Business Objective

ALG was contracted by a large-scale distributor to develop site specific plans and training in accordance with the requirements of the new California General Industrial Stormwater Permit (General Permit). The project involved mapping the storm water drainage system, developing individual monitoring implementation plans, prepare and upload the storm water permit registration documents, and conducting initial assessments of site hydrologically disconnected from waters of the US for each distribution facility within California. Upon completion of these initial task, ALG was further contracted to prepare the final Stormwater Pollution Prevention Plans (SWPPPs) and prepare the final Monitoring Implementation Plans (MIPs) for the approximately 100 sites required to file a Notice of Intent (NOI), and the Notice of Non-Applicability (NONA) technical reports for a subset of facilities found to be disconnected from Waters of the United States. ALG was also responsible for the submittal of all required permit registration documents to the Water Board's online Storm Water Multiple Application and Reports Tracking System (SMARTS).

In addition to updating the stormwater monitoring plans, ALG was contracted to develop a Learning Management System (LMS) e-learning tool to train the distribution company's staff on the requirements of the new stormwater permit. ALG developed an efficient method to create site-specific training materials for over 100 facilities.

Technical Approach

ALG developed a cost-effective method to complete approximately 100 comprehensive site evaluations, mapping, and plan preparation for Californian distribution facilities. The client provided ALG with copies of the existing stormwater plans and facility maps, from which ALG updated as a part of each facility site inspection. In coordination with a separate contractor specializing in mapping, the updated stormwater maps were digitized for inclusion in the necessary plans and permits.

Based on the individual site inspections, ALG updated the MIPs for each facility. These plans had previously been based on an outdated template that did not reflect the broad array of new requirements under the General Permit. ALG successfully incorporated the nuances in facility design and operation and the logistical difficulties of collecting stormwater samples into the MIP to accurately reflect actual operations. To determine the receiving water body and evaluate associated water quality impairments, ALG developed a GIS tool, which employed elevation data and other publicly available hydrology information to accurately determine the receiving water body for each facility.

Upon completion of the MIPs, ALG was provided multiple SWPPP templates based on six types of distribution facilities operated by the distributor. ALG developed a method to populate each of these templates with site-specific information gathered during the site visits. This enabled ALG to efficiently manage site-specific data and ultimately generate over 100 SWPPP documents.

To ensure the proper implementation of the updated plans and permits, ALG developed a series of training modules specific to each type of operation. One series was developed for site operators and pollution prevention team members, and a second module was developed for management and office staff. The training modules were made available online in order to reduce training costs, allow for rapid delivery of the new training, and simplify electronic records management. The online training system incorporated Knowledge Checks, which required staff to properly answer questions before moving forward in the training, or continue reviewing a section to ensure sufficient understanding of the topic before moving forward.

Results

ALG efficiently completed all required aspects of this project by their respective deadlines. This included the following:

• Submittal of all required permit registration documents by the applicable deadline for the facilities obtaining Notice of Intent (NOI) permit coverage. This included a completed site map, SWPPP, and other required information for each facility.

• Submittal of all required No Exposure Certification (NEC) documents by the applicable deadline for facilities certifying NEC coverage.

• Analyzing the applicability Notice of Non-Applicability (NONA) status for a number of potential NONA candidate facilities, and managing the completion of technical reports for each applicable facility prior to the July 1, 2015 NOI deadline.

• Development of site-specific industrial stormwater e-learning materials for both staff and management use.

ALG effectively managed this large and complex project by developing and executing a practical and efficient approach. As a result, over 100 industrial facilities are appropriately registered for the General Permit. It is important to note that the General Permit was a new, complex, and often controversial regulation at the time of its adoption. Because of ALG's comprehensive understanding of the General Permit requirements and its real-world applications, the client was able to start the permit term in compliance.