7 Tips to Improve Your Stormwater Sampling Efforts | October 23, 2017

If it rained today, are you 100% confident that your industrial stormwater sampling efforts would be violation-free?

As we head into the storm season, we want to offer you some invaluable sampling tips that could help you avoid some common pitfalls and costly mistakes

1. Know Your Pollutants: Many dischargers are unaware of the entire suite of pollutants for which they must sample. At a minimum, you must collect samples for total suspended solids (TSS), oil and grease (O&G), and pH. In addition to these basic pollutants, you will need to collect samples for additional pollutants if they are present on site. Additional pollutants may be based on your intimate knowledge of certain pollutant-generating activities at your facility, your SIC code(s), and/or impairments in the downstream receiving waters. After you conduct this pollutant source assessment, confirm that all these pollutants are documented in your Storm Water Pollution Prevention Plan (SWPPP) for ongoing reference.
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2. Understand Your Site Drainage Patterns: Your site’s unique drainage patterns and industrial activities will define your sampling location(s), which are required to be shown on your Site Map. To determine your sampling location(s), first identify the point(s) at which stormwater exits the site during a storm event and then investigate “uphill” in all directions until a boundary can be defined. Look for clues, such as inlets, curbs, gutters, ditches, roof downspouts, or eroded ground cover. If your site features more than one drainage area, be sure to identify the pollutants that reside within each drainage area to ensure the proper testing regimens are submitted to the laboratory. You wouldn’t want to pay the lab to sample for metals three discharge points if metals were only present at one!

3. Establish a Trusted Relationship with Your Laboratory: Your sampling responsibilities extend beyond the sampling event itself. Have you selected an ELAP-certified laboratory accredited to test for your entire suite of pollutants? Have you ensured that the lab can perform the required pollutant-specific test methods? Are you satisfied with their customer service? If so, the next step is to ensure you have the appropriate number and type of sample containers, as well as the proper labels, forms, instructions, and chain of custody in your possession prior to the storm event. It is critical to plan, coordinate, and inquire with the lab ahead of time, as labs may not be able to answer in-depth questions on or around rainy days due to a high influx of samples (you won’t be the only one sending them your samples around that time). We also highly recommend that all the necessary labels and forms are filled out as much as possible before the storm event. The chain of custody is a legal document requiring a very specific information—an error here can make or break your entire effort!

4. Assign Sampling Responsibilities: When the storm arrives, there is not much time for anything less than execution. Due to the “flashy” and unpredictable nature of Southern California storms, you will usually have a very short time to collect your samples. Who is responsible to ensure that your facility—at all times—possesses the correct sampling equipment? Who is responsible for ensuring the samples are properly taken? Who is responsible for storing the samples—at 4 degrees Celsius—and ensuring they are transported to the laboratory within their specified holding time? Who will submit the sample results into SMARTS within 30 days of receipt from the laboratory? Once all these questions are answered, you must also determine who will be prepared to step in and perform any of these tasks during the absence of primary personnel.

5. Learn How to Sample Properly: Improper sampling techniques almost always cause or contribute to poor sampling results, which in turn lead to costly follow-up compliance efforts. Be sure to familiarize yourself with proper sampling techniques and procedures. If your site drains completely over the ground surface (i.e. no on-site drainage structures, inlets, etc.), then you likely face the seemingly insurmountable challenge of collecting runoff into the lab-issued container without compromising sample quality. This phenomenon is called “sheet flow” and—believe it or not—there is a way to increase your odds of collecting a decent sheet flow sample. Watch this video to learn more.

6. Collect Your Samples at the Right Time: Once you have taken all the necessary pre-storm measures, only then are you truly prepared to collect samples. When the rain does arrive, it is important to know that not every rain event is sample-worthy. A Qualifying Storm Event (QSE) is a precipitation event that produces discharge for at least one drainage area and is preceded by 48 hours with no discharge from any drainage area. If a QSE is underway during your normal business hours, then collect your samples within 4 hours of the start of the storm. Conduct your sampling regimen a minimum of four times per year: twice between July 1st and December 31st and twice between January 1st and June 30th. Lastly, remember to upload the sampling results into SMARTS within 30 days of receipt from the lab—otherwise they won’t be valid!

7. Get Help If You’re Overwhelmed: The Industrial General Permit is enforceable by State and Federal law, and as with any law, to violate its statues due to ignorance or negligence is not a valid defense. At any given time, failure to maintain compliance with the Industrial General Permit can result in swift legal action by an aggrieved party. With these 7 tips, our workshops, and the free resources we provide at IGPcomply.com, we hope to equip you with the information you need to effectively and independently manage your stormwater program because there is no substitute for the intimate knowledge and day-to-day operational insights that you alone possess. However, if you sense that your stormwater program might be vulnerable to noncompliance, we are here to come alongside and help you through your challenges. Do not brave the storm alone—give us a call.


How Stormwater Management Has Evolved and How It Needs to Mature |  June 20, 2017

Here is an interesting discussion about how our current perspective on managing stormwater needs to shift, due to ever-evolving cultural, environmental and financial dynamics. The author points out ten emerging stormwater management best practices occurring in leading programs around the globe that are, arguably, critical for future success. Check it out here.


A Little Rain Can’t Stop Us!  |  May 15, 2017

Thank you to all who attended our San Bernardino IGP workshop despite the rain (and we hope you used what you learned about stormwater sampling to promptly retrieve a good sample)! One of the great things about our workshops is that we take the time to answer questions specific to your facility; and we received some great questions from business owners and City staff alike! Are you interested in seeing how other businesses are handling the IGP process, or would you like to stay current on the ever-changing permit? Join the discussion on Linked In, where we can all share stories, ask questions and post up-to-date news about how the statewide IGP is being implemented. Whether you are a small business, a stormwater manager/inspector or a regulator – the more that join, the more we will ALL benefit from each other!


 Helping More Businesses in Riverside County  |  April 7, 2017

The turnout at our IGP workshops has been incredible, and the one this week at the Riverside Main Library was no different. We had a full house! Our co-presenters from Filtrexx always help to make these events a success, and their generous provision of a free catered lunch is always a hit. The goal of our workshops is to take a very complicated process and make it easier for the average business owner to understand. We jump right into what the permit is all about, how to determine what coverage is needed, and specific requirements to comply, all while taking the time to answer your questions along the way. We invite you to come out to our next workshop in San Bernardino on May 10 for another informative and interactive discussion.


The Word Is Getting Out About Stormwater Compliance  |  March 20, 2017

We are honored to be featured in an article by the Press Enterprise, that shines the spotlight on just how challenging it is becoming for businesses to comply with the new regulations under the IGP. While a No Exposure Certification (NEC) is ideal, it is often not possible, which adds unexpected time, costs and complications to small and large businesses alike. Our goals are to increase awareness and understanding of a very complicated set of ever-changing regulations, and to assist businesses in navigating and managing the process so they can get back to what they do best.


Taking Anaheim by Storm!  |  February 23, 2017

Ariel and Alex did an amazing job presenting at our workshop yesterday in Anaheim! Thanks to more time available, they were able to be even more thorough and answer individual questions throughout the presentation. This format provided added value for our attendees as we were able to address their specific site issues. We look forward to two more workshops nearby – We will be in Riverside on April 4, and San Bernardino on May 10. Partnering with Filtrexx gives us an opportunity to offer helpful BMP products for stormwater compliance solutions. We are grateful to be part of such a knowledgeable team of experts! Check out our IGP Workshops page for updated information on the next events.


 Another Successful IGP Workshop!  |  February 7, 2017

City of TemeculaAnother successful IGP workshop at the City of Temecula with our friends at Filtrexx! In addition, we had a guest speaker, Barbara Barry, who is a regulator for the Santa Ana RWQCB and who was able to offer some great insight as to how to avoid some common compliance issues. Weren’t able to make it? That’s okay! We have several more workshops on the calendar all around Southern California. Be sure to keep an eye on our website, www.igpcomply.com, for dates and locations so you are armed with information for navigating the complex stormwater regulations. Knowledge is power!


 Watch Out for Legal Action  |  January 18, 2017

Environmental Lawyers on the Lookout

Perhaps “IGP” is starting to sound familiar to most industrial businesses, since it has been nearly 2 years since it was introduced. However, for the many businesses that are still evading compliance under the new permit, we would like to issue a warning. With the grace period now over, environmental groups are becoming aggressive in pursuit of legal action against noncompliant businesses. Private attorneys and outside environmental groups are making it their jobs to sift through regulatory paperwork (it is all public!), identifying companies to take to court for violating clean water laws. Penalties can reach as much as $37,500 per violation, and those violations can add up quick, whether or not you are aware of them. Once you are targeted, things can escalate quickly – consider this story with a sad ending. Read More

We can help you avoid running into legal action. If you need help navigating the new permit, and understanding what it means for your business, give us a call today, or visit us at one of our workshops below.

A Calendar of Workshops

TRWE is pleased to kick-off 2017 with a calendar full of workshops to choose from, thanks to interest from city and chamber sponsors, as well as our partnership with Filtrexx Sustainable Technologies. Right now, our Southwest Riverside workshop is open for registration, and registration for other upcoming workshops will be available soon:

  • SW Riverside – February 2
  • Orange County – February 22
  • Riverside – April 5
  • San Bernardino – May 10
  • Chula Vista – TBD

For an up-to-date list, visit our new IGP Workshops webpage!

New Stormwater Group on LinkedIn

We invite you to join the new California Industrial Stormwater Group on LinkedIn. This is a place to share stories, ask questions and post news about how the statewide IGP is being implemented. The IGP represents the largest regulatory impact to small local businesses in the last 20 years. This forum is designed to help businesses, cities and regulators be successful in the compliance process by offering resources and expert guidance. It is an opportunity for stormwater professionals to support one another, share ideas, and provide up-to-date news and information. The more that join, the more we will ALL benefit from each other, whether you are a small business, a storm water manager/inspector or a regulator, so SPREAD THE NEWS!


Tory R. Walker, PE, CFM, LEED GA, QISP


Site Maps, SWPPPs, and Sampling – Oh My!  |  June 17, 2016

Similar to last summer, TRWE will be presenting a free IGP workshop for North County industrial businesses at the City of San Marcos on July 21st (seating is limited so RSVP). This time we’re going to focus on proper site maps, stormwater pollution prevention plans (SWPPP), observations and sampling, and actions to take if you’ve gone up to Level 1 due to your sampling results.  We are offering this workshop based on our observation that many businesses are still struggling with the new IGP requirements as we approach the end of the reporting year. Below are some of the common issues, which will be addressed in greater detail at the workshop:
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  • How to properly enroll and maintain permit coverage
    • If the primary economic activity of your business is described here or here (same info, different breakdowns) you need to enroll in the permit—even if your entire operation is indoors. This four-digit number is your SIC code.
    • NEC is No Exposure Certification. To meet NEC requirements your business must comply with the NEC Checklist (page 7). If it does not you must enroll NOI (Notice of intent).
  • How to create proper site maps
    • Site maps are extensive and their requirements can be found in Section X.E (page 26) of the IGP.
  • How to develop and implement a proper stormwater pollution prevention plan (SWPPP)
    • Your SWPPP identifies what your business will do to prevent stormwater pollution.  It needs to be personalized to your facility.
    • The California Stormwater Quality Association provides an IGP-specific template to start from for $160 here.
  • How to sample properly
    • Proper sampling is complex and VERY site specific.  We are offering an IGP workshop on July 21st at the City of San Marcos that will cover basic sampling. We also offer personalized site consultations.
    • NOI enrollment requires sampling from 4 qualifying storm events per year: 2 collected between July 1st-December 31st and 2 more collected between January 1st-June 30th.
    • All NOI enrolled businesses are required to sample for pH, Oil and Grease (O&G), and Total Suspended Solids (TSS).
    • In addition to pH, O&G, and TSS, other constituents may also be required based on your industrial activity.
    • You must evaluate pH on-site (within 15 minutes of sample collection).
    • All other contaminants must be analyzed by an ELAP certified lab (view labs on a map).
  • How to formally submit sample results
    • Results must be reported in an AD HOC report in SMARTS within 30 days of receipt.
    • No result should be reported as zero (0) in SMARTS; instead report the method detection limit (MDL)–not to be confused with the reporting limit (RL).
    • Also be aware of numbers that don’t make sense, if your pH is 2 (very acidic) then there may be a contaminant or a technique issue causing that result.

Still lost? To help simplify the major points of the IGP we have created a flow chart, to help you figure out how to navigate through the myriad requirements of the permit.  Please take some time to walk through it, and see what you need to address.

Don’t forget:

  1. Businesses with sampling results in excess of numeric action levels (NALs) will automatically enter into “Level 1” on July 15th and are required to use the services of a Qualified Industrial Stormwater Practitioner (QISP) to take their next steps.
  2. NOI annual reports are due July 15th
  3. NEC recertification is due October 1st

We at Tory R. Walker Engineering provide full IGP service; whether you’re looking for someone to briefly look over your current documentation and make recommendations for improvement or someone to create an entire SWPPP – we can help.  We also have QISPs on staff who are ready to assist you with your Level 1 requirements.

If you’re looking for more information on the requirements of the IGP check out our Helpful Resources, and do not hesitate to contact us at Tory R. Walker Engineering; we are your North County stormwater resource.


Ariel Lewis
Junior Engineer, QISP


Are you Staying Dry?  |  May 5, 2016

Regardless of how much it rained this past year, stormwater compliance is always in effect.  Since our last workshop, the Industrial General Permit (IGP) is about to require all facilities to take some unfamiliar steps. I’d like to take a moment of your time to introduce you to some of these fast approaching compliance measures and to provide you with a few updates:
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Upcoming Compliance Workshop
TRWE is planning to hold a workshop to prepare Notice of Intent (NOI) dischargers for the unique challenges you will navigate through during the upcoming 2017 permit year. The workshop will be a joint effort between TRWE, several North County cities, local chambers of commerce, and the San Diego Regional Water Quality Control Board. Are you interested in attending? Let us know! More details to follow.

NOI/NEC Webcast
Are you having difficulties understanding the IGP enrollment process? The SWRCB is offering a free webcast to all interested parties on May 10, 2016. The live webcast will begin at 8:30 – Don’t miss out on this limited opportunity!

Annual Report and Annual Recertification
Regardless if you are a Notice of Intent (NOI) or a No Exposure Certification (NEC) facility, you have yearly submittals that must be submitted via SMARTS by the annual deadline:
NOI facilities must submit the Annual Report by July 15. Failure to report is a violation of the permit.
NEC facilities must recertify NEC coverage by October 1. Annual recertification is not an automatic process, and failure to do so will result in a permit violation. This can be an overwhelming process, but we can help.

QISP Training
Did your 2015 stormwater samples come back from the lab with levels that exceed the IGP’s Numeric Action Levels (NALs)? If so, the IGP requires you to now work with a Qualified Industrial Stormwater Practitioner (QISP) to take several measures as you prepare your compliance efforts for 2016. There is no substitute for a QISP.
The State Water Resources Control Board (SWRCB) announced that its QISP Training Program will go live May 1, 2016. The only requirement to become a QISP is to complete the QISP Training Program. For more details on the Training Program, or to see if you will need a QISP, check out the QISP Fact Sheet.

Does your facility have an NOI? If so, remember that sampling is a critical component of your compliance efforts. Improper sampling techniques may cause or contribute to poor sampling results. Be sure to have your samples sent to an ELAP-certified laboratory within the required holding time and then upload the results into SMARTS within 30 days—otherwise the sample results are not valid! Do you have someone on-call to help with water quality sampling?

Do you have Notice of Intent (NOI) coverage? If so, did you know that later this year you will be required to take extra measures to ensure you are compliant with local Total Maximum Daily Loads (TMDLs)? To find out which TMDL may apply to you, use our map!

TMDLs are quantitative assessments of water quality problems, their contributing sources, and corresponding control actions needed to restore and protect bodies of water. For example, a TMDL was adopted in 2010 for the many San Diego beaches and creeks impaired by bacteria. The bacteria TMDL identified several sources, including our storm drain systems, agricultural lands, and wildlife habitats. The IGP is soon requiring NOI facilities located within TMDL areas to corroborate with the contaminant load reduction efforts, which may require you to revise your SWPPP and conduct additional monitoring and sampling. Visit the San Diego Water Board IGP TMDL page for more information.

Those are all the updates I have for now. If you would like further guidance on how to approach your industrial stormwater compliance efforts, shoot me an email or give me a call. We hope to empower you so that you can focus on what you do best.

Best Regards,

Alex J. Smith
Water Resource Control Engineer


Learning the Impact of New IGP Regulations  |  May 25, 2015

We enjoyed working with a team of four senior students from California State University San Marcos, in providing an opportunity for their Senior Experience “Capstone” Project.  They were able to learn about the regulations under the new Industrial General Permit (IGP), and survey many of the affected local businesses in North County. We were then featured in the San Diego Business Journal regarding our involvement in the CSUSM program. Check out the article for more information!