Page 148 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

If an Industrial Activity BMPs Demonstration is submitted as the Level 2 ERA
Technical Report and the Discharger is able to show reductions in pollutant
concentrations below the NALs for four (4) subsequent consecutive QSEs,
the Discharger returns to Baseline Status. A Discharger that submits an
Industrial Activity BMPs Demonstration but has not installed additional BMPs
that are expected to eliminate future NAL exceedance(s) will remain with
Level 2 status but is not subject to additional ERAs unless directed by the
Regional Water Board.

ii. Non-Industrial Pollutant Source Demonstration

A Non-Industrial Pollutant Source Demonstration is for a Discharger to
demonstrate that the pollutants causing the NAL exceedances are not related
to industrial activities conducted at the facility, and additional BMPs at the
facility will not contribute to the reduction of pollutant concentrations.

Dischargers including the Non-Industrial Pollutant Demonstration in their
Level 2 ERA Technical Report shall have a QISP determine that the sources
of non-industrial pollutants in storm water discharges are not from industrial
activity or natural background sources within the facility.

Sources of non-industrial pollutants that are discharged separately and are
not comingled with storm water associated with industrial activity are not
considered subject to this General Permit’s requirements. When pollutants
from non-industrial sources are comingled with storm water associated with
industrial activity, the Discharger is responsible for all the pollutants in the
combined discharge unless the technical report clearly demonstrates that the
NAL exceedances due to the combined discharge are solely attributable to
the non-industrial sources. The pollutant may also be present due to
industrial activities, in which case the Discharger must demonstrate that the
pollutant contribution from the industrial activities by itself does not result in
an NAL exceedance. In most cases, the Non-Industrial Pollutant Source
Demonstration will contain sampling data and analysis distinguishing the
pollutants from non-industrial sources from the pollutants generated by
industrial activity.

Once the Level 2 ERA Technical Report, including this demonstration is
certified and submitted via SMARTS, the Discharger has satisfied all the
requirements necessary for that pollutant for ERA purposes. A Discharger
that submits a Non-Industrial Pollutant Demonstration remains with Level 2
status but is not subject to additional ERAs unless directed by the Regional
Water Board.

iii. Natural Background Pollutant Source Demonstration

The benchmark monitoring schedule in section 6.2.1.2 of the 2008 MSGP
allows a Discharger to determine that the exceedance of the benchmark is
attributable solely to the presence of that pollutant in the natural background.
A Discharger making this determination is not required to perform corrective

Order 2014-0057-DWQ 64