If your facility is currently permitted, you have until July 1, 2015 to update its storm water pollution prevention plan.
The IGP permits industries to discharge industrial storm water. There are major changes that will be in effect as of July 1, 2015. So, we have just one year to comply with the new provisions.
Industrial storm water is rain that falls on an industrial facility, makes contact (or has the potential to make contact) with the industrial processes and materials of that facility and then discharges or runs off the facility. If not properly handled on the site, it can contribute to pollution in our waterways, such as the Russian River, Sonoma Creek, Napa Creek, Novato Creek and many others.
If your facility is currently permitted, you have until July 1, 2015 to update its storm water pollution prevention plan (SWPPP—rhymes with “slip”), register and upload your SWPPP to SMARTS (the state online database) and comply with all the changes. If your facility isn’t currently permitted, you’ll need to verify the Standard Industry Code (SIC), also known as the North American Industry Classification System (NAICS), then check your SIC to the IGP listing of 546 SIC classifications ranging from cattle feedlots (SIC 0211) to petroleum bulk stations and terminals (SIC 5171). A facility not permitted will no longer be allowed to ignore the IGP, but must evaluate the facility and determine if a permit is required.
If the permit isn’t required, a Non-Exposure Certificate (NEC) must be filed by October 1, 2015 on SMARTS and annually recertified. The new IGP is intended to have all identified facilities either filing the NOI or NEC. For those currently permitted, the new IGP will go a long way toward leveling the economic playing field for similar industries.
Were there enough acronyms for you? There are many changes, accompanied lots more new acronyms, which I’ll try not to further burden you with. However, you’ll need to know about the major changes. Here are some of them.
1. Sampling frequency changed from two per year to four, but no longer necessary to sample the first storm of the season. Two storms must be sampled between July 1 and December 31 and two others between January 1 and June 30.
2. Separate storm events are now defined if there’s been no discharge for 48 hours.
3. Sampling must occur within four hours of discharge or 12 hours if it occurs after the facility has been closed.
4. Specific conductivity is no longer required to be analyzed.
5. pH must be measured in the field.
6. Monthly “wet” inspections have been replaced with monthly non-storm water discharge inspections.
7. “Wet” discharge observations are now conducted at the time of sampling.
8. Quarterly inspections have been eliminated.
9. Annual reports have been streamlined and will be completed on SMARTS.
10. All sampling data must be uploaded to SMARTS.
11. The annual inspection requirements have been reduced.
12. Three tiers of compliance have been developed: Baseline, Level 1 and Level 2.
13. The tiers are tied to numeric action limits on field measurements and analytical results from a laboratory.
14. A training program is currently being developed to certified Qualified Industrial Storm Water practitioners (QISP—oops, I threw in another acronym). The QISP will assist dischargers in Level 1 and Level 2 when Exceedance Response Actions (plans, evaluations and reports) are required.
15. The QISP will also assist a new discharger whose facility runoff enters an impaired water body.
16. Design storms are now defined.
And there’s more…
So, what’s a non-permitted industrialist to do? First, verify your SIC, then check it against the list on the SWRCB website. If your SIC is on the SWRCB list, you’ll need to evaluate your facility using the new list that has been developed (available within the permit). If appropriate, file the required documents for the NEC on SMARTS and pay the fee. If your facility needs the permit, then a notice of intent (NOI) to comply will have to be filed and a SWPPP prepared. Assistance may be needed, so you might need a QISP if discharging to an impaired water body. Or you can take the training and become certified yourself.
Art Deicke is the owner of Environmental Pollution Solutions, LLC, based in Santa Rosa, and member of CASQA, IGPTT and certified as a CPSWQ, QSP and QSD (www.epsh2o.com). He also chairs the Santa Rosa Chamber of Commerce Land Use Task Force. You can reach him at (707) 322-2015 or aedeicke@epsh2o.com .
