SWPPP Plan, SPCC Plan, RCRA Plan In Pensacola, Tallahassee Area

Caltha LLP provides expert stormwater compliance services to clients on northwest Florida and south Alabama, including areas surrounding:

• Pensacola, Florida
• Tallahassee, Florida
• Mobile Alabama

Caltha prepares stormwater pollution prevention plans (SWPPP), spill prevention plans, SPCC plans, RCRA contingency plan an other related plans. Caltha also provides a full range of environmental and safety training services.
To request a quote for a SWPPP, SPCC or other plan, click here and complete the EH&S Plan Quote Request Form.

California Revision To Current IGP Proposed To Address TMDL and Monitoring

The California State Water Board has proposed amends to the Industrial General Permit (IGP) current in effect. Comments on the proposed amendments are due by January 31, 2018. The State Water Board is proposing the Amendment to the Statewide Storm Water Industrial General Permit (General Permit) to address the following items:

• Implement TMDLs included in General Permit,
• Update the monitoring requirements and
• Add statewide compliance options to incentivize storm water capture and regional collaboration.

The current IGP includes a reopener to incorporate Total Maximum Daily Load (TMDL) requirements through a future permit amendment (Section XX.A). The proposed General Permit Amendment incorporates requirements for implementing existing TMDLs adopted by the San Francisco Bay, Santa Ana, Los Angeles, and San Diego Regional Water Quality Control Boards identifying industrial storm water as a source of the receiving water Impairment.


The proposed General Permit Amendment includes statewide compliance options to allow compliance with water quality objectives through onsite and regional storm water capture best management practices in place of typical compliance with numeric action levels and numeric effluent limitations.


In 2014, US EPA finalized the new Use of Sufficiently Sensitive Test Methods for Permit Applications and Reporting Rule for discharges regulated by NPDES permits. The new Rule became effective on September 18, 2014. The EPA Rule requires NPDES permitees to use “sufficiently sensitive” analytical test methods for the analyses of regulated pollutants or pollutants parameters. The proposed General Permit Amendment includes revised monitoring and reporting requirements for industrial storm water sampling consistent with the new Rule.


Click here to review other regulatory updates for California.

IA Stormwater Permit And Compliance Consultant- SWPPP Engineer

Caltha LLP maintains a library of SWPPP Templates developed to meet the requirements of individual States, including Iowa. Separate stormwater plan templates are provided to Industrial, Municipal (MS4) and Construction stormwater dischargers. Our Iowa SWPPP templates are updated to meet new State permit requirements as new or revised permits are finalized.

Leaking Fuel Lines From Underground Fuel Tank

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 Iowa Department of Natural Resources (IDNR) permit requirements, including site specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a State Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the stormwater general permit.


Click here to request further information or a quote to prepare a facility SWPPP or revise your existing SWPPP. Click here to review example Caltha projects in Iowa and IA regulatory updates.

State Spill Plan, SPCC Plan, Contingency Plan Requirements

Caltha LLP maintains a library of SPCC Plan Templates developed to meet the above ground tank and spill prevention and response requirements of individual States and the Federal SPCC Rule. An SPCC Plan is require for any facility that exceeds an oil storage capacity of 1,320 gallons. Facilities potentially subject to the SPCC Rules (40 CFR 112) are not limited to industrial sites, but can include municipal, commercial, retail, institutional sites, construction sites, and even farms.

Leaking Fuel Tanks And Refueling Area 

Without Properly Sized Secondary Containment

The revised SPCC Rule now allows the use of streamlined SPCC plan formats if facilities meet certain criteria. These streamline SPCC Template plans do not need to be signed by a professional engineer in most States. Other SPCC plans may need to be reviewed and signed by an engineer. Caltha LLP also provides SPCC training for companies subject to the SPCC Rule and conducts SPCC inspections.

Caltha prepares SPCC Plans for the following States: [Click on a State to request information and options]

Alabama SPCC Plan

Alaska SPCC Plan
Arkansas SPCC Plan
California SPCC Plan
Connecticut SPCC Plan
Florida SPCC Plan
Georgia SPCC Plan
Illinois SPCC Plan
Indiana SPCC Plan
Iowa SPCC Plan
Kansas SPCC Plan
Kentucky SPCC Plan
Louisiana SPCC Plan
Maine SPCC Plan
Massachusetts SPCC Plan
Michigan SPCC Plan
Minnesota SPCC Plan
Mississippi SPCC Plan
Nebraska SPCC Plan
Nevada SPCC Plan
New Jersey SPCC Plan
New York SPCC Plan
North Carolina SPCC Plan
North Dakota SPCC Plan
Ohio SPCC Plan
Oklahoma SPCC Plan
Oregon SPCC Plan
Pennsylvania SPCC Plan
South Carolina SPCC Plan
South Dakota SPCC Plan
Tennessee SPCC Plan
Texas SPCC Plan
Utah SPCC Plan
Virginia SPCC Plan
Washington SPCC Plan
Wisconsin SPCC Plan

New NOI Required To Continue Coverage Under Revised Illinois Permit

The Illinois EPA issued its revised NPDES General Permit for industrial stormwater discharge in March 2017 and the permit was effective on April 5, 2015. Facilities that had been covered under the prior permit was wished to continue coverage under the new permit have to submit a new application.


Applications (Notice of Intent) for permit coverage were due with in 150 days after the new permit was effective. All permitted facilities need to submit a NOI before September 5, 2017.


Click here to review example Caltha projects related to stormwater permitting and stormwater pollution prevention, including SWPPP projects in Illinois.

New York No Longer Accepting NOI For General Permit Coverage

The New York State Department of Environmental Conservation (NYSDEC) published revisions to the SPDES Multi-Sector General Permit for Stormwater Discharges from Industry Activity (MSGP) (GP-0-17-004), which will replace the current one (GP-0-12-001) which expired on October 1, 2017.The new permit regulates stormwater discharges from industrial activities and was scheduled to become effective on October 1, 2017 with a five year permit term.


The revised permit has not been finalized and the expired permit remains in place. The Department will not be accepting applications for continued coverage until the revised permit and the new NOI are posted on agency website. The NOI for GP-12-001 has been removed and is no longer available to gain coverage under the MSGP.


Once GP-0-17-004 takes effect, there will be an interim period of 90 days. During this time, an owner or operator needs to update the facility’s Stormwater Pollution Prevention Plan (SWPPP) to comply with the requirements of the new permit before submitting a Notice of Intent (NOI) to obtain permit coverage. Some key changes in the new permit are expected to include:

• Non-numeric effluent limits were updated to include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response productions, and employee training.
• Semi-annual monitoring and discharge monitoring reports will be required for Benchmark and Numeric Effluent Limit monitoring. With this change, the Corrective Action forms and the Non-Compliance event forms will no longer be needed.
• Discharge Monitoring Reports must be submitted electronically through EPA’s electronic reporting system, NetDMR.
• The owner or operator must wait three days in a row without precipitation before they may complete the Comprehensive Site Compliance Inspection. This allows for dry weather flow monitoring to be performed so that non-stormwater discharges can be detected and addressed as necessary.

Click here to review example Caltha projects related to stormwater permitting and stormwater pollution prevention, including SWPPP projects in New York.

Warehousing and Logistics Facilities Needed Storm Water Permit And SWPPP

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: International Retailer
Location(s): California, Washington, Utah, Georgia, Florida, Virginia, North Carolina, Pennsylvania, Ohio, Massachusetts, New York, Kansas, Virginia, Louisiana, Texas, Tennessee, Minnesota, Illinois, Indiana, South Carolina, Colorado, Nevada, New Jersey, Connecticut, Missouri

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this international retailer at multiple logistics and warehousing locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State or EPA application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

Leaking Hydraulic System On Trash Compactor 

Contaminates Stormwater Discharge

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

Obtaining Permit Waiver Under 2017 EPA General Permit

The revised US EPA general permit for stormwater discharge from construction sites began effective on February 22, 2017. The revised general permit included an option for a permit waiver for certain projects.


These waivers are only available to stormwater discharges associated with small construction activities (i.e., 1-5 acres). The operator of a small construction activity may be able to qualify for a waiver in lieu of needing to obtain coverage under the general permit based on three factors. Each operator, unless otherwise needing permit coverage, must notify EPA of its intention for a waiver by submitting a waiver certification. Where the operator changes or another is added during the construction project, the new operator must also submit a waiver certification to be waived.


Waiver certifications are submitted prior to commencement of construction activities. If operators submit a TMDL or equivalent analysis waiver request, the project is not waived until EPA approves the request, and operators are advised not commence construction activities until receipt of approval from EPA. Operators are not prohibited from submitting waiver certifications after initiating clearing, grading, excavation activities, or other construction activities. However, EPA has indicated it reserves the right to take enforcement for any unpermitted discharges that occur between the time construction commenced and waiver authorization is granted.


Click here for more information on Caltha's Construction Stormwater Permitting and Compliance Support in your State.

New Kansas Industrial Discharge Permit

The Kansas General Permit for Stormwater Runoff Associated with Industrial Activities became effective on November 1, 2016. The reissued permit and forms contain new and additional requirements.


Owners or operators of new or existing unpermitted facilities subject to regulation of stormwater runoff must complete the new Notice of Intent (NOI) form to apply for and obtain coverage under the industrial stormwater general permit S-ISWA-1611-1.
Facilities that currently have industrial stormwater discharge coverage under the previous Kansas General Permit do not need to submit a new NOI, but need to comply with the requirements of the new general permit. Existing permitted facilities that wish to decline coverage under the new permit must submit an application for coverage under an individual permit by February 1, 2017 and must continue to comply with the conditions of the previous general permit until the individual permit is issued.


The principal requirement of the Kansas General Permit for Stormwater Runoff from Industrial Activity has remained the same - for the owner to develop, implement and maintain a Stormwater Pollution Prevention Plan (SWPPP). Caltha LLP has prepared a SWPPP Template to align with the 2016 Kansas permit requirements.


For more information go to Caltha Stormwater Services

Large Development Site Permitting, SWPPP and Storm Water Training

Caltha LLP Project Summary

Project: Construction Permitting, SWPPP & Training
Client: National Home Builder
Location(s): Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 49-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.

Stormwater Controls And Waste Management 

At Construction Site

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

Annual Employee Training For Industral Stormwater At North Dakota Food Facility

Caltha LLP Project Summary

Project: Annual Employee Stormwater Training For Food Sector Facility
Client: Food Sector SIC 20 Facility
Location(s): North Dakota

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training, Webinar

Overview: Caltha LLP was retained by this food manufacturing company to prepare and present annual SWPPP training, as required under the North Dakota Department of Health (NDDH) multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

• Overview of discharge permit
• Overview of the contents of the SWPPP;
• Spill prevention and response procedures
• Good housekeeping practices;
• Maintenance requirements
• Material management practices
• Location and maintenance of on-site stormwater pollution prevention controls;
• Operating procedures for preventing pollution; and
• Inspection procedures and records maintenance.

Training was presented by "live" webinar to all affected employees by a qualified SWPPP trainer.For more information on Caltha LLP services, go to the Caltha Contact Page

Annual Storm Water Training For Minnesota Permit

Caltha LLP Project Summary

Project: Annual SWPPP Training For Food Sector Facility
Client: Food Sector SIC 20 Facility
Location(s): Minnesota

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training

Overview: Caltha LLP was retained by this food manufacturing corporation to prepare and present annual SWPPP training, as required under the Minnesota Pollution Control Agency multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

• Overview of Discharge Permit
• Components and Goals of the SWPPP
• Stormwater Monitoring
• Monthly Facility Inspections
• Other Tasks Required By Permit

Training was presented to all affected employees by a qualified SWPPP trainer.For more information on Caltha LLP services, go to the Caltha Contact Page

SWPPP and Permit Compliance Training For Revised WDNR Tier 2 Permit

Caltha LLP Project Summary

Project: SWPPP and Permit Compliance Documentation To Meet Tier 2 Permit
Client: Concrete manufacturer
Location(s): Wisconsin

Key Elements: Facility SWPPP, stormwater inspection, visual stormwater monitoring

Overview: Caltha LLP was retained by this regional concrete manufacturer to conduct compliance reviews and prepare updated SWPPPs for two of its facilities located in Wisconsin. Both sites were covered under the WDNR Tier 2 General Permit for discharge of industrial stormwater. Caltha staff conducted a site visit and met with plant personnel to determine what updates were required to the existing facility SWPPP to meet the newly revised WDNR permit. A revised SWPPP was issued to each location which included updates to quarterly monitoring procedures, spill prevention measures, routine employee training and monthly housekeeping inspections.


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

2017 Georgia General Pemit | What If I Exceeded Benchmarks Under Current Permit?

The current Georgia industrial stormwater general discharge permit expires on May 30, 2017. The revised NPDES General Storm Water Permit For Discharges of Stormwater Associated With Industrial Activity (2017 IGP) was finalized in 2016 and becomes effective on June 1, 2017. The revised permit made some modifications to requirements permitted facilities must meet, but not as substantial of changes as compared to the release of the 2012 IGP.

If a facility exceeded the impaired waters benchmark based on the criteria presented in 2012 IGP permit, then the facility has the option to conduct 12 months of flow-weighted composite sampling to demonstrate the discharge does not cause or contribute to an exceedance of water quality standards, or make the necessary improvements to the facility to achieve the instream water quality standard as an effluent limit within 36 months. If the facility still is unable to meet the impaired waters benchmark(s), they may not be authorized to discharge stormwater under this permit and may be required to apply for an individual NPDES permit or alternative general permit. Facilities that failed to meet the applicable benchmarks of the 2012 IGP permit have the option to sample their discharge(s) for 12 months to confirm whether the facility causes or contributes to an exceedance of the applicable Water Quality Standard, or prevent all exposure of industrial processes, materials, and equipment to stormwater, and/or capture and treat storm events of up to 1.2 inches within industrial areas exposed to stormwater within 36 months.

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

Georgia 2017 IGP | What If My Facility Is Already Covered Under the Existing Permit?

The current Georgia industrial stormwater general discharge permit expires on May 30, 2017. A revised permit NPDES General Storm Water Permit For Discharges of Stormwater Associated With Industrial Activity (2017 IGP) was finalized in 2016 and becomes effective on June 1, 2017. The revised permit made some modifications to requirements permitted facilities must meet, but not as substantial of changes compared to the release of the 2012 IGP.


Current permittees are required to submit a new Notice of Intent (NOI) to obtain coverage under the 2017 IGP and to maintain coverage for discharging stormwater associated with industrial activities. Facilities previously covered under the 2012 IGP will have up to 30 days to submit the new NOI for coverage under the updated 2017 IGP after the effective date.

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 BMP Requirements Due September 24 In Pennsylvania

The Pennsylvania DEP General Industrial Stormwater Permit General PAG-03 was revised in September 2016. This latest version of the permit updated the Best Management Practices (BMP) that apply to all industrial sectors to conform to the general BMPs contained in EPA’s most recent Multisector General Permit (MSGP), which was released in 2015.
The reissued General Permit identified several new BMPs to reduce pollutants in the stormwater discharges of industrial facilities and been expanded the 12 industrial sectors that were included in the prior version to 30 specific industrial sectors. The new BMPs requirements included:

• Use of spill/overflow protection equipment,
•  Control discharges through secondary containment or treatment for open dumpsters and roll off boxes,
• Install velocity dissipation devices at discharge sites, and
• Maintain readily accessible spill kits in locations where spills may occur.

Because some of the new BMPs may not have been required for previously permitted facilities, DEP provided a one year “transition period” for any required BMPs that existing permittees must implement that were not part of the previous General Permit. DEP included a provision that alternatives to the sector-specific BMPs may be implemented, if authorized by DEP. The deadline for implementing new BMPs is September 24, 2017.

Nonstormwater Discharge From Improper 

Waste Storage At Industrial Facility

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


For recent news and Caltha project examples for Pennsylvania, click here.

New Requirements For PPC Plans Apply To No Exposure Certification Sites In Pennsylvania

In the revised General Industrial stormwater discharge permit issued in September 2016, Pennsylvania DEP has updated the requirements for Preparedness, Prevention and Contingency (PPC) Plan. The purpose for the update was to make the General Permit consistent with the current language being used for individual NPDES permits for industrial stormwater discharges.
Compared to the previous PAG-03 General Permit, several significant changes were made:

1. removal of the requirement for engineering certification of PPC Plans every year for facilities subject to SARA Title III, Section 313, and
2. requires annual review and update, if necessary, of the PPC Plan to be documented in the annual report.

In addition, a PPC Plan will be required as part of each complete NOI submission, including No Exposure Certification submissions.



For recent news and Caltha project examples for Pennsylvania, click here.

Amendement To 2015 Washington Construction Stormwater Permit

On November 18, 2015, Ecology issued an updated Construction Stormwater General Permit (CSWGP). The permit became effective January 1, 2016. One appeal was filed with the Washington Pollution Control Hearings Board on December 17, 2015. To resolve the case, Ecology has proposed several revisions to the permit and has posted these revisions for public comment. Comments are due by February 10, 2017

The proposed changes are to dust control (S1.C.3.i), pH sampling requirements (S4.D), engineering calculation requirements (S9.B.1.f), and concrete washout (S9.D.9.h). The proposed changes are:

• S1.C.3.i - Uncontaminated or potable water used to control dust. Permittees must minimize the amount of dust control water used.
• S4.D - pH Sampling Requirements – Significant Concrete Work or Engineered Soils
  If construction activity results in the disturbance of 1 acre or more, and involves significant concrete work (significant concrete work means greater than 1000 cubic yards poured concrete or recycled concrete used over the life of a project ) or the use of recycled concrete or engineered soils (soil amendments including but not limited to Portland cement-treated base [CTB], cement kiln dust [CKD], or fly ash), and stormwater from the affected area drains to surface waters of the State or to a storm sewer system that drains to surface waters of the State, the Permittee must conduct pH sampling as set forth below. Note: In addition, discharges to segments of water bodies on Washington State’s 303(d) list (Category 5) for high pH are subject to a numeric effluent limit for pH; refer to Special Condition S8.

1. For sites with significant concrete work, the Permittee must begin the pH sampling period when the concrete is first poured and exposed to precipitation, and continue weekly throughout and after the concrete pour and curing period, until stormwater pH is in the range of 6.5 to 8.5 (su).
2. For sites with recycled concrete where monitoring is required, the Permittee must begin the weekly pH sampling period when the recycled concrete is first exposed to precipitation and must continue until the recycled concrete is fully stabilized with the and stormwater pH is in the range of 6.5 to 8.5 (su).

• S9.B.1.f – Engineering calculations for ponds, treatment systems, and any other designed structures. When a treatment system requires engineering calculations, these calculations must be included in the SWPPP. Engineering calculations do not need to be included in the SWPPP for treatment systems that do not require such calculations.
• S9.D.9.h - Assure that washout of concrete trucks is performed off-site or in designated concrete washout areas only. Do not wash out concrete trucks drums or concrete handling equipment onto the ground, or into storm drains, open ditches, streets, or streams. Do not dump excess concrete on site, except in designated concrete washout areas. Concrete spillage or concrete discharge directly to groundwater or to surface waters of the State is prohibited. Do not wash out to formed areas awaiting LID facilities.

 

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

Compliance With State Multi-sector Industrial General Permit | Seminar Module

The link below provides training slides from a training module on basic compliance strategies to address general permit requirements. The emphasis of the training module is to provide photograph examples of key areas which should be concerned in developing a site-specific SWPPP.

Presentation Slides: Complying with State Industrial Storm Water 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

How Were Stormwater Benchmark Values Developed? Historical Monitoring Data Compared To Industial Bench Marks

The following link provides a technical review of State Stormwater Benchmark values compared to historical industrial sector monitoring data.

Presentation Slides: Comparison of State Stormwater Benchmarks to Historical Industrial Sector Monitoring Results

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

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