New Permit Requires Update To SWPPP For South Dakota Sites

Effective April 1, 2018, South Dakota's General Permit for Stormwater Discharges Associated with Construction Activities was reissued. New applications for permits must be submitted at least 15 days prior to the project start date on the new forms beginning May 1, 2018. The 2018 South Dakota Legislature also passed Senate Bill 25 which authorized new stormwater permit fees. Effective July 1, 2018, new construction Notice of Intents (NOIs) must include the new fee.

SWPPP and Solid Waste Controls At Large Residential Construction Project

The new stormwater discharge permit included new requirements for a stormwater pollution prevention plan, or SWPPP. Existing Stormwater Pollution Prevention Plans need to be updated by October 1, 2018.For projects that discharge stormwater to a water body listed as impaired under section 303(d) of the Federal Clean Water Act due to sediment, suspended solids, or turbidity, the SWPPP must identify the water body and impairment and must describe and conform to any Wasteload Allocation (WLA) for the water body.

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

Key Changes To New MPCA General Permit

The Minnesota Pollution Control Agency (MPCA) has issued a draft NPDES/SDS permit to control pollution generated from runoff associated with construction activities discharging into waters of the State of Minnesota.The draft permit will replace the current general permit which will expire on August 1, 2018. Some of the key revisions in the draft permit include:

Application and permit coverage effective date

MPCA is proposing to omit the mandatory 7 day waiting period. However, payment confirmation is required before the MPCA can issue permit coverage. The waiting period of “seven (7) calendar days” has been replaced with “upon completing the payment process”. All project proposers must obtain NPDES coverage electronically. The online application assures that all of the questions are completed and requires the user to certify that a SWPPP has been prepared for the project. MPCA is also proposing to omit the mandatory 30 day waiting period. For projects that require a SWPPP review before coverage is issued, the MPCA will grant coverage upon the completion of the application and payment process and after the MPCA has made a determination that the SWPPP meets all of the permit requirements. Stormwater Pollution Prevention Plan content The requirements for SWPPP content have been re-written and re-ordered for clarity.

SWPPP Amendments

In order to prevent contractors from deviating from the SWPPP and selecting inappropriate BMP option with no regard to the specific site conditions, the MPCA has added the following language regarding SWPPP amendments: “All SWPPP changes must be done by one of the individuals described in item 21.4 or item 21.5 or another qualified individual. Changes involving the use of a less stringent BMP must include a justification describing how the replacement BMP is effective for the site characteristics.”

Documentation when the volume control standard cannot be achieved

For those projects where the full volume reduction requirement cannot be met on site, (e.g., the site has infiltration prohibitions), the permittee must document the reasons in the SWPPP.

Documentation of infeasibility

For projects adjacent to surface waters, the current permit requires the preservation of a 50’ buffer unless infeasible. For projects adjacent to special waters or impaired waters, a 100' buffer zone must be preserved. The proposed permit requires permittees to document in the SWPPP why the buffer was not preserved.

Impaired waters and TMDL’s

This section was deleted. MPCA has made a programmatic decision not to include specific implementation activities or BMP’s in TMDL implementation plans for construction activity.

Permanent stormwater management

This section was deleted. The current permit offers permittees an option to follow a municipalities (or other plan approval authority such as a watershed district) stormwater ordinance in lieu of the permit requirements if that municipality is regulated by the state through the Municipal Separate Storm Sewer System (MS4) program. This provision was intended to reduce duplicate regulations as all regulated MS4 communities should have an ordinance in place that is at least as stringent as the state permit. However, MPCA’s determined many of the ordinances have not been written such that the requirements were at least as stringent as the state requirements and prevented the MPCA from taking any action if the permittees plans were approved by the municipality.

Permanent stormwater management

Projects that will result in a net increase in impervious surfaces of one acre or more must include plans for a permanent stormwater treatment system. Permittees are still expected to provide some type of volume reduction treatment if the site is conducive for stormwater infiltration. If the site is not conducive to stormwater infiltration (see item 16.14 through 16.22) other types of systems must be utilized such as a wet sedimentation basin. The permit will still offer flexibility for linear projects or projects where bedrock limits any type of stormwater management.

Infiltration prohibition

The proposed permit would prohibit infiltration systems constructed as part of the project regardless of whether or not the CSW permit requires stormwater management if the site receives runoff from vehicle fueling and maintenance areas. Infiltration requirement The current permit requires “appropriate on-site testing consistent with the recommendations found in the Minnesota Stormwater Manual to verify soil types…”. The manual recommends a certain number of on-site soil tests depending on the size of the system. The proposed permit specifically requires permittees to provide at least one soil boring, test pit or infiltrometer test in the area of each infiltration system for determining infiltration rates. The proposed permit allows field tested rates to be used with a safety factor of 2 or permittees may use the infiltration rate chart found in the Minnesota Stormwater Manual to determine design infiltration rates based on soil type.

Infiltration prohibition

The current permit prohibits constructing infiltration systems in areas with contaminated soil or groundwater. The current language states that infiltration is prohibited in: “areas where high levels of contaminants in soil or groundwater will be mobilized by the infiltrating stormwater.” The proposed permit includes additional language describing the steps permittees are expected to take to demonstrate compliance with this requirement. The proposed language is as follows: "Permittees are prohibited from constructing infiltration systems where high levels of contaminants in soil or groundwater may be mobilized by the infiltrating stormwater. Permittees must either complete the MPCA's site screening assessment checklist or conduct their own assessment to determine the suitability for infiltration. The assessment must be retained with the SWPPP. For more information and to access the MPCA's screening assessment tool see the Minnesota Stormwater Manual”.

Infiltration prohibitions for Drinking Water Supply Management Areas (DWSMA)

The current permit prohibits infiltration anywhere within a DWSMA. The proposed permit limits the prohibition to "within an Emergency Response Area (ERA) as defined by the Department of Health" and "areas within a Drinking Water Supply Management Area (DWSMA) as defined in Minn. R. 4720.5100, subp. 13, classified as having high or very high vulnerability, unless a regulated MS4 Permittee has performed a higher level of engineering review sufficient to provide a functioning treatment system and to prevent adverse impacts to groundwater."

Filtration systems

The following requirement has been added to the filtration system item: "The filter media must not be installed until the contributing drainage area has been constructed and fully stabilized unless rigorous erosion prevention and sediment controls (e.g., diversion berms) are provided to keep sediment and runoff completely away from the filtration area."

Wet sedimentation basin requirement

A new requirement was added to the proposed permit requiring an impermeable liner to be included in the design of a basin located in active karst terrain.

Ditch stabilization methods

The current permit specifically states that some less effective stabilization methods such as mulch cannot be used in ditches or swales for stabilization and permittees must rely on more robust practices such as erosion control blankets. The proposed permit allows permittees more flexibility for the type of stabilization chosen for a ditch bottom if the slope is less than 2%. Additionally, as with all BMP requirements in the permit, If the selected BMP is found to be inadequate at minimizing erosion from ditches or swales, another more effective BMP must be utilized.

Sediment controls near stockpiles

The proposed permit specifically states that perimeter controls are required near the base of stockpiles. This change in language better clarifies that stockpile perimeter controls are required in addition to the perimeter sediment controls required in item 9.2. This does not represent a change in MPCA policy regarding stockpile management.

50 foot buffer

The current permit requires redundant sediment controls around surface waters if a 50 foot natural buffer cannot be maintained. The proposed permit requires that the sediment control practices must be spaced at least 5 feet apart. The MPCA believes that proper spacing for sediment storage between the practices is necessary in order to function properly. Language was also included to relieve permittees of the spacing requirement if there are site constraints.

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

   

Revised Georgia EPD Construction Permits

Georgia EPD has reissued general permits for stormwater discharge from construction sites. As background, NPDES General Permit No. GAR100000 for storm water discharges associated with construction activity was issued in 2000 and regulated construction activities that disturbed five (5) or more acres. In 2003, the permit was reissued as three general permits that regulate construction activities that disturb one (1) or more acres: NPDES Permit No. GAR100001 - regulates stand-alone construction sites, NPDES Permit No. GAR100002 - regulates infrastructure construction sites, and NPDES Permit No. GAR100003 - regulates common development construction sites.

 
 SWPPP and SWPPP Training For
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Summary of Changes to Permit

• The term “projects” has been changed to “sites” for consistency with the permit definitions.
• The draft permits contain changes as a result of EPD’s implementation of the NPDES Electronic Reporting Rule. Beginning on the effective date of the permit, All Notices of Intent (NOI), Modifications and Notices of Terminations (NOT) must be submitted through EPD’s electronic submittal portal. EPD is preparing an electronic method for submitting sampling reports. ES&PC Plans required to be submitted to the EPD District Offices must now be submitted electronically through EPD’s electronic submittal portal or as a PDF on CD-ROM or other storage device.
• All references to anionic polyacrylamide (PAM) have been replaced by “flocculants or coagulants”, and “matting or blankets” has been replaced with “slope stabilization” to be consistent with the most recent Manual for Erosion and Sediment Control.
• BMP options which were no longer “over and beyond” have been removed from the options to address impaired waters.
• The permit now requires a large sign (minimum 4 feet x 8 feet) must be posted on site by the actual start date of construction. The sign must be visible from a public roadway. The sign must identify : (1) the construction site, (2) the permittee(s), (3) the contact person(s) along with their telephone number(s), and (4) the permittee-hosted website where the ES&PC Plan can be viewed. The sign must remain on site and the ES&PC Plan must be available on the provided website until a NOT has been submitted.
• EPD has added a BMP option to address impaired waters, to conduct inspections during the intermediate grading and drainage BMP phase and during the final BMP phase of the project by a certified Level II design professional to improve overall site management quality control, and to install Post Construction BMPs which remove 80% TSS
• EPD has clarified that Whenever a permittee finds that a BMP has failed or is deficient (beyond routine maintenance) and has resulted in sediment deposition into waters of the State, the permittee shall submit a summary of the violations to EPD correct such BMP as follows: 
• When the repair does not require a new or replacement BMP or significant repair, the BMP failure or deficiency must be repaired by the close of the next business day from the time of discovery; 
• When the repair requires a new or replacement BMP or significant repair, the installation of the new or modified BMP must be completed and the BMP must be operational by no later than seven (7) days from the time of discovery. If it is infeasible to complete the installation or repair within seven (7) days, the permittee must document why it is infeasible to complete the installation or repair within the seven (7) day timeframe and document the schedule for installing or repairing the BMPs and making the BMPs operational as soon as feasible after the seven (7) day timeframe.

Summary of Changes to Erosion, Sedimentation and Pollution Control Plans

Revisions to the requirements for Erosion, Sedimentation and Pollution Control Plans include:

• For building materials, building products, construction wastes, trash, landscape materials, fertilizers, pesticides, herbicides, detergents, sanitary waste and other materials present on the site, provide cover (e.g. plastic sheeting, temporary roofs) to minimize the exposure of these products to precipitation and to stormwater, or a similarly effective means designed to minimize the discharge of pollutants from these areas. Minimization of exposure is not required in cases where exposure to precipitation and to stormwater will not result in a discharge of pollutants, or where exposure of a specific material or product poses little risk to stormwater contamination (such as final products and materials intended for outdoor use).
• The permit requires permittees to measure and record rainfall within disturbed areas of the site that have not met final stabilization once every 24 hours except any non-working Saturday, non-working Sunday and non-working Federal holiday.

Construction Activities Not Requiring Permit Coverage

EDP has also clarified that permit coverage is not required for discharge of storm water associated with infrastructure road construction sites that consist solely of the installation of cable barriers and guard rail for an existing facility within the existing rights-of-way. The construction activity shall, as a minimum, implement and maintain best management practices, including sound conservation and engineering practices to prevent and minimize erosion and resultant sedimentation, which are consistent with, and no less stringent than, those in the “Manual for Erosion and Sediment Control in Georgia”. In order to be eligible for this exemption the project must comply with the following conditions: (1) no mass grading shall occur on the project, (2) the project shall be stabilized by the end of each day with temporary or permanent stabilization measures, (3) final stabilization must be implemented at the end of the project.

 Permit coverage is also not required for discharge of storm water associated with infrastructure construction sites that consist of the installation of buried utility lines and comply with the following conditions: (1) solely installed via vibratory plow, (2) the conduit does not exceed 4 inches in diameter, and (3) occurs within an existing stabilized right-of-way. The construction activity shall, as a minimum, implement and maintain best management practices, and the following conditions: (1) no mass grading shall occur on the project, (2) no tree clearing, (3) no change in grade, (4) the project shall be stabilized by the end of each day with temporary or permanent stabilization measures, and (5) final stabilization must be implemented at the end of the project.

    

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

Deadline To Reapply For Texas General Permit Coverage Is June 3

The Texas Commission on Environmental Quality has renewed 2018 Construction General Permit (CGP) TXR150000 (2018 CGP) which became effective March 5, 2018. Project sites that would like continue their current authorization under the prior permit must reapply during the 90 day grace period which ends June 3, 2018.

 
SWPPP and SWPPP Training For
Residential Site Construction  


 Some of the important changes in the revised permit included:

• Added the 2014 and 2015 amendments to the federal effluent limitation guidelines (ELGs) (40 CFR Part 450 - Construction and Development Point Source Category)
• Added definition of “infeasible.” (Not technologically possible or economically achievable in light of best industry practices.)
• Added requirement to minimize pollutants in discharges.
• Added requirement to minimize channel and streambank erosion and scour in the immediate vicinity of discharge points.
• Replaced the term “surface waters” with “Waters of the U.S.” (Water in the state was placed in the permit, rather than Waters of the U.S.)
• Added requirement to maximize stormwater infiltration to reduce pollutant discharges, unless infeasible.
• Added requirement which states that minimizing soil compaction not required where the intended function of a specific area dictates that it is compacted.
• Added requirement which states that a permittee must preserve topsoil, unless infeasible. The requirement also states that preserving topsoil is not required where the intended function of a specific area of a site dictates that the topsoil will be disturbed or removed.
• Added requirement which states that stabilization (in arid, semi-arid, and drought-stricken areas) must be completed within a period of time as specified by the permitting authority. The requirement also states that in limited circumstances, stabilization may not be required if the intended function of a specific area of the site necessitates that it remain disturbed.
• Revised the benchmark monitoring level for Total Suspended Solids (TSS) in the permit from 100 milligrams per Liter (mg/L) to 50 mg/L in discharges of stormwater from concrete batch-mixing plants covered under the permit. This change is consistent with the benchmark monitoring level for TSS that is required for concrete manufacturers and ready-mix concrete plants in the 2016 Multi-Sector General Permit (MSGP) TXR050000.
• Revised the definition of Construction Activity in Part I, Section B of the permit to more clearly capture “other construction-related activities” (i.e., soil disturbance that can occur from stockpiling of fill material and demolition), construction support activity, and any soil disturbance activities which have occurred in conjunction with construction-related activity and construction support activity.
• Clarified requirements for operators of small construction activities with low potential for erosion.
• Revised the language for inspections of construction sites that are consistent with the 2017 EPA CGP and requirements for inspection reports and completion of reports within 24-hours following the inspection.

Caltha LLP | Your Stormwater Permit, 

SWPPP and Spill Plan Partner

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 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

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 inspectors, certified 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.


 
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

Action On Waters of US At Supreme Court

On January 22, 2018, the Supreme Court unanimously decided a procedural issue determining the court in which challenges to the meaning of the term “Waters of the United States” (WOTUS) may be brought. The choice of court is significant because it affects the resources needed to litigate the merits of challenges, sets the statute of limitations for filing lawsuits and helps determine whether actions can be challenged in subsequent civil or criminal proceedings.

Immediate Impact of Waters of US Decision

The decision requires that any challenge to the current meaning of WOTUS must be brought in the federal district court rather than in the federal court of appeals and allowed pending litigation in the district courts to continue. Lifting the stay puts the Obama-era WOTUS definition back into effect and forces any future litigation to occur throughout the United States wherever there is a challenge to the WOTUS definition, unless it is able to get a stay in the pending litigation.

Why is Waters of the US Definition Important?

WOTUS is a key term impacting the scope of Clean Water Act. The EPA and Corps of Engineers issued the definition in May 2015. The rule was widely criticized, with many, such as farmers, home builders, and developers, claiming that the rule impermissibly allowed EPA to regulate private land. Others felt the rule narrowed federal jurisdiction. In the Supreme Court, the current Administration argued that any challenges to the meaning of WOTUS must be brought in a court of appeals; this argument was rejected in the court decision.

Under the Clean Water Act, the uncertainty as to the scope of the WOTUS rule affects whether a Federal discharge permit (NPDES permit) is required and the scope of permits needed to discharge wastewater and storm water. It also impacts whether real estate contains federally-regulated wetlands.

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.

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.

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

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

Stormwater Training, SPCC Training & Related Compliance Training

Caltha LLP provides a wide range of training programs to industrial, government and construction site dischargers to meet the requirements of State and EPA stormwater discharge permits and related spill and emergency preparedness rules.

Training can be provided to large or small groups and is provided either in person at your location, or through a live webinar format. The training sessions commonly requested include:

• Industrial stormwater discharge permit - SWPPP training
• Construction site stormwater discharge permit training
• Stormwater monitoring training
• Training for site inspections
• Hazardous waste management training
• SPCC annual training
• Spill response training
• DOT hazardous material (HazMat) triennial recertification and initial training
• Facility compliance training overview (covering a wide range of typical facility environmental compliance topics)
• Internal compliance auditor training

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

Webinar-based SWPPP Training to Meet State Permit Requirements and Facility Specific Programs

Caltha LLP offers facilities nationwide webinar based SWPPP Training meeting their individual permit requirements. Each training is customized for the facility and includes elements of the facility's unique Stormwater Pollution Prevention Plan (SWPPP).


Training is conducted in real-time and provides two-way interaction between the trainer and the trainees. Training sessions can be recorded and replayed for other shifts.


Click here to see an excerpt from a typical training session (no audio)





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

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

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

Impaired Waters and Outstanding Arizona Waters Requirements Under Proposed ADEQ Permit

The Arizona Department of Environmental Quality (ADEQ) has released a draft Construction General Permit (AZG2008-001). This permit replaces the previous construction general permit that was issued for a five-year term by ADEQ. As written, this general permit becomes effective on March 1, 2013.

The draft permit coverage has the following conditions and requirements apply if any portion of the construction site is located within 1/4 mile of a receiving water listed as impaired under section 303(d) of the Clean Water Act:

• The operator must submit a copy of the SWPPP with the NOI to ADEQ; and
• The SWPPP must include a sampling and analysis plan for analytical monitoring if there is potential for discharges from the site to include the pollutant(s) for which the receiving water is impaired. If the operator can demonstrate there is no reasonable expectation that construction activities could be an additional source of the identified pollutant(s), analytical monitoring is not required. As part of this demonstration, the operator must consider all on-site activities, including the potential for the pollutants (metals, nutrients, etc.) to be present in site soils. The demonstration must be included in the SWPPP submitted for ADEQ’s review;
• If a discharge contains pollutants for which a Total Maximum Daily Load (TMDL) has been established, the SWPPP must specifically identify control measures necessary to ensure the discharges will be consistent with the provisions of the TMDL.

For discharges to outstanding Arizona waters (OAW) the following conditions and requirements apply if any portion of the construction site is located within 1/4 mile of a receiving water listed as an OAW in A.A.C. R18-11-112(G):

• The operator must submit a copy of the SWPPP with the NOI to ADEQ; and
• The SWPPP must include a sampling and analysis plan for analytical monitoring of pollutants expected to discharge from the site, including sediment.

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

Reissued Kansas KDHE Construction Discharge Permit

The Kansas Department of Health & Environment (KDHE) reissued the Kansas General Permit for Stormwater Runoff Associated with Construction Activities on March 2, 2012 with various modifications. The new permit expires March 1, 2017 and replaces the current general permit for stormwater discharges from construction activities which remained in effect through March 1, 2012. Projects authorized prior to March 2, 2012 may operate under the previous general permit for 18 months, ending September 1, 2013. If these projects are not terminated by September 1, 2013, they must meet the requirements of the new general permit. Coverage continues from the date of authorization until the site is stabilized and the construction stormwater discharge Notice of Termination (NOT) is accepted by KDHE or the permit is revoked/terminated for cause by KDHE.

Owners or operators of any project or combination of projects who engage in construction activities which will disturb one (1) or more acres must have authorization to discharge stormwater under the Stormwater Runoff from Construction Activities General Permit S-MCST-0312-1. Construction activities consist of any activity (e.g. clearing, grubbing, excavating, and grading) which disturb a cumulative total of one or more acres or when the site is a part of a larger common plan of development or sale which will disturb a cumulative total of one or more acres.

Owners or operators of construction activities which disturb less than one acre and which are not part of larger common plan of development or sale, must have authorization to discharge stormwater runoff from construction activities under this NPDES general permit when KDHE notifies the owner or operator that the water quality impact from discharge of stormwater runoff from construction activity warrants consideration because the proposed construction activities constitute a significant pollution potential.

Major modifications in the reissued permit include:

• the addition of EPA’s Construction and Development effluent guideline standard (40 CFR 450),
• procedures for construction activities undertaken to avoid imminent endangerment to the public health or environment in response to a public emergency,
• additional best management practices for steep slopes,
• revision to the Sediment Basin Design Criteria to allow easier alternative basin detention size calculation for areas where large off-site areas drain to the basin or for areas of Western Kansas where the 2-year, 30-minute rain event is less than 1.3 inches, and
• various wording changes to clarify permit requirements.

Caltha LLP provides expert consulting services to public and private sector clients in Kansas 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

Revised EPA 2012 Construction General Permit (CGP) Released

U.S. Environmental Protection Agency (EPA) is issuing a new general permit for stormwater discharges from construction activities. The 2012 construction general permit (CGP) is required under the Clean Water Act and replaces the existing 2008 CGP, which expired on February 15, 2012. The new permit includes a number of enhanced protections for surface waters, including provisions to protect impaired and sensitive waters. The 2012 CGP updates include requirements intended to limit erosion, minimize pollution sources, provide natural buffers or their equivalent around surface waters, and further restrict discharges to areas impaired by previous pollution discharge.

Many of the permit requirements implement new effluent limitations guidelines and new source performance standards for the construction and development industry that became effective on February 1, 2010, which include pollution control techniques to decrease erosion and sediment pollution.

The permit will be effective in areas where EPA is the permitting authority: Idaho, Massachusetts, New Hampshire, New Mexico, Washington, D.C., and most U.S. territories and in Indian country lands.

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