EMC delivers regulatory compliance services across three practice areas: stormwater compliance under the California Industrial General Permit, Qualified Industrial Stormwater Practitioner (QISP) and Exceedance Response Action (ERA) services, and CERS Hazardous Materials Business Plan (HMBP) reporting. Use the links below to jump to a specific service area, or scroll to view all services.

Stormwater Compliance & Training
QISP & ERA Services
CERS — Hazardous Materials Business Plan (HMBP)

Stormwater Compliance & Training

EMC’s stormwater compliance services support California industrial facilities subject to the Industrial General Permit (Order WQ 2014-0057-DWQ, as amended by Orders WQ 2015-0122-DWQ and WQ 2018-0028-DWQ) across the full permit lifecycle.

Permit Coverage and Termination

• Notice of Intent (NOI) preparation and SMARTS submittal
• No Exposure Certification (NEC) evaluation, preparation, and annual recertification
• Notice of Termination (NOT) preparation
• Permit coverage transition support for facility ownership or operator changes

SWPPP and Site Documentation

• Storm Water Pollution Prevention Plan (SWPPP) drafting, amendments, and revisions
• Facility Site Map preparation and amendments
• Best Management Practice (BMP) selection and documentation
• Stormwater Management Records binder preparation and annual updates

Sampling and Monitoring Support

• Pre-assembled laboratory sampling collection kits with pre-printed chain-of-custody forms
• On-site or virtual sampling collection training for facility personnel
• Qualified Storm Event (QSE) identification and weather alert support
• Monthly Visual Observation tracking and record keeping
• Pre-storm inspection and Non-Stormwater Discharge (NSWD) observation support

Reporting and Data Management

• Sampling results data tracking, NAL/NEL comparison, and exceedance flagging
• Ad Hoc Report preparation for SMARTS submittal
• Annual Comprehensive Site Compliance Evaluation (ACSCE) services
• Annual Report preparation and SMARTS submittal ahead of the July 15 deadline
• Mitigation guidance for facilities approaching or exceeding Numeric Action Levels

Inspection and Violation Response

• Regional Water Board inspection preparation
• Notice of Violation (NOV) and Notice of Non-Compliance (NNC) response support
• Compliance gap analysis and remediation planning

Training

• On-site facility personnel training (individual or group format)
• SWPPP implementation training for newly assigned facility staff
• Annual training refreshers for designated Stormwater Pollution Prevention Team members

QISP & ERA Services

When a facility’s sampling results trigger Level 1 or Level 2 status under the IGP’s Exceedance Response Action framework, the permit requires the involvement of a Qualified Industrial Stormwater Practitioner (QISP). EMC provides QISP-led ERA services for facilities at every stage of the response process.

Level 1 Exceedance Response Action

• Level 1 ERA Evaluation, including pollutant source identification and BMP adequacy review
• Level 1 ERA Report preparation and SMARTS submittal
• Industry-specific BMP recommendations targeted at observed exceedance pollutants

Level 2 Exceedance Response Action

• Level 2 ERA Action Plan preparation and SMARTS submittal
• Level 2 ERA Technical Report preparation, including demonstrations under permit Section XII.D (Demonstration of Compliance, Industrial Activity BMP, and Non-Industrial Pollutant Source demonstrations as applicable)
• Ongoing technical oversight for facilities maintaining Level 2 status

Sampling Frequency Reduction (SFR Certification)

• Eligibility evaluation for Sampling Frequency Reduction Certification under permit Section XI.C.6

• SFR Certification preparation and SMARTS submittal

CERS — Hazardous Materials Business Plan (HMBP)

California facilities that handle hazardous materials at or above threshold quantities under California Health and Safety Code Chapter 6.95 must submit a Hazardous Materials Business Plan through the California Environmental Reporting System (CERS). EMC provides full HMBP preparation and submittal services, with deliverables tailored to facility operations and the requirements of the local Certified Unified Program Agency (CUPA).

HMBP Preparation and Submittal

• Hazardous Materials Inventory preparation, including identification of pure substances, mixtures, and waste streams
• Site Map preparation showing storage locations, secondary containment, emergency equipment, and evacuation routes
• Emergency Response Plan and Employee Training Plan documentation
• CERS account setup and electronic submittal support
• Annual HMBP recertification

Ongoing HMBP Support

• HMBP amendments for changes in hazardous material inventory, quantity, or storage configuration
• CUPA inspection preparation
• Coordination with facility safety, regulatory, and operations personnel during inventory changes

Additional Services

• Litigation Support. EMC provides regulatory consulting support for stormwater-related litigation involving California IGP-regulated facilities. This work is performed in coordination with the client’s retained attorney and may include document review, regulatory interpretation, sampling history analysis, and SMARTS records assembly. Litigation support is evaluated on a case-by-case basis and billed separately from standard compliance retainers.

• Spanish-Language Support. Bilingual delivery of facility training, document explanation, and field walkthroughs (Se Habla Español).