Page 88 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

 In all cases, Dischargers should implement a suite of minimum BMPs,
including, but not limited to, good housekeeping practices, employee training,
and preventing exposure of materials to rain.

 Standard Industrial Classification (SIC) code categories are not a satisfactory
way of identifying industrial activities at any given site. The State Water
Board should develop an improved method of characterizing industrial
activities that will improve water quality in storm water.

 Recognizing that implementing the Panel’s suggested changes is a large
task, the State Water Board should set priorities for implementation of the
Panel’s suggested approach in order to achieve the greatest reduction of
pollutants statewide.

 Recognizing that an increasing number of industries have moved industrial
activities indoors to prevent storm water pollution, such facilities should be
granted regulatory relief from NALs and/or NELs , but should still be required
to comply with any applicable MS4 permit requirements.

 Recognizing the need for improved monitoring and reduction of pollutants in
industrial storm water discharges, the State Water Board should consider the
total economic impact of its requirements to not economically penalize
California industries when compared to industries outside of California.

With regard to the industrial activities component of its charge, the Panel limited its
focus to the question of whether sampling data can be used to derive technology-based
NELs. The Panel did not address other factors or approaches that may relate to the
task of determining technology- and water quality-based NELs consistent with the
regulations and law. Examples of these other factors are discussed in more detail in
this Fact Sheet. Additionally, in its final report the Panel did not clearly differentiate
between the role of numeric and non-numeric effluent limitations, nor did it consider
U.S. EPA procedures used to promulgate effluent limitation guidelines (ELGs) in 40
Code of Federal Regulations, Chapter I, Subchapter N (Subchapter N).

D. Summary of Significant Changes in this General Permit

The previous permit issued by the State Water Board on April 17, 1997, had been
administratively extended since 2002 until the adoption of this General Permit.
Significant revisions to the previous permit were necessary to update permit
requirements consistent with recent regulatory changes pertaining to industrial storm
water under the CWA. This General Permit differs from the previous permit in the
following areas:

1. Minimum Best Management Practices (BMPs)

This General Permit requires Dischargers to implement a set of minimum BMPs.
Implementation of the minimum BMPs, in combination with any advanced BMPs
(BMPs, collectively,) necessary to reduce or prevent pollutants in industrial storm
water discharges, serve as the basis for compliance with this General Permit’s

Order 2014-0057-DWQ 4