The new Industrial General Permit 2014-0057-DWQ (IGP) adopted by the California State Water Resources Control Board became effective on July 1, 2015. The IGP includes a requirement to conduct potentially costly exceedance response actions (ERAs) if your facility’s storm water sampling results exceed the established numeric action levels (NALs) listed in the IGP. As your business receives sampling results from the laboratory for the first half of the monitoring year, it is important to assess if your facility has the potential to be in ERA Level 1 compliance status before the end of the reporting year. If any of your results are above the listed NALs, we recommend starting investigations to understand pollutant sources and implement corrective actions to reduce concentrations as soon as possible.
What are the NALs?
The IGP includes two types of NALs. For compliance purposes, the reporting year is defined as July 1 through June 30.
What happens if a NAL is exceeded?
If an instantaneous maximum NAL or an annual NAL is exceeded from a single monitoring event it does not necessarily mean you will be in ERA Level 1 status the next reporting year. However, you will have a much higher chance if subsequent results are also elevated or above the NALs. Once a facility exceeds the Instantaneous NAL or the Average NAL the facility will move from Baseline status to ERA Level 1 status for the next reporting year, beginning July 1, 2016. Responding to a NAL exceedance will require expert guidance, new and/or improved BMPs, and additional reporting. Your business must designate a Qualified Industrial Storm Water Practitioner (QISP) and is required to evaluate their SWPPP and implement BMP changes by October 30, 2016 and prepare and submit a Level 1 ERA report by January 1, 2017. A facility may also move from Baseline to ERA Level 1 status in subsequent years if conditions change that result in NAL exceedances.
The figure above demonstrates the annual NAL calculation for hypothetical TSS results from a facility with two discharge locations. In this scenario, even if BMPs are implemented after the first two sample events and are effective at lowering subsequent TSS results, the facility will still exceed the annual NAL. The scenario above assumes near perfect results for TSS (near the reporting limit) after effective BMPs are implemented. If sources were corrected and low results were achieved similar to these, it may be possible to add another round of sampling to reduce your annual NAL and avoid ERA Level 1 status. This essentially becomes a numbers game and it would be advisable to assess likely scenarios based on the actual results a facility is able to achieve after BMPs have proven to be effective at lowering results to a consistent level. In some cases, it may not be possible to conduct additional events due to no more rain events or practical if one can anticipate that additional events will yield similar elevated results.
In reality, there may be nothing one can do to avoid ERA Level 1 status based on the results that have already occurred. Here are a few options facility managers have.
Do nothing now….
Take no action now, but plan for ERA Level 1 requirements in July.
Conduct a comprehensive site evaluation to identify the sources of the exceeding parameter and implement the appropriate BMPs.
Conduct a comprehensive site evaluation to identify the sources of the exceeding parameter and implement the appropriate BMPs as soon as possible.
With a comprehensive site evaluation and implementation of effective BMPs, reducing TSS results may be relatively easy and cost effective. However, parameters such as metals and nutrients may be more difficult and costly to address. Pollutants can come from a variety of sources that may include industrial activities or may be related non-industrial sources (e.g., building materials, aerial deposition, or landscaping activities to name a few). The table below provides examples of lost cost BMPs commonly used to address TSS.
Alta Environmental can help assess your facility’s data, evaluate the likelihood of an NAL exceedance, conduct site evaluations, source identifications, and recommend BMPs to possibly avoid ERA Level 1 status. If ERA Level 1 status can’t be avoided, Alta’s experts can provide your business with proactive solutions to mitigate the escalating cost of IGP compliance.
To learn more, or for assistance keeping your business in compliance before it’s too late, give us a call at 562-495-5777 or email our Water Resources experts.
David Renfrew, QISP/ToR, QSD, CPSWQ, can be reached via email at email@example.com.
Garth Engelhorn, CPSWQ, can be reached via email at firstname.lastname@example.org.