Stormwater Discharges Become Priority Under CWA Enforcement Plan

Stormwater runoff from industrial, construction and urban lands is included as a priority under US EPA's recent Clean Water Act enforcement initiative.

EPA has announced that it is stepping up efforts on Clean Water Act enforcement. A plan "Clean Water Action Enforcement Plan" has been drafted as a first step in revamping the compliance and enforcement program. The plan outlines how EPA will strengthen the way it addresses modern water pollution challenges. These challenges include pollution caused by numerous, dispersed sources, such as concentrated animal feeding operations, sewer overflows, contaminated water that flows from industrial facilities, construction sites, and runoff from urban streets.

The agency intends to target enforcement toward the most significant pollution problems, improve transparency and accountability by providing the public with access to better data on the water quality in their communities, and strengthen enforcement performance at the state and federal levels. Elements of the plan include the following:

• Develop more comprehensive approaches to ensure enforcement is targeted to the most serious violations and the most significant sources of pollution.
• Work with states to ensure greater consistency throughout the country with respect to compliance and water quality.
• Ensure that states are issuing protective permits and taking enforcement to achieve compliance and remove economic incentives to violate the law
• Use modern information technology to collect, analyze, and use information in new, more efficient ways and to make that information readily accessible to the public.

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
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New Airport Deicing Fluid Regulations - Requirement to Collect and Treat

U.S. Environmental Protection Agency has proposed regulations requiring airports to collect at least some of the deicing fluid after it is used on aircrafts with a goal of cutting chemical discharge by 22%. The regulations would require six of the 14 major U.S. airports that are the biggest users of deicing fluid to install deicing pads or other collection systems to capture 60% of fluid sprayed and to install deicing pads or other collection systems. Some of the targeted airports include:

• New York's John F. Kennedy and LaGuardia airports,
• Chicago's O'Hare,
• Boston Logan International,
• Cleveland-Hopkins International, and
• New Jersey's Newark Liberty International

It would then be the airports' responsibility to ensure that the collected fluid was treated and handled in accordance with requirements. Some 200 smaller facilities around the US would have to collect 20 percent of the fluid by using technologies such as a glycol recovery vehicle, while airports with fewer than 1,000 yearly jet departures would not be impacted.

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
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Industrial Storm Water Permit - Extension of Public Comment Period

The Minnesota Pollution Control Agency (PCA) has extended the public comment period for the proposed Industrial Stormwater Discharge Permit. PCA issued its draft NPDES permit on July 6 and is accepting public comments through September 5, 2009.

For more information, go to:

Summary of Proposed Industrial Stormwater Permit

Summary of Industrial Sectors and Industrial Sector Requirements

Minnesota Industrial Stormwater Training Opportunities

Minnesota Industrial Stormwater Services Summary

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
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Virginia DEQ Industrial SWPPP Template - Monitoring Plan Template

The Virginia Department of Environmental Quality (VDEQ) has issued its revised Multi-sector Industrial Stormwater Permit, which became effective on July 1, 2009. The reissued permit includes a number of compliance requirements that are new to many Virginia industries, including:

• Increased training requirements


• Increased inspection requirements


• Stormwater benchmark monitoring

[Read more about changes to DEQ benchmark monitoring requirements]

Existing facilities that were previously covered under the VDEQ industrial permit are required to come into compliance with the reissued permit by October 1, 2009. New facilities are required to be in compliance with the industrial permit when they submit their permit application (Notice of Intent, or NOI).

Caltha LLP has recently completed a stormwater pollution prevention plan (SWPPP) template, Compliance Plan template, and Stormwater Monitoring Plan template specifically constructed to meet the requirements of the new VDEQ stormwater permit. For more information on how these templates can reduce the time and cost for permit compliance, contact Caltha LLP by email at Virginia SWPPP Template

Looking for SWPPP Compliance templates for a different State? Click here

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

Virginia VDEQ Stormwater Benchmarks - Changes To Sector Requirements

The Virginia Department of Environmental Quality (DEQ) revised general permit for industrial stormwater discharges became effective on July 1, 2009. The revised permit changed the compliance requirements for many industrial sectors that are subject to the industrial storm water regulations.

Existing facilities that were previous covered under the VDEQ industrial permit are required to come into compliance with the reissued permit by October 1, 2009.

The reissued permit amended some of the requirements for benchmark monitoring, including adding some new industrial sectors that in the past had not been required to conduct benchmark (chemical) monitoring of their stormwater discharges. The amended permit also added to the number of chemical parameters some sectors need to sample for.

Newly Added industrial Sectors that require benchmark monitoring

Sector P Land Transportation and Warehousing
Sector U Dairy Products Facilities
Sector R Ship and Boat Building or Repairing Yards

Industrial Sectors with Expanded Benchmark Monitoring Requirements

Sector N - Ship Dismantling, Marine Salvaging and Marine Wrecking Facilities
Sector S - Airports

The revised permit clarified that benchmark monitoring needs be performed at least once during at least the first two, and potentially all monitoring periods, unless the facility qualifies for a waiver. Benchmark monitoring waiver requests will be evaluated by DEQ based upon (1) benchmark monitoring results below the applicable benchmark concentration values; (2) a favorable compliance history (including inspection results); and (3) no outstanding enforcement actions. The benchmark monitoring waivers can be revoked by DEQ for cause. The revised general storm water permit also clarified that for inactive and unstaffed sites must have no industrial materials or activities exposed to storm water to qualify for this waiver

Caltha LLP has recently completed a stormwater pollution prevention plan (SWPPP) template, Stormwater Monitoring Plan template and Compliance Plan template specifically constructed to meet the requirements of the new VDEQ stormwater permit. For more information on how these templates can reduce the time and cost for permit compliance, contact Caltha LLP by email at Virginia SWPPP Template

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

Arkansas - ADEQ Industrial Stormwater Permit - SWPPP Template

The Arkansas Department of Environmental Quality (ADEQ) has issued its revised Multi-sector Industrial Stormwater Permit, which became effective on July 1, 2009. The reissued permit includes a number of compliance requirements that are new to many Arkansas industries, including:

• Increased training requirements
• Increased inspection requirements
• Stormwater benchmark monitoring

Caltha LLP has recently completed a stormwater pollution prevention plan (SWPPP) template and Compliance Plan template specifically constructed to meet the requirements of the new ADEQ stormwater permit. For more information on how these templates can reduce the time and cost for permit compliance, contact Caltha LLP by email at Arkansas SWPPP Template

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

Air Transportation Facilities - SWPPP - Stormwater Permit Proposed Requirements

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in October of 2002.

[Read an overall summary of the proposed MPCA Industrial Stormwater Permit]

Some key changes in the July 6, 2009 proposed permit are the additional details for 29 different sector specific requirements. The requirements described below are proposed for the Air Transportation Facilities Sector (Sector S). Sector S facilities include only those portions of the site that are engaged in servicing, repairing, or maintaining aircraft and ground vehicles, equipment cleaning and maintenance, or deicing/anti-icing operations.. These requirements are in addition to permit requirements that apply to all sectors.

Employee Training:
In addition to other training requirements, employee training programs need to include training:
1. Proper handling of deicing materials and fuels.
2. Spill and leak prevention.
3. Proper recordkeeping of deicing fluids applied and stored.

[Read more about Minnesota stormwater training]

Good Housekeeping:
For agricultural aviation operations occur, the facility must prevent contact of stormwater with pesticides, herbicides, and other agricultural chemicals.

Inspections:
In addition to the routine inspection requirements, facilities must conduct two inspections per month during the deicing season. Operations must conduct two of the monthly inspections during runoff events. One of the inspections must be performed during a snow melt runoff event. Each inspection must include a visual assessment of the runoff to identify any visible sheens or films that indicate the presence of oil or grease in the discharge.

Preventive Maintenance:
All facilities must evaluate whether over application of deicing chemicals on runways occurs by analyzing and adjusting application rates as necessary, consistent with considerations and requirements of flight safety The site SWPPP must include measures to prevent or minimize contamination of stormwater from all areas used for aircraft, ground vehicle and equipment maintenance, and must store all aircraft, ground vehicles and equipment awaiting maintenance in designated areas only.

Leaks & Spills:
Each individual permittee is required to report spills equal to or exceeding the reportable quantity (RQ) levels. If an airport authority is the sole permittee under the permit, then the sum of all spills at the airport must be assessed against the RQ. If tenants exist at the airport, then the amount spilled by each tenant shall be assessed against the RQ determination.

Potential Pollutant Sources:
The site SWPPP must also describe potential pollutant sources including aircraft, runways, ground vehicle and equipment maintenance and cleaning, aircraft and runway deicing operations, runways and loading areas where agricultural aviation operations occur.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. The benchmark concentrations are based on deicing chemical usage:

>100,000 gallons of glycol-based deicing/anti-icing chemicals and/or >100 tons of urea on an average annual basis:
BOD 25 mg/L
COD 120 mg/L
Total Ammonia 2.8 mg/L
pH 6-9

Less than 100,000 gallons
BOD 25 mg/L
COD 120 mg/L
Total Ammonia 2.8 mg/L

Note: Benchmark for ammonia were derived based on the Aquatic Life Standards for these parameters in Minnesota Rules.

[Read more about use of Aquatic Life Standards to derive stormwater benchmarks]
[Read more about how benchmarks are used under the proposed MPCA industrial permit]


Looking for information on Minnesota SWPPP - Industrial Stormwater Training?, go to:
MPCA Industrial Stormwater Training - SWPPP Training - Stormwater Inspection Training


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