Guidance and Rules For Salt Storage in Ohio

Ohio EPA has released a guidance document on the elements of salt storage that are relevant to preventing contamination include siting, design, and operation. The document provides guidance on salt storage practices to prevent the contamination of ground water and surface water. “Salt”, as used here, includes solids such as the popular sodium chloride (NaCl), as well as potassium chloride (KCl), calcium chloride (CaCl2), and magnesium chloride (MgCl2). It also includes mixtures of the same substances with abrasives such as sand, cinder, slag, etc.

Summary of Regulatory Requirements Affecting Salt Storage Operations in Ohio


Caltha LLP provides expert consulting services to public and private sector clients in Ohio and 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

Benchmark Monitoring Requirements Under MDE Draft Industrial General Permit

Maryland Department of the Environment (MDE) is issuing a draft General Permit Number 12-SW of stormwater discharges from industrial facilities. MDE has chosen to base the state’s permit on the EPA’s Multi-Sector General Permit (MSGP).

The draft permit will replace the General Permit Number 02-SW that was issued for a five-year term on December 1, 2002. The General Permit 02-SW expired on November 30, 2007 but was administratively continued for facilities that were covered under the permit at the time it expired. The final permit is expected to be issued in early 2013.

Read a summary of the key changes to the Maryland General Permit.

Information about Maryland General Permit SWPPP Template and Compliance Plan

One of the key difference in the draft permit compared to the EPA MSGP is that MDE chose to focus on reducing stormwater volume rather than on benchmark monitoring for specific pollutants. MDE evaluated the full list of benchmark monitoring requirements in the MSGP, and narrowed the selection down to three industries that have the highest potential for metals in their stormwater,

1. Subsector C1 – Agricultural Chemicals for (SIC 2873-2879), part of Sector C - Chemical and Allied Products Manufacturing, and Refining (Nitrate plus Nitrite Nitrogen at 0.68 mg/L, Total Lead at 0.014, Total Iron at 1.0 mg/L, Total Zinc at 0.04 mg/L and Phosphorus at 2.0 mg/L).
2. Sector M – Automobile Salvage Yards (Total Suspended Solids (TSS) at 100 mg/L, Total Aluminum at 0.75 mg/L, Total Iron at 1.0 mg/L, Total Lead at 0.014 mg/L).
3. Sector N – Scrap Recycling and Waste Recycling Facilities (Chemical Oxygen Demand (COD) at 120 mg/L, Total Suspended Solids (TSS) at 100 mg/L, Total Recoverable Aluminum at 0.75 mg/L, Total Recoverable Iron at 1.0 mg/L, Total Recoverable Lead at 0.014 mg/L, Total Zinc at 0.04 mg/L, Total Recoverable Copper at 0.0038 mg/L).
4. Sector AA – Fabricated Metal Products (Nitrate plus Nitrite Nitrogen at 0.68 mg/L, Total Zinc at 0.04 mg/L)

Benchmark monitoring must occur during the first 4 full quarters of permit coverage after the permittee is granted access to NetDMR. If the average of the 4 quarters of monitoring values exceeds the benchmark, the permittee is required to either:
1. perform corrective actions, and conduct an additional 4 quarters of monitoring until the average value is below the benchmark, or
2. determine that no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice to meet applicable effluent limits, and continue to monitor once-per-year.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and 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

Impaired Waters and Antidegradation Requirements In Draft Maryland Industrial Permit

Maryland Department of the Environment (MDE) is issuing a draft General Permit Number 12-SW of stormwater discharges from industrial facilities. MDE has chosen to base the state’s permit on the EPA’s Multi-Sector General Permit (MSGP). The draft permit will replace the General Permit Number 02-SW that was issued for a five-year term on December 1, 2002. The General Permit 02-SW expired on November 30, 2007 but was administratively continued for facilities that were covered under the permit at the time it expired. The final permit is expected to be issued in early 2013.

Read a summary of the key changes to the Maryland General Permit.

Information about Maryland General Permit SWPPP Template and Compliance Plan

The draft permit contains new, specific WQBEL requirements applicable to impaired waters and antidegradation policies:

• Discharges to Impaired Waters – The permit contains requirements for new and existing discharges to impaired waters with or without EPA approved or established TMDLs. New dischargers are only eligible for discharge authorization if they demonstrate that there is either no exposure of stormwater to the pollutant for which the water is impaired, or the impairment pollutant is not present at the facility, or that the discharge is not expected to cause or contribute to a water quality standards exceedance. For existing discharges to impaired waters with State approved or established TMDLs, MDE will determine if more stringent requirements are necessary to ensure that the permittee is discharging consistent with the TMDL and applicable WLA.
• Antidegradation Requirements – MDE has clarified its expectation of operators to meet antidegradation requirements as part of the permit authorization process as well as to comply with permit provisions after authorization to discharge is received. If an NOI indicates that an operator is seeking coverage for a new discharge to a Tier 2 water, MDE will determine if additional requirements are necessary to be consistent with the applicable antidegradation requirements, or if alternatively, an individual permit application is necessary. New dischargers are no longer eligible for coverage under this permit for discharges to waters designated as Tier 3 for antidegradation purposes.

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

Final Rule On Logging Roads As Industrial Discharges

On December 7, 2012, EPA published a final rule clarifying that stormwater permitting is not required for logging roads. The Agency had proposed the rule in September in response to a 2011 citizen suit brought before the Ninth Circuit Court . The suit alleged violations of the Clean Water Act (CWA) against a logging company for discharging stormwater from ditches alongside two logging road in state forests without a permit.

The court decided that because the stormwater runoff from the two roads in question is collected by and then discharged from a system of ditches, culverts, and channels, it was a point source discharge of industrial stormwater for which a National Pollutant Discharge Elimination System (NPDES) permit would be required.

According to EPA, the agency never intended for logging roads to be regulated as industrial facilities. Therefore, the Agency revised 40 CFR 122.26(b)(14) to clarify its intent. The final rule will be effective on January 7, 2013. EPA believes stormwater discharges from forest roads, including logging roads, should be evaluated under section 402(p)(6) of the CWA because the section allows for a broad range of flexible approaches that are better suited to address the complexity of forest road ownership, management, and use. The final rule adds language to existing Phase I stormwater regulations to clarify that, for the purposes of assessing whether stormwater discharges are “associated with industrial activity,” the only facilities that would qualify as “industrial” would be rock crushing, gravel washing, log sorting, and log storage.

Caltha LLP provides technical support services to industrial facilities nationwide to complete individual and general permit application materials and to develop storm water permit compliance plans and stormwater pollution prevention plans (SWPPP). For more information, go to:
Caltha Stormwater Permitting and Compliance Page

Reissued Kentucky General Industrial Permit For "Other Facilities"

Note: Click here to read update on release of Final Kentucky General Stormwater Permit and NOI submittal dates.

On September 13, 2012, the Kentucky Energy and Environment Cabinet, Department of Environmental Protection, Division of Water (DOW) released a draft Kentucky Pollutant Discharge Elimination System (KPDES) General Permit for Stormwater Discharges Associated with Industrial Activity from “Other Facilities”. The previous KYR000000 permit had expired in 2007 and was administratively continued. This draft General KPDES Permit does not address specific categories of facilities, but provides permit coverage for facilities that are not required to obtain an individual KPDES Permit.

Currently, industrial stormwater dischargers in Kentucky are required to apply for an individual KPDES permit, which does not change under the new draft permit. Facilities that are subject to a promulgated national effluent guideline and those facilities that discharge to a receiving water that is subject to a TMDL for suspended solids are not eligible for coverage under the general permit. Some of the key changes from the previous permit include:

1. Specific effluent limits for Total Suspended Solids (TSS), Oil and Grease (O&G), and pH are in place of the previous requirement to monitor and report the results of monitoring for these parameters. Monitoring is no longer required for Chemical Oxygen Demand (COD).
2. The Stormwater Best Management Practices (SWBMP) Plan will now be refered to as a “Stormwater Pollution Prevention Plan (SWPPP).”
3. Inspections with subsequent written reports to document the findings of the inspections would be required on a minimum weekly basis and in response to 2-year, 24-hour storm events that occur.
4. The SWPPP Site Map must include additional features to be shown including directions of stormwater flow, locations of impaired waters and any TMD’s associated with them, and locations of stormwater monitoring points.
5. The SWPPP must include procedures for preventing and responding to spills, and schedules for inspections, preventive maintenance, and employee training required.
6. The SWPPP must contain a daily precipitation log, incident reports in response to spills, employee training records, and control measure maintenance and repair logs.

Caltha LLP maintains a library of SWPPP templates to meet general permit requirements for individual States, including Kentucky. Once the revised permit is issued, Caltha will revise the Kentucky SWPPP template to meet any new requirements and will use this to support our clients located in Kentucky. Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
For further information contact Caltha LLP at info@calthacompany.com  

 

Final North Carolina Industrial General Permit Effective December 1, 2012

North Carolina NPDES General Permit NCG060000 expired on October 31, 2012, which regulates stormwater discharges from a number of industrial sectors including:

• Food and Kindred Products [standard industrial classification (SIC) 20],
• Tobacco Products (SIC 21),
• Soaps, Detergents and Cleaning Preparations; Perfumes, Cosmetics and Other Toilet Preparations (SIC 284),
• Drugs (SIC 283), and
• Public Warehousing and Storage (SIC 4221-4225), 

The North Carolina Division of Water Quality (DWQ) released a draft of the proposed renewal General Permit in September 2012 and the public comment period closed on October 8th.

DWQ received several public comments and EPA Region IV responded that the agency concurred with no comments. Based on the comments received, DWQ revised the draft permit before finalizing. The revisions included:

1. Part II, Section A (Stormwater Pollution Prevention Plan), Added language to include petroleum products and reference how federal oil Spill Prevention, Control, and Countermeasure Plan (SPCC) can fulfill some requirements of the Stormwater Pollution Prevention Plan (SPPP) where it demonstrates compliance.
2. Part II, Table 1 (Analytical Monitoring for Stormwater), Footnote 3: Added clarification that DWQ’s representative outfall status (ROS) approval remains in effect through subsequent renewals as long as relevant site conditions and operations have not changed.
3. Part II, paragraph following Table 1: Language added to specify that “Sampling is not required outside of the facility’s normal operating hours.”
4. Part II, paragraph following Table 2: Language modified to include option for Division to require monthly monitoring because of a failure to monitor semi-annually (rather than automatically requiring monthly monitoring upon failure to monitor). Also, clarification that adverse weather conditions preventing sample collection does not constitute a failure to monitor.
5. Part II, second paragraph following Table 2: Added clarification that DWQ’s release of a permittee from Tier 2 monthly monitoring remains in effect through subsequent renewals unless other conditions are specified.
6. Part II, Table 3: Modified Footnote 1 to allow precipitation pH (if lower than 6 s.u.) as lower benchmark value.

In final permit was issued in late November with the effective date December 1, 2012.

Caltha LLP maintains a library of SWPPP templates to meet general permit requirements for individual States, including North Carolina. Caltha is currently revising the North Carolina SWPPP template for NPDES General Permit NCG060000 to meet any new requirements and will use this to support our clients located in North Carolina that are subject to this general permit.

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

Impaired Waters and Outstanding Arizona Waters Requirements Under Proposed ADEQ Permit

The Arizona Department of Environmental Quality (ADEQ) has released a draft Construction General Permit (AZG2008-001). This permit replaces the previous construction general permit that was issued for a five-year term by ADEQ. As written, this general permit becomes effective on March 1, 2013.

The draft permit coverage has the following conditions and requirements apply if any portion of the construction site is located within 1/4 mile of a receiving water listed as impaired under section 303(d) of the Clean Water Act:

• The operator must submit a copy of the SWPPP with the NOI to ADEQ; and
• The SWPPP must include a sampling and analysis plan for analytical monitoring if there is potential for discharges from the site to include the pollutant(s) for which the receiving water is impaired. If the operator can demonstrate there is no reasonable expectation that construction activities could be an additional source of the identified pollutant(s), analytical monitoring is not required. As part of this demonstration, the operator must consider all on-site activities, including the potential for the pollutants (metals, nutrients, etc.) to be present in site soils. The demonstration must be included in the SWPPP submitted for ADEQ’s review;
• If a discharge contains pollutants for which a Total Maximum Daily Load (TMDL) has been established, the SWPPP must specifically identify control measures necessary to ensure the discharges will be consistent with the provisions of the TMDL.

For discharges to outstanding Arizona waters (OAW) the following conditions and requirements apply if any portion of the construction site is located within 1/4 mile of a receiving water listed as an OAW in A.A.C. R18-11-112(G):

• The operator must submit a copy of the SWPPP with the NOI to ADEQ; and
• The SWPPP must include a sampling and analysis plan for analytical monitoring of pollutants expected to discharge from the site, including sediment.

Caltha LLP provides expert consulting services to public and private sector clients in Arizona and 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

New or Expanded Stormwater Discharges Under Proposed MPCA Nondegradation Policy

The Minnesota Pollution Control Agency (MPCA) has been attempting to revise the Minnesota Nondegradation Policy for several years. One major issue has been how rule will apply to stormwater discharges, because the existing policy was developed to apply to traditional point source discharges.

In September 2012, MPCA released its proposed revision to the State Nondegradation Policy. Under the proposed rule, MPCA will address future nondegradation requirements for stormwater discharges as new permits are issued. For new, reissued, or modified stormwater permits, agency will conduct nondegradation review. This review will include an analysis of prudent and feasible alternatives that avoid and minimize net increases in loading or other causes of degradation. The agency will then select the least degrading prudent and feasible alternatives identified. Therefore, with the final revision of the Nondegradation Policy, as currently proposed, the requirements for new or expanded stormwater discharges will not be clarified. These requirements will be incorporated into various permits (e.g, industrial, construction, MS4) issued in the future.

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

Maryland Department of the Environment Proposed General Permit for Storm Water Discharges from Industrial Activities

The Maryland Department of the Environment is proposing to reissue the General Permit for Storm Water Discharges from Industrial Activities, General Permit No. 12-SW. The Department will hold public hearings to receive oral testimony concerning the proposed permit on November 26 and 30, 2012 Written comments concerning the draft permit will also be accepted on or before January 4, 2013.

Read a summary of the key changes to the Maryland General Permit.

Information about Maryland General Permit SWPPP Template and Compliance Plan


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

NYDEC Releases New Industrial Permit - NOI Deadline Dec 31, 2012

The New York State Department of Environmental Conservation (NYSDEC) has prepared the new SPDES Multi Sector General Permit for Stormwater Discharges from Industrial Activity (GP-0-12-001). The new permit is effective on October 1, 2012 and will replace the current Multi Sector General Permit for Stormwater Discharges Associated with Industrial Activity (GP-0-11-009) which expired on September 30, 2012.

Permitted facilities must prepare a stormwater pollution prevention plan (SWPPP), notify DEC that they intend to be covered by the MSGP, and comply with the general and sector-specific requirements of the permit. Major changes to the MSGP include new technology-based effluent limits, additional requirements for discharges to impaired waters, changes to the best management practices options for certain sectors, and lower benchmark monitoring cutoff concentrations. DEC also reformatted the permit and various required forms and made numerous other changes. Facilities subject to the prior MSGP must revise their SWPPPs to conform to the new permit and submit a new Notice of Intent form requesting coverage under the permit by December 31, 2012.

To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on the revised New York permit requirements, including New York specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a New York Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the DEC general permit.

For more information on the new New York industrial SWPPP template, compliance plan and expert SWPPP consulting services, email Caltha at info@calthacompany.com

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

Washington DC Proposes Rulemaking For Stormwater Fee Discount Program

The Washington District Department of the Environment (DDOE) has released its revised rules and has requested public comments on its Proposed Rulemaking for a Stormwater Fee Discount Program, published in the October 5, 2012 issue of the DC Register. The provisions in this rule will allow District water and sewer ratepayers to receive a discount of up to 55% of the stormwater fee that appears on their DC Water bill, by installing measures that retain or prevent stormwater runoff.

This is the second revision that DDOE has proposed to rules to establish a Stormwater Fee Discount Program. DDOE’s first proposal was published in the DC Register on July 29, 2011, and was made available for a 30-day public comment period. DDOE received comments from a wide array of stakeholders and individuals, and has revised the Proposed Rules to incorporate a number of the comments and suggestions provided. The public comment period on the Proposed Rules is open through November 4, 2012.

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 Phase I Stormwater Regulations

US EPA has announced that it intends to propose revisions to its Phase I stormwater regulations (40 CFR 122.26) to specify that stormwater discharges from logging roads are not included in the definition of "storm water discharge associated with industrial activity." EPA is taking this action in response to the 9th Circuit Court of Appeals decision in Northwest Environmental Defense Center (NEDC) v. Brown, which addressed the question of whether discharges from certain logging roads require National Pollutant Discharge Elimination System (NPDES) permits.

The Agency intends to clarify that a permit is not required for 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

Industrial Storm Water Training Seminar - Eagan, MN Nov. 30, 2012

Complying with Minnesota Industrial Stormwater Requirements
Eagan, MN
Friday, November 30, 2012

This full day training seminar will cover the requirements of the Minnesota Pollution Control Agency (MPCA) Multi-Sector General Permit (MSGP) for industrial storm water discharges. The course will begin with a discussion of the regulation of stormwater discharge under the Federal Clean Water Act, and then the specific requirements under the MPCA industrial permit, issued in 2010. This will include sector specific requirements, use of benchmark monitoring, effluent guideline monitoring and corrective action requirements. The morning session will include a discussion of additional requirements for stormwater discharges to impaired waters and other special waters identified in the MSGP.

The afternoon session will focus on implementing best managemt practices and development of a stormwater pollution prevention plan (SWPPP) at individual facilities. This will include a discussion of monitoring and reported requirements to comply with the Minnesota MSGP.

For more information or to register, go to:
Training Seminar - Complying with Minnesota Industrial Stormwater Requirements, November 30, 2012

Agenda

Industrial Stormwater Laws and Regulations

• Federal Clean Water Act overview
• Application of Clean Water Act to stormwater discharges

Minnesota industrial stormwater permitting process

• Overview of permit requirements
• Industrial sector-specific requirements
• Benchmark monitoring/effluent monitoring
• Corrective action triggers

Application of Rules/Permit to Individual Facilities

• Impaired waters/TMDLs
• Nondegradation/antidegradation requirements
• Special waters
• Wetlands
• Industrial sites with potential soil/groundwater contaminants
• Local and regional requirements

Creating Stormwater Pollution Prevention Plan (SWPPP)

• Complying with stormwater control measure requirements
• Describing facility
• Providing assessment of activities and materials
• Modification and reporting requirements
• Availability requirements
• Construction site runoff control

Implementing Best Management Practices (BMPs)

• BMPs to achieve “no exposure”
• Stormwater reduction
• Reuse of stormwater
• Stormwater control/management
• Structural BMPs for treating stormwater
• Contingency planning for extreme weather

Sampling and Annual Reporting

• Setting up monitoring procedures
• Collecting and evaluating samples
• Submitting annual reports
• Modifying BMPs

Comment Period For California Industrial General Permit Extended

The California State Water Board has extended the deadline for written comments on the 2012 Draft IGP an additional 30 days. Thus, comments on the 2012 Draft NPDES Industrial General Permit may be submitted on or before 12:00 p.m. (Noon) on October 22, 2012.

The State Water Board still plans to conduct a public hearing to accept oral comments on October 17, 2012. A quorum of State Water Board members may be present at the public hearing; however, no board action will be taken. The time and location of the public hearing is:
Wednesday, 9:00 a.m. October 17, 2012
Joe Serna, Jr. Cal/EPA Building Coastal Hearing Room
1001 I Street, Second Floor
Sacramento, CA 95814

For a summary of the current draft permit, Click Here


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

Washington Reissues Phase 1 and Phase 2 MS4 Permits

On August 1, 2012, the Washington State Department of Ecology (Ecology) reissued three general National Pollutant Discharge Elimination System (NPDES) municipal stormwater permits:

• Phase I Municipal Stormwater General Permit (Phase I permit 2012 to 2013)
• Western Washington Phase II Municipal Stormwater Permit (WWA Phase II permit 2012 to 2013)
• Eastern Washington Phase II Municipal Stormwater Permit (EWA Phase II permit 2012 to 2014)

In accordance with 2012 legislation, Ecology reissued both Phase II permits without modification for a period of one (Western WA) and two (Eastern WA) years. Ecology also reissued the Phase I permit for a period of one year with limited changes.
In addition, Ecology reissued updated permits for the permit terms below:

• Phase I permit (2013 to 2018)
• Western Washington Phase II permit (2013 to 2018)
• Eastern Washington Phase II permit (2014 to 2019)

The National Pollutant Discharge Elimination System (NPDES) and State Waste Discharge General Permits cover discharges from municipal separate storm sewer systems (MS4s). The Phase I Municipal Stormwater Permit regulates the discharges from MS4s owned or operated by Clark, King, Pierce and Snohomish Counties; and the cities of Seattle and Tacoma (incorporated cities with a population over 100,000 and unincorporated counties with populations of more than 250,000 according to the 1990 census). The permit also applies to MS4s owned by public entities located in a Phase I city or county; including the Ports of Seattle and Tacoma.


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

Preproduction Plastics Control Options Under California 2012 IGP

The revised California draft Industrial General Permit (IGP) includes controls required for pre-production plastic. Preproduction plastics used by the plastic manufacturing industry are small in size and have the potential to mobilize in storm water. Water Code section 13367 requires the State Water Board to implement measures that control discharges of preproduction plastic. Water Code section 13367 outlines five mandatory BMPs that are required for all facilities that handle preproduction plastic. These mandatory BMPs are included in the 2012 draft IGP.

The State Water Board had received comments regarding the Water Code requirements that plastic facilities to install a containment system for on-site storm drain locations that meet 1mm capture and 1-year 1-hour storm flow requirement standards. As a result, the 2012 IGP includes the option under Water Code section 13367 that allows a plastics facility to propose an alternative BMP or suite of BMPs that can meet the same performance and flow requirements as a 1mm capture and 1-year 1-hour storm flow containment system standards. These alternative BMPs are to be submitted to the Regional Water Board for approval. This alternative is intended to allow the facility to develop BMPs that focus on pollution prevention measures that can perform as well as, or better than, the containment system otherwise required by the statute.

The State Water Board also included two additional containment system alternatives that are considered to be equivalent to, or better than, the 1mm capture and 1-year 1-hour storm flow requirements:

•  An alternative allowing plastic facilities to implement a suite of eight BMPs addressing the majority of potential sources of plastic discharges.
• An alternative allowing a facility to operate in a manner such that all preproduction plastic materials are used indoors and pose no potential threat for discharge off-site.

The facility is required to notify the Regional Water Board of the intent to seek this exemption and of any changes to the facility or operations that may disqualify the facility for the exemption. The exemption may be revoked by the Regional Water Board at any time.

Plastic facilities may use preproduction plastic materials that are less than 1mm in size, or produce materials, byproducts, or waste that is smaller than 1mm in size. These materials will bypass the 1mm capture containment system required by Water Code section 13367. Plastic facilities with sub-1mm materials must design a containment system to capture the smallest size material onsite with a 1-year 1-hour storm flow requirement, or propose alternative BMPs for Regional Water Board approval that meet these same requirements.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and 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

Cost Analysis For Compliance With Revised Industrial Permit

The California State Water Resources Control Board (State Water Board) has released its cost analysis comparing estimated costs associated with the current Industrial General Permit (ICP), the draft revised permit issued in 2011, and the draft revised permit issued in July 2012. The purpose of the analysis is to provide an estimate of the compliance costs associated with the State Water Board’s Statewide General Permit for Discharges of Storm Water Associated with Industrial Activity (IGP).

Read a summary of the 2012 California IGP: http://www.calthacompany.com/Draft_California_Industrial_Stormwater_Permit_Summary.pdf

The key finding of the report are that the average annual cost of compliance of the 2012 permit for facilities with no exceedances would increase between 5% and 12% compared to the annual cost of compliance with the 1997 IGP. Annual average cost of compliance with the new permit depends on multiple factors including size of operations, location, and level of exceedances. Staff estimated annual compliance costs for the 1997 IGP to range between $23,000 to approximately $137,000. For facilities with no exceedances, compliance with the 2012 draft will cost between $25,000 and approximately $155,000 annually.

The increase in compliance costs would be more significant for those facilities with exceedances. Staff does not expect a significant increase in compliance costs for those facilities with no exceedances. Facilities with exceedances would see a more significant increase in costs to bring the facility in compliance. Facilities with Level 1 status (one NAL exceedance) would face an additional annual average cost between $97 and $622. Facilities with Level 2 status (second NAL exceedance for same parameter) would face an additional annual average cost between $1,138 and up to $38,641.

The annual average cost of compliance with the 2012 draft is approximately half (50% less) of what the 2011 draft originally required. Based on Water Board staff’s best judgment, the most likely scenario is that 50% of facilities will have no exceedances, 50% of facilities will reach Level 1, and 25% will reach Level 2. Using this assumption, the total annual average compliance costs of the 2012 draft as compared to the 1997 IGP would be increased by approximately 7% for industry as a whole.

The most commented upon elements of the draft 2011 IGP were the proposed numeric effluent limitations (NELs), the increased number of reportable inspections and/or visual observations, and the compulsory training requirements. In response to these comments, NELs have been eliminated, revisions and clarification were made so that the number of inspections and visual observations are the same as the 1997 IGP (with the exception of pre-storm visual observations), and the compulsory training requirement has been simplified. Additionally, a new ERA system has been proposed that (1) more narrowly focuses on those facilities with the highest concentrations of pollutants, and (2) allows dischargers to avoid costly structural or treatment controls if it is proven that the pollutant concentrations are related to non-industrial sources, natural background conditions, or if the facility is already in compliance with BAT/BCT.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and 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

No Exposure Certification Under Proposed California General Permit

Phase II of the Federal stormwater rules changed the requirement for “no exposure certification” or NEC which existed in 1997, then the current California general permit was finalized. EPA extended the option to certify no exposure to any industrial sector. The draft IGP applies US EPA’s Phase II rules regarding a conditional exclusion for facilities where there is no exposure of industrial activities and materials to storm water. The previous California permit mandated that light industries obtain coverage only if their activities were exposed to storm water. This General Permit meets US EPA rules allowing any type of industry to claim the conditional exclusion.

In the draft IGP, the NEC requires enrollment for coverage but conditionally excludes dischargers from a majority of the permit requirements. Some minor modifications were added to clarify the types of “storm resistant shelters” and the periods when “temporary shelters” may be used to meet the NEC requirements. Under the draft ICP, dischargers meeting all the NEC would need to recertify each year.

Facilities that self-certified no exposure under the previous permit (category 11) are required to designate a Legally Responsible Person (LRP) to certify and submit via SMARTS for NOI or NEC coverage under this General Permit. NEC will need to be recertified through SMARTS on an annual basis.

Click here for a summary of the Draft California Industrial Storm Water Permit

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and 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

Proposed California Industrial Storm Water General Permit Released

In July 16, 2012, the California State Water Resources Control Board (State Water Board) published its third draft of its proposed “General Permit For Storm Water Discharges Associated With Industrial Activities, NPDES No. CAS000001” or “IGP”. This permit covers stormwater discharges from certain types of industrial and “industrial-like” operations that are required to have a stormwater discharge NPDES permit.

NPDES permits, including general permits, are typically reissued on a 5- year cycle. However, the current IGP has been in effect since 1997.

The proposed permit includes numerous significant changes to the compliance requirements in California. These changes are in response to new Federal requirements for industrial stormwater discharges (most notably the 2008 EPA Multisector General Permit, or MSGP), changes recommended by State Water Board staff, recommendations from a “blue ribbon panel of experts” convened in 2005-2006, and several court actions.

Read a Regulatory Briefing on the Draft California Industrial Permit

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Storm Water Plan Certification - What is Certified? Who Must Sign?

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

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

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

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


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

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

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


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

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Integrated Municipal Stormwater and Wastewater Planning Approach Framework

The U.S. Environmental Protection Agency (EPA) issued a new framework to help local governments meet their Clean Water Act obligations. The Integrated Municipal Stormwater and Wastewater Planning Approach Framework assists EPA regional offices, states, and local governments to develop voluntary storm and wastewater management plans and implement effective integrated approaches to reduce overflows from wastewater systems and pollution from stormwater.

EPA's framework outlines new flexibility to pursue innovative, cost-saving solutions, like green infrastructure to help communities as they develop storm and wastewater infrastructure plans. The framework also highlights the importance of controlling and managing releases of storm and wastewater into the waters of the US.

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.

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Final Washington Industrial Permit Effective July 1, 2012

The Washington Department of Ecology (Ecology) has issued a final modified Industrial Stormwater NPDES and State Waste Discharge General Permit May 16, 2012. The modified permit is effective July 1, 2012. The permit modification is necessary to address the April 25, 2011 order by the Washington State Pollution Control Hearings Board, which required significant changes to the sampling and corrective action requirements. Ecology has also made revisions to the effluent limits for fecal coliform that apply to approximately 80 facilities discharging to 303(d)-listed impaired waterbodies. Other minor changes were made in response to public comments and to correct various errors and typos.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
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Revised New York General Industrial Storm Water Permit

The New York State Department of Environmental Conservation (NYSDEC) has proposed to issue SPDES Multi Sector General Permit for Stormwater Discharges from Industrial Activity (GP-0-12-001). The current Multi Sector General Permit for Stormwater Discharges Associated with Industrial Activity (GP-0-06-002) will expire on March 27, 2012. An interim permit (GP-0-11-009) will take effect on March 28, 2012 and will expire on September 30, 2012. Once finalized, this draft permit will replace the interim permit.

There are several major changes in this permit compared to the previous permit. The following summarizes some of the changes contained within the proposed Multi Sector General Permit for Stormwater Discharges Associated with Industrial Activity (GP-0-12-001)

• SWPPP Development/BMP considerations. The permit includes in various places, updated lists of BMP options that, along with any functional equivalents, shall be considered for implementation. At a minimum, the owner or operator must evaluate the applicability of the BMPs. If the owner or operator concludes that any of the BMPs are not appropriate for the facility, a written explanation of why they are not appropriate must be included in the Stormwater Pollution Prevent Plan required by the permit.
• Benchmark Monitoring & Numeric Effluent Limits – The draft permit proposes additional monitoring if Benchmarks or Numeric Limits are exceeded. The intent of this additional sampling is to document that the corrective actions taken in response to the exceedance were effective in reducing the pollutant discharge levels. The increased sampling puts the responsibility on the owner/operator to demonstrate that their actions were effective.
• Mercury. The Benchmark Monitoring Requirements for Mercury have been revised and USEPA Method 1631 has been specified for analyses of stormwater discharges associated with Sectors G, K and N. This is consistent with DEC Program Policy – DOW – 1.3.10 – Mercury – SPDES Permitting, Multiple Discharge Variance and Water Quality Monitoring. This policy states that the MSGP procedures require updating to improve water quality protection.
• Benchmark Monitoring Cutoff Concentrations. Lower benchmarks were incorporated in the Sector Specific requirements to reflect benchmarks in EPA’s 2008 MSGP.
• Stand Alone SWPPP for Construction Activities at Mines and Landfills. Construction of new mines, access roads and other impervious surfaces and construction of new landfills or expansion cells that have the potential to discharge to surface waters can be covered by the MSGP permit provided that a Stand Alone Construction SWPPP is developed that meets the requirements in Part IX which specifies construction, erosion and sediment control and post construction control, and inspection requirements. Only activities that comply with the technical standards, defined as the New York State Stormwater Management Design Manual, August 2010 and New York State Standards & Specifications for Erosion & Sediment Control, 2005 can be authorized by the MSGP. Any project that proposes to deviate must obtain coverage under the SPDES General Permit for Stormwater from Construction Activities or other SPDES permit.
• Reference to “permittee” was changed to “owner/operator” throughout the permit. This change is intended to reflect the fact that the owner obtains coverage under an issued permit rather than having a permit issued to them individually. Definition of owner or operator from 6NYCRR Part 750-1.2 has been added to the definitions.
• Forms. Many forms that were part of the permit are now being referenced in this draft permit. This change provides the Department greater flexibility in making changes to those forms without permit modification and the workload associated with the public notice process

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Revised Small MS4 General Permit Released By MPCA

The Minnesota Pollution Control Agency (MPCA) intends to issue the National Pollutant Discharge Elimination System (NPDES) State Disposal System (SDS) General Permit (MNR040000) for discharges of stormwater associated with small Municipal Separate Storm Sewer Systems (MS4s). MPCA will host a public information meeting to discuss the draft MS4 General Permit on June 21, 2012, at the MPCA St. Paul office. MPCA also intends to establish an e-mail list for the purpose of providing notification to persons interested in receiving notice of the public notice dates for the Stormwater Pollution Prevention Program (SWPPP) documents submitted pursuant to the MS4 General Permit. The draft permit is open for public comment from May 21 - July 23, 2012. The MPCA is requesting written comments on the draft permit.
This MS4 General Permit was issued first in 2006 to address new federal Phase II National Pollutant Discharge Elimination System (NPDES) stormwater regulations for small MS4s. These federal rules identified an iterative process for improved stormwater management where MS4 programs are strengthened with each five year permit cycle. This current permit reissuance effort shifts from the initial focus on permit program development to measuring program implementation. The next MS4 General Permit reissuance in 2017 will need to comply with the new federal NPDES stormwater rules expected to be final in December 2012.

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Reissued Kansas KDHE Construction Discharge Permit

The Kansas Department of Health & Environment (KDHE) reissued the Kansas General Permit for Stormwater Runoff Associated with Construction Activities on March 2, 2012 with various modifications. The new permit expires March 1, 2017 and replaces the current general permit for stormwater discharges from construction activities which remained in effect through March 1, 2012. Projects authorized prior to March 2, 2012 may operate under the previous general permit for 18 months, ending September 1, 2013. If these projects are not terminated by September 1, 2013, they must meet the requirements of the new general permit. Coverage continues from the date of authorization until the site is stabilized and the construction stormwater discharge Notice of Termination (NOT) is accepted by KDHE or the permit is revoked/terminated for cause by KDHE.

Owners or operators of any project or combination of projects who engage in construction activities which will disturb one (1) or more acres must have authorization to discharge stormwater under the Stormwater Runoff from Construction Activities General Permit S-MCST-0312-1. Construction activities consist of any activity (e.g. clearing, grubbing, excavating, and grading) which disturb a cumulative total of one or more acres or when the site is a part of a larger common plan of development or sale which will disturb a cumulative total of one or more acres.

Owners or operators of construction activities which disturb less than one acre and which are not part of larger common plan of development or sale, must have authorization to discharge stormwater runoff from construction activities under this NPDES general permit when KDHE notifies the owner or operator that the water quality impact from discharge of stormwater runoff from construction activity warrants consideration because the proposed construction activities constitute a significant pollution potential.

Major modifications in the reissued permit include:

• the addition of EPA’s Construction and Development effluent guideline standard (40 CFR 450),
• procedures for construction activities undertaken to avoid imminent endangerment to the public health or environment in response to a public emergency,
• additional best management practices for steep slopes,
• revision to the Sediment Basin Design Criteria to allow easier alternative basin detention size calculation for areas where large off-site areas drain to the basin or for areas of Western Kansas where the 2-year, 30-minute rain event is less than 1.3 inches, and
• various wording changes to clarify permit requirements.

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

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Draft Small MS4 General Permits For New Hampshire and Massachusetts

EPA has issued three separate draft Small MS4 General Permits for the operators located in the state of New Hampshire and various watersheds in Massachusetts. The most recent schedules for each of the 2012 Permits for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems (MS4s) in New Hampshire and Massachusetts are:

• State of New Hampshire: EPA has revised its 2008 Draft New Hampshire Small MS4 Permit and will issue it as a new draft permit for public comment in the spring of 2012. Issuance of a final permit anticipated for spring 2012 will therefore be delayed until late 2012 or early 2013 to allow for the public to comment on the draft permit and for EPA to respond to those comments. A Notice of Availability for the new draft New Hampshire Small MS4 general permit will be published in the Federal Register as well as information about any scheduled public meetings or hearings.
• North Coastal Watershed: The 2010 Draft Massachusetts North Coastal Small MS4 General Permit is available on EPA's "Draft Massachusetts North Coastal Small MS4 General Permit" webpage. The Draft Massachusetts North Coastal Small MS4 General Permit was published in the Federal Register and was available for public comment on February 4, 2010. EPA held a public hearing for the draft permit on March 18, 2010 and the public comment period ended March 31, 2010. EPA anticipates a Final Massachusetts North Coastal Small MS4 General Permit in the summer of 2012.
• Interstate, Merrimack and South Coastal Watersheds (IMS): The 2010 Draft Massachusetts Interstate, Merrimack and South Coastal Watersheds Small MS4 General Permit is available on EPA's "Draft Massachusetts Interstate, Merrimack and South Coastal Small MS4 General Permit" webpage and is accessible through EPA 1's NPDES Storm Water Permit Program webpage. The Draft Massachusetts Interstate, Merrimack and South Coastal Watersheds Small MS4 General Permit was published in the Federal Register and was available for public comment on February 15, 2011. EPA held a public meeting for the draft permit on March 9, 2011 and the public comment period ended March 11, 2011. EPA anticipates a Final IMS Small MS4 General Permit in the fall of 2012.
• Massachusetts Department of Transportation (MassDOT): EPA anticipates issuing a separate individual small MS4 Permit for MassDOT with a draft available in the summer of 2012.

The effective date of each final general permit will be no sooner than the date the final permit is signed and made publicly available. To obtain coverage, operators will be required to submit a new Notice of Intent (NOI) for the permit for which they are eligible. EPA anticipates that NOIs will be due 90 days after the effective date of each final permit.

The new draft Small MS4 General Permits released to date include the same six minimum control measures as the 2003 MS4 General Permit in addition to provisions to protect water quality standards. To improve the effectiveness of stormwater management programs and reduce the adverse effects of stormwater runoff on receiving waters, these draft permits include:

1. enhanced illicit discharge detection and elimination (IDDE) requirements to identify, isolate and remove sanitary and other wastes from the stormwater system;
2. water quality monitoring of stormwater discharges;
3. encouragement of low impact development and green infrastructure techniques; and
4. requirements designed to implement approved total maximum daily load (TMDL) waste load allocations (WLAs).

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Reissue of Washington MS4 Stormwater Permits

In June 2012, the Washington State Department of Ecology (Ecology) is preparing to reissue three general National Pollutant Discharge Elimination System (NPDES) municipal (also known as MS4) stormwater permits:

• Phase I Municipal Stormwater General Permit (Phase I permit).
• Phase II Western Washington Municipal Stormwater General Permit (Phase II WWA permit)
• Phase II Eastern Washington Municipal Stormwater General Permit (Phase II EWA permit).

For the past three years, Washington State Department of Ecology (Ecology) has been working with interested parties and advisory groups in Western Washington to develop permit requirements. Ecology developed and managed advisory groups for input on monitoring and low impact development requirements. During 2011, Ecology held meetings with permittees and interested parties in Eastern Washington to discuss changes to the Eastern Washington permit requirements.

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Changes To Requirements For Logging Roads Proposed

In a May 23 Notice of Intent (NOI), EPA published its intend to propose revisions to stormwater regulations for logging roads. Under the proposal, storm water discharges from logging roads are not discharges "associated with industrial activity," meaning a National Pollutant Discharge Elimination System (NPDES) permit is not required for such discharges. EPA issued the NOI is in response to a ruling by the Ninth Circuit Court of Appeals, which found that certain logging roads are stormwater point sources “associated with industrial activity.”

EPA is also seeking comments on water quality impacts associated with discharges of stormwater from forest roads. EPA says that where best management practices are used, waters that receive runoff from forest roads can be protected. However, if not properly managed, stormwater discharges from some forest roads can cause preventable impairments to water quality. EPA plans to study the water quality impacts of forest roads along with existing federal, state, tribal, and voluntary programs designed to address them to determine if additional action is necessary.

EPA believes that stormwater discharges from forest roads should be evaluated under section 402(p)(6) of the Clean Water Act because the section allows for a broad range of flexible approaches that are well-suited to address the complexity of forest road ownership, management, and use. The section allows EPA to consider a range of regulatory and nonregulatory approaches and determine which forest road discharges (if any) should be regulated under the CWA.

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Stormwater Best Management Practices For Marinas

U.S. Environmental Protection Agency Region 2 is recommending that New York State marinas take steps to prevent the pollution of local waterways, including best environmental practices for reducing pollution from boat washing and other maintenance activities that can degrade water quality. These practices are included in a manual created by the EPA with assistance from the New York State Department of Environmental Conservation. It has been provided to over 500 marina operators throughout New York State and provides recommendations on ways marina owners and operators can reduce pollution through more efficient use of materials, energy and land. 
According to EPA and DEC, cleaning products and toxic chemicals used in boat maintenance can pollute waterways when they are washed into the water when it rains. The effect of runoff from a single boat or marina on a water body may seem insignificant, but when multiplied, it can degrade water quality. Because marinas are located at the water’s edge, the water is affected by maintenance practices and pollution that flows into the water from surrounding areas.

Key recommendations for preventing water pollution from boat operations and maintenance:

• Regularly inspect above-ground fuel storage tanks and associated piping for leaks, and ensure that these tanks have secondary containment areas to contain spills.
• Store spill containment and control materials in a clearly marked and easily accessible location attached or adjacent to the fuel dock. Keep oil absorbent pads and pillows available at the fuel dock for staff and customers to mop up drips and small spills.
• Avoid underwater boat bottom cleaning or hull scraping to remove antifouling paint from boat hulls.
• Make every attempt to collect wash water, treat it and either dispose of it at a sewage treatment plant or recycle it.
• Perform as much boat repair and maintenance as practicable inside work buildings. Where an inside workspace is not available, perform abrasive blasting and sanding within spray booths or tarp enclosures.
• Use cleaning products that are less toxic and contain lower concentrations of volatile organic compounds, ozone depleting chemicals and toxic materials. Always clean with water and a coarse cloth first.
• Permanently seal floor drains in maintenance areas with concrete if they do not connect to a sewer or holding tank. Sweep or vacuum floors often and immediately before floor washing.
• Use propylene glycol antifreeze (usually pink), which is less toxic than ethylene glycol (usually green) to winterize all systems except “closed” or freshwater cooling systems.
• Minimize impervious areas on the marina site by paving only where absolutely necessary. Plant a vegetated filter strip or buffer between impervious areas and the marina basin.

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