Keep runoff from your facility from becoming a permit violation.
Facilities that discharge stormwater associated with industrial activity are generally required to obtain permit coverage under the Clean Water Act's National Pollutant Discharge Elimination System (NPDES) program. Vanguard prepares Stormwater Pollution Prevention Plans (SWPPPs), files permit applications, and manages ongoing monitoring and reporting obligations for facilities nationwide – including California's state-specific SMARTS system.
Who Needs Stormwater Runoff Permitting?
You likely need stormwater permit coverage if your facility:
- Falls within one of the EPA's designated industrial sectors (manufacturing, metal recycling, chemical storage, transportation, and others) with outdoor material storage, loading, or processing areas
- Has outdoor areas where materials, waste, or equipment are exposed to rain or snowmelt
- Discharges stormwater to a municipal storm sewer system, ditch, or nearby waterway
- Is located in California, where the State Water Resources Control Board requires permit coverage and reporting through the SMARTS (Storm Water Multiple Application and Report Tracking System) portal
California's SMARTS System
California handles industrial stormwater permitting differently than most states. Instead of filing directly with the EPA, California facilities must register, file, and report through the state's online SMARTS (Storm Water Multiple Application and Report Tracking System) portal, administered by the State Water Resources Control Board.
- Notice of Intent (NOI): Initial registration for coverage under California's General Industrial Stormwater Permit, filed through SMARTS
- Annual Reporting: California requires an Annual Report filed through SMARTS by July 1st each year, summarizing monitoring results and compliance status
- Numeric Action Levels (NALs) & Effluent Limitations: California's permit includes specific benchmark thresholds that trigger additional response actions if exceeded
- Qualified SWPPP Developer/Practitioner (QSD/QSP) Requirements: California requires SWPPPs to be developed and certain inspections to be conducted by state-certified QSD/QSP professionals
Vanguard manages SMARTS registration, filings, and annual reporting directly for California clients, in addition to standard federal/state permitting elsewhere.
Vanguard Service Areas
Vanguard supports stormwater permitting for facilities nationwide, with particular depth in states with active industrial stormwater enforcement, including:
- California (SMARTS system) • Texas (Dallas/Ft. Worth, Houston)
- Illinois (Chicagoland) • Arizona (Phoenix)
- Ohio (Cincinnati/Dayton) • Florida (Tampa/St. Petersburg)
- Oklahoma (Tulsa/Oklahoma City)
Frequently Asked Questions
Do I need a stormwater permit if I don't discharge directly to a river or lake?
Yes, in most cases. Discharging to a municipal storm sewer system that eventually reaches a waterway still requires permit coverage under most federal and state programs.
What is a SWPPP, and do I need one?
A Stormwater Pollution Prevention Plan (SWPPP) is a site-specific document identifying pollutant sources and control measures. It's required as part of permit coverage in nearly all industrial stormwater programs, including California's General Industrial Permit.
How is California's SMARTS system different from other states?
California requires registration, monitoring data, and annual reporting to be filed directly through its online SMARTS portal, with its own Numeric Action Levels and QSD/QSP certification requirements – distinct from the federal NPDES framework used in most other states.
How often do I need to sample or monitor stormwater discharge?
Sampling frequency depends on your permit type and state program, but many industrial permits require sampling after qualifying rain events, with results compared against benchmark thresholds.
What happens if my facility exceeds a benchmark or Numeric Action Level?
Exceedances typically trigger additional required actions, such as updating your SWPPP, increasing monitoring frequency, or implementing additional best management practices, depending on your state's program.
Can Vanguard handle stormwater permitting alongside our other environmental compliance work?
Yes. Many Vanguard clients manage stormwater permitting together with RCRA, SARA, and TRI compliance under a single ongoing relationship.
Let Vanguard Manage Your Stormwater Compliance
Don't let an unpermitted discharge or missed SMARTS filing turn into an enforcement issue. Call (918) 641-5588 or contact us to schedule a stormwater applicability review.