Industrial General Permit Level 1 Status
Updated: Apr 2, 2021
While many facilities are meeting the NALs, approximately 2,250 facilities across California are in Level 1 status based on 2015-2016 results. The time to act is now, if you haven’t already. The January 1stLevel 1 Exceedance Response Action (ERA) Report deadline is just around the corner, and the State Water Board has indicated that this deadline will be strictly enforced.
Is your Site Baseline or Level 1?
Have you confirmed if your site is listed as Level 1 in SMARTS? Some sites we’ve assisted thought they were in Baseline based on their sample results, but unfortunately data entry errors caused them to be flagged in SMARTS as Level 1. The easiest way to check is through the Public Search Tool: https://smarts.waterboards.ca.gov/smarts/faces/Reports/SwIndustrialReports.xhtml
ALG saw this issue early on while assisting clients with their Annual Reports, and were able to get Regional Water Board approval to modify the results to eliminate the need for Level 1 reporting. If you discover this issue now, you may want to contact your Regional Water Board to try correcting this issue; otherwise, you must submit a Level 1 Report.
Did you have a QISP perform the Level 1 Evaluation by October 1st
The deadline for Level 1 Evaluations, which must be performed by a Qualified Industrial Stormwater Practitioner (QISP), was October 1. If you have not met this deadline, ALG has QISPs who can perform this evaluation. The QISP is required to work with the facility to perform the evaluation, make recommendations, implement BMPs, and write the final report.
ALG’s Approach to Level 1 Reports
Once the Annual Reports were completed, ALG began assisting clients who entered Level 1 status. ALG implemented an effective 5-step approach for performing Level 1 evaluations and reports. Just remember the acronym, STORM:
S– SWPPP Review: Complete a detailed review of the SWPPP, including visual observations and any other pertinent stormwater files related to the facility. This way, we are already familiar with your business and can hit the ground running when we come onsite.
T– Test Data: We will review stormwater test data from the lab and any data already submitted to SMARTS to make sure all the information is properly reported and lab reports are comprehensive.
O– Onsite Evaluation and Training: ALG arrives at the facility ready to complete the Level 1 evaluation. This includes a site tour and staff interviews to confirm potential pollution sources, sampling techniques, review BMPs, etc. As Level 1 facilities are required to be trained by a QISP, we will try to conduct stormwater training during our time onsite if possible to be efficient as possible. If not, training will be conducted in advance to the ERA Level 1 Report submittal.
R– Recommendations: Based on the onsite evaluation, ALG will compile a Recommendation Report, which details our findings of pollution sources, outlines the BMP modifications and/or additions, investigative sampling options (e.g., run-on, roof discharge, etc.), and SWPPP revisions. We will then work with the facility to decide which BMPs are most feasible to implement right away. It is important to finalize and implement any new or modified BMPs as soon as possible enable the site to collect a sample from the next Qualifying Storm Event.
M- Meet the Deadline! We recommend certifying the Level 1 reports well before the January 1, 2017 deadline to avoid the rush. Between the holidays and the technical difficulties in the past during submittal deadlines, better safe than sorry. ALG can help you navigate through SMARTS – just be sure your Legally Responsible Person (LRP) or Duly Authorized Representative (DAR) is familiar with SMARTS and able to certify the final report submittal. And don’t forget to revise your SWPPP to include all your improvements. Reminder, SWPPPs must be uploaded within 30 days of making revisions!
Remember the Goal – Return to Baseline!
Throughout the Level 1 process, it’s easy to get caught up in the various deadlines and other requirements. However, don’t let this distract you from the ultimate goal of this Level 1 process, which is to return to baseline status by having four consecutive sampling events below NALs! How do you improve stormwater results? Implement effective BMPs! Remember, a BMP is only as good as its implementation, and it is up to you to make sure BMPs are implemented properly. If you think this Level 1 process is complicated, focus on avoiding Level 2. Level 2 will require extensively more effort, time and money to comply with than Level 1. The time to act is now!
Check Out Our Level 1 Fact Sheet
For some more information, please take a look at our IGP Level 1 Fact Sheet on our literature page: http://www.algcorp.com/literature.php
ALG has QISPs available on staff, so please call us if you have questions regarding your stormwater compliance: 805-764-6005.
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