Page 153 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

not categorized as acid rain as referred to by the U.S. EPA for the NEC coverage
requirements. The No Exposure Guidance Document15 developed by the U.S. EPA
mentions acid rain as a potential source of contaminants to consider for NEC coverage.
The acid rain leachate language was not included in this General Permit’s Appendix 2 to
clarify that Dischargers may qualify for NEC coverage, even if the facility has metal
buildings or structures.

The Discharger shall certify and submit complete PRDs for NEC coverage via
SMARTS. Based upon the State Water Board’s experience with reissuing and
implementing the 2009 Construction General Permit, the transition for existing
Dischargers to register under this new General Permit is staff resource intensive. The
State Water Board staff is available to assist Dischargers requiring assistance with
enrolling under this General Permit, both for NOI coverage and NEC coverage. The
State Water Board has also experienced that more time is needed for its staff to assist
Dischargers registering for NEC coverage. To provide better customer service to all
Dischargers, three months have been added to the NEC coverage PRD submittal
schedule for new and existing Dischargers (Section II.B.4 of this General Permit,
extending the NEC coverage registration date to October 1, 2015.

Dischargers must annually inspect their facility to ensure continued compliance with
NEC requirements, and annually re-certify and submit an NEC via SMARTS. Based on
its regulatory experience, the State Water Board has determined that a five-year NEC
re-certification period is inadequate. A significant percentage of facilities may revise,
expand, or relocate their operations in any given year. Furthermore, a significant
percentage of facilities experience turnover of staff knowledgeable of the NEC
requirements and limitations. Accordingly, the State Water Board believes that annual
NEC evaluation and re-certification requirements are appropriate to continually assure
adequate program compliance.

Q. Special Requirements - Plastic Materials

Water Code section 13367 requires the Water Boards to implement measures that
control discharges of preproduction plastic from point and nonpoint sources. The State
Water Board intends to use this General Permit to regulate discharges of preproduction
plastics from areas of facilities that are subject to this General Permit. A Regional
Water Board may designate facilities, or areas of facilities, that are not otherwise
subject to this General Permit, pursuant to Section XIX.F. For example, a Regional
Water Board may designate Plastic Materials handling areas of a transportation facility
that are not associated with vehicle maintenance as requiring coverage under this
General Permit.

Preproduction plastics used by the plastic manufacturing industry are small in size and
have the potential to mobilize in storm water. Preproduction plastic washed into storm
water drains can move to waters of the United States where it contributes to the growing
problem of plastic debris in inland and coastal waters. Water Code section 13367

15 U.S. EPA. Guidance Manual for Conditional Exclusion from Storm Water Permitting Based On “No Exposure” of Industrial
Activities to Storm Water. Web. June 2000. < http://www.epa.gov/npdes/pubs/noxguide.pdf>. [as of January 31, 2014].

Order 2014-0057-DWQ 69