California’s Industrial General Permit (IGP) regulates stormwater discharges from industrial facilities and requires monitoring, a SWPPP, and Best Management Practices to meet numeric action levels. SCS Engineers prepares SWPPPs, conducts sampling, and guides facilities through NOI filing and Exceedance Response Actions. Learn more about our stormwater management services and how our engineers keep sites permit-compliant.
For the first time in California’s long water-quality history, a new stormwater permit has been adopted that could significantly change the California waterscape. This new permit represents a major expansion of stormwater regulation beyond the traditional California Industrial General Permit (IGP). While the application is limited to two Los Angeles watersheds, the precedent is clear and could lead to increased stormwater regulations statewide.
Commercial, Industrial, and Institutional Facilities Impacted
The new Waste Discharge Requirements and General National Pollutant Discharge Elimination System (NPDES) Permit No. CAS004005 issued by the California Regional Water Quality Control Board, Los Angeles Region regulates stormwater discharges associated with commercial, industrial, and institutional (CII) facilities within the Dominguez Channel/Los Angeles and Long Beach Inner Harbor Watershed and the Los Cerritos Channel/Alamitos Bay Watershed.
Several hundred industrial and institutional facilities in the Dominguez Channel and Los Cerritos Channel watersheds are subject to permit compliance requirements. These facilities must manage stormwater runoff and authorized non-stormwater discharges because their discharges can contribute to water quality.
Most parcels are owned or leased by large businesses, which are expected to bear the majority of compliance costs. The permit’s requirements are estimated to represent a small percentage of average commercial or industrial rents. The permit also considers the economic benefits of improved water quality, including public health and tourism benefits.
General Permit Coverage and Applicability
The permit authorizes discharges of stormwater runoff and authorized non-stormwater discharges (NSWDs) from certain privately owned CII sites, excluding residential facilities.
Coverage includes sites with five or more acres of impervious surface that are not covered by other NPDES stormwater permits, or portions of sites not covered by other permits. Facilities with individual NPDES permits with at least as stringent requirements are exempt.
Dischargers must submit Permit Registration Documents via the Stormwater Multiple Application and Report Tracking System (SMARTS), including:
Compliance Options
Permittees and dischargers will have three primary compliance options for meeting water quality-based effluent limitations:
Option 1: Enter into a legally binding agreement with a local Watershed Management Group (WMG) to fund existing or planned downstream regional stormwater projects. Funding is proportional to the facility’s stormwater volume relative to the watershed’s total volume. This option is deemed compliant upon execution of the agreement and participation in it.
Option 2: Implement facility-specific design standards to capture and reduce stormwater runoff volume equivalent to the 85th percentile 24-hour storm event. This includes the use of structural and non-structural BMPs designed and certified by a California-licensed civil engineer. Infiltration BMPs must protect groundwater quality by meeting applicable Maximum Contaminant Levels (MCLs).
Option 3: Directly demonstrate compliance with numeric water quality-based effluent limitations through site-specific monitoring and reporting. This includes developing a Monitoring and Reporting Plan, conducting sampling during Qualifying Storm Events (QSEs), and submitting results via SMARTS.
Discharge Prohibitions and Authorized Non-Stormwater Discharges
The permit prohibits discharges inconsistent with eligibility, unauthorized non-stormwater discharges, trash discharges, and discharges of radiological, chemical, or biological warfare agents. Authorized NSWDs include fire hydrant flushing, potable water system discharges, uncontaminated groundwater, and incidental windblown mist, provided BMPs minimize pollutant contact and volume.
Stormwater Pollution Prevention Plan (SWPPP) Requirements
Dischargers must develop and implement a site-specific SWPPP including:
Effluent Limitations
The permit establishes both technology-based effluent limitations (TBELs) requiring implementation of BMPs reflecting Best Conventional Technology (BCT) and Best Available Technology economically achievable (BAT), and water quality-based effluent limitations (WQBELs) based on Total Maximum Daily Loads (TMDLs) and water quality objectives. Numeric effluent limits apply to specific pollutants including metals (copper, lead, zinc), indicator bacteria (Enterococcus, E. coli), toxicity, nutrients, legacy pesticides (DDT, chlordane, dieldrin), and PCBs in various receiving waters.
Sediment-associated effluent limitations are also established for certain pollutants in the Dominguez Channel Estuary and Los Angeles and Long Beach Inner Harbor Waters.
Monitoring and Reporting Requirements
All dischargers must conduct initial sampling within 18 months of the permit effective date to assess pollutant levels. Reporting includes annual visual observations of discharges, BMP implementation, and corrective actions. Specific monitoring requirements vary by compliance option:
Option 1: Annual reporting of funding agreements and visual observations during two Qualifying Storm Events (QSEs) per reporting period.
Option 2: Submission of design documentation, reporting of any bypass events, and annual inspection reports of BMPs.
Option 3: Detailed site-specific monitoring plans with sampling during four QSEs annually, analysis for all applicable pollutants, and submission of results and visual observations via SMARTS.
Provisions and Enforcement
Standard provisions consistent with federal regulations are included, such as a duty to comply, inspection rights, a prohibition on bypasses except under specific conditions, and requirements for proper operation and maintenance. Enforcement actions and penalties for violations are described, including mandatory minimum penalties for serious violations. Corrective actions must be taken for any exceedances of effluent limitations.
Special Provisions
The permit includes reopener provisions allowing modification or revocation for cause, including new information or changes in regulations. Electronic signature and certification requirements ensure compliance with electronic reporting rules. The permit continues in effect beyond its expiration date until a new order is adopted.
Watershed and Receiving Water Descriptions
The permit covers discharges to waters within the Dominguez Channel/Los Angeles and Long Beach Inner Harbor Watershed and the Los Cerritos Channel/Alamitos Bay Watershed, including Machado Lake sub-watershed. These watersheds are highly urbanized and include estuaries, harbors, lagoons, and coastal waters that support diverse aquatic life and endangered species. Many waterbodies are listed as impaired under the Clean Water Act and subject to TMDLs for various pollutants.
Prepare for the CII Permit
Screen your facility, using the >5-acre threshold and other NPDES parameters from the State Water Resources Control Board (SWRCB). Further consultation is likely needed as the CII Permit leaves the traditional SIC Code and Sector-based selection to geography and land use.
Start baseline copper/zinc source investigations before regulatory sampling drives stormwater management decisions. This has the potential to save considerable money later. The EPA expressly identifies copper and zinc impairment as a basis for the residual designation.
Sources that could cause or contribute stormwater pollutants of concern to this impairment include outdoor materials and activities, including galvanized roofing and fencing; metal roofs/downspouts; brake/tire wear; parking areas; HVAC equipment; dumpsters; outdoor metal storage; loading areas; vehicle traffic; wash areas; industrial fallout; and legacy site conditions.
SCS recommends seeking a Property and Applicability Screening as a first step. Some facilities may require Facility Compliance or Pollutant Source Assessments, and a Compliance Option Analysis to determine a roadmap to compliance.
Additional Resources:
Jonathan Meronek specializes in comprehensive stormwater management programs. He has conducted BMP and Pollutant Source Assessments (PSAs), written Stormwater Pollution Prevention Plans (SWPPPs), performed Training and Education classes and implemented Monitoring Implementation Plans (MIPs) for hundreds of facilities in the United States. His accreditations include IGP-TOR, QISP, ENV-SP, CPESC, QSP/D, with over eighteen years of supporting clients at SCS Engineers. As a State of California Industrial General Permit (IGP) Qualified Industrial Storm Water Practitioner (QISP) and QISP Trainer-of-Record (ToR), he finds stormwater solutions for a multitude of industrial clients.
When Endeavor Media (Stormwater Magazine, Wastewater Mag, and Water World) decided to launch their new education platform called “Stormwater University,” they reached out to Jonathan. He now has the good fortune of being one of twelve people to sit on Endeavor’s National Technical Advisory Board.
Jonathan is excited and looks forward to supporting his colleagues in stormwater management. He has promised not to add another post-nominal after his name.
When a release of PFAS occurs at a metal finishing facility, it is often due to the integrity of the wastewater system. Due to the persistence of PFAS and very low concentrations considered to be toxic, even water containing a small amount of PFAS can result in a large impact on the environment. If water can migrate into the subsurface, so can PFAS. Once in the soil, any water introduced into the soil can transport the PFAS into the groundwater.
The Californian chrome plating facilities are being required to test for PFAS even if there is no evidence of historical contamination at the property from any chemicals. Current testing is requiring the analysis of 25 different kinds of PFAS, including PFOS and 6:2 FTS.
Because such low concentrations of PFAS are considered to be toxic and their prevalence in common consumer products and tools, false-positive detections are common during the investigations for PFAS. False positives detections can lead to unnecessary expense and additional investigations. Therefore, selecting a knowledgeable, skilled, and experienced environmental consulting firm, is paramount to keeping the investigation as low cost as possible.
The author is Lynleigh Love a Senior Professional Geologist at SCS Engineers specializing in emerging contaminants.
To purchase, read, or cite this article: https://doi.org/10.1080/00202967.2020.1696597
(2020) Upcoming mandatory testing requirements for chromium plating facilities, Transactions of the IMF, 98:1, 6-7, DOI: 10.1080/00202967.2020.1696597.
Your facility will need a Qualified Industrial Stormwater Practioner (QISP) to perform an ERA Level 1 Assessment, on or before October 1, 2017, and follow up with an ERA Level 1 Technical Report by January 1, 2018, or as soon as is practicable. We recommend that this assessment and report be performed prior to the wet season of the 2017-18 permit cycle year, to assist dischargers in reviewing their minimum required BMPs and if needed, implement additional BMPs.
Review your ERA Level 1 Action Plan now. Is it correct given the additional NAL exceedances? You should review all items needed for a successful ERA Level 2 Action Plan and Technical Report to successfully reduce and/or eliminate pollutants of concern in stormwater discharge.
Your facility is required to submit an ERA Level 2 Action Plan, prepared by a QISP, which addresses each Level 2 NAL exceedance via SMARTs. This Action Plan must identify which of the three options below (or a combination thereof) of demonstration(s) the Discharger has selected to perform:
The State Water Board acknowledges that there may be cases where a combination of the demonstrations may be appropriate; therefore a Discharger may combine any of the three demonstration options in their Level 2 ERA Technical Report, when appropriate.
It is important to note that Level 2 is a serious situation under the IGP and you should start working immediately on your stormwater management goals for the ERA Level 2 Action Plan, which is due by January 1, 2018. For the BMP demonstration option, Dischargers may have to implement additional BMPs, which may include physical, structural, or mechanical devices that will reduce and/or eliminate pollutants in stormwater discharge.
The ERA Level 2 Technical Report, which summarizes the option(s) chosen and all relevant technical information, including design storm standards for treatment control BMPs, must be overseen and signed by a California Professional Engineer (PE) and submitted by January 1st, 2019.
Get help now by contacting an SCS Stormwater Professional near you.
Recent direct communications with SWRCB and local Regional Boards’ have indicated that during the 2016-2017 permit cycle year, inspections will be more detailed for facilities considered to be at high risk, which were specifically named as those with a long history of water quality violations, as well as scrap metal recyclers, and End-of-Life Vehicle (ELV) recycling. There will also be increased focus on facilities that discharge to impaired waterbodies with adopted Total Maximum Daily Load (TMDL) requirements.
Industries should take action now if there is any uncertainty in regards to the meeting permit regulations. Contact your local SCS Engineers’ office or one of our industrial stormwater experts in California, Cory Jones or Jonathan Meronek. If you need questions answered, or if you are unsure of your business’s requirements, and believe that your facility may be in violation, SCS will help sort through the permitting red-tape. This includes SMARTs filing, NOI/NEC or NONA submittals, SWPPPs and Monitoring and Implementation Plans.
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It’s not just that we like wine and happen to live and work in every wine producing region of the U.S.; SCS Engineers understands the need for clean water resources and how important they are to the wine industry and for agriculture in general. SCS helps wineries face an array of environmental and regulatory challenges including:
SCS is pleased to announce we are the newest member of WIN, the Wine Industry Network.
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This workshop was insightful, tightly constructed, and – most impressive – able to deliver high quality information that businesses can use immediately. I have been to hundreds of business workshops where companies feel drowned in the amount of expert information coming at them. Not so at this concise, one-hour workshop where businesses clearly understood the next steps they should take and where they can find resources to help them proceed.
Jo Marie Diamond, President and CEO, East County Economic Development Authority after attending the SCS seminar in San Diego, CA. on March 1, 2016.
SCS Engineers staff professionals are available to answer questions about compliance and the proposed fee schedule changes for attendees and any business unsure about the storm water permit. We can help clarify questions such as:
See the slide presentation here if you have not attended the seminars.
If you have questions about how the storm water permit could impact your business, or would like to know more about the permit fees, please contact Cory Jones, your nearest SCS office in California, or .
Cory Jones, P.E., ToR, QSIP, is a stormwater program manager at SCS Engineers. Jones manages complex projects for private and public clients that include site/civil, water/wastewater and stormwater engineering. He has completed a wide variety of special studies in storm water management and National Pollutant Discharge Elimination System (NPDES) compliance for federal, state and municipal public agencies.
Businesses attending California’s Storm Water Workshop know that the State Board is currently considering a tiered approach for storm water fees. Toward that end, the Board is reviewing the industrial storm water fee schedule with the intent of updating it by this summer.
Current rates are flat fees where permittees pay approximately $1,800 for a permit whether you have one acre of industrial operations or 100. The proposed rates would consider criteria such as total acres of activity exposed to storm water, permeability, and percent of property used for industrial operations. If you would like to comment directly to the Water Board, email your suggestions to
A panel of experts will convene on Tuesday, March 1, 2016, from 7:30 a.m. to 9:15 a.m. at the Civic Building #8P-Presentation Hall to provide businesses with information necessary to determine if they need to comply or are exempt. The building is located at 10601 Magnolia Avenue in Santee, CA.
Register with Amy Snyder at 1-619-464-1200 or via email at
The session is free and will cover these topics:
Panel of Experts:
Bill Fischbeck, Esq., and the moderator is an attorney in East San Diego County since 1976, Bill’s practice is concentrated in real estate, including transactions and dispute analysis as well as land use matters before public agencies throughout the County.
Cory Jones, P.E., ToR, is a storm water program manager at SCS Engineers. Jones manages complex projects for private and public clients that include site/civil, water/wastewater and storm water engineering. He has completed a wide variety of special studies in storm water management and National Pollutant Discharge Elimination System (NPDES) compliance for federal, state and municipal public agencies.
An Environmental Attorney will also join the panel. The educational session is sponsored by Commercial Properties Group and the San Diego East County Economic Development Council.
Link to more information about storm water management
Meet Chuck Pryatel, the newly appointed Industrial Environmental Association (IEA) Secretary.
Chuck Pryatel is a Senior Project Advisor for SCS Engineers with over 30 years of experience in environmental regulatory compliance. He manages projects that include hazardous materials and waste compliance audits, preparation of spill prevention control and countermeasure plans, hazardous waste tank system assessments and certifications, and assists as a regulatory liaison resolving complex environmental issues. His experience includes completing environmental site assessments, subsurface investigations, preliminary endangerment assessments, health risk assessments, and environmental mitigation and clean-ups.
Prior to his private sector work Chuck served in positions of leadership at the County of San Diego Department of Environmental Health including Chief of the Hazardous Materials Division and Chief of the Site Assessment and Mitigation Division.
Chuck has a Masters of Business Administration from San Diego State University and a Bachelors of Arts in Biology from the University of California San Diego. He is a Registered Environmental Health Specialist in the State of California.
Congratulations Chuck!
The Industrial Environmental Association was formed in 1983 to promote responsible, cost-effective environmental laws and regulations, facilitate environmental compliance among member companies and provide related education activities for the community at large. The IEA’s evolution, however, has included an expanding role as the “voice” for manufacturing and associated companies in San Diego and Southern California, not only on legislative matters but on a variety of environmental issues that affect the quality of life of businesses in the region.
The Industrial Environmental Association actively insists on strong environmental compliance efforts among member companies as a matter of written policy. The IEA organizes a number of educational opportunities for member companies and the greater community including information exchanges, technical workshops, written papers, committees, and an annual conference.
IEA activism aims to prove with deeds as well as words that industrial companies care about the community, both environmentally and economically. IEA believes that industry must be involved in the process of environmental policy-making, and urges reliance on scientific, analytical data to evaluate regulations. The IEA willingly works closely with city and county government officials in an effort to realize environmental and community health protection.
The Industrial General Permit is an NPDES permit that regulates discharges of stormwater associated with industrial activity. Based on the projected revenue and the predicted surplus, SWRCB is working to refine program funding and plans to adjust the current IGP permit fee structure.
Glen Osterhage, Fee Branch Manager for the California State Water Resources Control Board (SWRCB), Division of Administrative Services, met with industry leaders on November 3, 2015, to discuss potential changes to the stormwater Industrial General Permit (IGP) fee structure. Meeting attendees included: SCS Engineers, the Industrial Environmental Association (IEA), California Stormwater Quality Association (CASQA), the California Taxpayers Association (CTA), California Chamber of Commerce, the Independent Energy Producers Association (IEPA), and the host – California Manufacturing and Technology Association (CMTA).
The SWRCB funds eight core permit programs through the Waste Discharge Permit Fund, which pays for over 800 staff. California has cut allocations for agency staff funding by approximately $30 million dollars, forcing SWRBC to distribute its cost burden across the permit fee base. Currently, IGP permit fee revenue is $14.4 million (a single permit fee of $1,791 multiplied by approximately 8,035 permittees). However, SWRCB projects higher revenues due to increased enrollment when all newly required permittees file. Core programs are also subsidized with excess funds coming from the Construction Permit fees (excess of $2M over required $2M last year). Based on the current projected revenue and the predicted surplus the SWRCB is working to refine the IGP program funding and plans to adjust the structure of the permit fee from a flat rate to a rate adjusted for facility size, project complexity, and the threat to water quality.
Following the 2017 to 2018 year permit periods, the SWRCB will have better estimates with which they can accurately adjust fees. The SWRCB is exploring the potential for providing fee discounts for benefits or subsidizing other permit compliance cost burdens. For now, the No Exposure Certification (NEC) IGP Permits are likely to remain a flat fee, but their value may change following additional baseline permit data results.
The SWRCB’s revenue goal is, as always, to break-even; any proposed change to the fee structure is not intended to boost agency revenue over expenses. Another goal is to have data readily available for selecting a permit fee tier from the information submitted on the IGP’s online database application (Storm Water Multiple Application & Report Tracking System, SMARTS, smarts.waterboards.ca.gov).
The SWRCB will have additional meetings to collect comments on the proposed change in hopes of creating a consensus with permittees on these impending changes.
SCS Engineers will provide information as it becomes available. Our professionals are available to assist newly required permittees with filing and compliance requirements.
Contact SCS’s Stormwater Manager, Cory Jones at 1-858-571-5500 or .
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