Page 151 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

allows Dischargers of the same industry type to comply with this General Permit through
shared resources in a cost saving manner.

This General Permit emphasizes sampling and analysis as a means to evaluate BMP
performance and overall compliance, and the significantly reduced sampling
requirements previously afforded to Group Monitoring Participants (two samples within
a five-year period) does not provide the necessary information to achieve these goals.
However, a moderate reduction in sampling requirements is included as an incentive for
Compliance Group Participants while concurrently requiring sufficient individual facility
sampling data to determine compliance. A Compliance Group Leader is required to
provide the necessary sampling training and guidance to the Compliance Group
Participants. This additional training requirement will increase sampling data quality
that will offset the reduced sampling frequency for Compliance Groups.

Participation in Compliance Groups will provide additional cost savings for Dischargers
in the preparation of the Consolidated Level 1 ERA Reports, and for Compliance Group
Leader assistance in preparing the Level 2 ERA Action Plans and the individual Level 2
ERA Technical Reports. It is likely that many of the pollutant sources causing NAL
exceedances, and the corresponding BMP cost evaluation and selection, when
appropriate, will overlap for groups of facilities in a similar industry type. When these
overlaps occur, a Compliance Group Leader should be able to more efficiently evaluate
the pollutant sources and BMP options, and prepare the necessary reports.

The State Water Board believes that it is necessary for Compliance Group Leaders to
have a higher level of industrial storm water compliance and training experience than
the expectations of a QISP. Many stakeholder comments on this General Permit
suggested various certifications to provide this higher level of experience; however, the
State Water Board believes a process similar to the Trainer of Record process for the
Construction General Permit training program will develop Compliance Group Leaders
with the appropriate level of experience to fulfill the necessary qualifications.

The intent of the Compliance Groups is to have only one or a small number of
Compliance Groups per industrial sector. The process for becoming a QISP trainer
and/or a Compliance Group Leader is purposely similar to the Construction General
Permit trainer of record process for consistency within storm water regulatory leaders.
The formal process to qualify to conduct trainings for QISPs and/or to be a Compliance
Group Leader will include the submittal of a statement of qualifications for review, a
review fee, completion of an exam and training specific to this role. For more
information see the Construction General Permit trainer of record process:
http://www.casqa.org/TrainingandEducation/ConstructionGeneralPermitTrainingQSDQS
PToR/tabid/205/Default.aspx

After the initial Compliance Group registration, Compliance Group Leaders are required
to submit and maintain their list of Compliance Group Participants via SMARTS. There
are no additional administrative documents required. The previous permit required
group leaders to provide annual group evaluation reports and a letter of intent to
continue group monitoring. The State Water Board found these items to be resource
intensive and placed an unnecessary administrative burden on group leaders. The

Order 2014-0057-DWQ 67