Page 122 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

containers when not in use, clean and manage spills from waste, and observe
outdoor areas and equipment that may come into contact with waste and
become contaminated.

m. Dust Generation and Vehicle Tracking of Industrial Materials

Section 2.1.2.12 of the 2008 MSGP requires that generation of dust and off-site
tracking of raw, final, or waste materials is minimized. This General Permit does
not require minimization of dust generation and vehicle tracking of industrial
materials as a minimum BMP directly. Dust generation and vehicle tracking of
industrial materials BMPs are included in Section X.H.1.a (“good housekeeping”)
of this General Permit where Dischargers must prevent dust generation from
industrial materials or activities and contain all stored non-solid industrial
materials that can be transported or dispersed via wind or come in contact with
storm water, and Section X.H.1.d. (“material handling and waste management”)
of this General Permit, which requires Dischargers to contain non-solid industrial
materials or wastes that can be dispersed via wind erosion or come into contact
with storm water during handling.

n. Quality Assurance and Record Keeping

Section 2.1.2 of the 2008 MSGP does not directly designate record keeping as a
control measure. This General Permit (Section X.H.1.g) includes quality
assurance and record keeping as a minimum BMP and requires Dischargers to
implement three (3) general BMPs. These BMPs include: developing and
implementing procedures to ensure that all elements of the SWPPP are
implemented, develop a method of tracking and recording the implementation of
all BMPs identified in the SWPPP, and a requirement to keep and maintain those
records. This ensures that management procedures are designed and permit
requirements are implemented by appropriate staff.

o. Implementation of BMPs in the SWPPP

Like the previous permit, this General Permit does not assign Dischargers a
schedule to implement BMPs. Instead, this General Permit requires Dischargers
to select the appropriate schedule to implement the minimum BMPs. In addition,
this General Permit requires Dischargers to identify, as necessary, any BMPs
that should be implemented prior to precipitation events. Although Dischargers
are required to maintain internal procedures to ensure the BMPs are
implemented according to schedule or prior to precipitation events, Dischargers
are only required to certify in the Annual Report whether they complied with the
BMP implementation requirements.

Dischargers are required to implement an effective suite of BMPs that meet the
technology and water-quality based limitations of this General Permit. Based
upon Regional Water Board staff inspections, there is significant variation
between Dischargers’ interpretations of what BMPs were necessary to comply
with the previous permit. This General Permit establishes a new requirement
that Dischargers must implement, to the extent feasible, specific minimum BMPs

Order 2014-0057-DWQ 38