Spill Plan Requirements For Iowa SARA 313 Reporting Facilities

The Iowa Department of Natural Resources general permit for industrial stormwater water discharges was revised in 2018 and the new permit became effective on March 1, 2018. The revised permit includes additional requirements which apply to those facilities that report under SARA 313, also known as the Toxic Release Inventory or TRI.

 Storm water pollution prevention plans for facilities subject to reporting requirements under SARA Title III, Section 313 for chemicals which are classified as "Section 313 water priority chemicals" are required to include a discussion of the facility's conformance with the appropriate guidelines listed below: In areas where Section 313 water priority chemicals are stored, processed or otherwise handled, appropriate containment, drainage control and/or diversionary structures shall be provided. At a minimum, one of the following preventive systems or its equivalent shall be used:

• curbing, culverting, gutters, sewers or other forms of drainage control to prevent or minimize the potential for storm water run-on to come into contact with significant sources of pollutants; or
• roofs, covers or other forms of appropriate protection to prevent storage piles from exposure to storm water, and wind blowing.

   

 If the installation of structures or equipment is not economically achievable at a given facility, the facility shall develop and implement a spill contingency and integrity testing plan which provides a description of measures that ensure spills or other releases of toxic amounts of Section 313 water priority chemicals do not occur. A spill contingency and integrity plan must include, at a minimum:

• a description of response plans, personnel needs, and methods of mechanical containment; steps to be taken for removal of spilled Section 313 water priority chemicals;
• access to and availability of sorbents and other equipment.
• The testing component of the alternative plan must provide for conductingintegrity testing of storage tanks at least once every five years, and conducting integrity and leak testing of valves and piping a minimum of every year; and
• A written and actual commitment of manpower, equipment and materials required to comply with the provisions of the permit and to expeditiously control and remove quantities of Section 313 water priority chemicals that may result in a toxic discharge.

Annual Employee Training For Industral Stormwater At North Dakota Food Facility

Caltha LLP Project Summary

Project: Annual Employee Stormwater Training For Food Sector Facility
Client: Food Sector SIC 20 Facility
Location(s): North Dakota

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training, Webinar

Overview: Caltha LLP was retained by this food manufacturing company to prepare and present annual SWPPP training, as required under the North Dakota Department of Health (NDDH) multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

• Overview of discharge permit
• Overview of the contents of the SWPPP;
• Spill prevention and response procedures
• Good housekeeping practices;
• Maintenance requirements
• Material management practices
• Location and maintenance of on-site stormwater pollution prevention controls;
• Operating procedures for preventing pollution; and
• Inspection procedures and records maintenance.

Training was presented by "live" webinar to all affected employees by a qualified SWPPP trainer.For more information on Caltha LLP services, go to the Caltha Contact Page

Annual Storm Water Training For Minnesota Permit

Caltha LLP Project Summary

Project: Annual SWPPP Training For Food Sector Facility
Client: Food Sector SIC 20 Facility
Location(s): Minnesota

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training

Overview: Caltha LLP was retained by this food manufacturing corporation to prepare and present annual SWPPP training, as required under the Minnesota Pollution Control Agency multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

• Overview of Discharge Permit
• Components and Goals of the SWPPP
• Stormwater Monitoring
• Monthly Facility Inspections
• Other Tasks Required By Permit

Training was presented to all affected employees by a qualified SWPPP trainer.For more information on Caltha LLP services, go to the Caltha Contact Page

SWPPP and Permit Compliance Training For Revised WDNR Tier 2 Permit

Caltha LLP Project Summary

Project: SWPPP and Permit Compliance Documentation To Meet Tier 2 Permit
Client: Concrete manufacturer
Location(s): Wisconsin

Key Elements: Facility SWPPP, stormwater inspection, visual stormwater monitoring

Overview: Caltha LLP was retained by this regional concrete manufacturer to conduct compliance reviews and prepare updated SWPPPs for two of its facilities located in Wisconsin. Both sites were covered under the WDNR Tier 2 General Permit for discharge of industrial stormwater. Caltha staff conducted a site visit and met with plant personnel to determine what updates were required to the existing facility SWPPP to meet the newly revised WDNR permit. A revised SWPPP was issued to each location which included updates to quarterly monitoring procedures, spill prevention measures, routine employee training and monthly housekeeping inspections.


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

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
info@calthacompany.com or Caltha LLP Website

Compliance With State Multi-sector Industrial General Permit | Seminar Module

The link below provides training slides from a training module on basic compliance strategies to address general permit requirements. The emphasis of the training module is to provide photograph examples of key areas which should be concerned in developing a site-specific SWPPP.

Presentation Slides: Complying with State Industrial Storm Water Requirements

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

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

How Were Stormwater Benchmark Values Developed? Historical Monitoring Data Compared To Industial Bench Marks

The following link provides a technical review of State Stormwater Benchmark values compared to historical industrial sector monitoring data.

Presentation Slides: Comparison of State Stormwater Benchmarks to Historical Industrial Sector Monitoring Results

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

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

List of Industrial Stormwater Training Providers in Minnesota | SWPPP Trainer

Caltha staff are stormwater experts, having worked with stormwater permitting and development of stormwater discharge permit compliance programs and SWPPP since the first stormwater rules were drafted in the 1980s. With this deep foundation in the stormwater rules, Caltha provides expert and cost effective storm water consultant services to clients across the US.


One of the key compliance elements is development of an Employee Training Program. Based on an individual employees job responsibilities, different level of training may be required, included training certification. Caltha provides stormwater training in a number of flexible formats, including “train the trainer”. Caltha also offers "real time" web-based training. Trainees log into a webinar format at their own work station and can interact with the trainer in real time. Training sessions are individualized for each facility.


For more information on options available for EH&S training and to request a quote, go to Caltha's Employer Environmental Health & Safety Training Center


Caltha also maintains a library of stormwater permit compliance plan templates to assist permitted sites in developing and managing their overall compliance program. Compliance plan templates incorporate State-specific requirements, such as inspections, monitoring, reporting and training, and provide an easy way to allocate resources and to develop a compliance tracking system. Caltha also conducts Non Stormwater Discharge Evaluations and provides Non Stormwater Discharge Certifications.


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

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

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

2016 Revised Pennsylvania Department of Environmental Protection’s NPDES General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03)

The Pennsylvania Department of Environmental Protection’s National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03) expired on December 5, 2015.


The Department published a draft revised permit on October 18, 2015. The PAG-03 General Permit is intended to provide NPDES permit coverage to facilities discharging stormwater associated with industrial activity to waters of the Commonwealth that are not considered High Quality or Exceptional Value. If a facility is not eligible for coverage under the PAG-03 General Permit because it is located in a High Quality or Exceptional Value watershed, it may apply for an individual NPDES permit.

Click here for a Summary of the Requirements Under the New PDEP Industrial Permit
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


For recent SWPPP news and Caltha project examples in Pennsylvania, click here.

Revised Texas Industrial Permit 2016

The Texas Commission on Environmental Quality (TCEQ) has proposed to revise the current TPDES Multi Sector General Permit (MSGP) TXR050000, issued August 14, 2011 and expires on August 14, 2016. This permit authorizes the discharge of stormwater associated with industrial activity. The revised draft MSGP specifies which facilities must obtain permit coverage, which are eligible for exclusion from permit requirements, which may be automatically authorized, and which may be required to obtain individual permit coverage.



Click here for a Summary of Proposed Changes To the Current Texas Permit


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

New Industrial Permit Requirements For Kentucky Storm Water Dichargers

Kentucky Division of Water (DOW) reissued the Kentucky Pollutant Discharge Elimination System (KPDES) General Permit for Stormwater Discharges Associated with Industrial Activity- Other Facilities (KYR000000) on May 1, 2013, with an effective date of June 1, 2013. Facilities that are subject to a promulgated national effluent guideline and those facilities that discharge to a receiving water that is subject to a TMDL for suspended solids are not eligible for coverage under the general permit. Facilities seeking new coverage, modification of existing coverage, or renewal of existing coverage are required to submit an updated eN0I-KYROO:

1. Operators seeking initial coverage for an existing facility that has commenced discharge must electronically submit the eN0I-KYROO by June 16, 2013.
2. Operators seeking modification of an existing coverage to address facility modifications must electronically submit an updated eN0I-KYROO a minimum of 15 days prior to the modification of the facility.
3. For existing coverage granted prior to September 30, 2007 the operator must electronically submit an updated eN0I-KYROO by August 29, 2013 to renew the coverage.

If a facility does not submit the updated eN0I-KYROO by the deadline, DOW will terminate of coverage, even if a facility has been permitted in the past. Facilities can seek a conditional exclusion for no exposure by filing an electronic No Exposure Certification (eNoExposure). This certification is time limited and must be resubmitted upon each reissuance of KYR000000 or every 5 years, whichever is first, in order to continue the exclusion for the next permit term.

Some of the key changes from the previous permit include:

1. Specific effluent limits for Total Suspended Solids (TSS), Oil and Grease (O&G), and pH are in place of the previous requirement to monitor and report the results of monitoring for these parameters. Monitoring is no longer required for Chemical Oxygen Demand (COD).
2. The Stormwater Best Management Practices (SWBMP) Plan will now be refered to as a “Stormwater Pollution Prevention Plan (SWPPP).”
3. Inspections with subsequent written reports to document the findings of the inspections would be required on a minimum weekly basis and in response to 2-year, 24-hour storm events that occur.
4. The SWPPP Site Map must include additional features to be shown including directions of stormwater flow, locations of impaired waters and any TMD’s associated with them, and locations of stormwater monitoring points.
5. The SWPPP must include procedures for preventing and responding to spills, and schedules for inspections, preventive maintenance, and employee training required.
6. The SWPPP must contain a daily precipitation log, incident reports in response to spills, employee training records, and control measure maintenance and repair logs.

Caltha LLP maintains a library of SWPPP templates to meet general permit requirements for individual States, including Kentucky. Caltha has revised our Kentucky SWPPP template to meet new permit requirements and is using this SWPPP Template to support our clients located in Kentucky.
 For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

New General Stormwater Discharge Permit For Marina Operations In Ohio

The Ohio Environmental Protection Agency (OEPA) has issued an industrial stormwater discharge permit specifically to cover marinas which would otherwise need to apply for coverage under the Ohio multisector general permit (MSGP). Marinas nationwide are subject to industrial stormwater under the Transportation Sector. OEPA under General Permit No. OHRM00002 became effective on January 22, 2013. Marinas that wish to be covered under this permit are required to submit an application (“Notice of Intent, or NOI”) to OEPA.

Compliance requirements under the Marina general permit are similar in many ways to the Ohio MSGP, including:

• Requirement to prepare and implement a stormwater pollution prevention plan (SWPPP) meeting the requirements listed in the permit
• Requirement to eliminate non-stormwater discharges
• Requirement to conduct regular facility inspections
• Requirement to develop and implement an employee training program
• Requirement to conduct regular visual monitoring of stormwater discharges.

Read a summary of the Ohio Multisector General Permit

There are some important differences also:

• Marinas are allowed to discharge wash water from boat cleaning, although cleaning of engines or other oily parts is prohibited; use of detergents or other chemical cleaning agents is prohibited.
• Larger marinas (greater than 200 total slips) must conduct chemical monitoring of stormwater discharges on an annual basis.

Read a summary of Ohio general permit monitoring requirements for marinas

Read about Caltha’s new SWPPP Template and Compliance Plan Template for the Ohio marina general permit


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

Benchmark Monitoring Requirements Under MDE Draft Industrial General 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

One of the key difference in the draft permit compared to the EPA MSGP is that MDE chose to focus on reducing stormwater volume rather than on benchmark monitoring for specific pollutants. MDE evaluated the full list of benchmark monitoring requirements in the MSGP, and narrowed the selection down to three industries that have the highest potential for metals in their stormwater,

1. Subsector C1 – Agricultural Chemicals for (SIC 2873-2879), part of Sector C - Chemical and Allied Products Manufacturing, and Refining (Nitrate plus Nitrite Nitrogen at 0.68 mg/L, Total Lead at 0.014, Total Iron at 1.0 mg/L, Total Zinc at 0.04 mg/L and Phosphorus at 2.0 mg/L).
2. Sector M – Automobile Salvage Yards (Total Suspended Solids (TSS) at 100 mg/L, Total Aluminum at 0.75 mg/L, Total Iron at 1.0 mg/L, Total Lead at 0.014 mg/L).
3. Sector N – Scrap Recycling and Waste Recycling Facilities (Chemical Oxygen Demand (COD) at 120 mg/L, Total Suspended Solids (TSS) at 100 mg/L, Total Recoverable Aluminum at 0.75 mg/L, Total Recoverable Iron at 1.0 mg/L, Total Recoverable Lead at 0.014 mg/L, Total Zinc at 0.04 mg/L, Total Recoverable Copper at 0.0038 mg/L).
4. Sector AA – Fabricated Metal Products (Nitrate plus Nitrite Nitrogen at 0.68 mg/L, Total Zinc at 0.04 mg/L)

Benchmark monitoring must occur during the first 4 full quarters of permit coverage after the permittee is granted access to NetDMR. If the average of the 4 quarters of monitoring values exceeds the benchmark, the permittee is required to either:
1. perform corrective actions, and conduct an additional 4 quarters of monitoring until the average value is below the benchmark, or
2. determine that no further pollutant reductions are technologically available and economically practicable and achievable in light of best industry practice to meet applicable effluent limits, and continue to monitor once-per-year.

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

Final Rule On Logging Roads As Industrial Discharges

On December 7, 2012, EPA published a final rule clarifying that stormwater permitting is not required for logging roads. The Agency had proposed the rule in September in response to a 2011 citizen suit brought before the Ninth Circuit Court . The suit alleged violations of the Clean Water Act (CWA) against a logging company for discharging stormwater from ditches alongside two logging road in state forests without a permit.

The court decided that because the stormwater runoff from the two roads in question is collected by and then discharged from a system of ditches, culverts, and channels, it was a point source discharge of industrial stormwater for which a National Pollutant Discharge Elimination System (NPDES) permit would be required.

According to EPA, the agency never intended for logging roads to be regulated as industrial facilities. Therefore, the Agency revised 40 CFR 122.26(b)(14) to clarify its intent. The final rule will be effective on January 7, 2013. EPA believes stormwater discharges from forest roads, including logging roads, should be evaluated under section 402(p)(6) of the CWA because the section allows for a broad range of flexible approaches that are better suited to address the complexity of forest road ownership, management, and use. The final rule adds language to existing Phase I stormwater regulations to clarify that, for the purposes of assessing whether stormwater discharges are “associated with industrial activity,” the only facilities that would qualify as “industrial” would be rock crushing, gravel washing, log sorting, and log storage.

Caltha LLP provides technical support services to industrial facilities nationwide to complete individual and general permit application materials and to develop storm water permit compliance plans and stormwater pollution prevention plans (SWPPP). For more information, go to:
Caltha Stormwater Permitting and Compliance Page

Final North Carolina Industrial General Permit Effective December 1, 2012

North Carolina NPDES General Permit NCG060000 expired on October 31, 2012, which regulates stormwater discharges from a number of industrial sectors including:

• Food and Kindred Products [standard industrial classification (SIC) 20],
• Tobacco Products (SIC 21),
• Soaps, Detergents and Cleaning Preparations; Perfumes, Cosmetics and Other Toilet Preparations (SIC 284),
• Drugs (SIC 283), and
• Public Warehousing and Storage (SIC 4221-4225), 

The North Carolina Division of Water Quality (DWQ) released a draft of the proposed renewal General Permit in September 2012 and the public comment period closed on October 8th.

DWQ received several public comments and EPA Region IV responded that the agency concurred with no comments. Based on the comments received, DWQ revised the draft permit before finalizing. The revisions included:

1. Part II, Section A (Stormwater Pollution Prevention Plan), Added language to include petroleum products and reference how federal oil Spill Prevention, Control, and Countermeasure Plan (SPCC) can fulfill some requirements of the Stormwater Pollution Prevention Plan (SPPP) where it demonstrates compliance.
2. Part II, Table 1 (Analytical Monitoring for Stormwater), Footnote 3: Added clarification that DWQ’s representative outfall status (ROS) approval remains in effect through subsequent renewals as long as relevant site conditions and operations have not changed.
3. Part II, paragraph following Table 1: Language added to specify that “Sampling is not required outside of the facility’s normal operating hours.”
4. Part II, paragraph following Table 2: Language modified to include option for Division to require monthly monitoring because of a failure to monitor semi-annually (rather than automatically requiring monthly monitoring upon failure to monitor). Also, clarification that adverse weather conditions preventing sample collection does not constitute a failure to monitor.
5. Part II, second paragraph following Table 2: Added clarification that DWQ’s release of a permittee from Tier 2 monthly monitoring remains in effect through subsequent renewals unless other conditions are specified.
6. Part II, Table 3: Modified Footnote 1 to allow precipitation pH (if lower than 6 s.u.) as lower benchmark value.

In final permit was issued in late November with the effective date December 1, 2012.

Caltha LLP maintains a library of SWPPP templates to meet general permit requirements for individual States, including North Carolina. Caltha is currently revising the North Carolina SWPPP template for NPDES General Permit NCG060000 to meet any new requirements and will use this to support our clients located in North Carolina that are subject to this general permit.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Revision To Phase I Stormwater Regulations

US EPA has announced that it intends to propose revisions to its Phase I stormwater regulations (40 CFR 122.26) to specify that stormwater discharges from logging roads are not included in the definition of "storm water discharge associated with industrial activity." EPA is taking this action in response to the 9th Circuit Court of Appeals decision in Northwest Environmental Defense Center (NEDC) v. Brown, which addressed the question of whether discharges from certain logging roads require National Pollutant Discharge Elimination System (NPDES) permits.

The Agency intends to clarify that a permit is not required for these discharges.


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

Cost Analysis For Compliance With Revised Industrial Permit

The California State Water Resources Control Board (State Water Board) has released its cost analysis comparing estimated costs associated with the current Industrial General Permit (ICP), the draft revised permit issued in 2011, and the draft revised permit issued in July 2012. The purpose of the analysis is to provide an estimate of the compliance costs associated with the State Water Board’s Statewide General Permit for Discharges of Storm Water Associated with Industrial Activity (IGP).

Read a summary of the 2012 California IGP: http://www.calthacompany.com/Draft_California_Industrial_Stormwater_Permit_Summary.pdf

The key finding of the report are that the average annual cost of compliance of the 2012 permit for facilities with no exceedances would increase between 5% and 12% compared to the annual cost of compliance with the 1997 IGP. Annual average cost of compliance with the new permit depends on multiple factors including size of operations, location, and level of exceedances. Staff estimated annual compliance costs for the 1997 IGP to range between $23,000 to approximately $137,000. For facilities with no exceedances, compliance with the 2012 draft will cost between $25,000 and approximately $155,000 annually.

The increase in compliance costs would be more significant for those facilities with exceedances. Staff does not expect a significant increase in compliance costs for those facilities with no exceedances. Facilities with exceedances would see a more significant increase in costs to bring the facility in compliance. Facilities with Level 1 status (one NAL exceedance) would face an additional annual average cost between $97 and $622. Facilities with Level 2 status (second NAL exceedance for same parameter) would face an additional annual average cost between $1,138 and up to $38,641.

The annual average cost of compliance with the 2012 draft is approximately half (50% less) of what the 2011 draft originally required. Based on Water Board staff’s best judgment, the most likely scenario is that 50% of facilities will have no exceedances, 50% of facilities will reach Level 1, and 25% will reach Level 2. Using this assumption, the total annual average compliance costs of the 2012 draft as compared to the 1997 IGP would be increased by approximately 7% for industry as a whole.

The most commented upon elements of the draft 2011 IGP were the proposed numeric effluent limitations (NELs), the increased number of reportable inspections and/or visual observations, and the compulsory training requirements. In response to these comments, NELs have been eliminated, revisions and clarification were made so that the number of inspections and visual observations are the same as the 1997 IGP (with the exception of pre-storm visual observations), and the compulsory training requirement has been simplified. Additionally, a new ERA system has been proposed that (1) more narrowly focuses on those facilities with the highest concentrations of pollutants, and (2) allows dischargers to avoid costly structural or treatment controls if it is proven that the pollutant concentrations are related to non-industrial sources, natural background conditions, or if the facility is already in compliance with BAT/BCT.


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