Thursday, July 19, 2012

Cost Analysis For Compliance With Revised Industrial Permit

The California State Water Resources Control Board (State Water Board) has released its cost analysis comparing estimated costs associated with the current Industrial General Permit (ICP), the draft revised permit issued in 2011, and the draft revised permit issued in July 2012. The purpose of the analysis is to provide an estimate of the compliance costs associated with the State Water Board’s Statewide General Permit for Discharges of Storm Water Associated with Industrial Activity (IGP).

Read a summary of the 2012 California IGP:

The key finding of the report are that the average annual cost of compliance of the 2012 permit for facilities with no exceedances would increase between 5% and 12% compared to the annual cost of compliance with the 1997 IGP. Annual average cost of compliance with the new permit depends on multiple factors including size of operations, location, and level of exceedances. Staff estimated annual compliance costs for the 1997 IGP to range between $23,000 to approximately $137,000. For facilities with no exceedances, compliance with the 2012 draft will cost between $25,000 and approximately $155,000 annually.

The increase in compliance costs would be more significant for those facilities with exceedances. Staff does not expect a significant increase in compliance costs for those facilities with no exceedances. Facilities with exceedances would see a more significant increase in costs to bring the facility in compliance. Facilities with Level 1 status (one NAL exceedance) would face an additional annual average cost between $97 and $622. Facilities with Level 2 status (second NAL exceedance for same parameter) would face an additional annual average cost between $1,138 and up to $38,641.

The annual average cost of compliance with the 2012 draft is approximately half (50% less) of what the 2011 draft originally required. Based on Water Board staff’s best judgment, the most likely scenario is that 50% of facilities will have no exceedances, 50% of facilities will reach Level 1, and 25% will reach Level 2. Using this assumption, the total annual average compliance costs of the 2012 draft as compared to the 1997 IGP would be increased by approximately 7% for industry as a whole.

The most commented upon elements of the draft 2011 IGP were the proposed numeric effluent limitations (NELs), the increased number of reportable inspections and/or visual observations, and the compulsory training requirements. In response to these comments, NELs have been eliminated, revisions and clarification were made so that the number of inspections and visual observations are the same as the 1997 IGP (with the exception of pre-storm visual observations), and the compulsory training requirement has been simplified. Additionally, a new ERA system has been proposed that (1) more narrowly focuses on those facilities with the highest concentrations of pollutants, and (2) allows dischargers to avoid costly structural or treatment controls if it is proven that the pollutant concentrations are related to non-industrial sources, natural background conditions, or if the facility is already in compliance with BAT/BCT.

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

For further information contact Caltha LLP at or Caltha LLP Website

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