Numeric Action Level 1 or 2 Status

Is your facility in ERA Level 1 Status or ERA Level 2 Status?

The Industrial General Permit (IGP) sets Numeric Action Levels (NALs) that serve as limits for pollutant parameters. The purpose of this report is to ensure overall pollutant control performance, and additionally, for all industrial facilities to assess pollutants and determine the feasibility of numeric effluent limitations .

Read the full permit here:

Every facility must perform sampling, analysis and reporting in accordance with the requirements of the General Permit and shall compare the results to the two types of NAL values. There are two types of potential NAL exceedances.

1. Annual NAL exceedance: The Discharger shall determine the average concentration for each parameter using the results of all the sampling and analytical results for the entire facility for the reporting year. The discharger shall compare the average concentration for each parameter to the corresponding annual NAL values. For Dischargers using composite sampling or flow-weighted measurements in accordance with standard practices, the average concentrations shall be calculated in accordance with the US EPA’s NPDES Stormwater Sampling guidance document. An Annual NAL exceedance occurs when the average of all analytical results for a parameter from samples taken within a reporting year exceedance the annual NAL value for that parameter listed.
2. Instantaneous maximum NAL exceedance: The Discharger shall compare all sampling and analytical results from each distinct sample (individual or combined as authorized to the corresponding instantaneous exceedance occurs when two or more analytical results form samples taken for any single parameter within a reporting year exceed the instantaneous maximum NAL value (for TSS and OG) or are outside of the instantaneous maximum NAL range for pH. 

How we can help your facility avoid Level 1 Status and Level 2 Status:

Sidera Environmental can help your facility avoid ERA Level 1 Status and ERA Level 2 Status. Please contact us at 805-850-8150 for a free on-site evaluation and quote. We will determine the best Best Management Practices for your facility and recommend other industrial devices to help strategize status avoidance.

Are you already in ERA Level 1/2 Status?

Sidera Environmental can help take you out of ERA Level 1 Status as efficiently and quickly as possible. Our licensed QISPs on staff and lead engineers will work diligently to reduce your pollutants and ensure your facility returns to Baseline status, while remaining in compliance with the Industrial General Permit.

Click here for our direct contact for Level 1 consulting services.

Find more details on the requirement in the IGP Section XII.A.D.2, Pg. 51-54.