Stormwater Management Considerations for CWA Third-Party Citizen Suits

Description

California’s Industrial General Stormwater Permit became effective July 1, 2015. After four years of working through the assessment and reporting programs with new Exceedance Response Actions (ERAs), business owners are still struggling to come to grips with the ever changing conditions and compliance risks associated with this permit. With the most recent amendment including the adoption of total maximum daily load (TMDL) requirements, businesses face greater challenges with soon to come numeric effluent limits. Regional Water Quality Control Board (RWQCB) inspections and Clean Water Act (CWA) third-party citizen lawsuits make storm water compliance in California even more challenging. Permitting requirements for constructed Best Management Practices (BMPs) devices need to consider compliance with both stormwater and groundwater infiltration regulations, engineering concerns, permitting with local building codes and health department agency requirements. This presentation will provide real world compliance concerns for facilities trying to implement stormwater capture and use systems as a result of Permit requirements and third-party citizen suit actions.