Under the California Industrial General Storm Water Permit (IGP or General Permit), annual reports are due in SMARTS on July 15. We’ve learned a number of valuable lessons about completing these annual reports over the years and wanted to share with the regulated community, so here’s a few helpful tips on how to make sure you have this requirement covered:
Draft your Annual Report before July 1: If during your Annual Evaluation and/or Annual Report you discover any changes that need to be made in SMARTS, such as a correction or addition of an Ad Hoc report, do so before July 1; after July 1, remanding previously-submitted reports must be approved by the Water Board.
Response to Question 3 – Number of QSEs Sampled: Question 3 of the Annual Report asks if the “required number of Qualified Storm Events” (QSEs) were sampled from “all discharge locations.” If your site sampled two QSEs in each half of the year (or one if under Sample Frequency Reduction) at each sample location, you are in good shape. If less than the required number of QSEs were sampled at each location, you must provide an explanation. This is one of the most important explanations in the Annual Report and is often cited in 60-day Notices of Intent to File Suit issued by Non-Governmental Organizations (NGOs). To reduce the risk, we recommend being aware of what is an acceptable explanation and, if applicable, use these in your Annual Report explanation for Question 3.
Here’s a few tips:
Samples do not need to be collected during dangerous conditions, such as flooding or electrical storms (see IGP Section XI.C.6.a.i).
Samples do not need to be collected outside of scheduled operating hours (see IGP Section XI.C.6.a.ii).
Only Qualifying Storm Events need to be sampled, meaning a discharge must be produced from at least one drainage area. If it is not raining heavy enough to produce a discharge (i.e., storm water is leaving your property), samples are not required to be collected (see IGP Section XI.B.1).
A common explanation that does not demonstrate compliance with the permit includes not having enough staff or the appropriate trained staff (e.g. the Pollution Prevention Team) onsite to collect samples during a QSE. The bottom line is that if there is a QSE during operating hours, samples need to be collected until you reach the required amount for the year.
If there is a storm in your region but it doesn’t rain enough to produce a discharge, it may be worthwhile to collect supporting documentation for this question. If neighboring facilities are collecting samples and you are not, you could be asked for additional information from the Water Board, and NGOs are generally on the lookout for this situation. Consider using rain gauge data, local weather station data, taking pictures of your outfall not discharging, and documenting “No Discharge” on your Sample Event Visual Observation Log. We even have some clients that use a daily log to document if it rained onsite and if so, if discharge occurred.
Level 2 Technical Report: Remember that Level 2 Technical Report updates are due with the Annual Report, subsequently after you’ve submitted your initial Technical Report on January 1. If you’ve returned to Baseline and then re-enter Level 2, Technical Reports are also due July 15 (read carefully IGP Section XII.d.4.a, which refers back to Section XII.d.3.c). To access in SMARTS, under Reports go to the first reporting year you submitted your Technical Report. There should be a tab called Update Technical Report (see screenshot below). Subsequent updates should be uploaded using this tab. The SMARTS help guide does not detail this step, but we’ve confirmed with the State Water Board that this is the correct method in SMARTS.
Check Out Our CASQA Presentation: Jayme Dryden, one of our QISPs, gave a presentation at the CASQA conference in September 2021 with plenty of advice for how to properly complete these reports. Check out her presentation here:
SMARTS Help Guide: The Water Board website has published a help guide on how to navigate the Annual Report on SMARTS: