Page 105 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

determine what must be done to meet the applicable effluent limits. For example,
Section X.H.1.a.vi of this General Permit requires Dischargers to contain all stored
non-solid industrial materials that can be transported or dispersed via wind or
contact with storm water. How this is achieved will vary by facility: for some
facilities, all activities may be moved indoors, while for others this will not be
feasible. However, even for the latter, many activities may be moved indoors, others
may be contained using tarps or a containment system, while still other activities
may be limited to times when exposure to precipitation is not likely. Each of these
control measures is acceptable and appropriate depending upon the facility-specific
circumstances.

BMPs can be actions (including processes, procedures, schedules of activities,
prohibitions on practices and other management practices), or structural or installed
devices to reduce or prevent water pollution. (40 C.F.R. § 122.2.) They can be just
about anything that is effective at preventing pollutants from entering the
environment, and for meeting applicable limits of this General Permit. In this
General Permit, Dischargers are required to select, design, install, and implement
facility-specific control measures to meet these limits. Many industrial facilities
already have such control measures in place for product loss prevention, accident
and fire prevention, worker health and safety or to comply with other environmental
regulations. Dischargers must tailor the BMPs detailed in this General Permit to
their facilities, as well as improve upon them as necessary to meet permit limits.
The examples detailed in this Fact Sheet emphasize prevention over treatment.
However, sometimes more traditional end-of-pipe treatment may be necessary,
particularly where a facility might otherwise cause or contribute to an exceedance of
water quality standards.

This General Permit requires Dischargers to implement BMPs “to the extent
feasible.” Consistent with the control level requirements of the CWA, for the
purposes of this General Permit, the requirement to implement BMPs “to the extent
feasible” means to reduce and/or prevent discharges of pollutants using BMPs that
represent BAT and BPT in light of best industry practice. 4 In other words,
Dischargers are required to select, design, install and implement BMPs that reduce
or prevent discharges of pollutants in their storm water discharge in a manner that
reflects best industry practice considering their technological availability and
economic practicability and achievability.

To determine technological availability and economic practicability and achievability,
Dischargers need to consider what control measures are considered “best” for their
industry, and then select and design control measures for their site that are viable in
terms of cost and technology. The State Water Board believes that for many
facilities minimization of pollutants in storm water discharges can be achieved
without using highly engineered, complex treatment systems. The BMPs included in

4 Because toxic and nonconventional pollutants are controlled in the first step by BPT and in the second step by BAT, and the
second level of control is “increasingly stringent” (EPA v. National Crushed Stone, 449 U.S. 64, 69 (1980), for simplicity of
discussion, the rest of this discussion will focus on BAT. Similarly, because the BAT levels of control in this General Permit are
expressed as BMPs and pollution prevention measures, they will also control conventional pollutants. Therefore this
discussion will focus on BAT rather than BCT or BPT for conventional pollutants.

Order 2014-0057-DWQ 21