Reducing Zinc In Stormwater Discharge Where Does Zinc Come From?

Zinc From Galvanized Metal And Dust

Many facilities required to monitor metal concentrations under their industrial stormwater permit have found high levels of zinc in their stormwater discharges. 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.

Zinc From Oil and Hydraulic Fluid Leaks and Spills

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


Leaking Hydraulic System On Trash Compactor  



Contaminated Soil From Improper Used Oil Drum Storage

 Caltha LLP provides expert technical support to facilities that need to reduce pollutants in stormwater discharge. For further information go to Caltha Stormwater Compliance and Permitting Page.

    

Caltha LLP | Your Pollution Prevention Partner

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.

Amendement To 2015 Washington Construction Stormwater Permit

On November 18, 2015, Ecology issued an updated Construction Stormwater General Permit (CSWGP). The permit became effective January 1, 2016. One appeal was filed with the Washington Pollution Control Hearings Board on December 17, 2015. To resolve the case, Ecology has proposed several revisions to the permit and has posted these revisions for public comment. Comments are due by February 10, 2017

The proposed changes are to dust control (S1.C.3.i), pH sampling requirements (S4.D), engineering calculation requirements (S9.B.1.f), and concrete washout (S9.D.9.h). The proposed changes are:

• S1.C.3.i - Uncontaminated or potable water used to control dust. Permittees must minimize the amount of dust control water used.
• S4.D - pH Sampling Requirements – Significant Concrete Work or Engineered Soils
  If construction activity results in the disturbance of 1 acre or more, and involves significant concrete work (significant concrete work means greater than 1000 cubic yards poured concrete or recycled concrete used over the life of a project ) or the use of recycled concrete or engineered soils (soil amendments including but not limited to Portland cement-treated base [CTB], cement kiln dust [CKD], or fly ash), and stormwater from the affected area drains to surface waters of the State or to a storm sewer system that drains to surface waters of the State, the Permittee must conduct pH sampling as set forth below. Note: In addition, discharges to segments of water bodies on Washington State’s 303(d) list (Category 5) for high pH are subject to a numeric effluent limit for pH; refer to Special Condition S8.

1. For sites with significant concrete work, the Permittee must begin the pH sampling period when the concrete is first poured and exposed to precipitation, and continue weekly throughout and after the concrete pour and curing period, until stormwater pH is in the range of 6.5 to 8.5 (su).
2. For sites with recycled concrete where monitoring is required, the Permittee must begin the weekly pH sampling period when the recycled concrete is first exposed to precipitation and must continue until the recycled concrete is fully stabilized with the and stormwater pH is in the range of 6.5 to 8.5 (su).

• S9.B.1.f – Engineering calculations for ponds, treatment systems, and any other designed structures. When a treatment system requires engineering calculations, these calculations must be included in the SWPPP. Engineering calculations do not need to be included in the SWPPP for treatment systems that do not require such calculations.
• S9.D.9.h - Assure that washout of concrete trucks is performed off-site or in designated concrete washout areas only. Do not wash out concrete trucks drums or concrete handling equipment onto the ground, or into storm drains, open ditches, streets, or streams. Do not dump excess concrete on site, except in designated concrete washout areas. Concrete spillage or concrete discharge directly to groundwater or to surface waters of the State is prohibited. Do not wash out to formed areas awaiting LID facilities.

 

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Washington DC Proposes Rulemaking For Stormwater Fee Discount Program

The Washington District Department of the Environment (DDOE) has released its revised rules and has requested public comments on its Proposed Rulemaking for a Stormwater Fee Discount Program, published in the October 5, 2012 issue of the DC Register. The provisions in this rule will allow District water and sewer ratepayers to receive a discount of up to 55% of the stormwater fee that appears on their DC Water bill, by installing measures that retain or prevent stormwater runoff.

This is the second revision that DDOE has proposed to rules to establish a Stormwater Fee Discount Program. DDOE’s first proposal was published in the DC Register on July 29, 2011, and was made available for a 30-day public comment period. DDOE received comments from a wide array of stakeholders and individuals, and has revised the Proposed Rules to incorporate a number of the comments and suggestions provided. The public comment period on the Proposed Rules is open through November 4, 2012.

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

Washington Reissues Phase 1 and Phase 2 MS4 Permits

On August 1, 2012, the Washington State Department of Ecology (Ecology) reissued three general National Pollutant Discharge Elimination System (NPDES) municipal stormwater permits:

• Phase I Municipal Stormwater General Permit (Phase I permit 2012 to 2013)
• Western Washington Phase II Municipal Stormwater Permit (WWA Phase II permit 2012 to 2013)
• Eastern Washington Phase II Municipal Stormwater Permit (EWA Phase II permit 2012 to 2014)

In accordance with 2012 legislation, Ecology reissued both Phase II permits without modification for a period of one (Western WA) and two (Eastern WA) years. Ecology also reissued the Phase I permit for a period of one year with limited changes.
In addition, Ecology reissued updated permits for the permit terms below:

• Phase I permit (2013 to 2018)
• Western Washington Phase II permit (2013 to 2018)
• Eastern Washington Phase II permit (2014 to 2019)

The National Pollutant Discharge Elimination System (NPDES) and State Waste Discharge General Permits cover discharges from municipal separate storm sewer systems (MS4s). The Phase I Municipal Stormwater Permit regulates the discharges from MS4s owned or operated by Clark, King, Pierce and Snohomish Counties; and the cities of Seattle and Tacoma (incorporated cities with a population over 100,000 and unincorporated counties with populations of more than 250,000 according to the 1990 census). The permit also applies to MS4s owned by public entities located in a Phase I city or county; including the Ports of Seattle and Tacoma.


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

Reissue of Washington MS4 Stormwater Permits

In June 2012, the Washington State Department of Ecology (Ecology) is preparing to reissue three general National Pollutant Discharge Elimination System (NPDES) municipal (also known as MS4) stormwater permits:

• Phase I Municipal Stormwater General Permit (Phase I permit).
• Phase II Western Washington Municipal Stormwater General Permit (Phase II WWA permit)
• Phase II Eastern Washington Municipal Stormwater General Permit (Phase II EWA permit).

For the past three years, Washington State Department of Ecology (Ecology) has been working with interested parties and advisory groups in Western Washington to develop permit requirements. Ecology developed and managed advisory groups for input on monitoring and low impact development requirements. During 2011, Ecology held meetings with permittees and interested parties in Eastern Washington to discuss changes to the Eastern Washington permit 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

Draft MS4 Permit Issued For Joint Base Lewis-McChord, Washington

The U.S. Environmental Protection Agency has issued a received a proposed Municipal Stormwater discharge permit to Joint Base Lewis-McChord (JBLM). Located just south of Tacoma, JBLM is the largest military installation on the West Coast. The most recent population estimate for the base was 95,000 people, including military personnel, military dependants residing on base, civilian employees, and visitors. The permit, when final, is expected to regulate how stormwater is managed across nearly 142 square miles of base property.

EPA’s draft municipal separate storm sewer system (MS4) permit for JBLM is the first such proposed permit for a military or other federal facility in western Washington. The draft permit requires specific actions and activities that must be accomplished over at least the next five years to protect local waters.

Among the new requirements under the proposed permit, the base must control runoff from all construction sites; control runoff from all new development and redevelopment sites; map, inspect, and maintain the storm system, and engage JBLM employees and the community about preventing pollutants in storm water runoff.

Due to its proximity to Puget Sound, the Base permit also requires:

• stormwater runoff from redevelopment and new projects must meet performance standards through use of Low Impact Development (LID) techniques and, if needed, traditional stormwater features (detention ponds);
• a new construction project threshold of 5,000 square feet or greater;
• a program to reduce runoff from the existing developed areas;
• a biological stream health monitoring program using aquatic insects in Clover and Murray Creeks.

EPA’s proposed permit requires LID practices such as rain gardens, permeable pavement, native vegetation areas, and green roofs to avoid or lessen the reliance on traditional stormwater pipes and ponds. By using LID, a larger portion of rainfall will be intercepted, infiltrated, evaporated, or reused to avoid excess runoff. LID actions are expected to maintain or restore a more natural stream flow throughout the year, replenish groundwater, help protect fish and other aquatic organisms, and to reduce the influx of pollutants discharged into the streams, creeks and lakes on the base or into Puget Sound.

EPA will hold a public meeting to discuss the permit on March 19, 2012 in Lakewood, Washington. Comments on the Draft Permit will be accepted through March 30, 2012. EPA will then consider and respond to all comments, and make any necessary changes to the draft permit. The Washington Department of Ecology will also consider certifying the permit in accordance with Section 401 of the Clean Water Act. The EPA Director of the Office of Water & Watersheds will then make a final decision about permit issuance.

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

Final Washington DC MS4 Stormwater Discharge Permit

US EPA has released the final stormwater discharge permit for the Washington DC area municipal separate storm sewer system (“Washington DC MS4 Permit”). The Washington DC MS4 Permit included a number of performance-based requirements, including:

• Requiring a minimum of 350,000 square feet of green roofs on District properties;


• Planting at least 4,150 trees annually and developing a green landscaping incentives program;


• Retaining 1.2 inches of stormwater on-site from a 24-hour storm for all development projects of at least 5,000 square feet;


• Developing a stormwater retrofit strategy, and implementing retrofits over 18 million square feet of drainage of impervious surfaces;


• Developing consolidated implementation plans for restoring the impaired waterways of the Anacostia and Potomac Rivers, Rock Creek, and the Chesapeake Bay; and


• Preventing more than 103,000 pounds of trash annually from being discharged to the Anacostia River.

EPA believed the new permit conditions were necessary because impervious surfaces in the District, such as roads, rooftops and parking lots, channel stormwater directly into local streams and rivers. Improperly managed stormwater runoff from the District damages streams, causes significant erosion, and carries excessive pollutants like nitrogen, phosphorus, sediment, toxic metals, and solvents downstream and into the Chesapeake Bay. The permit aids the District in meeting its Chesapeake Bay pollution reduction targets and its Watershed Implementation Plan.

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.com or Caltha LLP Website

Stormwater Treatment System for PCB in Seattle

The Boeing Company signed an agreement with EPA to construct a new stormwater treatment system at North Boeing Field in Seattle. The treatment system will be designed to reduce the amount of polychlorinated biphenyls (PCBs), which are an on-going source of pollution to the Duwamish River.

The North Boeing Field storm drain system carries stormwater to the Duwamish River through more than seven miles of catch basins, drains, inlets, and oil-water separators. Studies by the Washington State Department of Ecology (Ecology), the City of Seattle, and Boeing showed the North Boeing Field storm drain system is the biggest source of PCBs to the river sediments in Slip 4, one of the most highly contaminated sites on the lower Duwamish waterway.

With the installation of this stormwater treatment system to address the on-going source of PCBs, cleanup of Slip 4 will proceed in 2011. Several acres of contaminated sediments in Slip 4 will be cleaned up under an EPA settlement agreement with the City of Seattle and King County.

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

Washington Mandatory BMP and Industrial Stormwater Requirements

The revised Washington Department of Ecology industrial stormwater general permit became effective on January 1, 2010. The revised permit has numerous substantive changes compared to the previous industrial stormwater permit. Some highlights of these changes include:


Stormwater Pollution Prevention Plan (SWPPP) Requirements

Mandatory BMPs must be implemented no later than July 1, 2010. The facility may omit individual BMPs if site conditions render the BMP unnecessary, infeasible, or the Permittee provides alternative and equally effective BMPs; and justifies the omission in the SWPPP. The mandatory BMPs include:

Operational Source Control BMPs:

• Vacuum paved surfaces with a vacuum sweeper once each quarter.
• Minimize stormwater contamination from dust. Inspect and maintain bag houses monthly.
• Keep all dumpsters under cover or keep dumpster lid closed when not in use.
• Clean catch basins when at capacity.
• Inspect all equipment and vehicles for leaking fluids. Take leaking equipment and vehicles out of service or prevent leaks until repaired.
• Store all chemical liquids, fluids, and petroleum products on an impervious surface with containment that is capable of containing 10% of the total enclosed tank volume or 110% of the volume contained in the largest tank, whichever is greater.
• Prevent precipitation from accumulating in containment areas.
• Locate spill kits within 25 feet of all stationary fueling stations, fuel transfer stations, and mobile fueling units.
• Facility personnel can not lock shut-off fueling nozzles in the open position, or “top-off” tanks being refueled.
• During fueling, facility personnel must block, plug or cover storm drains that receive runoff from areas where fueling.
• Use drip pans or equivalent containment measures during all petroleum transfer operations.
• Maintain a spill log that documents chemical and petroleum spills.
  

Structural Source Control BMPs:

• Use grading, berming, or curbing to prevent runoff of contaminated stormwater flows and divert run-on away from manufacturing, processing, and material storage areas.
• Perform all cleaning operations indoors, under cover, or in bermed areas that prevent stormwater runoff and run-on and capture any overspray. Drain wash water to a collection system for further treatment or storage.
  

SWPPP Signature/Certification

The Permittee must sign and certify the SWPPP and any revisions.

Benchmark Monitoring / Sampling

Facility must sample each distinct point of discharge off-site each calendar quarter; except “substantially identical outfalls”. Sampling must occur within the first 12 hours of stormwater discharge or as soon as practicable after the first 12 hours. Facilies must sample the stormwater discharge from the first fall storm event, after October 1st. “Consistent attainment” requires that four consecutive quarterly samples be equal to or less than the benchmark value; or for pH, within the range of 5.0 – 9.0.

Benchmarks and Effluent Limitations
Click here to review new stormwater benchmark concentrations

Discharges to 303(d)-Listed Waters

Numeric effluent limits now apply to facilities with discharges to 303(d)-listed impaired waterbodies (Category 5).

Inspections

Qualified personnel conduct and document visual inspections of the site monthly. Dry season and annual comprehensive inspection eliminated.

Corrective Actions

Permittees that exceed benchmark value (for a single parameter) for any two quarters during a calendar year complete a Level 2 Corrective Action (Structural Source Control BMPs). Permittees that exceed benchmark value (for a single parameter) for any three quarters during a calendar year complete a Level 3 Corrective Action (Treatment BMPs).

Facilities must revise their SWPPP and complete installation by September 30th the following year. All corrective actions must be documented in Annual Report. A licensed professional engineer, geologist, hydrogeologist, or certified professional in storm water quality (CPSWQ) must design and stamp the portion of the SWPPP that addresses (Level 3) stormwater treatment structures or processes.

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

Washington Ecology Industrial Permit Reissue - Proposed NPDES Permit

The current Washington State Department of Ecology (Ecology) Industrial Stormwater General Permit will expire April 30, 2009. The previous Industrial Stormwater NPDES and State Waste Discharge General Permit, first issued by Ecology in 2002, then reissued in 2007, expired on May 31, 2008. In 2008, Ecology proposed to reissue the expired general permit again without changes until April 30, 2009.

Ecology continues to work with stakeholders on drafting a new permit and plans to release the draft permit on May 20, 2009 for public comment. Once the public comment period ends, Ecology will consider the comments, make appropriate revisions, and then issue a final permit. Ecology intends to issue the final permit on October 21, 2009. Facilities currently covered under the expired permit will automatically be covered under the new final 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