OTC 216 – Industrial Stormwater General Permit Workshop
The California State Water Resources Control Board has issued revisions to the 2012 Third Draft NPDES Industrial General Permit (IGP). This draft permit and related documents became available for public viewing on 7/18/2012. Similar to the Construction General Permit (CGP), the IGP requires dischargers to comply with minimum technology-based effluent limitations (referred to as “BCT/BAT”), plus additional stringent limitations necessary to meet local water quality standards (WQS).
Dischargers must monitor runoff and compare the results to benchmark concentrations or numeric action levels (NAL), but not Numeric Effluent Limits (NEL). Most of the NALs are derived from USEPA’s 2008 Multi Sector General Permit (2008 MSGP). Exceedances trigger Exceedance Response Action (ERAs). The permit includes two levels of ERAs which are similar to the 3 levels of Corrective Actions in the 2011 draft IGP. Facilities must install additional structural/treatment control BMPs if NALs are exceeded and it is determined that the facility is not implementing BCT/BAT. A new “Compliance Group” concept replaces the group monitoring option from the 2011 draft. Qualified Industrial Storm Water Practitioners (QISP) would lead the Groups and also have many other mandated responsibilities. This workshop is designed to assist those interested with understanding how they are affected and the major changes proposed.