Stormwater / SMARTS Compliance (QISP; IGP ToR)
EHI focuses on compliance with the Statewide IndustrialStormwater General NPDES (National Pollutant Discharge Elimination System) permit; which is also known as the IGP.
The Storm Water program is managed by the State Water Resources Control Board (SWRCB) which regulates storm water discharges from locations such as industrial facilities and construction sites. EHI focuses on compliance with the Statewide Industrial General NPDES (National Pollutant Discharge Elimination System) permit, which is also known as the IGP. The SWRCB is responsible for (and to a certain extent relies on the staff of the nine Regional Water Quality Control Boards) for processing, reviewing, updating, instituting Notices of Intent (NOI) or termination (NOT) for coverage under the IGP. They also review and approve required annual stormwater reports, and maintain the billing status of each discharger.
On June 18, 2015,the California Stormwater Quality Association (CASQA), in association with the SWRCB, certified its inaugural class of IGP Trainers of Record (ToRs). This group of approximately 130 storm water experts was recognized by CASQA as the first Qualified Industrial Stormwater Practitioners (“QISPs”) under the revised IGP.
Mr. B. J. Atkins, founder and co-owner of Environmental HELP, Inc., was among the first water experts to be certified as a QISP, IGP-ToR (#006).
All industrial facilities subject to the stormwater regulations (some 50,000 facilities in California established by SIC Code) must either prepare & submit a No Exposure Certification (NEC) excluding them from the bulk of compliance requirements, or a (NOI) to come under the IGP. All those covered by the IGP enter as “baseline” facilities relative to the new numeric action levels (NALs – formerly thought of as benchmarks) discharge limits. If the quality of a Dischargers stormwater exceeds the NALs the Discharger goes from baseline to “level 1” status. A second exceedance puts the discharger in “level 2” status. A QISP must assist the Discharger in completing the mandatory Level 1 or Level 2 Exceedance Response Action and technical reporting requirements.
Other QISP responsibilities include assisting dischargers with implementing their SWPPPs and Monitoring Implementation Plans (MIPs), performing Annual Comprehensive Facility Compliance Evaluations, assisting in the preparation of Annual Reports, preparing Exceedance Response Action (ERA) Plans, and training Pollution Prevention Team members.
A ToR is an individual authorized to train QISPs. Current thinking on the part of the SWRCB is “classroom” training can occur only after the QISP candidate has received two days of “online” training and passed the related examination administered by CASQA.
The IGP allows a group of Dischargers of the same industry type to create a compliance group; Dischargers which operate facilities with similar types of industrial activities, pollutant sources, and pollutant characteristics (e.g., truck maintenance or paper recyclers). Compliance Groups must be led by a Compliance Group Leader, who must be a QISP-Trainer of Record. Each participant in a Compliance Group is responsible for their facility, but can benefit from the resources of the group to assist with program implementation (e.g., information sharing and the potential for sample frequency reduction). Only ToRs can act as compliance group leaders.
Storm Water Multiple Application and Report Tracking System = SMARTS has been developed to provide an online tool 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. The system will also allow the Regional Board and State Board staff to process and track discharger submitted documents. EHI can HELP with:
- SMARTS Registration and Data Entry Work,
- Development / amendment of site specific IGP related No Exposure Certification (NEC) & recertification
- SMARTS Technical Assistance including preparation and submittal of a Notice of Intent (NOI) / Change of Information (COI) / Notice of Termination (NOT),
- Development / amendment of site specific IGP related SWPPPs,
- Development / amendment of site specific IGP related MIPs,
- Recommendations for appropriate and cost-effective Best Management Practices (BMPs)
- Agency liaison and response to agency enforcement actions.
- EHI can HELP with required IGP training, permitting, monitoring, and reporting.
EHI is a full service environmental consulting firm, founded in 1989 to assist California businesses in managing their ever more complex regulatory compliance requirements.