What You Need to Know About the Industrial General Permit
How Does a Facility Enter ERA Level 1 Status or ERA Level 2 Status?
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 during the 2015-2016 storm water year, that facility’s status will be Level 1 as of July 1st, 2016. If the same facility continues to exceed in the 2016-2017 storm water 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.
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