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


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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.



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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.

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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