Saturday, February 24, 2018

Who Needs To Certify SWPPP Plan? What Certifications Are Needed?

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);
  • Annual Site Compliance Certifications;
  • Endangered Species Certifications;
  • Historic Places Certification,
  • Environmental Professional Certification (in Indiana)
  • Certified Stormwater Operator Certification (in Michigan)
  • Others.

Rail Car Loading Area Covered In SWPPP Inspection
Rail Car Loading Area Covered In SWPPP Inspection

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."

 Non-Stormwater Discharge At Industrial Facility Identified During SWPPP Inspection
Non-Stormwater Discharge At Industrial Facility

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.

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


 
Caltha LLP | Your Stormwater Permit, SWPPP 
and Spill Plan Partner

Does Oil Sheen On Pond Need To Be Reported? What Is Sheen Rule?

Under the Clean Water Act, the "sheen rule" provides the framework for determining whether an oil spill should be reported to the federal government. Federal regulation requires the person in charge of a facility or vessel responsible for discharging oil that may be "harmful to the public health or welfare" to report the spill. The regulation establishes the criteria for determining whether an oil spill may be harmful to public health or welfare, thereby triggering the reporting requirements:
  • · Discharges that cause a sheen or discoloration on the surface of a body of water;
  • · Discharges that violate applicable water quality standards; and
  • · Discharges that cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorelines.
These reporting criteria are independent of local or State spill reporting requirements. Therefore, spills might be reportable even if State spill reporting thresholds are not exceeded.


  Hazardous Chemical Spill to Sewer Outside Manufacturing Plant
Hazardous Chemical Spill to Sewer Outside Manufacturing Plant 

Because the Oil Pollution Act of 1990, which amended the Clean Water Act, broadly defines the term "oil," the sheen rule applies to both petroleum and non-petroleum oils and fats (e.g., vegetable oil, milk). The regulation also provides several exemptions from the notification requirements.

 Need more information of federal, State or local spill reporting requirements? Contact Caltha at info@calthacompany.com

   
Caltha LLP | Your EH&S Compliance, 
Auditing and EMS/SMS Partner

Thursday, February 22, 2018

Most Common Problems With Secondary Containment

Common Problems With Secondary Containment

Missing Secondary Containment

Fuel Tank Without Containment Or Proper Support
Fuel Tank Without Containment Or Proper Support

Fuel Loading Area Without Drainage Control
Fuel Loading Area Without Secondary Containment

Leaking Used Oil Storage tank Observed During Phase I Facility Inspection
Leaking Used Oil Storage AST Observed During
Facility Inspection

Inadequate Volume Containment

Phase I Environmental Inspection Finds Leaking Tanks And Pumps In Refueling Area
Environmental Inspection Finds Leaking Tanks
And Pumps In Refueling Area

Wrong Material

Bulk Fuel Storage With Hay Bale Secondary Containment Observed During SPCC Audit
Bulk Fuel Storage With Hay Bale
Secondary Containment

Missing or Inadequate Maintenance

Broken Secondary Containment Wall Identified During SWPPP inspection
Cracked Secondary Containment Wall Identified
During SPCC Inspection


Damaged Oil Storage Containment

This photo shows an example of a Leaking Waste Solvent Hazardous Waste Tank identified during a hazardous waste inspection
Leaking Waste Solvent Hazardous Waste Tank


 

Caltha LLP | Your Stormwater Permit, 
SWPPP and Spill Plan Partner

Monday, February 19, 2018

Reducing Zinc In Stormwater Discharge Where Does Zinc Come From?

Zinc From Galvanized Metal And Dust

Many facilities required to monitor metal concentrations under their industrial stormwater permit have found high levels of zinc in their stormwater discharges. Work conducted by the State of Washington found the major sources of zinc were galvanized materials, particularly on roof surfaces, as well as motor oil and hydraulic fluid accumulated on parking areas, loading docks, and paved grounds. Tire dust in areas with high volumes of trucks and forklifts may also be an important source. Zinc concentrations in runoff from roofs with galvanized ductwork were about 10-fold greater than found from the roofs without galvanized materials.

Zinc From Oil and Hydraulic Fluid Leaks and Spills

Both motor oil and hydraulic fluid contain high concentrations of zinc, about 0.1% by weight. As an example, as little as ½ cup of motor oil spilled on a small paved parking lot could result in 250 µg/L of zinc in runoff during a small rain event.

Can Hydraulic System On Trash Compactor Leak?
Leaking Hydraulic System On Trash Compactor  


Contaminated Soil From Improper Used Oil Drum Storage identified during a facility environmental inspection
Contaminated Soil From Improper Used Oil Drum Storage

 Caltha LLP provides expert technical support to facilities that need to reduce pollutants in stormwater discharge. For further information go to Caltha Stormwater Compliance and Permitting Page.


    SWPPP and stormwater pollution prevention plans
Caltha LLP | Your Pollution Prevention Partner

Friday, February 16, 2018

Construction SWPPP And Contractor SWPPP Training, Spill Training

Caltha LLP Project Summary

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

Key Elements: Stormwater permitting, SWPPP, Inspection training, Spill Control Plan

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 8-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, spill control plan and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.


  SWPPP and Solid Waste Controls At Large Residential Construction Project
SWPPP and SWPPP Training For Residential Site Construction

For more information on Caltha LLP construction stormwater services, go to the Caltha Storm water Permitting and Compliance Page


   
Caltha LLP | Your Stormwater Permit, SWPPP 
and Spill Plan Partner

Friday, February 9, 2018

Contracting For SWPPP Inspections Stormwater Inspections

Caltha LLP provides SWPPP Inspection  and Annual Comprehensive Facility Inspection services to industrial facilities and construction sites regulated under State General Permits for stormwater discharge. Inspections are conducted by certified stormwater inspectorscertified hazardous material managers or certified environmental compliance auditors.

What Are Storm Water Inspection Requirements ?

The frequency of SWPPP inspections will vary from State to State, but for industrial sites inspections are generally conducted monthly or quarterly. In some cases, one or two inspections may have to be completed during a rainfall event. For construction sites, generally weekly inspections are required, and special inspections after significant rainfall events. In addition, most industrial permits will require an Annual Comprehensive Facility Compliance Inspection, which also reviews overall permit compliance records, such as training.


  This photo shows an example of Leaking Waste Solvent Drums contaminating soil and groundwater near the property line
Leaking Waste Solvent Drums
Along Property Line

Why Contract Your SWPPP Inspections?

Contracting to have inspections conducted by Caltha ensures that inspections will be conducted by certified professionals to meet the inspection requirements of your discharge permit. This also frees facility staff from the responsibility of making sure inspections are done on time and eliminates the need for specialized training of facility staff assigned to conduct inspections.

Request a Quote For SWPPP Inspection Services

Caltha provides routine weekly, monthly or quarterly SWPPP inspection services and Annual Comprehensive Facility Compliance Inspection.

To request a quote, go to the Caltha Contact Page.


    
Caltha LLP | Your Stormwater Permit, SWPPP 
and Spill Plan Partner

Contract SPCC Inspections, Tank Inspections

Caltha LLP provides SPCC Inspection services to facilities regulated under the Federal SPCC Rule (40 CFR 112). Inspections are conducted by certified hazardous material managers or certified environmental compliance auditors.

What Are Facility Inspection Requirements Under SPCC Rule?

The SPCC Rule requires that at a minimum monthly inspections be conducted and documented. Various provisions of the SPCC rule relate to the inspection, evaluation, and testing of containers, associated piping, and other oil-containing equipment. Different requirements apply to different types of equipment, oil, and facilities. The requirements are generally aimed at preventing discharges of oil caused by leaks, corrosion, brittle fracture, overfill, or other forms of container or equipment failure by ensuring that containers used to store oil have the necessary physical integrity for continued oil storage. The requirements are also aimed at detecting container and equipment failures (such as pinhole leaks) before they can become significant and result in a discharge as described in §112.1(b). For certain above ground tanks, these monthly inspections can be used in lieu of more extensive tank inspections and integrity testing by a certified tank inspector.



Cracked Secondary Containment
Dike Around Oil Tank


Why Contract Your SPCC Inspections?

Contacting to have inspections conducted by Caltha ensures that inspections will be conducted by certified professionals to meet the SPCC Rule. This also frees facility staff from the responsibility of making sure inspections are done on time and eliminates the need for specialized training of facility staff assigned to conduct inspections.

Request a Quote For SPCC Inspection Services

To request a quote, go to the Caltha Contact Page.


  
Caltha LLP | Your SPCC Compliance, 
Auditing and EMS/SMS Partner