Since the Level 2 ERA Action Plan requires facilities to identify the BMPs being implemented, to effectively eliminate exceedances, the Level 2 ERA Technical Report is essentially a review of the effectiveness of the BMPs implemented in improving sample results.
The Technical Report requires a facility to provide the following:
- Site specific data (i.e. sample results) to demonstrate discharges are meeting the NALs. In cases where facilities did not meet NALs, the sample results will be analyzed to assess what level (%) of improvement was achieved.
- A detailed assessment of the BMPs implemented from the Level 2 ERA Action Plan. Including design, design capacity, and any physical or chemical processes used to remove pollutants; if applicable.
- Reasons for selecting the implemented BMPs such as cost, technical feasibility, site-specific characteristics, etc.
- The appropriateness of the selected BMPs to specifically address the pollutants causing the exceedance(s) (i.e. case studies, research, etc.)
- If NALs were not met, an analysis of additional BMPs proposed to eliminate exceedances should be discussed and justified.
Because the Level 2 ERA Technical Report requires a detailed analysis of the Level 2 ERA Action Plan BMPs and how they performed, it’s imperative to select and implement BMPs that will significantly reduce exceedances. The sooner these BMPs are implemented the better. Four (4) consecutive samples without exceedances, results in a return to Baseline Status and alleviates scrutiny from the Water Board and litigious environmental groups.
The Level 2 Technical Report must be prepared by a QISP, certified and submitted via the SMARTS Database by January 1st of the reporting year following the submittal of the Level 2 ERA Action Plan