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.

IA Stormwater Permit And Compliance Consultant- SWPPP Engineer

Caltha LLP maintains a library of SWPPP Templates developed to meet the requirements of individual States, including Iowa. Separate stormwater plan templates are provided to Industrial, Municipal (MS4) and Construction stormwater dischargers. Our Iowa SWPPP templates are updated to meet new State permit requirements as new or revised permits are finalized.

Leaking Fuel Lines From Underground Fuel Tank

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 Iowa Department of Natural Resources (IDNR) permit requirements, including site specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a State Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the stormwater general permit.


Click here to request further information or a quote to prepare a facility SWPPP or revise your existing SWPPP. Click here to review example Caltha projects in Iowa and IA regulatory updates.

State Spill Plan, SPCC Plan, Contingency Plan Requirements

Caltha LLP maintains a library of SPCC Plan Templates developed to meet the above ground tank and spill prevention and response requirements of individual States and the Federal SPCC Rule. An SPCC Plan is require for any facility that exceeds an oil storage capacity of 1,320 gallons. Facilities potentially subject to the SPCC Rules (40 CFR 112) are not limited to industrial sites, but can include municipal, commercial, retail, institutional sites, construction sites, and even farms.

Leaking Fuel Tanks And Refueling Area 

Without Properly Sized Secondary Containment

The revised SPCC Rule now allows the use of streamlined SPCC plan formats if facilities meet certain criteria. These streamline SPCC Template plans do not need to be signed by a professional engineer in most States. Other SPCC plans may need to be reviewed and signed by an engineer. Caltha LLP also provides SPCC training for companies subject to the SPCC Rule and conducts SPCC inspections.

Caltha prepares SPCC Plans for the following States: [Click on a State to request information and options]

Alabama SPCC Plan

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

New NOI Required To Continue Coverage Under Revised Illinois Permit

The Illinois EPA issued its revised NPDES General Permit for industrial stormwater discharge in March 2017 and the permit was effective on April 5, 2015. Facilities that had been covered under the prior permit was wished to continue coverage under the new permit have to submit a new application.


Applications (Notice of Intent) for permit coverage were due with in 150 days after the new permit was effective. All permitted facilities need to submit a NOI before September 5, 2017.


Click here to review example Caltha projects related to stormwater permitting and stormwater pollution prevention, including SWPPP projects in Illinois.

New York No Longer Accepting NOI For General Permit Coverage

The New York State Department of Environmental Conservation (NYSDEC) published revisions to the SPDES Multi-Sector General Permit for Stormwater Discharges from Industry Activity (MSGP) (GP-0-17-004), which will replace the current one (GP-0-12-001) which expired on October 1, 2017.The new permit regulates stormwater discharges from industrial activities and was scheduled to become effective on October 1, 2017 with a five year permit term.


The revised permit has not been finalized and the expired permit remains in place. The Department will not be accepting applications for continued coverage until the revised permit and the new NOI are posted on agency website. The NOI for GP-12-001 has been removed and is no longer available to gain coverage under the MSGP.


Once GP-0-17-004 takes effect, there will be an interim period of 90 days. During this time, an owner or operator needs to update the facility’s Stormwater Pollution Prevention Plan (SWPPP) to comply with the requirements of the new permit before submitting a Notice of Intent (NOI) to obtain permit coverage. Some key changes in the new permit are expected to include:

• Non-numeric effluent limits were updated to include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response productions, and employee training.
• Semi-annual monitoring and discharge monitoring reports will be required for Benchmark and Numeric Effluent Limit monitoring. With this change, the Corrective Action forms and the Non-Compliance event forms will no longer be needed.
• Discharge Monitoring Reports must be submitted electronically through EPA’s electronic reporting system, NetDMR.
• The owner or operator must wait three days in a row without precipitation before they may complete the Comprehensive Site Compliance Inspection. This allows for dry weather flow monitoring to be performed so that non-stormwater discharges can be detected and addressed as necessary.

Click here to review example Caltha projects related to stormwater permitting and stormwater pollution prevention, including SWPPP projects in New York.

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.

Obtaining Permit Waiver Under 2017 EPA General Permit

The revised US EPA general permit for stormwater discharge from construction sites began effective on February 22, 2017. The revised general permit included an option for a permit waiver for certain projects.


These waivers are only available to stormwater discharges associated with small construction activities (i.e., 1-5 acres). The operator of a small construction activity may be able to qualify for a waiver in lieu of needing to obtain coverage under the general permit based on three factors. Each operator, unless otherwise needing permit coverage, must notify EPA of its intention for a waiver by submitting a waiver certification. Where the operator changes or another is added during the construction project, the new operator must also submit a waiver certification to be waived.


Waiver certifications are submitted prior to commencement of construction activities. If operators submit a TMDL or equivalent analysis waiver request, the project is not waived until EPA approves the request, and operators are advised not commence construction activities until receipt of approval from EPA. Operators are not prohibited from submitting waiver certifications after initiating clearing, grading, excavation activities, or other construction activities. However, EPA has indicated it reserves the right to take enforcement for any unpermitted discharges that occur between the time construction commenced and waiver authorization is granted.


Click here for more information on Caltha's Construction Stormwater Permitting and Compliance Support in your State.