On Wednesday, July 1, the California State Water Resources Control Board (SWRCB) announced it would extend the deadline for enrolling under the new Industrial General Permit (IGP) for Storm Water Discharges (Permit No. 2014-0057-DWQ) until close of business on Friday, August 14, 2015. The SWRCB also pushed back the deadline for submittal of 2014-15 annual storm water reports under the now-expired 1997 IGP (Permit No. 97-03-DWQ) to August 14.
The SWRCB blamed “ongoing technical difficulties” associated with users attempting to submit annual reports and permit registration documents to its online database, known as SMARTS (Storm Water Multiple Application and Report Tracking System).
Despite the failure of SMARTS to accommodate the large number of users seeking to comply with the new IGP, the SWRCB nevertheless indicated that “[w]hile technical issues are being resolved, the General Permit is in effect.” Draft Order 2015-XXXX-EXEC Amending Order 2014-0057-DWQ (Hearing date August 4, 2015). Thus, entities subject to the new IGP will need to ensure they are in compliance with the substantive requirements of the 2014 permit and maintain all necessary documents, while they wait to access SMARTS for registration.
Barg Coffin attorneys have previously analyzed the key changes and requirements of the new IGP here, here, and here.
--Don Sobelman and Dave Metres
For more information, contact Don Sobelman at (415) 228-5456 or des@bcltlaw.com, or Dave Metres as (415) 228-5488 or dmm@bcltlaw.com.
Showing posts with label Industrial General Permit. Show all posts
Showing posts with label Industrial General Permit. Show all posts
Monday, July 6, 2015
Friday, April 4, 2014
California Water Board Finalizes New Water Quality Requirements for Industrial Facility Storm Water Discharges
For the first time in 17 years, industrial facilities in California must contend with a new set of legal requirements controlling storm water. On April 1, 2014, the California State Water Resources Control Board (State Board) formally adopted the final draft of the general NPDES permit that regulates storm water discharges associated with industrial activity, known as the “Industrial General Permit.”
The new Industrial General Permit imposes additional permitting requirements and expands the scope of the Permit to cover new categories of industrial facilities. Facility and EHS managers should review the new permit and ensure their facilities are on-track to be in compliance when the new Permit becomes effective on July 1, 2015. Failure to comply with the new Permit could expose facilities to regulatory action by the State Board and the Regional Water Quality Control Boards, or result in a citizen group lawsuit under the Clean Water Act.
As discussed previously by Barg Coffin attorneys here, here, and here, the new Industrial General Permit will impose mandatory best management practices (“BMPs”), require increased sampling and monitoring, and mandate technical reports and action plans if monitoring shows that storm water discharges exceed certain pollutant concentrations.
According to the State Board, there are over 10,000 California industrial facilities currently enrolled under the previous Industrial General Permit, and each will need to confirm that their operations and practices comply with the new requirements.
Additionally, for the first time, some facilities not previously subject to regulation will be required to notify the State Board that their industrial activities are not exposed to rain water and will not discharge to storm drains in order to obtain an exemption from the substantive requirements of the Industrial General Permit.
Additional information is available on the State Board website, and the Order adopting the Industrial General Permit (2014-0057-DWQ) is available here.
-Don Sobelman and Dave Metres
For more information, please contact Don Sobelman at (415) 228-5456 or des@bcltlaw.com, or Dave Metres at (415) 228-5488, or dmm@bcltlaw.com
The new Industrial General Permit imposes additional permitting requirements and expands the scope of the Permit to cover new categories of industrial facilities. Facility and EHS managers should review the new permit and ensure their facilities are on-track to be in compliance when the new Permit becomes effective on July 1, 2015. Failure to comply with the new Permit could expose facilities to regulatory action by the State Board and the Regional Water Quality Control Boards, or result in a citizen group lawsuit under the Clean Water Act.
As discussed previously by Barg Coffin attorneys here, here, and here, the new Industrial General Permit will impose mandatory best management practices (“BMPs”), require increased sampling and monitoring, and mandate technical reports and action plans if monitoring shows that storm water discharges exceed certain pollutant concentrations.
According to the State Board, there are over 10,000 California industrial facilities currently enrolled under the previous Industrial General Permit, and each will need to confirm that their operations and practices comply with the new requirements.
Additionally, for the first time, some facilities not previously subject to regulation will be required to notify the State Board that their industrial activities are not exposed to rain water and will not discharge to storm drains in order to obtain an exemption from the substantive requirements of the Industrial General Permit.
Additional information is available on the State Board website, and the Order adopting the Industrial General Permit (2014-0057-DWQ) is available here.
-Don Sobelman and Dave Metres
For more information, please contact Don Sobelman at (415) 228-5456 or des@bcltlaw.com, or Dave Metres at (415) 228-5488, or dmm@bcltlaw.com
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