Are Stormwater Benchmarks The Same As Permit Limits?

Benchmark values differ from permit limits. In a typical wastewater NPDES permit, limits may be specified for chemical parameters; if any of the limits are exceeded, it becomes a violation of the permit and may be subject to enforcement action. Benchmark values, in the context of stormwater NPDES permits, are intended to provide a measurement of the effectiveness of the stormwater pollution prevention plan (SWPPP). Exceeding a benchmark does not directly result in a permit violation.

 
Industrial Waste Discharge To Storm Sewer 

However, permits typically require facilities to reevaluate their SWPPP and to take prompt corrective action after a benchmark value is exceeded. Failure to take prompt corrective action if a benchmark value is exceeded can be a permit violation and subject to enforcement action. Multiple exceedances of a benchmark could result in a State requiring that the facility apply for an individual stormwater discharge permit. In this case, legally enforceable stormwater discharge limits may be written into the permit.

 

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

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

California Revision To Current IGP Proposed To Address TMDL and Monitoring

The California State Water Board has proposed amends to the Industrial General Permit (IGP) current in effect. Comments on the proposed amendments are due by January 31, 2018. The State Water Board is proposing the Amendment to the Statewide Storm Water Industrial General Permit (General Permit) to address the following items:

• Implement TMDLs included in General Permit,
• Update the monitoring requirements and
• Add statewide compliance options to incentivize storm water capture and regional collaboration.

The current IGP includes a reopener to incorporate Total Maximum Daily Load (TMDL) requirements through a future permit amendment (Section XX.A). The proposed General Permit Amendment incorporates requirements for implementing existing TMDLs adopted by the San Francisco Bay, Santa Ana, Los Angeles, and San Diego Regional Water Quality Control Boards identifying industrial storm water as a source of the receiving water Impairment.


The proposed General Permit Amendment includes statewide compliance options to allow compliance with water quality objectives through onsite and regional storm water capture best management practices in place of typical compliance with numeric action levels and numeric effluent limitations.


In 2014, US EPA finalized the new Use of Sufficiently Sensitive Test Methods for Permit Applications and Reporting Rule for discharges regulated by NPDES permits. The new Rule became effective on September 18, 2014. The EPA Rule requires NPDES permitees to use “sufficiently sensitive” analytical test methods for the analyses of regulated pollutants or pollutants parameters. The proposed General Permit Amendment includes revised monitoring and reporting requirements for industrial storm water sampling consistent with the new Rule.


Click here to review other regulatory updates for California.

2017 Georgia General Pemit | What If I Exceeded Benchmarks Under Current Permit?

The current Georgia industrial stormwater general discharge permit expires on May 30, 2017. The revised NPDES General Storm Water Permit For Discharges of Stormwater Associated With Industrial Activity (2017 IGP) was finalized in 2016 and becomes effective on June 1, 2017. The revised permit made some modifications to requirements permitted facilities must meet, but not as substantial of changes as compared to the release of the 2012 IGP.

If a facility exceeded the impaired waters benchmark based on the criteria presented in 2012 IGP permit, then the facility has the option to conduct 12 months of flow-weighted composite sampling to demonstrate the discharge does not cause or contribute to an exceedance of water quality standards, or make the necessary improvements to the facility to achieve the instream water quality standard as an effluent limit within 36 months. If the facility still is unable to meet the impaired waters benchmark(s), they may not be authorized to discharge stormwater under this permit and may be required to apply for an individual NPDES permit or alternative general permit. Facilities that failed to meet the applicable benchmarks of the 2012 IGP permit have the option to sample their discharge(s) for 12 months to confirm whether the facility causes or contributes to an exceedance of the applicable Water Quality Standard, or prevent all exposure of industrial processes, materials, and equipment to stormwater, and/or capture and treat storm events of up to 1.2 inches within industrial areas exposed to stormwater within 36 months.

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

Reducing Zinc In Stormwater. What Are Possible Sources Of Zinc In Storm Water?

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.

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.

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

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

Technical Consultant Support To Address Stormwater Benchmark Exceedance for TSS, Iron, Zinc, Aluminum

Caltha LLP Project Summary

Project: Consulting Support To Address Stormwater Benchmark Exceedance
Client: Manufacturer
Location(s): Minnesota

Key Elements: Stormwater monitoring; MPCA stormwater permit compliance; Industrial storm water BMPs

Overview: This manufacture retained Caltha to provide technical support and guidance in addressing exceedance of MPCA industrial storm water benchmark concentrations. Monitoring data collected in Permit Cycle Year 2 exceeded limits for total suspended solids (TSS), zinc, iron and aluminum. Caltha staff reviewed past data, monitoring procedures and conducted a site inspection to determine root causes for the exceedance as part of a formal corrective action process. Based on recommendations, the facility began implementation of revised stormwater controls and began preparations for subsequent year 4 monitoring activities.

For more information on Caltha LLP services, go to the Caltha Contact Page

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

New Benchmark Monitoring Requirements For Discharges To Impaired Waters

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

Review a Regulatory Briefing on the Georgia 2012 IGP

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

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

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

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

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

MPCA Reports Low Compliance Rates With New Industrial Stormwater Permit

In 2010, the Minnesota Pollution Control Agency (MPCA) finalized a new industrial stormwater discharge general permit. The new permit had numerous new requirements that facilities are required to meet. One of the most significant changes was that facilities are now required to collect samples of their stormwater discharge, send the samples to a laboratory for testing, and to report the results to MPCA on a Stormwater Monitoring Report Form (SWMR).

[Read a summary of MPCA industrial stormwater monitoring requirements]

[Read a summary of the revised MPCA permit]

According to information now being circulated by MPCA, as of November 2011, about 50% of all permitted facilities in Minnesota that are required to collect a sample and submit results had failed to do so. In addition, another 25% are missing results/data on a previously-submitted SWMR. In summary, according to MPCA, only about 25% of permitted facilities were in compliance with stormwater monitoring requirements of the general permit.

MPCA indicated that it is currently considering options it can take to improve compliance rates with industrial stormwater discharge 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

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

Numeric Action Levels, Numeric Effluent Limits, and Corrective Action Triggers In California Draft Permit

UPDATE: On July 16, 2012, an updated draft was released. Click here for a summary of the revised draft ICP

On January 28, 2011, the California State Water Resources Control Board proposed a draft industrial stormwater discharge general permit. The draft General Permit amends a number of the existing requirements for permitted facilities and adds some new requirements.

One of the more significant changes to the California General NPDES Permit is the incorporation of quantitative Action Levels and Effluent Limits which could apply to any discharger:


Numeric Action Levels (NALs) are derived from the US EPA Multi-Sector General Permit’s benchmarks, and are used as numeric thresholds for corrective action. Exceedances of an NAL are not a violation of the permit; however, exceedance of specific NAL Corrective Action Triggers requires the facility to enter into Level 1 Corrective Action.

[More information on US EPA benchmarks, and comparison to historic industrial sector monitoring results]


Numeric Effluent Limits (NELs) are could also apply to any facility. Dischargers in Corrective Action Level 3 (see below) are subject to a numeric effluent limitation (NEL) that will be the same value as the applicable pollutant NAL. A daily average exceedance of the NEL is a violation of the General Permit and may subject the discharger to mandatory minimum penalties.

NAL Corrective Action Triggers are defined in the draft general permit as follows:
1. The Daily Average (DA) for any one constituent exceeds the NAL value for two or more storm events of a reporting year, or;
2. The DA for any two constituents exceed the NAL values for any single storm event within a reporting year, or;
3. The concentration for any one constituent exceeds 2.5 times the NAL value for any one individual or allowable combined sample (or is more than one pH unit outside the NAL pH range)

In the event that any of the NAL Corrective Action Triggers are met, the facility will need to complete Level 1 Corrective Actions. The need to do further corrective actions will depend on subsequent monitoring results.


Level 1 - Operational Source Control Corrective ActionsUpon the first occurrence meeting any of the NAL corrective action triggers, the discharger will be required to valuate areas of the facility to identify where additional operational source control BMPs and/or SWPPP implementation measures are necessary to prevent or reduce pollutants in storm water discharges in compliance with BAT/BCT. Based upon the facility evaluation, the facility will certify that the pollutant source(s) have been identified and 1) additional operational source control BMPs and/or SWPPP implementation measures have been included in the SWPPP , 2) no additional operational source control BMPs or SWPPP implementation measures are required , or 3) pollutant source(s) causing the exceedance are not related to the facility’s industrial activities. A Level 1 NAL Exceedance Evaluation Report will need to be prepared and submitted.
Level 2 Structural and/or Treatment Corrective ActionsIf in any subsequent reporting year the sampling results meet an NAL corrective action trigger, the discharger is require to take addition action. If the NAL corrective action trigger is for a constituent that had not been included in a previous Level 1 NAL Exceedance Evaluation Report, the discharger go through Level 1 Corrective Actions.
If the NAL corrective action trigger is for one or more of the constituents previously addressed in a Level 1 NAL Exceedance Evaluation Report, the discharger would need to evaluate and select additional structural source control BMPs and/or treatment BMPs with the goal of achieving the applicable NAL value(s) in future discharges. A Level 2 NAL Exceedance Evaluation Report will need to be prepared and submitted and more frequent monitoring is required.
Level 3 Imposition of Numeric Effluent LimitsIf in any subsequent reporting year the sampling results meet an NAL corrective action trigger for the same constituents subject to the Level 2 corrective actions, the discharger shall the applicable NAL(s) will become an NEL(s), and starting October 1 of the following compliance year, the discharger will be required to sample every qualifying storm event.

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.comorCaltha LLP Website

Arizona DEQ Stormwater Monitoring and Industrial Storm Water Benchmarks

In December 2010, the Arizona Department of Environmental Quality (ADEQ) issued the Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The revised permit included significant changes to stormwater discharge requirements for permitted sites, which are now divided into 29 industrial sectors. One of the most significant changes was the requirement for sampling stormwater and reporting results to ADEQ. The monitoring requirement begins immediately after permit coverage begins. ADEQ has defined monitoring seasons in the permit:
Summer wet season: June 1 – October 31
Winter wet season: November 1 – May 31
The frequency for stormwater sampling in the permit is at least twice each wet season (summer and winter) from each monitoring location.

All sites permitted under the MSGP (with some limited exceptions) will have to collect stormwater samples and have samples analyzed for their sector-specific benchmark parameters. If one or more benchmarks are exceeded, sites will be required to upgrade their pollution prevention measures and will need to do further stormwater monitoring.

Some stormwater benchmarks that apply to several sectors include:

Ammonia 2.14 mg/L
Biochemical Oxygen Demand (BOD) 30 mg/L
Chemical Oxygen Demand (COD) 120 mg/L
pH 6.0 – 9.0 s.u.
Total Aluminum 0.75 mg/ L
Total Arsenic 0.15 mg/L
Total Cyanide 0.022 mg/ L
Total Iron 1.0 mg/L
Total Magnesium 0.064 mg/L
Total Mercury 0.0014 mg/L
Total Selenium 0.005 mg/L
Total Suspended Solids (TSS) 100 mg/L


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

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

Industrial Stormwater Benchmarks – Comparison of New Minnesota Benchmark Concentrations To Historic Industry-specific Testing Results
Caltha LLP provides expert consulting services to public and private sector clients in Arizona 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

MPCA Storm Water Benchmarks, Comparison To Historic Sector Monitoring Data

In 2010, the Minnesota Pollution Control Agency (MPCA) reissued the Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The reissued permit included significant changes to stormwater discharge requirements for permitted sites, which are now divided into 29 industrial sectors. One of the most significant changes was the requirement for sampling stormwater and reporting results to MPCA. Each sector has been assigned sector-specific stormwater benchmark concentrations. Beginning in June 2011, all sites permitted under the MSGP will have to collect stormwater samples and have samples analyzed for their sector-specific benchmark parameters. If one or more benchmarks are exceeded, sites will be required to upgrade their pollution prevention measures and will need to do further stormwater monitoring.

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

Note: Because many States use the same benchmark concentrations used by Minnesota, this analysis and conclusions can be applied to most States.
Link to presentation slides:

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

CT DEP Revised Industrial Stormwater General Permit

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

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

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

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

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

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

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

Link to presentation slides:

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



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

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

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

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Industrial Stormwater Monitoring in Minnesota - Benchmark Monitoring

The Minnesota Pollution Control Agency has released its revised general permit for stormwater discharges from industrial sites. The most important change in the draft permit compared to the previous MPCA general permit is the requirement to sample stormwater discharges.

Flowchart of MPCA Stormwater Monitoring Requirements


All permittees, regardless of size or business sector, will collect and analyze at least four quarterly samples during Year 2 of permit coverage. These samples will be compared to “benchmark” concentrations. Depending on the results, further quarterly samples may need to be collected in Year 4 and 5, and corrective actions may be required. Additional reporting, including a “Benchmark Exceedence Report” and evaluations will be required for dischargers who continue to exceed benchmark concentrations. All sample results will be reported to MPCA.

Related Links:

Further information on stormwater benchmarks

Further information on selecting stormwater monitoring techniques

Comparison of stormwater benchmarks to historic industrial sector discharge data

It should be noted that some permittees will also be subject to EFFLUENT LIMITS and will have to conduct effluent limit monitoring. The schedule and requirements for effluent limit monitoring are different from Benchmark Monitoring.

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