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.

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Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits

A New Topic Page has been created:

Water Quality Standards - Aquatic Toxicology - NPDES Permit Limits

Discussion of a variety of topics related to State and Federal Water Quality Standards, Ambient Water Quality Criteria, Sediment Criteria, NPDES & Site-specific Discharge Standards, Water Quality Management, Aquatic Toxicology, Aquatic Community Impacts, and Water Quality Assessment

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Stormwater Permit Compliance Plan - Companion to Facility SWPPP

Caltha LLP maintains a library of stormwater permit compliance plan templates developed based on the requirements of individual States and EPA general industrial stormwater discharge permits (also known as “Multisector general permits” or MSGP).

The stormwater permit compliance plan templates are simple plans, usually about 2 to 5 pages in length that provide basic guidance on permit compliance tasks and schedules. Facilities use the compliance plan as a resource planning guide and training tool.

How is a stormwater permit compliance plan different than the stormwater pollution prevention plan (SWPPP)? The SWPPP is an important document for any permitted facility – however, the SWPPP is only one compliance requirement within the permit. The compliance plan does not duplicate the SWPPP, but rather compliments the SWPPP by organizing all compliance tasks in the permit so that facilities can quickly make assignments, develop a Pollution Prevention Team, and track compliance.

Caltha provides Stormwater Permit Compliance Plan templates for the following States:
[Click on a State to request information]

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

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

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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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NPDES Permit Program Changes - Delegation For ADEC

The U.S. Environmental Protection Agency has recently delegated its authority under the Clean Water Act to the State of Alaska. EPA will hand off wastewater discharge permitting authority and enforcement in Alaska to the Alaska Department of Environmental Conservation (DEC).

Stormwater permitting program responsibility will not be immediately transferred to DEC. Existing dischargers will remain under the US EPA Multi-sector General Permit ("MSGP-2008"), finalized in September 2008. Over the next three years, Alaska DEC will take over the stormwater permitting program, and will issue their own permits for industrial, MS4 and construction site stormwater discharge.

Alaska joins 45 other states that oversee their own National Pollutant Discharge Elimination System (NPDES). Delegated States can write their own standards, but they can not be any less strict than federal standards.

In November 2008, DEC took control over wastewater discharge permits for timber harvesting, seafood processing and municipal dischargers. Existing permits from the EPA will turn into state permits. Over the next three years, in phases, the State will take over permitting of Federal facilities in Alaska, stormwater, mining, and finally oil and gas permits, cooling water and other minor permitting programs.

Caltha LLP assists clients in meeting State and Federal NPDES permit and compliance requirements. For more information on Stormwater Permits and Compliance, go to Stormwater and SWPPP website.

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Regulation of Pesticide Discharges Under NPDES Permit - New Court Ruling

On January 7, 2009, an Appeals Court vacated a U.S. Environmental Protection Agency (EPA) rule that has allowed pesticides to be applied to U.S. waters without a Clean Water Act permit. In November 2007, EPA had issued the final rule stating that pesticides applied in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) are exempt from the Clean Water Act's permitting requirements.

The Clean Water Act regulates the discharge of pollutants into the nation's waters by, among other things, requiring entities that discharge pollutants to obtain a National Pollutant Discharge Elimination System (NPDES) permit. For nearly 30 years before adoption of the 2007 rule, pesticide labels issued under the FIFRA were required to contain a notice stating that the pesticide could not be "discharged into lakes, streams, ponds, or public waters unless in accordance with an NPDES permit".

The court ruled that pesticide residues and biological pesticides constitute pollutants under federal law and therefore must be regulated under the Clean Water Act in order to minimize the impact to human health and the environment.

Caltha LLP assists dischargers in meeting State and Federal requirements for stormwater and wastewater discharge. Caltha also provides specialized expertise in the assessment, standards and regulation of pesticides and herbicides in the environment.

For further information contact Caltha LLP at
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What Are Non Stormwater Discharges and Illicit Discharges?

Stormwater discharge permits include sections discussing the prohibition on non stormwater discharges. Municipal stormwater permits (MS4 permits) also refer to “illicit discharges”; illicit discharges are equivalent to non stormwater discharges. The municipality must develop programs to detect illicit discharges and to eliminate them from being discharged to their system.

Non stormwater discharges are any waste or wastewater discharge through a stormwater outfall that is not stormwater. Non stormwater discharges are not limited to piped discharge of wastewater; discharges could be infrequent or even one-time discharges. Examples of periodic or infrequent discharges include washing of equipment or pavement, blowdown from cooling towers, condensation from chillers or compressors. Non stormwater discharges can be small discharges of water, such as dumping floor scrubber water in a parking lot.

The Clean Water Act does not recognize a “deminimis” discharge – all non stormwater discharge is prohibited, regardless of how small. [Read more about connection between non stormwater discharge prohibition and the Clean Water Act]

The obligation on the discharger under most State stormwater permits is to 1) conduct and document an assessment of potential non stormwater discharges at the permitted facility, and 2) either eliminate the discharge, or to obtain a separate discharge permit that allows the discharge. Permits will also contain a list of allowable non stormwater discharges, which is a small subset of non stormwater discharges that can be discharged without a separate permit, if certain conditions are met.

Caltha LLP assists permitted facilities in conducting non stormwater discharge assessments and determining preferred options for the alternate disposal of non stormwater discharges. Click here to request further information on Stormwater and SWPPP Services.

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MSGP 2008 - EPA Warning Regarding Delays in NOI Processing

US EPA has issued an alert to dischargers covered under the new industrial Multi-sector General Permit (2008 MSGP).

If you are an existing discharger that was covered under the 2000 MSGP and have already submitted a paper NOI, US EPA is advising that due to a technical system error, the EPA NOI Processing Center is experiencing delays in posting the paper NOIs on the Internet. EPA expects that the system error will be corrected by the end of January, at which time the NOI Processing Center can begin posting the paper NOIs received by EPA on the Internet. Please note that the NOI waiting period for the facility does not begin until the NOI has been posted on the Internet.

According to EPA, if the paper NOI was sent before or postmarked by January 5, 2009, your coverage under the 2000 MSGP will be administratively continued until you are authorized to discharge under the 2008 MSGP.

If you are an existing discharger and you have not yet filed your NOI, EPA recommends that you file your NOI electronically using the eNOI system immediately to minimize any delay in your discharge authorization under the 2008 MSGP and that you minimize any period of noncompliance without NPDES permit coverage.

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.

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EPCRA 313 Facility Requirements Under Stormwater Discharge Permits

When initially drafted, the US EPA general discharge permit for industrial stormwater discharges contained additional requirements which applied to selected facilities that stored and used larger quantities of chemicals. These requirements applied to a subset of EPCRA (also referred to as SARA) Section 313 reporting facilities; because a facility was required to submit a Toxic Release Inventory (TRI) report did not necessarily mean that these additional requirements had to be met under their stormwater discharge permit. The additional requirements included:

• Specific containment/diversion requirements
• Additional inspections
• Material compatibility requirements
• Site security
  

Over time, as “sector specific” or “multi-sector” general permits became more common, the need for additional requirements for Section 313 facilities became less critical. These requirements could be inserted into the requirements for individual industrial sector that typically used Section 313 chemicals.

Currently, only about one-third of States have general industrial permits that include additional requirements for EPCRA 313 facilities.

Caltha LLP provides technical support to facilities nationwide to meet their State-specific stormwater permitting requirements. Caltha maintains a library of SWPPP templates, Monitoring Plan templates, and SPCC templates to meet individual State requirements.

For further information contact Caltha LLP at
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Iowa (IDNR) Antidegradation Policy - Potential Impacts on Stormwater Permits

The Iowa Department of Natural Resources (IDNR) is proposing changes to its “Antidegradation Policy”. The changes can impact any wastewater discharger in Iowa, but especially new permittees or existing permittees that may wish to increase their discharge in the future. The changes being proposed include:

• Incorporate by reference the document entitled “Iowa Antidegradation Implementation Procedure,” which proposes an approach to assessing and minimizing degradation of Iowa’s surface waters,
  
• Update antidegradation policy language with four tier approach,


• Remove High Quality (Class HQ) and High Quality Resource (Class HQR) designated uses and add several waters to the newly proposed Outstanding Iowa Water (OIW) category.
  
  

Antidegradation policies can potentially have a significant impact on stormwater permitting requirements. Adding new stormwater discharge points, or increasing impervious area could be viewed as “new or expanded” discharge. This could result in extensive antidegradation reviews before proposed projects are allowed permit coverage. However, currently the IDNR is proposing to conduct antidegradation reviews for discharges authorized by general permits will occur for the entire class of general permittees when the general permit is issued. Although additional requirements may have to be met, individual projects would not need to conduct their own antidegradation review under the IDNR proposal.

The purpose of the antidegradation policy is to set minimum requirements to conserve, maintain, and protect existing uses and water quality for water bodies that currently meet their water quality standards. The department is required by Clean Water Act to develop and adopt a statewide antidegradation policy and to identify procedures for implementing the policy. Comments on the draft policy are being accepted through January 29, 2009.

Caltha LLP provides technical support to dischargers needing to evaluate and address their State's antidegradation requirements.

For further information contact Caltha LLP at
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No Exposure Exemption - Maintaining Compliance with NEC

Many industrial and “industrial-like” municipal facilities can avoid stormwater permit requirements by submitting and complying with No Exposure Certifications (NEC) which provides a conditional exemption from the requirement to obtain a stormwater permit. States differ in their exact requirements for this NEC exemption [read example of NEC differences], however, in general to meet the NEC requirements, no materials and industrial activities can be exposed to precipitation or stormwater run-off.

The important point regarding the NEC is that it creates a conditional exemption – as long as the facility meets the conditions, it is exempted. At any time the facility does not meet the conditions, the exemption does not apply and the facility may technically be discharging without a permit. Therefore, having systems or procedures to assure continuous compliance with the NEC requirements is important.

Caltha has found several areas at typical operations present a significant challenge to maintaining NEC compliance:

• Waste handling
• Loading/unloading
• Equipment maintenance activities
• Construction and renovation activities

Assuring that contractors that may be working on-site for short periods also meet NEC requirements is a important element of NEC compliance. Contractor materials and wastes, such as temporary roll-off containers, need to meet NEC requirements in most States.

Caltha LLP provides technical guidance to dischargers nationwide to meet NEC requirements and develop procedures to maintain compliance.

For further information contact Caltha LLP at
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Municipally-owned Industrial Facilities – Requirement for Separate Stormwater Permit

With the exception of power plants, airports, and uncontrolled sanitary landfills, stormwater discharges associated with specific industrial activities at facilities owned or operated by municipalities with populations of less than 100,000 had been temporarily exempted from the need to obtain coverage under an NPDES industrial storm water permit.

However, under the provisions of the NPDES Stormwater Program Phase II Final Rule, these industrial facilities now may require permit coverage. These permit requirements are separate, and are in addition to, the requirement for designated municipalities to obtain coverage for their storm water discharges under the general permit for stormwater discharges from regulated small Municipal Separate Storm Sewer Systems (MS4s) (i.e., Phase II or MS4 Permit).

Some municipalities may own or operate one or more industrial facilities that are likely to require permit coverage for their storm water discharges. Some examples include:

• Sand and Gravel Operations
• Landfills, Land Application Sites, and Open Dumps
• Recycling Facilities
• Steam Electric Generating Facilities
• Marinas
• Waste Collection and Hauling
• Motor Freight Transportation and Warehousing
• Municipal Airports
• Wastewater Treatment Works

As more small municipalities become subject to MS4 permits, they are reviewing operations to determine if additional permit coverage under an industrial stormwater permit is required. Regardless of the requirement for additional coverage under an industrial permit, these municipal operations need to be evaluated and addressed under the MS4 stormwater pollution prevention program.

Caltha LLP provides technical support to MS4 permitees and/or their municipal engineers nationwide to assess operations and determine permit applicability. Contact Caltha LLP for further information on assessing municipally-owned industrial operations to determine applicability.

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SIC and NAICS Systems – Use in Stormwater Permit Rules

Industrial stormwater discharge permit requirements are largely driven by the Standard Industrial Classification (SIC) code assigned to the site. The stormwater regulation is one of the few environmental regulatory programs that use SIC codes. In 1997, the use of the North American Industry Classification System (NAICS) adopted by the US to replace the SIC code system. Both the SIC and NAICS systems were developed to organize and track information the US economy.

The basic difference in approach to the two systems is that the SIC system classifies establishments based on their economic output (i.e, what they produce or provide), and the NAICS classifies establishments according to the processes used to produce goods and services (i.e., what they do).

The basis for stormwater permitting rules remains the SIC code system. The only US EPA environmental regulatory program that had adopted the NAICS system is the Emergency Preparedness and Community Right-to-know Act (EPCRA) Section 313, commonly referred to as Toxic Release Inventory (TRI) reporting. The most significant difference between the two systems from a regulatory perspective is how they address “auxiliary” or “ancillary” facilities. [read more about auxiliary facilities]

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Stormwater Benchmarks - Comparison To Typical Stormwater Concentrations

About one-third of US States include chemical monitoring in their general stormwater discharges permits. Over time, this percentage has been increasing as States renew these permits as they expire. For States that require chemical analysis of stormwater samples, “benchmark” concentrations or values are often included. Benchmark concentrations can be specified for a number of different chemical parameters, but the more common chemicals which are assigned benchmarks include total suspended solids (TSS), biochemical oxygen demand (BOD), chemical oxygen demand (COD), nutrients and heavy metals.

Benchmark values differ from permit limits. In a typical wastewater NPDES permit, limits may be specified for chemical parameters; if any of the limits are exceeded, it becomes a violation of the permit and may be subject to enforcement action.

Benchmark values are intended to provide a measurement of the effectiveness of the stormwater pollution prevention plan (SWPPP). Exceeding a benchmark does not directly result in a permit violation. However, permits typically require facilities to reevaluate their SWPPP and to take prompt corrective action after a benchmark value is exceeded. Failure to take prompt corrective action if a benchmark value is exceeded can be a permit violation and subject to enforcement action.

Benchmark values tend to be fairly stringent. For example, a common benchmark concentration for total suspended solids (TSS) is 100 mg/L. To put this concentration into perspective, it is roughly equivalent to 1 teaspoon of sediment added to 14.5 gallons of water.

As a sector example, US EPA tested the stormwater discharge at 185 transportation and warehousing facilities. The average TSS was reported as 466 mg/L and half the facilities sampled exceeded 159 mg/L (Federal Register Vol. 60, No. 189).

The message in these data is simple; meeting stormwater benchmark values or other stormwater discharge limits can be a challenge to many facilities. It requires a thoughtful evaluation of potential pollution sources and an effective plan to minimize discharges.

[read more about selecting appropriate stormwater monitoring techniques]

Caltha LLP maintains a library of Stormwater Monitoring Plan templates to meet individual State requirements, and provides ad hoc technical guidance in developing and implementing stormwater monitoring programs.

For further information contact Caltha LLP at
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Local Stormwater Requirements - Additional Stormwater Compliance Requirements

One of the challenges many facilities face is complying with local stormwater requirements. These requirements are beyond those requirements specified in an NPDES permit. In fact, many local requirements apply to all properties, regardless of SIC code or whether or not a facility is required to obtain a discharge permit.

One of the most challenging aspects of complying with local requirements is the fact that different jurisdictions can have widely different requirements. Cities, Counties or other jurisdictions can range from very generic requirements, or very detailed requirements. For example, the City of Tampa Bay, Florida has general requirements:

Sec. 21-9. Protection of public drainage systems. •It is unlawful to introduce any foreign matter (including, but not limited to, trash, leaves, grass clippings, debris, garbage, fill, construction materials, organic or inorganic pollutants, acids, and petroleum products), whether by action or inaction, to any public drainage system including but not limited to streets.

In contrast, the City of Fremont, CA, for example, has very prescriptive requirements. Here is a small sample of the City's requirements:

I.K. Vehicle/Equipment Repair and Maintenance –1) Vehicle/equipment repair and maintenance shall be performed in a designated area indoors, or if such services must be performed outdoors, in an area designed to prevent the run-on and runoff of stormwater. 2) Secondary containment shall be provided for exterior work areas where motor oil, brake fluid, gasoline, diesel fuel, radiator fluid, acid-containing batteries or other hazardous materials or hazardous wastes are used or stored. Drains shall not be installed within the secondary containment areas.

Whether the local requirements are general or specific, in most cases, NPDES permits require compliance with local requirements in addition to permit conditions. In preparing SWPPPs, local requirements need to be considered in addition to the permit requirements.

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SPCC Requirements for Electric Transformers & Other Electrical Equipment

Oil-filled equipment are regulated under SPCC requirements - 40 CFR 112. This includes some very common types of equipment: hydraulic systems, lubricating systems, gear boxes, electrical transformers & other electrical equipment, coolant and heat transfer systems.

Some electrical equipment, such as transformers, on a property may not be under the control of the facility. This equipment could be installed, owned and operated by the local power provider or municipality. The SPCC Rule still applies to this equipment, however the specific requirements may be different depending on who owns and operates the equipment.

Caltha LLP provides expert technical support to facilities and/or consulting engineers on compliance with SPCC Rules. Caltha maintains a library of SPCC Plan templates to match site-specific needs. For futher information on SPCC services, go to:
SPCC - 40 CFR 112 Compliance Services

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Oil-filled Equipment Requirements Under SPCC Rule - 40 CFR 112

Oil-filled equipment is regulated under SPCC requirements. This includes some very common types of equipment: hydraulic systems, lubricating systems, gear boxes, electrical transformers & other electrical equipment, coolant and heat transfer systems.

One of the challenges of complying with SPCC requirements is providing adequate secondary containment around this type of equipment. Recent revisions to the SPCC rule now may allow facilities to rely on an inspection program and contingency planning in lieu of secondary containment. To quality for this exemption, facilities need to meet a number of specific conditions.

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Polycyclic Aromatic Hydrocarbons in Stormwater - Austin Sealcoating Studies

Collaborative studies (Fact Sheet) 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, as indicated by loss of species and decreased numbers of organisms.

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.

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Self-Certification of SPCC Plans - Requirements for Certification

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.
  

SPCC Plans 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.

Caltha LLP offers expert technical and regulatory support to develop facility Spill Prevention, Control & Countermeasure (SPCC) plans to be "self-certified". Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112 requirements.

For further information contact Caltha LLP at
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Minnesota (MPCA) Stormwater Discharge Permit Enforcement Actions

The Minnesota Pollution Control Agency (MPCA) recently released a summary of enforcement actions closed in the third quarter of 2008. These data, combined with the previous two quarters, show that 20% of all enforcement actions taken by MPCA so far in 2008 involve violations of stormwater discharge regulations.

For further information contact Caltha LLP at
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