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
Wednesday, May 26, 2010
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
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
Tuesday, May 18, 2010
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.
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.comor
Tuesday, May 11, 2010
Regulation of Milk Under SPCC Rule 40 CFR 112
The storage of "oils" regulated under the federal SPCC Rule (40 CFR 112) includes materials well outside the traditional lubricants and fuels. Many food grade oils, fats, cooking oils, etc are regulated and require spill prevention and controls. Even liquids that contain even small amounts fats or oils in a mixture can be regulated.
Many facilities are surprised to learn that milk is also regulated under SPCC Rules. In 2009, US EPA proposed a rule to exempt milk from SPCC Rules; however, to date this proposed exemption has not been promulgated. Currently, it is assumed that in 2010 US EPA will again propose amendments to 40 CFR 112 to address milk. Milk can also be regulated as a potential pollutant if spilled, and be subject to spill notification requirements outside of regulation under 40 CFR 112.
Example: Minnesota spill reporting requirements
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
Many facilities are surprised to learn that milk is also regulated under SPCC Rules. In 2009, US EPA proposed a rule to exempt milk from SPCC Rules; however, to date this proposed exemption has not been promulgated. Currently, it is assumed that in 2010 US EPA will again propose amendments to 40 CFR 112 to address milk. Milk can also be regulated as a potential pollutant if spilled, and be subject to spill notification requirements outside of regulation under 40 CFR 112.
Example: Minnesota spill reporting requirements
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
Monday, May 10, 2010
Preproduction Plastic Debris Program In California
Update: Preproduction Plastic controls are added to 2012 draft industrial general permit:
http://swppp.calthacompany.com/2012/07/preproduction-plastics-control-options.html
In 2007, Assembly Bill (AB) 258 was passed, and became effective January 1, 2008, which added Chapter 5.2 to Division 7 of the California Water Code, section 13367. Chapter 5.2 entitled “Preproduction Plastic Debris Program”. This law applies to facilities in California that manufacture, handle, or transport preproduction plastics.
Preproduction plastic is the raw plastic resin materials that are molded into finished plastic products. Preproduction plastics are often produced in a resin pellet format, occasionally termed as “nurdles.” These small, 1- to 5- mm diameter pieces are produced in various shapes, colors, and plastic types. Preproduction plastic resins are also produced in powder, granule, and flake form.
Once in the environment, preproduction plastic resin pellets, powders, and production scrap can be mistaken for food by marine life. They also contribute to California’s litter problem, which state and local agencies spend millions of dollars per year on collecting. Preproduction plastic discharges pose a significant threat to California’s marine environment, which is an important part of California's $46-billion dollar ocean-dependent, tourism economy.
State and Regional Water Board staff have conducted and are continuing to conduct compliance inspections of various types and scales of preproduction plastic manufacturing, handling, and transport facilities enrolled under California's Industrial General Permit (IGP) for storm water discharges. Additionally, the Los Angeles Regional Water Quality Control Board has conducted inspections of facilities suspected to be "non-filers," or facilities subject to the permit, but have not enrolled.
The State Water Board has issued an investigative order to all plastic-related facilities enrolled under the IGP to conduct a Self-Compliance Evaluation and to provide the State Water Board with information needed to satisfy the legislative mandates in AB 258. Facilities subject to this order must complete an online evaluation and assess their points of potential preproduction plastics discharge and means of controlling these 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
In 2007, Assembly Bill (AB) 258 was passed, and became effective January 1, 2008, which added Chapter 5.2 to Division 7 of the California Water Code, section 13367. Chapter 5.2 entitled “Preproduction Plastic Debris Program”. This law applies to facilities in California that manufacture, handle, or transport preproduction plastics.
Preproduction plastic is the raw plastic resin materials that are molded into finished plastic products. Preproduction plastics are often produced in a resin pellet format, occasionally termed as “nurdles.” These small, 1- to 5- mm diameter pieces are produced in various shapes, colors, and plastic types. Preproduction plastic resins are also produced in powder, granule, and flake form.
Once in the environment, preproduction plastic resin pellets, powders, and production scrap can be mistaken for food by marine life. They also contribute to California’s litter problem, which state and local agencies spend millions of dollars per year on collecting. Preproduction plastic discharges pose a significant threat to California’s marine environment, which is an important part of California's $46-billion dollar ocean-dependent, tourism economy.
State and Regional Water Board staff have conducted and are continuing to conduct compliance inspections of various types and scales of preproduction plastic manufacturing, handling, and transport facilities enrolled under California's Industrial General Permit (IGP) for storm water discharges. Additionally, the Los Angeles Regional Water Quality Control Board has conducted inspections of facilities suspected to be "non-filers," or facilities subject to the permit, but have not enrolled.
The State Water Board has issued an investigative order to all plastic-related facilities enrolled under the IGP to conduct a Self-Compliance Evaluation and to provide the State Water Board with information needed to satisfy the legislative mandates in AB 258. Facilities subject to this order must complete an online evaluation and assess their points of potential preproduction plastics discharge and means of controlling these 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
Friday, May 7, 2010
Industrial & Municipally Owned SWPPP Training, Moorhead Minnesota
SWPPP Implementation, Review & Amendment Training
Date: June 3, 2010
Time: 9 am to 11 am
Location: Moorhead, Minnesota
Cost: $125
Attendance is limited to individuals from permitted facilities; class size limited
This training is being provided to individuals who have responsibilities for managing
implementation of the Stormwater Pollution Prevention Plan (SWPPP) for their permitted industrial or municipally-owned facility.
Topics include an overview of permit compliance requirements, documentation,
annual review requirements and keeping SWPPP program up-to-date. Training will also cover corrective action and evaluating benchmark monitoring results. All attendees will receive a training certificate to document successful completion of training.
Why is SWPPP Implementation Training Needed?
Effective April 5, 2010, the Minnesota Pollution Control Agency (MPCA) requires specific training for certain staff at each facility permitted under the new General Permit for Industrial Stormwater Discharges. Each facility must designate an individual responsible for implementation and management of the SWPPP program. These individuals are required under the permit to have specific training on SWPPP implementation, compliance, review and amendments.
To register, email contact information below to info@calthacompany.com
Name:
Company:
Phone:
Email:
Or call (763) 208-6430 to register or for more information
Additional SWPPP Implementation Training Sessions:
Preregister or get further information on SWPPP Implementation, Review & Amendment Training tentatively planned in July-September 2010 in:
Metro (scheduled for May 19) - FULL
Mankato, Minnesota (scheduled for May 27)
Duluth, Minnesota
Rochester, Minnesota
Saint Cloud, Minnesota
For more information or to be placed on pre-registration list for a session, email info@calthacompany.com
Also coming soon…
Stormwater inspection training………….July-October 2010
Stormwater monitoring training………....January-March 2011
Date: June 3, 2010
Time: 9 am to 11 am
Location: Moorhead, Minnesota
Cost: $125
Attendance is limited to individuals from permitted facilities; class size limited
This training is being provided to individuals who have responsibilities for managing
implementation of the Stormwater Pollution Prevention Plan (SWPPP) for their permitted industrial or municipally-owned facility.
Topics include an overview of permit compliance requirements, documentation,
annual review requirements and keeping SWPPP program up-to-date. Training will also cover corrective action and evaluating benchmark monitoring results. All attendees will receive a training certificate to document successful completion of training.
Why is SWPPP Implementation Training Needed?
Effective April 5, 2010, the Minnesota Pollution Control Agency (MPCA) requires specific training for certain staff at each facility permitted under the new General Permit for Industrial Stormwater Discharges. Each facility must designate an individual responsible for implementation and management of the SWPPP program. These individuals are required under the permit to have specific training on SWPPP implementation, compliance, review and amendments.
To register, email contact information below to info@calthacompany.com
Name:
Company:
Phone:
Email:
Or call (763) 208-6430 to register or for more information
Additional SWPPP Implementation Training Sessions:
Preregister or get further information on SWPPP Implementation, Review & Amendment Training tentatively planned in July-September 2010 in:
Metro (scheduled for May 19) - FULL
Mankato, Minnesota (scheduled for May 27)
Duluth, Minnesota
Rochester, Minnesota
Saint Cloud, Minnesota
For more information or to be placed on pre-registration list for a session, email info@calthacompany.com
Also coming soon…
Stormwater inspection training………….July-October 2010
Stormwater monitoring training………....January-March 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.comor
Thursday, May 6, 2010
SWPPP Training - Mankato, Minnesota - May 27
SWPPP Implementation, Review & Amendment Training
Date: May 27, 2010
Time: 9 am to 11 am
Location: Mankato, Minnesota
Cost: $125
Attendance is limited to individuals from permitted facilities; class size limited
This training is being provided to individuals who have responsibilities for managing
implementation of the Stormwater Pollution Prevention Plan (SWPPP) for their permitted industrial facility.
Topics include an overview of permit compliance requirements, documentation,
annual review requirements and keeping SWPPP program up-to-date. Training will also cover corrective action and evaluating benchmark monitoring results. All attendees will receive a training certificate to document successful completion of training.
Why is SWPPP Implementation Training Needed?
Effective April 5, 2010, the Minnesota Pollution Control Agency (MPCA) requires specific training for certain staff at each facility permitted under the new General Permit for Industrial Stormwater Discharges. Each facility must designate an individual responsible for implementation and management of the SWPPP program. These individuals are required under the permit to have specific training on SWPPP implementation, compliance, review and amendments.
To register, email contact information below to info@calthacompany.com
Name:
Company:
Phone:
Email:
Or call (763) 208-6430 to register or for more information
Additional SWPPP Implementation Training Sessions:
Preregister or get further information on SWPPP Implementation, Review & Amendment Training tentatively planned in July-September 2010 in:
Metro (scheduled for May 19) - FULL
Moorhead, Minnesota (scheduled for June 3)
Duluth, Minnesota
Rochester, Minnesota
Saint Cloud, Minnesota
For more information or to be placed on pre-registration list for a session, email info@calthacompany.com
Also coming soon…
Stormwater inspection training………….July-October 2010
Stormwater monitoring training………....January-March 2011
Date: May 27, 2010
Time: 9 am to 11 am
Location: Mankato, Minnesota
Cost: $125
Attendance is limited to individuals from permitted facilities; class size limited
This training is being provided to individuals who have responsibilities for managing
implementation of the Stormwater Pollution Prevention Plan (SWPPP) for their permitted industrial facility.
Topics include an overview of permit compliance requirements, documentation,
annual review requirements and keeping SWPPP program up-to-date. Training will also cover corrective action and evaluating benchmark monitoring results. All attendees will receive a training certificate to document successful completion of training.
Why is SWPPP Implementation Training Needed?
Effective April 5, 2010, the Minnesota Pollution Control Agency (MPCA) requires specific training for certain staff at each facility permitted under the new General Permit for Industrial Stormwater Discharges. Each facility must designate an individual responsible for implementation and management of the SWPPP program. These individuals are required under the permit to have specific training on SWPPP implementation, compliance, review and amendments.
To register, email contact information below to info@calthacompany.com
Name:
Company:
Phone:
Email:
Or call (763) 208-6430 to register or for more information
Additional SWPPP Implementation Training Sessions:
Preregister or get further information on SWPPP Implementation, Review & Amendment Training tentatively planned in July-September 2010 in:
Metro (scheduled for May 19) - FULL
Moorhead, Minnesota (scheduled for June 3)
Duluth, Minnesota
Rochester, Minnesota
Saint Cloud, Minnesota
For more information or to be placed on pre-registration list for a session, email info@calthacompany.com
Also coming soon…
Stormwater inspection training………….July-October 2010
Stormwater monitoring training………....January-March 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
or
Monday, May 3, 2010
Proposed Erosion Sediment Control Rules in PA
The Pennsylvania Department of Environmental Protection (PADEP) is expected to finalize proposed changes to Pennsylvania's regulations governing erosion and sedimentation control measures set forth in 25 Pa. Code Chapter 102. The proposed regulations revise existing requirements pertaining to erosion and sedimentation controls, and add new provisions regulating the management of stormwater discharges during construction activities, defining long term obligations to manage stormwater discharges following the completion of construction activities, and requiring the creation and maintenance of forested riparian buffers.
The Pennsylvania Environmental Quality Board (EQB) published the proposed regulations in the Pennsylvania Bulletin in late August 2009 triggering a 90-day public comment period.
The Pennsylvania Environmental Quality Board (EQB) published the proposed regulations in the Pennsylvania Bulletin in late August 2009 triggering a 90-day public comment period.
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
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