Stormwater Level 1 Reporting

Level 1 Status

Storm Water Permit regulatory changes (effective July 2015) require that facilities sample the stormwater discharge from there facility. The Discharger shall collect and analyze storm water samples from two (2) Qualified Storm Event (QSE) within the first half of each reporting year (July 1 to December 31), and two (2) QSEs within the second half of each reporting year (January 1 to June 30).


At the beginning of a Discharger’s NOI Coverage, all Dischargers have Baseline status for all sampling parameters. A Discharger’s Baseline status for any given parameter shall change to Level 1 status if sampling results indicate an NAL exceedance for that same parameter. Level 1 status will commence on July 1 following the reporting year during which the exceedance(s) occurred.

What is a NAL exceedance?
A facility has a NAL exceedance when instantaneous or average storm water samples collected at the facility exceed NAL levels for any parameter, per the storm water regulation.

What happens when I have a NAL exceedance?

Level 1 facilities must conduct a facility evaluation by October 1 and submit a Level 1 Report.

CDMS will address a Storm Water Industrial Permit Level 1 Exceedance Response Action (ERA) Evaluation and Report.

Assistance will be addressed under and certified by a registered Qualified Industrial Storm Water Practitioner (QISP), as is required by the Industrial Permit.


Initial Level 1 ERA Facility Evaluation

A QISP must conduct an evaluation of the facility in an attempt to identify the source of NAL exceedances that occurred over the previous storm water reporting year. The evaluation must consider such things as:

  • Facility processes and operations
  • Current Storm Water Pollution Prevention Plan
  • Current BMP’s being implemented at the site
  • Pollutant sources that may be related to NAL exceedances
  • Previous sample results
  • Evaluate additional BMPs to reduce the exceedance


Level 1 ERA Report

The facility must prepare and submit to the SMARTS reporting system, a Level 1 ERA Report including:

  • A summary of the Level 1 ERA Evaluation findings
  • A description of the SWPPP revisions and additional BMPs
  • Submitting updated Storm Water Pollution Prevention Plan documents (either updated by the Client or CDMS)
  • Identification of the Certified QISP that is appointed to the facility.


Storm Water Pollution Prevention Plan Updates

The facility must update their SWPPP to reflect any modifications or additional BMPs that will be incorporated in the plan to address the exceedance levels.


Storm Water Team Level 1 Training

As the Storm Water Plan will be updated to reflect changes to improve pollutant levels, The Storm Water team must be retrained in the Plan and its modifications. As a level 1 facility, Storm Water team training must be conducted by a QISP.




Contact CDMS for more information on how we can assist with addressing the Level 1 requirements at the Contact Information below.