Final Arizona ADEQ Industrial Stormwater MSGP Storm Water Rule

The Arizona Department of Environmental Quality (ADEQ) has finalized its multisector industrial stormwater discharge general permit, known officially as the AZPDES Multi-Sector General Permit, or MSGP 2010. This permit replaces the existing industrial stormwater permit, which expired in 2005. This permit is nearly identical to the draft permit released for public comment in February 2010.

[Review a summary of the draft ADEQ Industrial Stormwater Permit]

All facilities that require permit coverage are required to submit a permit application (Notice of Intent, or NOI) to ADEQ; an NOI needs to be submitted even for facilities that were previously covered by the old permit.

Some key changes in the new permit compared to the previous permit are the additional of sector-specific requirements for each of 30 different sectors.

Click on a sector below to review proposed sector specific requirements:

Arizona DEQ SWPPP Requirements for Sector A - Timber Products
Arizona DEQ SWPPP Requirements for Sector B - Paper and Allied Products Manufacturing
Arizona DEQ SWPPP Requirements for Sector C - Chemical and Allied Products Manufacturing
Arizona DEQ SWPPP Requirements for Sector D - Asphalt Paving and Roofing Materials and Lubricant Manufacturing
Arizona DEQ SWPPP Requirements for Sector E - Glass, Clay, Cement, Concrete, and Gypsum Products
Arizona DEQ SWPPP Requirements for Sector F - Primary Metals
Arizona DEQ SWPPP Requirements for Sector G - Metal Mining
Arizona DEQ SWPPP Requirements for Sector H - Coal Mining
Arizona DEQ SWPPP Requirements for Sector I - Oil and Gas Extraction and Refining
Arizona DEQ SWPPP Requirements for Sector J - Mineral Mining
Arizona DEQ SWPPP Requirements for Sector K - Hazardous Waste Treatment, Storage, or Disposal Facilities
Arizona DEQ SWPPP Requirements for Sector L - Landfills, Land Application Sites, and Open Dumps
Arizona DEQ SWPPP Requirements for Sector M - Automobile Salvage Yards
Arizona DEQ SWPPP Requirements for Sector N - Scrap Recycling and Waste Recycling Facilities
Arizona DEQ SWPPP Requirements for Sector O - Steam Electric Generating Facilities
Arizona DEQ SWPPP Requirements for Sector P - Land Transportation and Warehousing
Arizona DEQ SWPPP Requirements for Sector Q - Water Transportation
Arizona DEQ SWPPP Requirements for Sector R - Ship and Boat Building and Repair Yards
Arizona DEQ SWPPP Requirements for Sector S - Air Transportation Facilities
Arizona DEQ SWPPP Requirements for Sector T - Treatment Works
Arizona DEQ SWPPP Requirements for Sector U - Food and Kindred Product
Arizona DEQ SWPPP Requirements for Sector V - Textile Mills, Apparel, and Other Fabric Products
Arizona DEQ SWPPP Requirements for Sector W - Furniture and Fixtures
Arizona DEQ SWPPP Requirements for Sector X - Printing and Publishing
Arizona DEQ SWPPP Requirements for Sector Y - Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
Arizona DEQ SWPPP Requirements for Sector Z - Leather Tanning and Finishing
Arizona DEQ SWPPP Requirements for Sector AA - Fabricated Metal Products
Arizona DEQ SWPPP Requirements for Sector AB - Transportation Equipment, Industrial and Commercial Machinery
Arizona DEQ SWPPP Requirements for Sector AC - Electronic and Electrical Equipment and Components

[Read more about ADEQ stormwater monitoring requirements and industrial stormwater benchmarks]

Caltha LLP provides expert consulting services to public and private sector clients in Arizona to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Arizona DEQ Stormwater Monitoring and Industrial Storm Water Benchmarks

In December 2010, the Arizona Department of Environmental Quality (ADEQ) issued the Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The revised permit included significant changes to stormwater discharge requirements for permitted sites, which are now divided into 29 industrial sectors. One of the most significant changes was the requirement for sampling stormwater and reporting results to ADEQ. The monitoring requirement begins immediately after permit coverage begins. ADEQ has defined monitoring seasons in the permit:
Summer wet season: June 1 – October 31
Winter wet season: November 1 – May 31
The frequency for stormwater sampling in the permit is at least twice each wet season (summer and winter) from each monitoring location.

All sites permitted under the MSGP (with some limited exceptions) will have to collect stormwater samples and have samples analyzed for their sector-specific benchmark parameters. If one or more benchmarks are exceeded, sites will be required to upgrade their pollution prevention measures and will need to do further stormwater monitoring.

Some stormwater benchmarks that apply to several sectors include:

Ammonia 2.14 mg/L
Biochemical Oxygen Demand (BOD) 30 mg/L
Chemical Oxygen Demand (COD) 120 mg/L
pH 6.0 – 9.0 s.u.
Total Aluminum 0.75 mg/ L
Total Arsenic 0.15 mg/L
Total Cyanide 0.022 mg/ L
Total Iron 1.0 mg/L
Total Magnesium 0.064 mg/L
Total Mercury 0.0014 mg/L
Total Selenium 0.005 mg/L
Total Suspended Solids (TSS) 100 mg/L


Since the 1980s, the U.S. Environmental Protection Agency (EPA) has collected industry-sector data on stormwater discharge. The linked presentation provides a comparison of these historic industrial stormwater results to the many of the ADEQ stormwater benchmark concentrations. The results are discussed in context of which stormwater benchmark parameters have a higher potential for exceedance of benchmark values. This presentation also discusses which of the industrial sectors have a higher potential for exceedance of their specific benchmark values.

Note: Arizona uses the same benchmark concentrations used by EPA and many other States; although the this linked presentation was specific to Minnesota, the analysis and conclusions apply to Arizona.
Link to presentation slides:

Industrial Stormwater Benchmarks – Comparison of New Minnesota Benchmark Concentrations To Historic Industry-specific Testing Results
Caltha LLP provides expert consulting services to public and private sector clients in Arizona to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.


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

Revised Wisconsin Stormwater General Permits - Public Hearings

The Wisconsin Department of Natural Resources has proposed to reissue four of its expired general industrial storm water discharge permits:

Tier 1 Industrial Facilities (Permit No. S067849-3);
Tier 2 Industrial Facilities (Permit No. S067857-3);
Recycling of Scrap and Waste Materials (Permit No. S058831-2); and
Dismantling of Vehicles for Parts Selling and Salvage (Permit No. S059145-2).

The Department will be conducting three public hearings on the proposed permits:

December 14, Madison, WI
December 15, Wausau, WI
December 16, Milwaukee, WI

The purpose of the hearings is to receive public comments on the WDNR’s tentative decision to reissue these general permits. During the hearings, DNR staff will briefly explain the content of the proposed permits. Written comments on the reissued permits must be received no later than January 7, 2011.

To review a summary of each of the permit, click on the links below:

Tier 1 Industrial Facilities (Permit No. S067849-3);
Tier 2 Industrial Facilities (Permit No. S067857-3);
Recycling of Scrap and Waste Materials (Permit No. S058831-2); and
Dismantling of Vehicles for Parts Selling and Salvage (Permit No. S059145-2).

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

MPCA Storm Water Benchmarks, Comparison To Historic Sector Monitoring Data

In 2010, the Minnesota Pollution Control Agency (MPCA) reissued the Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The reissued permit included significant changes to stormwater discharge requirements for permitted sites, which are now divided into 29 industrial sectors. One of the most significant changes was the requirement for sampling stormwater and reporting results to MPCA. Each sector has been assigned sector-specific stormwater benchmark concentrations. Beginning in June 2011, all sites permitted under the MSGP will have to collect stormwater samples and have samples analyzed for their sector-specific benchmark parameters. If one or more benchmarks are exceeded, sites will be required to upgrade their pollution prevention measures and will need to do further stormwater monitoring.

Since the 1980s, the U.S. Environmental Protection Agency (USEPA) has collected industry-sector data on stormwater discharge. The linked presentation provides a comparison of these historic industrial stormwater results to the current MPCA stormwater benchmark concentrations. The results are discussed in context of which stormwater benchmark parameters have a higher potential for exceedance of benchmark values. This presentation also discusses which of the industrial sectors have a higher potential for exceedance of their specific benchmark values.

Note: Because many States use the same benchmark concentrations used by Minnesota, this analysis and conclusions can be applied to most States.
Link to presentation slides:

Industrial Stormwater Benchmarks – Comparison of New Minnesota Benchmark Concentrations To Historic Industry-specific Testing Results
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Correction Rule for Construction & Development Effluent Limitations Guidelines

US EPA has announced that it is taking action will address an error that was identified in the Effluent Limitations Guidelines for the Construction & Development (C&D) Point Source Category. The C&D rule was issued on December 1, 2009 and became effective on February 1, 2010. This rule contains a numeric effluent limit for turbidity, based on the application of passive treatment technology.

After the final rule was promulgation, EPA received two petitions for reconsideration of the C&D rule. The petitions pointed out a potential error in the calculation of the numeric limit. Based on EPA's examination of the underlying dataset, EPA has determined that the calculations used to develop the limit were not adequate to support the numeric effluent limit. Consequently, EPA intends to propose a correction rule for public comment and then take final action on a revised limitation.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.comorCaltha LLP Website

Stormwater Treatment System for PCB in Seattle

The Boeing Company signed an agreement with EPA to construct a new stormwater treatment system at North Boeing Field in Seattle. The treatment system will be designed to reduce the amount of polychlorinated biphenyls (PCBs), which are an on-going source of pollution to the Duwamish River.

The North Boeing Field storm drain system carries stormwater to the Duwamish River through more than seven miles of catch basins, drains, inlets, and oil-water separators. Studies by the Washington State Department of Ecology (Ecology), the City of Seattle, and Boeing showed the North Boeing Field storm drain system is the biggest source of PCBs to the river sediments in Slip 4, one of the most highly contaminated sites on the lower Duwamish waterway.

With the installation of this stormwater treatment system to address the on-going source of PCBs, cleanup of Slip 4 will proceed in 2011. Several acres of contaminated sediments in Slip 4 will be cleaned up under an EPA settlement agreement with the City of Seattle and King County.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Fee Increase For California Storm Water Permits

The California State Water Resources Control Board is considering emergency measures that will result in a significant increase the fees charged to stormwater permittees.

According to the State Board, the increase is needed to respond to both reductions in revenue generated and increased program costs. The shortfall in revenue is a result of under-collection of revenue in the Surface Water Ambient Monitoring Program (SWAMP) in FY 2009-10 and a substantial drop in enrollment under the State Water Board’s recently adopted storm water construction permit. In July 2009, the State Water Board adopted Order 2009-0009-DWQ requiring storm water construction dischargers to enroll in a new storm water construction permit by July 1, 2010. Approximately 64 % of previous storm water construction permit holders did not renew their permits by the deadline and have been terminated from coverage. Many of these permittees did not reenroll because of a decline in construction activity. At the same time, the downturn in the construction industry has resulted in a reduction of the number of new permits being issued.

During the same period, costs increased substantially due to a shift in funding for basin planning from General Fund support to fee support and a return to full payroll costs due to the discontinuance of the furlough program.

According to the State Board, the Storm Water program needs to generate an additional $4.4 million in revenue to meet the FY 2010-11 Budget, which translates to a 21.5 % increase to all Storm Water fee categories.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Stormwater Seminar in MN & ND Permiting and Design

Minnesota and North Dakota Stormwater Management Seminar
Fargo, North Dakota
Friday, November 19, 2010


Purpose:

• Examine federal, state, and local rules on stormwater management
• Review municipal, industrial and construction permits and the permitting process
• Explore green stormwater practices
• Examine site selection, sizing, and design
• Evaluate erosion and water quality

Agenda:

Understanding Federal and State Rules on Stormwater Management
Federal statutes and regulations, National Pollutant Discharge Elimination System (NPDES) requirements, State statutes and regulations, North Dakota Department of Health NDDH stormwater requirements, Minnesota Pollution Control Agency MPCA stormwater requirements, Local requirements and procedures, Storm water permits and permit application process, Special waters and impaired waters

Stormwater Management Using Wet and Dry Detention Facilities
Detention/retention pond overview, Advantages and disadvantages, Design considerations, Hydrology, Permitting, Site selection, Water quality, Pond sizing, Safety considerations, Outlet structures, Good design practices, Pond routing theory, Interconnected ponds, Steps for detention design

Stormwater Quality Best Management Practices
Bioretention and rain-leader disconnect raingardens, Cisterns, Permeable pavers/pervious concrete, Disconnecting impervious area/vegetated swales, Soil amendments, Rainwater harvesting, Green roofs

Bioretention Design and Maintenance
Costs and consequences of poor design, Site evaluation, Cell configuration and soils, Siting, ponding depth, vegetation, Installation specifications, Maintenance program, Overview of maintenance activities, Costs, Case Study: City of Plymouth, Minnesota, residential raingarden and maintenance program

Download Seminar brochure

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Trash Limits for MS4s in Anacostia Watershed - Trash TMDL

U.S. EPA, the District of Columbia, and the state of Maryland have announced a new Total Maximum Daily Load (TMDL) for trash in the Anacostia River, making the Anacostia the first interstate river in the nation with such a Clean Water Act (CWA) trash limit. Each year, hundreds of tons of trash and debris are illegally dumped or washed into the Anacostia with stormwater runoff. As a result, the District and Maryland have both included the Anacostia River on their respective lists of impaired waters due to excessive quantities of trash and debris.

The TMDL requires capturing or removing more than 600 tons (1.2 million pounds) of trash from the watershed annually. To complement this TMDL, the EPA, as the permitting authority for the District, and the state of Maryland are developing MS4 storm sewer permits which will serve as key implementation tools requiring municipalities in the Anacostia watershed to achieve the trash reductions required in the TMDL. In addition, continued implementation of the Combined Sewer Overflow Long Term Control Plan for the District of Columbia supports achievement of the limits.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Revised Rule 6 Reporting Forms - IDEM Industrial Storm Water Permit

The Indiana Department of Environmental Management (IDEM) Office of Water Quality has created new state forms for all permitted facilities to complete and submit to meet the annual reporting and stormwater discharge monitoring reporting requirements of Rule 6.

Rule 6 requires each permittee to complete and submit an Annual Report. Annual Reporting is an effective way of ensuring the Storm Water Pollution Prevention Plan (SWP3) is current, potential pollution sources are identified, and Best Management Practices and corrective measures are implemented, properly designed and functioning, and are being maintained. An Annual Report is due no later than 365 days from submitting the Notice of Intent and must contain information obtained during the previous year of regulation. Subsequent annual reports must be submitted no later than 365 days from the previous report in years 2 through 5.

Rule 6 also requires each permittee to conduct annual storm water monitoring. A Storm Water Discharge Monitoring Report is due no later than 365 days from submitting the Notice of Intent. Subsequent annual storm water discharge monitoring reports must be submitted no later than 365 days from the previous report in years 2 through 5. Each year of the permit, permitted facilities are required to collect grab storm water samples from qualified rainfall. The samples must be sent to a lab and analyzed for any pollutant that has the potential to be present in a storm water discharge in addition to the following required 8 sampling parameters:
• pH;
• Oil and Grease;
• Nitrates plus nitrite nitrogen;
• Kjeldahl nitrogen, total (TKN);
• Phosphorous, total;
• Suspended solids, total (TSS);
• Chemical oxygen demand (COD);
• Carbonaceous bio-chemical oxygen demand (CBOD5)

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

CT DEP Revised Industrial Stormwater General Permit

The Connecticut Department of Environmental Protection (DEP) has revised the requirements for management of storm water runoff from industrial sites under its General Permit program.
The revised industrial storm water General Permit is scheduled to go into effect Oct. 1, 2011. DEP is in the process of reissuing the existing General Permit so that it will remain in effect until that date. Industrial facilities will automatically remain registered under the existing General Permit once it is reissued. All industrial facilities are required to register for the revised permit by June 1, 2011. To provide compliance assistance to permittees, DEP will conduct outreach on new permit requirements in the fall of 2010.

The most significant new requirements of the General Permit for management of storm water at industrial sites include:

Industrial Sectors
The provisions of the General Permit apply to all sites, however there are additional sector-specific requirements for monitoring and stormwater controls that apply to specific types of industries. The sectors are:

• asphalt plants;
• non-metallic mines and quarries;
• refuse systems;
• auto salvage yards;
• scrap recycling facilities;
• steam electric power facilities;
• transportation and public works facilities;
• marinas and yacht clubs and boat dealers;
• ship and boat building and repair;
• small scale composting facilities.
  

Monitoring
The revised permit requires all permittees to conduct visual monitoring of storm water discharges on a quarterly basis and sampling and testing of storm water for 10 parameters on a semi-annual basis. In addition to these standard requirements, some industry sectors have additional parameters that are specific to the industry type, which must be also sampled.

Note: Since the 1980s, the U.S. Environmental Protection Agency (EPA) has collected industry-sector data on stormwater discharge. The linked presentation provides a comparison of these historic industrial stormwater results to the many of the ADEQ stormwater benchmark concentrations. The results are discussed in context of which stormwater benchmark parameters have a higher potential for exceedance of benchmark values. This presentation also discusses which of the industrial sectors have a higher potential for exceedance of their specific benchmark values.

Note: CT uses the same benchmark concentrations used by EPA and many other States; although the this linked presentation was specific to Minnesota, the analysis and conclusions apply to CT.

Link to presentation slides:

Industrial Stormwater Benchmarks – Comparison of New Minnesota Benchmark Concentrations To Historic Industry-specific Testing Results



Impaired waters
The revised permit includes specific requirements for discharges to impaired waters. For existing discharges, a permittee will monitor annually for the pollutant(s) associated with the water impairment. In certain cases, a permittee will have to install additional site controls to improve storm water quality so that the impaired water quality can be improved. New discharges to impaired water will be authorized if the storm water discharge does not contain the pollutant(s) of concern, or if the site prevents the exposure of the pollutant(s) of concern to storm water. However, if the pollutant(s) are present onsite and exposed to storm water, the registrant must demonstrate that the discharge meets requirements in place to meet water quality before the discharge can occur.

Public Notice
The General Permit expands opportunities for public comment and access to information about pending registrations. Pollution Prevention Plans can also be reviewed, with the exception of elements that are trade secrets or otherwise exempt from the disclosure requirements of the state Freedom of Information Act. Notice of pending registrations and the availability of Pollution Prevention Plans for a site will be posted on the DEP website for public review and comment.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Revision to Rhode Island Stormwater Requirements

The Rhode Island Department of Environmental Management (DEM) is proposing to adoption of the Rhode Island Stormwater Design and Installation Standards Manual (Stormwater Manual), amendments to the rules and regulations relating to the state Fresh Water Wetlands Act , and amendments to state water quality regulations.

The primary purpose of the proposed Stormwater Manual is to implement the "Smart Development for a Cleaner Bay Act of 2007". This Act requires that DEM and the Coastal Resources Management Council (CRMC) amend the 1993 version of the Stormwater Manual. The Act states, "The changes shall include, but not be limited to, incorporation into existing regulatory programs that already include the review of stormwater impacts the following requirements:
a. Maintain pre-development groundwater recharge and infiltration on site to the maximum extent practicable;
b. Demonstrate that post-construction stormwater runoff is controlled, and that post-development peak discharge rates do not exceed pre-development peak discharge rates; and
c. Use low impact-design techniques as the primary method of stormwater control to the maximum extent practicable."

To avoid, minimize and manage the impacts of stormwater on stream channels, water quality, groundwater, wetland habitat, and flooding, DEM and CRMC are proposing extensive updates to the 1993 Stormwater Manual. The changes reflect the state of the art in science and engineering practice concerning stormwater management. The proposed Stormwater Manual specifies standards and design requirements for stormwater management on new development, redevelopment, and infill projects and requires Low Impact Development (LID) as the "industry standard" for handling and treating stormwater.

The proposed amendments to the Fresh Water Wetlands Regulations and the Water Quality Regulations are necessary in order to reference and incorporate the new Stormwater Manual provisions into the regulatory requirements of these regulations, as well as to stipulate appropriate timetables to begin requiring use of the new Stormwater Manual.

DEM is proposing to begin requiring compliance with the new Stormwater Manual on most applications beginning on January 1, 2011. In addition, amendments are proposed to the Fresh Water Wetlands Regulations and the Water Quality Regulations to address the 2010 revisions to the RIGL §42-17.1-2.5 regarding tolling of expiration periods of development permits.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

SD DENR Revised Industrial Discharge Permit

The South Dakota Department of Environment and Natural Resources (DENR) has drafted a revised general stormwater discharge permit for industrial dischargers in the State. The existing permit expired in 2008, but has remained in effect until the revised permit is finalized.

The revised permit that has been draft is similar in many aspects to the existing permit, including requirements for stormwater pollution prevention plan (SWPPP), site inspections, and prohibition on non stormwater discharges, such as equipment and vehicle washing.

There are some important differences in the working draft that will change the compliance requirements for South Dakota industrial sites.

Multi Sector Industrial Requirements. The current draft permit does not include the industrial sectors associated with the EPA Multi Sector General Permit (MSGP), however it does segregate seven industrial sectors:

• Metals
• Transportation (other than airports)
• Air Transportation, Airports
• Food and Kindred Products
• Auto Salvage
• Landfills
• Waste Treatment

The draft permit is expected to have the same compliance requirements for all industrial facilities, including the seven sectors, with the exception of monitoring requirements.

Stormwater Monitoring Requirements. Under the draft permit requirements, all industrial sites will have to conduct storm water discharge monitoring. All sites would have to collect samples during the first year of the permit and report results to SDDENR. The chemical parameters to be tested by each site will depend on the industrial sector the site falls into.

Under the current plan, monitoring results reported to DENR will be used to determine if industrial benchmark concentrations will be established during the next permit revision and as a basis for future benchmarks.

The revised permit is expected to be released for public review and comment in the Fall 2010; South Dakota DENR anticipates that the new permit will be effective January 1, 2011.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Suspended Solids Limits In Runoff To Chesapeake Bay

EPA has announced plans to issue draft sediment limits as the next step in establishing the Watershed Implementation Plans (WIPs) for the Chesapeake Bay Total Maximum Daily Load (TMDL). The six States within the Bay watershed are expected to use sediment limits, along with those previously issued for nitrogen and phosphorus, as the basis for completing their WIPs This plans would also detail how States will further divide these limits among pollution sources, and what best management practices and stormwater controls will be implemented to meet water quality standards.

The first drafts of the State WIPs are due to EPA by September 1. On September 24, EPA plans to issue a draft TMDL and open a 45-day public comment period, including 18 public meetings. The final WIPs are due November 29, and EPA will establish the final Bay TMDL by December 31.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP atinfo@calthacompany.comorCaltha LLP Website

Minnesota South Dakota Stormwater Training Seminar

Stormwater Management
Sioux Falls, South Dakota
Tuesday, September 28, 2010


Purpose:

• Examine federal, state, and local rules on stormwater management
• Review municipal, industrial and construction permits and the permitting process
• Explore green stormwater practices
• Examine site selection, sizing, and design
• Evaluate erosion and water quality

Agenda:

Understanding Federal and State Rules on Stormwater Management
Federal statutes and regulations, National Pollutant Discharge Elimination System (NPDES) requirements, State statutes and regulations, South Dakota Department of Environment and Natural Resources, Minnesota Pollution Control Agency, Local requirements and procedures, Permits and permitting process, special waters and impaired waters

Stormwater Management Using Wet and Dry Detention Facilities
Detention/retention pond overview Advantages and disadvantages Steps for detention design, Hydrology, site selection, water quality, Pond sizing, safety considerations, outlet structures, Pond routing and interconnected ponds, emerging issues

Green Stormwater Practices
Bioretention basics What are others doing? (Twin Cities, Omaha, Kansas City, Denver), LEED Specific practices, Constructed wetland, vegetated swale, Vegetated filter strip, rain gardens, rain barrels, BioRetention, pervious/permeable pavement Sustainable landscaping, plant selection, grass selection, amenities to showcase site

Pond Maintenance Issues
Pond access & easement issues, Evaluating water quality, Sediment management, Vegetation management, Emerging pollutant problems, Pretreatment Issues

Download Seminar brochure

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

MS4 Enforcement Action In Pennsylvania

U.S. Environmental Protection Agency has sent orders to four south central Pennsylvania municipalities requiring improvements to their respective Municipal Separate Storm Sewer System (MS4) programs. Orders went to Silver Spring Township and Lower Allen Township in Cumberland County, and Wyomissing Borough and West Reading Borough in Berks County. EPA issued similar orders last April to 79 other municipalities in this south central part of the state, an area that drains to the Chesapeake Bay.

The orders require the municipalities to correct problems with their respective MS4 programs and come into compliance with their stormwater discharge permit. In order to comply with their permit, municipalities are required to develop stormwater management programs to control pollutants from entering their drainage systems, which include storm drains, pipes, and ditches, designed to collect and convey stormwater runoff.

EPA continues to perform on-the-ground MS4 inspections of municipalities throughout Pennsylvania and other mid-Atlantic states for compliance with existing MS4 permit provisions. The Pennsylvania Department of Environmental Protection (PDEP) is in the process of completing a 5-year renewal of the MS4 general permit which is scheduled to be completed in the latter half of 2011.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Minnesota Restrictions on Coal Tar-Based Sealants

In 2009, the Minnesota Legislature enacted a law restricting to use of coal tar-based asphalt sealants in Minnesota. The bill prohibited state agencies from purchasing undiluted coal tar-based sealant, and directed the Pollution Control Agency (MPCA) to study its environmental effects and develop management guidelines.

The 2009 legislation was contained in House File 1231. The main requirements outlined in the legislation are:

• Notify state and local government units
By January 15, 2010 the MPCA must notify state agencies and local governments of the potential for contamination of stormwater ponds and wetlands by coal tar-based sealants.
• Inventory stormwater ponds
The MPCA must complete a plan to inventory stormwater ponds in the state by January 15, 2010.
• Use by State agencies restricted as of July 1, 2010
State agencies may not purchase undiluted coal tar-based sealant after this date.
• Develop best management practices and develop model ordinance on use of sealants for local units of government (LUGs)
The MPCA must develop and make available best management practices that can avoid or mitigate environmental impacts of coal tar-based sealants.
• Develop grant process
MPCA will develop a process by July 2010 for awarding grants to LUGs for treatment of contaminated sediment.

By the next cycle of municipal stormwater permitting, beginning June 2011, all MS4 permittees will be required to comply by all provisions of the legislation.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

MPCA MSGP Application Due Dates - Sector Deadlines

All facilities subject to the Minnesota industrial stormwater rules must submit an application for coverage under the new Multi Sector General Permit (MSGP), even if previously covered under the expired MPCA permit. Existing facilities must have prepared and implemented a new SWPPP and be in compliance with the new permit before they apply for permit coverage. New facilities must submit applications at least 180-days before beginning construction or operation.

Note: Facilities that have previously submitted a No Exposure Certification need to reassess their site based on current MPCA certification requirements and reapply for coverage.

Application due dates will be based on the PRIMARY INDUSTRIAL SECTOR CODE the facility falls into:

Sector Group 1
Applications due by June 7

Sector A - Timber Products
Sector C - Chemical and Allied Products Manufacturing
Sector D - Asphalt Paving and Roofing Materials and Lubricant Manufacturing
Sector E - Glass, Clay, Cement, Concrete, and Gypsum Products
Sector F - Primary Metals & Foundries
Sector G - Metal Mining
Sector I - Oil and Gas Extraction and Refining
Sector J - Mineral Mining
Sector L - Landfills, Land Application Sites, and Open Dumps
Sector M - Automobile Salvage Yards
Sector N - Scrap Recycling and Waste Recycling Facilities
Sector Q - Water Transportation
Sector Y - Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
Sector AA - Fabricated Metal Products

Sector Group 2
Applications due by August 6

Sector H - Coal Mining
Sector K - Hazardous Waste Treatment, Storage, or Disposal Facilities
Sector O - Steam Electric Generating Facilities
Sector P - Land Transportation and Warehousing
Sector R - Ship and Boat Building and Repair Yards
Sector S - Air Transportation Facilities
Sector Z - Leather Tanning and Finishing
Sector AC - Electronic and Electrical Equipment and Components


Sector Group 3
Applications due by October 4

Sector B - Paper and Allied Products Manufacturing
Sector T - Treatment Works
Sector U - Food and Kindred Product
Sector V - Textile Mills, Apparel, and Other Fabric Products
Sector W - Furniture and Fixtures
Sector X - Printing and Publishing
Sector AB - Transportation Equipment, Industrial and Commercial Machinery

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Stormwater Rule Small Business Advocacy Review Panel

U.S. Environmental Protection Agency (EPA) is inviting small businesses and municipalities to nominate representatives to provide input on a proposed stormwater rule. The rule would strengthen the national stormwater program under the Clean Water Act (CWA) and focus on stormwater discharges from developed sites, such as subdivisions, roadways, industrial facilities, and commercial buildings or shopping centers.

Selected participants would provide input to a Small Business Advocacy Review panel, which will consist of officials from EPA, the U.S. Small Business Administration and the Office of Management and Budget. As required by the Regulatory Flexibility Act, EPA is establishing this panel because the rule could have a significant economic impact on small entities. The representatives will provide input on how EPA can minimize the potential burden on small entities of the proposed regulation. Nominations must be received by August 4, 2010.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Oregon DEQ Stormwater Permit Changes - MSGP

The Oregon Department of Environmental Quality (DEQ) is currently revising the State industrial stormwater general permits 1200-COLS permit (which went into effect September 2006) and the 1200-Z permit (which went into effect July 2007). Two environmental advocacy groups, Northwest Environmental Defense Center and Columbia Riverkeeper, challenged the permits validity under the Federal Clean Water Act. DEQ settled the legal challenge and as part of the settlement agreement, agreed to revise the permits.

The June 2009 settlement agreement required DEQ to amend the permits to conform to the 2008 US EPA Multi Sector General Permit (MSGP). The agreement also requires DEQ to include certain conditions of the existing permits that when beyond the MSGP, including that DEQ review and approve all stormwater pollution prevention plans (SWPPP). In May 2010, DEQ and the environmental advocacy groups amended the settlement agreement to provide additional time for DEQ to develop water quality based benchmarks for copper, lead, and zinc.

DEQ intends to revise these permits by the Fall 2011. The public will have an opportunity to comment on the proposed changes to the permits before they become effective. While these new permits are in development, the requirements under the existing permits remain in effect.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Wet Weather Pollution in Michigan Report Released

Michigan Department of Natural Resources and Environment (DNRE) has released its report “Wet Weather Pollution in Michigan” (Report No. MI/DNRE/WB-10/020). DNRE formed five work groups to evaluate issues related to wet weather pollution and develop a strategy to more effectively protect water quality: Wastes to Land, Earth Change, Urban Living, Monitoring, and Water Quality Based Effluent Limits and Standards Applicability. Each work group report is included as a chapter of the report.

The conclusions and recommendations made by the Work Groups include:

1. Increased E. coli concentrations are the most documented effects from wet weather pollution discharges.
2. Urban streams are heavily impacted by flow modifications from wet weather pollution discharges, due to unnaturally high runoff volumes.
3. A large amount of subjectivity exists in many of the existing wet weather pollution programs.
4. A lack of consistent terminology exists across programs that deal with wet weather pollution.
5. Measuring the impacts of wet weather pollution is problematic, primarily due to sampling difficulty, a lack of methods to monitor pollutants, and established means to evaluate the impacts of wet weather pollution discharges.
6. Based on available records, animal wastes are the largest, by volume, wastes that are applied to land in Michigan.
7. Good regulatory mechanisms exist for biosolids, septage, CAFO permits, combined sewer overflow (CSO), storm sewer overflow (SSO), Industrial Storm Water, Municipal
Storm Water (those under permit), Construction Storm Water and soil erosion and sedimentation control (SESC).
8. Urban infrastructure in Michigan is currently in need of a clearly defined adequate maintenance program.
9. Effective best management practices (BMP) need to be identified and BMP standards established.
10. It is difficult to understand and address total maximum daily load (TMDL) obligations for wet weather pollution discharges.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

WDNR MS4 Suspended Solids Reduction Guidance

The Wisconsin Department of Natural Resources (WDNR) has recently published guidance to be used by municipalities to demonstrate compliance with total suspend solids reduction requirements. Under Wisconsin Rules NR 151.13 (2), municipalities subject to the municipal WPDES stormwater permit requirements must, to the maximum extent practicable, implement a 20% and a 40% reduction in total suspended solids in runoff that enters waters of the state as compared to no controls, by March 10, 2008 and March 10, 2013, respectively.

The updated guidance assists affected municipalities to understand what areas under the municipalities' jurisdictions will be included in this requirement, what is meant by "no controls" and "with controls", and what methods are acceptable for making these calculations.
To comply with the code, the developed urban area must be modeled under a "no control" condition and a "with controls" condition. The 20% and 40% TSS reductions are assessed against the "no control" condition for the entire area served by the MS4.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

Infiltration Basin or Class V Injection Well?

Class V wells use injection techniques different from those used by other types of injection wells. A typical Class V well is shallow and relies on gravity to drain or inject liquid waste into the ground. There are over 20 different Class V Well types. Well types can be subdivided based on how the wells are used. Sample categories include drainage wells used for storm water and agricultural irrigation, and domestic wastewater disposal wells.

Class V storm water drainage wells manage surface water runoff (rainwater or snow melt) by placing it below the ground surface. They are typically shallow disposal systems designed to infiltrate storm water runoff below the ground surface. Storm water drainage wells may have a variety of designs and may be referred to by other names including dry wells, bored wells, and infiltration galleries. Regardless of the common name used, a Class V well by definition is any bored, drilled, or driven shaft, or dug hole that is deeper than its widest surface dimension, or an improved sinkhole, or a subsurface fluid distribution system (an infiltration system with piping to enhance infiltration capabilities).

Construction and operation of a Class V stormwater drainage well requires a US EPA permit, and potentially additional State and local permits.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

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

What Is the Sheen Rule? Oil Spill Reporting

Under the Clean Water Act, the "sheen rule" provides the framework for determining whether an oil spill should be reported to the federal government. Federal regulation requires the person in charge of a facility or vessel responsible for discharging oil that may be "harmful to the public health or welfare" to report the spill.

The regulation establishes the criteria for determining whether an oil spill may be harmful to public health or welfare, thereby triggering the reporting requirements:

• Discharges that cause a sheen or discoloration on the surface of a body of water;
• Discharges that violate applicable water quality standards; and
• Discharges that cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorelines.

These reporting criteria are independent of local or State spill reporting requirements. Therefore, spills might be reportable even if State spill reporting thresholds are not exceeded.

Because the Oil Pollution Act of 1990, which amended the Clean Water Act, broadly defines the term "oil," the sheen rule applies to both petroleum and non-petroleum oils and fats (e.g., vegetable oil, milk). The regulation also provides several exemptions from the notification requirements.

FAQ: What is the difference between a SWPPP and and SPCC Plan?

40 CFR 112 SPCC compliance and SPCC Plan services
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Difference Between SPCC SWPPP SWP3 Plans

What is the Difference Between a SPCC Plan and a SWPPP Plan?
Some municipal and industrial sites may be required to prepare and implement either a SPCC Plan, a SWPPP Plan, or both. SPCC Plans and SWPPP Plans are different documents, requiring different types of information, and are required under different regulatory programs.


SPCC Plans. SPCC Plans are required under the federal Oil Pollution Control Act, and the requirements are specified in 40 CFR 112 ("SPCC Rule"). In order to determine if SPCC Rules apply to an individual site, an inventory of oil and fat containing vessels, which may include oil-filled equipment, must be made. The results are compared to the SPCC threshold. If the site exceeds the threshold, a SPCC Plan needs to be prepared and the site needs to comply with other aspects of the SPCC Rule.


SWPPP Plans. Stormwater Pollution Prevention Plans ("SWPPP Plans", or "SWP3 Plan") are required by the federal Clean Water Act, specifically under requirements for National Pollutant Discharge Elimination System (NPDES). The requirement to prepare and implement a SWPPP, and the contents of the SWPPP, will be defined in an NPDES permit. Many industrial, municipal and construction sites are required to obtain an NPDES permit to discharge stormwater, and are therefore required to have a SWPPP.

The SWPPP and SPCC Plan can be related; most SWPPPs need to incorporate procedures for spill prevention and response. Sites that are required to have a SPCC Plan can use that plan to satisfy this one requirement, as long as the oils and fats addressed in the SPCC Plan are the only materials that need to be addressed in the SWPPP.  In summary, sites could need either a SPCC Plan, a SWPPP, or both.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address preparation of SPCC Plans and 40 CFR 112 Compliance Programs, preparation of Stormwater Pollution Prevention Plans (SWPPP), and SPCC Training and SWPPP Training. For further information contact Caltha LLP at
info@calthacompany.com

MN Stormwater Inspection Checklists - SWPPP Inspection Form

Depending on the industrial sectors they fall into, as soon as June 2010, Minnesota industrial and municipal sites that are subject to the MPCA general permit for industrial discharges will need begin conducting facility SWPPP Inspections.

Note: Looking for inspection checklists or other information on other States? Caltha maintains checklists and SWPPP templates for all States. For more information go to:
Caltha LLP Stormwater Services

Who Can Conduct Inspections?
The General Permit requires that facility stormwater inspections be conducted by appropriately trained staff (internal or external). The SWPPP must list the individuals who have been trained to conduct these inspections.

Click here for more information on SWPPP training services, stormwater inspection training and stormwater monitoring training.


Upcoming SWPPP implementation training: Plymouth, MN, Mankato, MN, Moorhead, MN

What Areas Need To Be Inspected?
The areas that need to be inspected will change for different types of industrial sites and will also depend on the types of Best Management Practices (BMPs) being used at the individual site.

Review a summary of industrial sector requirements in Minnesota
Comparison of MPCA industrial stormwater benchmarks to historical industrial group monitoring

Site Inspection Form - Inspection Form
Because the inspections will be different between the numerous industrial sectors and between individual facilities, a "standard" inspection checklist or inspection form has not been prepared by MPCA. Individual sites are expected to determine what areas need to be inspected at their site.
SWPPP checklist - Stormwater inspection form preparation


For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form. Caltha LLP provides expert consulting services to public and private sector clients in Minnesota to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.


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

Revised MS4 Stormwater Regulation - Post Construction Retrofit

In 2006, National Research Council (NRC) conducted a review of the US EPA stormwater program and recommend ways to strengthen it. The NRC Report, which was finalized in October 2008, found that the current stormwater program "...is not likely to adequately control stormwater's contribution to waterbody impairment." and recommended that EPA take action to address the effects of stormwater flow.

In response to this review, EPA is currently revising the municipal (MS4) stormwater program, and plans to establish requirements for managing stormwater discharges from new development and re-development. This action may also expand the areas subject to Municipal Separate Storm Sewer Systems (MS4) permits to include rapidly developing areas and to cover some discharges that are not currently regulated. A single set of stormwater requirements may be developed to combine both Phase I and Phase II MS4s. EPA currently believes that retrofitting for existing discharges may be addressed, although expectations for retrofitting will likely differ significantly from requirements for new- and re-development.

The initiative to revise the MS4 permitting program began in September 2009; EPA currently anticipates finalizing the revision in September 2011.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website