Is Your Facility Headed for ERA Level 1 Status?
What You Need to Know NOW About Level 1 Status under the New Industrial General Permit for the Upcoming Storm Water Year
If your business falls under the category of Industrial, the California State Water Resources Control Board requires stormwater compliance with the Industrial General Permit for all storm water runoff exposed to industrial activity. Facilities with high enough NAL Exceedances for the 2015-2016 storm water year fall into ERA Level 1 Status for the 2016-2017 storm water Year. Here’s what you need to know to prepare.
What Does ERA Level 1 Require?
- An ERA Level 1 Evaluation by a QISP about the facility’s pollutant sources and drainage areas must be completed by October 1st, 2016
- The evaluation will specify BMPs to prevent future NAL Exceedances
- An ERA Level 1 Report prepared by a QISP must be completed by January 1st, 2017
- The report will describe SWPPP revisions and additional BMPs
- The report must be prepared by a QISP and be certified and submitted via the SMARTS database
What Does ERA Level 2 Require?
- Level 2 includes an Exceedance Response Action Plan prepared by a QISP.
- A specific demonstration must be chosen and performed for each new NAL exceedance.
- Level 2 also includes an Exceeedance Response Action Technical Report to be prepared by QISP, including a demonstration such as an Industrial Activity BMPs Demonstration, a Non-Industrial Pollutant Source Demonstration or a Natural Background Pollutant Source Demonstration
Take Action Now. If your facility is about to be raised to ERA Level 1 Status for the upcoming stormwater year, there are many steps to take immediately to avoid ERA Level 2 Status the following year.
If you are remaining at Baseline Status, the proactive approach is to guard your Baseline Status and do everything that can be done to ensure continued compliance to stay at Baseline Status. In either situation, the best course of action is to implement appropriate Best Management Practices (BMPs) as soon as possible. Affordable Basic BMPs can be your first line of defense against exceedances.
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Level 1: How Can My Facility Return to Baseline?
If your facility has recently been designated as Level 1 Status due to an Annual Average or Instantaneous Maximum Numeric Action Level (NAL) exceedance during the 2015-2016 stormwater year, Frog Environmental is here to help.
Return to Baseline
By achieving four clean samples in a row, industrial companies can return to baseline and avoid the costly reporting or QISP oversight required by Level 1 or Level 2 Status. Frog Environmental specializes in assisting facilities like yours. Step one is cleaning up pollutants with a BMP Plan designed and engineered to move your facility out of Level 1 Status.
BMPs Lower Results
Our custom, individualized analysis of your site will reveal the BMPs needed to reduce exceedances and return to Baseline Status. Our Stormwater Consultants are experts in environmental compliance and will provide personal support, along with technical analysis to ensure your employees are trained and ready to achieve stormwater compliance.
Take Action Now
Contact Frog Environmental immediately at 310-241-0866 to schedule a site evaluation to get your facility on the road to recovery from Level 1 Status.
Strategies for Success: Using BMPs to Lower Sample Results
The Right BMPs for the Job
Depending on how far above the Numeric Action Level (NAL) your sample results may be, different types of BMPs may be dictated to improve sample results, allowing your facility to return to Baseline. Basic BMPs typically reduce NAL Exceedances by approximately 30%, while Intermediate BMPs often attain 60% reductions in NAL sample results. An Advanced BMP, such as Stormwater Treatment is guaranteed to reduce NAL Exceedances by as much as 90%.
Looking Ahead to Level 1 and 2
Level 2 Requirements include mandatory Advanced BMPs. This means facilities will be in a position where they may be forced to implement Treatment, Containment or Sheltering BMPs. While Containment and Sheltering are not always practical or possible depending on space and industrial limitations, Treatment is usually a viable solution. However, if your facility can implement Basic and Intermediate BMPs to reduce exceedances, you may avoid Level 1 and Level 2 Status.
California Stormwater Management (SWPPP)
California Storm Water Management and Treatment Consultants, Frog Env Inc., services all of California with over 15 years of expertise in Industrial Stormwater Permits. As a Storm Water Treatment provider, we offer services for Permit application (Notice of Intent- NOI), SWPPP (Storm Water Pollution Prevention Plan) development, Monitoring Plan development, Runoff Sampling, Training, Annual Reports, Permit termination (Notice of Termination- NOT), and all other aspects of Industrial Stormwater Consulting. Our “hands-on” approach produces compliance with California storm water Permit regulations and Regional Water Quality Control Boards.
Frog Env Inc. offers a FREE on-site evaluation of your current Stormwater Program, including analysis of your facility SWPPP and Best Management Practices (BMPs). Our certified technicians shall identify potential pollutant sources and recommend BMPs for reducing the associated potential pollutants. Frog Environmental will train your pollution prevention team about new BMPs and implementation of a Monitoring Plan; which includes all California mandated discharge monitoring, sampling, and lab analysis (under the NPDES – National Pollutant Discharge Elimination System).
Frog Env Inc. will assemble, compose, and submit your Annual Report by the July 1 deadline to the appropriate SWRCB (State Water Resource Control Board) or RWQCB (Regional Water Quality Control Board). A stamped receipt is provided as proof of filing.
As a combined staff, Frog Env, Inc. has over 50 years of experience in Stormwater and other environmental areas. Please refer to our “Other Consulting” Tab for information about additional services provided.
For information about Storm Water Treatment Systems, please visit Storm Water Systems