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Industrial General Permit Order

         BMPs being implemented to ensure they are adequate to achieve compliance
         with this General Permit.

    65. U.S. EPA regulations at Subchapter N establish ELGs for storm water
         discharges from facilities in 11 industrial categories. Dischargers subject to
         these ELGs are required to comply with the applicable requirements.

    66. Exceedances of the NALs that are attributable solely to pollutants originating
         from non-industrial pollutant sources (such as run-on from adjacent facilities,
         non-industrial portions of the Discharger’s property, or aerial deposition) are
         not a violation of this General Permit because the NALs are designed to
         provide feedback on industrial sources of pollutants. Dischargers may submit
         a Non-Industrial Source Pollutant Demonstration as part of their Level 2 ERA
         Technical Report to demonstrate that the presence of a pollutant causing an
         NAL exceedance is attributable solely to pollutants originating from non-
         industrial pollutant sources.

    67. A Discharger who has designed, installed, and implemented BMPs to reduce
         or prevent pollutants in industrial storm water discharges in compliance with
         this General Permit may submit an Industrial Activity BMPs Demonstration, as
         part of their Level 2 ERA Technical Report.

    68. This General Permit establishes design storm standards for all treatment
         control BMPs. These design standards are directly based on the standards in
         State Water Board Order 2000-0011 regarding Standard Urban Storm Water
         Mitigation Plans (SUSMPs). These design standards are generally expected
         to be consistent with BAT/BCT, to be protective of water quality, and to be
         effective for most pollutants. The standards are intended to eliminate the
         need for most Dischargers to further treat/control industrial storm water
         discharges that are unlikely to contain pollutant loadings that exceed the
         NALs set forth in this General Permit.

N. Compliance Groups

    69. Compliance Groups are groups of Dischargers (Compliance Group
         Participants) that share common types of pollutant sources and industrial
         activity characteristics. Compliance Groups provide an opportunity for the
         Compliance Group Participants to combine resources and develop
         consolidated Level 1 ERA Reports for Level 1 NAL exceedances and
         appropriate BMPs for implementation in response to Level 2 status ERA
         requirements that are representative of the entire Compliance Group.
         Compliance Groups also provide the Water Boards and the public with
         valuable information as to how industrial storm water discharges are affected
         by non-industrial background pollutant sources (including natural background)
         and geographic locations. When developing the next reissuance of this
         General Permit, the State Water Board expects to have a better
         understanding of the feasibility and benefits of sector-specific and watershed-
         based permitting alternatives, which may include technology- or water quality-
         based numeric effluent limitations. The effluent data, BMP performance data

Order 2014-0057-DWQ  12
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