These last two winters have produced record rainfall, and there were plenty of qualifying storm events (QSE) for each of our clients to produce sufficient samples to comply with their reporting requirements under their Industrial Stormwater General Permit. However, we found that some clients did not obtain the requisite number of samples and received violations via mail.
California agencies communicate with each other
The local water agencies obtain their information from both the Regional Water Quality and California State Water Resources Control Board. They also share information with weather and county officials. There is ample data available (number of QSEs, total number of weekdays with rainfall, total inches of rain) to generate a notice of violation for any permit holder in California who did not comply. In other words, one cannot fool Mother Nature.
So, why are we discussing this during July?
The abundance of rainfall over the past few seasons could easily lead to complacency. For a time just a few months ago, it felt that dry weather would never arrive and that stormwater sampling opportunities would be limitless. There is no guarantee our upcoming winter will produce the same amount of rainfall as the past two years. Mid-summer weather models are showing a trend for a slight La Niña state. We need to prepare ourselves for the first storm of the season. Most permits require two samples between July 1 and December 31, and two more between January 1 and June 30.
It’s also important to remember that monthly visual observations of the drainage areas are still required, even during the dry season.
Finally, for our clients in the City of Alameda
The City of Alameda has announced plans to launch a Trash Load Reduction Program to prevent trash and pollutants in private storm drains from entering the City’s storm drains and local waterways. This is facilitated by one of two methods:
- The installation and maintenance of a Full Trash Capture (FTC) device (essentially a grate/screen) to filter out debris from stormwater.
- Additional trash mitigation measures: increased inspections, litter pick-up, street sweeping, etc.. For those facilities that are unable to meet a low trash generation standard, then mandatory installation of FTC devices may be required.
CDMS’s Role:
Stormwater training and plan development is offered to our California clients. Please reach out to service@cdms.com to schedule an evaluation if you think your facility may be subject to the stormwater requirements.
