Blog - Rincon Consultants, Inc.

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. 

ESA Quote

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

2014 Industrial General Permit Blog Article 1

Posted on Fri, Apr 4, 2014

With the release of the new 2014 Industrial General Permit, we will be launching a blog series to introduce and provide information to determine whether an industrial facility must comply with California’s stormwater regulations.  Over the next few months, keep an eye out for posts in our new series, “Stormwater Dischargers Associated with Industrial Activities” with subtopics that will help explain specific 2014 IGP key changes and compliance requirements. 

Newly Adopted 2014 Industrial General Permit For Stormwater Dischargers

On April 1, 2014 the California State Water Resource Control Board released the news that the National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Dischargers Associated with Industrial Activities, NPDES No. CAS000001 has been adopted and will replace the current Industrial General Permit (IGP) issued in 1997.  You can find the new 2014 IGP and supporting documents here

Background

The new lengthy 2014 IGP differs substantially from current requirements and contains significant revisions from the former permit and the circulated drafts in 2011 and 2013.  The 2014 IGP will vastly increase the number of industries affected and impose new and increased compliance requirements.  The complete implementation of the 2014 IGP is on or before July 1, 2015 with appropriate documents uploaded and certified to the State Water Board’s Storm Water Multiple Application and Report Tracking System (SMARTS), making all reports readily available to the public. 

Key Changes to the Industrial General Permit

Regulation of Light Industries: Under the former permit, certain so-called "light industry" facilities were exempt from the permit's requirements as long as the facility eliminated non-storm water discharges and that their industrial activities were not exposed to storm water. However, under the 2014 IGP, these light industries must now enroll for permit coverage.  These light industries may claim a conditional exclusion by filing a "No Exposure Certification" (NEC), certifying that their facility has no exposure of industrial activities and materials to storm water discharges. In order for a Discharger to seek NEC coverage, the Discharger must apply and submit Permit Registration Documents (PRDs), prepare and submit a Site Map, pay the annual fee and certify the NEC demonstrating no exposure via SMARTS on or before the implementation date.  In addition, the Discharger or facility must allow inspections by Water Boards, local MS4, or US EPA staff.  In order for the Discharger to stay in compliance with the State Water Resource Control Board, the Discharger must annually verify no exposure and pay the annual fee via SMARTS.

Mandatory BMPs: The former permit allowed dischargers to "consider" which non-structural and structural best management practices (BMPs) should be implemented to reduce or prevent pollutants in storm water discharges. The 2014 IGP requires the implementation of numerous "minimum BMPs," including good housekeeping requirements, preventative maintenance, material handling and waste management, erosion and sediment controls, and employee training programs. Additional "advanced BMPs," including exposure minimization, storm water containment, discharge reduction, and treatment control BMPs, must also be implemented as necessary to reduce or prevent pollutant discharge.

Monitoring and Sampling Requirements: The former permit required conducting pre-storm visual observations and quarterly authorized and unauthorized non-storm water discharge visual observations.  The 2014 IGP has now combined these two previous requirements into one new visual observation that is conducted at least once per calendar month during daylight hours of scheduled facility operating hours and on days without precipitation.  The Discharger shall provide an explanation in the Annual Report for uncompleted monthly visual observations.  Additionally, sampling protocols under the 2014 IGP have been modified to collect and analyze storm water samples from 2 Qualifying Storm Events (QSE) within the first half of each reporting year (July 1 to December 31) and 2 QSE within the second half of each reporting year (January 1 to June 30).  Minimum required analyses are as follows: Total Suspended Solids (TSS), oil and grease (O&G) and pH.  Additional analyses and parameters may be required based on the facilities Standard Industrial Classification Codes and location to impaired water bodies with a 303(d).  The Discharger shall submit all sampling and analytical results for all sampling events via SMARTS within 30 days of obtaining all results for each sampling event. 

Numeric Action Levels (NALs) and Exceedance Response Actions (ERAs): The 2014 IGP includes both annual and instantaneous maximum NALs, exceedances of which will trigger increasing levels of required actions and treatment controls (Figure 1). If a NAL exceedance occurs as specified in the 2014 permit, the Discharger has to implement various ERA corrective actions.  There are two levels of these actions: Level 1 ERA and Level 2 ERA.  Level 1 ERAs require a site evaluation and report by a QISP and Level 2 ERAs require a technical report by a QISP, non-industrial or background considerations and possible treatment. 

Figure 1: Compliance Determination Flowchart

IGP Scematic2Source: Fact Sheet for the IGP.

Compliance Groups: The 2014 IGP eliminated group monitoring and created a new “compliance group” option for facilities and Dischargers of the same industry type with similar activities, pollutant sources and pollutant characteristics.  Participating facilities and Dischargers that form a compliance group are required to have a designated compliance group leader who has completed a State Water Board approved training program for compliance group leaders.  The compliance group leader is responsible to inspect each participant’s facility each year and is required to collect and analyze storm water samples from the participating group facilities twice each year.  

The release of the 2014 IGP is very detailed and has many more compliance requirements than the previous 1997 permit.  Rincon Consultants can assist Dischargers and facilities with the preparation of these new IGP compliance requirements. 

Our goal with this series is to prepare you for the 2014 IGP key changes and requirements. Please stay tuned for our next post. 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.

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Topics: SWPPP, NPDES, stormwater, IGP, California Construction General Permit, Storm Water Management Program

Complying with Different Stormwater Requirements in California

Posted on Fri, Jun 14, 2013

Rincon

In order for Rincon to meet our client’s stormwater compliance needs during construction, it is important to understand the different requirements of the state, counties, and cities in California. Under the State of California Construction General Permit (CGP), construction or demolition activity resulting in land disturbance equal to or greater than one acre (or less than 1 acre if part of a common plan of development) will be regulated with project-specific requirements. Furthermore, several counties and cities in California have adopted storm water programs with specific standards and requirements that apply in addition to the CGP requirements. The Ventura Countywide Municipal Stormwater (Ventura MS4) Permit Development Construction Program is a great example.

If a project causes soil disturbance during construction or demolition activities and falls within any of the following categories, the site will be required to comply with the Ventura MS4 Permit.

  • Small construction sites (less than 1 acre of soil disturbance)
  • Large construction sites (1 acre or greater but less than 5 acres of soil disturbance)
  • Over 5 acres of soil disturbance
  • High risk sites (determined by site location and conditions) 

All construction sites (small or large) must implement an effective combination of erosion and sediment control Best Management Practices (BMPs) to prevent erosion and sediment loss and the discharge of construction wastes for the construction site. BMP consideration is site specific and implementation will depend on site conditions and type of development. For further information regarding these BMPs please visit: Ventura County MS4 Permit, and Tables 6, 7 and 8 for BMP considerations 

Project Type/Size

Regulated Under Ventura MS4 Permit

Regulated Under CA CGP

< 1 acre

Yes

Only if part of a common plan of development that is ≥ 1 acre

≥ 1 acre

Yes

Yes

High Risk Projects

Yes

If ≥ 1 acre or part of a common plan of development that is ≥ 1 acre

 

Understanding the Permits: Permittees are regulated under the Ventura MS4 Permit for all soil disturbance during construction or demolition activities. Permittees will also be subject to California CGP regulation if the project is greater than one acre of soil disturbance or is less than one acre but part of a larger common plan of development (greater than one acre). In this case, no additional planning is necessary since the site-specific Storm Water Pollution Prevention Plan (SWPPP) that is written to satisfy the State CGP requirements and BMP implementation considerations (refer to Tables 6-8 above) for the specific construction site can also be used to satisfy Ventura County requirements.

When ensuring stormwater compliance, it is a great idea to look into other counties and cities in California that have also adopted similar stormwater programs. For instance, the City of Santa Barbara has also implemented a program called: Storm Water Management Program (SWMP), which was created to reduce the discharge of non-point source pollutants into local creeks and the ocean by implementing six minimum control measures that are outlined and required in the California CGP. For further stormwater permit and program information please visit your local government and State Water Resources Control Board websites.

Have questions about stormwater compliance? Download Rincon's Stormwater Management Flyer or contact us.

Topics: SWPPP, Ventura MS4, SWMP, BMP, stormwater, Construction, water, California Construction General Permit, Storm Water Management Program, storm, CGP, Best Management Practices