SWPPP Certifications - What Is Certified and Who Needs to Sign?

Under State and EPA stormwater permitting rules, a Stormwater Pollution Prevention Plan (SWPPP) may need to be certified. This SWPPP Certification is in addition to other types of certifications that may be required. The types of certifications will vary depending on the State and type of permit; in addition to SWPPP Certification, some other types of certifications might include:

• Non-stormwater Discharge Certification,
• No-exposure Monitoring Exemption Certification;
• Heavy Metal No-exposure Certification (in Texas);
• Site Compliance Certifications;
• Endangered Species Certifications;
• Historic Places Certification
• Others.
  

SWPPP Certification – What is Being Certified?
In most cases, the SWPPP Certification statement indicates that the SWPPP has been 1) prepared; 2) implemented and that 3) the SWPPP conforms to the requirements of the discharge permit. The SWPPP Certification generally includes a statement that the information documented is correct. The exact wording and scope of the certification statement will vary from State-to-State, but here is an example:

"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."


Who needs to certify the SWPPP?
In some States (for example, Michigan, Indiana, Connecticut and others), the SWPPP needs to be signed by a certified or qualified environmental professional.

In most States, the SWPPP also needs to be signed by a Responsible Company Officer, or his/her duly authorized representative. State or EPA rules will determine who can sign the SWPPP. This SWPPP Certification can be in addition to any certifications needed by a qualified environmental professional.

Click here for more information on State-specific SWPPP Templates.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Mercury Controls - Requiring Air Emission Controls to Reduce Mercury in Water

The New England Interstate Water Pollution Control Commission has petitioned that EPA regarding Section 319(g) of the Clean Water Act, which requires controls on air emissions of mercury. EPA is being asked to bring together a management conference with eleven States that contribute much of the mercury emissions that end up in water bodies in the Northeast.
The EPA approved a Northeastern regional mercury TMDL last year that the States beleive can only can be achieved through stricter federal air emission controls on mercury. Under Section 319(g) of the Clean Water Act, States can petition the EPA to bring together "a management conference of all states which contribute significant pollution resulting from nonpoint sources,".

The petition prepared by the New England Interstate Water Pollution Control Commission says that Pennsylvania, Virginia, New Jersey, Ohio, West Virginia, Maryland, Michigan, Indiana, Kentucky, North Carolina and Illinois each contribute significant nonpoint source mercury pollution that prevent them from meeting their to reduce mercury in water and fish.

Most stormwater discharge permits include requirements for impaired waters - both with and without approved TMDLs. However, in the future air permits may also include similar provisions under the petition.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SWPPP Training Videos and Stormwater On-line Training - Do These Resources Meet Requirements?

Many good training resources are available, including video training and “on-line” courses. Caltha often recommends these resources as an element of a facility’s training program.

Whether or not these types of “off-the-shelf” training resources meet the training requirements will depend on the specific requirements for your State. In many cases, training needs to include information on the facility SWPPP, and therefore the “off-the shelf” resources need to be augmented with facility-specific training.

For example, here is an excerpt from a State permit that specifies training requirements:

Texas (TCEQ) General Permit:
Employee Training Program and Employee Education: A section within the SWP3 shall be
developed to establish a training program. Training shall be provided to all employees who are
responsible for implementing or maintaining activities identified in the SWP3. Employee training
shall include, at a minimum:
(1) proper material management and handling practices for specific chemicals, fluids, and other materials used or commonly encountered at the facility;
(2) spill prevention methods;
(3) the location of materials and equipment necessary for spill clean up;
(4) spill clean up techniques;
(5) proper spill reporting procedures; and
(6) familiarization with good housekeeping measures, BMPs, and goals of the SWP3.

...Education must be provided to those employees at the facility who are not directly responsible for implementing or maintaining activities identified in the SWP3, and who do not participate in the employee training program. At a minimum, these employees must be informed of the basic goals of the SWP3 and how to contact the facility’s storm water Pollution Prevention Team regarding storm water issues.

This this case, generic training materials would need to be supplemented with site-specific information on the facility's stormwater pollution prevention plan and site specific controls and procedures. Even the basic "awareness" training required for all employees needs to be site-specific.

Click here for more information on State-specific SWPPP - Stormwater Training Resources.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Using Infiltration as Stormwater BMP - Regulatory Issues

Infiltration is used as a stormwater control or Best Management Practice (BMP) in many areas. However, infiltrating run-off has some unique regulatory issues. First, in some States, infiltrating stormwater is a viable means to eliminate a discharge that would otherwise require an NPDES discharge permit. However, in most cases, the system would need to infiltrate all run-off from even the largest rain events. In addition, seasonal changes must also be considered; all run-off would need be collected and infiltrated even during frozen conditions. Some States, such as Minnesota, regulate groundwater as a "water of the State", and therefore can regulate discharges to the groundwater using infiltration.

The Minnesota Pollution Control Agency (MPCA) has been drafting regulations relating to infiltration of stormwater at sites regulated under the industrial stormwater discharge general permit. These requirements are still in revision, however as of November 2008 the format for regulation of infiltration as a stormwater control has included:

• Design criteria for amount of run-off to be infiltrated
• Rate at which infiltration must occur after a storm event
• Pretreatment requirements for run-off prior to discharge to designed infiltration basin
• Stormwater monitoring requirements and standards ("benchmarks") for run-off prior to discharge to designed infiltration basin
• Operation and maintenance requirements.

The draft MPCA infiltration requirements also include several prohibitions, where infiltration can not be used to manage stormwater. These include:

• Certain industrial sectors are prohibited from using infiltration BMPs;
• Certain sensitive areas where groundwater is vulnerable to contamination, including karst areas, and well head protection areas.

Finally, under some circumstances the disposal of stormwater run-off using a designed infiltration system can be further regulated as a Class V Injection Well. This will require further permitting and associated regulation.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

MPCA Stormwater Monitoring Requirements - Proposed Requirements

The Minnesota Pollution Control Agency has released its revised general permit for stormwater discharges from industrial sites. The current general permit was written in 1997, and the upcoming revision will reflect major changes in stormwater permitting requirements.

Review a summary of the MPCA industrial permit

The most important proposed change in the draft permit compared to the current MPCA general permit is the requirement to sample stormwater discharges.

Flowchart of Draft MPCA Stormwater Monitoring Requirements


All permittees will collect and analyze at least four quarterly samples during Year 2 of permit coverage. These samples will be compared to “benchmark” concentrations. Depending on the results, further quarterly samples may need to be collected in Year 4 and 5, and corrective actions may be required. Additional reporting, including a “Benchmark Exceedence Report” and evaluations will be required for dischargers who continue to exceed benchmark concentrations. All sample results will be reported to MPCA.

Related Links:

Further information on stormwater benchmarks

Further information on selecting stormwater monitoring techniques

Comparison of stormwater benchmarks to typical discharge data

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

MPCA Industrial Stormwater - Key Elements of Draft Permit

UPDATE: On July 6, 2009, MPCA is scheduled to release its proposed Multisector Industrial General Stormwater Permit. In July, Caltha LLP will be hosting seminars in several cities across Minnesota to provide information on the proposed permit and rule changes, and steps facilities can take to reduce their impact.

For more information, go to:

MPCA SWPPP Permit - Industrial Stormwater Permit Reissue Seminars

++++++++++++++++++++++++++

The Minnesota Pollution Control Agency has been drafting its revised general permit for stormwater discharges from industrial sites. The current general permit was written in 1997, and the upcoming revision will reflect major changes in stormwater permitting requirements.

A partial draft permit was released on November 20, 2008. This draft did not contain some important sections of the permit – most significantly, it did not include any SECTOR SPECIFIC requirements which will be incorporated into the final permit. All sections of the draft are subject to further revision; this article provides a briefing on some of the key elements of the draft permit.

Some key requirements in the draft permit are:

Requirements for Designated “Special” Waters. MPCA intends to have additional requirements for stormwater discharges to a number of different types of special waters, such as trout streams, wetlands and others. The nature of these additional requirements has not been released.

Facility Inspections. Facility inspections will need to be conducted on a monthly basis. All employee(s) performing inspections must be trained.

Maintenance of BMPs. If BMPs/structural controls are found to be not functioning properly, repairs should be made within seven days. Anyone performing installation, inspection, maintenance and repair of BMPs must have appropriate training.

Mercury Minimization Plan. Each permittee must evaluate their facility to determine if any sources of mercury are potentially exposed to stormwater. If mercury sources or devices are found, a Mercury Minimization Plan must be developed.

Stormwater Monitoring. The most important change compared to the current MPCA general permit is the requirement to sample stormwater discharges. All permittees will collect and analyze at least four quarterly samples during Year 2 of permit coverage. Depending on the results, further samples may need to be collected in Year 4 and 5, and corrective actions may be required. Additional reporting and evaluations will be required for dischargers who continue to exceed benchmark concentrations.

Related Links:
Flowchart of Draft MPCA Stormwater Monitoring Requirements
Further information on stormwater benchmarks
Comparison of stormwater benchmarks to typical discharge data
Further information on selecting stormwater monitoring techniques

Special Requirements for Stormwater Infiltration. MPCA intends to include specific requirements for the design and operation of infiltration BMPs. For some industry sectors, infiltration will be prohibited.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Benchmarks - Comparison To Typical Stormwater Concentrations

About one-third of US States include chemical monitoring in their general stormwater discharges permits. Over time, this percentage has been increasing as States renew these permits as they expire. For States that require chemical analysis of stormwater samples, “benchmark” concentrations or values are often included. Benchmark concentrations can be specified for a number of different chemical parameters, but the more common chemicals which are assigned benchmarks include total suspended solids (TSS), biochemical oxygen demand (BOD), chemical oxygen demand (COD), nutrients and heavy metals.

Benchmark values differ from permit limits. In a typical wastewater NPDES permit, limits may be specified for chemical parameters; if any of the limits are exceeded, it becomes a violation of the permit and may be subject to enforcement action.

Benchmark values are intended to provide a measurement of the effectiveness of the stormwater pollution prevention plan (SWPPP). Exceeding a benchmark does not directly result in a permit violation. However, permits typically require facilities to reevaluate their SWPPP and to take prompt corrective action after a benchmark value is exceeded. Failure to take prompt corrective action if a benchmark value is exceeded can be a permit violation and subject to enforcement action.

Benchmark values tend to be fairly stringent. For example, a common benchmark concentration for total suspended solids (TSS) is 100 mg/L. To put this concentration into perspective, it is roughly equivalent to 1 teaspoon of sediment added to 14.5 gallons of water.

As a sector example, US EPA tested the stormwater discharge at 185 transportation and warehousing facilities. The average TSS was reported as 466 mg/L and half the facilities sampled exceeded 159 mg/L (Federal Register Vol. 60, No. 189).

The message in these data is simple; meeting stormwater benchmark values or other stormwater discharge limits can be a challenge to many facilities. It requires a thoughtful evaluation of potential pollution sources and an effective plan to minimize discharges.

[read more about selecting appropriate stormwater monitoring techniques]

Caltha LLP maintains a library of Stormwater Monitoring Plan templates to meet individual State requirements, and provides ad hoc technical guidance in developing and implementing stormwater monitoring programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Benchmarks Compared to Permit Limits

Benchmark values differ from permit limits, sometimes referred to as "effluent limits". In a typical wastewater NPDES permit, limits may be specified for chemical parameters; if any of the limits are exceeded, it becomes a violation of the permit and may be subject to enforcement action. Certain typical of stormwater discharges have federally enforceable Effluent Limits, with are Incorporated into stormwater general permits (such as a MSGP) or into individual NPDES permits.

Benchmark values are intended to provide a measurement of the effectiveness of the stormwater pollution prevention plan (SWPPP). Exceeding a benchmark does not directly result in a permit violation. However, permits typically require facilities to reevaluate their SWPPP and to take prompt corrective action after a benchmark value is exceeded. Failure to take prompt corrective action if a benchmark value is exceeded can be a permit violation and subject to enforcement action. Multiple exceedances of a benchmark could result in a State requiring that the facility apply for an individual stormwater discharge permit. In this case, legally enforceable stormwater discharge limits may be written into the permit.

[read more about selecting appropriate stormwater monitoring techniques]

Caltha LLP maintains a library of Stormwater Monitoring Plan templates to meet individual State requirements, and can provide ad hoc technical guidance in development of stormwater monitoring programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Local Stormwater Requirements - Additional Stormwater Compliance Requirements

One of the challenges many facilities face is complying with local stormwater requirements. These requirements are beyond those requirements specified in an NPDES permit. In fact, many local requirements apply to all properties, regardless of SIC code or whether or not a facility is required to obtain a discharge permit.

One of the most challenging aspects of complying with local requirements is the fact that different jurisdictions can have widely different requirements. Cities, Counties or other jurisdictions can range from very generic requirements, or very detailed requirements. For example, the City of Tampa Bay, Florida has general requirements:

Sec. 21-9. Protection of public drainage systems. •It is unlawful to introduce any foreign matter (including, but not limited to, trash, leaves, grass clippings, debris, garbage, fill, construction materials, organic or inorganic pollutants, acids, and petroleum products), whether by action or inaction, to any public drainage system including but not limited to streets.

In contrast, the City of Fremont, CA, for example, has very prescriptive requirements. Here is a small sample of the City's requirements:

I.K. Vehicle/Equipment Repair and Maintenance –1) Vehicle/equipment repair and maintenance shall be performed in a designated area indoors, or if such services must be performed outdoors, in an area designed to prevent the run-on and runoff of stormwater. 2) Secondary containment shall be provided for exterior work areas where motor oil, brake fluid, gasoline, diesel fuel, radiator fluid, acid-containing batteries or other hazardous materials or hazardous wastes are used or stored. Drains shall not be installed within the secondary containment areas.

Whether the local requirements are general or specific, in most cases, NPDES permits require compliance with local requirements in addition to permit conditions. In preparing SWPPPs, local requirements need to be considered in addition to the permit requirements.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SPCC Requirements for Electric Transformers & Other Electrical Equipment

Oil-filled equipment is regulated under SPCC requirements - 40 CFR 112. This includes some very common types of equipment:

• hydraulic systems,
• lubricating systems,
• gear boxes, e
• lectrical transformers & other electrical equipment,
• coolant and heat transfer systems.

Some electrical equipment, such as transformers, on a property may not be under the control of the facility. This equipment could be installed, owned and operated by the local power provider or municipality. The SPCC Rule still applies to this equipment, however the specific requirements may be different depending on who owns and operates the equipment.

Caltha LLP provides expert technical support to facilities and/or consulting engineers on compliance with SPCC Rules. Caltha maintains a library of SPCC Plan templates to match site-specific needs. For futher information on SPCC services, go to:
SPCC - 40 CFR 112 Compliance Services

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Oil-filled Equipment Requirements Under SPCC Rule - 40 CFR 112

Oil-filled equipment is regulated under SPCC requirements. This includes some very common types of equipment: hydraulic systems, lubricating systems, gear boxes, electrical transformers & other electrical equipment, coolant and heat transfer systems.

One of the challenges of complying with SPCC requirements is providing adequate secondary containment around this type of equipment. Recent revisions to the SPCC rule now may allow facilities to rely on an inspection program and contingency planning in lieu of secondary containment. To quality for this exemption, facilities need to meet a number of specific conditions.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Polycyclic Aromatic Hydrocarbons in Stormwater - Austin Sealcoating Studies

Collaborative studies (Fact Sheet) by the City of Austin, TX, and the U. S. Geological Survey have identified coal-tar based sealcoat as a major and previously unrecognized source of polycyclic aromatic hydrocarbon (PAH) contamination. Several PAHs are suspected human carcinogens and are toxic to aquatic life. Studies in Austin, Texas, showed that particles in runoff from coal-tar based sealcoated parking lots have concentrations of PAHs that are about 65 times higher than concentrations in particles washed off parking lots that have not been sealcoated. Biological studies, conducted by the City of Austin in the field and in the laboratory, indicate that PAH levels in sediment contaminated with abraded sealcoat are toxic to aquatic life and are degrading aquatic communities, as indicated by loss of species and decreased numbers of organisms.

This research has led the City of Austin to ban the use of coal-tar sealants for roads, parking lots, driveways, and other paved areas.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Self-Certification of SPCC Plans - Requirements for Certification

The SPCC Rule (40 CFR 112) now allows SPCC Plans to be self-certified (no PE certification required) by facilities, if they meet a few qualifications:

• On-site oil storage capacity must be less than 10,000 gallons;
• Over the past three years, no single spill greater than 1,000 gallons, and no more than two spills greater than 42 gallons have occurred;
• The SPCC meets all SPCC Rule (40 CFR 112) requirements, without the use of “environmentally equivalent” or “impracticality” determinations.

SPCC Plans will still need to be signed by a responsible person on behalf of the facility. By signing the SPCC Plan, that person certifies that he/she is:

• Familiar with SPCC requirements,
• Has visited and reviewed the facility,
• The Plan was prepared in accordance with accepted and sound industry practices,
• Procedures for inspections and testing have been established,
• The Plan is fully implemented, and
• The facility meets all the requirements to qualify for self certification.

Caltha LLP offers expert technical and regulatory support to develop facility Spill Prevention, Control & Countermeasure (SPCC) plans to be "self-certified". Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112 requirements.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Minnesota (MPCA) Stormwater Discharge Permit Enforcement Actions

The Minnesota Pollution Control Agency (MPCA) recently released a summary of enforcement actions closed in the third quarter of 2008. These data, combined with the previous two quarters, show that 20% of all enforcement actions taken by MPCA so far in 2008 involve violations of stormwater discharge regulations.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SPCC Secondary Containment Requirements for Mobile Refueling Equipment

The revised SPCC Rule (40 CFR 112) clarified a few points in regards to mobile tanks. First, the Rule clarified that tanks on vehicles used to hold fuels and operating fluids required to operate the vehicle are not intended to be included under the SPCC requirements. Typical mobile refueling equipment would have two types of fuel storage –a fuel tank for operation of the engine, and a storage tank used to move fuel around the facility. Under the revised Rule, the engine’s fuel tank (i.e., “motive fuel container”) would not be included under an SPCC Plan; however, the bulk fuel tank the vehicle carries would be included.

The bulk fuel tank on the refueling vehicle would normally require the same spill protections that other containers need. However, the revised SPCC Rule clarified that these refueling vehicles are exempted from some SPCC requirements. Specifically, the revision exempts mobile refueling vehicles from the requirements to have a sized secondary containment structure.
However, when this equipment (included towed equipment) is placed or stored in a designated area of the site, that area must have the required secondary containment.

Caltha LLP provides expert technical support to facilities and/or consulting engineers on compliance with SPCC Rules. Caltha maintains a library of SPCC Plan templates to match site-specific needs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Monitoring - Selecting Appropriate Technique and Equipment

Many States now require dischargers to collect stormwater samples to demonstrate that their stormwater pollution prevention measures are effective. Samples are either visually examined on-site, or sent to a laboratory for chemical analysis. Either way – samples need to be collected.

Because in most States samples need to be collected within the first 30 minutes of discharge, stormwater monitoring presents some special challenges. To further complicate this requirement, rain events may also need meet specific requirements (i.e., 0.25 inch total rain fall, dry for previous 3 days, etc.). There are three basic options available to dischargers:

1. Train Facility Staff to Collect Samples. In this case, a few staff are trained on how to collect and handle samples.
2. Contract Third-party Sampler. Here, you would need to contract with a vendor who is located close enough to be at the site and ready to sample within 30 minutes of the start of a rain fall event.
3. Buy or Lease Automated Sampling Equipment. In this case, equipment is installed at each outfall and samples are collected automatically when water begins to flow. In most cases, equipment would need to be installed by trained personnel.
   

Each of these options has its unique benefits and drawbacks. Using a third-party sampler has some logistically problems, as most facilities find it difficult to have someone on-site within 30 minutes, especially considering that the vendor may also be providing this service to others. Using automatic equipment eliminates this logistical problem; however, automated equipment tends to be more costly, and often needs to be reset after small rain events or if any other water gets inadvertently discharged to the storm sewer. Therefore many dischargers opt to train their own staff to collect samples, as it is the least expensive and most reliable method.

Selecting the appropriate option for a given discharger requires consideration of all the outfalls that need to be sampled. For example, some outfalls may not be conducive for installing automated sampling equipment, and might require a different technique. Therefore, if a facility has four outfalls to sample and one can not be effectively sampled with automated equipment, staff may need to be trained to collect samples at that outfall anyway, and therefore it may not make much sense to install automated equipment at the other outfalls, unless other factors prevail.

The bottom line is that selecting a reliable and cost effective sampling method is dependant on a number of factors, including:

• Frequency of monitoring
• Types of parameters to be tested for
• Physical layout and constraints of the outfalls
• Safety considerations
• Availability of on-site staff
• Availability of contract sampling vendors
• Availability of equipment

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Revised SPCC Rules - Connection with Stormwater Permit Compliance

Stormwater discharge permits commonly reference other regulatory requirements. Possibly the most common regulatory reference is that permitted facilities must be in compliance with SPCC Rules (40 CFR 112). Since 2002, the SPCC Rules have been evolving; the result of these changes has been that many more facilities are now subject to SPCC requirements. However, a significant number of facilities are not aware of changes to the SPCC Rule and that they are now subject to this regulation.

The most significant change has been the threshold on oil storage capacity that makes a facility subject to SPCC Rules. Although the threshold for total facility oil storage capacity increased to 1320 gallons, the size of containers which must be included in the calculation decreased to 55 gallons. Now, a facility must add the oil storage capacity for all containers 55 gallons or greater; if the total exceeds 1,320 gallons, the facility is subject to SPCC Rules. Facilities that include a significant drum storage of oil can easily exceed this threshold.

Many of the revisions to the SPCC requirements streamlined compliance requirements and ultimately reduce the complexity and costs associated with compliance. US EPA believed that reducing the overall complexity of the program will improve compliance, especially with small to mid-sized facilities that are affected.

Specifically, the types of facilities that benefited were:

• Facilities with total oil storage capacity between 1,320 and 10,000 gallons
• Facilities with certain types of regulated oil-filled equipment
• Facilities with mobile refueling vehicles
  

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SWPPP Template - What Makes a Good Stormwater Pollution Prevention Plan Template?

Caltha LLP uses SWPPP Templates to prepare stormwater pollution prevention plans each day. Templates can be used to prepare stormwater pollution programs for industrial sites, municipal dischargers (MS4) and for construction sites. In additon, SWPPP Templates can be augmented by Stormwater Monitoring Plan Templates, Sediment and Erosion Control Templates, Compliance Plan Templates, if needed.

Good SWPPP templates guide the user through a thoughtful self assessment, and not a “rush” to select BMPs. It has been our experience that using SWPPP templates is an excellent method to cost-effectively develop a site-specific pollution prevention program. However, the SWPPP templates needs to be more than a “fill-in-the-blank” exercise. By simplifying the process of preparing the plan, users often minimize the assessment process and move quickly to selecting BMPs.

Effective SWPPPs need to start with a thorough assessment of potential pollutant sources, which then can be carried forward through evaluation of potential controls, selection of BMPs, and all the way through on-going inspections and program improvements. An effective SWPPP template guides the user thorough the assessment process and creates a transparent and logical path to how potential pollutant sources will be controlled.

Based on our experience, some key features of an effective SWPPP template are:

• SWPPP template should guide the user through a thoughtful assessment process, which then serves as the basis for selecting SWPPP program elements and long-term implementation and permit compliance;
• The format of the SWPPP template should not detract from the final SWPPP product; the final SWPPP needs to be a well written plan that is easily read and understood. Unnecessary “remnants” of the template should not be included in the final SWPPP;
• The SWPPP template should incorporate requirements of the stormwater discharge permit. Because each State and Federal permit has unique requirements, a different SWPPP template needs to be used for each State.

Read more about SWPPP - Stormwater Compliance Document Virtual Library.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Revised Arizona ADEQ Stormwater Permit Requirements for Dischargers Near Impaired Waters or Unique Waters

On February 29, 2008, the revised Arizona Department of Environmental Quality (ADEQ) general permit for the discharge of stormwater from construction sites became effective. This permit replaced an earlier general permit which had expired. The revised general permit now applies to all construction sites greater than one acre in size, with the exception of sites located on Indian lands within the State. For these sites, a different permit, issued by U.S. EPA, applies.

The requirements under the ADEQ permit will change substantially depending on the location of the project. The key criteria will be whether the site is within ¼-mile of:

• An impaired water
• A listed unique water (also known as an “Outstanding Arizona Water”, or OAW)

For project sites located within this radius, significantly more stringent permit compliance requirements may apply which include:

• Submittal of SWPPP with NOI, and extended waiting period for permit coverage
• Additional prohibitions on non-stormwater discharges
• Additional prohibitions on post-construction discharges
• Additional inspection requirements
• Stormwater monitoring

For project sites located with ¼-mile of either an impaired water or a listed unique water, a Stormwater Monitoring Plan must be developed and implemented. Monitoring of stormwater includes visual monitoring each week and collection and analysis of samples when stormwater is discharged. Monitoring results are then reported to ADEQ on Discharge Monitoring Report (DMR) forms.

For more information on this permit, go to:

Summary of Revised ADEQ Permit

What Kind of Stormwater Training Is Required?

The answer will depend on the State your facility is located in – different States will have different training requirements. However, Caltha generally sees three categories for training:

a) SWPPP Awareness Training. This is “high-level” training which may be given to all employees, and covers basics of stormwater program and facility controls that would apply to any employee.
b) Stormwater Training. This training would be addressing employees whose day-to-day work activities relate to the specific controls and procedures the facility has established in its SWPPP, such as dock workers who might be involved with spills.
c) Stormwater Permit Compliance Training. Employees who have been assigned specific compliance tasks, such as conducting inspections, collecting stormwater samples, need to be trained to conduct their tasks.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Permit and SWPPP Requirements - Summary Trends and Changes

Here is a link to a presentation given at the ACHMM Annual Conference in August 2007:

Trends and Changes in Stormwater Permitting and SWPPP Requirements Across US

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website