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

Friday, February 27, 2009

Stormwater Management Improvement Projects Funded Through Federal Stimulus

The Iowa State Revolving Fund (SRF) is currently soliciting "green projects" to be funded the SRF in response to the recent Federal Stimulus Bill. The federal stimulus bill routes some of the funds for water quality through the State Revolving Fund programs. Iowa’s allocation is $53 million for Clean Water SRF and $24 million for Drinking Water SRF. About 20% of each amount is intended to be used for green infrastructure, water or energy efficiency improvements, or other environmentally innovative activities. While the Iowa SRF has projects that can be to funded with the remaining 80 percent, there are currently few fundable proposals for “green” projects.

Eligible stormwater management projects might include:

Water efficiency
o Reclamation, recycling, and reuse of rainwater, condensate, degraded water, stormwater, and/or wastewater streams

Stormwater quality management
o Stormwater infrastructure with a treatment component
o Stormwater retrofits that address hydrologic impacts to receiving waters by reducing discharge flow volume
o Street sweepers and vacuum trucks

Green infrastructure
o Implementation of green streets (green infrastructure practices in transportation right-of-ways)
o Porous paving, bioretention, green roofs
o Establishment or restoration of riparian buffers
o Retrofits to keep stormwater out of sewer system

All of the projects funded through the stimulus funds must have an environmental review and must comply with all federal regulations

Caltha LLP provides expert technical support to clients nationwide in addressing environmental review, stormwater management and stormwater pollution prevention 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

Thursday, February 26, 2009

Preventive Maintenance of Industrial Equipment - Permit Requirements

Maintenance of equipment and controls is a requirement for most stormwater pollution prevention programs. Maintenance can be 1) routine maintenance to correct deficiencies identified during routine inspections, and 2) preventive maintenance to address problems before they occur. In many jurisdictions, a written Preventive Maintenance Plan is required.

In most cases, two types of equipment or systems must be maintained:

Industrial equipment and systems, and
Stormwater BMPs and Stormwater Controls

Relative to industrial equipment and systems, routine maintenance and preventive maintenance is required for equipment and systems that could result in stormwater impacts if not properly maintained. Using the recent US EPA Multisector Permit (MSGP-2008) as one example, dischargers "must regularly inspect, test, maintain, and repair all industrial equipment and systems to avoid situations that may result in leaks, spills, and other releases of pollutants in stormwater discharged to receiving waters."

In addition, the MSGP-2008 requires that equipment that is awaiting maintenance be handled separately. Dischargers are required to "confine the storage of leaky or leak-prone vehicles and equipment awaiting maintenance to protected areas."

[Read more about maintenance requirements for stormwater controls and BMPs]

Caltha LLP provides expert technical support to clients nationwide in addressing stormwater permitting and SWPPP requirements, including developing effective inspection and preventive maintanence programs, and providing employee training programs.

[Read further information on Stormwater - SWPPP Services]

For further information contact Caltha LLP at
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Maintenance of Stormwater Controls - BMPs - Regulatory Requirements

Once installed stormwater Best Management Practices (BMPs) or stormwater controls need to be maintained in order to remain effective. The most intuitive example is a stormwater detention basin or pond. If the pond is sized to remove 90% of suspended solids, it will only meet this target removal efficiency if it is maintained at its designed size. Over time, an effective pond will trap sediment; this sediment displaces the water volume in the pond and its removal efficiency begins to drop. Without maintenance (which in this example would be removing accumulated sediment), the pond will eventually approach 0% removal efficiency.

From a regulatory perspective, most State permits require that stormwater BMPs be maintained; in this context, BMPs could be any structural or non-structural control measure that the site uses.

Using the recent US EPA Multisector General Permit (MSGP-2008) as an example, dischargers must "maintain all control measures ... in effective operating condition. Nonstructural control measures must also be diligently maintained (e.g., spill response supplies available, personnel appropriately trained). If you find that your control measures need to be replaced or repaired, you must make the necessary repairs or modifications as expeditiously as practicable."

Maintenance of stormwater controls requires:

Scheduled routine inspections, conducted by qualified staff
Detailed evaluation under comprehensive site compliance evaluations
Detailed documentation
Rapid corrective action

Industrial sectors that are required to conduct routine benchmark monitoring will find maintenance to be especially important. In addition to conducting routine visual inspections of their controls, they will also be collecting and analyzing samples of their stormwater discharge in order to demonstrate that their controls remain effective.

[Read further information on Stormwater - SWPPP Services]

For further information contact Caltha LLP at
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Tuesday, February 24, 2009

Stormwater Infiltration - Regulatory and Permitting Aspects

Infiltration is used as a stormwater control or Best Management Practice (BMP) in many areas. However, infiltrating run-off has some unique regulatory issues. First, in some States, infiltrating stormwater is a viable means to eliminate a discharge that would otherwise require an NPDES discharge permit. However, in most cases, the system would need to infiltrate all run-off from even the largest rain events. In addition, seasonal changes must also be considered; all run-off would need be collected and infiltrated even during frozen conditions. Some States regulate groundwater as a "water of the State", and therefore can regulate discharges to the groundwater using infiltration.

Here are two recent examples:

New Hampshire. New Hampshire has recently proposed requiring a "Alteration of Terrain" permit for many types of new projects. Infiltration of stormwater is prohibited if the run-off comes from "high load areas", which include many typical industrial activities.

[Read more about New Hampshire Alteration of Terrain permits]

Minnesota. The Minnesota Pollution Control Agency (MPCA) has been drafting regulations relating to infiltration of stormwater at sites regulated under the industrial stormwater discharge general permit. These requirements are still in revision, however as of November 2008 the format for regulation of infiltration as a stormwater control has included:

Design criteria for amount of run-off to be infiltrated

Rate at which infiltration must occur after a storm event

Pretreatment requirements for run-off prior to discharge to designed infiltration basin

Stormwater monitoring requirements and standards ("benchmarks") for run-off prior to discharge to designed infiltration basin

Operation and maintenance requirements.

The draft MPCA infiltration requirements also include several prohibitions, where infiltration can not be used to manage stormwater. These include:

Certain industrial sectors are prohibited from using infiltration BMPs;

Certain sensitive areas where groundwater is vulnerable to contamination, including karst areas, and well head protection areas.

Finally, under some circumstances the disposal of stormwater run-off using a designed infiltration system can be further regulated as a Class V Injection Well. This will require further permitting and associated regulation.

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

Monday, February 23, 2009

Stormwater Permit Compliance Plan - Companion to Facility SWPPP

SPCC Plan - Does My Spill Plan Expire?

From time-to-time, Caltha receives inquiries from facilities that believe their Spill Prevention, Control & Countermeasure (SPCC) Plan may have "expired".

The SPCC Plan, prepared in accordance with 40 CFR 112, is a "dynamic" document, and does not expire. At any point in time, the SPCC Plan needs to accurately reflect the current physical layout of the facility, the existing spill containment and control measures, and the current emergency response procedures.

Because facilities change overtime, the SPCC Plan needs to be reviewed and updated accordingly. At a minimum, the plan needs a formal review and revision (if necessary) every five years. However, certain elements of the Plan may change much more frequently - especially emergency contact information. The SPCC Plan should be revised before making changes to the facility that are relevant to compliance with the SPCC Rule.

Caltha LLP offers expert technical and regulatory support to develop 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. Click here to request further information on SPCC and SWPPP Services.
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Thursday, February 19, 2009

Visual - Benchmark Stormwater Monitoring Compared To Wet Weather Inspections

Overtime, the requirements for stormwater discharge monitoring have shifted. During the 1990s, when stormwater discharge permitting requirements began to develop, “wet weather inspections” were incorporated into many State general permits. These inspections were to be conducted during a rain event and required the discharger to make certain observations about the stormwater being discharged at each of the stormwater outfalls. In most cases, wet weather inspections could be conducted without actually collecting a sample of the stormwater discharge.

Subsequently, the US EPA Multisector General Permit (MSGP) became more detailed and the Visual Monitoring requirement was developed. Overtime, State permits also incorporated a requirement to conduct visual monitoring. However, in some cases permits were not clear as to whether or not a sample of stormwater needed to be collected. Because of this ambiguity, some dischargers believed that the same protocol they were using for wet weather inspections still applied.

Recently, the EPA MSGP was revised to eliminate any uncertainty regarding the protocol to be used for Visual Monitoring:
“The visual assessment must be made:
- Of a sample in a clean, clear glass, or plastic container, and examined in a well-lit area;
- On samples collected within the first 30 minutes of an actual discharge from a storm event.”

Benchmark monitoring is also required of some industrial sectors. Benchmark monitoring becomes an extension of Visual Monitoring. Rather than documenting the visual characteristics of the sample, it is simply sent to an analytical laboratory for chemical analysis.

Therefore, in practice the same basic protocol is required to collect stormwater samples for both visual monitoring and benchmark monitoring.

[Read more about benchmark monitoring]
[Read more about selected stormwater monitoring techniques and equipment]

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]

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