Qualified SWPPP Developer & Qualified SWPPP Practitioner Requirements Under Draft California Permit

UPDATE: On July 16, 2012, an updated draft was released. Click here for a summary of the revised draft ICP

On January 28, 2011, the California State Water Resources Control Board released its draft General Permit for stormwater discharges associated with industrial activities. The draft NPDES permit proposes several changes from the existing California General Permit.

One of the important changes will be especially significant for facilities that have in the past prepared their own stormwater pollution prevention plan (SWPPP). Under the proposed permit, all dischargers will need to appoint a Qualified SWPPP Developer (QSD) to prepare, write, and make any revisions to the SWPPP, and appoint a Qualified SWPPP Practitioner (QSP) to help implement the SWPPP.

The minimum requirements to become a certified Qualified SWPPP Developer includes have one of the following registrations for certifications, and appropriate experience, as required for:

• California registered professional civil engineer;
• California registered professional geologist or engineering geologist;
• California registered landscape architect;
• Professional hydrologist registered through the American Institute of Hydrology;

In addition, the QSD must successfully complete the State Water Board-sponsored or approved QSD training course within one year after the effective date of this General Permit.

Unless a facility has a registered engineer, geologist, landscape artitict, or professional hydrologist on staff, facilities subject to the permit will need to contract outside professional services to prepare, certify and update the SWPPP.

The minimum requirement to become a certified Qualified SWPPP Practitioner is to successfully complete the State Water Board-sponsored or approved QSP training course within one year from the effective date of the General Permit.
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Numeric Action Levels, Numeric Effluent Limits, and Corrective Action Triggers In California Draft Permit

UPDATE: On July 16, 2012, an updated draft was released. Click here for a summary of the revised draft ICP

On January 28, 2011, the California State Water Resources Control Board proposed a draft industrial stormwater discharge general permit. The draft General Permit amends a number of the existing requirements for permitted facilities and adds some new requirements.

One of the more significant changes to the California General NPDES Permit is the incorporation of quantitative Action Levels and Effluent Limits which could apply to any discharger:


Numeric Action Levels (NALs) are derived from the US EPA Multi-Sector General Permit’s benchmarks, and are used as numeric thresholds for corrective action. Exceedances of an NAL are not a violation of the permit; however, exceedance of specific NAL Corrective Action Triggers requires the facility to enter into Level 1 Corrective Action.

[More information on US EPA benchmarks, and comparison to historic industrial sector monitoring results]


Numeric Effluent Limits (NELs) are could also apply to any facility. Dischargers in Corrective Action Level 3 (see below) are subject to a numeric effluent limitation (NEL) that will be the same value as the applicable pollutant NAL. A daily average exceedance of the NEL is a violation of the General Permit and may subject the discharger to mandatory minimum penalties.

NAL Corrective Action Triggers are defined in the draft general permit as follows:
1. The Daily Average (DA) for any one constituent exceeds the NAL value for two or more storm events of a reporting year, or;
2. The DA for any two constituents exceed the NAL values for any single storm event within a reporting year, or;
3. The concentration for any one constituent exceeds 2.5 times the NAL value for any one individual or allowable combined sample (or is more than one pH unit outside the NAL pH range)

In the event that any of the NAL Corrective Action Triggers are met, the facility will need to complete Level 1 Corrective Actions. The need to do further corrective actions will depend on subsequent monitoring results.


Level 1 - Operational Source Control Corrective ActionsUpon the first occurrence meeting any of the NAL corrective action triggers, the discharger will be required to valuate areas of the facility to identify where additional operational source control BMPs and/or SWPPP implementation measures are necessary to prevent or reduce pollutants in storm water discharges in compliance with BAT/BCT. Based upon the facility evaluation, the facility will certify that the pollutant source(s) have been identified and 1) additional operational source control BMPs and/or SWPPP implementation measures have been included in the SWPPP , 2) no additional operational source control BMPs or SWPPP implementation measures are required , or 3) pollutant source(s) causing the exceedance are not related to the facility’s industrial activities. A Level 1 NAL Exceedance Evaluation Report will need to be prepared and submitted.
Level 2 Structural and/or Treatment Corrective ActionsIf in any subsequent reporting year the sampling results meet an NAL corrective action trigger, the discharger is require to take addition action. If the NAL corrective action trigger is for a constituent that had not been included in a previous Level 1 NAL Exceedance Evaluation Report, the discharger go through Level 1 Corrective Actions.
If the NAL corrective action trigger is for one or more of the constituents previously addressed in a Level 1 NAL Exceedance Evaluation Report, the discharger would need to evaluate and select additional structural source control BMPs and/or treatment BMPs with the goal of achieving the applicable NAL value(s) in future discharges. A Level 2 NAL Exceedance Evaluation Report will need to be prepared and submitted and more frequent monitoring is required.
Level 3 Imposition of Numeric Effluent LimitsIf in any subsequent reporting year the sampling results meet an NAL corrective action trigger for the same constituents subject to the Level 2 corrective actions, the discharger shall the applicable NAL(s) will become an NEL(s), and starting October 1 of the following compliance year, the discharger will be required to sample every qualifying storm event.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.comorCaltha LLP Website