Page 4 - California Stormwater Workshop Handouts

SIGNIFICANT CHANGES TO THE
INDUSTRIAL STORMWATER PERMIT

The Storm Water Resources Control Board (SWRCB) documents 13 significant changes in the new Industrial
Stormwater General Permit (IGP), Trihydro has emphasized those changes that are likely the least understood or
expected to have the largest financial impact to a facility:
• Minimum Best Management Practices (BMPs) are specified and required at each facility.
• Conditional Exclusion – No Exposure Certification (NEC) - This Permit implements current EPA Phase II

rules allowing any type of industry to claim conditional exemption while requiring all facilities to complete
annual enrollment for coverage prior to conditionally excluding a discharger from the majority of the permit
requirements. This most likely impacts “light industry” facilities that did not previously have to apply for
exemption.
• Electronic Report Requirements – All dischargers are required to submit and certify all notices and reports
electronically via the SWRCB’s SMARTS online database.
• Training Expectations and Roles – All facilities are required to have appropriately trained personnel on
site or contracted to implement permit requirements such as BMPs, compliance/training documentation,
and sampling. There is a new requirement that a Qualified Stormwater Practioner (QISP) complete Action
Plans and Technical Reports. The QISP is a trained a person with a high degree of technical knowledge and
environmental experience. The SWRCB is currently developing the QISP training and has stated it will roll
out the program in Fall 2015. QISP training is expected to mirror the Qualified Stormwater Developer (QSD)
position defined in the General Construction Permit. This may impact a facility, especially if Numeric Action Levels
are exceeded.
• Numeric Action Levels (NALs) and NAL Exceedances – NALs are established for three parameters: Oil and
Grease (O&G); Total Suspended Solids (TSS), and pH. There are two types of NAL exceedances:

■■ Annual – NALannual – Occurs when the average of the sampling results in a reporting year exceeds
the applicable annual NAL for either TSS or O&G.

■■ Instantaneous maximum – NALmax – Addresses hot spots or episodic discharges and occurs when
2 or more analytical results for a parameter exceed the applicable value in a given reporting year

Parameter Test Method Annual NAL Instaneous Maximum NAL
pH Wide-range litmus Not applicable <6 or >9
paper or equivalent* 400
Total Suspended 100 25
Solids (TSS)+ SM 2540-D 15
Oil & Grease+
EPA 1664A

• Exceedance Response Actions (ERA) – Dischargers are required to develop and implement ERAs when
there is an NAL exceedance. The first exceedance moves the site from the Baseline status to Level 1, an
additional exceedance move the site to Level 2. Level 1 and Level 2 status require discharges to undertake
additional actions with the assistance of a QISP. These additional actions are different for each Level and
become more substantial and costly under Level 2.