Page 90 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

addition, if a Discharger’s facility enters Level 1 status, the Level 1 ERA Report must
be prepared by a Qualified Industrial Storm Water Practitioner (QISP). All Action
Plans and Technical Reports required in Level 2 status must also be prepared by a
QISP.

Dischargers may appoint a staff person to complete the QISP training or may
contract with an outside QISP. QISP training is tailored to persons with a high
degree of technical knowledge and environmental experience. Although QISPs do
not need to be California licensed professional engineers, it may be necessary to
involve a California licensed professional engineer to perform certain aspects of the
Technical Reports.

5. Numeric Action Levels (NALs) and NAL Exceedances

This General Permit contains two types of NAL exceedances. An annual NAL
exceedance occurs when the average of all sampling results within a reporting year
for a single parameter (except pH) exceeds the applicable annual NAL. The annual
NALs are derived from, and function similarly to, the benchmark values provided in
the 2008 MSGP. Instantaneous maximum NALs target hot spots or episodic
discharges of pollutants. An instantaneous maximum NAL exceedance occurs when
two or more analytical results from samples taken for any parameter within a
reporting year exceed the applicable instantaneous maximum NAL value.
Instantaneous maximum NALs for Total Suspended Solids (TSS) and Oil and
Grease (O&G) are based on previously gathered California industrial storm water
discharge monitoring data. The instantaneous maximum NAL for pH is derived from
the benchmark value provided in the 2008 MSGP.

6. Exceedance Response Actions (ERA)

This General Permit requires Dischargers to develop and implement ERAs, when an
annual NAL or instantaneous maximum NAL exceedance occurs during a reporting
year. The first time an annual NAL or instantaneous maximum NAL exceedance
occurs for any one parameter, a Discharger’s status is changed from Baseline to
Level 1 status, and the Discharger is required to evaluate and revise, as necessary,
its BMPs (with the assistance of a QISP) and submit a report prepared by a QISP.
The second time an annual NAL or instantaneous maximum NAL exceedance
occurs for the same parameter in a subsequent reporting year, the Discharger’s
status is changed from Level 1 to Level 2 status, and Dischargers are required to
submit a Level 2 ERA Action Plan and a Level 2 ERA Technical Report. Unless the
demonstration is not accepted by the State Water Board or a Regional Water Board,
the Discharger is not required to perform additional ERA requirements for the
parameter(s) involved if the Discharger demonstrates that:

a. Additional BMPs required to eliminate NAL exceedances are not technologically
available or economically practicable and achievable; or,

b. NAL exceedances are solely caused by non-industrial pollutant sources; or,

Order 2014-0057-DWQ 6