Manufacturers Take Note: New Storm Water Requirements for Industry Finalized
On April 1, 2014, the State Water Resources Control Board adopted a new Industrial General Storm Water Permit (IGP). Those operating under the existing 1997 permit should examine the new requirements before the permit takes effect in order to be prepared for implementation. Others who have not previously had this permit – perhaps because their operations are indoors – should check to be sure they qualify to sign the new No Exposure Certification or are eligible to submit the Notice of Non-Applicability.
The new IGP retains the familiar framework of the existing IGP, with several twists and additions. Facility operators will continue to implement Best Management Practices (BMPs) and monitor runoff at their facilities in accordance with a Storm Water Pollution Prevention Plan (SWPPP), but they must implement specific “Minimum BMPs” prescribed by the permit and, if those are inadequate, “Advanced BMPs” as well.
Facility monitoring will also continue but at different frequencies. Under the new permit, sampling results above specified Numeric Action Levels (NALs) will trigger a whole new set of requirements to evaluate, report on and improve analytical results. Facility operators will not only spend considerably more time scrutinizing analytical data, but also more money altering their facility and operations to better control pollutants. Reviewing historic data now can enable facilities to anticipate problems and make adjustments before they become compliance problems.
Prudent companies considering moving to another site, building a new facility, or renovating their current location will examine the new requirements before finalizing plans. Design features and other facility considerations could significantly reduce the cost of compliance and the risk of enforcement for years to come.