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 TrainingSummer 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 1If 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 2This 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