State Spill Plan, SPCC Plan, Contingency Plan Requirements

Caltha LLP maintains a library of SPCC Plan Templates developed to meet the above ground tank and spill prevention and response requirements of individual States and the Federal SPCC Rule. An SPCC Plan is require for any facility that exceeds an oil storage capacity of 1,320 gallons. Facilities potentially subject to the SPCC Rules (40 CFR 112) are not limited to industrial sites, but can include municipal, commercial, retail, institutional sites, construction sites, and even farms.

Leaking Fuel Tanks And Refueling Area 

Without Properly Sized Secondary Containment

The revised SPCC Rule now allows the use of streamlined SPCC plan formats if facilities meet certain criteria. These streamline SPCC Template plans do not need to be signed by a professional engineer in most States. Other SPCC plans may need to be reviewed and signed by an engineer. Caltha LLP also provides SPCC training for companies subject to the SPCC Rule and conducts SPCC inspections.

Caltha prepares SPCC Plans for the following States: [Click on a State to request information and options]

Alabama SPCC Plan

Alaska SPCC Plan
Arkansas SPCC Plan
California SPCC Plan
Connecticut SPCC Plan
Florida SPCC Plan
Georgia SPCC Plan
Illinois SPCC Plan
Indiana SPCC Plan
Iowa SPCC Plan
Kansas SPCC Plan
Kentucky SPCC Plan
Louisiana SPCC Plan
Maine SPCC Plan
Massachusetts SPCC Plan
Michigan SPCC Plan
Minnesota SPCC Plan
Mississippi SPCC Plan
Nebraska SPCC Plan
Nevada SPCC Plan
New Jersey SPCC Plan
New York SPCC Plan
North Carolina SPCC Plan
North Dakota SPCC Plan
Ohio SPCC Plan
Oklahoma SPCC Plan
Oregon SPCC Plan
Pennsylvania SPCC Plan
South Carolina SPCC Plan
South Dakota SPCC Plan
Tennessee SPCC Plan
Texas SPCC Plan
Utah SPCC Plan
Virginia SPCC Plan
Washington SPCC Plan
Wisconsin SPCC Plan

Warehousing and Logistics Facilities Needed Storm Water Permit And SWPPP

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: International Retailer
Location(s): California, Washington, Utah, Georgia, Florida, Virginia, North Carolina, Pennsylvania, Ohio, Massachusetts, New York, Kansas, Virginia, Louisiana, Texas, Tennessee, Minnesota, Illinois, Indiana, South Carolina, Colorado, Nevada, New Jersey, Connecticut, Missouri

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this international retailer at multiple logistics and warehousing locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State or EPA application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

Leaking Hydraulic System On Trash Compactor 

Contaminates Stormwater Discharge

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

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

Guidance and Rules For Salt Storage in Ohio

Ohio EPA has released a guidance document on the elements of salt storage that are relevant to preventing contamination include siting, design, and operation. The document provides guidance on salt storage practices to prevent the contamination of ground water and surface water. “Salt”, as used here, includes solids such as the popular sodium chloride (NaCl), as well as potassium chloride (KCl), calcium chloride (CaCl2), and magnesium chloride (MgCl2). It also includes mixtures of the same substances with abrasives such as sand, cinder, slag, etc.

Summary of Regulatory Requirements Affecting Salt Storage Operations in Ohio


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

Ohio Antidegradation Requirement Under Revised Industrial Permit

Antidegradation rules have been required since 1972, and set standards that need to be meet for New or Expanded discharges. These rules also establish additional evaluations, controls, and sometimes prohibit discharges to selected high value water bodies.

The Ohio EPA has recently proposed antidegradation requirements that will apply to industrial stormwater discharges under the State of Ohio Multisector general permit (MSGP) for industrial stormwater. In order to comply with the Ohio Antidegradation Rules, facilities that were not authorized to discharge storm water by an NPDES industrial storm water general permit prior to February 11, 1996 are not eligible for coverage under the revised general permit if the site discharges to outstanding state waters, superior high quality waters or outstanding national resource waters, other than Lake Erie, as defined by and identified in rule 3745-1-05 of the Ohio Administrative Code, or direct tributaries to these waters within 1 mile of these waters.

Facilities excluded from coverage under the revised general permit will need to permit stormwater discharges by other means, and will need to meet antidegradation requirements.

[Read summary of OEPA general permit]

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

Ohio SWPPP Template, Inspection Checklists and Compliance Plan

The Ohio Environmental Protection Agency (OEPA) has proposed a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP. This permit will replace the existing Ohio general permit, which expires on May 31, 2011. The draft Ohio general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For most facilities subject to the existing general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP.


[read a Regualtory Briefing on the revised Ohio MSGP]


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 Ohio permit requirements, including Ohio specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Ohio Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the OEPA general permit.


For further information on Caltha's Ohio SWPPP Templates (or other State SWPPP templates), email: info@calthacompany.com



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

Determining Benchmark Concentrations For Metals Under Draft Ohio MSGP

The Ohio Environmental Protection Agency (OEPA) has released its draft Multi-sector General Permit (MSGP) which, once finalized, will replace the existing industrial stormwater discharge general permit, which will expire on May 31, 2011. The draft MSGP is modeled after the US EPA MSGP, released in 2008, and is significantly different compared to the existing Ohio permit.

One of the key changes is the requirement for most permitted facilities to conduct benchmark monitoring of their industrial storm water discharge. Results are compared to a list of sector-specific benchmark concentrations to determine if improvements to the stormwater pollution prevention program are needed, and whether or not further benchmark monitoring is needed.

The benchmark concentrations for each sector are listed in the permit, with several important exceptions. These are benchmarks for seven metals:

• Beryllium



• Cadmium



• Copper



• Lead



• Nickel



• Silver



• Zinc
  

The benchmarks for these chemicals must be calculated for each individual facility based on the hardness of the receiving water, which each facility must determine. This will require individual facilities or groups of facilities to collect additional samples and do additional testing prior to starting their benchmark monitoring program.

The necessity to determine site-specific stormwater benchmarks only affects certain Ohio discharges, includes some or all facilities in fall into ten of the industrial sectors:

Sector A – Timber Products
Sector C – Chemical and Allied Products Manufacturing, and Refining
Sector F – Primary Metals
Sector G – Metal Mining
Sector K – Hazardous Waste Treatment, Storage, or Disposal Facilities
Sector M – Automobile Salvage Yards
Sector N – Scrap Recycling and Waste Recycling Facilities
Sector Q – Water Transportation Facilities
Sector Y – Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
Sector AA – Fabricated Metal Products

Caltha LLP provides expert consulting services to public and private sector clients in Ohio and nationwide to address stormwater permitting & regulatory support, including determination of stormwater benchmarks for water hardness dependant metals, development of Stormwater Pollution Prevention Plans (SWPPP) using a SWPPP template prepared to meet the new permit requirements, stormwater monitoring and stormwater training.

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

Draft Ohio Industrial Permit, Stormwater Monitoring and Effect of Hardness on Benchmarks

The proposed stormwater monitoring requirements in the proposed General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP) include both effluent monitoring requirements for some facilities and benchmark monitoring requirements for most permitted facilities in Ohio. Consistent with the US EPA MSGP, the OEPA draft permit contains numeric effluent limitations based on Effluent Limitations Guidelines for Sectors A, C, D, E, J and O. [more information on difference between effluent limitations and benchmark concentrations]

The Ohio MSGP requires benchmark monitoring, specific for each industrial sector, for pollutant parameters which US EPA has determined to be of concern by industrial sector. The draft Ohio general permit requires that 19 of the 29 industrial sectors perform benchmark analytical monitoring. The benchmark monitoring requirements are not effluent limitations. Benchmark values represent a level to determine whether a facility’s SWP3 is effective.

The benchmark monitoring is based on a collection of 4 quarterly samples. If the average of the 4 monitoring values for any parameter does not exceed the benchmark value, the permittee has fulfilled their monitoring requirements for that parameter for the permit term. If this average exceeds the benchmark for a parameter, then the permittee will need to review their SWP3 and control measures and modify accordingly. Additional monitoring would be required. The US EPA MSGP’s primary source of benchmark concentrations is derived from EPA’s National Water Quality Criteria. For a majority of the benchmarks, USEPA used the acute aquatic life, fresh water ambient water quality criteria. USEPA believes these acute freshwater values best represent the highest concentrations at which typical fresh water species can survive exposures of pollutants for short durations, such as a storm discharge event.

[read recent comparison of benchmark concentrations to typical industrial sector monitoring data]

Ohio EPA evaluated each benchmark monitoring parameter and followed US EPA’s methodology, but used Ohio Water Quality Criteria when available. As such, some US EPA benchmark values have been changed to be consistent with Ohio Water Quality Criteria. The benchmark values of some metals are dependent on water hardness. For these parameters, permittees will need to determine the hardness of the receiving water to determine the benchmark concentration that applies to their facility. Depending on the condition of the receiving water, benchmark values for heavy metals can vary widely between facilities.

[read of summary of the revised OEPA genernal stormwater discharge permit]

Caltha LLP provides expert consulting services to public and private sector clients in Ohio & nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWP3), Stormwater Monitoring (including determination of the effects of receiving water hardness on benchmark concentrations), and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website