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

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

Industrial Storm Water Training Seminar - Eagan, MN Nov. 30, 2012

Complying with Minnesota Industrial Stormwater Requirements
Eagan, MN
Friday, November 30, 2012

This full day training seminar will cover the requirements of the Minnesota Pollution Control Agency (MPCA) Multi-Sector General Permit (MSGP) for industrial storm water discharges. The course will begin with a discussion of the regulation of stormwater discharge under the Federal Clean Water Act, and then the specific requirements under the MPCA industrial permit, issued in 2010. This will include sector specific requirements, use of benchmark monitoring, effluent guideline monitoring and corrective action requirements. The morning session will include a discussion of additional requirements for stormwater discharges to impaired waters and other special waters identified in the MSGP.

The afternoon session will focus on implementing best managemt practices and development of a stormwater pollution prevention plan (SWPPP) at individual facilities. This will include a discussion of monitoring and reported requirements to comply with the Minnesota MSGP.

For more information or to register, go to:
Training Seminar - Complying with Minnesota Industrial Stormwater Requirements, November 30, 2012

Agenda

Industrial Stormwater Laws and Regulations

• Federal Clean Water Act overview
• Application of Clean Water Act to stormwater discharges

Minnesota industrial stormwater permitting process

• Overview of permit requirements
• Industrial sector-specific requirements
• Benchmark monitoring/effluent monitoring
• Corrective action triggers

Application of Rules/Permit to Individual Facilities

• Impaired waters/TMDLs
• Nondegradation/antidegradation requirements
• Special waters
• Wetlands
• Industrial sites with potential soil/groundwater contaminants
• Local and regional requirements

Creating Stormwater Pollution Prevention Plan (SWPPP)

• Complying with stormwater control measure requirements
• Describing facility
• Providing assessment of activities and materials
• Modification and reporting requirements
• Availability requirements
• Construction site runoff control

Implementing Best Management Practices (BMPs)

• BMPs to achieve “no exposure”
• Stormwater reduction
• Reuse of stormwater
• Stormwater control/management
• Structural BMPs for treating stormwater
• Contingency planning for extreme weather

Sampling and Annual Reporting

• Setting up monitoring procedures
• Collecting and evaluating samples
• Submitting annual reports
• Modifying BMPs

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

No Exposure Certification Under Proposed California General Permit

Phase II of the Federal stormwater rules changed the requirement for “no exposure certification” or NEC which existed in 1997, then the current California general permit was finalized. EPA extended the option to certify no exposure to any industrial sector. The draft IGP applies US EPA’s Phase II rules regarding a conditional exclusion for facilities where there is no exposure of industrial activities and materials to storm water. The previous California permit mandated that light industries obtain coverage only if their activities were exposed to storm water. This General Permit meets US EPA rules allowing any type of industry to claim the conditional exclusion.

In the draft IGP, the NEC requires enrollment for coverage but conditionally excludes dischargers from a majority of the permit requirements. Some minor modifications were added to clarify the types of “storm resistant shelters” and the periods when “temporary shelters” may be used to meet the NEC requirements. Under the draft ICP, dischargers meeting all the NEC would need to recertify each year.

Facilities that self-certified no exposure under the previous permit (category 11) are required to designate a Legally Responsible Person (LRP) to certify and submit via SMARTS for NOI or NEC coverage under this General Permit. NEC will need to be recertified through SMARTS on an annual basis.

Click here for a summary of the Draft California Industrial Storm Water Permit

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

Storm Water Plan Certification - What is Certified? Who Must Sign?

Under State and EPA stormwater permitting rules, a Stormwater Pollution Prevention Plan (SWPPP) may need to be certified. This signed SWPPP Certification is in addition to other types of certifications that may be required. The types of certifications will vary depending on the State and type of permit; in addition to SWPPP Certification, some other types of certifications might include:

• Non-stormwater Discharge Certification,
• No-exposure Monitoring Exemption Certification;
• Heavy Metal No-exposure Certification (in Texas);
• Site Compliance Certifications;
• Endangered Species Certifications;
• Historic Places Certification
• Others.

SWPPP Certification – What is Being Certified?
In most cases, the SWPPP Certification statement indicates that the SWPPP has been 1) prepared; 2) implemented and that 3) the SWPPP conforms to the requirements of the discharge permit. The SWPPP Certification generally includes a statement that the information documented is correct. The exact wording and scope of the certification statement will vary from State-to-State, but here is an example:

"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."


Who needs to certify the SWPPP?
In some States (for example, Michigan, Indiana, Connecticut and others), the SWPPP needs to be signed by a certified or qualified environmental professional.

In most States, the SWPPP also needs to be signed by a Responsible Company Officer, or his/her duly authorized representative. State or EPA rules will determine who can sign the SWPPP. This SWPPP Certification can be in addition to any certifications needed by a qualified environmental professional.

Click here for more information on State-specific SWPPP Templates.


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

Georgia Industrial Stormwater SWPPP Template and Compliance Plan

The Georgia Environmental Protection Division(EPD) has finalized a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP). This permit replaces the previous Georgia general permit, which had expired in July 2011. The Georgia general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For many facilities subject to the previous general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP. Facilities must submit a new NOI for permit coverage by June 30, 2012, including certification that the operation is in compliance with new requirements.

Read a Summary of the Revised Georgia Industrial Permit Requirements
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 Georgia permit requirements, including Georgia specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Georgia Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the EPD general permit.

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

No Exposure Exclusion NEE Requirements Under Revised EPD Industrial Permit

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.

Click here to review a Regulatory Briefing on the 2012 ICP

One of the significant requirements in the final draft permit is related to facilities that submit a No Exposure Exclusion (NEE). Those facilities that have certified to a condition of No Exposure by submitting the Industrial No Exposure Exclusion Certification form are exempt from the IGP as long as the condition of No Exposure is maintained. However, Georgia is unique is requiring that NEE facilities document compliance with the NEE requirements. Owners and operators of facilities for which an NEE form is submitted are required to conduct quarterly inspections each year to ensure that a condition of No Exposure is maintained at the facility. Results of the inspections must be maintained at the facility and available to EPD upon request.

If an inspection shows that any condition of the No Exposure Exclusion does not exist, then appropriate remedial measures are required within 30 days of the inspection, or the facility owner or operator must submit an NOI to obtain coverage under the general permit

The NEE form must be submitted on every permit cycle re-issuance. Therefore facilities that submitted their NEE form under the previous permit must resubmit their certification within 30 days after the effective date of the 2012 IGP.

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 at

info@calthacompany.com or Caltha LLP Website

SPCC Rule Extension For Agricultural Facilities

EPA has extended the date that agricultural facilities must come into compliance with the new Spill Prevention, Control, and Countermeasure (SPCC) rule to May 10, 2013. Agricultural facilities that began storing oil before August 16, 2002 must revise their SPCC plan to meet the 2002 changes by the May 2013 deadline.

There are several exemptions for agricultural operations. These include: milk and milk product containers, associated piping, and appurtenances; home heating oil tanks at single family homes; pesticide containers used to mix and load formulations; and pesticide application equipment.

The recent Rule changes also allow agricultural operations that store 10,000 gallons of oil or less and meet the Tier 1 or 2 qualified facility requirements to prepare and self-certify their SPCC Plan. Although anyone can use the templates, not all states allow self-certification For example, New Hampshire requires all SPCC Plans to be certified by a professional engineer.

FAQ: What industries need an SPCC Plan?


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address SPCC and Stormwater Permitting & Regulatory Support, preparing and certifying SPCC Plans and SWPPPs, SPCC rule compliance and SPCC Training.

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

Stormwater Seminar in MN & ND Permiting and Design

Minnesota and North Dakota Stormwater Management Seminar
Fargo, North Dakota
Friday, November 19, 2010


Purpose:

• Examine federal, state, and local rules on stormwater management
• Review municipal, industrial and construction permits and the permitting process
• Explore green stormwater practices
• Examine site selection, sizing, and design
• Evaluate erosion and water quality

Agenda:

Understanding Federal and State Rules on Stormwater Management
Federal statutes and regulations, National Pollutant Discharge Elimination System (NPDES) requirements, State statutes and regulations, North Dakota Department of Health NDDH stormwater requirements, Minnesota Pollution Control Agency MPCA stormwater requirements, Local requirements and procedures, Storm water permits and permit application process, Special waters and impaired waters

Stormwater Management Using Wet and Dry Detention Facilities
Detention/retention pond overview, Advantages and disadvantages, Design considerations, Hydrology, Permitting, Site selection, Water quality, Pond sizing, Safety considerations, Outlet structures, Good design practices, Pond routing theory, Interconnected ponds, Steps for detention design

Stormwater Quality Best Management Practices
Bioretention and rain-leader disconnect raingardens, Cisterns, Permeable pavers/pervious concrete, Disconnecting impervious area/vegetated swales, Soil amendments, Rainwater harvesting, Green roofs

Bioretention Design and Maintenance
Costs and consequences of poor design, Site evaluation, Cell configuration and soils, Siting, ponding depth, vegetation, Installation specifications, Maintenance program, Overview of maintenance activities, Costs, Case Study: City of Plymouth, Minnesota, residential raingarden and maintenance program

Download Seminar brochure

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

Revised Rule 6 Reporting Forms - IDEM Industrial Storm Water Permit

The Indiana Department of Environmental Management (IDEM) Office of Water Quality has created new state forms for all permitted facilities to complete and submit to meet the annual reporting and stormwater discharge monitoring reporting requirements of Rule 6.

Rule 6 requires each permittee to complete and submit an Annual Report. Annual Reporting is an effective way of ensuring the Storm Water Pollution Prevention Plan (SWP3) is current, potential pollution sources are identified, and Best Management Practices and corrective measures are implemented, properly designed and functioning, and are being maintained. An Annual Report is due no later than 365 days from submitting the Notice of Intent and must contain information obtained during the previous year of regulation. Subsequent annual reports must be submitted no later than 365 days from the previous report in years 2 through 5.

Rule 6 also requires each permittee to conduct annual storm water monitoring. A Storm Water Discharge Monitoring Report is due no later than 365 days from submitting the Notice of Intent. Subsequent annual storm water discharge monitoring reports must be submitted no later than 365 days from the previous report in years 2 through 5. Each year of the permit, permitted facilities are required to collect grab storm water samples from qualified rainfall. The samples must be sent to a lab and analyzed for any pollutant that has the potential to be present in a storm water discharge in addition to the following required 8 sampling parameters:
• pH;
• Oil and Grease;
• Nitrates plus nitrite nitrogen;
• Kjeldahl nitrogen, total (TKN);
• Phosphorous, total;
• Suspended solids, total (TSS);
• Chemical oxygen demand (COD);
• Carbonaceous bio-chemical oxygen demand (CBOD5)

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

What Is the Sheen Rule? Oil Spill Reporting

Under the Clean Water Act, the "sheen rule" provides the framework for determining whether an oil spill should be reported to the federal government. Federal regulation requires the person in charge of a facility or vessel responsible for discharging oil that may be "harmful to the public health or welfare" to report the spill.

The regulation establishes the criteria for determining whether an oil spill may be harmful to public health or welfare, thereby triggering the reporting requirements:

• Discharges that cause a sheen or discoloration on the surface of a body of water;
• Discharges that violate applicable water quality standards; and
• Discharges that cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorelines.

These reporting criteria are independent of local or State spill reporting requirements. Therefore, spills might be reportable even if State spill reporting thresholds are not exceeded.

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

FAQ: What is the difference between a SWPPP and and SPCC Plan?

40 CFR 112 SPCC compliance and SPCC Plan services
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

Preproduction Plastic Debris Program In California

Update: Preproduction Plastic controls are added to 2012 draft industrial general permit: http://swppp.calthacompany.com/2012/07/preproduction-plastics-control-options.html


In 2007, Assembly Bill (AB) 258 was passed, and became effective January 1, 2008, which added Chapter 5.2 to Division 7 of the California Water Code, section 13367. Chapter 5.2 entitled “Preproduction Plastic Debris Program”. This law applies to facilities in California that manufacture, handle, or transport preproduction plastics.

Preproduction plastic is the raw plastic resin materials that are molded into finished plastic products. Preproduction plastics are often produced in a resin pellet format, occasionally termed as “nurdles.” These small, 1- to 5- mm diameter pieces are produced in various shapes, colors, and plastic types. Preproduction plastic resins are also produced in powder, granule, and flake form.

Once in the environment, preproduction plastic resin pellets, powders, and production scrap can be mistaken for food by marine life. They also contribute to California’s litter problem, which state and local agencies spend millions of dollars per year on collecting. Preproduction plastic discharges pose a significant threat to California’s marine environment, which is an important part of California's $46-billion dollar ocean-dependent, tourism economy.

State and Regional Water Board staff have conducted and are continuing to conduct compliance inspections of various types and scales of preproduction plastic manufacturing, handling, and transport facilities enrolled under California's Industrial General Permit (IGP) for storm water discharges. Additionally, the Los Angeles Regional Water Quality Control Board has conducted inspections of facilities suspected to be "non-filers," or facilities subject to the permit, but have not enrolled.

The State Water Board has issued an investigative order to all plastic-related facilities enrolled under the IGP to conduct a Self-Compliance Evaluation and to provide the State Water Board with information needed to satisfy the legislative mandates in AB 258. Facilities subject to this order must complete an online evaluation and assess their points of potential preproduction plastics discharge and means of controlling 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

New Airport Deicing Fluid Regulations - Requirement to Collect and Treat

U.S. Environmental Protection Agency has proposed regulations requiring airports to collect at least some of the deicing fluid after it is used on aircrafts with a goal of cutting chemical discharge by 22%. The regulations would require six of the 14 major U.S. airports that are the biggest users of deicing fluid to install deicing pads or other collection systems to capture 60% of fluid sprayed and to install deicing pads or other collection systems. Some of the targeted airports include:

• New York's John F. Kennedy and LaGuardia airports,
• Chicago's O'Hare,
• Boston Logan International,
• Cleveland-Hopkins International, and
• New Jersey's Newark Liberty International

It would then be the airports' responsibility to ensure that the collected fluid was treated and handled in accordance with requirements. Some 200 smaller facilities around the US would have to collect 20 percent of the fluid by using technologies such as a glycol recovery vehicle, while airports with fewer than 1,000 yearly jet departures would not be impacted.

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

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

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

Stormwater Permit Compliance Plan - Companion to Facility SWPPP

Caltha LLP maintains a library of stormwater permit compliance plan templates developed based on the requirements of individual States and EPA general industrial stormwater discharge permits (also known as “Multisector general permits” or MSGP).

The stormwater permit compliance plan templates are simple plans, usually about 2 to 5 pages in length that provide basic guidance on permit compliance tasks and schedules. Facilities use the compliance plan as a resource planning guide and training tool.

How is a stormwater permit compliance plan different than the stormwater pollution prevention plan (SWPPP)? The SWPPP is an important document for any permitted facility – however, the SWPPP is only one compliance requirement within the permit. The compliance plan does not duplicate the SWPPP, but rather compliments the SWPPP by organizing all compliance tasks in the permit so that facilities can quickly make assignments, develop a Pollution Prevention Team, and track compliance.

Caltha provides Stormwater Permit Compliance Plan templates for the following States:
[Click on a State to request information]

[See a map showing States where Caltha LLP worked in 2008]

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

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

SPCC Plan - Does My Spill Plan Expire?

From time-to-time, Caltha receives inquiries from facilities that believe their Spill Prevention, Control & Countermeasure (SPCC) Plan may have "expired".

The SPCC Plan, prepared in accordance with 40 CFR 112, is a "dynamic" document, and does not expire. At any point in time, the SPCC Plan needs to accurately reflect the current physical layout of the facility, the existing spill containment and control measures, and the current emergency response procedures.

Because facilities change overtime, the SPCC Plan needs to be reviewed and updated accordingly. At a minimum, the plan needs a formal review and revision (if necessary) every five years. However, certain elements of the Plan may change much more frequently - especially emergency contact information. The SPCC Plan should be revised before making changes to the facility that are relevant to compliance with the SPCC Rule.

Caltha LLP offers expert technical and regulatory support to develop facility Spill Prevention, Control & Countermeasure (SPCC) plans, including several low cost options for SPCC Plans using the new SPCC Template Plan format. Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112. Click here to request further information on SPCC and SWPPP Services.
For further information contact Caltha LLP atinfo@calthacompany.com
orCaltha LLP Website

NPDES Permit Program Changes - Delegation For ADEC

The U.S. Environmental Protection Agency has recently delegated its authority under the Clean Water Act to the State of Alaska. EPA will hand off wastewater discharge permitting authority and enforcement in Alaska to the Alaska Department of Environmental Conservation (DEC).

Stormwater permitting program responsibility will not be immediately transferred to DEC. Existing dischargers will remain under the US EPA Multi-sector General Permit ("MSGP-2008"), finalized in September 2008. Over the next three years, Alaska DEC will take over the stormwater permitting program, and will issue their own permits for industrial, MS4 and construction site stormwater discharge.

Alaska joins 45 other states that oversee their own National Pollutant Discharge Elimination System (NPDES). Delegated States can write their own standards, but they can not be any less strict than federal standards.

In November 2008, DEC took control over wastewater discharge permits for timber harvesting, seafood processing and municipal dischargers. Existing permits from the EPA will turn into state permits. Over the next three years, in phases, the State will take over permitting of Federal facilities in Alaska, stormwater, mining, and finally oil and gas permits, cooling water and other minor permitting programs.

Caltha LLP assists clients in meeting State and Federal NPDES permit and compliance requirements. For more information on Stormwater Permits and Compliance, go to Stormwater and SWPPP website.

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

Regulation of Pesticide Discharges Under NPDES Permit - New Court Ruling

On January 7, 2009, an Appeals Court vacated a U.S. Environmental Protection Agency (EPA) rule that has allowed pesticides to be applied to U.S. waters without a Clean Water Act permit. In November 2007, EPA had issued the final rule stating that pesticides applied in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) are exempt from the Clean Water Act's permitting requirements.

The Clean Water Act regulates the discharge of pollutants into the nation's waters by, among other things, requiring entities that discharge pollutants to obtain a National Pollutant Discharge Elimination System (NPDES) permit. For nearly 30 years before adoption of the 2007 rule, pesticide labels issued under the FIFRA were required to contain a notice stating that the pesticide could not be "discharged into lakes, streams, ponds, or public waters unless in accordance with an NPDES permit".

The court ruled that pesticide residues and biological pesticides constitute pollutants under federal law and therefore must be regulated under the Clean Water Act in order to minimize the impact to human health and the environment.

Caltha LLP assists dischargers in meeting State and Federal requirements for stormwater and wastewater discharge. Caltha also provides specialized expertise in the assessment, standards and regulation of pesticides and herbicides in the environment.

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

What Are Non Stormwater Discharges and Illicit Discharges?

Stormwater discharge permits include sections discussing the prohibition on non stormwater discharges. Municipal stormwater permits (MS4 permits) also refer to “illicit discharges”; illicit discharges are equivalent to non stormwater discharges. The municipality must develop programs to detect illicit discharges and to eliminate them from being discharged to their system.

Non stormwater discharges are any waste or wastewater discharge through a stormwater outfall that is not stormwater. Non stormwater discharges are not limited to piped discharge of wastewater; discharges could be infrequent or even one-time discharges. Examples of periodic or infrequent discharges include washing of equipment or pavement, blowdown from cooling towers, condensation from chillers or compressors. Non stormwater discharges can be small discharges of water, such as dumping floor scrubber water in a parking lot.

The Clean Water Act does not recognize a “deminimis” discharge – all non stormwater discharge is prohibited, regardless of how small. [Read more about connection between non stormwater discharge prohibition and the Clean Water Act]

The obligation on the discharger under most State stormwater permits is to 1) conduct and document an assessment of potential non stormwater discharges at the permitted facility, and 2) either eliminate the discharge, or to obtain a separate discharge permit that allows the discharge. Permits will also contain a list of allowable non stormwater discharges, which is a small subset of non stormwater discharges that can be discharged without a separate permit, if certain conditions are met.

Caltha LLP assists permitted facilities in conducting non stormwater discharge assessments and determining preferred options for the alternate disposal of non stormwater discharges. Click here to request further information on Stormwater and SWPPP Services.

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