SWPPP | Stormwater Pollution Prevention Plans | Stormwater Permits | Stormwater Training

Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits,multisector general permits, impaired waters requirements, water quality standards, SWPPP, Stormwater Pollution Prevention Plans, stormwater monitoring, stormwater training, SWPPP training, spill prevention and control, SPCC compliance, site inspections, reporting and recordkeeping

Friday, February 27, 2009

Stormwater Management Improvement Projects Funded Through Federal Stimulus

The Iowa State Revolving Fund (SRF) is currently soliciting "green projects" to be funded the SRF in response to the recent Federal Stimulus Bill. The federal stimulus bill routes some of the funds for water quality through the State Revolving Fund programs. Iowa’s allocation is $53 million for Clean Water SRF and $24 million for Drinking Water SRF. About 20% of each amount is intended to be used for green infrastructure, water or energy efficiency improvements, or other environmentally innovative activities. While the Iowa SRF has projects that can be to funded with the remaining 80 percent, there are currently few fundable proposals for “green” projects.

Eligible stormwater management projects might include:

Water efficiency
o Reclamation, recycling, and reuse of rainwater, condensate, degraded water, stormwater, and/or wastewater streams

Stormwater quality management
o Stormwater infrastructure with a treatment component
o Stormwater retrofits that address hydrologic impacts to receiving waters by reducing discharge flow volume
o Street sweepers and vacuum trucks

Green infrastructure
o Implementation of green streets (green infrastructure practices in transportation right-of-ways)
o Porous paving, bioretention, green roofs
o Establishment or restoration of riparian buffers
o Retrofits to keep stormwater out of sewer system

All of the projects funded through the stimulus funds must have an environmental review and must comply with all federal regulations

Caltha LLP provides expert technical support to clients nationwide in addressing environmental review, stormwater management and stormwater pollution prevention requirements.

[Read further information on Stormwater Plan - SWPPP Services]

[Read further information on Stormwater Training - SWPPP Training]

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

Thursday, February 26, 2009

Preventive Maintenance of Industrial Equipment - Permit Requirements

Maintenance of equipment and controls is a requirement for most stormwater pollution prevention programs. Maintenance can be 1) routine maintenance to correct deficiencies identified during routine inspections, and 2) preventive maintenance to address problems before they occur. In many jurisdictions, a written Preventive Maintenance Plan is required.

In most cases, two types of equipment or systems must be maintained:

Industrial equipment and systems, and
Stormwater BMPs and Stormwater Controls

Relative to industrial equipment and systems, routine maintenance and preventive maintenance is required for equipment and systems that could result in stormwater impacts if not properly maintained. Using the recent US EPA Multisector Permit (MSGP-2008) as one example, dischargers "must regularly inspect, test, maintain, and repair all industrial equipment and systems to avoid situations that may result in leaks, spills, and other releases of pollutants in stormwater discharged to receiving waters."

In addition, the MSGP-2008 requires that equipment that is awaiting maintenance be handled separately. Dischargers are required to "confine the storage of leaky or leak-prone vehicles and equipment awaiting maintenance to protected areas."

[Read more about maintenance requirements for stormwater controls and BMPs]

Caltha LLP provides expert technical support to clients nationwide in addressing stormwater permitting and SWPPP requirements, including developing effective inspection and preventive maintanence programs, and providing employee training programs.

[Read further information on Stormwater - SWPPP Services]

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Maintenance of Stormwater Controls - BMPs - Regulatory Requirements

Once installed stormwater Best Management Practices (BMPs) or stormwater controls need to be maintained in order to remain effective. The most intuitive example is a stormwater detention basin or pond. If the pond is sized to remove 90% of suspended solids, it will only meet this target removal efficiency if it is maintained at its designed size. Over time, an effective pond will trap sediment; this sediment displaces the water volume in the pond and its removal efficiency begins to drop. Without maintenance (which in this example would be removing accumulated sediment), the pond will eventually approach 0% removal efficiency.

From a regulatory perspective, most State permits require that stormwater BMPs be maintained; in this context, BMPs could be any structural or non-structural control measure that the site uses.

Using the recent US EPA Multisector General Permit (MSGP-2008) as an example, dischargers must "maintain all control measures ... in effective operating condition. Nonstructural control measures must also be diligently maintained (e.g., spill response supplies available, personnel appropriately trained). If you find that your control measures need to be replaced or repaired, you must make the necessary repairs or modifications as expeditiously as practicable."

Maintenance of stormwater controls requires:

Scheduled routine inspections, conducted by qualified staff
Detailed evaluation under comprehensive site compliance evaluations
Detailed documentation
Rapid corrective action

Industrial sectors that are required to conduct routine benchmark monitoring will find maintenance to be especially important. In addition to conducting routine visual inspections of their controls, they will also be collecting and analyzing samples of their stormwater discharge in order to demonstrate that their controls remain effective.

[Read further information on Stormwater - SWPPP Services]

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Tuesday, February 24, 2009

Stormwater Infiltration - Regulatory and Permitting Aspects

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 regulate groundwater as a "water of the State", and therefore can regulate discharges to the groundwater using infiltration.

Here are two recent examples:

New Hampshire. New Hampshire has recently proposed requiring a "Alteration of Terrain" permit for many types of new projects. Infiltration of stormwater is prohibited if the run-off comes from "high load areas", which include many typical industrial activities.

[Read more about New Hampshire Alteration of Terrain permits]

Minnesota. 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.

Caltha LLP provides expert technical support to clients nationwide in addressing stormwater permitting and SWPPP requirements.

[Read further information on Stormwater Plan - SWPPP Services]

[Read further information on Stormwater Training - SWPPP Training]

For further information contact Caltha LLP at
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Caltha LLP Website

Monday, February 23, 2009

Stormwater Permit Compliance Plan - Companion to Facility SWPPP

SPCC Plan - Does My Spill Plan Expire?

From time-to-time, Caltha receives inquiries from facilities that believe their Spill Prevention, Control & Countermeasure (SPCC) Plan may have "expired".

The SPCC Plan, prepared in accordance with 40 CFR 112, is a "dynamic" document, and does not expire. At any point in time, the SPCC Plan needs to accurately reflect the current physical layout of the facility, the existing spill containment and control measures, and the current emergency response procedures.

Because facilities change overtime, the SPCC Plan needs to be reviewed and updated accordingly. At a minimum, the plan needs a formal review and revision (if necessary) every five years. However, certain elements of the Plan may change much more frequently - especially emergency contact information. The SPCC Plan should be revised before making changes to the facility that are relevant to compliance with the SPCC Rule.

Caltha LLP offers expert technical and regulatory support to develop facility Spill Prevention, Control & Countermeasure (SPCC) plans, including several low cost options for SPCC Plans using the new SPCC Template Plan format. Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112. Click here to request further information on SPCC and SWPPP Services.
For further information contact Caltha LLP atinfo@calthacompany.com
orCaltha LLP Website

Thursday, February 19, 2009

Visual - Benchmark Stormwater Monitoring Compared To Wet Weather Inspections

Overtime, the requirements for stormwater discharge monitoring have shifted. During the 1990s, when stormwater discharge permitting requirements began to develop, “wet weather inspections” were incorporated into many State general permits. These inspections were to be conducted during a rain event and required the discharger to make certain observations about the stormwater being discharged at each of the stormwater outfalls. In most cases, wet weather inspections could be conducted without actually collecting a sample of the stormwater discharge.

Subsequently, the US EPA Multisector General Permit (MSGP) became more detailed and the Visual Monitoring requirement was developed. Overtime, State permits also incorporated a requirement to conduct visual monitoring. However, in some cases permits were not clear as to whether or not a sample of stormwater needed to be collected. Because of this ambiguity, some dischargers believed that the same protocol they were using for wet weather inspections still applied.

Recently, the EPA MSGP was revised to eliminate any uncertainty regarding the protocol to be used for Visual Monitoring:
“The visual assessment must be made:
- Of a sample in a clean, clear glass, or plastic container, and examined in a well-lit area;
- On samples collected within the first 30 minutes of an actual discharge from a storm event.”

Benchmark monitoring is also required of some industrial sectors. Benchmark monitoring becomes an extension of Visual Monitoring. Rather than documenting the visual characteristics of the sample, it is simply sent to an analytical laboratory for chemical analysis.

Therefore, in practice the same basic protocol is required to collect stormwater samples for both visual monitoring and benchmark monitoring.

[Read more about benchmark monitoring]
[Read more about selected stormwater monitoring techniques and equipment]

Caltha LLP provides a range of stormwater monitoring services, from development of a written Stormwater Monitoring Plan, to conducting stormwater monitoring training, to supplying equipment and sampling personnel to collect samples.
[Read more about Stormwater Monitoring Services]

For further information contact Caltha LLP at
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or
Caltha LLP Website

Monday, February 16, 2009

Numeric Nutrient Water Quality Criteria Requirement for FL

The US Environmental Protection Agency (EPA) has recently announced that the agency is taking actions to develop the required Nutrient Water Quality Criteria within the State of Florida. These actions include EPA issuing a formal determination under the Clean Water Act that “numeric” nutrient water quality criteria are necessary in Florida, and Florida needs to accelerate its efforts to adopt numeric nutrient criteria into state regulations.

EPA believes that water quality degradation from nutrient pollution is a significant issue in Florida. Florida’s 2008 Integrated Water Quality Assessment estimated that at least 1,000 miles of rivers and streams, 350,000 acres of lakes, and 900 square miles of estuaries are impaired by nutrients. The new numeric nutrient water quality standards will help the Florida Department of Environmental Protection (FDEP) improve the efficiency and effectiveness of its water quality management tools, identify waters impaired because of nutrient pollution, establish total maximum daily loads and Basin Management Action Plans, and derive National Pollutant Discharge Elimination System permit limits.

EPA expects to propose numeric nutrient standards for lakes and flowing waters within 12 months, and for estuaries and coastal waters within 24 months.

Caltha LLP provides expert technical support to clients nationwide to address State water quality standards. Caltha provides specialized expertise in biomonitoring, aquatic toxicology and impacts to aquatic communities.

[Click here to request further information on water quality and aquatic community impact assessment]

For further information contact Caltha LLP at
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Sunday, February 15, 2009

Biomonitoring Requirements - Amendment to OK Rules

The Oklahoma Department of Environmental Quality (ODEQ) is proposing to modify its rules concerning biomonitoring (whole effluent toxicity, or WET) requirements for wastewater dischargers. Under the proposed rules, a sublethal test failure (failure to demonstrate growth or reproduction) will be handled the same as a lethal test failure (death to the test organisms). This change is required based on changes in US EPA requirements and has already been promulgated into Oklahoma’s Water Quality Standards.

The proposed rule modifications also refine when a facility may request a biomonitoring organism change from Daphnia pulex or Ceriodaphnia dubia to Daphnia magna. Finally, the proposed rule modifications would also require monthly monitoring for phosphorus and/or nitrogen if a facility is discharging to a nutrient limited watershed as designated by Oklahoma’s Water Quality Standards.

Caltha LLP provides expert technical support to clients nationwide to address State water quality standards. Caltha provides specialized expertise in biomonitoring, aquatic toxicology and impacts to aquatic communities.

[Click here to request further information on aquatic toxicology and aquatic community impact assessment]

For further information contact Caltha LLP at
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NH Alteration of Terrain Permit – High Load Areas

The New Hampshire Department of Environmental Services (DES) has recently finalized new rules requiring an Alteration of Terrain Permit (AOT) for many types of construction projects. The purpose of these rules to protect drinking water supplies, surface waters, and groundwater by specifying the procedures and criteria for obtaining permits required by the rule. These rules shall apply to any person proposing to:
(a) Dredge, excavate, place fill, mine, transport forest products, or undertake construction in or on the borders of surface waters; or
(b) Significantly alter the characteristics of the terrain in such a manner as to impede the natural runoff or create an unnatural runoff.

One key aspect of the rule is the definition and requirements for “High-Load Areas”. High-load areas include:
(1) Industrial facilities subject to the NPDES Multi-Sector General Permit;
(2) Petroleum storage facilities;
(3) Petroleum dispensing facilities;
(4) Vehicle fueling facilities;
(5) Vehicle service, maintenance and equipment cleaning facilities;
(6) Fleet storage areas;
(7) Public works storage areas;
(8) Road salt facilities;
(9) Commercial nurseries;
(10) Non-residential facilities having uncoated metal roofs with a slope flatter than 20%;
(11) Facilities with outdoor storage, loading, or unloading of hazardous substances, regardless of the primary use of the facility; and
(12) Facilities subject to chemical inventory under EPCRA Section 312.

A Source Control Plan may need to be prepared and submitted to NHDES for any proposed projects that include high-load areas and larger commercial parking areas.

The new rule also details requirements that apply to stormwater management practices from high-load areas, which include:

Prohibition on groundwater recharge;
Prohibition on infiltration practices;
Prohibition on stormwater filtering practices, without an impermeable liner; and
Prohibition on stormwater swale practices, without an impermeable liner.

Caltha LLP provides expert technical support to clients nationwide to develop cost effective pollution prevention programs to meet State and Federal requirements.

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

Stormwater Monitoring – Storm Water Sampling Services

An increasing number of States require routine sampling of stormwater discharges to demonstrate compliance with NPDES discharge permits. Whether samples are needed for visual monitoring, chemical monitoring, or benchmark monitoring, one of the more challenging tasks a permitted facility must address is how to collect valid stormwater samples.

Caltha LLP provides expert technical support to permitted facilities and/or their consultants and engineers to develop stormwater monitoring programs developed to meet the requirements of individual States. Storm water programs are provided to meeting the needs of both Industrial and Municipal (MS4) stormwater dischargers.

[Read more about selecting the right stormwater monitoring approach]
[Read more about stormwater benchmark monitoring]

Caltha LLP provides a range of stormwater monitoring services, from development of a written Stormwater Monitoring Plan, to conducting stormwater monitoring training, to supplying equipment and sampling personnel to collect samples.
[Read more about Stormwater Monitoring Services]

Wednesday, February 11, 2009

When Does SWPPP Need To Be Prepared? - New Facility Start-up

New facilities that require an NPDES stormwater discharge permit are required to prepare and implement a stormwater pollution prevention plan (SWPPP). In the sequence of constructing and beginning operations at a new facility, when does the SWPPP need to be completed?

For many new facilities, the period of construction through startup will actually require two SWPPPs - one during construction phase and one for the on-going industrial activities.

Regarding the industrial permit phase, the specific requirements will differ somewhat from State-to-State. In general, the SWPPP will need to be prepared and implemented prior to submitting a Notice of Intent (NOI) for permit coverage. This is because the NOI will typically require certification the the SWPPP has been completed and implemented. Therefore, because many States require the NOI to be submitted well in advance of start-up, the SWPPP may need to be completed several weeks or even months prior to start-up.

In some cases, especial for discharges to impaired water or other special waters, the SWPPP document may also need to be submitted along with the NOI.

Caltha LLP provides expert technical support to clients nationwide in addressing stormwater permitting and SWPPP requirements.

[Read further information on Stormwater Plan - SWPPP Services]

[Read further information on Stormwater Training - SWPPP Training]

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

Tuesday, February 10, 2009

Polyaromatic Hydrocarbon (PAH) in Sealants - Stormwater Impact Studies

Collaborative studies 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.

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.

Caltha LLP assists private and public sector clients in evaluating potential stormwater pollution sources and developing cost effective stormwater pollution prevention programs to minimize their environmental impacts.

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

Stormwater Plan Certification - SWPPP Certifications

Under most 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, 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
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.

Who must 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.

Caltha LLP provides expert technical support to private and public sector clients in developing stormwater pollution prevention programs to meet regulatory requirements.

[Read more about State-specific SWPPP Templates

[Read more about Stormwater Training - SWPPP Training]

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

Stormwater Training - Stormwater Pollution Prevention Training

Monday, February 9, 2009

SPCC Plans - State Spill Prevention - Preparedness Requirements

Friday, February 6, 2009

Substantially Identical Outfalls - Substantially Identical Effluents

One option potentially available to dischargers required to conduct stormwater monitoring is the use of "Substantially Identical" outfalls. This is particularly useful to facilities with many outfalls that need to be monitored.

The selection of substantially identical outfalls does not have to be "pre-approved" in many cases. However, the risk to dischargers is that if the permitting agency does not agree with the determination of substantially identical outfalls, the discharger may be subject to enforcement action. Therefore, careful consideration and documentation that the selected identical outfalls are valid is important.

The criteria used to determine if the "Substantially Identical" option applies will change from State-to-State. Generally, the factors used can include:

Location ;
Industrial activities conducted in the drainage area of each outfall;
Control measures implemented in the drainage area of each outfall;
Materials used or stored;
Runoff coefficient of the drainage areas.

Caltha LLP assists dischargers nationwide in developing and implementing cost effective stormwater monitoring programs, including determination and documentation of substantially identical outfalls. To request further information, go to SWPPP and SPCC website.

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

Substantially Identical Outfalls - Potential Option To Reduce Sampling Costs

The availability of this option will change from State-to-State, as will the exact requirements. However, generally if the facility has two or more outfalls that discharge substantially identical effluents, the facility may be allowed to conduct visual and/or benchmark monitoring at one of the outfalls and report that the results also apply to the substantially identical outfall(s). In many cases, the facility will need to perform monitoring on a rotating basis of each substantially identical outfall. However, if stormwater contamination is identified at any substantially identical outfall, control measures may need to be installed for all identical outfalls.

In many cases, selection of substantially identical outfalls does not have to be "pre-approved". However, the risk to dischargers is that if during subsequent compliance inspections the permitting agency does not agree with the determination of substantially identical outfalls, the discharger may be subject to enforcement action. Therefore, careful consideration and documentation that the selected identical outfalls are valid is important.

Caltha LLP asssists dischargers nationwide in developing and implementing cost effective stormwater monitoring programs, including determination and documentation of substantially identical outfalls. To request further information, go to SWPPP and SPCC website.

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

Thursday, February 5, 2009

Stormwater Monitoring - Considerations for Selecting Sampling Technique

Selecting the optimum stormwater sampling approach is a key element to managing costs for stormwater compliance monitoring.

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

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. Click here to request further information on Stormwater and SWPPP Services.

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

Wednesday, February 4, 2009

Self Certification of SPCC Template Plans – What Is Required?

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.

For Tier I Qualifying facilities, the facility must also certify that it meets all the requirements necessary to use the SPCC Template Plan format. All "self-certified" SPCC Plans, including those using the SPCC Template Plan format, 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.

[Request information on State-specific SPCC Plans and Template Plans]

Caltha LLP offers expert technical and regulatory support to develop "self-certified" facility Spill Prevention, Control & Countermeasure (SPCC) plans, including several low cost options for SPCC Plans using the new SPCC Template Plan format. Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112 requirements. 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

Tuesday, February 3, 2009

Cost for Stormwater Monitoring - Managing Costs By Selecting Optimum Sampling Stategy

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:

Train Facility Staff to Collect Samples. In this case, a few staff are trained on how to collect and handle samples.
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.
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.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules, including Development of Stormwater Monitoring Plans and Training Facility Staff to Collect Stormwater Samples. Click here to request further information on Stormwater and SWPPP Services.

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

Monday, February 2, 2009

Optimizing Consistency Between Multiple Industial SWPPP Plans

Larger companies may have several facilities that are subject to stormwater permit requirements and are required to develop site-specific Stormwater Pollution Prevention Plans (SWPPP). Some elements of the SWPPP will likely represent corporate wide programs that apply to all facilities. Companies may also want to “standardize” their SWPPP so that each facility is implementing similar programs; these will allow multiple facilities to share training materials, for example.

If all facilities are located within a single State, the process of standardizing the SWPPP programs is straightforward. Each facility SWPPP will need to include a site specific facility information and evaluation of the potential pollutant sources, but many of the program descriptions can be identical.

If facilities are located in different States, the process of maximizing consistency between SWPPPs requires significantly more thought. One option is to compile the most stringent set of requirements, and use them to develop the SWPPP template. The clear advantage of this approach is that all facilities will be conducting the same programs. The disadvantage is that many facilities will be implementing programs which are well beyond their own State requirements and will be incurring higher costs. Finding the proper balance between consistency and meeting individual State requirements is key.

For those companies that favor a higher degree of consistency between facilities, even at higher cost, there is another factor that should be considered. Overtime, individual State requirements change – on average, 20% of States revise their requirements each year. Therefore, careful consideration must be made to whether or not a change in one State will require that all SWPPPs in all States to be revised. If the answer is no, then over time, the SWPPP programs between States will become more and more different from each other. Therefore, the benefit of consistency that was important in the beginning will be lost.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. Caltha specializes in developing cost effective corporate-wide SWPPP programs covering multiple facilities. Click here to request further information on Stormwater and SWPPP Services.

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