Saturday, October 21, 2017

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.

Monday, October 2, 2017

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.