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The California Industrial General Permit (IGP) has upcoming deadlines for Exceedance Response Action (ERA) Reporting on October 1, 2019 and January 1, 2020. The State Water Resources Control Board (State Water Board) has recently updated the IGP, with an unofficial draft of the newly adopted IGP released here. The proposed amendments include the implementation of Total Maximum Daily Load (TMDL), sufficiently sensitive test methods, and alternative compliance options. The IGP identifies Numeric Action Levels (NALs) for pollutant discharges, including, pH, suspended solids and oil & grease, metals and other pollutants. All facilities start at “Baseline Status”, which indicates there are no existing exceedances of applicable NALs. For facilities which exceed applicable NALs, the IGP specifies several ERA steps to be completed, which are summarized as follows:

  • Level 1 ERA Evaluation - By October 1st following the commencement of Level 1 exceedance of any NAL, the Site is required to assign a Qualified Industrial Stormwater Practitioner (QISP) to the Site. The QISP is required to complete a Level 1 Evaluation of facility operations, drainage areas, NAL exceedances, Best Management Practices and conduct training, as deemed necessary.
  • Level 1 ERA Report - By January 1st following the commencement of Level 1 exceedance of any NAL, the Site's QISP is required to complete and submit a Level 1 ERA Report into the Stormwater Multiple Application Reporting System (SMARTS), which the Site shall certify. The implementation of additional BMPs, changes to the SWPPP and other compliance requirements shall be identified in the Level 1 ERA Report.

A facility's Level 1 ERA status for a parameter will return to Baseline Status once a Level 1 ERA report has been completed, all identified additional BMPs have been implemented, and results from four (4) consecutive Qualified Stormwater Events (QSEs) that were sampled subsequent to BMP implementation indicate no additional NAL exceedances for that parameter. In the event there is a subsequent exceedance of applicable NALs while the Site is a Level 1 ERA status, the IGP prescribes the following additional steps:

  • Level 2 ERA Action Plan - By January 1st following the commencement of Level 2 exceedance of any NAL, the Site's QISP to complete a Level 2 ERA Action Plan, which shall include a schedule and tasks necessary to complete one of the following: Industrial Activity BMP Demonstration, Non-Industrial Pollutant Source Demonstration, or Natural Background Pollutant Source Demonstration.
  • Level 2 ERA Technical Report - By January 1st of the reporting year following the submittal of the Level 2 ERA Action Plan, a facility with Level 2 status shall certify and submit a Level 2 ERA Technical Report prepared by the Site's QISP, which shall provide relevant information and tasks completed for one of the above referenced technical demonstrations identified by the Level 2 ERA Action Plan.

Note that when a facility's compliance status remains at Level 1 or Level 2 ERA, employee training at the Site related stormwater compliance and IGP must be conducted by a QISP.

For more information regarding ERA Reporting, please contact your local Trinity Consultant's office at (866) 830-0796.