For industrial facilities in California that operate under the Industrial General Permit (IGP), June 30th 2016 marks the end of a new and interesting year. From July 1, 2015 to June 30, 2016, these facilities have been operating under a new IGP with increased sampling requirements, minimum BMPs, and Numeric Action Levels (NALs). The final steps in their journey this year are the Annual Comprehensive Facility Compliance Evaluation (Annual Evaluation) and Annual Report. The Annual Evaluation is required to consist of the following:
Review of all sampling, visual observation and inspection records conducted during the previous reporting year;
Inspection of all industrial activity areas and potential pollutant sources for evidence of, or potential for, pollutants to enter the stormwater system;
Inspection of all drainage areas previously identified as having no exposure to industrial activities and materials;
Inspection of equipment needed to implement the BMPs; and
Review and assessment of all BMPs and potential pollutant sources to determine if the BMPs are properly designed, implemented, and effective in reducing and preventing pollutants in stormwater discharges.
The Annual Evaluation under the IGP is used to review and improve your industrial stormwater program for the upcoming year and also as part of the Annual Report process. Areas of non-compliance and updates done during the year to the Stormwater Pollution Prevention Plan (SWPPP) will need to be included with your industrial stormwater Annual Report checklist.
The Annual Report is done via a series of 26 questions in SMARTS and is required to be completed by July 15, 2016. In addition to the questions, which are yes/no with areas of explanation, a compliance checklist, which details areas of non-compliance and updates to the SWPPP will also need to be attached to your industrial stormwater Annual Report in SMARTS.
If your monitoring data has exceedances of Numeric Action Levels (NALs) for the year, you will need to address them via the Exceedance Response Action (ERA) process.