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2014 Industrial General Permit Summary of Key UpdatesOrder 2014-0057-DWQ
Sandy MathewsAugust 19, 2014
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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