-Water Quality Permitting and Compliance

Water Quality Permitting and Compliance

Stormwater Pollution Prevention Plan (SWPPP)

The Clean Water Act (CWA) is implemented by the Environmental Protection Agency (EPA) to help preserve and improve water quality standards by regulating facilities that discharge pollutants to surface water. California has additional regulatory requirements by which contractors, developers, and site owners must comply. A Stormwater Pollution Prevention Plan (SWPPP) is a written document that identifies all of the activities and conditions at a site that could cause water pollution. It outlines the steps that will be taken to prevent the discharge of any unpermitted pollution, how it will avoid exceeding Numeric Action Levels (NALs), and how the company plans to comply with all federal, state and local regulations. The SWPPP is a site-specific “live” document and must be updated as conditions at the facility change.
Federal Compliance:
Regulated facilities are required to obtain a National Pollutant Discharge Elimination System (NPDES) permit. If your facility is not located in a state with an EPA-approved state program, you must comply with the Federal Multi-Sector General Permit (MSGP) for stormwater discharges associated with industrial activity. The MSGP requires the development of an SWPPP that illustrates how the facility will comply with the terms of their NPDES permit, conduct required trainings, and provide sample stormwater discharges and reports to the EPA.

Federal stormwater regulations require industrial facilities included in any of the following categories to acquire an NPDES stormwater permit:

A permit is required for:

• Manufacturing 
• Mineral, metal, oil, and gas
• Hazardous waste treatment or disposal facilities 
• Landfills
• Recycling facilities
• Organization electric plants
• Transportation facilities
• Treatment works
• Construction activities
• Light industrial activity

Please contact one of our QISP’s for more information on SWPPPs or for a free proposal.

Call (559) 379-6029

Industries that required an SWPPP:

• Air Transportation
• Asphalt/Roofing
• Chemical Products
• Coal Mines
• Electronic, photo goods
• Fabricated Metal Products
• Food Products
• Furniture and Fixtures
• Glass, Clay, Cement
• Hazardous Waste
• Land Transportation
• Landfills
• Leather Tanning/ Finishing
• Metal Mining
• Mineral Mining

• Oil and Gas
• Paper Products
• Primary Metals
• Printing, Publishing
• Rubber, Misc. Plastics
• Salvage Yards
• Scrap Recycling
• Ship/Boat Building, Repair
• Steam Electric Facilities
• Textile Mills
• Timber Products
• Transportation Equipment
• Treatment Works (WWTPs)
• Water Transportation

What Requires a Permit

• Manufacturing 
• Mineral, metal, oil, and gas
• Hazardous waste treatment or disposal facilities 
• Landfills
• Recycling facilities
• Organization electric plants
• Transportation facilities
• Treatment works
• Construction activities
• Light industrial activity

State Compliance
Additionally, many states are authorized by the federal government to issue NPDES permits directly, along with any other state requirements. Businesses in California are regulated by the State Water Resources Control Board (SWRCB), which is authorized to implement the Federal Clean Water Act (CWA) and California’s Porter-Cologne Water Quality Control Act to protect surface water, groundwater and wetlands. An Industrial General Permit (IGP) is required to regulate stormwater discharges in the state’s nine regions, and an SWPPP must be developed to illustrate how the facility will comply with regulations and terms of the IGP.

Facilities are also required to perform water sampling and file an annual stormwater report. It is critical that the following businesses closely comply with these requirements:

Manufacturing Facilities

Hazardous Waste Treatment, Storage, or Disposal Facilities

Landfills, Land Application Sites, and Open Dumps

Recycling Facilities (salvage yards, metal scrap yards, vehicle dismantlers)

Transportation Facilities (airports, vehicle maintenance shops, equipment cleaning operations)

Sewage or Wastewater Treatment Works

We Can Help You Stay in Compliance
Pacific Engineering & Consulting can provide your organization with stormwater related compliance services and help you understand these requirements to ensure your company meets all local, state and federal regulations. From water sampling to plan development and reporting, our experienced team has helped hundreds of businesses throughout the state meet their compliance requirements. We work effectively with all California Regional Water Quality Control Boards (RWQCB), as well as many other similar agencies across the United States. Contact one of our Qualified Industrial Stormwater Practitioners (QISP) to help you develop an effective plan and decide which best management practices to incorporate and implement. Or if you already have a SWPPP in place, we can review and update the document to ensure that your current practices and procedures are in full compliance.
Compliance

• Manufacturing Facilities
• Hazardous Waste Treatment, Storage, or Disposal Facilities
• Landfills, Land Application Sites, and Open Dumps
• Recycling Facilities (salvage yards, metal scrap yards, vehicle dismantlers)
• Transportation Facilities (airports, vehicle maintenance shops, equipment cleaning operations)
• Sewage or Wastewater Treatment Works

The Consequences of Non-Compliance

Administrative and/or civil penalties may be issued up to $70,000 per day, per violation if a facility fails to comply with the outlined conditions, standards, and time schedules. Our qualified and experienced engineers have helped hundreds of clients better understand their compliance requirements and avoid costly fines and penalties. Let’s Get In Touch

Compliance Status Levels

Level 1 and Level 2 Status – ERA (Exceedance Response Action)

Additional requirements may be assigned to a facility that has been given Level 1 status due to an annual NAL exceedance, or two exceedances. Level 1 requirements include:

• Facility oversight by a Qualified Industrial Stormwater Practitioner (QISP)
• Implementation of additional best management practices (BMPs) to address pollutants in stormwater runoff
• A Level 1 ERA Report submitted online via the SMARTS database

A facility at Level 1 status can quickly escalate to Level 2 status if just one water sample provided in the upcoming stormwater year exceeds acceptable NALs.

Please contact one of our QISPs for more information on Level 1 / Level 2 Reports or for a free proposal.

Call (559) 379-6029

If a business is designated Level 2 status, additional costly obligations will be required including:

Additional requirements may be assigned to a facility that has been given Level 1 status due to an annual NAL exceedance, or two exceedances. Level 1 requirements include:

• A Level 2 ERA plan developed by a QISP that must be submitted to the SMARTS database by January 1st of the stormwater year following the exceedance
  
  
• Advanced BMPs required
• Stormwater treatment may be necessary to reduce exceedances below NAL levels
• A Level 2 Discharger will be required to submit a Level 2 Technical report prepared by a QISP that must be submitted via the SMARTS database

Facilities must comply with the IGP to avoid costly lawsuits from environmental groups and non-compliance penalties from government regulators. Our team of experienced QISPs can help your facility maintain applicable exceedance parameters and prevent the unnecessary escalation of your compliance status.
Contact us today to learn more, and how we can assist with Level 1 and Level 2 reports if needed

Notice of Non-Applicability (NONA)

Do you have an on-site stormwater pond or is your facility in a region that does not discharge to Waters of the United States (WOTUS)? You might qualify for a NONA, which would make your facility completely exempt from permitting under the CWA.

Pacific Engineering & Consulting can help you determine if your facility is exempt by evaluating the hydraulics and hydrology of your site and running a continuous simulation model to determine if the pond would ever discharge to WOTUS. If your facility meets all requirements, our specialists can provide your organization with a
No Discharge Technical Report, which must be prepared and signed by a California licensed professional engineer and submitted with the NONA application on the SMARTS database.

No Exposure Certification (NEC)

Are all your industrial materials and operations contained and protected by a storm-resistant shelter? Then you might be eligible for a No Exposure Certification (NEC), an alternative compliance path that is far less burdensome. All industrial categories, except construction, are eligible to apply for the NEC exclusion. You may qualify for the NEC if your facility has been evaluated and can certify that there is no exposure of industrial activities and materials in eleven major areas, now or in the foreseeable future. If eligible, Pacific Engineering & Consulting can file this report for your organization annually, and you will simply pay a nominal fee to the SWRCB.

Contact one of our QISPs who can help you determine if your facility qualifies for either of these exclusions.

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