State Water Resources Control Board
Division of Water Quality
Industrial/Construction Storm Water
Unit
PRESENTATION GOAL
 To provide information on the
regulations of the industrial storm
water program.
 Not intended to cover every situation
but to discuss the storm water
program and answer questions.
 Provide information on how to stay
informed.
PRESENTATION OUTLINE
 Federal Regulations
 Storm Water Associated with Industrial
Activities
 Permit Coverages and Requirements:
• Notice of Intent (NOI)
• No Exposure Certification
 Notice of Non-Applicability(NONA)
HISTORY ON REGULATION
November 16, 1990
 U.S. EPA promulgated compliance with Section 402 of
the Clean Water Act, requiring Industrial Activities to
obtain coverage under the National Pollutant
Discharge Elimination System (NPDES) for storm
water discharges.
 U.S. EPA defined industrial activities: Manufacturing
of Beverages: Standard Industrial Classification
Codes 2082-2087 Beverages (Wine Making under
2084)
 California Water Boards is the designated authority to
implement the NPDES program.
SCHEDULE
 April 17, 1997 - June 30, 2015
• 97-03-DWQ Industrial Permit expired

April 1, 2014
• State Water Board adopted the new Industrial
General Permit
 Early 2000s
• Outreach letter was sent to wineries in California,
notifying the operators of the regulations
• Around 200 wineries obtained coverage
• Group Monitoring formed for wineries (mainly in
Napa county)
SCHEDULE
 July 1, 2015
• 2014-0057-DWQ Industrial General Permit effective
• Reissuance of the Industrial General Permit went
through about a decade of public comment and
review
• No changes were made to the regulated industry
sectors (2084 for wine manufacturing was in the
1997 permit and in the 2014 permit)
SCHEDULE

Summer 2015
• The State Water Resources Control Board discussed the
regulations with the Wine Institute, the California Family
Winemakers Association, and the California Farm Bureau.

July 3, 2015
• The State Water Resources Control Board had database
issues and proposed the extension of the date to file for
coverage to August 14, 2015, this extension was approved.

July 31, 2015
• The State Water Resources Control Board sent out an
information letter to wineries.

Currently
• Assisting wineries and other permittees with compliance
assistance.
Manufacturing Activities –
conducted at an industrial facility?
Waste
Discharge
Requirements?
Research Triangle Institute
http://www.greenbiz.com/sites/default/files/document/O16F2388.pdf
STORM WATER ASSOCIATED WITH
INDUSTRIAL ACTIVITIES
 The discharge from any conveyance of
storm water from industrial manufacturing,
processing, or raw materials storage
areas as identified in Attachment A of the
Industrial General Permit.
 Discharges to a Waters of the United
States(e.g. lakes, creeks, rivers, streams).
 Includes storm water discharges as
defined at 40 C.F.R. section 401.
ATTACHMENT A
STORM WATER ASSOCIATED WITH
INDUSTRIAL ACTIVITIES

Currently about 9,500 facilities (food
manufacturing, auto dismantlers, metal fabrication,
landfills etc.) have an active permit.

About 230 wineries have an active permit.

Based upon definition of industrial activity, not size
or location.

The industrial activity is the mainly the grape
crushing/pressing, fermentation, and clarifying

Sorting and aging can be included if at the
industrial facility.

Vineyards/harvest is not an industrial activity.
INDUSTRIAL GENERAL PERMIT
COVERAGE
When is a Notice of Intent Required
 Is activity identified in Attachment A?
 Is there a discharge of storm water
associated with industrial activity to a
Water of the United States?
 Is there exposure of industrial
activities/materials to precipitation?
INDUSTRIAL GENERAL PERMIT
COVERAGE
Notice of Intent (NOI) Requirements
 Storm Water Pollution Prevention Plan
 Site Map
 Electronic Application and Reporting
 Visual Observations
 Best Management Practices
 Storm Water Sampling (when there is a discharge)
 Annual Report
 Annual fee ($1, 632)
COMPLIANCE GROUPS
 Facilities with similar industrial activities,
pollutant sources and pollutant characteristics
can form a group.
 Most helpful for facilities with NOIs, sampling
reduction and centralized assistance from
Compliance Group Leader.
 2 groups exist for wineries, more could form.
 Intended to provide comprehensive compliance
assistance for an industrial sector (not 1-2
facilities at a time) and resource sharing.
INDUSTRIAL GENERAL PERMIT
COVERAGE
No Exposure Certification (NEC)
Requirements
 Is activity identified in Attachment A?
 Is there a discharge of storm water
associated with industrial activity to a
Water of the United States?
 Has all the exposure of industrial
activities/materials to precipitation been
eliminated?
INDUSTRIAL GENERAL PERMIT
COVERAGE
NEC Requirements
 Facility complies with criteria in NEC
Section XVII of the Industrial General
Permit (all year)
 Site Map
 Electronic Application and Reporting
 Annual fee ($200)
NEC Checklist
 Checklist - no exposure for industrial materials/activities,
nothing exposed to precipitation:
 Unauthorized Non Storm Water Discharges are eliminated Using, storing
or cleaning industrial machinery or equipment;
 Materials or residuals on the ground or in storm water inlets from
spills/leaks;
 Materials or products from past industrial activity;
 Material handling equipment (except adequately maintained vehicles);
 Materials or products during loading/unloading or transporting activities;
 Materials or products stored outdoors - except final products intended
for outside use;
 Materials contained in open/deteriorated/leaking storage drums, barrels,
tanks (etc);
 Materials or products handled/stored on roads or railways
 Waste material;
 Application or disposal of processed wastewater (unless already
covered by an NPDES permit);
 Particulate matter/visible deposits of residuals on roof.
What About?
Roof vents/Stacks?
Shipping and receiving?
Outdoor storage?
 Is your crush pad exposed
to rain water?
 Are your tanks exposed to
rain water?
 Do you land apply pomace
without special permit?
 Do you irrigate with wash
water without a special
permit?
 Do you store used barrels
outdoors?
 Do you load and unload
bins outdoors?
 Do you clean your tanks or
barrels outdoors?
 Have all unauthorized
NSWD been eliminated?
 Do you have material
tracking at the facility
Considerations for some of the
NEC criteria
 Do you store used barrels
outdoors?
Can they be stored inside?
 Do you load and unload bins
outdoors?
Can well-secured tarps be used or
unload bins under cover?
 Do you clean your tanks or barrels
outdoors?
Can they be cleaned in areas of other
process water?
 Do you have material tracking at
the facility?
How could industrial materials leave
immediate access of industrial
facility?
Considerations for some of the
NEC criteria
 Do you store used barrels
outdoors?
Can they be stored inside?
 Do you load and unload bins
outdoors?
Can well-secured tarps be used or
unload bins under cover?
 Do you clean your tanks or barrels
outdoors?
Can they be cleaned in areas of
other process water?
 Do you have material tracking at
the facility?
How could industrial materials leave
immediate access of industrial
facility?
What about a crush
pad outside, can it be
covered?
Notice of Non-Applicability (NONA)
There may be many reasons or combinations of reasons there
is no discharge of storm water associated with industrial
activities to waters of the U.S.
Some example scenarios:
 The industrial area and immediate access area is extremely
small, designed to not discharge, is surrounded by
vineyards that absorb any potential storm water runoff, the
nearest water of the U.S. is not nearby.
 The winery has a retention pond for its process water and
all storm water associated with industrial activity is routed to
the retention pond (treated as process water). The water
from the retention pond is used to irrigate the surrounding
vineyards in accordance with a WDR.
 The winery is in an area that is not hydrologically connected
to waters of the U.S.
Notice of Non-Applicability (NONA)
 The Regional Board can determine whether or not the
Industrial General Permit applies, or if a NONA is required.
 Under the Industrial General Permit, dischargers have to file a
NONA with a technical report demonstrating no discharge only
upon request by the Regional Boards pursuant to Water Code
13399.30.
 If the NONA is not required by the Regional Water Board, the
discharger is not required to take any action and obtain permit
coverage.
 Note: Even if there is no discharge to waters of the U.S., the
State and Regional Water Boards retain the authority to
regulate discharges to waters of the state, but any such
regulation would be separate from coverage under this permit.
Notice of Non-Applicability (NONA)
 If conditions change and the discharger anticipates that it
will start to discharge storm water associated with
industrial activities to waters of the U.S., then the
discharger must file for IGP permit coverage (NOI or
NEC).
 If additional information is discovered that indicates that
the discharger was mistaken and it discharges to waters
of the U.S. (or if the information provided was
inaccurate), the discharger must obtain IGP permit
coverage (NOI or NEC). The discharger would be liable
for any storm water discharges to waters of the U.S.
 We are not providing authorization for or exemptions for
any past, current, or future discharges to waters of the
U.S.
NONA – No Discharge
Technical Report
 Facility constructed to have no Discharge
or
 Facility located in a basin or other physical location that
is not hydrologically connected to waters of the United
States
 California Licensed Professional Engineer required to
sign technical report
RESOURCES
Get informed: Email list!
http://www.swrcb.ca.gov/water_issues/programs/stormwater/
>Subscribe online to our electronic mailing lists.
>Select Water Quality Topics
>Select Storm Water Industrial Permitting Issues
>Enter email address and hit subscribe
Industrial General Storm Water Program Page
http://www.swrcb.ca.gov/water_issues/programs/stormwater/industrial.
shtml
•Help Guide for the Electronic database
•Permit resources
•Contact information
Thank you
Laurel Warddrip
lwarddrip@waterboards.ca.gov
916-341-5531