Significant changes are coming to the State Water Resources Control Board (State Water Board) Construction General Permit (CGP). Below is a summary of these changes and how Condor can help you prepare.
- Implementation of total Maximum Daily Loads (TMDL)
- Implementation of Statewide Trash Policy Requirements
- Passive Treatment Technologies
- Notice of Non-Applicability
- Sampling and monitoring Requirements
If your site is discharging to a watershed in which new TMDL’s have been issued, you may be required to sample for the constituents of concern. This expands testing requirements beyond the erosion and sediment requirements which were the main concerns in the past permits. This can increase costs substantially, from additional testing and sampling, to installing metal removing BMP controls to bring project discharge within the NEL and NAL’s
You may be required to install full capture systems in all storm drains if the site is unable to demonstrate compliance with trash reduction BMPs. Construction sites will need to implement trash controls that prevent anything larger than a cigarette butt from leaving the site.
For years, it’s been common practice to use cationic and anionic polyacrylamide- based flocculant chemicals in a passive treatment system to help reduce turbidity at a project site. The new permit may have a passive treatment provision, which is designed to provide a set of regulations for construction activities use of these treatment technologies. Passive treatment system plans will need to be prepared by a qualified stormwater professional.
If you are a construction site situated in an area where stormwater discharges to water that are not hydrologically connected to waters of the United States, you can apply for a Notice of Non-Applicability (NONA). With an accepted NONA, you will not need to follow the requirements of the Construction General Permit. To prove the non-connection to waters of the United States, you will need to have a certified hydrologist prove there is no connection.
QSD’ s and QSP’s will have increased roles and will be required to do increased on-site visual inspections. During phase changes at the construction site, any time a QSD is replaced, and twice yearly, the QSD will be required to visit the project site. The increase in QSD visits has eliminated the Rain Event Action Plan (REAP) and will no longer be sued in the new permit.
They also clarified language of a Qualifying Precipitation Event. Qualifying precipitation events continue with subsequent 24-hour periods that have precipitation of 0.25” or more forecast, and end with two consecutive 24 hour periods with less than 0.25” forecast.