What is an Exceedance Response Action (ERA) Report and Do I Need One?
State regulations require some facilities to take action to lower a pollutant in their storm water discharge. Not only this, but the Water Board requires permittees to follow their mandated, specific process to implement and document the improvements that are made. If the facility doesn't follow this process, the Water Board will not recognize these improvements.
So, what is this process?
The first step depends on what compliance level your pollutant is (please note that different pollutants can be at different levels).
Facilities with Level 1 pollutants must have a Qualified Industrial Stormwater Practitioner (QISP) help them conduct their Level 1 ERA Evaluation by October 1. The Level 1 ERA Report (the document that corresponds with the evaluation) must be submitted by January 1.
The process for Level 2 facilities is a bit more complicated. To summarize: the first storm water year that the facility is Level 2, a Level 2 ERA Action Plan must be completed. This document must address each new Level 2 exceedance, map out how they will address the exceedance, choose which approved demonstration they will perform to measure their solution’s effectiveness, and more. It must also be prepared by a QISP and submitted by January 1.
The next year, the facility must submit a Level 2 Technical Report. Its requirements vary depending on the situation, but it must always identify the source of the exceeding pollutants, describe the changes they made to lower those pollutants, and report the outcome of the demonstration the facility chose to perform in the Action Plan. Like the other documents, it must be prepared by a QISP, and submitted online by January 1.
If you still need to take any of these steps, we can help! This is an important process that increases in demand as the deadline approaches. A good next step is to have Frog conduct an Engineering Assessment of the site to find economic, practical, and effective solutions.