2014 Industrial General Permit Summary of Key Updates Order 2014-0057-DWQ

1. 2014 Industrial General Permit Summary of Key UpdatesOrder 2014-0057-DWQ Sandy MathewsAugust 19, 2014

3. IGP History in California

4. 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-Applicability Not a typo

5. 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

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

7. 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

8. Electronic filing and reporting • NOIs, SWPPPs, Annual Reports, monitoring data are entered into SMARTS • No 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 SMARTS – Stormwater Multiple Application and Report Tracking System

9. 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 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.

10. Key monitoring elements remain similar • Visual observations • Effluent sampling But there will be changes …

11. 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.

12. Required monitoring

13. Key Definition Qualified 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.

14. Required water quality monitoring parameters

15. Numeric Action Levels • 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

16. NAL exceedances trigger action Baseline Status (all facilities start here) • Evaluate results for each parameter • If NAL is exceeded, initiate required ERAs • ERA Status Level updates July 1 regardless of when the exceedance occurred Trigger Sampling NALs Level 1 Status Trigger Sampling NALs Level 2 Status After completing ERA Actions and 4 consecutive QSEs sampled with no NAL exceedances return to Baseline Status Trigger Original Graphic Credit: SWRCB

17. ERA requirements ERA Level 1 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 • Get QISP to assist with ERA actions • Write ERA Level 1 Report • Implement actions • BMPs, SWPPP update • Continue implementing SWPPP and monitoring QISP – Qualified SWPPP Practitioner

18. 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 process • Each Region will propose and notice requirements • State will add to IGP in early 2016 • Trash Amendments will be incorporated into the IGP after they are adopted by the State Board

19. 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

20. Sandy Mathews Larry Walker Associates 510-625-1580 sandym@LWA.com

21. See IGP Factsheet 45