Compliance Deadline Alert for all California industrial businesses with Notice of Intent (NOI) coverage under the California Industrial General Permit (IGP) for stormwater who recently entered Level 1 status after July 1st, 2020.

Have you received notice from the State Water Board regarding an IGP Level 1 Numeric Action Level Exceedance?

Following July 1st, the end of each reporting year, the Storm Water Multiple Application & Report Tracking System (SMARTS) database assigns a regulatory “Level” status to each industrial facility based on their stormwater monitoring data submitted during the past reporting period.

A discharger’s Baseline status for a given parameter in their sampling and analysis suite will change to Level 1 status if sampling results from the previous year show a Numeric Action Level (NAL) exceedance for that same parameter. Level 1 status will commence on July 1st following the reporting year during which the exceedance(s) occurred.

Per the IGP Section XII.C., once a facility enters Level 1 status, an Exceedance Response Action (ERA) Evaluation must be performed and a Level 1 ERA Report must be filed with the State Water Board via submission to the SMARTS database.

Oct. 1, 2020: ERA Level 1 Evaluation Deadline

The facility evaluation must take place by October 1st of the reporting period following the reporting year during which the NAL exceedance occurred. This evaluation, conducted with the assistance of a Qualified Industrial Storm Water Practitioner (QISP), will consist of an assessment of the industrial pollutant sources at the facility that may have perpetuated the associated NAL exceedance(s) and should identify the corresponding Best Management Practices (BMPs) for these pollutant sources, and any additional BMPs supplemented for implementation to prevent future NAL exceedances. Although the evaluation may focus on the drainage areas where the NAL exceedance(s) occurred, all drainage areas shall be evaluated.

Jan. 1, 2021: Level 1 ERA Report Deadline

Based upon the evaluation, the discharger shall file the Level 1 ERA Report in SMARTS by January 1st following commencement of Level 1 status, as prepared by a QISP. The Level 1 ERA Report is a comprehensive facility analysis and extensive BMP evaluation focusing on the potential sources of the NAL exceedance, the discharge point(s) where the exceedance occurred, and a determination of what actions and BMPs are to be taken in order to prevent future exceedances. The discharger should update their Storm Water Pollution Prevention Plan (SWPPP) with these additional BMPs following their implementation.

Per the IGP Section XII.C.2.b., a discharger’s Level 1 status for a parameter will return to Baseline status once a Level 1 ERA report has been completed, all identified additional BMPs have been implemented, and results from four (4) consecutive Qualified Storm Events (QSEs) that were sampled subsequent to BMP implementation indicate no additional NAL exceedances for that parameter.

What should I do if my facility enters ERA Level 1 Status?

KERAMIDA’s seven QISP-certified California stormwater consultants can provide your business with effective solutions to mitigate the efforts and cost of compliance. If your facility has recently entered Level 1 status, our California experts are readily available to conduct your ERA Level 1 Evaluation and prepare the ERA Level 1 Report to ensure both compliance deadlines are met.

KERAMIDA’s GIS mapping solutions can document stormwater activities at your facility on an interactive figure and map, which provides an easy, user-friendly, and effective way to stay on top of your stormwater compliance needs.

For assistance with management, IGP compliance, and industrial stormwater permitting, contact us or call KERAMIDA’s California-based Senior Project Managers, Jodie Crandell, QISP, TOR at (916) 202-3480 or Ron Hayes, QISP, TOR at (818) 626-8614 regarding your stormwater compliance efforts.

Contact:

Jodie Crandell, QISP, QEP, TOR
Senior Project Manager
KERAMIDA Inc.

Contact Jodie at jcrandell@keramida.com.