Overview Training - Clean Water Act And Related Rules And Programs

Overview of Clean Water Act 

Click link above to download presentation slides.

Overview of the Clean Water Act and underlying programs. Clean Water Act; CWA; wastewater; NPDES; pretreatment permit; water quality standards; permit limits; effluent guidelines; effluent standards; waters of the US, water quality criteria, SPCC rule

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.

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
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Zinc and Nickel In Industrial Stormwater - Key Zinc Sources At Industrial Facilities

Many facilities are required under their industrial stormwater permit to monitor metal concentrations. Two of the most common metals detected are zinc and nickel.
Considering zinc, 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.

Both motor oil and hydraulic fluid contain high concentrations of zinc, about 0.1% by weight. As an example, just 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.

Link to a technical analysis of stormwater benchmarks compared to historical industrial sector monitoring data

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

Impaired Waters and Antidegradation Requirements In Draft Maryland Industrial Permit

Maryland Department of the Environment (MDE) is issuing a draft General Permit Number 12-SW of stormwater discharges from industrial facilities. MDE has chosen to base the state’s permit on the EPA’s Multi-Sector General Permit (MSGP). The draft permit will replace the General Permit Number 02-SW that was issued for a five-year term on December 1, 2002. The General Permit 02-SW expired on November 30, 2007 but was administratively continued for facilities that were covered under the permit at the time it expired. The final permit is expected to be issued in early 2013.

Read a summary of the key changes to the Maryland General Permit.

Information about Maryland General Permit SWPPP Template and Compliance Plan

The draft permit contains new, specific WQBEL requirements applicable to impaired waters and antidegradation policies:

• Discharges to Impaired Waters – The permit contains requirements for new and existing discharges to impaired waters with or without EPA approved or established TMDLs. New dischargers are only eligible for discharge authorization if they demonstrate that there is either no exposure of stormwater to the pollutant for which the water is impaired, or the impairment pollutant is not present at the facility, or that the discharge is not expected to cause or contribute to a water quality standards exceedance. For existing discharges to impaired waters with State approved or established TMDLs, MDE will determine if more stringent requirements are necessary to ensure that the permittee is discharging consistent with the TMDL and applicable WLA.
• Antidegradation Requirements – MDE has clarified its expectation of operators to meet antidegradation requirements as part of the permit authorization process as well as to comply with permit provisions after authorization to discharge is received. If an NOI indicates that an operator is seeking coverage for a new discharge to a Tier 2 water, MDE will determine if additional requirements are necessary to be consistent with the applicable antidegradation requirements, or if alternatively, an individual permit application is necessary. New dischargers are no longer eligible for coverage under this permit for discharges to waters designated as Tier 3 for antidegradation purposes.

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

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

New or Expanded Stormwater Discharges Under Proposed MPCA Nondegradation Policy

The Minnesota Pollution Control Agency (MPCA) has been attempting to revise the Minnesota Nondegradation Policy for several years. One major issue has been how rule will apply to stormwater discharges, because the existing policy was developed to apply to traditional point source discharges.

In September 2012, MPCA released its proposed revision to the State Nondegradation Policy. Under the proposed rule, MPCA will address future nondegradation requirements for stormwater discharges as new permits are issued. For new, reissued, or modified stormwater permits, agency will conduct nondegradation review. This review will include an analysis of prudent and feasible alternatives that avoid and minimize net increases in loading or other causes of degradation. The agency will then select the least degrading prudent and feasible alternatives identified. Therefore, with the final revision of the Nondegradation Policy, as currently proposed, the requirements for new or expanded stormwater discharges will not be clarified. These requirements will be incorporated into various permits (e.g, industrial, construction, MS4) issued in the future.

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 Washington Industrial Permit Effective July 1, 2012

The Washington Department of Ecology (Ecology) has issued a final modified Industrial Stormwater NPDES and State Waste Discharge General Permit May 16, 2012. The modified permit is effective July 1, 2012. The permit modification is necessary to address the April 25, 2011 order by the Washington State Pollution Control Hearings Board, which required significant changes to the sampling and corrective action requirements. Ecology has also made revisions to the effluent limits for fecal coliform that apply to approximately 80 facilities discharging to 303(d)-listed impaired waterbodies. Other minor changes were made in response to public comments and to correct various errors and typos.

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.
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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.

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New Benchmark Monitoring Requirements For Discharges To Impaired Waters

The 2012 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity (2012 IGP) was issued as a third draft for public comment on January 17, 2012. Comments are being accepted from January 17 to March 16, 2012. Georgia Department of Natural Resources - Environmental Protection Division (EPD) anticipates the final industrial permit will be issued in April 2012.

Review a Regulatory Briefing on the Georgia 2012 IGP

The 2012 IGP has certain requirements that apply only to facilities that discharge either directly to an impaired water, or to a tributary to an impaired water, if the facility is located less than one mile from the impaired water. An impaired water is a water body, or part of a water body, that does not meet State Water Quality Standards and has been placed on the 303(d) Impaired Waters list submitted to and approved by US EPA.

If the pollutant of concern (POC), such as sediment, could be exposed and/or could be contained in the stormwater run-off, facilities are required to conduct benchmark monitoring twice each quarter, rather than once per year. In addition, the applicable benchmark concentration becomes equal to the State Water Quality Standard, and not the sector-specific benchmarks in the 2012 IGP (which are generally higher). If benchmarks are not exceeded, sampling could be reduced to twice per year.

For those facilities that conducted impaired waters monitoring under the previous permit (2006 IGP) and passed all benchmarks, the additional monitoring under the 2012 IGP is twice per year.

Some facilities may be able to certify that the POC is not present at the facility, in which case they are not required to conduct the additional impaired water monitoring. Finally, some facilities may be able to conduct studies or analyses that demonstrate that their stormwater discharge will meet applicable Water Quality Standards. In this case, the analysis must be certified by a Professional Engineer or Professional Geologist and approved by EPD.

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

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Draft Georgia Industrial General Permit Released For Public Comment

The Georgia Environmental Protection Division (EPD) has released a draft Industrial General permit (“2011 IGP”) that will replace the previous general permit (”2006 IGP”) which will expire in August 2011. The draft 2011 IGP is based to a large degree on the US EPA Multi-sector General Permit promulgated in 2008 (“2008 MSGP”). Below are some key changes in the proposed Georgia storm water permit

Current permittees covered under the 2006 IGP will be required to submit a new Notice of Intent (NOI) within 30 days after the effective date of the new permit. New dischargers commencing discharge after the effective date of the 2011 IGP must submit an NOI for coverage 7 days prior to commencing discharge. Also, existing facilities which had previously filed for a “No Exposure Exclusion‟ (NEE) must submit a new NEE form no later than 30 days after the effective date of the 2011 IGP. The 2011 IGP requires facilities that claim they have no storm water discharges associated with industrial activity file a “No Discharge Exclusion” (NDE) form which must be certified by a professional engineer

If a facility failed the benchmark sampling required by the 2006 permit, then the facility may not be authorized to discharge storm water under the proposed permit and may be required to apply for an individual NPDES permit or alternative general permit. The facility has the options 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 18 months

The 2011 IGP stormwater benchmarks are a combination of benchmarks from the 2006 IGP and the 2008 MSGP. The 2011 IGP requires all analytical sampling performed during the term of the previous 2006 IGP be summarized and the summary retained until the end of the next permit term. In the 2011 IGP, all monitoring data not prepared in situ is required to be prepared by a laboratory registered or accredited by the State or by a State certified Laboratory Analyst. If there is an exceedance of a benchmark value, under the 2011 IGP the facility is required to make modifications of best management practices (BMPs) and sample each subsequent quarter until the benchmark is met, or must make a determination that no further pollutant reductions are technologically available and economically practicable.

At least once during the term of the 2011 IGP, a dye or smoke test must be conducted to evaluate for the presence of non-storm water discharges into the storm sewer system, where applicable

The impaired stream segment sampling and requirements of the 2011 IGP apply to all dischargers located within one linear mile of an impaired water. In the 2006 IGP, only those facilities discharging to streams with an approved total maximum daily load (TMDL) had requirements associated with an impaired stream segment. In the 2011 IGP, dischargers to all impaired waters identified in the Georgia 305(b)/303(d) list are required to monitor for appropriate parameters, and corrective action is required if the discharge exceeds the benchmark value, pollutant of concern (POC) listed in the TMDL, as appropriate. Compliance alternatives in the 2011 IGP include a) preventing all exposure, b) documenting that the POC is not present at the site, c) showing that the discharge containing the POC is not likely to cause or contribute to an exceedance of water quality standards, or if the ability of a discharge to cause or contribute to an exceedance of water quality standards is unknown, then d) executing BMPs and evaluating their effectiveness.

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

For further information contact Caltha LLP atinfo@calthacompany.comorCaltha LLP Website

Trash Limits for MS4s in Anacostia Watershed - Trash TMDL

U.S. EPA, the District of Columbia, and the state of Maryland have announced a new Total Maximum Daily Load (TMDL) for trash in the Anacostia River, making the Anacostia the first interstate river in the nation with such a Clean Water Act (CWA) trash limit. Each year, hundreds of tons of trash and debris are illegally dumped or washed into the Anacostia with stormwater runoff. As a result, the District and Maryland have both included the Anacostia River on their respective lists of impaired waters due to excessive quantities of trash and debris.

The TMDL requires capturing or removing more than 600 tons (1.2 million pounds) of trash from the watershed annually. To complement this TMDL, the EPA, as the permitting authority for the District, and the state of Maryland are developing MS4 storm sewer permits which will serve as key implementation tools requiring municipalities in the Anacostia watershed to achieve the trash reductions required in the TMDL. In addition, continued implementation of the Combined Sewer Overflow Long Term Control Plan for the District of Columbia supports achievement of the limits.

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

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CT DEP Revised Industrial Stormwater General Permit

The Connecticut Department of Environmental Protection (DEP) has revised the requirements for management of storm water runoff from industrial sites under its General Permit program.
The revised industrial storm water General Permit is scheduled to go into effect Oct. 1, 2011. DEP is in the process of reissuing the existing General Permit so that it will remain in effect until that date. Industrial facilities will automatically remain registered under the existing General Permit once it is reissued. All industrial facilities are required to register for the revised permit by June 1, 2011. To provide compliance assistance to permittees, DEP will conduct outreach on new permit requirements in the fall of 2010.

The most significant new requirements of the General Permit for management of storm water at industrial sites include:

Industrial Sectors
The provisions of the General Permit apply to all sites, however there are additional sector-specific requirements for monitoring and stormwater controls that apply to specific types of industries. The sectors are:

• asphalt plants;
• non-metallic mines and quarries;
• refuse systems;
• auto salvage yards;
• scrap recycling facilities;
• steam electric power facilities;
• transportation and public works facilities;
• marinas and yacht clubs and boat dealers;
• ship and boat building and repair;
• small scale composting facilities.
  

Monitoring
The revised permit requires all permittees to conduct visual monitoring of storm water discharges on a quarterly basis and sampling and testing of storm water for 10 parameters on a semi-annual basis. In addition to these standard requirements, some industry sectors have additional parameters that are specific to the industry type, which must be also sampled.

Note: Since the 1980s, the U.S. Environmental Protection Agency (EPA) has collected industry-sector data on stormwater discharge. The linked presentation provides a comparison of these historic industrial stormwater results to the many of the ADEQ stormwater benchmark concentrations. The results are discussed in context of which stormwater benchmark parameters have a higher potential for exceedance of benchmark values. This presentation also discusses which of the industrial sectors have a higher potential for exceedance of their specific benchmark values.

Note: CT uses the same benchmark concentrations used by EPA and many other States; although the this linked presentation was specific to Minnesota, the analysis and conclusions apply to CT.

Link to presentation slides:

Industrial Stormwater Benchmarks – Comparison of New Minnesota Benchmark Concentrations To Historic Industry-specific Testing Results



Impaired waters
The revised permit includes specific requirements for discharges to impaired waters. For existing discharges, a permittee will monitor annually for the pollutant(s) associated with the water impairment. In certain cases, a permittee will have to install additional site controls to improve storm water quality so that the impaired water quality can be improved. New discharges to impaired water will be authorized if the storm water discharge does not contain the pollutant(s) of concern, or if the site prevents the exposure of the pollutant(s) of concern to storm water. However, if the pollutant(s) are present onsite and exposed to storm water, the registrant must demonstrate that the discharge meets requirements in place to meet water quality before the discharge can occur.

Public Notice
The General Permit expands opportunities for public comment and access to information about pending registrations. Pollution Prevention Plans can also be reviewed, with the exception of elements that are trade secrets or otherwise exempt from the disclosure requirements of the state Freedom of Information Act. Notice of pending registrations and the availability of Pollution Prevention Plans for a site will be posted on the DEP website for public review and comment.

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

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Suspended Solids Limits In Runoff To Chesapeake Bay

EPA has announced plans to issue draft sediment limits as the next step in establishing the Watershed Implementation Plans (WIPs) for the Chesapeake Bay Total Maximum Daily Load (TMDL). The six States within the Bay watershed are expected to use sediment limits, along with those previously issued for nitrogen and phosphorus, as the basis for completing their WIPs This plans would also detail how States will further divide these limits among pollution sources, and what best management practices and stormwater controls will be implemented to meet water quality standards.

The first drafts of the State WIPs are due to EPA by September 1. On September 24, EPA plans to issue a draft TMDL and open a 45-day public comment period, including 18 public meetings. The final WIPs are due November 29, and EPA will establish the final Bay TMDL by December 31.

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 atinfo@calthacompany.comorCaltha LLP Website

Revised MS4 Stormwater Regulation - Post Construction Retrofit

In 2006, National Research Council (NRC) conducted a review of the US EPA stormwater program and recommend ways to strengthen it. The NRC Report, which was finalized in October 2008, found that the current stormwater program "...is not likely to adequately control stormwater's contribution to waterbody impairment." and recommended that EPA take action to address the effects of stormwater flow.

In response to this review, EPA is currently revising the municipal (MS4) stormwater program, and plans to establish requirements for managing stormwater discharges from new development and re-development. This action may also expand the areas subject to Municipal Separate Storm Sewer Systems (MS4) permits to include rapidly developing areas and to cover some discharges that are not currently regulated. A single set of stormwater requirements may be developed to combine both Phase I and Phase II MS4s. EPA currently believes that retrofitting for existing discharges may be addressed, although expectations for retrofitting will likely differ significantly from requirements for new- and re-development.

The initiative to revise the MS4 permitting program began in September 2009; EPA currently anticipates finalizing the revision in September 2011.

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

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New Regional Permiting and SWPPP Requirements In MA

EPA will require new measures to control stormwater pollution in the Charles River watershed. Under a proposed pilot program large industrial, commercial and multi-family residential facilities in three communities in the Upper Charles River Watershed will be required to reduce polluted runoff from their properties. This initiative is part of a continuing, multi-faceted effort to restore the Charles River.

The EPA action will apply to properties with two or more acres of impervious area in the Towns of Milford, Franklin, and Bellingham, Massachusetts. Property owners with two or more acres of impervious surfaces will now be required to obtain an EPA discharge permit, and to take steps to reduce pollutants in stormwater.

The permit is designed to encourage private property owners and municipalities to work together, to produce a comprehensive approach to storm water management. Under the EPA program, property owners can choose to control their own stormwater to specified standards, or can work with their town government on a community-wide approach. Facilities can choose from a simple menu of stormwater controls, and receive specified credits to meet their reduction requirement. The permits will require that these facilities reduce phosphorus discharges by 65 percent through a variety of stormwater management practices. Ultimately, these requirements will likely apply to the entire Charles River watershed.

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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Massachusetts DEP Proposed Stormwater Regulations

The Massachusetts Department of Environmental Protection (DEP) is proposing a new approach to stormwater management which will require private owners of large impervious surfaces (including institutions, commercial, industrial and residential properties) to manage stormwater. The draft requirements include:

• Statewide private property owners of impervious surfaces ≥5 acres will be required to implement good housekeeping practices,
• Statewide private new developments with impervious surfaces ≥5 acres will be required to meet the state’s Stormwater Standards 3-6, including recharge and water quality treatment,
• Redevelopments with impervious surfaces ≥5 acres must maintain the same level of stormwater control and recharge, to the extent site constraints allow.

In areas that drain to an impaired waters with an existing or pending TMDL, a 65 % reduction in phosphorus load is required to achieve compliance with the State’s water quality standards.

Private property owners of impervious surfaces ≥2 acres will also be have requirements under the new program. New projects and redevelopments will have to meet statewide requirements and implement stormwater Best Management Practices (BMPs) capable of reducing phosphorus. Existing properties will be given 10 years to retrofit their properties to meet the phosphorus reduction requirement. TMDL areas include the Charles River watershed (with a 65% phosphorus reduction requirement) and a number of lake watersheds across the state.

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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Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits

A New Topic Page has been created:

Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits

Discussion of a variety of topics related to State and Federal Water Quality Standards, Ambient Water Quality Criteria, Sediment Criteria, NPDES & Site-specific Discharge Standards, Water Quality Management, Aquatic Toxicology, Aquatic Community Impacts, and Water Quality Assessment

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Numeric Nutrient Water Quality Criteria Requirement for FL

The US Environmental Protection Agency (EPA) has recently announced that the agency is taking actions to develop the required Nutrient Water Quality Criteria within the State of Florida. These actions include EPA issuing a formal determination under the Clean Water Act that “numeric” nutrient water quality criteria are necessary in Florida, and Florida needs to accelerate its efforts to adopt numeric nutrient criteria into state regulations.

EPA believes that water quality degradation from nutrient pollution is a significant issue in Florida. Florida’s 2008 Integrated Water Quality Assessment estimated that at least 1,000 miles of rivers and streams, 350,000 acres of lakes, and 900 square miles of estuaries are impaired by nutrients. The new numeric nutrient water quality standards will help the Florida Department of Environmental Protection (FDEP) improve the efficiency and effectiveness of its water quality management tools, identify waters impaired because of nutrient pollution, establish total maximum daily loads and Basin Management Action Plans, and derive National Pollutant Discharge Elimination System permit limits.

EPA expects to propose numeric nutrient standards for lakes and flowing waters within 12 months, and for estuaries and coastal waters within 24 months.

Caltha LLP provides expert technical support to clients nationwide to address State water quality standards. Caltha provides specialized expertise in biomonitoring, aquatic toxicology and impacts to aquatic communities.

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Biomonitoring Requirements - Amendment to OK Rules

The Oklahoma Department of Environmental Quality (ODEQ) is proposing to modify its rules concerning biomonitoring (whole effluent toxicity, or WET) requirements for wastewater dischargers. Under the proposed rules, a sublethal test failure (failure to demonstrate growth or reproduction) will be handled the same as a lethal test failure (death to the test organisms). This change is required based on changes in US EPA requirements and has already been promulgated into Oklahoma’s Water Quality Standards.

The proposed rule modifications also refine when a facility may request a biomonitoring organism change from Daphnia pulex or Ceriodaphnia dubia to Daphnia magna. Finally, the proposed rule modifications would also require monthly monitoring for phosphorus and/or nitrogen if a facility is discharging to a nutrient limited watershed as designated by Oklahoma’s Water Quality Standards.

Caltha LLP provides expert technical support to clients nationwide to address State water quality standards. Caltha provides specialized expertise in biomonitoring, aquatic toxicology and impacts to aquatic communities.

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