Join the CTA Storm Water Compliance Group-Save Money & Help CTA

The Industrial General Permit (IGP) regulates facilities in California for storm water associated with industrial activities discharging to water of the United States. Transportation facilities that perform maintenance, including fueling and washing may need IGP coverage. The IGP allows compliance group programs for facilities with similar industrial activities and classifications, such as the California Trucking Association. Since 1999, NES has served as the Technical Group Leader for the California Trucking Association’s Storm Water Compliance Group Program (CTACG), one of the largest storm water compliance groups in the State of California. Joining the CTACG reduces individual member costs and enables a broader understanding of developing and implementing best management practices common to the trucking industry. As part of the annual CTACG membership fee of $1,595, NES provides members with the following storm water benefits that could save a facility thousands of dollars:

Members are provided with the documents necessary for implementing a cost effective Storm Water Pollution Prevention Program (SWPPP). As a member of the CTACG, a SWPPP template will be provided to facilitate the development of your SWPPP document. Preparation of the SWPPP outside of the compliance group could cost $2,000 - $6,000 (depending on the industrial operations at a facility). NES reviews member submitted documents to verify accuracy and completeness along with assistance in uploading documents electronically on the SMARTS Database. Permit support and document review services could range from $50 to $200 per hour (depending on the industrial operations at a facility).

Facilities are required to collect storm water to identify potential pollutants discharging from industrial activity areas. Facilities participating in the CTACG are required to collect two (2) samples per compliance year, representing a 50% reduction compared to facilities not in a Compliance Group. As part of the annual CTACG membership fee, member facilities are provided sampling kits, guidance documents, pre-paid shipping labels, and detailed reports of analytical results by NES. Typical cost for these services outside of the CTACG could range between $300 and $600 (depending on the industrial operations at a facility).

The Industrial General Permit (IGP) introduced significant changes to each facility’s storm water pollution prevention program. As the IGP requirements shift focus towards compliance, it is increasingly important to stay on top of the new storm water regulations. Members are provided semi-annual training classes and webinars by NES. Classes are typically offered in Northern & Southern California. Typical cost for these training services outside of the CTACG could range between $100 and $300 per attendee.

CTACG members receive an annual site visit by NES to assist with adherence to the IGP. These site visits are conducted by the Compliance Group Leaders and are geared towards preparing facilities for formal regulatory inspections by the Water Board. Each site visit includes a thorough review of storm water documents and a site walk to observe industrial activities performed onsite. Typical cost for these services outside of the CTACG could range between $300 and $800 (depending on the industrial operations at a facility).

Facilities that exceeded an instantaneous or annual Numerical Action Level (NAL) during the 2015-2016 reporting year, moved into Level 1 on July 1st for the exceeded parameter(s) (i.e. Total Suspended Solids). Level 1 facilities are required to obtain a Qualified Industrial Storm Water Practitioner (QISP) to perform an evaluation by October 1, 2016. NES staff are QISP certified and provide the following services to members at no additional cost: ERA Level 1 onsite evaluation, employee training and development of ERA Level 1 Report. The QISP will assist facilities in identifying pollution sources and implementing BMPs to correct issues. Facilities can elect to send employees to receive QISP training. However, the cost to train an in-house QISP is approximately $700 in certification courses plus at least 24 hours in labor to complete the process.