Preparedness, Prevention, and Contingency (PPC) Plan and Industrial Permiting For Pennsylvania Plant

Caltha LLP Project Summary

Project: PPC Plan, Storm Water Permitting and Permit Compliance
Client: National Manufacturer
Location(s): Pennsylvania

Key Elements: Preparedness, Prevention, and Contingency (PPC) Plan preparation, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this manufacturing site at its Pennsylvania location to comply with the Pennsylvania Department of Environmental Protection (DEP) industrial stormwater permit. In contrast to other States, PADEP requires permitted facilities to prepare and implement a Preparedness, Prevention, and Contingency (PPC) Plan in accordance with “Guidelines for the Development and Implementation of Environmental Emergency Response Plans”. A PPC Plan is similar to a stormwater pollution prevention plan (SWPPP) required by most States and US EPA for permitted facilities. However, the PPC Plan includes additional requirements beyond a typical SWPPP.

FAQ: How is a PPC Plan different than a SWPPP? Services included preparing facility PPC plan using Caltha's PPC Plan template, preparation of DEP application forms (Notice of Intent), and preparation of site-specific inspection checklists to comply with Pennsylvania inspection requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facility to address questions during roll-out of the compliance programs.

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 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 Stormwater SWPP and MPCA Permit Compliance Program Development For Transportation Facility

Caltha LLP Project Summary

Project: SWPPP and MPCA Permit Compliance Program For Transportation Facility
Client: Transportation Company
Location(s): Minnesota

Key Elements: MPCA industrial stormwater discharge permit compliance, SWPPP, Facility inspections, Storm water BMP

Overview: The national transportation company selected Caltha to conduct a facility assessment to determine if the operations could meet "No Exposure" requirements under the MPCA general industrial permit. Caltha prepared a list of corrective actions which would be required to comply with MPCA requirements and discussed potential costs with facility managers. Upon consideration of costs, facility management determined that applying for coverage under the Minnesota industrial permit was the preferred alternative. Caltha then prepared the storm water pollution prevention plan (SWPPP) using Caltha's SWPPP template designed to meet permit requirements. Caltha also prepared a permit compliance plan and site-specific inspection checklists to streamline on-going permit compliance tasks that the facility staff would be conducting.

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 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

Technical Consultant Support To Address Stormwater Benchmark Exceedance for TSS, Iron, Zinc, Aluminum

Caltha LLP Project Summary

Project: Consulting Support To Address Stormwater Benchmark Exceedance
Client: Manufacturer
Location(s): Minnesota

Key Elements: Stormwater monitoring; MPCA stormwater permit compliance; Industrial storm water BMPs

Overview: This manufacture retained Caltha to provide technical support and guidance in addressing exceedance of MPCA industrial storm water benchmark concentrations. Monitoring data collected in Permit Cycle Year 2 exceeded limits for total suspended solids (TSS), zinc, iron and aluminum. Caltha staff reviewed past data, monitoring procedures and conducted a site inspection to determine root causes for the exceedance as part of a formal corrective action process. Based on recommendations, the facility began implementation of revised stormwater controls and began preparations for subsequent year 4 monitoring activities.

For more information on Caltha LLP services, go to the Caltha Contact Page

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

Response To Notice Of Violation For Industrial Stormwater Discharges and Non-Storm Water Discharge

Caltha LLP Project Summary

Project: Response To MPCA NOV For Industrial Stormwater Discharges and Non-Storm Water Discharge
Client: Transportation Sector
Location(s): Minnesota

Key Elements: Compliance with No Exposure Certification, Compliance with prohibition of unauthorized non storm water discharge

Overview: In a routine compliance inspection of industrial sites which had submitted no exposure certifications (NEC) being conducted by the State, this facility was found to be in non-compliance with both the conditions of the NEC and was also found to be discharging wash water without a permit. The facility was placed in enforcement action to resolve these issues. Caltha LLP was retained by the facility to assist them in evaluating requirements to meet the NEC and to identify options for addressing unpermitted discharge. Working with facility management, it was determined that costs for necessary corrective actions to comply with the NEC were too high compared to costs to obtain and comply with an industrial stormwater discharge permit. The facility terminated its NEC and applied for permit coverage. Caltha assisted the facility in preparing a facility SWPPP using our Minnesota SWPPP template and a permit compliance plan. Alternate off-site facilities were found to eliminate the discharge of unauthorized wastewater releases from the facility.

For more information on Caltha LLP services, go to the Caltha Contact Page

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

Updated Schedule For New California Industrial General Permit

According to the California State Water Board staff, the State Board anticipates a new 2013 Draft Industrial General Permit (IGP) and supporting documents to be released on or around July 20, 2013. Staff anticipate the State Water Board will provide at least 45 days for written comments to be submitted and during that window the State Water Board will hold a public hearing (tentatively scheduled for August 20, 2013) for oral comments to be provided on the new, draft requirements. Based on this schedule staff anticipate the State Water Board considering the IGP for adoption near the end of the year, 2013 or early 2014. Staff will recommend to the State Water Board an effective date for the new permit requirements to be about one year later, on January 1, 2015.

One on the key proposed changes from the existing permit under which many California facilities are currently covered is the requirement that storm water pollution prevention plans (SWPPP) be prepared by a Qualified SWPPP Developer, or QSD. Facilities will also have to designate a Qualified SWPPP Practitioner, or QSP, at the facility who will be responsible for implementing the SWPPP and overseeing ongoing compliance with the permit. Both QSDs and QSPs would have special training and certification requirements.

Read a Regulatory Briefing on the Draft California Industrial Permit

Caltha LLP provides expert consulting services to public and private sector clients in California 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 Industrial Permit Requirements For Kentucky Storm Water Dichargers

Kentucky Division of Water (DOW) reissued the Kentucky Pollutant Discharge Elimination System (KPDES) General Permit for Stormwater Discharges Associated with Industrial Activity- Other Facilities (KYR000000) on May 1, 2013, with an effective date of June 1, 2013. 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. Facilities seeking new coverage, modification of existing coverage, or renewal of existing coverage are required to submit an updated eN0I-KYROO:

1. Operators seeking initial coverage for an existing facility that has commenced discharge must electronically submit the eN0I-KYROO by June 16, 2013.
2. Operators seeking modification of an existing coverage to address facility modifications must electronically submit an updated eN0I-KYROO a minimum of 15 days prior to the modification of the facility.
3. For existing coverage granted prior to September 30, 2007 the operator must electronically submit an updated eN0I-KYROO by August 29, 2013 to renew the coverage.

If a facility does not submit the updated eN0I-KYROO by the deadline, DOW will terminate of coverage, even if a facility has been permitted in the past. Facilities can seek a conditional exclusion for no exposure by filing an electronic No Exposure Certification (eNoExposure). This certification is time limited and must be resubmitted upon each reissuance of KYR000000 or every 5 years, whichever is first, in order to continue the exclusion for the next permit term.

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. Caltha has revised our Kentucky SWPPP template to meet new permit requirements and is using this SWPPP Template to support our clients located in Kentucky.
 For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Final Arizona Construction General Permit Released

The Arizona Department of Environmental Quality (ADEQ) has finalized the new 2013 Construction General Permit (CGP) which will become effective Monday, June 3, 2013. According to ADEQ, existing operators covered by the 2008 CGP are required to update their SWPPPs and be in compliance with the new permit as of that date, but to not need to reapply for permit coverage. Beginning on that date, operators of new projects requiring coverage must apply under the new permit. ADEQ expects to send an update and reminder approximately two weeks before the implementation date.

Click here for information on how the ADEQ 2013 CGP implements USEPA’s 2009 C&D rule including non-numeric limits.

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

EPA Proposes Revision To Discharge Requirements For Construction and Development Sources

Pursuant to a settlement agreement to resolve litigation, US EPA is proposing changes to the effluent limitations guidelines and standards for the Construction and Development point source category. This proposed rule would withdraw the numeric discharge standards, which are currently stayed, and change several of the non-numeric provisions of the existing rule. Comments on the proposed rule are being accepted through May 31, 2013. The revisions to 40 CFR part 450 now being proposed by EPA consist of the following three elements:

1. Addition of a definition of "infeasible" consistent with the preamble to the 2009 final rule and 2012 CGP;
2. Revisions to the effluent limitations reflecting the best practicable control technology currently available (BPT), effluent limitations reflecting the best available technology economically achievable (BAT), effluent limitations reflecting the best conventional pollutant control technology (BCT), and the new source performance standards reflecting the best available demonstrated control technology (NSPS) found at 40 CFR 450.21, 450,22, 450.23 and 450.24, respectively; and
3. Withdrawing the numeric turbidity effluent limitation and monitoring requirements found at 40 CFR 450.22(a) and 450.22(b) and reserving these subparts.

Click here for further information on the history of rulemaking for this effluent standard.


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

Current Arizona Construction General Permit CGP Extended

The Arizona Department of Environmental Quality has administratively continued the current statewide general permit (2008 CGP) that applies to construction sites which expires on February 28.

In accordance with a provision made in SB1289 during the 2012 Legislative session, which amended the AZPDES statute by adding ARS § 49 – 255.01(M), the CGP 2008 will be continued beyond February 28, 2013. Construction operators may continue to apply for stormwater permit coverage under the 2008 CGP after February 28, 2013, until the Department's approval and issuance of the  AZPDES 2013 Construction General Permit (2013 CGP). Approval and issuance are anticipated to occur before May 1, 2013.

Read Update On Final 2013 CGP

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

Draft MS4 Permit Revised For New Hampshire Municipalities

EPA has released a revised draft New Hapshire small “Municipal Separate Storm Sewer System” (MS4) General Permit for public review and comment. The draft general permit has been published in the Federal Register. Public comments must be submitted by April 15, 2013.

The general permit will apply to 60 municipalities located in an urbanized area as defined by the 2010 census. Regulated MS4s include traditional cities and towns, state and federally owned facilities such as universities and military bases, and the state transportation agency (NHDOT). The draft general permits will apply to all the regulated MS4s, although waivers are possible for eligible municipalities within the urbanized area where population is less than 1,000.

  The revised draft permit updates the previous general permit finalized in 2003. EPA previously released draft general permits for small MS4s in NH in 2008. EPA decided to release revised draft general permits to account for significant public comments received on the 2008 proposal, the availability of updated demographic information from the 2010 Census, and several recently approved TMDLs for various waters in New Hampshire.

Click here for more information on control measures and estimated costs associated with compliance with the draft permit, as written.

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

California Industrial General Permit Reissuance Update

The California Water Board has released an update regarding the status of the State Water Board’s reissuance of the NPDES General Permit for the Discharge of Storm Water associated with Industrial Activities (Industrial General Permit, or IGP). State Water Board staff are currently working to address the comments received on the previous draft of the Industrial General Permit released on July 16, 2012 and expect to release a final draft of the Industrial General Permit by April 2013.  This final draft will be opened for a public comment period of least 45 days. The State Water Board also plans to hold a formal workshop on May 8, 2013, where the board will accept oral comments.

After the close of the public comment period staff expect to review the new comments, revise the permit as necessary, and queue it up the revised General permit for the State Water Board’s consideration during Summer 2013.

Read a summary of the California General Industrial Permit Issued in July 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

New General Stormwater Discharge Permit For Marina Operations In Ohio

The Ohio Environmental Protection Agency (OEPA) has issued an industrial stormwater discharge permit specifically to cover marinas which would otherwise need to apply for coverage under the Ohio multisector general permit (MSGP). Marinas nationwide are subject to industrial stormwater under the Transportation Sector. OEPA under General Permit No. OHRM00002 became effective on January 22, 2013. Marinas that wish to be covered under this permit are required to submit an application (“Notice of Intent, or NOI”) to OEPA.

Compliance requirements under the Marina general permit are similar in many ways to the Ohio MSGP, including:

• Requirement to prepare and implement a stormwater pollution prevention plan (SWPPP) meeting the requirements listed in the permit
• Requirement to eliminate non-stormwater discharges
• Requirement to conduct regular facility inspections
• Requirement to develop and implement an employee training program
• Requirement to conduct regular visual monitoring of stormwater discharges.

Read a summary of the Ohio Multisector General Permit

There are some important differences also:

• Marinas are allowed to discharge wash water from boat cleaning, although cleaning of engines or other oily parts is prohibited; use of detergents or other chemical cleaning agents is prohibited.
• Larger marinas (greater than 200 total slips) must conduct chemical monitoring of stormwater discharges on an annual basis.

Read a summary of Ohio general permit monitoring requirements for marinas

Read about Caltha’s new SWPPP Template and Compliance Plan Template for the Ohio marina general permit


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 Construction Stormwater Effluent Standards

EPA has announced that it will be considering revisions to selected portions of the Effluent Limitations Guidelines and Standards for the Construction and Development Point Source Category. This action will address revisions to the effluent guidelines and standards for the construction and development point source category 40 CFR 450. The C and D rule was issued on December 1, 2009 and became effective on February 1, 2010. EPA plans to revise several of the non-numeric portions of the rule in response to litigation.


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