Biomonitoring Requirements - Amendment to OK Rules

The Oklahoma Department of Environmental Quality (ODEQ) is proposing to modify its rules concerning biomonitoring (whole effluent toxicity, or WET) requirements for wastewater dischargers. Under the proposed rules, a sublethal test failure (failure to demonstrate growth or reproduction) will be handled the same as a lethal test failure (death to the test organisms). This change is required based on changes in US EPA requirements and has already been promulgated into Oklahoma’s Water Quality Standards.

The proposed rule modifications also refine when a facility may request a biomonitoring organism change from Daphnia pulex or Ceriodaphnia dubia to Daphnia magna. Finally, the proposed rule modifications would also require monthly monitoring for phosphorus and/or nitrogen if a facility is discharging to a nutrient limited watershed as designated by Oklahoma’s Water Quality Standards.

Caltha LLP provides expert technical support to clients nationwide to address State water quality standards. Caltha provides specialized expertise in biomonitoring, aquatic toxicology and impacts to aquatic communities.

[Click here to request further information on aquatic toxicology and aquatic community impact assessment]

For further information contact Caltha LLP at
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NH Alteration of Terrain Permit – High Load Areas

The New Hampshire Department of Environmental Services (DES) has recently finalized new rules requiring an Alteration of Terrain Permit (AOT) for many types of construction projects. The purpose of these rules to protect drinking water supplies, surface waters, and groundwater by specifying the procedures and criteria for obtaining permits required by the rule. These rules shall apply to any person proposing to:
(a) Dredge, excavate, place fill, mine, transport forest products, or undertake construction in or on the borders of surface waters; or
(b) Significantly alter the characteristics of the terrain in such a manner as to impede the natural runoff or create an unnatural runoff.

One key aspect of the rule is the definition and requirements for “High-Load Areas”. High-load areas include:
(1) Industrial facilities subject to the NPDES Multi-Sector General Permit;
(2) Petroleum storage facilities;
(3) Petroleum dispensing facilities;
(4) Vehicle fueling facilities;
(5) Vehicle service, maintenance and equipment cleaning facilities;
(6) Fleet storage areas;
(7) Public works storage areas;
(8) Road salt facilities;
(9) Commercial nurseries;
(10) Non-residential facilities having uncoated metal roofs with a slope flatter than 20%;
(11) Facilities with outdoor storage, loading, or unloading of hazardous substances, regardless of the primary use of the facility; and
(12) Facilities subject to chemical inventory under EPCRA Section 312.

A Source Control Plan may need to be prepared and submitted to NHDES for any proposed projects that include high-load areas and larger commercial parking areas.

The new rule also details requirements that apply to stormwater management practices from high-load areas, which include:

• Prohibition on groundwater recharge;
• Prohibition on infiltration practices;
• Prohibition on stormwater filtering practices, without an impermeable liner; and
• Prohibition on stormwater swale practices, without an impermeable liner.
  

Caltha LLP provides expert technical support to clients nationwide to develop cost effective pollution prevention programs to meet State and Federal requirements.

For further information contact Caltha LLP at
info@calthacompany.com
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Stormwater Monitoring – Storm Water Sampling Services

An increasing number of States require routine sampling of stormwater discharges to demonstrate compliance with NPDES discharge permits. Whether samples are needed for visual monitoring, chemical monitoring, or benchmark monitoring, one of the more challenging tasks a permitted facility must address is how to collect valid stormwater samples.

Caltha LLP provides expert technical support to permitted facilities and/or their consultants and engineers to develop stormwater monitoring programs developed to meet the requirements of individual States. Storm water programs are provided to meeting the needs of both Industrial and Municipal (MS4) stormwater dischargers.

[Read more about selecting the right stormwater monitoring approach]
[Read more about stormwater benchmark monitoring]

Caltha LLP provides a range of stormwater monitoring services, from development of a written Stormwater Monitoring Plan, to conducting stormwater monitoring training, to supplying equipment and sampling personnel to collect samples.
[Read more about Stormwater Monitoring Services]

Caltha provides State-specific stormwater training for the following States:
[Click on a State to request more information]

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

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

When Does SWPPP Need To Be Prepared? - New Facility Start-up

New facilities that require an NPDES stormwater discharge permit are required to prepare and implement a stormwater pollution prevention plan (SWPPP). In the sequence of constructing and beginning operations at a new facility, when does the SWPPP need to be completed?

For many new facilities, the period of construction through startup will actually require two SWPPPs - one during construction phase and one for the on-going industrial activities.

Regarding the industrial permit phase, the specific requirements will differ somewhat from State-to-State. In general, the SWPPP will need to be prepared and implemented prior to submitting a Notice of Intent (NOI) for permit coverage. This is because the NOI will typically require certification the the SWPPP has been completed and implemented. Therefore, because many States require the NOI to be submitted well in advance of start-up, the SWPPP may need to be completed several weeks or even months prior to start-up.

In some cases, especial for discharges to impaired water or other special waters, the SWPPP document may also need to be submitted along with the NOI.

Caltha LLP provides expert technical support to clients nationwide in addressing stormwater permitting and SWPPP requirements.

[Read further information on Stormwater Plan - SWPPP Services]

[Read further information on Stormwater Training - SWPPP Training]

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

Polyaromatic Hydrocarbon (PAH) in Sealants - Stormwater Impact Studies

Collaborative studies by the City of Austin, TX, and the U. S. Geological Survey have identified coal-tar based sealcoat as a major and previously unrecognized source of polycyclic aromatic hydrocarbon (PAH) contamination. Several PAHs are suspected human carcinogens and are toxic to aquatic life.

Studies in Austin, Texas, showed that particles in runoff from coal-tar based sealcoated parking lots have concentrations of PAHs that are about 65 times higher than concentrations in particles washed off parking lots that have not been sealcoated. Biological studies, conducted by the City of Austin in the field and in the laboratory, indicate that PAH levels in sediment contaminated with abraded sealcoat are toxic to aquatic life and are degrading aquatic communities.

This research has led the City of Austin to ban the use of coal-tar sealants for roads, parking lots, driveways, and other paved areas.

Caltha LLP assists private and public sector clients in evaluating potential stormwater pollution sources and developing cost effective stormwater pollution prevention programs to minimize their environmental impacts.

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

Stormwater Plan Certification - SWPPP Certifications

Under most State and EPA stormwater permitting rules, a Stormwater Pollution Prevention Plan (SWPPP) may need to be certified. This 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, 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
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.

Who must 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.

Caltha LLP provides expert technical support to private and public sector clients in developing stormwater pollution prevention programs to meet regulatory requirements.

[Read more about State-specific SWPPP Templates

[Read more about Stormwater Training - SWPPP Training]

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

Stormwater Training - Stormwater Pollution Prevention Training

Caltha LLP provides Stormwater Training courses developed to meet the requirements of individual States. Separate stormwater training programs are provided to meeting the needs of Industrial, Municipal (MS4) and Construction stormwater dischargers.

Training is offered in a number of flexible formats, ranging from traditional classroom training presented periodically in different locations, to facility-level training conducted at individual sites to meet employee and/or contractor training needs. Caltha offers cost-effective web-based and remote training options. Caltha also creates facility-specific training materials and conducts “train-the-trainer” sessions for facility training staff.

Caltha offers several training options especially suited to meet the needs of small organizations.

Caltha provides State-specific stormwater training for the following States:
[Click on a State to request information on upcoming stormwater training programs and training options]

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

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