SWPPP | Stormwater Pollution Prevention Plans | Stormwater Permits | Stormwater Training

Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits,multisector general permits, impaired waters requirements, water quality standards, SWPPP, Stormwater Pollution Prevention Plans, stormwater monitoring, stormwater training, SWPPP training, spill prevention and control, SPCC compliance, site inspections, reporting and recordkeeping

Monday, February 9, 2009

SPCC Plans - State Spill Prevention - Preparedness Requirements

Friday, February 6, 2009

Substantially Identical Outfalls - Substantially Identical Effluents

One option potentially available to dischargers required to conduct stormwater monitoring is the use of "Substantially Identical" outfalls. This is particularly useful to facilities with many outfalls that need to be monitored.

The selection of substantially identical outfalls does not have to be "pre-approved" in many cases. However, the risk to dischargers is that if the permitting agency does not agree with the determination of substantially identical outfalls, the discharger may be subject to enforcement action. Therefore, careful consideration and documentation that the selected identical outfalls are valid is important.

The criteria used to determine if the "Substantially Identical" option applies will change from State-to-State. Generally, the factors used can include:

Location ;
Industrial activities conducted in the drainage area of each outfall;
Control measures implemented in the drainage area of each outfall;
Materials used or stored;
Runoff coefficient of the drainage areas.

Caltha LLP assists dischargers nationwide in developing and implementing cost effective stormwater monitoring programs, including determination and documentation of substantially identical outfalls. To request further information, go to SWPPP and SPCC website.

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

Substantially Identical Outfalls - Potential Option To Reduce Sampling Costs

The availability of this option will change from State-to-State, as will the exact requirements. However, generally if the facility has two or more outfalls that discharge substantially identical effluents, the facility may be allowed to conduct visual and/or benchmark monitoring at one of the outfalls and report that the results also apply to the substantially identical outfall(s). In many cases, the facility will need to perform monitoring on a rotating basis of each substantially identical outfall. However, if stormwater contamination is identified at any substantially identical outfall, control measures may need to be installed for all identical outfalls.

In many cases, selection of substantially identical outfalls does not have to be "pre-approved". However, the risk to dischargers is that if during subsequent compliance inspections the permitting agency does not agree with the determination of substantially identical outfalls, the discharger may be subject to enforcement action. Therefore, careful consideration and documentation that the selected identical outfalls are valid is important.

Caltha LLP asssists dischargers nationwide in developing and implementing cost effective stormwater monitoring programs, including determination and documentation of substantially identical outfalls. To request further information, go to SWPPP and SPCC website.

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

Thursday, February 5, 2009

Stormwater Monitoring - Considerations for Selecting Sampling Technique

Selecting the optimum stormwater sampling approach is a key element to managing costs for stormwater compliance monitoring.

Selecting the appropriate option for a given discharger requires consideration of all the outfalls that need to be sampled. For example, some outfalls may not be conducive for installing automated sampling equipment, and might require a different technique. Therefore, if a facility has four outfalls to sample and one can not be effectively sampled with automated equipment, staff may need to be trained to collect samples at that outfall anyway, and therefore it may not make much sense to install automated equipment at the other outfalls, unless other factors prevail.

The bottom line is that selecting a reliable and cost effective sampling method is dependant on a number of factors, including:

Frequency of monitoring
Types of parameters to be tested for
Physical layout and constraints of the outfalls
Safety considerations
Availability of on-site staff
Availability of contract sampling vendors
Availability of equipment

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. 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

Wednesday, February 4, 2009

Self Certification of SPCC Template Plans – What Is Required?

The SPCC Rule (40 CFR 112) now allows SPCC Plans to be self-certified (no PE certification required) by facilities, if they meet a few qualifications:

On-site oil storage capacity must be less than 10,000 gallons;
Over the past three years, no single spill greater than 1,000 gallons, and no more than two spills greater than 42 gallons have occurred;
The SPCC meets all SPCC Rule (40 CFR 112) requirements, without the use of “environmentally equivalent” or “impracticality” determinations.

For Tier I Qualifying facilities, the facility must also certify that it meets all the requirements necessary to use the SPCC Template Plan format. All "self-certified" SPCC Plans, including those using the SPCC Template Plan format, will still need to be signed by a responsible person on behalf of the facility. By signing the SPCC Plan, that person certifies that he/she is:

Familiar with SPCC requirements,
Has visited and reviewed the facility,
The Plan was prepared in accordance with accepted and sound industry practices,
Procedures for inspections and testing have been established,
The Plan is fully implemented, and
The facility meets all the requirements to qualify for self certification.

[Request information on State-specific SPCC Plans and Template Plans]

Caltha LLP offers expert technical and regulatory support to develop "self-certified" 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 requirements. For futher information on SPCC services, go to:
SPCC - 40 CFR 112 Compliance Services

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

Tuesday, February 3, 2009

Cost for Stormwater Monitoring - Managing Costs By Selecting Optimum Sampling Stategy

Many States now require dischargers to collect stormwater samples to demonstrate that their stormwater pollution prevention measures are effective. Samples are either visually examined on-site, or sent to a laboratory for chemical analysis. Either way – samples need to be collected.

Because in most States samples need to be collected within the first 30 minutes of discharge, stormwater monitoring presents some special challenges. To further complicate this requirement, rain events may also need meet specific requirements (i.e., 0.25 inch total rain fall, dry for previous 3 days, etc.). There are three basic options available to dischargers:

Train Facility Staff to Collect Samples. In this case, a few staff are trained on how to collect and handle samples.
Contract Third-party Sampler. Here, you would need to contract with a vendor who is located close enough to be at the site and ready to sample within 30 minutes of the start of a rain fall event.
Buy or Lease Automated Sampling Equipment. In this case, equipment is installed at each outfall and samples are collected automatically when water begins to flow. In most cases, equipment would need to be installed by trained personnel.

Each of these options has its unique benefits and drawbacks. Using a third-party sampler has some logistically problems, as most facilities find it difficult to have someone on-site within 30 minutes, especially considering that the vendor may also be providing this service to others. Using automatic equipment eliminates this logistical problem; however, automated equipment tends to be more costly, and often needs to be reset after small rain events or if any other water gets inadvertently discharged to the storm sewer. Therefore many dischargers opt to train their own staff to collect samples, as it is the least expensive and most reliable method.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules, including Development of Stormwater Monitoring Plans and Training Facility Staff to Collect Stormwater Samples. 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

Monday, February 2, 2009

Optimizing Consistency Between Multiple Industial SWPPP Plans

Larger companies may have several facilities that are subject to stormwater permit requirements and are required to develop site-specific Stormwater Pollution Prevention Plans (SWPPP). Some elements of the SWPPP will likely represent corporate wide programs that apply to all facilities. Companies may also want to “standardize” their SWPPP so that each facility is implementing similar programs; these will allow multiple facilities to share training materials, for example.

If all facilities are located within a single State, the process of standardizing the SWPPP programs is straightforward. Each facility SWPPP will need to include a site specific facility information and evaluation of the potential pollutant sources, but many of the program descriptions can be identical.

If facilities are located in different States, the process of maximizing consistency between SWPPPs requires significantly more thought. One option is to compile the most stringent set of requirements, and use them to develop the SWPPP template. The clear advantage of this approach is that all facilities will be conducting the same programs. The disadvantage is that many facilities will be implementing programs which are well beyond their own State requirements and will be incurring higher costs. Finding the proper balance between consistency and meeting individual State requirements is key.

For those companies that favor a higher degree of consistency between facilities, even at higher cost, there is another factor that should be considered. Overtime, individual State requirements change – on average, 20% of States revise their requirements each year. Therefore, careful consideration must be made to whether or not a change in one State will require that all SWPPPs in all States to be revised. If the answer is no, then over time, the SWPPP programs between States will become more and more different from each other. Therefore, the benefit of consistency that was important in the beginning will be lost.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. Caltha specializes in developing cost effective corporate-wide SWPPP programs covering multiple facilities. 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