How to apply for the Industrial General Permit (IGP)

The new Industrial General Permit has implemented Permit Registration Documents (PRDs) that are mandatory to obtain a proper permit. There is an online database similar to CERS – its the Storm Water Multiple Application and Report Tracking System (SMARTS) – to file necessary reports and documents. In order to receive a permit, a complete Notice of Intent with a Storm Water Pollution Prevention Plan, Site Map uploaded to SMARTS. Lastly, permit fees must be paid and will allow the discharger to be assigned a Waste Discharge Identification (WDID). As contractors, we can be added as Data Submitters. This allows us to work on the backend of your SMARTS account to upload documents, make changes, and send those documents/changes for your approval.

Permit Registration Documents

• SMARTS Registration for new Industrial General Permit NOI
• Legally Responsible Person SMARTS account
• Certify and submit the new NOI application
• Upload a Storm Water Pollution Prevention Plan
• Upload a Facility Site Map
• Providing invoice to pay State Water Board permit fee

Does my facility need an SWPPP?

If your facility operates and contributes to potentially contaminated storm water runoff, you are required to apply for an Industrial General Permit. If your facility operation has no outside exposure to storm water, you may qualify for an NEC General Permit, which does not require an SWPPP. Only a site map and a verification of a questionnaire to ensure no exposure of industrial materials to storm water is required.

What is the process like?

We begin with a free on-site evaluation, meet and greet. This allows us to generate an accurate quote depending on the length and complexity of the project. The SWPPP and Site Map are an integral component of the storm water program at your facility. The newly adopted General Permit has included a number of new requirements for the SWPPP, including increased sampling and minimum Best Management Practices.

How long after accepting a quote will it take to receive my SWPPP/Site Map?

Generally, two to three weeks (10-15 business days). When a Notice of Non-Compliance is sent for a non-filer or a deficient SWPPP, the Waterboards provide 30-60 calendar days to obtain a permit or corrective actions an SWPPP.

What if the operator needs more time to make adjustments?

We speak the same language as inspectors and have good working relationships with many of them. Asking for time extensions or providing the documentation we have on hand to buy more time is apart of the service we provide for clients.

How often am I required to revise the SWPPP and Site Map?

SWPPP’s are considered a living document and need to be revised whenever significant changes occur to the site. The site map and SWPPP need to correspond to the site at all times. Legally Responsible Personnel changes need to be documented on SMARTS as soon as possible.

Who submits the SWPPP?

As a contractor, we can be assigned as Data Submitters on SMARTS.

• Contractors are able to input nearly all the data and upload the documents we need to obtain a permit. We cannot submit documents on your behalf.
• Dischargers must assign an LRP (Legally Responsible Person) to submit/certify all required documentation.
• LRP’s are able to appoint a Duly Authorized Representative to act on their behalf for most submissions.

We have our own easy to follow guides that make the certification process very simple. Our clients run through submittal of documents in a matter of minutes!

What are the SWPPP Requirements?

• Facility Name and Contact Information
• Location Map
• Date SWPPP was prepared and date of each SWPPP amendment
• List of Industrial Materials
• Description and Assessment of Potential Pollution Sources for each Industrial Area
• Minimum BMPs
• Advanced BMPs
• Monitoring Implementation Plan
• Advanced BMPs, if applicable
• Date SWPPP was prepared and date of each SWPPP amendment
• Signed Certification

What should be included in the Facility Site Map?

A Facility Site Map depicts areas of industrial activity, storm water drainage areas, and sampling locations are required by the General Permit. We specialize in drafting Industrial Facility Site Maps that meet all General Permit requirements.

• Legend and notes that are legible
• Facility boundaries
• Drainage Areas
• Direction of flow
• Water Bodies on property
• Each area of industrial activity
• Sampling points and discharge locations
• Areas of Soil Erosion

Is your facility in Level 1 or Level 2 Status?

Permitted facilities must perform sampling, analysis, and report in accordance with the requirements of the General Permit and shall compare the results to the two types of NAL values. There are two types of potential NAL exceedances.

1. Annual NAL exceedance: The Discharger shall determine the average concentration for each parameter using the results of all the sampling and analytical results for the entire facility for the reporting year. The discharger shall compare the average concentration for each parameter to the corresponding annual benchmarks. An Annual NAL exceedance occurs when the average of all analytical results for a parameter from samples taken within a reporting year exceed the annual NAL value for that parameter listed.
2. • SMARTS automatically calculates the averages for you between July and August after submittal of all AdHoc Reports and Annual Report.
   • SMARTS will label the facility accordingly to the following: Baseline, Level 1 or Level 2 Status.

2. Instantaneous maximum NAL exceedance: The Discharger shall compare all sampling and analytical results from each distinct sample (individual or combined) as authorized to the corresponding instantaneous exceedance. This occurs when two or more analytical results from samples taken for any single parameter within a reporting year exceed the instantaneous maximum NAL value (for TSS and OG) or are outside of the instantaneous maximum NAL range for pH. This causes an instant movement up the status ladder.

How we can help your facility avoid Level 1 Status and Level 2 Status:

• We are able to assist your facility to avoid Level 1 and Level 2 Status through preventative and proactive measures.
  • Level 2 Status is not always avoidable if the source of the pollutant is not industrial. Level 2 Status does not necessarily mean the facility is polluting.
  • We have the resources available and understand the documentation necessary to prove outside or background interference.

• We will determine the most appropriate Best Management Practices for your operations and other recommendations to help meet benchmarks.

• While working together we read permit exemptions to find ways to place facilities into Sample Reductions instead of increased samples and technical reports.

Our educational background mixed with hundreds of site visits in wet and dry weather have allowed us to understand the different effects that operations found at industrial sites have on storm water samples.

Are you already in ERA Level 1/2 Status?

Our licensed Qualified Industrial Storm Water Practitioners and environmental engineers will work diligently to find sources of pollutants and bring them to your attention.

Meanwhile, we find the minimum requirements of the Waterboards to ensure they are satisfied and the facility doesn’t need to do any unnecessary work. We are willing to work closely with operators to help facilitate your facility returns to baseline status and potential sample reductions that come along with it!

Do I need a Qualified Industrial Storm Water Practitioner (QISP)?

Only required once a Discharge reaches Level 1 Status, a QISP is an individual assigned to ensure compliance with this General Permit or to assist New Dischargers with determining coverage eligibility for discharges to an impaired water body. Responsibilities include:

• Implementing the SWPPP
• Performing the Annual Comprehensive Facility Compliance Evaluation (Annual Evaluation)
• Assisting in preparing of Annual Reports
• Performing Exceedance Response Actions (ERAs) for Level 1 and Level 2 Status facilities
• Training appropriate Pollution Prevention Team members

Sidera has state licensed QISPs ready to evaluate your facility and provide the necessary recommendations to remedy the situation.

• New cases are being filed every day against facilities. Damages awarded in these cases can be hundreds of thousands.
  • Funds go to the Consent Decree, attorney’s fees, environmental project funding, 3rd party legal fees.
• Record requests can go back up to 5 years, what may be thought to be a small issue, in the permitting framework can cost up to $10,000 a day in court.
• If avoiding a consent agreement is not possible. We work with 3rd party groups, lawyers, and facilities to ensure the requirements of the consent agreement are met and no further penalties are faced.

We can save you the hassle of a consent agreement and help you stay compliant with the state and federal regulations./

Dischargers who have NOI coverage may register for NEC coverage at any time following completion of facility changes.

• NEC coverage is available on a facility-wide basis only, not for individual drainage areas or discharge locations.
• Generally, if any exposed industrial materials or activities exist, or have a potential to exist, anywhere at a facility, NEC coverage is not applicable to the facility.
• If the Regional Water Board determines that a facility does have exposure or the facility’s storm water discharges have a reasonable potential to cause or contribute to an exceedance of applicable water quality objectives/standards, the Regional Water Board can deny NEC coverage

We can assist you to evaluate your facility and operations to find out if you may apply for the No Exposure Certification and be except permit requirements.

• Complete Notice of Intent (NOI) application: includes Storm Water Pollution Prevention Plans (SWPPPs), Facility Site Map
• Prompt violation and non-compliance resolution
• Numeric Action level parameters monitoring
• Exceedance Response Action technical reports for Level 1 & 2 status
• 24/7 sampling service during storm events, sample pickups/lab analysis & SMARTS management
• Staff Best Management Practice & sampling training by in-house QISPs
• Monthly, quarterly, and annual evaluations, depending on needs
• Notice of Intent (NOI) & Annual Report (AR)
• Storm Water Pollution Prevention Plans, management and oversight

We work with you during our free on-site evaluation to find what suites your facility best.