Developing a SWPPP under the CA IGP? Confused about stormwater compliance? We’ve compiled the answers to the most common questions below.
- Who must apply for coverage under this permit?
- How do I apply for permit coverage?
- Can I get an exemption from the permit?
- What are my deadlines?
- How often do I need to do training?
- Who needs training?
- How do I use SMARTS?
- How do I Link Users on SMARTS?
- How do I Submit Sampling Data (Ad hoc reports)?
- What do I need a certification and or training to do?
- When do I need a QISP?
- How do I become a QISP?
- What happens if I exceed Numeric Action Levels (NALs)?
- What samples do I need to collect at my facility?
- What’s a QSE?
- How do I collect samples?
- Do I need certification or training to collect samples?
- How are samples analyzed?
- How do I contact a lab to analyze my samples?
- When do I collect samples?
- How do I know if I have a sampling exceedance?
- What do I check for in a monthly inspection?
- What's required for the Annual Evaluation & Report?
- Why are there so many acronyms?
- What are the different levels in the permit?
- Baseline Status
- Level 1 Status
- Level 2 Status
- Contact Us
Covered facilities fall under one of the categories in Attachment A of the California industrial stormwater permit and applicability is usually based on Standard Industrial Classification (SIC) code. For more specifics on SIC codes, use the 1987 SIC code manual or an online reference tool.
The nine categories that companies fall into in terms of applicability are:
- Facilities with subchapter N effluent standards (refineries/fertilizer manufacturing)
- Manufacturing facilities
- Oil & gas/mining facilities
- Hazardous waste treatment sites
- Recycling facilities
- Electric power plants
- Transportation companies
- Sewage treatment plants
You will need to file for coverage and upload an updated Stormwater Pollution Prevention Plan (SWPPP) and site map online on the Water Board’s Stormwater Multiple Application and Report Tracking System (SMARTS). In some cases, you may qualify for an exemption via a No Exposure Certification (NEC), which only requires a site map. However, if these documents are not filed the Water Board can issue fines for non-filers. In addition, non-filers open themselves up to potential litigation by third-party organizations under the Clean Water Act.
Even though a facility may fall under one of the categories in Attachment A of the California industrial stormwater permit, they may qualify for an exemption from some of the requirements. A facility qualifies for a no exposure certification, only if industrial materials and activities are not exposed to rainfall. If a facility qualifies, then they do not have to implement Best Management Practices (BMPs) for their site and they do not have to prepare and follow a Stormwater Pollution Prevention Plan (SWPPP). This likely will mean facilities can avoid significant costs related to SWPPP development, sampling, and inspections. The California State Water Resources Control Board (SWRCB) has a very specific definition of no exposure and criteria necessary to qualify for the no exposure certification.
- A sitemap still must be submitted via SMARTS
- The legally responsible person (LRP) must certify that materials/activities are not exposed to precipitation
- Need to file for conditional exclusion each year by October 1st
Need help determining if you qualify for an NEC? Get help from a stormwater expert.
How often do I need to do training?
The industry standard is annually, but the IGP is not specific on this issue. Other states are more explicit that annual training is required.
Who needs training?
The California Industrial General Permit (IGP) says all team members (general the Pollution Prevention Team) need to know how to implement and evaluate BMPs, do visual observations (aka inspections), monitoring (aka sampling), etc. See page 32 and 33 of the IGP. The Factsheet (page 36 and 37) further clarifies that the team members means the PPT and training should include SWPPP implementation, monitoring, or BMPs. Generally industry conducts training annually for the PPT and also many conduct general awareness training for all facility staff once a year.
IGP Factsheet on Training
IGP Section on Training
The Industrial General Permit has several complex deadlines that change depending on your facilities status.
The stormwater year for California is July 1st to June 30th. This is the span of time for which yearly deadline repeat.
Some static deadlines all facilities are required to follow.
All CA facilities must follow these deadlines:
- June 30th: Last day of stormwater year, must have completed an Annual Evaluation at some point for the year. This deadline is rolling with the requirement being that it is conducted at least once per stormwater year (July 1 - June 30) and cannot be fewer than 8 months since the previous Annual Evaluation or more than 16 months since the last Annual Evaluation.
- July 15th: Previous stormwater year Annual Report is due.
- October 1st: Level 1: QISP shall inspect the facility in person for the Level 1 ERA evaluation.
- Jan 1st: Level 1 ERA report due, Level 2 ERA Action Plan Due, Level 2 ERA Technical Report Due, SWPPP modifications from ERA due.
- 30 days after lab report is returned from the lab, the sampling data is due to be certified and submitted on SMARTS.
- 30 days after significant changes to BMPs or processes are implemented onsite the SWPPP is due to be updated, certified, and submitted to SMARTS.
The Sormwater Multiple Application and Report Tracking System (SMARTS) is sometimes a difficult system to use. Thankfully, there are plenty of resources put forth to navigate SMARTS and become an adept user.
The State Water Resources Control Board (SWRCB) guide was developed to assist Dischargers in submitting their NOIs, NECs, NOTs, and Annual Reports, as well as, viewing/printing Receipt Letters, monitoring the status of submitted documents, and viewing their application/renewal fee statements through SMARTS. The guide contains general guidance, detailed information on how to access SMARTS, how to complete the required applications, a list of acronyms, frequently asked questions, and a glossary. The SWRCB guide for dischargers is available here. In addition, Frequently Asked Questions (FAQ) regarding the IGP and SMARTS have been compiled by the SWRCB into this reference document.
If you are aware of the general requirements of the IGP and want to jump onto SMARTS quickly, use this quick start guide from the SWRCB.
The SWRCB has put together a simple guide on Managing and Linking Users on SMARTS which you can find here.
The California IGP requires that sample results be submitted in SMARTS within 30 days of receipt of the final laboratory report. For more on how to submit the results, check out Mapistry's blog post on submitting sample results includes step-by-step instructions and the California State Water Resources Control Board (SWRCB) guide on sampling data submittal in SMARTS. Tired of entering the data, check out our monitoring program, because we do it for you.
Dischargers with Notice of Intent (NOI) or No Exposure Certification (NEC) coverage request termination of coverage under the Industrial General Permit (IGP) when either; (a) the operation of the facility has been transferred to another entity, (b) the facility has ceased operations, completed closure activities, and removed all industrial related pollutants, or (c) the facility’s operations have changed and are no longer subject to the Industrial General Permit. The IGP requires dischargers to electronically certify and submit a Notice of Termination (NOT) via SMARTS. The SWRCB guide on filing a NOT is available here.
The Change of Information form (COI) in SMARTS is used to update information such as facility name, address, Standard Industrial Classification (SIC) code, and/or Storm Water Pollution Prevention Plans (SWPPP) and site map revisions. The SWRCB guide on filing a COI is available here. If you are in Level 1 or 2 and/or updated your SWPPP, you will need to file a COI with a SWPPP update, which we explain how-to-do-it here.
Training is listed as a minimum BMP in the Industrial General Permit. However, while a discharger remains in baseline status and has not had any exceedances the training they receive or conduct is largely up to them. The formal requirement for training conducted by a QISP (Qualified Industrial Stormwater Practitioner) is only when a discharger has entered elevated status. In ERA Level 1 or ERA Level 2 status annual training is required.
The certification of QISP is required to conduct several actions if a discharger is elevated above baseline status for any parameters. The QISP certification can be obtained by anyone with the appropriate amount of experience working with industrial stormwater.
A QISP is required at Baseline status only when a facility is seeking coverage by the Industrial General Permit and discharges directly to a 303(d) listed water body.
A QISP is also required in ERA Level 1 and ERA Level 2 status to complete the evaluations, reports, and training that are required in elevated status.
You will need to complete the following steps:
- Take the 16-hour online training course through the Sacramento State Office of Water Programs (sign up here)
- Pass the online mid-term (score 70% or better)
- Take the in-person one-day class with a ToR-QISP
- Pass the final exam (score 70% or better)
More Info on QISP: Water Board factsheet
Need a QISP?
Are you going into Level 1 or 2? Are you filing a permit for the first time and need a 303(d) evaluation? You are in the right place because Mapistry's QISPs can help.
If a facility exceeds the Numeric Action Levels (NALs) for their industrial stormwater parameters, the facility's status will change from "baseline" to Exceedance Response Action (ERA) level 1 or level 2 status from level 1 on or before July 1 of the new SWPPP year. Per the IGP, a facility will need to complete an evaluation with a QISP (Qualified Industrial Stormwater Practitioner) on the related pollutant sources and identify Best Management Practices (BMPs) needed to reduce the discharge levels at elevated status. An ERA Level 1 report or an ERA Level 2 will also need to be prepared by a QISP. The final QISP required step for ERA Level 1 sites, is to conduct training for the facility's staff. In ERA Level 2 status a technical report is required in addition to similarly repeated steps from ERA Level 1.
- Enter ERA Level 1 status (no action needed) - July 1
- Annual Report due (2015-2016 reporting year) - July 15
- Complete ERA Level 1 evaluation with QISP - October 1
- Submit ERA Level 1 Report, ERA Level 2 Action Plan, ERA Level 2 Technical Report, and update SWPPP - January 1
Each facility regulated under the Industrial General Permit must collect at minimum samples for pH, Oil and Grease, and TSS (Total Suspended Solids).
A facility may be required to analyze for additional analytical parameters based on the facility SIC code (Standard Industrial Classification). This information can be found in Table 1 of the IGP. A facility may also have to analyze for additional parameters based on their potential pollutant source assessment or if they discharge to an impaired waterbody.
A QSE is a Qualified Storm Event. The Industrial General Permit defines this as a precipitation event that (1) produces a discharge for at least one drainage area and (2) is preceded by 48 hours with no discharge from any drainage area.
Remember that four stormwater samples are required to be collected per year, two each six months, and they must be collected from a Qualified Storm Event (QSE).
With the California Industrial Stormwater General Permit (IGP), all facilities need to collect samples for pH (in the field) and send samples to the laboratory for Oil & Grease (O&G) and Total Suspended Solids (TSS). For more on pH measurement, including pH meter calibration, check out our how-to guide.
If you are collecting samples from sheet flow across a site, it can be quite tricky. Here is a good video on sampling stormwater sheet flow from Minnesota on how to create a dam and collect a stormwater sample. However, please note that if you are sampling for O&G you should not use a plastic container to collect the sample (in the video they use a plastic bag). Instead, you should collect your industrial stormwater sample in the glass (amber) container supplied by the laboratory. The creation of a temporary dam should make it a lot easier.
For other resources on industrial stormwater sampling, see the list below:
- Laboratory analysis of industrial stormwater samples - behind the scenes video,
- Grab industrial stormwater sampling video from Minnesota,
- General industrial stormwater sampling video from Washington, and
- Washington industrial stormwater sampling guide.
No special certification is required to collect stormwater samples for analysis under the Industrial General Permit. However, all samples do need to be collected in accordance with Attachment H: Sample collection and Handling Instructions.
For a "behind the scenes" look at how analytical laboratories handle your stormwater samples, check out one laboratory's explanation of Total Suspended Solids (TSS) and Oil & Grease analysis plus a great video overview of stormwater sample analysis.
Analysis on stormwater samples in California must be completed by an ELAP certified laboratory. The California Water Boards has a GIS tool map to help facilities locate a certified laboratory here.
However, not every lab specializes in stormwater just because they are ELAP certified. Ensure you call to ask a lab if they will be able to complete the analysis you need with the appropriate test methods.
Facilities need to collect and analyze stormwater samples from two (2) Qualified Storm Events (QSEs) within the first half of each reporting year (July 1 to December 31), and two (2) QSEs within the second half of each reporting year (January 1 to June 30).
Sample collection is required during scheduled facility operating hours and when sampling conditions are safe in accordance with Section XI.C.6.a.ii of the General Permit. Samples from each discharge location shall be collected within four (4) hours of:
- The start of the discharge; or,
- The start of facility operations if the QSE occurs within the previous 12-hour period (e.g., for storms with discharges that begin during the night for facilities with day-time operating hours).
For more, check out some common errors around QSEs and how to better decode the definition of a QSE.
Stormwater sampling exceedances are calculated in two different ways. The instantaneous maximum NALs which are higher levels but any 2 readings through the year above those levels initiates exceedance status. The annual NALs are the yearly average of all discharge points from all QSEs combined.
The only way to know if you have an exceedance is to keep an eye on your sampling data, recording any number that is greater than the instantaneous NAL as well as averaging your results together after each new storm events data is available to see where you stand on your annual averages.
A monthly inspection must at minimum consist of a visual observation of each drainage area for the following: (1) the presence or indicators of potential unauthorized NSWD (Non-Storm Water Discharges) and their sources, (2) authorized NSWDs, sources, and associated BMPs, and (3) Outdoor industrial equipment and storage areas, outdoor industrial activities areas, BMPs, and all other potential source of industrial pollutants.
Although we can't explain why so many acronyms exist in the stormwater world we can help you out with what they all mean. Here's a quick guide breakdown of IGP's acronyms.
What's required for the Annual Evaluation & Report?
One Annual Evaluation must be conducted each reporting year (July 1 - June 30). If Annual Evaluation Is conducted fewer than eight (8) months, or more than sixteen (16) months, after it conducts the previous Annual Evaluation, document the justification for doing so. Revise the SWPPP, as appropriate, and implement the revisions within 90 days of the Annual Evaluation. At a minimum, Annual Evaluations shall consist of:
- A review of all sampling, visual observation, and inspection records conducted during the previous reporting year;
- An inspection of all areas of industrial activity and associated potential pollutant sources for evidence of, or the potential for, pollutants entering the storm water conveyance system;
- An inspection of all drainage areas previously identified as having no exposure to industrial activities and materials in accordance with the definitions in Section XVII;
- An inspection of equipment needed to implement the BMPs;
- An inspection of any BMPs
- A review and effectiveness assessment of all BMPs for each area of industrial activity and associated potential pollutant sources to determine if the BMPs are properly designed, implemented, and are effective in reducing and preventing pollutants in industrial storm water discharges and authorized NSWDs; and,
- An assessment of any other factors needed to comply with the requirements in
Certify and submit via SMARTS an Annual Report no later than July 15th following each reporting year using the standardized format and checklists in SMARTS.
Include in the Annual Report:
- A Compliance Checklist that indicates whether a Discharger complies with, and has addressed all applicable requirements of this General Permit;
- An explanation for any non-compliance of requirements within the reporting year, as indicated in the Compliance Checklist;
- An identification, including page numbers and/or sections, of all revisions made to the SWPPP within the reporting year; and,
- The date(s) of the Annual Evaluation.
See this SMARTS Annual Report help guide for more information
In California the Industrial General Permit has a level system that is based on sampling results from the laboratory. When exceedances of NALs occur, a discharger elevates in level the following SWPPP year. The levels are specific to each individual parameter that a discharger samples for, so a single facility may exist in multiple different levels at once.
At the beginning of a Discharger’s NOI Coverage, all Dischargers have Baseline status for all parameters.
A Discharger’s Baseline status for any given parameter shall change to Level 1 status if sampling results indicate an NAL exceedance for that same parameter. Level 1 status will commence on July 1 following the reporting year during which the exceedance(s) occurred.
- Level 1 ERA Evaluation
- By October 1 following commencement of Level 1 status for any parameter with sampling results indicating an NAL exceedance, the Discharger shall complete an evaluation, with the assistance of a QISP, of the industrial pollutant sources at the facility that are or may be related to the NAL exceedance(s) and identify in the evaluation the corresponding BMPs in the SWPPP and any additional BMPs and SWPPP revisions necessary to prevent future NAL exceedances and to comply with the requirements of the General Permit.
- Based upon the above evaluation, the Discharger shall, as soon as practicable but no later than January 1 following commencement of Level 1 status revise the SWPPP as necessary and implement any additional BMPs identified in the evaluation and certify and submit via SMARTS a Level 1 ERA Report prepared by a QISP.
A Discharger’s Level 1 status for a parameter will return to Baseline status once a Level 1 ERA report has been completed, all identified additional BMPs have been implemented, and results from four (4) consecutive QSEs that were sampled subsequent to BMP implementation indicate no additional NAL exceedances for that parameter.
A Discharger’s Level 1 status for any given parameter shall change to Level 2 status if sampling results indicate an NAL exceedance for that same parameter while the Discharger is in Level 1. Level 2 status will commence on July 1 following the reporting year during which the NAL exceedance(s) occurred.
- Level 2 ERA Action Plan
- Dischargers with Level 2 status shall certify and submit via SMARTS a Level 2 ERA Action Plan prepared by a QISP that addresses each new Level 2 NAL exceedance by January 1 following the reporting year during which the NAL exceedance(s) occurred.
- On January 1 of the reporting year following the submittal of the Level 2 ERA Action Plan, a Discharger with Level 2 status shall certify and submit a Level 2 ERA Technical Report prepared by a QISP
Dischargers with Level 2 status who submit an Industrial Activity BMPs Demonstration and have implemented BMPs to prevent future NAL exceedance(s) for the Level 2 parameter(s) shall return to baseline status for that parameter, if results from four (4) subsequent consecutive QSEs sampled indicate no additional NAL exceedance(s) for that parameter(s). If future NAL exceedances occur for the same parameter(s), the Discharger’s Baseline status will return to Level 2 status on July 1 in the subsequent reporting year during which the NAL exceedance(s) occurred. These Dischargers shall update the Level 2 ERA Technical Report as required in the General Permit.
Have other questions regarding the California Stormwater Industrial General Permit that could not be answered by this article? Contact us at (800) 553-7420 or firstname.lastname@example.org.