Have you been contacted by the State Water Resources Control Board with an IGP Level 1 NAL Exceedance Notice?
The new Industrial General Permit 2014-0057-DWQ (IGP) includes a requirement to conduct potentially costly exceedance response actions (ERAs) if your facility’s stormwater sampling results exceed the established numeric action levels (NALs) listed in the IGP. Facilities with results above the instantaneous or annual numeric action level entered into ERA Level I status on July 1, 2016 and must conduct an ERA Level I Evaluation and Level I ERA Report. If your facility is currently in ERA Level, 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 a facility exceeded the Instantaneous NAL or the Average NAL the facility moved from Baseline compliance status to Level 1 compliance status for current reporting year, which began on July 1, 2016. Responding to a NAL exceedance requires 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.
What to do next?
Conduct a comprehensive site evaluation to identify the sources of the exceeding parameter and implement the appropriate BMPs as soon as possible.
OCTOBER 1: Conduct an ERA Level 1 Evaluation with a QISP (Level 1 Status Facilities Only)
The ERA Level 1 evaluation is to be conducted by October 1. The discharger shall complete an evaluation, with the assistance of a QISP, of the industrial pollutant sources at the facility that are or may be related to the NAL exceedance(s); and, Identify in the evaluation the corresponding BMPs in the SWPPP and any additional BMPs and SWPPP revisions necessary to prevent future NAL exceedances and to comply with the requirements of the General Permit. Although the evaluation may focus on the drainage areas where the NAL exceedance(s) occurred, all drainage areas are to be evaluated.
JANUARY 1: ERA Level 1 Report (Level 1 Status Facilities Only)
Based upon the ERA Level 1 evaluation, the Discharger shall revise their SWPPP as necessary and implement any additional BMPs identified in the evaluation. Dischargers also must certify and submit via SMARTS, a Level 1 ERA Report prepared by a QISP that includes the following
Alta’s experts can provide your business with proactive solutions to mitigate the escalating cost of compliance. If your facility is in ERA Level 1, Alta’s QISPs can conduct your ERA Level 1 Evaluation and ERA Level 1 Report. Alta will 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 implementing effective BMPs, reducing 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). Starting early will provide the opportunity to establish how effective the chosen BMPs are. This will provide greater insight for adjusting your facility’s chance of returning to baseline status by getting one year of results below the NAL.
To learn more, or for assistance keeping your business in compliance, 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, QISP/ToR, CPSWQ, can be reached via email at firstname.lastname@example.org.