Page 5 - California Stormwater Workshop Handouts

• CWA Section 303(d) Impairment – Additional analytical monitoring is required if a facility discharges
stormwater water to receiving waters listed as impaired for specific pollutants listed in the CWA section 303d.

• Design Storm Standards for Treatment Control BMPs – Design parameters are provided for both volume
and flow based criteria for facilities that have/require treatment control BMPs. This change eliminates the
guess work, liability, and cost for over or under designed treatment systems that frequently impacted facilities
under the previous permit. Existing BMP controls do not need to be retrofitted unless required to meet
the NALs.

• Qualifying Storm Event (QSE) – A QSE produces a discharge for a drainage area and is preceded by 48 hours
with no discharge from a drainage area. The new definition will increase the number of rain events requiring
sampling.

• Sampling Protocols – Basically, this change increases the time to collect samples from a QSE from 1 hour
(under the previous permit) to 4 hours. This change will increase the number of QSEs and potentially
reduce the number of NALs due to a short spike in influent concentrations associated with the first
hour of rain.

• Sampling Frequency – The new permit divides the year into two periods: July - December (Period 1) and
from January – June (Period 2). Each period requires two sampling events from QSEs. This will increase the
number of possible QSEs eligible for monitoring.

• Compliance Groups – Compliance groups can be formed with in an industry group to satisfy permit
requirements. This will likely have limited impact over concerns with implementation details and potential
negative impacts to an individual facility from other facilities within the group.

• Ocean Dischargers – Facilities with ocean-discharging outfalls subject to the California Ocean Plan (COP) are
required to develop a monitoring plan in compliance with the provisions of the COP along with additional
provisions of the Water Code. Non-compliance with the monitoring program by January 1, 2015 are ineligible to
obtain coverage under the IGP and cannot discharge stormwater.

RECOMMENDED ACTIONS PRIOR TO JULY 2015

• Identify your QISP. A QISP can be on staff or Trihydro but additional training requirements will apply.
• EVALUATE NOW – are you a Baseline facility or a Level 1, or Level 2 reporting facility? There are steps that

can be taken now to remain Baseline compliant – the more economical, less restrictive status.
• Update Stormwater Pollution and Prevention Plan (SWPPP) with New Permit requirements for BMPs,

QSEs, and Sample Frequency.
• Train facility personnel on the new SWPPP actions.
• Evaluate your structural BMPs to remain in Baseline compliance – this could significantly reduce costs

and regulatory interaction by employing simple effective BMPs to reduce effluent issues. This is a long-lead
time item and should not be left until next spring.
• Prepare for a rainy season – though we are in an epic drought, compliance is still required. We don’t know
how much rain will come but better to be prepared now.