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Level 1 ERA Report / Evaluation by QISP -Exceedance Response Actions 2017-02-19T10:19:49+00:00

What You Need to Know About Industrial General Permit Enforcement

How Does a Facility Enter Level 1 or 2 ERA Status?

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.

The California Industrial General Permit (IGP) sets Numeric Action Levels (NALs) that serve as limits for pollutant parameters. If a facility’s storm water samples exceed those limits via annual averages or instantaneous maximums, that facility’s status will be elevated to Level 1. If the same facility continues to exceed the following stormwater year, it will then become Level 2 status. Facilities can become Level 1 or 2 status for each individual parameter they test for, if the limits of each parameter are exceeded. Level 1 and Level 2 are designed to trigger the implementation of additional Best Management Practices (BMPs) to reduce pollutant levels at industrial facilities. Due to the adoption of a new IGP, 2015-2016 and 2016-2017 are the first two storm water years in which facilities can enter Level 1 status or Level 2 status. However, facilities can enter Level 1 status and Level 2 status in any subsequent storm water year depending on their status and exceedances.

What are the Consequences of Entering Level 1 or Level 2 Status?

Level 1 Status
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 Water Board via the Storm Water Multiple Application & Report Tracking System (SMARTS) database. The facility evaluation must take place by October 1st of the storm water year following the reporting year during which the NAL exceedance occurred. The Level 1 ERA Report must be filed by January 1st. 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 determining what actions to take in order to prevent future exceedances. The Level 1 ERA Evaluation and Level 1 ERA Report must be completed by a Qualified Industrial Storm Water Practitioner (QISP) who must also update the Storm Water Pollution Prevention Plan (SWPPP) to reflect the BMP improvements, and certify and submit both the Report and updated SWPPP to SMARTS. Each parameter with an NAL exceedance that triggers Level 1 status is required to be individually addressed in the Level 1 ERA Report.

Level 2 Status
Once a facility enters Level 2 status, a Level 2 ERA Action Plan must be prepared by a QISP and certified and submitted via the SMARTS database by January 1st of the storm water year following the reporting year during which the NAL exceedance that triggered Level 2 status occurred. One year after the Level 2 ERA Action Plan due date, all elements of the Level 2 ERA Action Plan must be implemented and the Level 2 Technical Report prepared by a QISP must be submitted via SMARTS.

→ Click here to view URGENT information about ENFORCEMENT of Level 1 Status and Level 2 Status Exceedances

What are the requirements for Level 1 ERA (Exceedance Response Actions)?

  • A Level 1 ERA Evaluation by a QISP about the facility’s pollutant sources and drainage areas must be completed by October 1st
  • 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
  • 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 are the requirements for Level 2 ERA (Exceedance Response Actions)?

  • Level 2 ERA 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

How Can I Help My Facility Avoid Level 1 Status and Level 2 Status?

Frog Environmental can help your facility avoid ERA Level 1 Status and ERA Level 2 Status. Contact us at 310-241-0866 for a complimentary site visit to determine an affordable BMP strategy to reduce your facility’s pollutants now, before you advance to Level 1 status or Level 2 status.

→ Click here for a referral to Level 1 Consulting Services

What if I am already in ERA Level 1 Status or ERA Level 2 Status?

If you find that your facility has been placed in ERA Level 1 status already, Frog Environmental is here to help you comply with the requirements of the IGP. We have four QISP Trainers of Record (ToRs) and ten QISPs on staff to complete your Level 1 ERA Evaluation and Level 1 ERA Report by the deadlines. By planning ahead and being aggressive, you can implement BMPs now to reduce pollutants on your site and avoid being at risk for Level 2 status in the future. A facility’s Level 1 status can return to Baseline Status once the ERA Report is submitted, the identified additional BMPs are in place, and results from four consecutive storm events that were sampled after BMP implementation have no additional NAL exceedances for the affected parameters.

SCOPE OF WORK – Level 1 ERA REPORT and Level 1 ERA EVALUATION:

  • Site visit and ERA Evaluation conducted by a QISP by the October 1st, 2016 deadline.
  • ERA Evaluation will consist of:
    • Evaluating industrial pollutant sources at the facility that are, or may be related to the NAL exceedance(s).
    • Identifying and assessing corresponding BMPs in the SWPPP that should be better implemented or performed more frequently to prevent future NAL exceedances and to comply with IGP requirements.
    • Recommending additional BMPs necessary to prevent future NAL exceedances and to comply with the requirements of the IGP.
    • Evaluating all facility drainage areas, with a focus on drainage areas where NAL exceedance(s) occurred.
    • Identification of necessary SWPPP revisions.
  • Level 1 ERA Report prepared by a QISP by the January 1st, 2017 deadline* will include:
    • A summary of the Level 1 ERA Evaluation.
    • The Report will address each individual parameter exceeded at each specific discharge location where each parameter exceedance occurred.
    • A detailed description of SWPPP revisions and additional BMPs for the parameter that exceeded an NAL.
    • Frog Environmental engineering and QISP Trainer of Record (ToR) staff performing analysis and review to assist in preparation of ERA report and determine best BMPs to implement.
    • Certification and submittal of the Report via SMARTS including the QISP’s identification number, name, and contact information.
  • Updating of SWPPP by QISP to reflect new and revised BMPs stated in the Report, and certification and submittal via SMARTS. If SWPPP was not prepared by Frog Environmental, there may be additional charges for this service. This will be determined on a case-by-case basis.

*Although the deadline for the Level 1 ERA Report is January 1st, any revised and new BMPs should be in place by October 1st because any samples taken after October 1st will count toward determining ERA Level 2 status.

Take Action Now – Address Possible Exceedances and Level 1 Status Immediately

Frog Environmental is the largest boots-on-the-ground consulting firm specializing in industrial stormwater management in the State of California. We represent over 1,000 clients across the state from nearly every industry regulated under the Industrial General Permit. We provide extensive stormwater compliance services such as SWPPP development, monitoring, sampling, lab analysis, BMP implementation, Level 1 ERA Reporting and QISP supervision. We employ 12 QISPs and 4 Trainers of Record (ToRs) on staff.

Please contact us at 310-241-0866 to schedule a complimentary field evaluation to determine your next steps in response to stormwater compliance regulation. You can also fill out our online Site Evaluation Request form below. You will be contacted within 24 hours to set up a complimentary site visit with one of our expert consultants.

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