Just as soon as you caught your breath from the end of the year June rush, completing your Annual Comprehensive Facility Compliance Evaluations (ACFCEs) and Annual Report submittal in SMARTS, it’s time to jump back in and start preparing for the upcoming stormwater year in California! Here are some recommendations on ways to prepare over the summer, to ensure a successful, efficient, and compliant industrial stormwater reporting year for you and your stormwater pollution prevention team (PPT).
#1 Stormwater Team Training
Summer is a great time to get staff tuned up on what needs to be done before and during the upcoming rainy season. The key to having a smooth running industrial stormwater program is properly training your stormwater PPT on how to conduct monthly observations, sampling event observations, collecting samples and best management practices (BMP) implementation.
Having a stormwater professional to train your staff can be beneficial, as they can provide staff with a different view of stormwater, engaging content, and why it is so important to keep it pollutant free. Outside training can also bring a fresh set of eyes and new ideas to boost your stormwater team, plus suggestions on improved BMP implementation.
Important Training Topics
- Explaining differences between stormwater and wastewater (you would think this is obvious)
- Permit requirements
- Monthly Monitoring
- Sampling Event Visual Observations
- Sampling Techniques
- Lab Paperwork and Coordination
- BMP Implementation
- Exceedance Response Action (ERA) items to be addressed (If any)
#2 Exceedance Response Actions
ERA Level 1
If your facility has exceeded the numeric action levels (NAL) for the previous year, then now is the time to start planning for the ERA evaluation and report. If your facility is exceeding for the first time or for a new parameter this year, then you will be entering into ERA Level 1. Between now and October 1st, a qualified industrial stormwater practitioner (QISP) must come to your facility to conduct an evaluation on existing BMPs and the sources of the industrial stormwater exceedance. This evaluation will then be utilized to add BMPs to the company’s stormwater program or to correct currently implemented BMPs. All of this information will then be compiled into an ERA level 1 report, which is due in SMARTS by January 1st.
Timeline for Level 1
- Evaluation of facilities BMPs and exceedance sources – Due October 1st, 2017
- Implementation of additional or corrected BMPs – Between Now-December 31st, 2017
- ERA Level 1 Report submitted/certified in SMARTS – January 1st, 2018
ERA Level 2
This year will be the first year that facilities in California will be entering into Level 2 under the IGP, so it is imperative that preparation of the Action Plan, due January 1st, 2018, starts as soon as possible. Level 2 is anticipated to cost much more than Level 1 as the requirements have increased, including two reports (Action Plan and Technical Report), as well as likely implementation of advanced (e.g. treatment or containment) BMPs.
Timeline for Level 2
- Find a QISP and if needed, a professional engineer – ASAP
- Site evaluation and BMP recommendations by QISP – Between now and December 31st, 2018
- ERA Level 2 Action Plan in SMARTS – Due January 1st, 2018
- Investigation or additional BMP implementation – Between now and December 31st, 2019
- ERA Level 2 Technical Report in SMARTS- Due January 1st, 2019
#3 BMP Review and SWPPP Updates
Summer is also the time to review the facility’s current BMPs to see if corrections, replacement or additions are needed. A rule of thumb is to replace filter socks and storm drain inserts at least once a year, so summer is a good time to order more socks and/or inserts in preparation for the rainy season in the Fall. Cleaning of storm drains and catch basins is another great housekeeping BMP to implement during the summertime. If the facility is going into ERA Level 1 or 2 there will need to be BMP updates and/or additions, so now is a great time to start thinking about what those will be and how you can fit them into the yearly budget. Remember to plan for not only one-time capital costs for advanced BMPs, but also the ongoing maintenance and/or replacement costs of BMPs (e.g. filtration media).
If any stormwater BMPs are changed or added to the monitoring implementation plan (MIP) then the SWPPP must also be updated within 30 days. Other SWPPP updates that may need to be made are stormwater PPT members if anyone has been added or removed (note, this is a very common update for facilities every year). Another very important update that many facilities have not yet incorporated in their SWPPP, is the HUC 10 watershed impairment list and pollutant source assessment.
Summary
There are many things on your mind this summer, such as vacation and getting a much-needed tan. However, don’t forget about your industrial stormwater program! Make sure to get some good training in before the rain, take care of any exceedance response actions, give your BMPs a change-out, and update your SWPPP.
