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
