Page 145 - California Stormwater Workshop Handouts

Industrial General Permit Fact Sheet

Level 2 status. Dischargers do not go directly into Level 2 status from Baseline
status.

4. Level 1 Status

Regardless of when an NAL exceedance occurs during Baseline status, a
Discharger’s status changes from Baseline status to Level 1 status on July 1 of the
subsequent reporting year. By October 1 following the commencement of Level 1
status, the Discharger is required to appoint a QISP to assist with the completion of
the Level 1 Evaluation. The Level 1 Evaluation must include a review of the facility’s
SWPPP for compliance with the effluent and receiving water limitations of this
General Permit, an evaluation of the industrial pollutant sources at the facility that
are or may be related to the NAL exceedance(s), and identification of any additional
BMPs that will eliminate future exceedances. When conducting the Level 1
Evaluation, a Discharger must ensure that all potential pollutant sources that could
be causing or contributing to the NAL exceedance(s) are fully characterized, that the
current BMPs are adequately described, that employees responsible for
implementing BMPs are appropriately trained, and that internal procedures are in
place to track that BMPs are being implemented as designed in the SWPPP. A
Discharger is additionally required to evaluate the need for additional BMPs. Level
1 ERAs are designed to provide the Discharger the opportunity to improve existing
BMPs or add additional BMPs to comply with the requirements of this General
Permit.

By January 1 following commencement of Level 1 status, a Discharger is required to
certify and submit via SMARTS a Level 1 ERA Report prepared by a QISP. The
Level 1 ERA Report must contain a summary of the Level 1 Evaluation, all new or
revised BMPs added to the SWPPP.

In most cases, the State Water Board believes that Level 1 status BMPs will be
operationally related rather than structural and, therefore can be implemented
without delay. Recognizing that a Discharger should not be penalized for sampling
results obtained before implementing BMPs, sampling results for parameters and
their corresponding drainage areas that caused the NAL exceedance up to October
1 or the date the BMPs were implemented, whichever is sooner, will not be used for
calculating NAL exceedances. Although this General Permit allows up to January 1
to implement Level 1 status BMPs, the State Board has chosen an interim date of
October 1 to encourage more timely Level 1 BMP implementation. Dischargers who
implement Level 1 BMPs after October 1 may risk obtaining subsequent sampling
results that may cause them to go into Level 2 status.

5. Level 2 Status

Level 2 ERAs are required during any subsequent reporting year in which the same
parameter(s) has an NAL exceedance (annual average or instantaneous maximum),
if this occurs, a Discharger’s status changes from Level 1 status to Level 2 status on
July 1 of the subsequent reporting year. Dischargers with Level 2 status must
further evaluate BMP options for their facility. Dischargers may have to implement
additional BMPs, which may include physical, structural, or mechanical devices that

Order 2014-0057-DWQ 61