2014 Industrial General Permit Summary of Key UpdatesOrder 2014-0057-DWQ

Sandy MathewsAugust 19, 2014

Stormwater Permits

Municipal

MS4s

Industrial

IGP

Construction

CGP

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IGP History in California

1991 – 1st Generation IGP

1997 – 2nd Generation IGP

2014 – 5th Generation IGP

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Basic Facts & Information Order 2014-0057-DWQ

http://www.waterboards.ca.gov/water_issues/programs/stormwater/industrial.shtml

Adopted: April 1, 2014 Effective: July 1, 2015 Two types of coverage + non-applicability

NOI – Notice of Intent File by July 1, 2015, or when operations commence

NEC – No Exposure Certification File by October 1, 2015

NONA – Notice of Non-Applicability4

Not a typo

Facilities required to file for coverage Facilities subject to storm water ELGs, NSPS, or toxic

pollutant effluent standards Cement Manufacturing Manufacturing Oil and Gas/Mining Hazardous Waste Treatment, Storage, or Disposal Landfills, Land Application Sites, and Open Dumps Recycling Facilities Steam Electric Power Generating Transportation Sewage or Wastewater Treatment Works

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Sewage or Wastewater Treatment Works

Facilities used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge, that are located within the confines of the facility, with a design flow of one million gallons per day or more, or required to have an approved pretreatment program under 40 Code of Federal Regulations part 403.

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Note: In Region 2, the Regional Water Board typically requires smaller plants to develop SWPPPs through the wastewater NPDES Permits.

What to changes to look for Electronic filing and reporting Minimum Best Management Practices (BMPs) More frequent sampling and inspections Numeric Action Levels (NALs) Exceedance Response Actions (ERAs) Qualified Industrial SWPPP Practitioners (QISP) TMDLs & other requirements More acronyms than ever before

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Electronic filing and reporting NOIs, SWPPPs, Annual Reports, monitoring

data are entered into SMARTSNo more paper reports

Visual observations: document observations and report in annual report

Effluent sampling: data must be submitted into SMARTS within 30 days of obtaining results

Annual reports are due by July 15

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SMARTS – Stormwater Multiple Application and Report Tracking System

Minimum BMPs – No surprises but they are now all required Good Housekeeping Preventative Maintenance Spill & Leak Prevention & Response Material & Waste Management Erosion & Sediment Control Employee Training Quality Assurance & Quality Control

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Pay attention to the details in the sub-bullet in the permit, they are all part of the minimum required BMPs. If you cannot conform to the requirements must be justified in the SWPPP.

Key monitoring elements remain similar

Visual observations Effluent sampling

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But there will be changes …

Monitoring program designed around drainage areas

Observations and sampling are based on industrial activity drainage areas

Key Definition

Drainage Area

The area of land that drains water, sediment, pollutants, and dissolved materials to a common discharge location.

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Required monitoringType of

MonitoringFrequency Objective

Visual Observations

Monthly Facility operations, BMPs, non-stormwater discharges, unaddressed potential pollutants

Storm Event Discharge Observations

During sampling events

Stormwater discharges, presences/absence of visual pollutants, sources of pollutants

Sampling and Analysis

4 events per year: 2 in Jul-Dec, and2 in Jan-Jun

Sample each discharge point during a qualified storm event

Comprehensive Facility Evaluation

Annual Assess effectiveness of SWPPP

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Key DefinitionQualified Storm Event

Produces discharge from at least one drainage area, and is preceded by at least 48 hours with no discharge from

any drainage area.

Required water quality monitoring parametersWho Parameter

All Permittees pH, TSS, O&G

All Permittees Pollutants identified in your source assessment

IGP SIC Code IGP Table 1

Facilities discharging to waters with 303(d) listings or TMDLs

If the industrial activities are potential sources of the impairing pollutant

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Numeric Action Levels

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Parameter Annual NAL Instantaneous Maximum NAL

NAL Exceedance Criteria

Average of all results in a reporting year exceed

value

2 or more results in a reporting year exceed value

pH NA <6.0; >9.0 std. units

TSS 100 mg/L 400 mg/L

Oil & Grease 15 mg/L 25 mg/L

See IGP for the complete list of NALs

Exceeding NALs trigger a series of evaluations and actions – ERA

Exceeding NALs is not a permit violation! Not doing the ERA is a permit violation

Baseline Status(all facilities start here)

Level 2 Status

Trigger

After completing ERA Actions and 4 consecutive QSEs

sampled with no NAL exceedances return to

Baseline Status

NALs

Level 1 Status

NALs

Original Graphic Credit: SWRCB

NAL exceedances trigger action

Trigger

Tri

gg

er

Sampling

Sampling

Evaluate results for each parameter

If NAL is exceeded, initiate required ERAs

ERA Status Level updates July 1 regardless of when the exceedance occurred

ERA requirements

ERA Level 1 Get QISP to assist with

ERA actions Write ERA Level 1 Report Implement actions

BMPs, SWPPP update Continue implementing

SWPPP and monitoring

ERA Level 2 Get QISP to assist with

ERA actions Develop and submit ERA

Level 2 Action Plan Prepare and submit ERA

Level 2 Demonstration Technical Report

Continue implementing SWPPP and monitoring

17QISP – Qualified SWPPP Practitioner

Other requirements: TMDLs, ASBS, Trash… Dischargers to the Ocean and Areas of Special

Biological Significance have additional requirements, especially monitoring

TMDLs are being incorporated into the permit through a reopener processEach Region will propose and notice requirementsState will add to IGP in early 2016

Trash Amendments will be incorporated into the IGP after they are adopted by the State Board

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What to do before July 1, 2015 … Don’t panic, but don’t wait Assess monitoring data

NAL exceedances?Can you make corrections now?

Assess SWPPP does it address the minimum BMPs?Plan for SWPPP update

Look for updated Industrial BMP handbook from CASQA

Look for QISP training from State Board/CASQA Stayed tuned for more info fro the State Board

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Sandy MathewsLarry Walker Associates510-625-1580sandym@LWA.com

21See IGP Factsheet 45