1. Is my facility required to obtain Permit coverage?

Facilities that fall under one of the categories in Attachment A of the California Industrial General Storm Water Permit (IGP) must legally apply for coverage.  


The Permit groups facilities required to apply for coverage within the following categories:

  • Manufacturing facilities
  • Oil & gas/mining facilities
  • Hazardous waste treatment sites
  • Landfills
  • Recycling facilities
  • Electric power plants
  • Transportation companies
  • Sewage treatment plants
  • Facilities with subchapter N effluent standards (refineries/fertilizer manufacturing)

Standard Industrial Classification (SIC) code generally determines whether a facility falls within one of these categories.  A facility’s SIC Code(s) can be determined by referencing https://www.osha.gov/data/sic-manual or other online source.


Contact Frog for assistance determining Permit applicability. 

2. How do I apply for Permit coverage?

Coverage is applied for online on the Water Board’s Storm Water Multiple Application and Report Tracking System (SMARTS).  The required Permit Registration Documents (PRDs) must be submitted to complete the application and obtain coverage.  PRDs include Notice of Intent (NOI), signed Electronic Authorization Form, and Permit compliant Site Maps and Storm Water Pollution Prevention Plan (SWPPP). 

3. Is my facility eligible for No Exposure Certification (NEC)?

A facility that falls within one of the required categories in Attachment A of the  California Industrial General Storm Water Permit can be eligible for NEC coverage.  If a facility’s industrial materials and activities are not exposed to storm water, they are NEC eligible and exempt from some of the Permit requirements such as preparing a Stormwater Pollution Prevention Plan (SWPPP) and performing monitoring. 


Contact Frog for assistance determining NEC eligibility. 

4. How do I apply for No Exposure Certification (NEC) coverage?

Coverage is applied for online on the Water Board’s Storm Water Multiple Application and Report Tracking System (SMARTS).  The required Permit Registration Documents (PRDs) must be submitted to complete the application and obtain coverage.  PRDs include the NEC form, NEC Checklist, and compliant Site Map. 


NEC eligibility must be verified and re-certified annually by October 1st

5. What could happen if required facility does not obtain Permit coverage?

Non-filers can face fines and penalties from the Water Board and are at risk for potentially costly litigation from third-party organizations.


Also, Senate Bill 205 became effective January 1, 2020 and requires a person applying to a city or county for a new or renewed business license to demonstrate enrollment in a National Pollutant Discharge Elimination System (NPDES) storm water permit, if such a permit is required.

6. How do I navigate SMARTS?

The State Water Resources Control Board (SWRCB) guide was developed to assist Permittees submitting their NOIs, NECs, NOTs, AD Hoc Reports, Annual Reports, and other required documentation.  In addition to compliance documents, SMARTS is used to access all Permit related documentation such as fee statements, receipt letters, inspection documentation, enforcement actions, and even ERA status. 


The State Water Resource Control Board SMARTS user guide can be accessed here.

7. When do I need a QISP?

New Dischargers applying for NOI coverage under this General Permit that will be discharging to a water body with a 303(d) listed impairment are ineligible for coverage unless the Discharger submits required data and/or information, prepared by a Qualified Industrial Stormwater Practitioner (QISP).

Additionally, QISP certification is required to conduct several actions if a discharger is elevated above baseline status into Exceedance Response Action (ERA) Level 1 or Level 2 status for any parameters.  A QISP is required to complete the evaluations, reports, and training that are required for these elevated level statuses.

Frog has 17 QISPs ready to assist. 

8. What happens if I exceed IGP Numeric Action Levels?

If a facility exceeds the Numeric Action Levels (NALs) for their industrial storm water parameters, the facility's status will change from Baseline Status to Exceedance Response Action (ERA) Level 1, or to Level 2 status from Level 1 by July 1st of the new storm water year. 

For exceeded parameters, a facility is required to complete an evaluation of contributing pollutant sources and identify Best Management Practices (BMPs) needed to eliminate the exceedances.  A Qualified Industrial Stormwater Practitioner (QISP) is required to perform this evaluation.  A QISP is also required to prepare the Level 1 ERA Report or Level 2 ERA Action Plan and facility training.  A QISP prepared Technical Report is also required for Level 2 ERA status. 

9. What is an Exceedance?

There are two ways to exceed Permit Numeric Action Levels (NALs):


Annual NAL exceedance: The Discharger shall determine the average concentration for each parameter using the results of all the sampling and analytical results for the entire facility for the reporting year (i.e., all "effluent" data). The Discharger shall compare the average concentration for each parameter to the corresponding annual NAL values in Table 2.  An annual NAL exceedance occurs when the average of all the analytical results for a parameter from samples taken within a reporting year exceeds the annual NAL value for that parameter listed in Table 2.


Instantaneous maximum NAL/TNAL exceedance: The Discharger shall compare all sampling and analytical results from each distinct sample to the corresponding instantaneous maximum NAL values in Table 2 and TNAL values in Attachment E, Table E-2. An instantaneous maximum NAL/TNAL exceedance occurs when two (2) or more analytical results from samples taken for any single parameter within a reporting year exceed the instantaneous maximum NAL/TNAL value or are outside of the instantaneous maximum NAL range for pH.


Frog can help determine whether your facility is in exceedance of the Permit NALs. 

10. What parameters are my facility supposed to analyze storm water samples for?

Every NOI facility regulated under the Industrial General Permit is required to analyze for pH, Oil and Grease, and TSS (Total Suspended Solids).

However, a facility may be required to analyze for additional analytical parameters based on its Standard Industrial Classification (SIC) Code.  This information can be found in Table 1 of the IGP.

A facility may also be required to analyze for additional parameters based on their potential pollutant source assessment or if they discharge to an impaired waterbody.  This includes assessing for Total Maximum Daily Load (TMDL) applicability. 

11. Do Total Maximum Daily Loads (TMDLs) apply to my facility?

Contact Frog to perform the required in-depth facility assessment and applicable requirements, if any. 

12. When am I supposed to sample at my facility?

Dischargers are required to sample Qualifying Storm Events (QSEs) in accordance with the IGP.  The IGP defines a QSE as a precipitation event that:

  1. Produces a discharge for at least one drainage area; and,
  2. Is preceded by 48 hours with no discharge from any drainage area.

Sample collection is required during scheduled facility operating hours from each drainage location within four hours of:

  1. The start of the discharge from a QSE occurring during scheduled facility operating hours, or
  2. The start of scheduled facility operating hours if the QSE occurred in the previous twelve (12) hours.
13. How many times am I supposed to sample?

Facilities are required to collect and analyze four (4) total storm water samples.  Two (2) Qualified Storm Events (QSEs) within the first half of each reporting year (July 1 to December 31), and two (2) QSEs within the second half of each reporting year (January 1 to June 30).