1. 2014 Industrial General Permit Summary of Key Updates Order 2014-0057-DWQ Sandy Mathews August 19, 2014

2. Stormwater Permits Municipal MS4s Industrial IGP Construction CGP 2

3. IGP History in California 1991 – 1 st Generation IGP1997 – 2 nd Generation IGP2014 – 5 th Generation IGP 3

4. Basic Facts & Information Order 2014-0057-DWQ http://www.waterboards.ca.gov/water_issues/programs/ stormwater/industrial.shtml Adopted: April 1, 2014 Effective: July 1, 2015 Two types of coverage + non-applicability NOI – Notice of Intent File by July 1, 2015, or when operations commence NEC – No Exposure Certification File by October 1, 2015 NONA – Notice of Non-Applicability 4 Not a typo

5. Facilities required to file for coverage Facilities subject to storm water ELGs, NSPS, or toxic pollutant effluent standards Cement Manufacturing Manufacturing Oil and Gas/Mining Hazardous Waste Treatment, Storage, or Disposal Landfills, Land Application Sites, and Open Dumps Recycling Facilities Steam Electric Power Generating Transportation Sewage or Wastewater Treatment Works 5

6. Facilities used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including land dedicated to the disposal of sewage sludge, that are located within the confines of the facility, with a design flow of one million gallons per day or more, or required to have an approved pretreatment program under 40 Code of Federal Regulations part 403. 6 Note: In Region 2, the Regional Water Board typically requires smaller plants to develop SWPPPs through the wastewater NPDES Permits.

7. What to changes to look for Electronic filing and reporting Minimum Best Management Practices (BMPs) More frequent sampling and inspections Numeric Action Levels (NALs) Exceedance Response Actions (ERAs) Qualified Industrial SWPPP Practitioners (QISP) TMDLs & other requirements More acronyms than ever before 7

8. Electronic filing and reporting NOIs, SWPPPs, Annual Reports, monitoring data are entered into SMARTS No more paper reports Visual observations: document observations and report in annual report Effluent sampling: data must be submitted into SMARTS within 30 days of obtaining results Annual reports are due by July 15 8 SMARTS – Stormwater Multiple Application and Report Tracking System

9. Minimum BMPs – No surprises but they are now all required Good Housekeeping Preventative Maintenance Spill & Leak Prevention & Response Material & Waste Management Erosion & Sediment Control Employee Training Quality Assurance & Quality Control 9 Pay attention to the details in the sub-bullet in the permit, they are all part of the minimum required BMPs. If you cannot conform to the requirements must be justified in the SWPPP.

10. Key monitoring elements remain similar Visual observations Effluent sampling 10 But there will be changes …

11. Monitoring program designed around drainage areas Observations and sampling are based on industrial activity drainage areas Key Definition Drainage Area The area of land that drains water, sediment, pollutants, and dissolved materials to a common discharge location. 11

12. Required monitoring Type of Monitoring FrequencyObjective Visual Observations MonthlyFacility operations, BMPs, non- stormwater discharges, unaddressed potential pollutants Storm Event Discharge Observations During sampling events Stormwater discharges, presences/absence of visual pollutants, sources of pollutants Sampling and Analysis 4 events per year: 2 in Jul-Dec, and 2 in Jan-Jun Sample each discharge point during a qualified storm event Comprehensive Facility Evaluation AnnualAssess effectiveness of SWPPP 12

13. 13 Key Definition Qualified Storm Event Produces discharge from at least one drainage area, and is preceded by at least 48 hours with no discharge from any drainage area.

14. Required water quality monitoring parameters WhoParameter All PermitteespH, TSS, O&G All PermitteesPollutants identified in your source assessment IGP SIC CodeIGP Table 1 Facilities discharging to waters with 303(d) listings or TMDLs If the industrial activities are potential sources of the impairing pollutant 14

15. Numeric Action Levels 15 ParameterAnnual NALInstantaneous Maximum NAL NAL Exceedance Criteria  Average of all results in a reporting year exceed value 2 or more results in a reporting year exceed value pHNA 9.0 std. units TSS100 mg/L400 mg/L Oil & Grease15 mg/L 25 mg/L See IGP for the complete list of NALs Exceeding NALs trigger a series of evaluations and actions – ERA Exceeding NALs is not a permit violation! Not doing the ERA is a permit violation

16. Baseline Status (all facilities start here) Level 2 Status Trigger After completing ERA Actions and 4 consecutive QSEs sampled with no NAL exceedances return to Baseline Status NALs Level 1 Status NALs Original Graphic Credit: SWRCB NAL exceedances trigger action Trigger Sampling Evaluate results for each parameter If NAL is exceeded, initiate required ERAs ERA Status Level updates July 1 regardless of when the exceedance occurred

17. ERA requirements ERA Level 1 Get QISP to assist with ERA actions Write ERA Level 1 Report Implement actions BMPs, SWPPP update Continue implementing SWPPP and monitoring ERA Level 2 Get QISP to assist with ERA actions Develop and submit ERA Level 2 Action Plan Prepare and submit ERA Level 2 Demonstration Technical Report Continue implementing SWPPP and monitoring 17 QISP – Qualified SWPPP Practitioner

18. Other requirements: TMDLs, ASBS, Trash… Dischargers to the Ocean and Areas of Special Biological Significance have additional requirements, especially monitoring TMDLs are being incorporated into the permit through a reopener process Each Region will propose and notice requirements State will add to IGP in early 2016 Trash Amendments will be incorporated into the IGP after they are adopted by the State Board 18

19. What to do before July 1, 2015 … Don’t panic, but don’t wait Assess monitoring data NAL exceedances? Can you make corrections now? Assess SWPPP does it address the minimum BMPs? Plan for SWPPP update Look for updated Industrial BMP handbook from CASQA Look for QISP training from State Board/CASQA Stayed tuned for more info fro the State Board 19

20. 20 Sandy Mathews Larry Walker Associates 510-625-1580 sandym@LWA.com

21. 21 See IGP Factsheet 45