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Industrial Storm Water Permit 2011 Reissuance

Industrial Storm Water Permit 2011 Reissuance. Jonathon Bishop, Chief Deputy DIrector CA State Water Board. Charts and graphs. Industrial Facilities Inspected FY10/11. Industrial Facilities Submitting Annual Reports FY10/11. SW Permits.

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Industrial Storm Water Permit 2011 Reissuance

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  1. Industrial Storm Water Permit2011 Reissuance Jonathon Bishop, Chief Deputy DIrector CA State Water Board

  2. Charts and graphs.

  3. Industrial Facilities Inspected FY10/11

  4. Industrial Facilities Submitting Annual Reports FY10/11

  5. SW Permits • National Pollutant Discharge Elimination System (NPDES) Permit • Effluent Limitations • Provisions • Prohibitions • SWPPP (by extension) • Technology-based standards, mostly • Receiving Water Limitations • Water Quality Standards (WQS)

  6. Technology Based Standards • Industrial and construction: BPT/BAT/BCT • Permits may require best management practices (BMPs) • In establishing requirements, permit writers use best professional judgment (BPJ) • NRDC v USEPA: states establish BMP requirements

  7. Water Quality Standards • Water Quality Standards are made up of: • Beneficial Uses (designated to specific waterbodies), plus • water quality criteria; and • an antidegradation policy. • Beneficial Uses (BUs) are: • often not directly related to key water resource uses valued by communities (it might take a suite of them to protect wetlands and streams, for example) • Narrative or Numeric

  8. The Challenge of Numerics • Effluent limitations can either be “narrative” or “numeric” • Numeric effluent limitations can either be “technology-based” or “water quality-based” • Benchmark values are being used my many as training wheels for NELs • And just to be different, CA calls these “Numeric Action Levels” - NALs

  9. NELs and NALs

  10. Action Levels • aka Benchmark values in the MSGP • These are typically a hybrid of technology- and water quality-based values • MSGP values are derived from water quality criteria, however not site specific (nor are they CA specific) • If exceeded these generally do not constitute a violation of the permit

  11. CA Expert Panel on Numerics • Recommended differentiating between TMDL based NELs and the rest of the pack • Recommended a specific approach to setting TBALs and TBELs • Technology-based numbers should be based on effluent characterization data – mean plus one or two standard deviations • Panel went on to say our data was not acceptable

  12. More on TBALs, TBELs, WQBALs and WQBELs • Effluent data is only helpful in setting technology-based numbers if there is more known about the relationship to BAT/BCT implementation • Some individual NPDES permits for industrial storm water have WQBELs – Boeing SSFL, refineries, etc.

  13. Next steps.

  14. IGP - Next Steps • Release new IGP draft (before Christmas?) • Public, staff workshops (outreach) in January and February • Public Hearing to follow • Comment period ends • Staff digests and puts out FINAL draft for adoption • Adoption sometime in 2012

  15. Next Draft – Sneak Preview • Staff will recommend a continuation of narrative ELs this permit cycle (no NELs) • USEPA Benchmark values  quasi-WQBALs (and TBALs) in draft • Progressive (iterative) approach, akin to CASQA recommendations from 2006 • Improve data quality and breadth of information gathered, per Panel  QiSP role and other features • Aiming for possible TBELs in next permit (~2017)

  16. QISP Role(s) • Qualified Industrial Stormwater Practitioner (QISP) • Level 1 – on-site person, minimal training • Level 2 – multi-site, multi- facility, more training • Level 3 – required for advanced tasks, like background determination, etc., most training and maybe only for PEs

  17. Sampling • Effluent sampling • Sample 1 storm event per quarter (all sites, all “levels”) • Daily averages  compare to NALD • Annual averages  compare to NALA

  18. Action Levels • Daily and Annual Values (Annuals are basically 2.5x the daily) • Daily values are based on USEPA benchmark values in MSGP • No more EC • Trigger “Exceedance Response Actions – ERAs”

  19. Exceedance Response Action (ERA) Levels • Level 1 – after first exceedance, must evaluate operational BMPs, implement changes and report back • Level 2 – after subsequent exceedance, must evaluate structural and/or treatment control BMPs, implement them, or certify “background” or “BPT/BAT/BCT” is being met without further treatment • Must propose a new NAL

  20. Minimum BMPs • Number of overall required “inspections” and implied, mandatory BMPs are significantly reduced in the next draft • Some, new BMPs are now added, like those in the Water Code for facilities handling preproduction plastic pellets • Balance needed to comply with public participation court rulings

  21. Questions?

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