2020, and when compliance will be attained. It is thought that the TSO will not protect against a Citizen Suit if an exceedance is reported.

The Permittee must complete the following before June 30, 2020:
1. Identify the TMDL pollutant(s) of concern for the receiving water of the storm water discharges from the facility.
2. Verify whether the TMDL pollutant is on site and if so, listed in the SWPPP Pollutant Inventory.
3. Sampling for the NEL/TNAL pollutant(s) is not required if BMPs are implemented that eliminate pollutant exposure to storm water.
4. Update the new sampling procedures and new BMPs if new pollutants of concern have been added to the SWPPP.
5. Upload the updated SWPPP and Site Map to SMARTS.
The foregoing can be performed by the Permittee, as the necessary reference information has been provided by the Water Board in the TMDL Mapping Tool. If the Permittee is in good standing with the Brash Industries Storm Water Program, a special $125 price to complete this service is offered.

Please call BI if you have any questions or if more detailed information on this program is of interest.