Industrial General Permit (IGP) Compliance Guide for California Facilities

California’s Industrial General Permit (IGP) establishes the statewide framework for facilities that discharge stormwater associated with regulated industrial activities. It governs permit enrollment, Stormwater Pollution Prevention Plan (SWPPP) implementation, monitoring, sampling, and electronic reporting through SMARTS. The current permit, Order 2014-0057-DWQ (as amended), remains administratively continued until a replacement permit becomes effective. Whether coverage applies depends on a facility’s actual industrial activities together with the regulated Standard Industrial Classification (SIC) Code categories identified in Attachment A.

For Plant Managers and Operations Managers responsible for industrial facilities in Los Angeles and surrounding Southern California communities, the challenge extends beyond obtaining permit coverage. Daily compliance requires coordinating permit enrollment, Qualifying Storm Event (QSE) sampling, laboratory results, Numeric Action Level (NAL) evaluations, SMARTS reporting, and Exceedance Response Action (ERA) requirements while maintaining normal facility operations.

This guide explains how those requirements fit together—from determining permit applicability and selecting the appropriate enrollment pathway to managing monitoring, reporting, SWPPP implementation, and ERA obligations. Whether you oversee a manufacturing facility in Los Angeles, a warehouse in Anaheim, a recycling operation in the City of Orange, or another regulated industrial site in the Los Angeles area, SoCal Stormwater Solutions can assist with required documentation and reporting and provide site-specific guidance based on facility conditions and applicable permit requirements.

For a broader overview of California stormwater permits, SWPPP requirements, monitoring responsibilities, and regulatory risk-management considerations, see The Ultimate California Stormwater Compliance Handbook: SWPPP, Permits, and Risk Management. This guide builds on that statewide framework by focusing specifically on the operational requirements of the Industrial General Permit.

 

Scope and Applicability of the California Industrial General Permit

The first question most Plant Managers and Operations Managers need to answer is straightforward: Does my facility actually require Industrial General Permit (IGP) coverage?

Getting that determination wrong can affect every step that follows, from permit enrollment and monitoring obligations to SWPPP implementation, SMARTS account setup, reporting accuracy, and preparation for Regional Water Quality Control Board inspections and state reporting requirements. Establishing the correct applicability at the outset creates a more reliable compliance workflow and avoids building later processes on the wrong regulatory foundation.

Facilities that conduct stormwater discharges associated with regulated industrial activities identified under the Statewide General Permit for Stormwater Discharges Associated with Industrial Activities (Order 2014-0057-DWQ, as amended) generally require permit coverage. Applicability is determined by evaluating the facility’s actual industrial activities together with the regulated Standard Industrial Classification (SIC) Code categories identified in Attachment A.

The Industrial General Permit is structured around the industrial activities occurring at the facility rather than how the business is described in corporate records or general industry descriptions. Two facilities within the same industry sector may have different permit obligations because the regulated industrial activities occurring on-site are different.

The Standard Industrial Classification (SIC) Code is an important part of the applicability review, but it is not evaluated in isolation. Attachment A of the permit identifies the regulated SIC Code categories associated with industrial stormwater requirements. During the applicability review, those regulated categories are considered alongside the facility’s actual industrial activities to determine whether the operation falls within the scope of the permit. Facilities with multiple business functions should evaluate each regulated industrial activity occurring on-site rather than relying solely on a single SIC designation.

Attachment A therefore serves as the primary reference for identifying regulated industrial activities and associated SIC Code categories during the applicability determination. It helps identify whether regulated industrial activities are present, providing the framework for determining whether Industrial Stormwater Permit Compliance requirements apply. After applicability has been determined, facilities can identify the appropriate permit enrollment pathway and associated compliance obligations. Additional guidance on applicability and permit administration is available through the California Industrial Stormwater Program.

As of 2026, Order 2014-0057-DWQ, including subsequent amendments, remains administratively continued until a replacement Industrial General Permit becomes effective. Facilities that are subject to the current permit continue to follow its operative requirements during this administrative continuation period.

Determining permit applicability correctly is the starting point for every subsequent compliance activity. Once coverage has been established, facilities can determine the appropriate permit enrollment pathway before implementing the monitoring, sampling, SWPPP, and reporting requirements that apply under the permit.

The next step is determining the appropriate permit enrollment pathway based on the facility’s coverage eligibility and operating conditions.

 

Determining Your Permit Enrollment Pathway

Once a facility has determined that its operations fall within the scope of the Industrial General Permit (IGP), the next decision is selecting the correct enrollment pathway. This step establishes the administrative framework that governs the facility’s permit obligations, including applicable SMARTS documentation, monitoring responsibilities, SWPPP requirements, and reporting workflows, depending on the selected enrollment pathway. Choosing the wrong pathway can create unnecessary reporting work or leave important documentation incomplete.

Not every regulated facility follows the same enrollment process. The appropriate pathway depends on the facility’s operational conditions and how those conditions align with the requirements of the current permit. A project-specific review is essential to determine whether full permit coverage is required, whether qualifying no-exposure conditions are maintained, or whether the facility falls outside the scope of the permit.

Enrollment Pathway	Eligibility Criteria	Monitoring / Sampling Requirements	SMARTS Documentation Obligations
Notice of Intent (NOI)	Required When a Facility Conducts Regulated Industrial Activities and Requires Coverage under the Industrial General Permit for Authorized Stormwater Discharges Associated with Industrial Activity	Subject to Applicable SWPPP, Monitoring, Sampling, Inspection, Reporting, and Other Permit Requirements	Permit Registration Documents (PRDs), Including the NOI and Required Supporting Documents, Are Electronically Submitted through SMARTS and Maintained throughout Permit Coverage
No Exposure Certification (NEC)	Available Only When the Facility Demonstrates That Industrial Activities and Materials Are Completely Protected from Stormwater Exposure and All Permit No-Exposure Conditions Are Satisfied	Facilities with an Approved NEC Are Not Subject to the Industrial General Permit’s SWPPP, Monitoring, or Sampling Requirements While Qualifying No-Exposure Conditions Are Maintained	NEC Permit Registration Documents Are Submitted through SMARTS. Facilities Must Annually Re-Certify That No-Exposure Conditions Continue and Update Coverage If Site Conditions Change
Notice of Non-Applicability (NONA)	May Be Appropriate Only When a Facility Qualifies under One of the Specific Non-Applicability Provisions Identified in the Industrial General Permit. Eligibility Requires a Facility-Specific Technical Evaluation and Supporting Documentation Consistent with the Applicable NONA Provision	Standard Industrial General Permit Monitoring and Sampling Requirements Do Not Apply If Valid NONA Coverage Has Been Established under the Permit	Required Permit Registration Documents and Supporting Technical Documentation, Where Applicable, Are Submitted through SMARTS in Accordance with the Applicable NONA Provision
Operational Outcome	Determines Whether the Facility Enrolls through an NOI, Maintains Qualifying No-Exposure Status, or Documents That the Permit Does Not Apply under a Specific NONA Provision	Defines Whether Ongoing Monitoring and Sampling Obligations Apply under the Permit	Establishes the Documentation and Recordkeeping Framework That Will Be Maintained throughout the Facility’s Enrollment Status

Selecting the correct enrollment pathway affects much more than the initial filing. An unnecessary NOI can create monitoring, reporting, and administrative responsibilities that would not otherwise apply, while incorrectly claiming NEC or NONA status can require additional review if facility conditions do not satisfy the permit criteria. The objective is not to select the most convenient pathway, but to match documented site conditions with the applicable regulatory mechanism established by the permit.

That evaluation should be based on documented site conditions and actual industrial activities rather than assumptions about the business or its past permitting history. The chosen enrollment pathway establishes the framework for subsequent SWPPP preparation, monitoring responsibilities, SMARTS workflows, inspection readiness, and reporting obligations throughout the life of the permit. 

Facilities preparing NOI, NEC, or NONA documentation often benefit from organized administrative processes before submitting Permit Registration Documents. Maintaining complete records and coordinating supporting information during compliance document and permit registration document preparation can simplify the initial enrollment process and reduce the need to revisit incomplete documentation later.

Industrial facilities throughout Los Angeles and surrounding Southern California communities can rely on SoCal Stormwater Solutions to assist with required documentation and reporting, provide site-specific guidance based on facility conditions and applicable requirements, and help support compliance with applicable permit requirements while the facility retains responsibility for determining and maintaining the appropriate enrollment pathway.

 

Qualifying Storm Event (QSE) Sampling and Monitoring Protocol

A Qualifying Storm Event (QSE) is the starting point for stormwater sampling under the California Industrial General Permit (IGP). Under the permit, a QSE is a precipitation event that produces a stormwater discharge from at least one drainage area and is preceded by 48 hours with no discharge from any drainage area. Once those conditions are met, the applicable monitoring, visual observation, and sampling requirements established by the permit become part of the facility’s operational workflow.

Each applicable discharge location must be monitored according to the permit’s monitoring requirements unless representative sampling or another permit-authorized monitoring approach applies.

Successful sampling depends less on reacting to rainfall than on preparation before the storm arrives. For example, a warehouse in Los Angeles or a manufacturing facility in Anaheim may benefit from preparing sampling equipment and confirming discharge locations before forecasted storm events. Facilities that organize equipment, identify discharge locations, coordinate personnel, and establish documentation procedures in advance are better positioned to complete required monitoring while minimizing disruption to production schedules and normal site operations.

Step 1 — Confirm the Qualifying Storm Event

The first task is confirming that the rainfall event satisfies the permit definition of a QSE rather than assuming every storm requires sampling. This includes reviewing localized weather information, documenting the antecedent no-discharge period, and confirming that stormwater is discharging from at least one monitored drainage area. Weather forecasts can help teams prepare personnel and equipment, but the determination is based on actual field conditions and the permit definition—not the forecast itself. 

Maintaining a simple field log of rainfall timing, discharge observations, and weather conditions provides valuable context for later documentation and supports consistent monitoring records.

Step 2 — Conduct Required Visual Observations

Once a qualifying discharge is confirmed, visual observations should be completed in accordance with the permit’s monitoring requirements. During the sampling event, facility personnel document observable discharge characteristics such as color, clarity, floating materials, foam, sheen, suspended solids, and other visible indicators relevant to stormwater quality.

The permit requires sampling and associated observations to occur within four hours of the start of discharge during scheduled facility operating hours, or within four hours after scheduled operating hours begin if the qualifying discharge started during the previous twelve hours. Sampling is only required when it can be conducted safely, and the permit recognizes that unsafe field conditions should not place personnel at risk. 

Step 3 — Collect Representative Stormwater Samples

Representative sampling begins by identifying the designated discharge locations that reflect stormwater leaving the monitored drainage areas. Samples should be collected using laboratory-supplied containers appropriate for the required analyses while avoiding practices that could contaminate or alter the sample before laboratory testing.

Field personnel should document the sampling location, collection time, weather conditions, discharge observations, and other information needed to maintain a complete field record. Where representative sampling is allowed under the permit, the selected location should accurately reflect the discharge characteristics of the applicable drainage area. Protecting sample integrity from collection through laboratory delivery is just as important as collecting the sample itself. 

Step 4 — Maintain Chain of Custody and Laboratory Transfer

Once samples are collected, maintaining an unbroken chain of custody becomes the next priority. Chain-of-custody documentation records who collected the sample, when custody changed, and when the laboratory accepted responsibility for the sample.

Samples should be transferred to an ELAP-certified laboratory using the appropriate preservation methods and within the applicable analytical holding times specified for the required tests. Maintaining complete laboratory documentation supports later reporting and helps demonstrate that analytical results can be traced back to properly collected field samples.

Plan Monitoring Across the Reporting Year

For facilities subject to standard monitoring requirements, the permit generally requires sampling during four Qualifying Storm Events per reporting year, with two qualifying events between July 1 and December 31 and two qualifying events between January 1 and June 30, when sufficient qualifying events occur. If an adequate number of QSEs do not occur during a reporting period, the permit provides specific provisions addressing those circumstances rather than requiring facilities to create additional sampling opportunities. 

Because qualifying storms cannot be scheduled, operational planning is essential. Keeping sampling equipment ready, confirming discharge locations before the wet season, coordinating laboratory availability, and preparing field documentation in advance can reduce disruption when a qualifying event occurs.

Industrial facilities throughout Los Angeles and surrounding Southern California communities can turn to SoCal Stormwater Solutions for assistance with required documentation and reporting, site-specific guidance based on facility conditions, and support for inspections, monitoring, Qualifying Storm Event sampling, and laboratory coordination.

 

Navigating Numeric Action Level (NAL) Exceedances1 2

A Numeric Action Level (NAL) evaluation under the California Industrial General Permit (IGP) uses two independent methods: Annual Average and Instantaneous Maximum. Each applies different analytical mechanics to laboratory results collected during the reporting year. An NAL exceedance is a regulatory trigger for further evaluation under the permit—it is not an automatic permit violation.

Laboratory reports become meaningful only after they are evaluated using the permit’s prescribed methods. Reviewing an individual analytical result in isolation does not indicate whether an Annual Average NAL has been exceeded, while averaging results cannot determine whether an Instantaneous Maximum NAL has occurred. Understanding the distinction allows facility teams to interpret monitoring data correctly before considering any subsequent permit obligations.

Annual Average NAL

The Annual Average NAL evaluates analytical results collected for a single monitoring parameter across the entire July 1 through June 30 reporting year. All laboratory analytical results for that parameter are considered together, and the arithmetic mean of those results is calculated. That calculated annual average is then compared with the corresponding Annual Average NAL established by the Industrial General Permit.

An Annual Average NAL exceedance occurs when the calculated arithmetic mean exceeds the applicable Annual Average NAL for that parameter. Because this evaluation incorporates all qualifying analytical results collected during the reporting year, it reflects overall monitoring performance rather than a single elevated sample. 

Instantaneous Maximum NAL

The Instantaneous Maximum NAL follows a different evaluation method. Rather than calculating an annual average, each laboratory analytical result is compared individually with the applicable Instantaneous Maximum threshold established by the permit.

Under the current Industrial General Permit, an Instantaneous Maximum NAL exceedance occurs when two or more analytical results for the same parameter within a reporting year exceed the applicable Instantaneous Maximum threshold for Total Suspended Solids (TSS) or Oil and Grease (O&G), or fall outside the applicable Instantaneous Maximum range for pH. This approach evaluates repeated individual exceedances rather than the overall arithmetic average of all monitoring results. 

These two evaluation methods operate independently. A facility may experience an Annual Average exceedance without meeting the Instantaneous Maximum criteria, or vice versa. One calculation does not replace the other, and both are evaluated separately under the permit framework. 

Each evaluation method is performed independently using the analytical criteria established for that parameter under the Industrial General Permit.

Evaluation Method	Annual Average NAL	Instantaneous Maximum NAL
Calculation method	Arithmetic Mean of All Applicable Analytical Results for a Parameter Collected During the Reporting Year	Individual Analytical Results Compared Separately with the Applicable Instantaneous Maximum Threshold
Reporting-year basis	Uses All Applicable Results Collected Between July 1 and June 30	Evaluates Each Applicable Analytical Result Individually During the Reporting Year
Parameters evaluated	Parameters with applicable Annual Average Numeric Action Levels	Instantaneous Maximum Thresholds for TSS, Oil and Grease (O&G), and pH
Trigger mechanics	Average Concentration Exceeds the Applicable Annual Average NAL	Two or More Applicable Analytical Results Exceed the Applicable Instantaneous Maximum Threshold, or Two or More Applicable pH Results Fall Outside the Applicable Permit Range
Evaluation focus	Overall Pollutant Performance Across the Reporting Year	Repeated Individual Exceedances During the Reporting Year

Waiting until Annual Report preparation to review laboratory data can make it more difficult for industrial facilities in Los Angeles and surrounding communities to recognize developing trends in pollutant concentrations or assess whether existing Best Management Practices (BMPs) are performing as intended. Reviewing analytical results after each monitoring event provides an opportunity to evaluate recurring patterns, compare results across sampling events, and understand how operational activities may influence stormwater quality before reporting deadlines arrive.

Industrial facilities throughout Los Angeles and surrounding Southern California communities can also rely on SoCal Stormwater Solutions to assist with required documentation and reporting, help identify and address stormwater-management needs, provide site-specific guidance based on facility conditions and applicable requirements, and support laboratory coordination, analytical result evaluation, stormwater monitoring review, and ongoing monitoring activities.

 

The Exceedance Response Action (ERA) Implementation Pathway 3

When applicable Numeric Action Level (NAL) exceedances result in Level 1 or Level 2 status under the California Industrial General Permit, the Exceedance Response Action (ERA) process becomes mandatory for the affected parameter. SMARTS assigns the applicable regulatory Level status for each parameter annually on July 1 based on prior-year monitoring data submitted by June 30 and permit-defined criteria. If qualifying results are reported after June 30, the facility’s status may change when those results are reported, as provided by the permit.

The ERA process begins only after monitoring results have already been evaluated under the permit’s Numeric Action Level framework. A NAL exceedance alone is not a permit violation. Instead, the ERA pathway establishes a structured process for investigating pollutant sources, evaluating BMPs, documenting findings, and implementing required measures.

Failure to complete and submit required ERA actions and documents on time constitutes noncompliance with the permit.

Each stage introduces additional technical responsibilities, reporting milestones, and documentation requirements designed to help facilities evaluate recurring exceedances systematically. 

Step 1 — Transition from Baseline Status to Level 1

Baseline status applies on a parameter-specific basis before the applicable criteria place that parameter into Level 1 or Level 2 status. Following the close of each reporting year, SMARTS assigns the facility’s applicable regulatory Level status annually on July 1 based on submitted prior-year monitoring data and permit-defined criteria. SMARTS calculations and notifications assist the discharger, but the facility remains responsible for independently tracking monitoring results, NAL exceedances, regulatory status, reporting obligations, and applicable deadlines. 

Once the permit criteria for Level 1 status are met, the facility moves into the first stage of the ERA process for the affected parameter. From that point forward, the emphasis shifts from evaluating laboratory data to understanding why the exceedance occurred and determining whether existing stormwater controls remain appropriate. 

Step 2 — Required QISP Participation

When Level 1 ERA requirements apply, participation by a Qualified Industrial Stormwater Practitioner (QISP) is required under the Industrial General Permit. The Discharger completes the required Level 1 ERA Evaluation with the assistance of a Qualified Industrial Stormwater Practitioner (QISP). The evaluation addresses industrial pollutant sources that are or may be related to the NAL exceedance, corresponding BMPs in the SWPPP, and any additional BMPs or SWPPP revisions needed under the permit.

Although the evaluation may focus on drainage areas where the NAL exceedance occurred, the Level 1 ERA Evaluation must address all facility drainage areas as required by the permit.

The QISP’s responsibilities extend beyond identifying potential causes of an exceedance. The evaluation includes reviewing drainage areas, industrial activities, exposed materials, housekeeping practices, source-control measures, and other site conditions relevant to the affected parameter so the ERA process is supported by documented technical findings rather than assumptions.

Step 3 — Level 1 ERA Workflow4

The Level 1 process follows a defined operational sequence:

Facility assessment

↓

Pollutant-source investigation

↓

BMP evaluation

↓

SWPPP review

↓

Identify required additional BMPs and SWPPP revisions

↓

Implement identified additional BMPs and revise the SWPPP as necessary

↓

Preparation of the Level 1 ERA Evaluation

↓

Preparation of the Level 1 ERA Report

↓

Certification and submission through SMARTS

Rather than functioning as independent tasks, each stage builds on the findings of the previous step. The facility assessment establishes the areas requiring review, pollutant-source tracing evaluates where the affected parameter may originate, BMP evaluation determines whether existing controls remain effective, and the resulting findings support any SWPPP revisions before the Level 1 ERA Evaluation is completed with QISP assistance and the QISP prepares the Level 1 ERA Report for certification and submission through SMARTS.

After Level 1 status is assigned on July 1, the required Level 1 ERA Evaluation must be completed by October 1. The Level 1 ERA Report must be prepared by a QISP and certified and submitted through SMARTS by January 1 following the Level 1 status determination. Although the QISP prepares the technical evaluation and report, electronic certification responsibilities remain with the facility’s Legally Responsible Person (LRP) or Duly Authorized Representative (DAR).

Facilities should independently track these deadlines regardless of SMARTS notifications or automated status updates. 

Step 4 — Transition to Level 2

Entering Level 2 is not an automatic consequence of reaching Level 1. Instead, subsequent monitoring results are evaluated according to the permit’s Level 2 criteria during later reporting cycles. A parameter progresses from Level 1 to Level 2 when sampling results show another NAL exceedance for that same parameter while the facility is in Level 1 status. Level 2 status generally begins on July 1 following the reporting year in which the exceedance occurred; results reported after June 30 may change the status when reported, as specified by the permit.

This progression reflects the permit’s increasing emphasis on demonstrating that pollutant sources have been thoroughly evaluated and that appropriate corrective measures have been considered when monitoring results continue to satisfy the permit-defined Level 2 criteria for the same parameter. 

Step 5 — Level 2 ERA Implementation

Level 2 requires a broader technical evaluation than Level 1. The process expands pollutant-source investigations, re-evaluates existing BMP performance, considers additional operational or structural controls where appropriate, and requires preparation of both a Level 2 ERA Action Plan and a Level 2 ERA Technical Report prepared through the required QISP process.

The Level 2 ERA Action Plan identifies the activities needed to complete the required demonstrations, outlines implementation tasks, and addresses, at a minimum, each drainage area with a corresponding Level 2 NAL exceedance. All elements of the Action Plan must be implemented as soon as practicable and completed no later than one year after the Action Plan is submitted.

The Level 2 ERA Technical Report follows the Action Plan and documents the technical demonstrations selected under the permit. Depending on facility conditions, those demonstrations may involve industrial activity BMP evaluations, non-industrial pollutant source evaluations, or natural background source evaluations. Where appropriate, facilities may revise operational BMPs, implement structural BMP improvements, evaluate treatment controls, or document technical demonstrations recognized by the permit. The Technical Report is prepared by a QISP and certified and submitted by the facility’s LRP or DAR through SMARTS.

Industrial facilities throughout Los Angeles and nearby Southern California communities entering Level 1 or Level 2 ERA status often need to coordinate site assessments, stormwater inspections, routine monitoring, laboratory activities, and technical documentation within permit-defined timelines. Facilities seeking additional field support during an active ERA process can review inspections and monitoring for industrial facilities to understand how site evaluations, monitoring activities, and documentation support fit into the broader ERA workflow.

Requirement	Baseline Status	Level 1	Level 2
Regulatory Status	Parameter-Specific Baseline Status Before Applicable ERA Criteria Are Met	First ERA Stage After Applicable Criteria Are Met	Advanced ERA Stage After Applicable Level 2 Criteria Are Met
QISP Requirement	Not Required Solely Because of Baseline Status	Required for the Level 1 ERA Process	Required for the Level 2 ERA Process
Facility Assessment	Routine Permit Evaluations	Required QISP-assisted Level 1 ERA Evaluation Addressing All Drainage Areas	Expanded Technical Assessment
Pollutant Source Investigation	Routine Review of Facility Conditions During Normal Permit Implementation.	Required QISP Investigation Tracing the Affected Parameter to Specific Drainage Areas, Industrial Activities, Exposed Materials, Operational Practices, and BMP Effectiveness.	Expanded Technical Investigation Supporting the Level 2 ERA Action Plan and Technical Report, Including Additional Source Evaluations and Permit-Recognized Technical Demonstrations Where Applicable.
ERA Documentation	No Level 1 or Level 2 ERA Document Solely Due to Baseline Status	Level 1 ERA Evaluation and Report	Level 2 ERA Action Plan and Technical Report
SWPPP Updates	Routine Maintenance	Revise the SWPPP as Necessary and Implement as Soon as Practicable and No Later than January 1	Updated as Required by Action Plan Implementation and Technical Findings
SMARTS Reporting	Routine Permit Reporting	Level 1 ERA Report Submission	Action Plan and Technical Report Submissions, Plus Subsequent Updates Where Required
BMP Evaluation	Routine Review	Evaluation of existing BMP effectiveness	Expanded BMP Analysis and Additional Controls Where Appropriate
Corrective Measures	Implementation and Maintenance of Applicable SWPPP BMPs	Additional BMPs Identified Through the Level 1 ERA Evaluation, Implemented as Soon as Practicable and No Later Than January 1 Following Commencement of Level 1 Status	Additional Operational, Structural, Treatment, or Demonstration Measures Where Appropriate
Technical Reporting	Annual Permit Reporting	Level 1 ERA Report	Level 2 ERA Technical Report
Reporting Deadlines	Standard Permit Deadlines	July 1 status Assignment; October 1 Level 1 ERA Evaluation; January 1 Level 1 ERA Report	January 1 Following the Reporting Year of the Level 2 Exceedance: Action Plan; January 1 of the Reporting Year Following Action Plan Submission: Technical Report; Action Plan Implementation Completed No Later Than One Year After Submission.

 

The permit provides a one-time Level 2 ERA implementation extension of up to six months when the required extension materials are submitted through SMARTS; longer extensions require written Water Board approval.4

Typical Pollutant Source Investigation Workflow4

A typical ERA evaluation may follow this technical sequence:

Elevated laboratory result

↓

Identify the affected parameter

↓

Review the associated discharge location

↓

Review historical monitoring trends

↓

Trace industrial activities within the drainage area

↓

Evaluate potential pollutant sources

↓

Review BMP effectiveness

↓

Determine appropriate corrective measures

↓

Document technical findings

↓

Update the SWPPP where required

This investigation helps distinguish recurring operational issues from isolated events while providing the technical basis for any changes documented through the ERA process.

In addition to assigning annual Level status, SMARTS records ERA submissions, tracks report status, and supports electronic filing of required documentation. Those system functions do not replace the facility’s responsibility to review monitoring results, identify applicable exceedances, maintain schedules, or submit required documents by the permit deadlines.

Outside the mandatory Level 1 and Level 2 ERA process, a QISP may also support Annual Comprehensive Facility Compliance Evaluations, Annual Report preparation, SWPPP implementation activities, and Pollution Prevention Team training where those services are requested or required by applicable permit provisions.

Industrial facilities entering the ERA process often need to coordinate technical investigations, documentation, laboratory results, and reporting milestones within relatively short permit deadlines.

 

Industrial SWPPP Maintenance and BMP Strategy

A facility’s Stormwater Pollution Prevention Plan (SWPPP) must remain current throughout Industrial General Permit coverage. When changes in site conditions, industrial activities, drainage patterns, or stormwater controls affect information required by the permit, the SWPPP and supporting records must be updated to accurately reflect current facility conditions and pollutant-source management.

Operational BMP Documentation Within the SWPPP

SWPPP Component	Operational Documentation Expectations
Good housekeeping	Document routine cleaning practices, exposed-material management, waste-handling procedures, and controls used to minimize pollutant exposure. Records connect assigned tasks with the operational areas where housekeeping BMPs are implemented.
Preventive maintenance	Identify inspection practices, maintenance intervals, completed repairs, and methods used to evaluate BMP functionality. Frequencies should reflect the type of equipment or control, operating conditions, and observed maintenance needs rather than an unsupported universal schedule.
Spill response procedures	Document response responsibilities, containment practices, cleanup procedures, and the records created after a spill. The SWPPP should show how personnel respond to releases that could affect stormwater without extending into separate hazardous-waste requirements.
Material handling and storage	Describe loading and unloading practices, outdoor storage controls, transfer procedures, exposed materials, and assigned responsibilities. This documentation links daily material movement with controls intended to reduce contact between pollutant sources and stormwater.
Source control BMPs	Record the operational controls used at identified pollutant-generating activities, including where they are used, who maintains them, and how their condition is evaluated. Documentation helps connect each control to the source or activity it is intended to address.
Structural BMPs, where applicable	Identify installed physical controls, their locations, operating purpose, inspection needs, observed condition, and completed maintenance. Records should allow facility teams to determine whether the control remains functional under current drainage and operating conditions.
Employee responsibilities	Assign stormwater-related duties to appropriate personnel, including members of the Pollution Prevention Team where applicable. The SWPPP should reflect who performs inspections, maintains controls, responds to spills, manages records, and coordinates operational follow-up.
Inspection and maintenance records	Maintain inspection findings, observed deficiencies, maintenance activities, corrective work, and completion information. These records provide an operational history of BMP performance and support preparation for monitoring, reporting, and facility evaluations.

Good housekeeping documentation should describe the controls actually used across the facility rather than relying on broad statements. Routine cleaning, waste handling, exposed-material management, and work-area organization should be tied to responsible personnel and specific operational areas. This makes the SWPPP useful during daily implementation and later record reviews.

Preventive maintenance records serve a similar function. Inspection frequencies, maintenance intervals, completed repairs, and follow-up observations should reflect facility conditions, BMP type, and applicable permit requirements rather than applying a single schedule to every control.

Spill response procedures should identify who takes action, how a release is contained and cleaned, and how the event is documented. Material-handling sections should address actual loading, unloading, transfer, and outdoor-storage practices so the facility can connect potential pollutant sources with the controls used in those areas.

Source control BMPs reduce opportunities for pollutants to contact stormwater by managing industrial materials, housekeeping practices, spill prevention measures, and other operational activities at their source. Their effectiveness depends on facility-specific conditions, identified pollutant sources, the BMPs selected, and how consistently those controls are implemented and maintained. The Industrial General Permit therefore requires Dischargers to select, implement, maintain, and evaluate BMPs based on facility conditions and applicable permit requirements; it does not establish a single universal pollutant-reduction percentage for source control BMP performance.

Keeping the SWPPP Current

SWPPP maintenance is an ongoing facility responsibility, not a one-time filing task. Updates may be needed when new industrial activities begin, operations change in ways that affect pollutant exposure, drainage conditions are revised, BMPs are added or modified, inspections identify deficiencies, or corrective actions alter facility procedures.

Not every minor operational adjustment necessarily requires a formal SWPPP revision. Facilities should evaluate changes against applicable Industrial General Permit requirements. The key question is whether the change affects pollutant sources, drainage, monitoring locations, assigned responsibilities, or the controls used to implement the permit. When it does, the facility should evaluate whether the SWPPP and related records still accurately describe current conditions.

During routine permit implementation, maintaining the SWPPP remains the facility’s responsibility. When Level 1 or Level 2 ERA requirements apply, QISP participation is required for the applicable ERA evaluation, reports, Level 2 ERA Action Plan, and Level 2 ERA Technical Report. Any SWPPP revisions required as part of the ERA process should be completed in accordance with the applicable permit requirements.

Industrial facilities in Los Angeles, Orange County, and nearby communities that need additional support maintaining SWPPP documentation or evaluating BMP implementation can work with SoCal Stormwater Solutions, which provides site-specific technical guidance, assists with documentation updates, and supports ongoing Industrial General Permit implementation based on facility conditions and applicable requirements.

 

Data Reporting Timelines Inside the SMARTS Database

SMARTS is the California State Water Resources Control Board’s electronic reporting platform for Industrial General Permit administration. Throughout the reporting year, facility teams use it to submit analytical data, maintain administrative information, and complete required reports. Facilities generally benefit from entering required information as it becomes available rather than waiting until annual reporting deadlines.

Annual SMARTS Reporting Cycle

The table below summarizes the primary SMARTS reporting activities, their timing, and how each fits into the facility’s annual reporting workflow.

Reporting Activity	Timing	Operational Purpose
Laboratory analytical results	Within 30 days of obtaining all results for each sampling event	Records required sampling and analytical information through the applicable SMARTS reporting workflow.
Annual Report preparation	Throughout the reporting year, with final compilation after June 30	Organizes monitoring information, inspection records, laboratory data, certifications, and explanations required for annual reporting.
Reporting-year conclusion	June 30	Closes the July 1–June 30 reporting period used to organize the facility’s annual monitoring and reporting information.
Annual Report electronic submission	No later than July 15 following the reporting year	Certifies and submits the completed Annual Report through SMARTS using the required electronic format.
Contact information updates	When facility, LRP, DAR, or other administrative information changes	Keeps responsible-party and facility information current for permit communication, certification, and reporting workflows.

Enter Laboratory Results as They Become Available

After each sampling event, the facility reviews the laboratory report, confirms that the results correspond to the correct sampling locations and event, and organizes the supporting field records. The Industrial General Permit requires sampling and analytical results for individual or qualified combined samples to be submitted through SMARTS within 30 days of obtaining all results for the sampling event. In practice, this reporting period begins once the required final laboratory results are available. 

Analytical data are generally entered through the applicable SMARTS reporting workflow for analytical results rather than held until Annual Report preparation. Laboratory reports and associated documentation should be matched with the relevant field observations, sampling records, and chain-of-custody information so the electronic submission can be traced to the original monitoring event.

Close the July 1–June 30 Reporting Year

The Industrial General Permit reporting year runs from July 1 through June 30. June 30 is therefore the close of the annual monitoring period, not a separate deadline created only for administrative convenience. Information collected across that period forms the basis of the facility’s Annual Report and other permit-required evaluations. 

Waiting until the reporting year closes to organize records can create avoidable reconciliation work. Laboratory reports, inspection records, field observations, chain-of-custody forms, and other monitoring documentation should be reviewed and filed throughout the year so missing or inconsistent information can be addressed while the event remains recent.

Prepare and Submit the Annual Report

Following the June 30 reporting-year close, the facility completes its Annual Report using the standardized SMARTS format. The Annual Report incorporates the monitoring information, the Annual Comprehensive Facility Compliance Evaluation, required certifications, and other reporting elements specified by the Industrial General Permit. Preparation also brings together analytical results, inspection and observation records, and supporting documentation maintained throughout the reporting year.

The discharger must certify and submit the Annual Report electronically through SMARTS no later than July 15 following each reporting year. Preparation by facility personnel or technical support providers does not transfer certification responsibility from the appropriate Legally Responsible Person or Duly Authorized Representative. 

Where Level 1 or Level 2 ERA reporting requirements apply, the associated QISP-prepared documents are submitted through SMARTS according to the separate permit requirements governing those reports. Those ERA milestones do not replace the ordinary analytical-result and Annual Report workflows described here.

Keep Administrative Information Current

Facility contacts, Legally Responsible Person information, Duly Authorized Representative assignments, and other administrative details should be updated in SMARTS when changes occur. Maintaining current administrative information helps ensure that permit records, electronic certifications, system notifications, and reporting activities remain associated with the appropriate facility representatives. SMARTS guidance provides dedicated change-of-information workflows for updating permit records.

SoCal Stormwater Solutions supports industrial facilities throughout Los Angeles and surrounding Southern California communities with required documentation and reporting, laboratory coordination, SMARTS reporting support, and record organization while providing site-specific guidance based on facility conditions and applicable requirements.

 

Sources:

1. California State Water Resources Control Board – Attachment E
2. California State Water Resources Control Board – Attachment F
3. California State Water Resources Control Board – Level 2 ERA Technical Report Help Guide
4. California State Water Resources Control Board – Industrial General Permit Order
5. California State Water Resources Control Board – Attachment A
6. California State Water Resources Control Board – Attachment A NOI Instructions
7. California State Water Resources Control Board – Instructions for No Exposure Certification (NEC)
8. California State Water Resources Control Board – SMARTS NEC Final Guide
9. California State Water Resources Control Board – Level 1 ERA