8 Key Steps for Developing Comprehensive Level 1 & 2 ERA Plans

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Jul 10

In California, effective stormwater management is crucial for industrial facilities to comply with the stringent requirements of the Industrial General Permit (IGP). When stormwater discharge exceeds regulatory limits, facilities must implement Exceedance Response Action (ERA) Plans at Levels 1 and 2. These plans are essential for addressing pollution, maintaining compliance, and protecting water quality. This is a guide to developing comprehensive Level 1 and 2 ERA Plans, helping your facility stay compliant and environmentally responsible.

Step 1: Understanding ERAs

ERAs are crucial components of stormwater management for industrial facilities in California. The IGP requires facilities to develop and implement Level 1 and Level 2 ERA Plans when stormwater discharge exceeds numeric action levels.

Level 1 ERA: Triggered by initial exceedances, this level involves a prompt site assessment to identify pollutant sources and evaluate existing Best Management Practices (BMPs). This requires a comprehensive site evaluation by a Qualified Industrial Stormwater Practitioner (QISP). Facilities must update their Stormwater Pollution Prevention Plan (SWPPP) and submit a Level 1 ERA Report detailing their findings and corrective actions.

Level 2 ERA: Facilities escalate to Level 2 ERA if exceedance continues. Level 2 ERAs also require a comprehensive site evaluation by a QISP. The QISP develops a Corrective Action Plan (CAP) with enhanced BMPs to address persistent issues. Facilities must document and report these actions thoroughly.

For expert guidance on developing your ERA Plans, contact Stormwater Pro. We provide comprehensive support to ensure your facility meets all regulatory requirements and effectively manages stormwater discharges.

Step 2: Initiating Level 1 ERA Plans

When a facility's stormwater discharge exceeds the numeric action levels specified by the IGP, a Level 1 ERA Plan must be initiated. This process is designed to address and mitigate the causes of the exceedance.

Key Components of a Level 1 ERA Plan:

Immediate Site Assessment: Conduct a thorough assessment to identify potential sources of pollution. Evaluate areas where pollutants might be entering the stormwater system.
BMP Evaluation and Updates: Review current BMPs to determine their effectiveness. Update or implement new BMPs as necessary to reduce pollutant levels.
SWPPP Modifications: Revise the SWPPP to reflect the findings from the site assessment and BMP evaluation. Ensure that the SWPPP is comprehensive and addresses all identified issues.
Documentation and Reporting: Prepare a detailed Level 1 ERA Report. This report should outline the identified sources of pollution, the BMPs implemented or updated, and any changes made to the SWPPP. Submit this report to the California State Water Resources Control Board within the required timeframe.

Timeline and Deadlines: Ensure all actions and reporting are completed promptly to comply with IGP requirements and avoid further regulatory action.

Need help initiating a Level 1 ERA Plan? Contact Stormwater Pro for expert assistance in conducting site assessments, evaluating BMPs, and preparing comprehensive ERA Reports to keep your facility compliant.

Step 3: Transitioning to Level 2 ERA Plans

If stormwater discharge exceedances persist after implementing a Level 1 ERA Plan, your facility must escalate to a Level 2 ERA Plan. This stage requires more detailed analysis and enhanced corrective measures.

Key Components of a Level 2 ERA Plan:

Comprehensive Site Evaluation: Engage a QISP to perform an in-depth evaluation of your facility. The QISP will identify persistent pollutant sources and weaknesses in the current stormwater management practices.
Enhanced BMPs: Based on the QISP’s findings, develop and implement more robust BMPs. These may include structural controls, advanced treatment technologies, or significant operational changes.
CAP: The QISP will draft a CAP outlining the new BMPs and strategies to address the ongoing exceedances. This plan should be detailed and actionable, providing a clear path to compliance.
Documentation and Reporting: Prepare a comprehensive Level 2 ERA Report, including the findings from the site evaluation, the enhanced BMPs implemented, and the CAP. Submit this report to the California State Water Resources Control Board within the stipulated timeframe.

Timeline and Deadlines: Adhere to the deadlines for submitting the Level 2 ERA Report and implementing the corrective actions to ensure compliance and avoid penalties.

Are you struggling with persistent exceedances? Transition smoothly to a Level 2 ERA Plan with the help of Stormwater Pro. Our experts will conduct thorough evaluations, develop effective BMPs, and ensure your facility meets all regulatory requirements.

Step 4: Conducting Site Assessments

A thorough site assessment is critical for Levels 1 and 2 ERA Plans. Identifying pollutant sources and understanding how they interact with stormwater runoff is the foundation of an effective response plan.

Steps for Conducting Effective Site Assessments:

Visual Inspections: Perform detailed visual inspections of the facility to identify areas where pollutants may enter stormwater. Pay special attention to material storage areas, waste disposal sites, and process areas.
Review Facility Operations: Examine daily operations and processes to identify potential sources of pollution. Assess how materials are handled, stored, and disposed of.
Evaluate Stormwater Flow Paths: Map out how stormwater flows through and exits your facility. Identify potential contamination points along these paths.
Sample Collection and Analysis: Collect stormwater samples from various locations around the facility during rain events. Analyze these samples to determine the presence and concentration of pollutants.
Document Findings: Record all observations, sample results, and identified pollutant sources in a detailed site assessment report. This documentation will guide the development or update of your ERA Plan.

Ensure your site assessments are thorough and accurate with the help of Stormwater Pro. Our experienced professionals can conduct comprehensive assessments, identify potential pollutant sources, and provide actionable recommendations to enhance your ERA Plans.

Step 5: Implementing and Updating BMPs

BMPs are essential for controlling pollutants in stormwater runoff and ensuring compliance with the IGP. Level 1 and Level 2 ERA Plans require a critical evaluation and update of BMPs to address identified exceedances effectively.

Steps for Implementing and Updating BMPs:

Evaluate Existing BMPs: Review current BMPs to determine their effectiveness. Based on site assessment findings identify any gaps or areas where improvements are needed.
Select Appropriate BMPs: Choose BMPs specifically suited to your facility’s operations and the pollutants identified. This may include structural controls like sediment basins, operational controls such as improved housekeeping practices, or treatment controls like filtration systems.
Implement Enhanced BMPs: Put the new or updated BMPs into action. Ensure they are installed and maintained according to manufacturer specifications and best practice guidelines.
Train Staff: Educate your staff on the importance of BMPs and how to implement and maintain them correctly. Regular training ensures everyone understands their role in pollution prevention.
Monitor and Adjust BMPs: Continuously monitor the effectiveness of the BMPs. Use monitoring data to make necessary adjustments and improvements, ensuring ongoing compliance and pollution control.

Optimize your BMPs with the assistance of Stormwater Pro. Our team can help you select, implement, and maintain effective BMPs tailored to your facility's needs, ensuring continuous compliance and water quality protection.

Step 6: Monitoring and Sampling Protocols

Monitoring and sampling are crucial elements of Level 1 and Level 2 ERA Plans. These protocols help track the performance of BMPs and ensure that stormwater discharges comply with regulatory standards.

Key Steps for Monitoring and Sampling:

Develop a Monitoring Plan: Create a detailed plan that outlines where, when, and how often to collect stormwater samples. Include specific locations that are most likely to represent pollutant sources.
Select Appropriate Sampling Methods: Use standardized methods for collecting and analyzing stormwater samples to ensure accuracy and reliability. This may include grab sampling during storm events or automated sampling systems.
Conduct Regular Sampling: Perform regular sampling during significant rain events to capture data on stormwater quality. Ensure samples are collected, preserved, and transported according to established protocols.
Analyze Results: Analyze the collected samples in a certified laboratory to determine pollutant concentrations. Compare these results against the numeric action levels specified by the IGP.
Document and Report Findings: Keep detailed records of all sampling activities, including dates, times, weather conditions, and laboratory results. Use this information to adjust BMPs to prepare required reports for regulatory agencies.

Ensure accurate and reliable stormwater monitoring with the help of Stormwater Pro. Our experts can assist you in developing comprehensive monitoring plans, conducting effective sampling, and interpreting results to maintain compliance and protect water quality.

Step 8: Training and Staff Awareness

Effective training and awareness programs are crucial for Level 1 & 2 ERA Plans. Educating your staff ensures that everyone understands compliance with the IGP and their roles in stormwater management.

Key Components of Staff Training:

Regulatory Requirements: Train staff on the key components of the IGP, including the importance of ERA Plans, monitoring requirements, and BMPs. Ensure they understand the implications of non-compliance.
BMP Implementation and Maintenance: Provide hands-on training for implementing and maintaining BMPs. This includes proper installation, regular inspections, and necessary adjustments to ensure effectiveness.
Emergency Response: Equip staff with the knowledge and skills to respond quickly and effectively to spills or other emergencies that could impact stormwater quality. Regular drills and updated protocols can help in maintaining readiness.
Documentation Practices: Educate staff on proper documentation procedures for all stormwater management activities, including inspections, sampling, and maintenance. Accurate record-keeping is essential for compliance and reporting.
Continuous Improvement: Promote a culture of continuous improvement by encouraging staff to identify and report potential issues and suggest improvements to current practices.

Enhance your staff training and awareness programs with Stormwater Pro. Our tailored training sessions will ensure your team is well-prepared to manage stormwater effectively and maintain compliance with all regulatory requirements.

Ensuring Ongoing Compliance and Improvement

Developing comprehensive Level 1 and Level 2 ERA Plans is essential for industrial facilities in California to comply with the IGP and protect water quality. Understanding your obligations, conducting thorough site assessments, implementing and updating BMPs, establishing robust monitoring protocols, maintaining accurate documentation, and training your staff, can effectively manage stormwater discharges and prevent pollution.

Navigating the complexities of stormwater regulations can be challenging. With support from Stormwater Pro, your facility can achieve and maintain compliance. We offer expert guidance and tailored solutions to help you develop, implement, and manage your ERA Plans, ensuring your operations are environmentally responsible and compliant.

Contact Stormwater Pro today to ensure your ERA Plans are comprehensive, effective, and compliant. Let us help you safeguard our water bodies and uphold the highest standards of environmental stewardship.