How QISPs Can Help You Navigate Industrial General Permit Compliance

In the first two installments of our Stormwater Series, we covered the 10 Key Updates to the Industrial General Permit and examined IGP Enforcement Trends by Region and State. In this third installment, we explore the wide range of services that Qualified Industrial Stormwater Practitioners (QISPs) provide to help your facility stay compliant. 

What are QISPs? 

Qualified Industrial Stormwater Practitioners (QISPs) are professionals certified by the California State Water Resources Board (SWRCB) through a rigorous training and examination process to manage industrial stormwater compliance. They are knowledgeable about federal, state, and local stormwater regulations and are equipped to develop and implement effective Stormwater Pollution Prevention Plans (SWPPPs). QISPs play a crucial role in helping facilities adhere to the Industrial General Permit (IGP) requirements and ensure water quality protection. Their expertise in stormwater management makes them valuable partners to industrial facilities in achieving and maintaining compliance with environmental regulations. 

Environmental Consulting 

QISPs offer in-depth guidance on regulatory compliance, including: 

• Evaluating IGP Applicability: They help determine whether your facility needs to comply with the IGP, ensuring you understand the specific requirements that apply to your operations. For example, your facility could qualify for an No Exposure Certification (NEC) or a Notice of Intent (NOI), depending on the industrial materials and processes at your site. 
• Developing Comprehensive Stormwater Pollution Prevention Plans (SWPPPs): QISPs craft detailed plans to prevent stormwater pollution tailored to your facility’s unique characteristics and challenges. They can update plans to ensure facility changes are reflected in your documents.  
• Preparing Technical Reports: QISPs create Exceedance Response Action (ERA) Level 1 and Level 2 Technical Reports, Water Quality-Based Corrective Action Reports, and Time Schedule Orders to ensure compliance with regulatory standards. They track exceedances to verify when ERA reports will be needed or require updates.  
• Stormwater Litigation: There is an increase in enforcement not only by the SWRCB but also the organizations that help protect our environment, towards facilities that are exceeding IGP benchmarks year over year. Our QISPs can provide assistance with stormwater litigation responses and handle negotiations with these organizations.  

Monitoring Programs 

QISPs provide robust monitoring support, including: 

• Annual Stormwater Inspection: They conduct the required inspection by June 30 each year, identifying potential issues and recommending solutions. 
• Annual Reporting: QISPs prepare and submit Annual Reports through the Stormwater Multiple Application and Report Tracking System (SMARTS), ensuring accurate and timely compliance reporting. 
• Sampling and Monthly Inspections: They offer backup sampling and inspection services tailored to your facility’s needs, based on location and specific regulatory requirements. 
• Laboratory Analysis: QISPs collaborate with in-house laboratories for accurate analysis and prepare Ad Hoc Reporting on SMARTS, helping you stay on top of regulatory changes and requirements. 

Training 

QISPs conduct Annual Stormwater Training programs required for all industrial facilities. These programs ensure that your team is prepared to implement the necessary Best Management Practices (BMPs) and monitoring protocols, fostering a culture of compliance and environmental stewardship within your organization. 

Regulatory Compliance 

QISPs assist with preparing and submitting various permit applications, including: 

• Notice of Intent (NOI): Initiating coverage under the IGP. 
• No Exposure Certification (NEC): Certifying that industrial activities are not exposed to stormwater, reducing compliance burdens. 
• Notice of Non-Applicability (NONA): Declaring that a facility is not subject to IGP requirements, if applicable. 
• Notice of Termination (NOT): Ending IGP coverage when operations change or cease. 

These services ensure that your facility complies with IGP requirements and avoids penalties, providing peace of mind and regulatory assurance. 

Stormwater Management  

QISPs deliver tailored solutions to manage stormwater runoff effectively: 

• Addressing Inspector Concerns: They help meet industrial facility requirements, addressing any issues raised during inspections. 
• Site Investigations and Assessments: QISPs conduct thorough site investigations and assessments to identify the best available remedial treatment systems, ensuring compliance and environmental protection. 
• Responding to Regulatory Requests: They assist in responding to Notices of Violation, Notices of Non-Compliance, and other regulatory communications, such as Notices of Intent to Sue, helping navigate complex regulatory landscapes. 
• Developing Compliance Strategies: QISPs provide economically feasible strategies and remedial measures to comply with environmental regulations while protecting water quality, balancing compliance with operational efficiency. 

Contact a QISP today 

Understanding the value that QISPs provide is crucial for maintaining compliance and protecting our water resources. QISPs offer comprehensive services that ensure your facility meets the latest IGP requirements efficiently and effectively.  

At Montrose, we are here to help you easily navigate the IGP and ensure your facility meets the latest IGP requirements. Contact us today to discover how our stormwater experts can help you achieve environmental stewardship and full regulatory compliance for your site.