Storm Water Permit Compliance
Davenport Engineering LLC now offers the following services to assist with Storm Water Compliance needs in Southern California:
Storm Water Pollution Prevention Plan (SWPPP)
Davenport Engineering can assist facilities with the development of a new Storm Water Pollution Prevention Plan or an update of an existing SWPPP. The new Industrial General Permit (IGP) included many changes to what a facility is required to detail in their SWPPP. Some of the notable changes required for the SWPPP include:
- Addition of required Minimum Best Management Practices (BMPs)
- Addition of Advanced BMPs
- More detailed Site Map requirements
- Incorporation of pollutant Numeric Action Levels (NALs)
- Requiring a more detailed Monitoring Plan
Exceedance Response Action (ERA) Level 1 Evaluation & Report
A Level 1 ERA evaluation must be completed by October 1st for the prior reporting year when a pollutant has exceeded the Numeric Action Level (NAL) on a facility’s Annual Report for the first time. A Qualified Industrial Stormwater Practitioner (QISP) must then complete an evaluation of the facility’s Storm Water Pollution Prevention Plan, Best Management Practices (BMPs), and Monitoring and Implementation Plan (MIP). The QISP will then make recommendations for new or improvements to existing BMPs, SWPPP revisions, and/or changes to the MIP to prevent future NAL Exceedances and help the facility return to Baseline. The BMP, SWPPP, and MIP changes must be summarized in an ERA Level 1 Report prepared by the QISP, which must be certified and submitted to the State Water Resources Control Board (SWRCB) via the SMARTS webtool prior to January 1st.
Exceedance Response Action (ERA) Level 2 Action Plan & Technical Report
If a Level 1 facility’s changes made to their SWPPP, BMPs and MIP do not result in pollutants returning to below their NAL for their Annual Report due July 15, 2017, they now enter Level 2. The facility’s QISP must now complete an Action Plan to be submitted to the State Water Resources Control Board (SWRCB) via the SMARTS webtool prior to January 1, 2018. The ERA Level 2 Action Plan must include a schedule and description of the selected technical demonstration for each NAL exceedance. The three technical demonstrations available are as follows:
1. Industrial Activity BMP Demonstration
Option 1: implementation of additional control measures to achieve NAL & IGP compliance
Option 2: implementation of BMPs to achieve IGP compliance, but not eliminate NAL exceedances
2. Non-Industrial Pollutant Source Demonstration
3. Natural Background Pollutant Source Demonstration
These demonstrations should describe the reason for the facility’s NAL exceedance. The Industrial Activity BMP Demonstration’s Option 1 is the only technical demonstration which allows a facility to eventually return to baseline.
Once the facility has implemented their selected demonstration option, a Technical Report must be prepared by a QISP and submitted prior to January 1, 2019. The Technical Report should detail the outcome of the technical demonstrations and shall be recertified on an annual basis.
To learn more about Storm Water requirements, and how Davenport Engineering can help your facility stay complaint, please contact us today.