Receiving Water Impairments, the ERA Process, and Challenges to Implementing Advanced BMPs
Receiving waters across the state of California are impaired for a wide variety of pollutants from nutrients and fecal indicators to more persistent compounds such as metals and polychlorinated biphenyls. When the IGP says “…shall not cause or contribute to an exceedance of any applicable water quality standards in any affected receiving water,” how do stormwater practitioners evaluate a facility whether for a New Discharger or as part of an Exceedance Response Action? When a discharger has been found to be in violation of a Receiving Water Limitation, they are required to go beyond BAT/BCT, if necessary, regardless of the economical practicability of such measures. This presentation discusses issues that may arise from receiving water impairments and the re-opening of TMDLs as we move forward under the new IGP particularly with difficult pollutants that are both environmentally persistent and with extremely low water quality objectives (e.g., PCBs). Also, treatment options for selected pollutants will be reviewed.
For over twenty years, Mr. Zucca has had lead roles for a wide range of stormwater projects, including litigation support for clients subject to citizen lawsuits und the Clean Water Act, compliance evaluations of large industrial facilities, design and construction management of stormwater treatment system. Mr. Zucca is currently part of a fifteen-person team participating in the State Water Resources Control Board’s Industrial General Permit Training Team (“IGPTT”), which is the group responsible for developing the training program for the newly created “Qualified Industrial Stormwater Practitioner” position under the SWRCB’s General Permit for Stormwater Discharges associated Industrial Activities. Mr. Zucca has given numerous presentations regarding IGP to industry associations and lobbying groups to assist the regulated community in preparing for permit compliance.