Challenges and Lessons Learned in Implementing the LA MS4 Permit Industrial Facility Control Program with Transition to New Industrial General Permit and Numeric WLAs for TMDLs
This presentation will share issues and challenges encountered while implementing the Industrial Facility Control Programs consistent with 2012 LA MS4 Permit requirements and consider the implications for these programs in the context of the new Industrial General Permit (IGP) and 303d listings/TMDLs. These insights were garnered based on field assessments at more than 400 industrial facilities across a range of industrial categories from large railroad yards and heavy manufacturing facilities, to warehousing and light industrial manufacturing.
In part to meet the explicit requirements of the 2012 LA MS4 Permit, but also to facilitate industrial facility inventory data management and reporting, an off-the-shelf smart phone/tablet-enabled GIS cloud-based software application was utilized. The smart phone/tablet software was used to conduct the field assessments, update the database from the field, and document non-compliant conditions with photographs uploaded from the field. This presentation will share some of the issues encountered in customizing the software application to meet specific MS4 Permit requirements, as well as lessons learned and recommendations regarding features to consider when comparing and procuring such off-the-shelf software.
The LA MS4 Permit requires that the MS4 Permitee verify that each applicable industrial facility has a current Waste Discharge Identification (WDID) number for coverage under the IGP or a current No Exposure Certification and if not, that the facility owner/operator be notified that they must obtain coverage under the IGP as well as referring these “non-filing” facilities to the Regional Water Quality Control Board. The LA MS4 Permit also requires MS4 Permittees to verify the validity of No Exposure Certifications. These requirements were established in anticipation of but prior to the adoption of the new IGP and there are a number of regulatory challenges and practical issues that may result for facilities which lie within a 303d-listed watershed and/or a watershed for which a TMDL is in effect for pollutants of concern generated by the facility. Regional Board staff and MS4 Permittees engaged in the MS4 Permit renewal process as well as managers of industrial facilities within 303d-listed watersheds may find this information of particular interest.