The State Water Board adopted the new California Industrial General Permit on April 1, 2014. This Industrial General Permit (IGP) replaced the previous Industrial General Permit (97-03-DWQ). The permit effective date was July 1, 2015, but has been puhsed forward to August 14, which is right around the corner.
Now What Happens?
- The new IGP imposes new and increased compliance requirements and differs from the previous permit in the following general areas:
- Minimum Best Management Practices (BMPs)
- CWA Section 303(d) Impairment
- Electronic Reporting Requirements
- No Exposure Certification (NEC)
- Numeric Action Levels (NAL)
- Inspections and Sampling Frequency
- Exceedance Response Actions (ERA)
- Compliance Groups/Group Leader Qualification Requirements
- Training and QISP Requirements
How Can PM Environmental Help You Get into Compliance?
You may only have 30 – 60 days before the State imposes fines…..
SWPPP Updates, Record Keeping, Reporting – Avoid Fines for Non-Compliance!
Assist with record keeping, reporting, and certification, as well as SWPPP revisions and subsequent implementation of monitoring and sampling requirements. In addition, we can assist with preparation of monitoring plans, exceedance response action (ERA) reports, technical reports and other certifications that are required to be prepared by a Qualified Industrial Storm Water Practitioner (QISP).
Electronic Filing (SMARTS) – Avoid Costly Lawsuits from Citizens Groups!
Industrial dischargers were required to submit permit registration documents (PRDs) electronically. Subsequent annual reports must also be submitted electronically. This means that facility-specific information and data will be publically available. PM can assist dischargers with electronic reporting to ensure data accuracy and compliance with regulatory requirements and deadlines.
BMP Installation, Monitoring and Maintenance – Prevent Exceedances!
Provide BMPs and subsequent monitoring and maintenance of BMPs. We have existing relationships with BMP vendors and can assist industrial dischargers with BMP selection and design, construction, operation and maintenance services.
Compliance Group Management and Support – Get the Service You Deserve!
Under this IGP, participating dischargers with similar types of industrial activities, pollutant sources and pollutant characteristics, may join together to form Compliance Groups. A compliance group leader (who is a QISP and a Trainer of Record) must represent the group and provide assistance with permit compliance for the entire group. This arrangement provides economic benefit and cost savings to group members for SWPPP preparation/updates, training, sampling and ERA reporting. PM is available and qualified to function as a group leader to support specific industry groups who fall under the compliance group option.
QISP Training, Inspections, Monitoring and Sampling – Educate your Team!
PM provides the following training:
|Industrial Activities General
|California Qualified Industrial Stormwater Practitioner (QISP) Training
|National Pollutant Discharge Elimination System (NPDES) Permits require Permittees to train employees in targeted positions whose job or activities may impact stormwater or urban runoff water quality. PM staff has extensive experience in training public agency, developer, contractor, and industrial/commercial operator staff to comply with stormwater pollution prevention regulations and apply effective Best Management Practices (BMPs).
PM offers comprehensive stormwater compliance training to industrial/commercial personnel who are responsible for implementing activities identified in the facility specific SWPPP, conducting inspections, stormwater sampling, visual observations, and managing stormwater runoff. Training topics address areas such as spill response, good housekeeping, material handling procedures, and actions necessary to implement all BMPs identified in the SWPPP.
|As required by the current California Industrial General Permit (IGP), industrial facilities that have NAL exceedances during the 2015 – 2016 monitoring year are required to appoint a QISP to assist with IGP compliance and reporting requirements for the facility. A QISP must obtain both on-line and classroom training and pass an exam to receive official QISP certification.
PM offers basic IGP QISP primer training, if needed for facility staff, prior to taking the on-line QISP training class and exam. We will also offer the official QISP classroom training, once the online training and exam portion of QISP training requirement is released to the public.
Michele Kinaan of PM is one of the first QISPs and ToRs in California and has trained more than 200 storm water personnel and provided storm water inspections, monitoring and sampling at over 100 permitted sites in California. Currently serving on the State of California Industrial General Permit Training Team (IGPTT) and working directly with the State Water Board to develop the official Qualified Industrial Storm Water Practitioner training and examination materials.
For more information on industrial storm water compliance support services and specific details regarding IGP permit requirements please contact:
Michele Kinaan, PG, QISP, QSD
(916) 671-0382 or (916) 945-3772
Call PM Environmental at (916) 945-3772 for more details!