California Industrial General Permit (IGP) — Frequently Asked Questions
A copy of the California Industrial General Permit (Order WQ 2014-0057-DWQ, as amended by Orders WQ 2015-0122-DWQ and WQ 2018-0028-DWQ) is available here for download and review.
Disclaimer: The questions and answers below are provided for general informational purposes. Regulatory interpretations may change in response to permit amendments, new case law, or Water Board guidance. For interpretations specific to your facility, consult EMC or your Regional Water Quality Control Board.
Material handling and storage, equipment maintenance and cleaning, and other activities at industrial facilities are often exposed to the weather. Runoff from rainfall or snowmelt that comes in contact with these activities can pick up pollutants and transport them directly to a nearby river, lake, stream, or coastal water — or indirectly via a storm sewer — and degrade water quality.
Federal regulations at 40 CFR 122.26(b)(14)(i)–(xi) require stormwater discharges associated with specific categories of industrial activity to be covered under National Pollutant Discharge Elimination System (NPDES) permits, unless otherwise excluded. In California, this federal requirement is implemented through the Industrial General Permit (IGP).
A broad range of industrial facilities are required to obtain permit coverage under federal regulations. Facilities required to obtain coverage include manufacturing facilities, mining operations, disposal sites, recycling yards, transportation facilities, and other industrial operations identified in Attachment A of the IGP.
Regional Water Boards are also authorized to designate facilities that must obtain coverage under the IGP, even if those facilities are not specifically listed in Attachment A. See permit Section XIX.F for designation details.
If you are uncertain whether your facility’s Standard Industrial Classification (SIC) code triggers IGP coverage, contact EMC or your Regional Water Quality Control Board for an evaluation.
All Dischargers operating facilities described in Attachment A of the IGP, or designated by the Regional Water Board, must submit either a Notice of Intent (NOI) to obtain permit coverage or a No Exposure Certification (NEC) certifying that no industrial pollutants associated with their industry are exposed to stormwater. The NOI or NEC must be submitted at least seven days prior to the commencement of industrial activities.
The facility operator submits the NOI for each industrial facility required by U.S. EPA regulations to obtain a stormwater permit. The facility operator is typically the owner of the business or operation where the regulated industrial activities occur, and is responsible for all permit-related activities at the facility.
Where industrial operations have been discontinued but significant materials remain on site (such as closed landfills), the landowner may be responsible for filing the NOI and complying with the IGP. Landowners may also file an NOI for a facility if the landowner — rather than the facility operator — is responsible for compliance.
Dischargers operating the following types of facilities are not required to file for IGP coverage, unless designated by the Regional Water Board:
- Facilities not described in Attachment A of the IGP
- Facilities described in Attachment A but not discharging stormwater associated with industrial activity to waters of the United States (see permit Section XX.C)
- Facilities already covered by another NPDES permit for stormwater discharges associated with industrial activity
File the NOI or NEC through the State Water Board’s Stormwater Multiple Application and Report Tracking System (SMARTS). Only a Legally Responsible Person (LRP) — typically a facility owner, corporate officer, or designated principal executive — can certify and submit the NOI application or NEC certification.
A complete NOI submittal includes:
- A completed NOI application
- A Site Map (see permit Section X.E)
- A Storm Water Pollution Prevention Plan (SWPPP) (see permit Section X)
- A signed Electronic Authorization Form
- The applicable Application Fee
A complete NEC submittal includes:
- A completed NEC Application and NEC Checklist
- A Site Map (see permit Section X.E)
- A signed Electronic Authorization Form
- The applicable Application Fee
IGP application fees are updated annually by the State Water Resources Control Board. Current fee schedules are available on the State Water Board’s Water Quality Fees page.
- NOI fees are paid annually on the billing cycle established when the NOI was originally processed.
- NEC fees are paid each time the NEC is recertified. Dischargers must annually recertify the NEC.
- Checks should be made payable to: SWRCB.
Yes. Once a complete NOI submittal — including the NOI application, Site Map, SWPPP, and applicable fee — has been submitted and processed, the State Water Board will issue a Waste Discharge Identification (WDID) Number. The WDID is the facility’s unique permit identifier and is used in all subsequent SMARTS submittals and reporting.
Coverage under the IGP remains in effect until one of the following occurs:
- The Discharger submits a valid Notice of Termination (NOT) through SMARTS and the NOT is accepted by the Regional Water Board.
- Order WQ 2014-0057-DWQ expires (without administrative extension) or is superseded by a future order.
The Regional Water Quality Control Board may deny an NOT if the termination request is determined to be invalid — for example, if industrial activities subject to permit coverage are still occurring at the facility.
The WDID is not transferable. When a facility changes ownership or operator, the previous owner or operator must file a Notice of Termination, and the new owner or operator must file a new Notice of Intent to obtain a new WDID.
EMC supports facility ownership transitions by coordinating the timing of the outgoing NOT and incoming NOI to minimize coverage gaps.
Qualified Storm Event (QSE) Sampling. Dischargers must collect stormwater runoff samples during QSEs at each discharge location, with the following minimum sampling targets per reporting year:
- Standard sampling frequency: A minimum of four (4) QSE samples per discharge location — two in the first half of the reporting year (July 1 – December 31) and two in the second half (January 1 – June 30).
- Reduced sampling frequency: Facilities with a valid Sampling Frequency Reduction Certification under permit Section XI.C.6, or facilities participating in a Compliance Group, may reduce QSE sampling to a minimum of two (2) samples per discharge location per reporting year.
Minimum sampling targets are contingent on the occurrence of QSEs at the facility. If fewer QSEs produce qualifying discharge events than the minimum target, the Discharger documents the shortfall in the Annual Report rather than failing compliance.
Samples must be analyzed by a State-certified laboratory.
Dischargers are required to monitor stormwater discharges from their facility to identify pollutants that may affect water quality, human health, or the environment. Sampling results are compared against Numeric Action Levels (NALs) and, where applicable, Numeric Effluent Limits (NELs) established by the IGP.
Samples must be representative of stormwater associated with industrial activities, any authorized non-stormwater discharges (NSWDs), and contained stormwater released from the facility.
The IGP establishes Numeric Action Levels (NALs) for specific pollutants. NALs are not effluent limits — exceeding an NAL is not, by itself, a permit violation — but exceedances trigger escalating response obligations under the Exceedance Response Action (ERA) framework.
There are two types of NAL exceedances:
- Annual NAL exceedance: The annual average of all sampling results for a parameter exceeds the annual NAL.
- Instantaneous Maximum NAL exceedance: Two or more sampling results for a parameter exceed the instantaneous maximum NAL within a single reporting year.
When a facility experiences an NAL exceedance, the following reporting year the facility enters Level 1 ERA status. Level 1 status requires the Discharger to engage a Qualified Industrial Stormwater Practitioner (QISP) to evaluate the source of the exceedance, review the adequacy of existing Best Management Practices (BMPs), and prepare a Level 1 ERA Report for SMARTS submittal.
If exceedances continue, the facility advances to Level 2 ERA status, which requires a QISP-prepared Level 2 ERA Action Plan and Level 2 ERA Technical Report. Level 2 status carries additional documentation obligations and ongoing technical oversight until exceedances are resolved.
EMC provides QISP-led ERA services for facilities at every level of the response process. See QISP & ERA Services on the Services page for details.
The IGP Annual Report is due July 15 of each year, covering the prior reporting year (July 1 through June 30). The report is filed through SMARTS and must be certified and submitted by the facility’s Legally Responsible Person (LRP).
A complete Annual Report includes:
- All Qualified Storm Event (QSE) sampling results for the reporting year
- Monthly Visual Observation records for all twelve months of the reporting year
- Annual Comprehensive Site Compliance Evaluation (ACSCE) findings
- Documentation of BMP implementation and any BMP modifications
- Records of any NAL or Numeric Effluent Limit (NEL) exceedances and associated corrective actions
- SWPPP revisions, if any, made during the reporting year
- Any Level 1 or Level 2 ERA documentation, if applicable
Because the Annual Report consolidates twelve months of compliance data into a single SMARTS submittal, EMC recommends maintaining records throughout the reporting year rather than assembling them in late June. Late or incomplete Annual Reports are among the most common compliance findings cited during Regional Water Board reviews.
EMC supports clients with Annual Report preparation and SMARTS submittal in advance of the July 15 deadline. See Stormwater Compliance & Training on the Services page.
A Qualified Industrial Stormwater Practitioner (QISP) is an individual who has completed the State Water Board’s QISP training and registration process and is qualified to support facilities with specific compliance obligations under the IGP.
QISP involvement is required when a facility enters Level 1 ERA status following an NAL exceedance. The QISP is responsible for:
- Evaluating the source of the exceedance
- Reviewing the adequacy of the facility’s existing BMPs
- Preparing the Level 1 ERA Report for SMARTS submittal
- Preparing Level 2 ERA Action Plans and Technical Reports if the facility advances to Level 2 status
The QISP may be a facility employee who has completed the State Water Board’s training, or an external consultant retained for ERA services. For most facilities, retaining an external QISP is more cost-effective than training internal staff, particularly when ERA obligations are episodic rather than ongoing.
EMC’s services are QISP-led. See QISP & ERA Services on the Services page for details on Level 1 and Level 2 support.
Mandatory Minimum Penalties (MMPs) are statutory penalties established under California Water Code Section 13385(h)–(i) for specified categories of NPDES permit violations. Unlike discretionary penalties, MMPs are mandatory — the Regional Water Board is required to impose them when triggering violations are confirmed, with limited exceptions.
Common MMP triggers under the IGP include:
- Chronic violations: Four or more violations of the same effluent limit within a six-month period
- Serious violations: A single effluent limit violation exceeding the limit by 40 percent (toxic pollutants) or 20 percent (conventional pollutants)
- Reporting violations: Specified failures to submit required reports or monitoring data
The current MMP amount is $3,000 per violation, and individual penalty assessments can accumulate quickly when chronic exceedances are involved.
The most effective MMP avoidance strategy is consistent, documented compliance:
- Submit Annual Reports and other required SMARTS documents on time
- Conduct Monthly Visual Observations every month and maintain the records
- Address NAL exceedances early through Level 1 ERA evaluation, before they progress to NEL exceedances
- Maintain and update the SWPPP to reflect actual site conditions and BMP implementation
EMC’s compliance services are designed to support facilities in maintaining the documentation and reporting practices that prevent MMP exposure.
The Industrial General Permit and the CERS Hazardous Materials Business Plan are two independent regulatory programs that apply to many of the same California industrial facilities. Understanding how they interact helps facility operators avoid duplicative work and identify documentation that can serve both programs.
Different regulatory frameworks:
- The IGP is a stormwater discharge permit under the federal Clean Water Act (Section 402(p)) and California’s Porter-Cologne Water Quality Control Act, administered by the State Water Resources Control Board and Regional Water Quality Control Boards.
- The CERS HMBP is a hazardous materials handling and emergency response program under California Health and Safety Code Chapter 6.95, administered by local Certified Unified Program Agencies (CUPAs).
Different triggering thresholds:
- IGP coverage is triggered by industrial activity classification (SIC codes listed in Attachment A of the IGP) and stormwater discharge to waters of the United States.
- HMBP submittal is triggered by hazardous materials inventory thresholds — generally, 55 gallons of liquid, 500 pounds of solid, or 200 cubic feet of compressed gas, with lower thresholds for certain regulated substances.
Areas of operational overlap:
- Site maps: Both programs require detailed facility site maps, though with different content emphases. The IGP focuses on drainage areas, BMPs, and discharge locations; the HMBP focuses on hazardous materials storage areas, secondary containment, and emergency response equipment. A well-prepared site map can serve as the foundation for both submittals.
- Hazardous materials inventories: The HMBP inventory and the IGP’s Pollutant Source Assessment (a SWPPP element) often involve the same materials, evaluated through different regulatory lenses.
- Emergency response documentation: HMBP Emergency Response Plans and IGP spill response procedures address overlapping but distinct emergency scenarios.
Facilities subject to both programs benefit from coordinated documentation strategies. EMC provides both IGP and CERS HMBP services and supports clients in maintaining consistent, mutually reinforcing documentation across both programs.
Contact EMC for IGP and HMBP Compliance Support
EMC supports industrial facilities throughout California with regulatory consulting tailored to your operations and permit status. Call (323) 244-7260 or request a free consultation to discuss your facility’s compliance needs.
