CA IGP Permit Guide
This permit guide serves to explain and clarify many of the confusing aspects within the California Industrial General Permit. Terms are explained and sections of the permit are clarified.
Permit Registration Documents (PRDs)
The California Industrial General Permit (IGP) was revised and went into effect July 1, 2015. The IGP requires that the Discharger certify and submit all Permit Registration Documents (PRDs) for Notice of Intent (NOI) prior to the start of industrial operations and No Exposure Certification (NEC) coverage via the State Water Board’s Storm Water Multiple Application and Report Tracking System (SMARTS) website. The Discharger’s Legally Responsible Person (LRP) of an industrial facility seeking coverage under the General Permit shall certify and submit all PRDs. Dischargers registering for NOI coverage on or after July 1, 2015 shall certify and submit PRDs via SMARTS at least seven (7) days prior to commencement of industrial activities. Dischargers registering for NEC coverage shall electronically certify and submit PRDs via SMARTS at least seven (7) days prior to commencement of industrial activities.
A person, company, agency, or other entity that is the operator of the industrial facility covered by the General Permit.
A collection of industrial processes discharging stormwater associated with industrial activity within the property boundary or operational unit. A list of facility types that have to file for coverage under the IGP is included in Attachment A of the General Permit.
Notice of Intent (NOI)
The PRDs required for NOI coverage are:
1. Notice of Intent (NOI)
The Notice of Intent (NOI) requires the following information:
a. Operator/Owner Information
- Operator/Owner Company or Organization Name
- Contact First Name
- Contact Last Name
- Street Address
- Address Line 2
- Phone (e.g. 999-999-9999)
- E-mail (e.g. email@example.com)
- Federal Tax ID
b. Facility Information
- Facility Name
- WDID Number (if applicable)
- Contact First Name
- Contact Last Name
- Street Address
- Address Line 2
- Phone (e.g. 999-999-9999)
- Emergency Phone (e.g. 999-999-9999)
- E-mail (firstname.lastname@example.org)
- State/Zip CA
- Total Site Size (Acres)
- Latitude (Decimal degrees only, minimum 5 significant digits, e.g. 99.99999)
- Longitude (Decimal degrees only, minimum 5 significant digits, e.g. 99.99999)
- Total Percentage Site Imperviousness Area of Facility (Acres)
- Total Areas of Industrial Activities and Materials Exposed to Precipitation
- Primary SIC Code
- Secondary SIC Code
- Tertiary SIC Code
- Regional Water Board
c. Billing Information
- Billing Name
- Contact First Name
- Contact Last Name
- Street Address
- Address Line 2
- Phone (e.g. 999-999-9999)
- E-mail (e.g. email@example.com)
d. Receiving Water Information
Does your facility's stormwater flow directly or indirectly into waters of the US such as river, lake, ocean, etc. (check box for directly or indirectly)
- Indirectly to waters of the US
- Storm drain system - Enter owner's name:
- Directly to waters of the US (e.g., river, lake, creek, stream, bay, ocean, etc.)
- Name of the receiving water: ____________________________
2. Site Map
3. Storm Water Pollution Prevention Plan
The Storm Water Pollution Prevention Plan (SWPPP) must be prepared in accordance with Section X of the General Permit.
4. A NOI Certification
A NOI Certification by the Discharger that all PRDs submitted are correct and true.
5. Authorization Form
SMARTS Electronic Authorization Form (Signed by any user authorized to certify and submit data electronically).
No Exposure Certification (NEC)
The NEC requires enrollment for coverage prior to conditionally excluding a Discharger from a majority of the General Permit’s requirements. No Exposure means all industrial materials and activities are protected by a storm-resistant shelter to prevent exposure to rain, snow, snowmelt and/or runoff.
Storm-resistant shelters include: (1) completely roofed and walled buildings or structures, (2) structures with only a top cover (no side coverings) supported by permanent supports, provided material within the structure is not subject to wind dispersion (sawdust, powders, etc.) or being tracked out of the facility, and is not a source of pollutants in the industrial stormwater discharges.
A Storm-Resistant Shelter is not required for the following:
- Drums, barrels, tanks, and similar containers that are tightly Sealed, provided those containers are not deteriorated, do not contain residual industrial materials on the outside surfaces, and do not leak;
- Adequately maintained vehicles used in material handling;
- Final products, other than products that would be mobilized in stormwater discharge (e.g., rock salt);
- Any Industrial Materials and Activities that are protected by a temporary shelter for a period of no more than ninety (90) days due to facility construction or remodeling; and,
- Any Industrial Materials and Activities that are protected within a secondary containment structure that will not discharge stormwater to waters of the United States.
A Discharger must electronically certify and submit NEC Permit Registration Documents (PRDs) via State Water Board’s SMARTS to obtain NEC coverage. The following information is required in the PRDs:
A. Discharger Information
- The legal business name of the business entity, public organization, or any other entity that operates the facility described in the certification. The name of the operator may or may not be the same as the name of the facility. The operator is the legal entity that controls the facility operations, not the plant or site manager.
- The mailing address of the facility operator, including the city, state, and zip code.
- The facility operator contact person, telephone number and e-mail address.
B. Facility Information
- The legal business name of the facility.
- The total acreage of the facility associated with industrial activity. (Facility size in acres is calculated by taking the square feet and dividing by 43,560.)
- The complete physical street address (e.g. the street address used for express deliveries), including the city, State, and zip code. Do not use a P.O. Box number. If a physical street address does not exist, describe the location or provide the latitude and longitude of a point within the facility boundary. Latitude and longitude are available from United States Geological Survey quadrangle or topographic maps, or may be found using a mapping site on the internet.
- The facility contact person, telephone number, and email address.
- The 4-digit Standard Industrial Classification (SIC) code that represents the facility primary industrial activity. Provide a brief description of the primary industrial activity. If applicable, enter other significant SIC codes and descriptions.
- If the facility is currently covered under the General Permit, include the WDID number. The WDID number will be used at a later date to terminate the facility’s coverage under the General Permit as necessary.
C. Facility Mailing or Billing Address
Completion of this item is required if the facility mailing address or billing address differs from the physical facility address provided above. The Discharger must indicate which address the annual fee invoice must be sent to if the State Water Board is unable to transmit the invoice electronically.
D. Site Maps
Site maps must be prepared and submitted in accordance with the requirements in Section X.E of the General Permit.
E. NEC Checklist
An NEC Checklist must be prepared by the Discharger demonstrating that:
(1) the facility has been evaluated, (2) none of the following materials or activities are, or will be in the foreseeable future, exposed to precipitation, and (3) all unauthorized NSWDs have been eliminated:
- Using, storing or cleaning industrial machinery or equipment, and areas where residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed;
- Materials or residuals on the ground or in stormwater inlets from spills/leaks;
- Materials or products from past industrial activity;
- Material handling equipment (except adequately maintained vehicles);
- Materials or products during loading/unloading or transporting activities;
- Materials or products stored outdoors (except final products intended for outside use, i.e., new cars, where exposure to stormwater does not result in the discharge of pollutants);
- Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers;
- Materials or products handled/stored on roads or railways owned or maintained by the Discharger;
- Waste material (except waste in covered, nonleaking containers, i.e., dumpsters);
- Application or disposal of processed wastewater (unless already covered by an NPDES permit); and
- Particulate matter or visible deposits of residuals from roof stacks/vents evident in the stormwater outflow.
Federal and state statutes provide for severe penalties for Dischargers that submit false information on the PRDs. Dischargers shall certify and submit PRDs via SMARTS for NEC coverage in accordance with Electronic Signature and Certification Requirements in Section XXI.K of the General Permit.
This conditional exclusion does not become effective until the PRDs are submitted and the annual fee is paid. Upon receipt of the annual fee, the Discharger will electronically receive an NEC acceptance notification via SMARTS, which will include a Waste Discharge Identification (WDID) number. A Discharger must maintain a condition of “No Exposure” at the facility for the conditional exclusion to remain applicable. The Discharger must annually electronically re-certify the NEC via SMARTS to confirm that the conditions of “no exposure” are being maintained.
The Site Map(s) shall include the following Information:
- The facility boundary;
- Stormwater drainage areas within the facility boundary;
- Portions of any drainage area impacted by discharges from surrounding areas and flow direction of each drainage area;
- On-facility surface water bodies;
- Areas of soil erosion;
- Location(s) of nearby water bodies (such as rivers, lakes, wetlands, etc.);
- Location(s) of municipal storm drain inlets that may receive the facility’s industrial stormwater discharges and authorized Non-Storm Water Discharges (NSWDs);
- Locations of stormwater collection and conveyance systems and associated points of discharge, and direction of flow;
- Any structural control measures (that affect industrial stormwater discharges, authorized NSWDs, and run-on);
- All impervious areas of the facility, including paved areas, buildings, covered storage areas, or other roofed structures;
- Locations where materials are directly exposed to precipitation;
- Locations where significant spills or leaks identified (Section X.G.1.d of the General Permit) have occurred;
- Areas of industrial activity subject to the General Permit;
- All storage areas and storage tanks;
- Shipping and receiving areas;
- Fueling areas;
- Vehicle and equipment storage/maintenance areas;
- Material handling and processing areas;
- Waste treatment and disposal areas;
- Dust or particulate generating areas;
- Cleaning and material reuse areas; and,
- Any other areas of industrial activity which may have potential pollutant sources.
Storm Water Multiple Application and Report Tracking System (SMARTS)
SMARTS has been developed to provide an online tool to assist dischargers in submitting their NOIs, NECs, NOTs, and Annual Reports, as well as, viewing/printing Receipt Letters, monitoring the status of submitted documents, and viewing their application/renewal fee statements. The system will also allow the Regional Board and State Board staff to process and track the discharger submitted documents.
Standard Industrial Classification (SIC) Code
The 4-digit Standard Industrial Classification (SIC) codes that represent the facility’s significant industrial activity. To obtain these codes, see the 1987 SIC Manual or the Occupational Health and Safety Administration’s site: http://www.osha.gov/pls/imis/sicsearch.html .
Legally Responsible Person (LRP)
- For a corporation: by a responsible corporate officer. For the purpose of this section, a responsible corporate officer means:
- A president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function; or
- The manager of one or more manufacturing, production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the regulated facility including having the explicit or implicit duty of making major capital investment recommendations, and initiating and directing other comprehensive measures to assure long term environmental compliance with environmental laws and regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.
- For a partnership or sole proprietorship: by a general partner or the proprietor, respectively;
- For a municipality, state, federal, or other public agency: by either a principal executive officer or ranking elected official. This includes the chief executive officer of the agency or the senior executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., Regional Administrators of U.S. EPA).
Notice of Non-Applicability (NONA)
Requirements for Dischargers Claiming “No Discharge” through the NONA:
- For the purpose of the NONA, the Entity (Entities) is referring to the person(s) defined in section 13399.30 of the Water Code.
- Entities who are claiming “No Discharge” through the NONA shall meet the following eligibility requirements:
- The facility is engineered and constructed to have contained the maximum historic precipitation event (or series of events) using the precipitation data collected from the National Oceanic and Atmospheric Agency’s website (or other nearby precipitation data available from other government agencies) so that there will be no discharge of industrial stormwater to waters of the United States; or,
- The facility is located in basins or other physical locations that are not hydrologically connected to waters of the United States.
- When claiming the “No Discharge” option, Entities shall submit and certify via SMARTS both the NONA and a No Discharge Technical Report. The No Discharge Technical Report shall demonstrate the facility meets the eligibility requirements described above.
- The No Discharge Technical Report shall be signed (wet signature and license number) by a California licensed professional engineer.
The “No Discharge” determination does not cover stormwater containment systems that transfer industrial pollutants to groundwater. Entities must determine whether designs that incorporate infiltration may discharge to and contaminate groundwater. If there is a threat to groundwater, Entities must contact the Regional Water Boards prior to construction of infiltration design elements.
A facility from which there is a discharge, that did not commence the discharge at a particular site prior to August 13, 1979, which is not a new source as defined in 40 Code of Federal Regulations 122.29, and which has never received a finally effective NPDES permit for discharges at that site. See 40 Code of Federal Regulations 122.2.
New Dischargers applying for NOI coverage under the General Permit that will be discharging to an impaired water body with a 303(d) listed impairment are ineligible for coverage unless the Discharger submits data and/or information, prepared by a QISP, demonstrating that the facility will not cause or contribute to the impairment.
Qualified Industrial Stormwater Practitioner (QISP)
Only required once a Discharger reaches Level 1 status, a QISP is the individual assigned to ensure compliance with the General Permit or to assist New Dischargers with determining coverage eligibility for discharges to an impaired water body. A QISP’s responsibilities may include assisting with the preparation of the SWPPP, the Annual Comprehensive Facility Compliance Evaluation (Annual Evaluation), Annual Reports, performing ERAs, and training appropriate Pollution Prevention Team members. The individual must take the appropriate state approved or sponsored training to be qualified. Dischargers shall ensure that the designated QISP is geographically located in an area where they will be able to adequately perform the permit requirements at all of the facilities they represent.
Penalties for Violations of Permit Condition
Any person that violates any permit condition of the General Permit is subject to a civil penalty not to exceed $37,500 per calendar day of such violation, as well as any other appropriate sanction provided by section 309 of the Clean Water Act. This may be further adjusted in accordance with the Federal Civil Penalties Inflation Adjustment Act. The Porter-Cologne Water Quality Control Act also provides for civil and criminal penalties, which may be greater than penalties under the Clean Water Act.
The area of land that drains water, sediment, pollutants, and dissolved materials to a common discharge location. Dischargers are required to visually observe and collect samples of industrial stormwater discharges from each drainage area at all discharge locations except as allowed in Section XI.C of the General Permit.
A discharge location is typically the outlet for a drainage area. Each of these locations generally have a sample point unless applying for a reduced number of sample locations.
Dischargers are required to identify, when practicable, alternative discharge locations if: (1) the facility’s industrial drainage areas are affected by stormwater run-on from surrounding areas that cannot be controlled, or (2) discharge locations are difficult to observe or sample (e.g. submerged discharge outlets, dangerous discharge location accessibility).
Waters of the United States
Generally refers to surface waters, as defined for the purposes of the federal Clean Water Act. The determination of what is a water of the United States can be complicated, and in certain circumstances, a discharge to groundwater that has a direct hydrologic connection to waters of the United States may constitute a discharge to a water of the United States.
Receiving Water Body
A receiving water body is typically a Waters of the United States that a facility directly or indirectly discharges to.
Flow of water that occurs overland in areas where there are no defined channels and where the water spreads out over a large area at a uniform depth.
Discharges that originate offsite and flow onto the property of a separate facility or property or, discharges that originate onsite from areas not related to industrial activities and flow onto areas on the property with industrial activity.
Runoff Control BMPs
Measures used to divert run-on from offsite and runoff within the site.
303(d) Impaired Waters
The General Permit requires a Discharger to monitor additional parameters if the discharge(s) from its facility contributes pollutants to receiving waters that are listed as impaired for those pollutants (CWA section 303(d) listings). The General Permit lists the receiving waters that are 303(d) listed as impaired for pollutants that are likely to be associated with industrial stormwater in Appendix 3. For example, if a Discharger discharges to a water body that is listed as impaired for copper, and the discharge(s) from its facility has the potential sources of copper, the Discharger must add copper to the list of parameters to monitor in its stormwater discharge.
Total Maximum Daily Load (TMDL)
Attachment E of the General Permit contains a list of Regional Water Board adopted and/or U.S. EPA established/approved TMDLs, as of the adoption date of the General Permit, that are applicable to industrial stormwater Dischargers. TMDLs adopted/established after the effective date of the General Permit may, at the Water Board’s discretion, be included in the General Permit.
Discharges Subject to the California Ocean Plan
Dischargers with outfalls discharging to ocean waters that are subject to the model monitoring provisions of the California Ocean Plan shall develop and implement a monitoring plan in compliance with those provisions and any additional monitoring requirements established pursuant to Water Code section 13383. Dischargers are ineligible for the methods and exceptions provided in Section XI.C of the General Permit for any of the outfalls discharging to ocean waters subject to the model monitoring provisions of the California Ocean Plan.
Includes, but is not limited to: raw materials, recyclable materials, intermediate products, final products, by product, waste products, fuels, materials such as solvents, detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production; hazardous substances designated under Section 101(14) of Comprehensive Environmental Response, Compensation, and Liability Act (CERLCA); any chemical the facility is required to report pursuant to Section 313 of Title III of Superfund Amendments and Reauthorization Act (SARA); fertilizers; pesticides; and waste products such as ashes, slag, and sludge and that are used, handled, stored, or disposed in relation to a facility’s industrial activity.
The Discharger shall ensure the SWPPP includes a list of industrial materials handled at the facility, and the locations where each material is stored, received, shipped, and handled, as well as the typical quantities and handling frequency.
Stormwater Discharge Associated With Industrial Activity
The discharge from any conveyance which is used for collecting and conveying stormwater and which is directly related to manufacturing, processing, or raw materials storage areas at an industrial plant as identified in Attachment A of the General Permit.
The term includes, but is not limited to, stormwater discharges from industrial plant yards; immediate access roads and rail lines used or traveled by carriers of raw materials; manufactured products, waste material, or by-products used or created by the facility; material handling sites; refuse sites; sites used for the application or disposal of process wastewaters (as defined at 40 C.F.R. section 401); sites used for the storage and maintenance of material handling equipment; sites used for residual treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and intermediate and finished products; and areas where industrial activity has taken place in the past and significant materials remain and are exposed to stormwater.
Material handling activities include the: storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, finished product, by-product, or waste product.
The term does not include discharges from facilities or activities excluded from the NPDES program under 40 C.F.R. section 122.
The term excludes areas located on plant lands separate from the plant's industrial activities, such as office buildings and accompanying parking lots as long as the drainage from the excluded areas is not mixed with stormwater drained from the above described areas. Industrial facilities (including industrial facilities that are federally, State, or municipally owned or operated that meet the description of the facilities listed in this paragraph) include those facilities designated under 40 C.F.R. section 122.26(a)(1)(v).
Identify all industrial storage areas and storage tanks, shipping and receiving areas, fueling areas, vehicle and equipment storage/maintenance areas, material handling and processing areas, waste treatment and disposal areas, dust or particulate generating areas, cleaning and material reuse areas, and other areas of industrial activity that may have potential pollutant sources.
Any facility or building, property, road, or area that causes or contributes to pollutants in stormwater.
Pollutants that cause or threaten to cause pollution, contamination, or nuisance as defined in section 13050 of the Water Code, are prohibited.
Plastic Materials are virgin and recycled plastic resin pellets, powders, flakes, powdered additives, regrind, dust, and other similar types of preproduction plastics with the potential to discharge or migrate off-site.
Potential Pollutant Sources
Assessment of Potential Pollutant Sources
- The Discharger shall ensure that the SWPPP includes a narrative assessment of all areas of industrial activity with potential industrial pollutant sources. At a minimum, the assessment shall include:
- The areas of the facility with likely sources of pollutants in industrial stormwater discharges and authorized NSWDs;
- The pollutants likely to be present in industrial stormwater discharges and authorized NSWDs;
- The approximate quantity, physical characteristics (e.g., liquid, powder, solid, etc.), and locations of each industrial material handled, produced, stored, recycled, or disposed;
- The degree to which the pollutants associated with those materials may be exposed to, and mobilized by contact with, stormwater;
- The direct and indirect pathways by which pollutants may be exposed to stormwater or authorized NSWDs;
- All sampling, visual observation, and inspection records;
- The effectiveness of existing BMPs to reduce or prevent pollutants in industrial stormwater discharges and authorized NSWDs;
- The estimated effectiveness of implementing, to the extent feasible, minimum BMPs to reduce or prevent pollutants in industrial stormwater discharges and authorized NSWDs; and,
- The identification of the industrial pollutants related to the receiving waters with 303(d) listed impairments identified in Appendix 3 or approved TMDLs that may be causing or contributing to an exceedance of a water quality standard in the receiving waters.
Secondary containment prevents the loss of materials by installing a structural device able to contain leaks or spills. Examples of capture devices for secondary containment include, but are not limited to catch pans, tarps, berms or any other device that collects errant material.
If secondary containment is engineered to always prevent a discharge of collected rainfall (based on the historical rainfall record) and a simultaneous spill of any other industrial materials or liquids, the “No Exposure” condition may be claimed. Note that there must be proper disposal of any water or liquids collected from the containment (i.e., discharged in compliance with another NPDES permit, treated and discharged to the sanitary sewer, or trucked offsite to an appropriate disposal/treatment facility).
Non-Stormwater Discharges (NSWDs)
Discharges that do not originate from precipitation events. Including but not limited to, discharges of process water, air conditioner condensate, non-contact cooling water, vehicle wash water, sanitary wastes, concrete washout water, paint wash water, irrigation water, or pipe testing water.
Authorized Non-Stormwater Discharges (NSWDs)
The following NSWDs are authorized provided they meet the conditions below:
- Fire-hydrant and fire prevention or response system flushing;
- Potable water sources including potable water related to the operation, maintenance, or testing of potable water systems;
- Drinking fountain water and atmospheric condensate including refrigeration, air conditioning, and compressor condensate;
- Irrigation drainage and landscape watering provided all pesticides, herbicides and fertilizers have been applied in accordance with the manufacturer’s label;
- Uncontaminated natural springs, groundwater, foundation drainage, footing drainage;
- Seawater infiltration where the seawater is discharged back into the source: and,
- Incidental windblown mist from cooling towers that collects on rooftops or adjacent portions of your facility, but not intentional discharges from the cooling tower (e.g., “piped” cooling tower blowdown or drains).
Each of the permitted NSWDs listed above must meet the following conditions:
- The authorized NSWDs are not in violation of any Regional Water Board Water Quality Control Plans (Basin Plans) or other requirements, or statewide water quality control plans or policies requirement;
- The authorized NSWDs are not in violation of any municipal agency ordinance or requirements;
- BMPs are included in the SWPPP and implemented to:
- Reduce or prevent the contact of authorized NSWDs with materials or equipment that are potential sources of pollutants;
- Reduce, to the extent practicable, the flow or volume of authorized NSWDs;
- Ensure that authorized NSWDs do not contain quantities of pollutants that cause or contribute to an exceedance of a water quality standards; and,
- Reduce or prevent discharges of pollutants in authorized NSWDs in a manner that reflects best industry practice considering technological availability and economic practicability and achievability.
- The Discharger conducts monthly visual observations (Section XI.A.1) of NSWDs and sources to ensure adequate BMP implementation and effectiveness; and,
- The Discharger reports and describes all authorized NSWDs in the Annual Report.
Unauthorized Non-Stormwater Discharges (NSWDs)
Unauthorized NSWDs are non-stormwater discharges not listed as an authorized NSWD and can be generated from various pollutant sources. Depending upon their quantity and location where generated, unauthorized NSWDs can discharge to the storm drain system during dry weather as well as during a storm event (commingled with stormwater discharge). These NSWDs can consist of, but are not limited to; (1) waters generated by the rinsing or washing of vehicles, equipment, buildings, or pavement, or (2) fluid, particulate or solid materials that have spilled, leaked, or been disposed of improperly.
Unauthorized NSWDs shall be either eliminated or permitted by a separate NPDES permit. Unauthorized NSWDs may contribute significant pollutant loads to receiving waters. Ensure the SWPPP includes a description of how all unauthorized NSWDs have been eliminated. Measures to control sources of unauthorized NSWDs such as spills, leakage, and dumping, must be addressed through the implementation of Best Management Practices (BMPs).
Best Management Practices (BMPs)
BMPs include the scheduling of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants. BMPs also include treatment requirements, operating procedures, and practices to control site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
The Discharger shall, to the extent feasible, implement and maintain minimum BMPs and applicable advanced BMPs to reduce or prevent pollutants in industrial stormwater discharges and authorized NSWDs. Minimum BMPs are designed to reduce or eliminate the addition of pollutants through analysis of pollutant sources, implementation of proper handling/disposal practices, employee education, and other actions. Advanced BMPs are generally structural control measures and can include any BMPs that exceed the minimum BMPs. The Discharger shall also implement measures to control sources of unauthorized NSWDs such as spills, leakage, and dumping through the implementation of BMPs. “To the extent feasible” requires Dischargers to select, design, install and implement BMPs in a manner that reflects best industry practice considering technological availability and economic practicability and achievability (BAT and BCT).
Although there is great variation in industrial activities and pollutant sources between industrial sectors and, in some cases between operations within the same industrial sector, the minimum BMPs specified in the General Permit represent common practices that can be implemented by most facilities.
The Discharger shall, to the extent feasible, implement and maintain all of the following minimum BMPs to reduce or prevent pollutants in industrial stormwater discharges.
1. Good Housekeeping
- Observe all outdoor areas associated with industrial activity; including stormwater discharge locations, drainage areas, conveyance systems, waste handling/disposal areas, and perimeter areas impacted by off-facility materials or stormwater run-on to determine housekeeping needs. Any identified debris, waste, spills, tracked materials, or leaked materials shall be cleaned and disposed of properly;
- Minimize or prevent material tracking;
- Minimize dust generated from industrial materials or activities;
- Ensure that all facility areas impacted by rinse/wash waters are cleaned as soon as possible;
- Cover all stored industrial materials that can be readily mobilized by contact with stormwater;
- Contain all stored non-solid industrial materials or wastes (e.g., particulates, powders, shredded paper, etc.) that can be transported or dispersed by the wind or contact with stormwater;
- Prevent disposal of any rinse/wash waters or industrial materials into the stormwater conveyance system;
- Minimize stormwater discharges from non-industrial areas (e.g., stormwater flows from employee parking area) that contact industrial areas of the facility; and,
- Minimize authorized NSWDs from non-industrial areas (e.g., potable water, fire hydrant testing, etc.) that contact industrial areas of the facility.
2. Preventive Maintenance
- Identify all equipment and systems used outdoors that may spill or leak pollutants;
- Observe the identified equipment and systems to detect leaks, or identify conditions that may result in the development of leaks;
- Establish an appropriate schedule for maintenance of identified equipment and systems; and,
- Establish procedures for prompt maintenance and repair of equipment, and maintenance of systems when conditions exist that may result in the development of spills or leaks.
3. Spill and Leak Prevention and Response
- Establish procedures and/or controls to minimize spills and leaks;
- Develop and implement spill and leak response procedures to prevent industrial materials from discharging through the stormwater conveyance system. Spilled or leaked industrial materials shall be cleaned promptly and disposed of properly;
- Identify and describe all necessary and appropriate spill and leak response equipment, location(s) of spill and leak response equipment, and spill or leak response equipment maintenance procedures; and,
- Identify and train appropriate spill and leak response personnel.
4. Material Handling and Waste Management
- Prevent or minimize handling of industrial materials or wastes that can be readily mobilized by contact with stormwater during a storm event;
- ii. Contain all stored non-solid industrial materials or wastes (e.g., particulates, powders, shredded paper, etc.) that can be transported or dispersed by the wind or contact with stormwater;
- Cover industrial waste disposal containers and industrial material storage containers that contain industrial materials when not in use;
- Divert run-on and stormwater generated from within the facility away from all stockpiled materials;
- Clean all spills of industrial materials or wastes that occur during handling in accordance with the spill response procedures (Section X.H.1.c); and,
- Observe and clean as appropriate, any outdoor material or waste handling equipment or containers that can be contaminated by contact with industrial materials or wastes.
5. Erosion and Sediment Controls
For each erodible surface facility location identified in the SWPPP (Section X.G.1.f), the Discharger shall:
- Implement effective wind erosion controls;
- Provide effective stabilization for inactive areas, finished slopes, and other erodible areas prior to a forecasted storm event;
- Maintain effective perimeter controls and stabilize all site entrances and exits to sufficiently control discharges of erodible materials from discharging or being tracked off the site;
- Divert run-on and stormwater generated from within the facility away from all erodible materials; and,
- If sediment basins are implemented, ensure compliance with the design storm standards in Section X.H.6.
6. Employee Training Program
- Ensure that all team members implementing the various compliance activities of the General Permit are properly trained to implement the requirements of the General Permit, including but not limited to: BMP implementation, BMP effectiveness evaluations, visual observations, and monitoring activities. If a Discharger enters Level 1 status, appropriate team members shall be trained by a QISP;
- Prepare or acquire appropriate training manuals or training materials;
- Identify which personnel need to be trained, their responsibilities, and the type of training they shall receive;
- Provide a training schedule; and,
- v. Maintain documentation of all completed training classes and the personnel that received training in the SWPPP.
7. Quality Assurance and Record Keeping
- Develop and implement management procedures to ensure that appropriate staff implements all elements of the SWPPP, including the Monitoring Implementation Plan;
- Develop a method of tracking and recording the implementation of BMPs identified in the SWPPP; and
- Maintain the BMP implementation records, training records, and records related to any spills and clean-up related response activities for a minimum of five (5) years (Section XXI.J.4).
The discharge of potential leaks from drums in the storage area have been prevented with the installation of drum overpacks as a form of secondary containment.
Based upon the assessment of potential pollutant sources, Dischargers shall identify in the SWPPP any areas of the facility where the minimum BMPs will not adequately reduce or prevent pollutants in stormwater discharges in compliance the General Permit Section V.A. Dischargers shall identify any advanced BMPs, as described in the section below, for those areas.
Advanced BMPs may include one or more of the following BMPs:
- Exposure Minimization BMPs
- These include storm resistant shelters (either permanent or temporary) that prevent the contact of stormwater with the identified industrial materials or area(s) of industrial activity.
- Stormwater Containment and Discharge Reduction BMPs
- These include BMPs that divert, infiltrate, reuse, contain, retain, or reduce the volume of stormwater runoff. Dischargers are encouraged to utilize BMPs that infiltrate or reuse stormwater where feasible.
- Treatment Control BMPs
- This is the implementation of one or more mechanical, chemical, biologic, or any other treatment technology that will meet the treatment design standard.
- Other Advanced BMPs
- Any additional BMPs not described in subsections i-iii above that are necessary to meet the effluent limitations of the General Permit.
All new treatment control BMPs employed by the Discharger to comply with Section X.H.2 Advanced BMPs and new sediment basins installed after the effective date of this order shall be designed to comply with design storm standards in the General Permit Section X.H.6, except as provided in an Industrial Activity BMP Demonstration (Section XII.D.2.a).
A facility parking lot drains to a treatment system before discharging to the nearby receiving water body.
Best Available Technology Economically Achievable (BAT)
As defined by United States Environmental Protection Agency (U.S. EPA), BAT is a technology-based standard established by the Clean Water Act (CWA) as the most appropriate means available on a national basis for controlling the direct discharge of toxic and nonconventional pollutants to navigable waters. The BAT effluent limitations guidelines, in general, represent the best existing performance of treatment technologies that are economically achievable within an industrial point source category or subcategory.
Best Conventional Pollutant Control Technology (BCT)
As defined by U.S. EPA, BCT is a technology-based standard for the discharge from existing industrial point sources of conventional pollutants including biochemical oxygen demand (BOD), total suspended sediment (TSS), fecal coliform, pH, oil and grease.
Any structural facility designed and constructed to mitigate the adverse impacts of stormwater and urban runoff pollution. Examples of structural control measures are catch basins, berms, detention ponds, secondary containment, oil/water separators, diversion barriers, etc.
Erosion and Sediment Control
Erosion is the process by which soil particles are detached and transported by the actions of wind, water or gravity. Sediment includes solid particulate matter, both mineral and organic, that is in suspension, is being transported, or has been moved from its origin by air, water, gravity, or ice and has come to rest on the earth's surface either above or below sea level.
Structural and/or non-structural control measures can be implemented to stabilize exposed areas and contain runoff. The erosion control BMPs and sediment control BMPs include: implementing effective wind erosion controls, providing for effective stabilization of erodible areas, or erodible surfaces, prior to a forecasted storm event, site entrance stabilization/prevent material tracking offsite and implement perimeter controls, diversion of run-on and stormwater generated from within the facility away from all erodible materials, and ensuring compliance with the design storm standards in Section X.H.6.
The facility locations where soil erosion may be caused by industrial activity, contact with stormwater, authorized and unauthorized NSWDs, or runon from areas surrounding the facility.
Erosion Control BMPs
Vegetation, such as grasses and wildflowers, and other materials, such as straw, fiber, stabilizing emulsion, protective blankets, etc., placed to stabilize areas of disturbed soils, reduce loss of soil due to the action of water or wind, and prevent water pollution.
In order to reduce slope erosion during the rainy season, the slope was hydroseeded to grow native grasses.
Sediment Control BMPs
Practices that trap soil particles after they have been eroded by rain, flowing water, or wind. Includes those practices that intercept and slow or detain the flow of stormwater to allow sediment to settle and be trapped (i.e., silt fence, sediment basin, fiber rolls, etc.).
A silt fence was installed at the base of the drainage area to contain sediment during storms.
Monitoring Implementation Plan (MIP)
MIP is the planning document included in the Stormwater Pollution Prevention Plan (SWPPP). Dischargers are required to record information on the implementation of the monitoring requirements in the General Permit.
The Monitoring Implementation Plan shall be included in the SWPPP and shall include the following items:
- An identification of team members assigned to conduct the monitoring requirements;
- A description of the following in accordance with Attachment H:
- Discharge locations;
- Visual observation procedures; and,
- Visual observation response procedures related to monthly visual observations and sampling event visual observations.
- Justifications for any of the following that are applicable to the facility:
- Alternative Discharge Locations in accordance with Section XI.C.3;
- Representative Sampling Reduction in accordance with Section XI.C.4; or,
- Qualified Combined Samples in accordance with Section XI.C.5.
- Procedures for field instrument calibration instructions, including calibration intervals specified by the manufacturer; and,
- An example Chain of Custody form used when handling and shipping water quality samples to the lab.
Monthly Visual Observations
At least once per calendar month, the Discharger shall visually observe each drainage area for the following:
- The presence or indications of prior, current, or potential unauthorized NSWDs and their sources;
- Authorized NSWDs, sources, and associated BMPs to ensure compliance with Section IV.B.3; and,
- Outdoor industrial equipment and storage areas, outdoor industrial activities areas, BMPs, and all other potential source of industrial pollutants.
The monthly visual observations shall be conducted during daylight hours of scheduled facility operating hours and on days without precipitation. The Discharger shall provide an explanation in the Annual Report for uncompleted monthly visual observations.
Sampling Event Visual Observations
Sampling event visual observations shall be conducted at the same time sampling occurs at a discharge location. At each discharge location where a sample is obtained, the Discharger shall observe the discharge of stormwater associated with industrial activity.
- The Discharger shall ensure that visual observations of stormwater discharged from containment sources (e.g. secondary containment or storage ponds) are conducted at the time that the discharge is sampled.
- Any Discharger employing volume-based or flow-based treatment BMPs shall sample any bypass that occurs while the visual observations and sampling of stormwater discharges are conducted.
- The Discharger shall visually observe and record the presence or absence of floating and suspended materials, oil and grease, discolorations, turbidity, odors, trash/debris, and source(s) of any discharged pollutants.
- In the event that a discharge location is not visually observed during the sampling event, the Discharger shall record which discharge locations were not observed during sampling or that there was no discharge from the discharge location.
- The Discharger shall provide an explanation in the Annual Report for uncompleted sampling event visual observations.
Chain of Custody
Form used to track sample handling as samples progress from sample collection to the laboratory. The chain of custody is also used to track the resulting analytical data from the laboratory to the client. Chain of custody forms can be obtained from an analytical laboratory upon request.
Alternative Discharge Locations
- The Discharger is required to identify, when practicable, alternative discharge locations for any discharge locations identified in accordance with Section XI.B.4 if the facility’s discharge locations are:
- Affected by stormwater run-on from surrounding areas that cannot be controlled; and/or,
- Difficult to observe or sample (e.g. submerged discharge outlets, dangerous discharge location accessibility).
- The Discharger shall submit and certify via SMARTS any alternative discharge location or revisions to the alternative discharge locations in the Monitoring Implementation Plan.
Representative Sampling Reduction
- The Discharger may reduce the number of locations to be sampled in each drainage area (e.g., roofs with multiple downspouts, loading/unloading areas with multiple storm drains) if the industrial Industrial General Permit Order Order 2014-0057-DWQ 45 activities, BMPs, and physical characteristics (grade, surface materials, etc.) of the drainage area for each location to be sampled are substantially similar to one another. To qualify for the Representative Sampling Reduction, the Discharger shall provide a Representative Sampling Reduction justification in the Monitoring Implementation Plan section of the SWPPP.
- The Representative Sampling Reduction justification shall include:
- Identification and description of each drainage area and corresponding discharge location(s);
- A description of the industrial activities that occur throughout the drainage area;
- A description of the BMPs implemented in the drainage area;
- A description of the physical characteristics of the drainage area;
- A rationale that demonstrates that the industrial activities and physical characteristics of the drainage area(s) are substantially similar; and,
- An identification of the discharge location(s) selected for representative sampling, and rationale demonstrating that the selected location(s) to be sampled are representative of the discharge from the entire drainage area.
- A Discharger that satisfies the conditions of subsection b.i-v above shall submit and certify via SMARTS the revisions to the Monitoring Implementation Plan that includes the Representative Sampling Reduction justification.
- Upon submittal of the Representative Sampling Reduction justification, the Discharger may reduce the number of locations to be sampled in accordance with the Representative Sampling Reduction justification. The Regional Water Board may reject the Representative Sampling Reduction justification and/or request additional supporting documentation. In such instances, the Discharger is ineligible for the Representative Sampling Reduction until the Regional Water Board approves the Representative Sampling Reduction justification.
Qualified Combined Samples
- The Discharger may authorize an analytical laboratory to combine samples of equal volume from as many as four (4) discharge locations if the industrial activities, BMPs, and physical characteristics (grade, surface materials, etc.) within each of the drainage areas are substantially similar to one another.
- The Qualified Combined Samples justification shall include:
- Identification and description of each drainage area and corresponding discharge locations;
- A description of the BMPs implemented in the drainage area;
- A description of the industrial activities that occur throughout the drainage area;
- A description of the physical characteristics of the drainage area; and,
- A rationale that demonstrates that the industrial activities and physical characteristics of the drainage area(s) are substantially similar.
- A Discharger that satisfies the conditions of subsection b.i-iv above shall submit and certify via SMARTS the revisions to the Monitoring Implementation Plan that includes the Qualified Combined Samples justification.
- Upon submittal of the Qualified Combined Samples justification revisions in the Monitoring Implementation Plan, the Discharger may authorize the lab to combine samples of equal volume from as many as four (4) drainage areas. The Regional Water Board may reject the Qualified Combined Samples justification and/or request additional supporting documentation. In such instances, the Discharger is ineligible for the Qualified Combined Samples justification until the Regional Water Board approves the Qualified Combined Samples justification.
- Regional Water Board approval is necessary to combine samples from more than four (4) discharge locations.
Sampling and Analysis
The Discharger shall collect and analyze stormwater samples from two (2) Qualified Storm Events (QSEs) within the first half of each reporting year (July 1 to December 31), and two (2) QSEs within the second half of each reporting year (January 1 to June 30). Compliance GroupParticipants are only required to collect and analyze stormwater samples from one (1) QSE within the first half of each reporting year (July 1 to December 31) and one (1) QSE within the second half of the reporting year (January 1 to June 30).
Sample collection is required during scheduled facility operating hours and when sampling conditions are safe in accordance with Section XI.C.6.a.ii of the General Permit. Samples from each discharge location shall be collected within four (4) hours of:
- The start of the discharge; or,
- The start of facility operations if the QSE occurs within the previous 12-hour period (e.g., for storms with discharges that begin during the night for facilities with day-time operating hours).
Sample collection and handling instructions are outlined in Attachment H of the General Permit. The Discharger shall submit all sampling and analytical results for all individual or Qualified Combined Samples via SMARTS within 30 days of obtaining all results for each sampling event.
The General Permit contains two types of Numeric Action Level (NAL) exceedances: an annual NAL exceedance and instantaneous maximum NAL exceedance. The General Permit requires Dischargers to develop and implement Exceedance Response Actions (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.
Qualifying Storm Event (QSE)
A precipitation event that: (a) Produces a discharge for at least one drainage area; and (b) Is preceded by 48 hours with no discharge from any drainage area.
Except as provided in Section XI.C.4 (Representative Sampling Reduction) of the General Permit, samples shall be collected from each drainage area at all discharge locations. The samples must be:
- a. Representative of stormwater associated with industrial activities and any commingled authorized NSWDs; or,
- b. Associated with the discharge of contained stormwater.
Scheduled Facility Operating Hours
The time periods when the facility is staffed to conduct any function related to industrial activity, but excluding time periods where only routine maintenance, emergency response, security, and/or janitorial services are performed.
Any group of Dischargers of the same industry type or any QISP representing Dischargers of the same industry type may form a Compliance Group. A Compliance Group shall consist of Dischargers that operate facilities with similar types of industrial activities, pollutant sources, and pollutant characteristics (e.g., scrap metals recyclers would join a different group than paper recyclers, truck vehicle maintenance facilities would join a different group than airplane vehicle maintenance facilities, etc.). A Discharger participating in a Compliance Group is termed a Compliance Group Participant. Participation in a Compliance Group is not required. Compliance Groups may be formed at any time.
The Discharger shall analyze all collected samples for the following parameters:
- Total suspended solids (TSS) and oil and grease (O&G);
- pH (see Section XI.C.2);
- Additional parameters identified by the Discharger on a facility-specific basis that serve as indicators of the presence of all industrial pollutants identified in the pollutant source assessment (Section X.G.2). These additional parameters may be modified (added or removed) in accordance with any updated SWPPP pollutant source assessment;
- Additional applicable parameters listed in Table 1 of the General Permit. These parameters are dependent on the facility Standard Industrial Classification (SIC) code(s);
- Additional applicable industrial parameters related to receiving waters with 303(d) listed impairments or approved TMDLs based on the assessment in Section X.G.2.a.ix. Test methods with lower detection limits may be necessary when discharging to receiving waters with 303(d) listed impairments or TMDLs;
- Additional parameters required by the Regional Water Board. The Discharger shall contact its Regional Water Board to determine appropriate analytical test methods for parameters not listed in Table 2 below. These analytical test methods will be added to SMARTS; and
- For discharges subject to Subchapter N, additional parameters specifically required by Subchapter N. If the discharge is subject to ELGs, the Dischargers shall contact the Regional Water Board to determine appropriate analytical methods for parameters not listed in Table 2 below.
Numeric Action Level (NAL)
Pollutant concentration levels used to evaluate if best management practices are effective and if additional measures are necessary to control pollutants. NALs are not effluent limits. The exceedance of an NAL is not a permit violation.
Annual NAL Exceedance
The Discharger shall determine the average concentration for each parameter using the results of all the sampling and analytical results for the entire facility for the reporting year (i.e., all "effluent" data) and compare this to the corresponding Annual NAL values in Table 2. An annual NAL exceedance occurs when the average of all the analytical results for a parameter from samples taken within a reporting year exceeds an annual NAL value for that parameter listed in Table 2 (or is outside the NAL pH range);
Instantaneous Maximum NAL Exceedance
The Discharger shall compare all sampling and analytical results from each distinct sample (individual or composite) to the corresponding Instantaneous maximum NAL values in Table 2. An instantaneous maximum NAL exceedance occurs when two or more analytical results from samples taken for any parameter within a reporting year exceed the instantaneous maximum NAL value (for TSS and O&G), or are outside of the instantaneous maximum NAL range (for pH).
At the beginning of a Discharger’s NOI Coverage, all Dischargers have Baseline status for all parameters.
Level 1 Status
A Discharger’s Baseline status for any given parameter shall change to Level 1 status if sampling results indicate an NAL exceedance for that same parameter. Level 1 status will commence on July 1 following the reporting year during which the exceedance(s) occurred.
- Level 1 ERA Evaluation
By October 1 following commencement of Level 1 status for any parameter with sampling results indicating an NAL exceedance, the Discharger shall complete an evaluation, with the assistance of a QISP, of the industrial pollutant sources at the facility that are or may be related to the NAL exceedance(s) and identify in the evaluation the corresponding BMPs in the SWPPP and any additional BMPs and SWPPP revisions necessary to prevent future NAL exceedances and to comply with the requirements of the General Permit.
- Level 1 ERA Report
Based upon the above evaluation, the Discharger shall, as soon as practicable but no later than January 1 following commencement of Level 1 status revise the SWPPP as necessary and implement any additional BMPs identified in the evaluation and certify and submit via SMARTS a Level 1 ERA Report prepared by a QISP.
A Discharger’s Level 1 status for a parameter will return to Baseline status once a Level 1 ERA report has been completed, all identified additional BMPs have been implemented, and results from four (4) consecutive QSEs that were sampled subsequent to BMP implementation indicate no additional NAL exceedances for that parameter.
Level 2 Status
A Discharger’s Level 1 status for any given parameter shall change to Level 2 status if sampling results indicate an NAL exceedance for that same parameter while the Discharger is in Level 1. Level 2 status will commence on July 1 following the reporting year during which the NAL exceedance(s) occurred.
- Level 2 ERA Action Plan
Dischargers with Level 2 status shall certify and submit via SMARTS a Level 2 ERA Action Plan prepared by a QISP that addresses each new Level 2 NAL exceedance by January 1 following the reporting year during which the NAL exceedance(s) occurred.
- Level 2 ERA Technical Report
On January 1 of the reporting year following the submittal of the Level 2 ERA Action Plan, a Discharger with Level 2 status shall certify and submit a Level 2 ERA Technical Report prepared by a QISP
Dischargers with Level 2 status who submit an Industrial Activity BMPs Demonstration and have implemented BMPs to prevent future NAL exceedance(s) for the Level 2 parameter(s) shall return to baseline status for that parameter, if results from four (4) subsequent consecutive QSEs sampled indicate no additional NAL exceedance(s) for that parameter(s). If future NAL exceedances occur for the same parameter(s), the Discharger’s Baseline status will return to Level 2 status on July 1 in the subsequent reporting year during which the NAL exceedance(s) occurred. These Dischargers shall update the Level 2 ERA Technical Report as required in the General Permit.
The material and information provided is for information purposes to assist dischargers in preparing a site map and stormwater pollution prevention plan (SWPPP). The use of this information and/or Mapistry’s software does not guarantee compliance with the California Industrial General Permit (IGP). Dischargers should review the IGP to determine permit requirements for their site. In addition, regulatory interpretations may change over time as a result of new information, new court cases, or new laws. Dischargers should consult with their regulators, such as the California Regional Water Quality Control Board (RWQCB) or California State Water Resources Control Board (SWRCB) for current interpretations of environmental laws. In addition, dischargers should use their best professional judgement and utilize legal counsel and/or environmental consultant for questions about their site and applicable environmental regulations. Users assume all liability directly or indirectly arising from the use of this information.