In California facilities with similar industrial activities (e.g. SIC code) can form a compliance group under the Industrial General Permit (IGP) for stormwater. In order for this to happen a Trainer of Record (ToR) must form the compliance group by becoming the Compliance Group Leader. There are some benefits to being a member of a compliance group and there are some drawbacks. Let’s look at both sides of the coin so that you can choose for yourself if a compliance group would be beneficial for your facility. Oh and just FYI, our Ryan Janoch is a ToR and can create a compliance group for your facilities, if this is of interest to you! However, we might just convince you not to anyways…..every situation is different, so let’s dig in.
Benefits
- Your facility is only required to sample twice a year (or once a year with a sample frequency reduction)
- The Compliance Group Leader must visit your facility at least once a year for an evaluation
- Level 1 ERA Reports are “Consolidated” and written by the Compliance Group Leader
- There is more communication between facilities with similar activities
Possible Drawbacks
- Sampling only twice a year increased the risk for facilities to have exceedances in their annual averages (i.e. if the first sample if high you will need multiple low samples to bring the average down)
- You must have a ToR to be the Compliance Group Leader in order to form the compliance group
- Depending on your Compliance Group Leader, a consolidated Level 1 Report might not be as facility-specific as it would be if the facility was not in a compliance group and had a QISP conduct a single, non-consolidated, Level 1 Evaluation and Report.
- Dependent on the size of the compliance group and the Compliance Group Leader the facility might not get the kind of attention they need
- Level 2 Reports will require assistance from a Professional Engineer (PE) and not all compliance groups have PE’s on staff
Summary
Not all of these drawbacks are applicable to all compliance groups, and just because you only have to sample twice a year does not limit you to only two samples. Just like you can sample more than four times a year to assist in bringing your annual average down you can sample more than twice a year in a compliance group. However, if you are not paying attention to your sampling data and one sample is high, only sampling twice can cause your average to be over the NAL based on the law of averages.
Each compliance group and Compliance Group Leader will be a little different from the other. Some will be more site-specific and detailed in their Level 1 Reports. Just as some Compliance Group Leaders will be more attentive than others.
When deciding if a compliance group is right for your facility you should keep in mind the following; (a) what are the specific needs of my facility, (b) are the industrial activities at my facility able to be grouped with other facilities in my area, (c) what compliance groups or ToR are available to my kind of facility, (d) what does the compliance group offer, and finally (e) will a compliance group be beneficial for my facility?
Want to form a compliance group? We can help with that. Have more questions about stormwater in general? Give us a call or schedule a free consultation.
