Bringing a Coating Manufacturer Back Into Stormwater Compliance

Service Area: Stormwater Management | Industrial General Permit (IGP) Compliance

The Challenge

When an industrial facility’s stormwater discharge exceeds California’s Numeric Action Levels (NALs), the consequences escalate fast. Under the Statewide Industrial General Permit (IGP), a single reporting year of exceedances can move a facility from Baseline into Level I Exceedance Response Action (ERA) status, triggering mandatory evaluations, technical reporting, and hard regulatory deadlines.

A coating manufacturer Orange County found itself in exactly that position. Sampling results from the prior reporting year had pushed the facility into Level I status in the state’s SMARTS database, putting them on the clock to complete a formal ERA Evaluation and submit a Level I ERA Technical Report before penalties or continued non-compliance set in.

They needed a qualified partner who could move quickly, navigate the IGP requirements, and get them back on solid footing before the deadline.

A-Tech’s Approach

A-Tech assigned a Certified Industrial Hygienist (CIH) and Qualified Industrial Stormwater Practitioner (QISP) to lead the engagement, supported by staff engineers and scientists. Our team built a phased program designed to address both the immediate compliance gap and the underlying practices driving the exceedance:

• Site visit, field activities, and ERA Evaluation. We mobilized with a site-specific Health & Safety Plan, audited the facility’s activities, equipment, and supplies, and conducted a full ERA Evaluation to confirm whether proposed response actions were adequate to resolve the exceedance.
• Level I ERA Technical Report. We prepared and submitted the required Technical Report into SMARTS ahead of the regulatory deadline.
• SWPPP compliance revision. We reviewed the facility’s existing Storm Water Pollution Prevention Plan, identified deficiencies, and recommended updated Best Management Practices (BMPs) to keep pollutants from leaving the site.
• QISP compliance training. We trained the facility’s pollution prevention team on SWPPP implementation, Annual Comprehensive Facility Compliance Evaluations, and ongoing ERA responsibilities, building internal capacity so compliance sticks.

The Results

A-Tech delivered a clear, deadline-driven path out of Level I status. The facility received a completed ERA Evaluation, a submitted Level I ERA Technical Report, a revised and defensible SWPPP, and a trained internal team equipped to maintain compliance going forward, turning a reactive regulatory problem into a managed, repeatable program.

The Takeaway

IGP exceedances don’t resolve themselves, and the deadlines aren’t flexible. With a QISP-led team and a structured ERA approach, A-Tech helps industrial facilities respond to stormwater exceedances quickly, document compliance properly, and reduce the risk of penalties, all while building the in-house knowledge to stay ahead of the next reporting year.

Frequently Asked Questions About Stormwater Compliance

What is the Industrial General Permit (IGP)?

The IGP is California’s statewide permit governing stormwater discharges from industrial facilities. It sets monitoring, reporting, and pollution prevention requirements that covered facilities must follow throughout each reporting year, which runs from July 1 to June 30.

What does Level I ERA status mean?

A facility moves into Level I Exceedance Response Action status when its sampling results exceed a Numeric Action Level for an applicable parameter. Reaching Level I requires the facility to work with a Qualified Industrial Stormwater Practitioner, complete an ERA Evaluation, and submit a Level I ERA Technical Report into the SMARTS database.

What is a Numeric Action Level (NAL)?

A NAL is the threshold the state uses to flag a potential stormwater problem. If discharge results exceed an annual or instantaneous maximum NAL for a parameter, the facility advances to the next ERA level and must respond accordingly.

What is a SWPPP?

A Storm Water Pollution Prevention Plan is a site-specific document that identifies potential sources of runoff pollution and sets out the Best Management Practices used to keep pollutants from leaving the site. Examples of BMPs include diversion dikes, silt fences, and inlet protection.

Who is a QISP and why do I need one?

A Qualified Industrial Stormwater Practitioner is the trained professional responsible for guiding a facility through IGP compliance. A QISP implements the SWPPP, performs Annual Comprehensive Facility Compliance Evaluations, assists with Annual Reports, and carries out Exceedance Response Actions.

How long do I have to respond to a stormwater exceedance?

Deadlines are set by the IGP and tied to the reporting year. Level I facilities generally must complete their ERA Evaluation and submit the Technical Report on a fixed timeline, so it helps to start early rather than wait.

What happens if my facility does not comply?

Non-compliance can lead to penalties, charges, and continued regulatory scrutiny. Acting quickly with a qualified team reduces that risk and helps return the facility toward Baseline status.

Does A-Tech handle the water sampling portion?

Yes. A-Tech can take on stormwater sampling and instruct your team on proper sampling procedures, since sampling methods themselves can sometimes affect water quality results. Sound protocols help prevent cross-contamination and inaccurate data that carry penalties for non-compliance. Beyond sampling, our stormwater work covers the full compliance picture: ERA Evaluations and Level I ERA Technical Reports, SWPPP development and revision, QISP-led compliance support and team training, and ongoing Annual Comprehensive Facility Compliance Evaluations. We can manage as much or as little of the program as your facility needs.