Tag Archives: california industrial general stormwater permit

PFAS false-positive detections can lead to unnecessary expense and investigations

January 22, 2020

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.

 

Learn more about PFAS and the impact on industrial wastewater pretreatment and groundwater protection.

SCS Engineers PFAS Library – Free

 

 

 

 

 

 

Posted by Diane Samuels at 6:01 am
Tag Archives: california industrial general stormwater permit

What you need to know if you received a notice from the Water Board that your facility is ERA Level 1 or Level 2 Status

September 13, 2017

ERA Level 1 Status

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.

ERA Level 2 Status

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.

 

Requirements, Actions, Deadlines

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:

  • Industrial Best Management Practice (BMP) Demonstration – Description/evaluation of relevant potential pollutant sources whereby additional Facility BMPs are implemented to comply with all applicable effluent limitations (BAT/BCT, ELGs and/or TMDLs) and to prevent future NAL exceedances (If this is not feasible to implement, you must provide estimated cost and rationale);

 

  • Non-industrial Pollutant Source Demonstration (run-on from adjacent facilities, aerial deposition). This option allows for a Discharger to demonstrate that the pollutants causing the NAL exceedances are not related to industrial activities conducted at the facility, and additional BMPs at the facility will not contribute to the reduction of pollutant concentrations.  The determination that the sources are not from industrial activity or natural background must be done by a QISP; and

 

  • Natural Background Pollutant Source Demonstration (e., iron in soils). This option takes its cue from the 2008 Multi-Sector General Permit (MSGP) whereby and if a Discharger can determine that the exceedance of a benchmark (NAL) is attributable to the presence of that pollutant in the natural background. A Site Plan(s) is very important in this regard which should include, but not limited be to facility locations, available land cover information, reference site and test site elevation, available geology, and soil information for reference and test sites, photographs showing site vegetation, site reconnaissance survey data, and records.

 

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.

 

Four important considerations in light of the ERA Level 2 exceedances:

    • Your facility Pollution Prevention Team (PPT) and/or consultant hopefully reviewed all the relevant 2016-17 storm water sampling analytical results during the annual report process. It is worth taking another look and reviewing each and every lab report, and look for j-flags, and potential issues during sampling to make sure it is truly an NAL exceedance. If this is an issue, training should also be done fairly soon to ensure proper sampling techniques during the 2017-18 stormwater season.

 

    • Budgetary: Capital expenditures can take time to get approved. The earlier the compliance-based BMP items are submitted for budgetary approval, the better. This will give the Discharger more flexibility and options for a tiered approach for implementation.

 

    • Non-government Organizations (NGOs) and Environmental Groups (EGs) are a “de facto” regulatory mechanism, and there has been a proliferation of citizen suits under the Clean Water Act recently. ERA Level 2 Dischargers could be on a short list for non-compliance and have greater exposure.

 

  • Remember, if you return to Baseline status under the IGP and breach the former ERA Level 2 NALs with a yearly average or instantaneous maximum exceedance(s), your facility returns directly to ERA Level 2. Make sure your BMPs are implemented for the long-term to prevent returning to Level 2 status.

 

 

Get help now by contacting an SCS Stormwater Professional near you.

 

 

 

 

Posted by Diane Samuels at 6:03 am
Tag Archives: california industrial general stormwater permit

SCS Regulatory Alert: California EPA – State Waste Resources Control Board (SWRCB)- Industrial General Permit (IGP) Compliance Update and Storm Water Facts

September 7, 2016

 

The State Water Resources Control Board (SWRCB)’s industrial stormwater website has developed many new guides to help industrial dischargers (Industrial General Permit, IGP, permitees) understand what is required  and how to best to utilize the on-line reporting protocols for IGP compliance.  Despite the resources and this outreach provided on the SWRCB website many industries and businesses could be at risk, and may not understand that they could be in violation of the current IGP.

 

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.

 

Recent News, Stats, and Resources

  • The State Board notified enrolled permittees that they must submit their annual reports electronically.  Reference the Electronic Reporting – Storm Water Multiple Application and Report Tracking System (SMARTS) Database
  • As of June 30, 2016, only approximately 2000 out of 8581 annual reports (statewide) have been submitted electronically.
  • NONA: The State Board has reviewed the Notice of Non-Applicability (NONA) forms submitted for the Statewide NPDES Permit Coverage for Drinking Water System Discharges; only a small percentage (9 of 150±) were done correctly and approved.
    • The State Board found that a certification by a professional engineer had not been completed approving that the sites are not hydraulically connected, or
    • A No Exposure Certification (NEC) should have been filed instead of a NONA.

 

More Resources

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: california industrial general stormwater permit

Besides grapes, water is the second most important ingredient in wine. 

June 27, 2016

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:

  • Energy and natural resources conservation programs. These programs include protecting habitats and species.
  • Water Quality – Stormwater, Wastewater, Groundwater, Well-water and Surface Water;
  • Air Quality – Winery Fermentation and Aging Emissions, including VOCs, Stationary-Traditional Combustion Sources, and Greenhouse Gas Emissions;
  • Environmental Due Diligence -All Appropriate Inquiries, Phase I’s/Phase II’s, Environmental Compliance Reviews and Audits, Vapor Encroachment and Vapor Intrusion Studies
  • Hazardous Materials – For example in California, the California Unified Program Agency Requirements including Hazardous Materials Business Plans (HMBPs), Spill Control and Countermeasure Plans (SPCCs), and Hazardous Materials Inventories;
  • Sustainable Materials -Recycling, Reuse, and Repurposing of Materials;
  • Waste: Organic, Solid, Hazardous and other Wastes;
  • Geographic Information Services (GIS) -Spatial Databases; GPS Inventories, plots, varietal blocks and soils maps, vineyard development; and
  • Occupational Safety and Health – Facility Health and Safety Plans, Safety and OSHA Compliance Audits, Injury and Illness Prevention Programs.

 

SCS is pleased to announce we are the newest member of WIN, the Wine Industry Network.

SCS is a member in good standing. We help clients in California, Virginia, New York, and across the nation with environmental, packaging, recycling, and energy conservation challenges.
SCS is a member in good standing. We help clients in California, Virginia, New York, and across the nation with environmental, packaging, recycling, and energy conservation challenges.

 

SCS Engineers offers sustainable environmental solutions to businesses with environmental challenges. SCS provides these services to private and public sector clients through a network of nationwide offices. For more information about SCS, please visit our website at www.scsengineers.com, or contact us at service@scsengineers.com.

Posted by Diane Samuels at 9:24 am
Tag Archives: california industrial general stormwater permit

Complying: CA Industrial General Permit – IGP Storm Water

March 4, 2016

Who needs to comply with California’s Industrial General Permit for storm water?

 

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:

  • Who needs to comply, including the required list of Standard Industry Classification (SIC) codes, which includes many businesses you would not suspect! List of businesses affected here.
  • Compliance basics – How and what to file
  • Can I get out of the permit?
  • Are there value creation opportunities to minimize cost and still comply with the permit?
  • Liability issues – Can I be fined? How Much? Will Environmental Non-Government Organizations target my business for lawsuits? What is my recourse?
  • If I am a tenant, what is my liability to a property owner and what steps should I take to protect myself?
  • If I am a property owner, am I liable? What steps should I take during a purchase or lease to protect myself and inform my tenants of their legal obligations?

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 service@scsengineers.com.

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.

Posted by Diane Samuels at 3:40 pm
Tag Archives: california industrial general stormwater permit

Storm Water Compliance and Fees for the Industrial General Permit

February 10, 2016

Stormwater_Header_SCS_EngineersBusinesses 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 Glen.osterhage@waterboards.ca.gov

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 asnyder@lamesalaw.com

The session is free and will cover these topics:

  • Who needs to comply, including the listed SIC or NAICs codes, and many businesses that previously did not need to comply.
  • Compliance basics – How and what to file.
  • Who is exempt from the permit?
  • What value creation opportunities are available to minimize cost and still comply
  • Liability issues – Can I be fined? How much? What is my recourse?
  • As a tenant, what is my liability to a property owner and what steps should I take to protect myself?
  • As a property owner, am I liable? What steps should I take during a purchase or lease to protect myself?

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

Posted by Diane Samuels at 9:36 am
Tag Archives: california industrial general stormwater permit

Industrial Environmental Association (IEA) in San Diego Names New Leadership

January 13, 2016

Chuck_Pryatel_SCS_engineers
Chuck Pryatel, REHS at SCS Engineers

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.

Posted by Diane Samuels at 6:00 am
Tag Archives: california industrial general stormwater permit

SCS Engineers IGP Alert: California Industrial General Permit – Potential Permit Fee Change

November 14, 2015

Stormwater-Wastewater_SCS_Engineers-Med
SCS stormwater professionals are available to assist newly required permittees with filing and compliance requirements.

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 cjones@scsengineers.com.

Stormwater Management Services

Posted by Diane Samuels at 6:00 am
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