The California Industrial General Permit (IGP), implemented and enforced by the California State and Regional Water Boards, regulates industrial stormwater discharges and authorized non-storm water discharges from industrial facilities throughout California. It is a complex, frustrating, constantly evolving rule that brings about a unique set of challenges, successes, and lessons learned. In this post, KERAMIDA's QISP-certified professionals share their experiences and strategies for making IGP compliance less stressful.
California Industrial General Permit Overview:
Important components of the Industrial General Permit (IGP) include a digital tracking system for regulated facilities to enter data (SMARTS), a Stormwater Pollution Prevention Plan (SWPPP), site map, annual reports, Exceedance Responses Action Reports (ERAs), and many more required documents.
What industrial facilities are covered?
Oil & gas mining facilities
Publicly owned treatment works
Additional selected facilities
Why is a Qualified Storm Event (QSE) important?
A crucial component that facilities must closely monitor is a Qualified Storm Event (QSE). The California State Water Resources Control Board defines a QSE as a precipitation event that produces a discharge for at least one drainage area and is preceded by 48 hours with no discharge from any drainage area.
When the criteria for a QSE is met, facilities must sample and analyze both standard and potentially additional parameters. These results are extremely important, as they determine what level status a facility is classified as under the IGP. The three levels are: Baseline, Level One, and Level Two. A facility will ideally be in Baseline, but all too often find themselves in Level One or Two. Each level brings with it a multitude of reporting and monitoring requirements which increase financial and administrative requirements to ensure compliance is met.
Compliance Challenges: Regulation Complexity & Fluctuating Rainfall
As with any complex regulation, the IGP has a unique set of challenges. Its language and expectations are very complicated and often ambiguous, making compliance difficult. California’s fluctuating rainfall adds to this difficulty, as each rainy season’s unpredictability often affects a facility’s sampling results and frequency. A facility’s experience under the IGP often varies depending on the amount of staff employed, yet the permit provides no distinctive requirements that are dependent upon the size of the facility required to be covered. It is often difficult to ensure that even the most basic information that is reported in SMARTS is accurate. The multitude of required reports and information creates administrative and financial burdens that many facilities are struggling to bear. Finally, the self-reporting nature of the IGP makes backsliding on compliance efforts an effortless reality for many facilities.
Success Stories: The Benefits of Effective Environmental Consulting
KERAMIDA has several case studies that illustrate the complexity of IGP compliance, along with the incredible payoff of skillful environmental consulting.
A fence manufacturing facility in California had at one point in time been storing its raw material, the source of its pollutants, outside. In 2014, the facility received a Notice of Intent (NOI) to sue and has been operating under a Consent Decree since 2016. Per the Consent Decree, they have installed a treatment system and are considering infiltration. With the help of KERAMIDA, the facility was able to improve its storage of raw materials and finished product to reduce potential impacts on QSE sampling results. The sampling results spoke for themselves, as all their sampling parameters are now within the IGP’s Numeric Action Levels (NALs) and the facility is back to baseline.
A die casting facility had entered Level 1 after QSE sampling events were yielding high parameter results. During a site visit with the facility, a KERAMIDA employee noticed that the facility’s sampling location was located at an employee parking lot. This location was most likely resulting in unrepresentative samples and subsequently keeping the facility in a level status that was not indicative of their compliance efforts. Per KERAMIDA’s suggestion, the facility moved its sampling location from the employee parking lot to a roof downspout. This change has resulted in drastically improved sampling results and the facility has returned to baseline, demonstrating the importance of strategically-chosen sampling locations.
Lessons Learned: A Customized Approach to Stormwater Compliance
The lessons learned after nearly four years of assisting facilities who are trying to comply with the IGP stem from the challenges it presents. There is no doubt that stormwater compliance is complicated. Utilizing a close analysis of each individual facility’s characteristics and needs allows for an effective, personal response to reduce the complexity of IGP compliance. Our staff has learned that California’s fluctuating rainfall makes monitoring and compliance more difficult. In response to this troubling phenomenon, KERAMIDA has utilized strategies such as moving operations indoors to remove the possibility of unrepresentative sampling results dictating future IGP requirements. This in turn allows for less stringent monitoring and compliance efforts, which is the goal KERAMIDA strives to achieve for all clients. We know that small facilities have different needs than a large facility. Learning how to work with the specialized and individual needs of facilities allows KERAMIDA to provide a more custom approach to stormwater compliance.