Page 133 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

Water Code section 13383.5 requires that the State Water Board include (1)
standardized methods for collection of storm water samples, (2) standardized
methods for analysis of storm water samples, (3) a requirement that every
sample analysis be completed by a State certified laboratory or in the field in
accordance with Quality Assurance and Quality Control (QA/QC) protocols, (4) a
standardized reporting format, (5) standardized sampling and analysis programs
for QA/QC, and (6) minimum detection limits. The monitoring requirements in
this General Permit (Section XI), as supplemented by SMARTS, address these
requirements.

Under the previous permit, many Dischargers did not developed adequate
sample collection and handling procedures, decreasing the quality of analytical
results. In addition, Dischargers often selected inappropriate test methods,
method detection limits, or reporting units. This General Permit requires all
Dischargers to identify discharge locations that are representative of industrial
storm water discharges and develop and implement reasonable sampling
procedures to ensure that samples are not mishandled or contaminated.

It is infeasible for the State Water Board to provide a single comprehensive set of
sample collection and handling procedures/instructions due to the wide variation
in storm water conveyance and collection systems in use at facilities around the
state. As an alternative, Attachment H of this General Permit provides minimum
storm water sample collection and handling instructions that pertain to all
facilities. Dischargers are required to develop facility-specific sample collection
and handling procedures based upon these minimum requirements. Table 2 in
this General Permit provides the minimum test methods that shall be used for a
variety of common pollutants. Dischargers must be aware that use of more
sensitive test methods (e.g., U.S. EPA Method 1631 for Mercury) may be
necessary if they discharge to an impaired water body or are otherwise required
to do so by the Regional Water Board. This General Permit allows Dischargers
to propose an analytical test method for any parameter or pollutant that does not
have an analytical test method specified in Table 2 or in SMARTS. Dischargers
may also propose analytical test methods with substantially similar or more
stringent method detection limits than existing approved analytical test methods.
Upon approval, SMARTS will be updated over time to add additional acceptable
analytical test methods.

The previous permit allowed Dischargers to reduce sampling analysis
requirements for substantially similar drainage areas by either (1) combining
samples for an unspecified maximum number of substantially similar drainage
areas, or (2) sampling a reduced number of substantially similar drainage areas.
The State Water Board provided this procedure to reduce analytical costs. The
complexity associated with determining substantially similar drainage areas has
led Dischargers to produce various, and sometimes questionable, analytical
schemes. In addition, the previous permit did not establish a maximum number
of samples that could be combined.

To standardize sample collection and analysis as required by Water Code
section 13383.5, while continuing to offer a reduced analytic cost option, these

Order 2014-0057-DWQ 49