Baseline Status

The Industrial General Permit (IGP) requires all dischargers to sample at least four times during a storm water year, twice in the first half (July 1 – December 31) and twice in the second half (January 1 – June 30).  At the beginning of permit coverage, all dischargers have Baseline status for each of the parameters that are required to be tested.  At the end of the storm water year, the average concentration of each parameter is calculated using the results from all rain events that were sampled at the facility. If any of these averages exceed the Annual Numeric Action Levels (NALs) or if two or more results from individual samples exceed the Instantaneous Maximum NALs which are predetermined by the Water Board, then the facility is placed in Level 1 Status for that parameter. Level 1 status begins on July 1st of the following Storm Water Year. Due to Level 1 Status the discharger is required to complete a Level 1 Exceedance Response Action (ERA) Evaluation with the help of a Qualified Industrial Storm Water Practitioner (QISP) and submit a Level 1 ERA Report that is written by a QISP. The main purpose of the evaluation and report is to identify the sources of pollutants and to determine which Best Management Practices (BMPs) can be implemented to reduce the concentration of the parameters that were exceeding. The discharger can return to Baseline for each parameter if sample results from at least four consecutive samples indicate no additional NAL exceedances. There are many types of Basic BMPs and advanced BMPs that can help with the mitigation of a variety of pollutants. Frog Environmental consultants and QISPs are highly educated in using BMPs to reduce exceedances and can assist with determining what types of BMPs are best for your facility and where they should be implemented.  Call today or click here for a complimentary site assessment.

Level 1 Status: 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, 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.

→ Click here for more ERA Level 1 Status Information.

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 Status and Level 2 Status

Level 2 ERA (Exceedance Response Action) 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.

→ Click here for more BMP Information.