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Foothill Landfill <br />Storm Water Pollution Prevention Plan <br /> <br /> <br /> <br />Page 59 <br />12.0 Exceedance Response Actions (ERAs) <br />San Joaquin County uses sampling data to evaluate whether one or both types of numeric action <br />level (NAL) exceedances have occurred. <br />x An annual NAL exceedance occurs when the average of all sampling results within a <br />reporting year for a single parameter (except pH) exceeds the applicable annual NAL. <br />x An instantaneous maximum NAL exceedance occurs when two (2) or more analytical <br />results from samples taken of pH (outside the 6.0 to 9.0 pH units), total suspended <br />solids or oil and grease exceed the instantaneous maximum NAL value within a <br />reporting year. <br />ERAs in response to NAL exceedances correspond with varying status levels, according to <br />degree of exceedance. Each parameter maintains a separate status depending on the levels of <br />that parameter determined by sampling results. For example, the total suspended solids <br />parameter can still have Baseline status while the oil & grease parameter is at Level 1 status. <br />The NAL exceedance values for various parameters can be found in Table 2 of the General <br />Permit. <br />12.1 Baseline Status <br />At the beginning of Notice of Intent (NOI) coverage during the 2015-2016 storm season, the <br />Foothill Landfill had a Baseline status for all parameters. The analysis of sampling data <br />determines whether the facility stays at Baseline status or moves to Level 1 status. In <br />subsequent years, the analysis of sampling data, among other requirements, will determine <br />whether the facility stays at Level 1 status, or moves onto Level 2 status. <br />12.2 Level 1 Status <br />On July 1, 2016, the Foothill Landfill entered ERA Level 1 status for iron and TSS because of <br />NAL exceedances at the only outfall that discharged that year, ST-3. <br />12.2.1 Level 1 ERA Evaluation <br />On October 1 of the year during which Level 1 status begins for any parameter with a NAL <br />exceedance, a facility must: <br />x Complete an evaluation, with the assistance of a facility designated QISP, of the <br />industrial pollutant sources at the facility that are or may be related to the NAL <br />exceedance(s); and <br />x Identify in the evaluation the corresponding BMPs in the SWPPP and any additional <br />BMPs and SWPPP revisions necessary to prevent future NAL exceedances and to <br />comply with the requirements of the General Permit. Although the evaluation may <br />focus on the drainage areas where the NAL exceedance(s) occurred, all drainage areas <br />must be evaluated. <br />A Level 1 ERA Report must be submitted by January 1 of the year following the Level 1 status <br />commencement.