Page 104 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

The State Water Board does not have the information (including monitoring data,
industry specific information, BMP performance analyses, water quality information,
monitoring guidelines, and information on costs and overall effectiveness of control
technologies) necessary to promulgate NELs at the time of adoption of this General
Permit. Therefore, it is infeasible to include NELs in this statewide General Permit.

Many of the new requirements in this General Permit have been designed to
address the shortcomings of previous permits and the existing storm water data set.
Under this General Permit, sampling results must be certified and submitted into
SMARTS by Dischargers, along with SWPPPs which outline the technologies and
BMPs used to control pollutants at each facility. The ERA process will also collect
information on costs and the engineering aspects of the various control technologies
employed by each facility. Previous permit versions did not have a mechanism for
receiving this site specific information electronically, and only a small percentage of
Dischargers submitted their Annual Reports via SMARTS. This General Permit will
make this information more accessible, allowing the Water Boards to evaluate the
relationship between BMPs and the ability of facilities to meet the NALs set forth in
this General Permit. Finally, the new Qualified Industrial Storm Water Practitioner
(QISP) training requirements of this General Permit have been designed in part to
improve the quality of the data submitted.

5. Narrative Technology-Based Effluent Limitations (TBELs) and Best Management
Practices (BMPs)

The primary TBEL in this General Permit requires Dischargers to “implement BMPs
that comply with the BAT/BCT requirements of this General Permit to reduce or
prevent discharges of pollutants in their storm water discharge in a manner that
reflects best industry practice considering technological availability and economic
practicability and achievability.” (Section V.A of this General Permit). This TBEL is
a restatement of the BAT/BCT standard, as articulated by U.S. EPA in the 2008
MSGP and accompanying Fact Sheet. In order to comply with this TBEL,
Dischargers must implement BMPs that meet or exceed the BAT/BCT technology-
based standard. The requirement to “reduce or prevent” is equivalent to the
requirement in the federal regulations that BMPs be used in lieu of NELs to “control
or abate” the discharge of pollutants. (40 C.F.R. § 122.44(k).)

BMPs are defined as the “scheduling of activities, prohibitions of practices,
maintenance procedures, and other management practices to reduce or prevent the
discharge of pollutants… includ[ing] treatment requirements, operating procedures,
and practices to control site runoff, spillage or leaks, sludge or waste disposal, or
drainage from raw material storage.” (40 C.F.R. § 122.2.)

This General Permit (Sections X.H.1 and X.H.2) requires all Dischargers to
implement minimum BMPs, as well as any advanced BMPs that are necessary to
adequately reduce or prevent pollutants in discharges consistent with the TBELs.
The minimum BMPs specified in this General Permit represent common practices
that can be implemented by most facilities. This General Permit generally does not
mandate the specific mode of design, installation or implementation for the minimum
BMPs at a Discharger’s facility. It is up to the Discharger, in the first instance, to

Order 2014-0057-DWQ 20