Author: Chelsea Meddings, Project Scientist
As you may know, in 2018, the California State Water Resources Control Board amended the National Pollutant Discharge Elimination System (NPDES) Stormwater Industrial General Permit (IGP) Order 2014-0057-DWQ, with new regulations becoming effective in July 2020. Now moving into 2022, our industrial stormwater professionals would like to help support facilities that have found these regulations challenging. If your facility is out of compliance with the IGP regulations, or if you require support interpreting these regulations, we hope this information will be valuable in helping you successfully navigate the changes.
What’s Changed in the Statewide Industrial Stormwater General Permit?
The 2018 IGP amendment redefined analytical methods required for annual stormwater sampling. Analytical methods are now required to be sufficiently sensitive to detect and quantify pollutants at or below the applicable water quality criteria, action levels, or effluent limitations designated in the NPDES permit.
Additionally, the 2018 IGP amendment redefined sampling requirements for facilities where stormwater runoff discharges into an already impaired waterbody. Facility operators are now required to collect industrial stormwater samples for total maximum daily load (TMDL)-related pollutants and comply with applicable requirements. This specifically applies to facilities where stormwater or authorized non-stormwater discharges go through a separate municipal storm sewer system to impaired waterbodies, and where the discharge contains TMDL-related pollutants associated with the impaired receiving waterbody.
How Does Your Facility Comply with the Regulatory Amendments?
Our professionals have provided steps below to help you maintain compliance with the IGP regulations based on 2018 amendments.
- Conduct a Potential Pollutant Assessment to determine if your facility is sampling and analyzing for the correct constituents of concern.
- Identify the most efficient stormwater sampling locations and strategy to satisfy the NPDES permit.
- Mitigate potential stormwater exposure and constituents of concern through best management practices (BMPs).
How a Qualified Industrial Stormwater Professional (QISP) Can Help?
If your facility conducts of stormwater sampling and analysis internally, but you are having trouble staying in compliance, a QISP can help guide your facility to compliance. When hiring a QISP, you can expect the following:
- Ensure accurate and timely submittal of your facility sample results to the SMARTS website.
- Determine if your facility laboratory is using the correct analytical methods for stormwater sampling.
- Confirm your facility is sampling stormwater for the correct constituents of concern.
- Prepare Ad Hoc reports presenting analytical laboratory report data.
- Evaluate BMPs and implement an effective strategy to mitigate constituents of concern in analytical sample results.
- Conduct facility inspections within the required timeline (typically on a monthly basis).
- Collect stormwater samples in compliance with new Statewide Industrial Stormwater General Permit guidelines.
We hope that you have a better awareness of your facility’s industrial stormwater compliance considering the IGP 2018 amendment. Wherever your facility stands, we want you to feel confident about your options and next best steps. If you have any questions, please don’t hesitate to reach out to our certified industrial stormwater professionals.
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