Step 8 – Level One Corrective Action
A Level One Corrective Action requires an “Operational” response. This means you should look at your operational BMPs such as vacuum sweeping paved surfaces and other Good Housekeeping measures. It must be conducted within 14 days of receiving results from the lab.
First, conduct an inspection of your facility to investigate the cause of the exceedance . Have you been following your SWPPP? Have you been conducting all mandatory BMPs? Go back through your facility with an eye for what sources correspond with the pollutant benchmark value.
Here’s some examples of why your runoff did not meet the benchmarks:
1. Your facility was recently landscaped and the contractors did not clean up all the loose soil from around the landscaping area allowing dirt and sediment to enter your catch basins. This could explain a value higher than 25 NTU for Turbidity.
2. Your scrap metal container wasn’t kept closed or undercover causing rainwater to accumulate and run out onto the yard. This could cause an exceedance of zinc or copper.
3. You neglected to sweep your paved areas once per quarter (more is better). This could cause an exceedance of both zinc and copper from tire dust and brake pads.
Next, review your SWPPP and make sure that it fully complies with the permit and contains all the correct BMPs from the permit and stormwater manuals. Make appropriate changes and updates to your SWPPP and include any additional Operational Source Control BMPs as needed such as making sure landscapers clean up and all dumpsters are closed.
When you file your annual report, you will summarize the Level 1 Corrective Actions.
Level One Deadline: You must sign/certify and fully implement the revised SWPPP according to the Permit as
soon as possible, but no later than the DMR due date for the quarter the benchmark was