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2014 Industrial General Permit Blog Article 4

Posted on Tue, Jul 21, 2015

Deadline Extension For California’s Industrial General Permit For Storm Water Dischargers

As an update to the previous blog articles on the deadline for compliance with the new California Industrial General Permit (IGP) for storm water dischargers, the State Water Resource Control Board (State Water Board) has extended the compliance deadline from July 1, 2015 to close of business on Friday August 14, 2015.

StormwaterThe new IGP requires that all compliance filings be made electronically through the State Water Board’s Storm Water Multiple Application Reporting and Tracking System (SMARTS) online database. Technical issues affecting the SMARTS database had been limiting new enrollments and annual submittals from existing enrollees. This extended deadline should enable those industrial facilities that were either unaware of the July 1, 2015 deadline or those struggling to meet that deadline to timely register.

As previously discussed , the 2014 IGP requires light industrial facilities to enroll for permit coverage, even if they do not expose their industrial activity to storm water. Enrollment and compliance requirements for No Exposure Certification will become effective on October 1, 2015. To avoid being fined by the State Water Board we recommend that your facility/site be in compliance by the appropriate implementation date. Rincon can assist you with your compliance needs and questions. We can assist with SWPPP writing and amendments, No Exposure Certification, annual reporting, Environmental Action Reports, create up-to-date site maps, assist with electronic filing, provide storm water monitoring and inspection, provide training, and much more. If you have any questions regarding the IGP, to help determine if your facility is subject to the 2014 IGP, or have any compliance needs, please contact Kristin Roberts or Ed De La Llave at (805) 644-4455.

Topics: NPDES, State Water Control Board, General Permit, stormwater, National Pollutant Discharge Elimination System, IGP, Storm Water Management Program, storm, No Exposure Certification, SMARTS

2014 Industrial General Permit Blog Article 3

Posted on Fri, Sep 19, 2014

Compliance with the Industrial General Permit for Light Industrial Facilities - No Exposure Certification

describe the imageThe newly released National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Dischargers Associated with Industrial Activities, NPDES No. CAS000001 (2014 IGP) contains significant revisions from the prior 1997 Industrial Storm Water General Permit (1997 IGP).  The 2014 IGP includes many substantive changes that will impose new and increased compliance requirements to a large number of industrial facilities. 

Previously, light industrial facilities were exempt from the 1997 IGP requirements as long as the light industrial facility eliminated non-storm water discharges and ensured that their industrial activities were not exposed to storm water.  However, the 2014 IGP requires that these light industrial facilities must now enroll for permit coverage, even if they do not expose their industrial activity to storm water.  Any light industrial facility seeking to claim a conditional exclusion under the new 2014 IGP must apply and complete a No Exposure Certification and attach pertinent documents.  To be successful in obtaining a No Exposure Certification, the light industrial facility must show that no exposure to storm water occurs at their facility.   

What does it mean to have “No Exposure”?

All industrial materials and activities must be protected by a storm water-resistant shelter to prevent exposure to rain, snow, snowmelt and runoff.  The following must not come in contact with storm water or storm water runoff:

    • material-handling equipment or activities
    • industrial machinery
    • raw materials, intermediate products, by-products, final products, or waste products

Who May File for No Exposure Certification Coverage

An industrial facility may obtain No Exposure Certification coverage if the industrial facility certifies that a condition of “No Exposure” exists at the industrial facility by submitting No Exposure Certification Permit Registration Documents via the State Water Resources Control Board’s Storm Water Multi-Application and Report Tracking System (SMARTS) and pays an annual fee.

Steps to Obtain No Exposure Certification Coverage

1. Determine if your facility is subject to the 2014 IGP (as defined in Attachment A of the 2014 IGP)

A. Does your facility meet the definitions of “No Exposure” and qualify for the No Exposure Certification? If yes, proceed to step number 2. If no, obtain a Notice of Intent coverage via SMARTS.

2. Certify and electronically submit the completed Permit Registration Documents for No Exposure Certification coverage via SMARTS and mail the annual fee to the State Water Board. Permit Registration Documents include:

A. Facility information

B. Facility Site Maps

C. No Exposure Certification Checklist - An inspection and evaluation of each individual industrial facility that evaluates 11 major areas where storm water exposure may occur.

D. Certification - Via submitting forms electronically to SMARTS and pay an annual fee

3. Annual inspection and evaluation, re-certification and fee are required thereafter.  If a physical or operational change occurs which causes exposure of industrial activities or materials to storm water, the industrial facility must then immediately comply with all the requirements of the 2014 IGP and obtain Notice of Intent coverage. 

When will compliance of the 2014 IGP become effective?describe the image

The complete implementation of the new 2014 IGP is on or before July 1, 2015 with all appropriate documents uploaded and certified via SMARTS.  If your facility meets the No Exposure Certification requirements then enrollment and compliance will become effective on October 1, 2015.  To avoid being fined by the Water Board we recommend that your facility/site be in compliance by the implementation date.  Rincon can assist you with your compliance needs and questions.  We can assist with SWPPP writing and amendments, No Exposure Certification, annual reporting, Environmental Action Reports,  create up-to-date site maps, assist with electronic filing, provide storm water monitoring and inspecting, provide training, and much more.  If you have any questions regarding the 2014 IGP, to help determine if your facility is subject to the 2014 IGP, or have any compliance needs, please contact Ed De La Llave or Kristin Roberts at (805) 644-4455. 

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Topics: NPDES, State Water Control Board, General Permit, NEC, stormwater, National Pollutant Discharge Elimination System, IGP, Storm Water Management Program, storm, No Exposure Certification, light industrial facility

2014 Industrial General Permit Blog Article 2

Posted on Wed, May 14, 2014

Types of Industrial Facilities Requiring Permit Coverage Under the New 2014 IGP

Wastewater TreatmentThe new National Pollutant Discharge Elimination System (NPDES) General Permit for stormwater discharges associated with industrial activities (Industrial General Permit) will become effective on July 1, 2015, and includes significant changes to industrial facilities requiring permitting, monitoring, and reporting processes.

Facilities requiring permitting under the IGP can include Federal, State, municipally owned and private facilities. Types of industrial facilities requiring permit coverage under the new Industrial General Permit (IGP) include the following:

1. Facilities required by Federal regulations.

      • Examples of the Federal regulated facilities can be located in Attachment A of the IGP. 

2. Facilities designated by the State Regional Board. These facilities are further categorized and defined by Standard Industrial Classification codes (SIC). Examples of Category descriptions and corresponding SIC codes can be found in Attachment A of the IGP and examples of the designated facilities are as follows:

      • Manufacturing Facilities
      • Oil and Gas/Mining Facilities
      • Hazardous Waste Treatment, Storage or Disposal Facilities
      • Landfills, Land Applications Sites, and open Dumps Facilities
      • Recycling Facilities
      • Steam Electric Power Generating Facilities
      • Transport Facilities
      • Sewage or Wastewater Treatment Work Facilities

3. Facilities that have been directed by the Regional Board.

      • Facilities that have been directed by the Regional Board to obtain coverage under the new IGP are required to comply and be covered under the new permit.

Furthermore, the new IGP requires “light industry” to enroll under the new permit. However, a “light industry” facility can claim a conditional exclusion by filing a No Exposure Certification (NEC) certifying that there is no exposure of industrial activities and storage of materials to stormwater. The NEC is required to be filed annually.

The new IGP has recently adopted changes and will become effective on July 15, 2015. With changes to the new IGP, facilities must work with more stringent guidelines and produce documentation by the implementation deadline in order to remain in compliance. All facilities (new or previously covered) regulated under the IGP will now need to evaluate their current practices and documentation with respect to the new IGP requirements to assure that they are in full compliance. Significant advantages and an expedited permitting process can be found with those that understand the new requirements and can generate the required documents.

For additional information on determining your facilities enrollment under the new IGP, or any other related topics to the new IGP please contact us. For an overview of the 2014 IGP, see our previous article here, and stay tuned for our next post in the series.

If you have any questions, or wish any assistance in the new Industrial General Permit requirements, please feel free to contact Kristin Roberts or Ed De La Llave at (805) 644-4455, or request a quote below. 

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Topics: NPDES, State Water Control Board, General Permit, NEC, stormwater, National Pollutant Discharge Elimination System, IGP, Storm Water Management Program, storm, No Exposure Certification, Hazardous Waste Treatment, Recycling Facilities, Steam Electric Power Generating Facilities, Industrail Facilities, Manufacturing Facilities, Oil and Gas/Mining Facilities, Storage Facilities, Disposal Facilities, Landfills, Land Applications Sites, Open Dumps Facilities, Transport Facilities, Wastewater Treatment Work Facilities

2013 NPDES Industrial Storm Water Permit Proposes Significant Changes

Posted on Mon, Nov 4, 2013

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Urban stormwater runoff is increasingly recognized as a significant variable in the health of aquatic organisms and public health. Debris and pollutants carried by stormwater into surface waters used for potable and recreational water supplies can adversely affect these resources if not properly treated. For nearly two decades, the California State Water Resources Control Board (SWRCB) has regulated the runoff and treatment of storm water from industrial, construction and municipal sources in California. The State Water Board is required to issue permits that are consistent with the National Pollutant Discharge Elimination System (NPDES) storm water regulations adopted by the US Environmental Protection Agency (USEPA) in accordance with the federal Clean Water Act.

Storm Water Pollution Prevention Plans (SWPPPs) are a requirement of the NPDES that regulate water quality when associated with construction or industrial activities. This past July, the SWRCB released the 2013 Draft NPDES Permit for the Discharge of Storm Water Associated With Industrial Activities (the "Draft Industrial General Permit", or IGP), which proposes significant changes in the regulation of storm water discharges from industrial facilities.The following summarized changes in the revised and simplified Draft 2013 IGP from the 2012 Draft IGP.

Training Requirements
1. There is only one type of Qualified Industrial Storm Water Practitioner (QISP) in the IGP, instead of three as previously proposed.
2. QISP training is not required until exceedance response actions are triggered.
3. Additionally, anyone can prepare No Exposure Certification (NEC) – a QISP is no longer required.

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Monitoring Requirements
1. The previous requirements to conduct pre-storm visual observations and quarterly authorized and unauthorized non-storm water discharge visual observations are now combined into one new monthly visual observation requirement.
2. The previous requirement to conduct monthly storm water visual observations is now tied to the actual sampling events, which are required twice in each half of the year.
3. Rain gauges and measurement of rainfall are no longer required.
4. Litmus paper is allowed to be used for screening of pH exceedances.
5. Lastly, eligibility for a Sample Frequency Reduction only requires data from four storm events instead of eight.

Exceedance Response Actions (ERAs). The permit proposes differing levels of response when water quality is affected, depending on the magnitude and frequency of the exceedence.
1. Level changes in the ERA requirements now will become effective at the start of the reporting year following the exceedance(s).
2. Action plans and technical reports are part of the requirements for the highest level of exceedences requiring action.

Compliance Groups
1. Dischargers from the same or similar industries are encouraged to form Compliance Groups.
2. Only one type of Compliance Group is allowed, instead of two. Participants in Compliance

Annual Reports. The 2013 draft IGP greatly reduces annual reporting requirements.

No Discharge. The 2013 draft IGP provides new “No-Discharge” eligibility requirements for dischargers eligible to file a Notice of Non-Applicability.

The 2013 Draft NPDES Industrial General Permit (and other associated documents) may be viewed and downloaded from the State Water Board’s website at: http://www.waterboards.ca.gov/water_issues/programs/stormwater/industrial.shtml

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Topics: SWPPP, runoff, NPDES, United States Environmental Protection Agency, USEPA, Draft Industrial General Permit, QISP, stormwater, National Pollutant Discharge Elimination System, Clean Water Act, IGP, California State Water Resources Control Board, SWRCB