This webinar by Robert Kuykendall and Hari Gupta of BlueScape Environmental covers the California Industrial Storm Water Program requirements. The first part of the webinar provides an overview of the Program, including applicability, conditional exclusions and Notice of Non-Applicability, Storm Water Prevention Plan Requirements, the SMARTS reporting system, monitoring and sampling, and the role of the QISP. The second part discusses Level 1 and 2 Exceedance Action Requirements (ERAs), including 2016 evaluation and reporting requirements, and tips for implementing SWPPs and BMPs. BlueScape can be reached at training@bluescapeinc.com or 877-486-9257 for questions, customized training, and support for developing and implementing storm water plans.

1. California Industrial Storm
Water Compliance…
the Cascade is Coming!
September 8, 2016
BlueScape Environmental
training@bluescapeinc.com
877-486-9257

2. Webinar Topics
Topic
Subtopic
1. Overview of California
Industrial Storm Water
Regulations
• Storm Water Programs in California
• Program Applicability, Conditional Exclusions
and Notice of Non-Applicability (NONA)
• Storm Water Pollution Prevention Plan
(SWPPP) requirements
• SMARTS Electronic Reporting Requirements
• Best Management Practices and Requirements
• Monitoring Plans, Sampling and Inspections
• Role of the QISP in Storm Water Compliance
2. Level 1 and Level 2 ERA
Evaluations
• Trigger for Evaluation / Pollutant Numeric
Action Levels
• Level 1 ERA Report Requirements
• Is your facility heading to Level 2 Status?
• Tips for SWPPP and Implementing BMPs

3. About BlueScape
• Founded in 1997
• Extensive experience with Environmental, Health &
Safety Regulations
– Storm Water, Air Quality, Spill Prevention, Chemical Risk
Management
– See www.bluescapeinc.com
• Wide Range of Industries Served
– Chemical plants, power plants, data centers, building
materials, aerospace, refineries, coating manufacturing,
industrial gas, and oil & gas processing
• BlueScape EHS – EMS and managed compliance
services to reduce business risk
• BlueScape Technical Services - Solve tough EHS
permit and compliance issues:
- Develop permit and compliance strategies, quickly obtain
permits
- Technical analysis tools
- Leverage agency relationships, lead negotiations
- Compliance, enforcement and variance support
• Move business forward, reduce business risk

4. Overview of California
Industrial Storm Water
Regulations

5. Storm Water Regulation Overview
• Water runoff from our cities, highways, industrial facilities and
construction sites can carry
– Pollutants that degrade water quality
– Impact the beneficial uses of our waters.
• Federal Clean Water Act prohibits certain discharges of storm
water containing pollutants.
• National Pollutant Discharge Elimination System (NPDES)
– Authority and Framework for regulating storm water discharges comes
from the Federal Clean Water Act
• US EPA delegates it’s federal permitting program to State of
California
– Two decades State Water Resources Control Board (State Water Board);
Regional Water Quality Control Boards and the US EPA regulates the run
off and treatment of storm water in construction, industrial, municipal,
residential areas of California.

6. Storm Water Regulatory Programs
Municipal Separate
Storm Sewer System
(MS4) Permits
California
Department of
Transportation
(CALTRANS)
PHASE 1 MS4 Permit
Statewide
Construction Storm
Water General Permit
(Construction General
Permit (CGP))
Statewide Industrial
Storm Water General
Program (IGP)
Municipal Separate
Storm Sewer Systems
CALTRANS is the largest
municipal storm water
discharger in California
Construction projects
that disturb one or more
acres of soil, or disturb
less than one acre but
apart of a larger project
Industries
Regulates storm water
entering into local
municipal systems
Regulates storm water
discharges from linear
network of highways
and road facilities
Regulates construction
storm water based on
project-specific overall
risk
Regulates storm water
from industrial activity
areas from over 10,000
industries
Phase 1:
Medium: (100,000 to
200,000 people
Large (>250,000
people)
Phase 2:
Small municipalities
(<100,000 people)
Non Traditional Small
Operations:
Military Bases, public
campuses, prisons and
hospital complexes not
under Phase 1.
One statewide Phase 1
MS4 Permit
CGP requires temporary
and post construction
best management
practices. Measures to
prevent erosion and
reduce sediment and
pollutants in discharges
at construction sites.
IGP requires industry
owners to implement best
technology available to
reduce pollutants in their
storm discharges.
Requirement for Storm
Water Pollution Prevention
Plan (SWPPP) and
monitoring in accordance
with regulatory levels
specified in statewide
permit

7. Poll Question
Is your facility currently required to have a
Storm Water Pollution Prevention Plan?
¢ Yes
¢ No
¢ I don’t know

8. Exempt and Non-Exempt
Industrial Facilities
• Required industrial facilities must comply with the 2014
IGP permit to be in compliance with the Clean Water Act
• Exempted or Non Exempt
– Conditional Exclusion – No Exposure Certification (NEC)
• For facilities that have no exposure of industrial activities and
materials to storm water
– Notice of Non-Applicability (NONA)
• Allows facilities designed to contain storm water. No
discharges
• Submit a Technical Report in the SMART system
– Notice of Intent (NOI)
• Facilities that discharge storm water associated with
industrial activity

9. Basic IGP Requirements for
Covered Facilities
• Covered facilities
– Must develop and implement a storm water pollution
prevention plan (SWPPP) including Best Management
Practices (BMPs)
• Electronic Reporting Requirements
– Certify and submit all permit-related compliance
documents via the Storm Water Multi Application
Reporting and Tracking System (SMARTS)
• Best Management Practices (BMPs)
– Implement minimum BMPs and advanced BMPs to
achieve compliance with the effluent and receiving
water limitations

10. Covered Facilities Monitoring,
Testing & Inspections
• Monitoring Plans, Sampling and Inspections
– Facility shall have a written site-specific plan
– Collect and analyze samples from at least 4 Qualifying Storm
Events (QSEs) during the first four hours of discharge or start
of facility operating within the previous 12 hours
– Perform monthly storm water discharge visual observations
during the compliance year (July 1 – June 30)
• Perform the appropriate Exceedance Response Actions
(ERAs) when there are exceedances of the Numeric Action
Limits (NAL) leading to a Level 1 or 2 Status.

11. Exceedance Response
Actions (ERAs)

12. Poll Question
Will your facility need to complete a
Level 1 ERA evaluation and report?
¢ Yes
¢ No
¢ I don’t know
¢ Not a Facility
Manager

13. Exceedance Response Actions
(ERAs)
• ERAs are required when an annual Numeric Action
Level (NAL) or instantaneous maximum NAL
exceedance occurs for basic pollutants (TSS, pH*,
O&G) or the annual average NAL for additional
pollutants is exceeded during a reporting year.
• First time NAL exceedance, Discharger status
changes from Baseline to Level 1 status
• Second exceedance for the same parameter(s) in a
subsequent reporting year, Discharger status is
changed from Level 1 status to Level 2 status

14. Numeric Action Levels (NALs)
• For basic pollutants monitored (TSS, pH, and O&G),
an exceedance of the annual average for the
parameter and/or two or more exceedances of the
instantaneous maximum NAL results in the facility
being in Level 1 status
• For additional parameters such as metals, COD, BOD,
N+N monitored, exceedance of the annual average
NAL results in a Level 1 status
• Annual average is calculated from all sampling data
from all sampling locations

15. Numeric Action Levels (NALs)
Average
of
all
samples

16. Level 1 ERA Status: Now What?
Level 1 Status
• If an annual or instantaneous NAL is exceeded as
discussed, than Level 1 status begins on the next
July 1 (July 1, 2016 for compliance year
2015-2016)
• Discharger is required to conduct a Level 1 ERA
Evaluation using a QISP by October 1
• Level 1 ERA Evaluation Tasks
– Review SWPPP, and
– Evaluation of Industrial Pollutant Sources
– Assessment of existing Monitoring/Sampling Plan
– Assessment of existing minimum BMPs and any
advanced BMPs (if any) whether adequate
– Identification of additional BMPs; modify existing
BMPs

17. Role
of
the
QISP
• QISP = Qualified Industrial Storm Water Practitioner
• Required to perform ERAs when Discharger reaches
Level 1 & Level 2 status
• Performs the Annual Comprehensive Facility
Compliance Evaluation (Annual Evaluation) for Level 1
and 2 Status Facilities
• Assists in preparation of Annual Reports
• Prepares Level 1 ERA Evaluation and Report
• Prepares Level 2 ERA Action Plan and Technical Report
• Trains appropriate SWPPP team members when facility
is a Level 1 or Level 2 status
• Be informed, responsible, and attentive to the required
duties of QISP & maintain registration in good
standing.

18. Level 1 ERA Status
• Level 1 Status (cont.)
– Training of Employees by QISP
– Revise SWPPP
– Start implementing new/modified minimum BMPs
– Ensure internal procedures in place to track BMPs
designed and implemented in SWPPP
Once BMPs implemented, QISP to revisit facility and
assess Level 1 actions
If NAL for pH was exceeded, Level 1 facility has to use
pH meter (can’t use pH strips)

19. Level 1 ERA Report
• Due January 1 (January 1, 2017)
• Prepared by QISP
• Report Requirements
– Must contain a summary of the Level 1 evaluation
• All new or revised BMPs added to SWPPP
– Discharger must certify and submit electronically
via SMARTS

20. Is
Your
Facility
Heading
to
Level
2
Status?
• Level 2 ERA Status
– Any subsequent reporting year in which the same
parameter(s) has an NAL Exceedance (annual
average or instantaneous maximum)
– Level 1 status changes on July 1 (2017) of the
subsequent year
– What you must do?
• Submit a Level 2 ERA Action Plan by January 1
(2018) containing schedule and selected
demonstrations
• Submit a Level 2 ERA Technical Report by January 1
(2019) containing details on the selected
demonstrations

21. What are Level 2 ERA
Demonstrations?
• Level 2 ERA Facility Demonstrations
– Industrial activity BMP demonstration to show
industrial pollutant sources and advanced BMPs
designed to achieve compliance with effluent
limitations and/or NALs; feasibility analysis
– Non-Industrial Pollutant Source Demonstration
that the pollutant is from run-on, aerial deposition
from man-made sources, or generated by onsite
non-industrial sources that solely caused
exceedances
– Natural Background Pollutant Source
Demonstration that pollutant that caused NAL
exceedance was solely due to natural background
not disturbed by industrial activity

22. Tips
for
SWPPP
Updates
and
ImplemenDng
BMPs
• Retain a QISP
• Keep SWPPP Current
• Train Your Employees
• Perform Inspections
• Maintain House Keeping
• Minimize Exposure
• Prevent Spills & Releases
• Implement advanced BMPs ahead of time in Level
1 stage (e.g., permanent shelters, control and
treatment, erosion and sediment controls)
• Reduce Runoff with Vegetation

23. Questions?
Contact Information
BlueScape Environmental
James Westbrook, President
Robert Kuykendall, CHMM
Hari Gupta, PE, QISP
877-486-9257
training@bluescapeinc.com
www.bluescapeinc.com
The webinar presentation will be posted on
Slideshare and YouTube