The California State Water Resources Control Board’s (SWRCB) Industrial General Permit (IGP), adopted last April, will go into effect July 1. The new permit contains some noteworthy changes compared to the 1997 permit. These changes include a significant increase in permitted facilities. The old permit covered 11 industrial categories. And while the new permit has only nine categories, it expands the types of businesses covered as determined by a facility’s Standard Industrial Classification code. The expansion includes light industries not previously covered, such as wineries and breweries.
Generally, if a facility falls within the nine categories, they will either file a Notice of Intent, putting them on the path for full permit coverage, or they will file for No Exposure Certification (NEC) coverage. For NEC coverage, facilities must meet 11 requirements, including no exposure of industrial activities and operations to rainfall. Even these facilities must submit a site map in addition to obtaining and paying for annual NEC coverage at a cost of $200. SWRCB estimates that between 10,000 and 30,000 dischargers will register for either Notice of Intent or NEC coverage.
Additionally, the IGP requires dischargers to submit and certify all reports electronically. Annual reports, site maps, and Storm Water Pollution Prevention Plans will be publicly available.
Further, the new general permit requires minimum best management practices (BMPs), while the previous IGP only suggested them. These minimum BMPs include good housekeeping, preventive maintenance, spill and leak prevention and response, material handling and waste management, erosion and sediment controls, an employee training program, and quality assurance and record keeping. Advanced BMPs, such as treatment, are suggested and may be necessary if pollutants are present in stormwater discharges. Additionally, plastics facilities must establish BMPs for preproduction.
Further, the IGP now requires four annual stormwater effluent sampling events during which samples are collected from each drainage area onsite. This is compared to the two sampling events required under the previous permit. Permittees must also conduct visual observations monthly during dry weather and during each of the four sampling events.
Finally, SWRCB has established Numeric Action Levels — if water quality parameters in samples exceed these levels, permitees must implement a response action plan. In the case of an exceedance, a Qualified Industrial Storm Water Practitioner would create a technical report to evaluate the site’s stormwater controls. Qualified Industrial Storm Water Practitioners are required during the first permit year only for new permittees that discharge directly to impaired receiving water bodies or for those facilities that exceed Numeric Action Levels and are placed into Exceedance Response Action Level 1.