MPCA SWPPP Permit Revision - Industrial Stormwater Requirements

On July 6, 2009, MPCA is scheduled to release its proposed Multisector General Permit (MSGP) for industrial stormwater discharges. This permit represents a major shift in stormwater pollution prevention (SWPPP) requirements for Minnesota industries and other affected sectors, such as transportation, POTWs, landfills, etc.

In July, Caltha LLP will be hosting seminars in several cities across Minnesota to provide information on the proposed permit and rule changes, and steps facilities can take to reduce their impact.

For more information, go to:

MPCA SWPPP Permit - Industrial Stormwater Permit Reissue Seminars

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

SWPPP - Does My Stormwater Pollution Prevention Plan Expire?

From time-to-time, Caltha receives inquiries from facilities that believe their Stormwater Pollution Prevention Plan (SWPPP) may have "expired".

The SWPPP, prepared in accordance with State or EPA permit requirements, is a "dynamic" document, and does not expire. However, at any point in time, the SWPPP needs to accurately reflect the current physical layout of the facility, the existing stormwater controls and spill containment and control measures, and the current emergency response procedures.

Because facilities change overtime, the SWPPP needs to be reviewed and updated accordingly. In many cases, the SWPPP needs to be amended prior to making the changes. The SWPPP may have to be revised for a number of different reasons, including:

• Changes to physical layout of the site


• Changes to locations for specific industrial activities


• Changes to materials handled at the site


• Changes to best management practices (BMPs) or stormwater controls


• Changes to Pollution Prevention Plan team members and/or responsibilities.

Facilities may also need to review and revise the SWPPP in response to issues that are identified during site inspections, site compliance evaluations, or benchmark stormwater monitoring results.

[Read more about relationship between benchmark monitoring and SWPPP]

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

Draft MPCA SWPPP Requirements for Food Products Facilities

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 a summary of the overall Minnesota permit, stormwater monitoring, and sector requirements]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Food and Kindred Products Sector (Sector U). Sector U covers a fairly broad range of facility types, including meat products, dairy products, bakeries, beverage products, and many others. These requirements are in addition to permit requirements that apply to all sectors.

Employee Training:
SWPPP training programs must include information on:
1) used oil and spent solvent management;
2) segregation of organic materials, raw materials, and products from contact with stormwater and precipitation; and
3) pest control

[Read more about Minnesota stormwater training]

Inspections:
Inspections must include:
a) waste management units;
b) vents and stacks associated with industrial activities;
c) spoiled product and broken product container holding areas;
d) animal holding pens;
e) staging areas; and
f) air pollution control equipment.

At least two of the monthly inspections must be conducted during runoff events. One of the inspections must be performed during a snow melt runoff event.

Stormwater Pollution Prevention Plan (SWPPP) Content:
The SWPPP must identify:
1) vents and stacks from cooking, drying, and similar operations;
2) dry product vacuum transfer lines;
3) animal holding pens;
4) spoiled product; and broken product container storage areas.

Potential Pollutant Sources:
The SWPPP must describe application and storage of pest control chemicals (e.g., rodenticides, insecticides, fungicides) used on plant grounds.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on product type:

Grain Mill Products:
TSS 100 mg/L

Fats and Oils Products:
TSS 100 mg/L
BOD5 25 mg/L
COD 120 mg/L
Ammonia 34.8 mg/L
Total nitrogen None

All Other Food Sectors:
TSS 100 mg/L
BOD 25 mg/L
COD 120 mg/L
Ammonia 34.8 mg/L
Total nitrogen 10 mg/L
Phosphorus 1.0 mg/L

Note: Benchmarks for ammonia and nitrate 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]
[Read more about what a 100 mg/L benchmark for TSS relates to]

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

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

Proposed MPCA SWPPP Requirements for Electric Generating Facilities

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 a summary of the overall Minnesota permit, stormwater monitoring, and sector requirements]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Steam Electric Generating Facilities (Sector O). Sector O covers three primary types of facilities, 1) steam electric power generation using coal, natural gas, oil, nuclear energy, etc., to produce a steam source; 3) dual fuel co-generation facilities; and 3) alternative fuel generating facilities used to produce steam.

These requirements are in addition to permit requirements that apply to all sectors.

Good Housekeeping Practices:
The SWPPP must describe and implement procedures to reduce or control the tracking of ash and residue from ash loading areas. Clear the ash building floor and immediately adjacent roadways of spillage, debris, and any excess water before departure of each loaded vehicle.

Inspections
Inspections must include:
a) coal handling areas,
b) switchyards,
c) ash handling areas,
d) areas adjacent to disposal ponds and landfills.

Inspections must include all residue-hauling (i.e. ash) vehicles for proper covering over the load, adequate gate sealing, and overall integrity of the container body. Dischargers must repair, as soon as practicable, vehicles without load covering or adequate gate sealing, or with leaking containers or beds. Two of the monthly inspections must be conducted during runoff events and one of the inspections shall be performed during a snow melt runoff event.

Preventative Maintenance:
The SWPPP must describe and implement measures that prevent or minimize stormwater from contacting fugitive dust emissions from coal handling areas and to prevent or minimize contamination of stormwater runoff from delivery vehicles carrying significant materials arriving at the facility. The SWPP must have procedures ensuring overall integrity of the body or container and procedures to deal with leakage or spillage from vehicles or containers.

The SWPPP must also describe and implement measures that prevent or minimize contamination of surface runoff from oil-bearing equipment in switchyard areas and to retard flows and limit the spread of spills from oil-bearing equipment in switchyards, or collecting runoff in perimeter ditches from these areas.

Spills and Leaks:
The SWPPP must describe and implement measures to reduce the potential for an oil or chemical spill, or reference an SPCC plan, and to visually inspect the structural integrity of all above-ground tanks, pipelines, pumps, and related equipment, and conduct any necessary repairs immediately.

Management of Runoff:
The SWPPP must describe and implement measures that prevent or minimize contamination of surface runoff from areas adjacent to disposal ponds or landfills, and must include procedures to reduce ash residue that may be tracked on to access roads traveled by residue handling vehicles, and reduce ash residue on exit roads leading into and out of residue handling areas.

SWPPP Contents:
The SWPPP must identify:
1) scrap yards, and general refuse areas;
2) short- and long-term storage of construction materials, paint equipment, oils, fuels, used and unused solvents, cleaning materials, paint, water treatment chemicals, fertilizer, and pesticides);
3) landfills and construction sites; and
4) stockpile areas (e.g., coal or limestone piles).

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on facility type:

Coal Fired and Oil Fired Steam Electric Generating Facilities:
TSS 100 mg/L
Iron 1.0 mg/L

Nuclear and Natural Gas Fired Co-Generation Facilities:
TSS 100 mg/L

[Read more about how benchmarks are used under the proposed MPCA industrial permit]
[Read more about what a 100 mg/L benchmark for TSS relates to]

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

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

Making SWPPP Available to Public - EPA Requirement

Stormwater discharge permit holders around the county understand that they must prepare and maintain a stormwater pollution prevention plan (SWPPP), and they must make the SWPPP available for review by the permitting agency. In many States, the SWPPP must be provided to local stormwater management agencies upon request.

Whether or not the SWPPP must be provided to members of the general public, upon request, is much less consistent from State to State and much more controversial. Because the SWPPP is required to contain specific information on activities, processes, raw materials, and other site specific information, it could conceivably contain confidential business and/or security information.

Many State general stormwater permits are silent on the issue of making the SWPPP available to the public. For States that do address the issue, the approach varies widely. Here is a sampling of permit language:

California General Industrial Discharge Permit:
“The SWPPP shall be provided, upon request, to the Regional Water Board. The SWPPP is considered a report that shall be available to the public by the Regional Water Board under Section 308(b) of the Clean Water Act.”


Colorado General Industrial Discharge Permit:
“All SWMPs required under this permit are considered reports that shall be available to the public under Section 308(b) of the CWA. The owner or operator of a facility with stormwater discharges covered by this permit shall make plans available to members of the public upon request. However, the permittee may claim any portion of a stormwater pollution plan as confidential in accordance with 40 CFR Part 2.”


New York General Industrial Discharge Permit:
“…in the interest of the public’s right to know, the permittee must make a copy of the SWPPP available to the public upon written request. (Note: A facility may withhold justifiable portions of the SWPPP from public review that contain trade secrets, confidential commercial information or critical infrastructure information in accordance with 6 NYCRR Part 616.7).”

In 2008, US EPA revised its own general permit (“MSGP-2008”) and clarified its requirements for making the SWPPP available to the public. EPA’s approach does not require providing access to the public directly, but it clarified that the public could obtain access to portions of the SWPPP through EPA.

US EPA Multisector General Permit (MSGP-2008)
“You must retain a copy of the current SWPPP required by this permit at the facility, and it must be immediately available to EPA; a State, Tribal, or local agency approving stormwater management plans; the operator of an MS4 receiving discharges from the site; and representatives of the U.S. Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) at the time of an onsite inspection or upon request. EPA may provide access to portions of your SWPPP to a member of the public upon request. Confidential Business Information (CBI) may be withheld from the public, but may not be withheld from those staff cleared for CBI review within EPA, USFWS, or NMFS.
EPA encourages you to post your SWPPP online and provide the website address on your NOI.”

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 DCR SWPPP Requirements - Proposed Changes

The Virginia Department of Conservation and Recreation (DCR) has proposed certain revisions to its current General Permit for Discharges of Stormwater from Construction Activities, which expires on June 30, 2009. Several updates have been proposed to the requirements for and contents of a Stormwater Pollution Prevention Plan (SWPPP) for the construction site, including:

• A requirement for the SWPPP to be made available to the public. Access to the
  SWPPP could be arranged at a time and location convenient to the operator or permittee, but no less than twice per month and during normal business hours.
• A direct requirement that all operators implement an Erosion and Sediment
  Control plan for the site in accordance with the Erosion and Sediment Control Law and Regulations.
• Clarification that water quality and quantity requirements must be met by the operator.
  The addition of an option for inspections of the site to be conducted every 7 days; the operator can still choose the current inspection schedule of every 14 days and within 48 hours following a runoff producing event if desired,
• A requirement that the operator report if there has been any correspondence with Federal officials regarding endangered species on the site, and a description of any measures necessary to protect such species,
• A requirement that any TMDL wasteload allocations made to construction activities be addressed through the implementation of control measures and strategies described in the SWPPP.

DRC anticipates that the revised permit will be published in June 2009, with an effective date of July 1, 2009.

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

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

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

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

Optimizing Consistency Between Multiple Industial SWPPP Plans

Larger companies may have several facilities that are subject to stormwater permit requirements and are required to develop site-specific Stormwater Pollution Prevention Plans (SWPPP). Some elements of the SWPPP will likely represent corporate wide programs that apply to all facilities. Companies may also want to “standardize” their SWPPP so that each facility is implementing similar programs; these will allow multiple facilities to share training materials, for example.

If all facilities are located within a single State, the process of standardizing the SWPPP programs is straightforward. Each facility SWPPP will need to include a site specific facility information and evaluation of the potential pollutant sources, but many of the program descriptions can be identical.

If facilities are located in different States, the process of maximizing consistency between SWPPPs requires significantly more thought. One option is to compile the most stringent set of requirements, and use them to develop the SWPPP template. The clear advantage of this approach is that all facilities will be conducting the same programs. The disadvantage is that many facilities will be implementing programs which are well beyond their own State requirements and will be incurring higher costs. Finding the proper balance between consistency and meeting individual State requirements is key.

For those companies that favor a higher degree of consistency between facilities, even at higher cost, there is another factor that should be considered. Overtime, individual State requirements change – on average, 20% of States revise their requirements each year. Therefore, careful consideration must be made to whether or not a change in one State will require that all SWPPPs in all States to be revised. If the answer is no, then over time, the SWPPP programs between States will become more and more different from each other. Therefore, the benefit of consistency that was important in the beginning will be lost.

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.

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

Do Construction Sites Need SPCC Plan In Addition To SWPPP?

Does a construction site that operates under a stormwater discharge permit and has a Stormwater Pollution Prevention Plan (SWPPP) also need a Spill Prevention Control and Countermeasure (SPCC) Plan?

The answer is POSSIBLY; the requirements for a stormwater discharge permit and for a SPCC Plan are independent of each other. Not all construction sites that need a stormwater permit also need an SPCC Plan - and some construction sites that do not need a stormwater permit may need an SPCC Plan.

Whether or not a given construction site needs an SPCC Plan will depend on the oil storage capacity on site, even if storage tanks, mobile tanks, oil-filled equipment, etc are only on-site temporarily. [Read more about SPCC requirements] Individual State programs may also have additional requirements for notification, registration or permitting of above ground storage tanks at construction sites.

Even construction sites that do not exceed the thresholds requiring an SPCC Plan need to have spill prevention and control measures. In most cases this requirement is contained in the site stormwater discharge permit, or in State general duty provisions to prevent and control spills, and to clean up spilled materials.

Caltha LLP offers some very cost effective options for construction sites needing to prepare SPCC Plans, SWPPPs, or to develop spill prevention and response procedures. Click here to request more information on construction site SPCC/SWPPP Services.

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

Managing Wastes and Waste Containers - Dumpsters - Roll-offs

One of the more challenging aspects of compliance with State and Federal stormwater pollution prevention requirements is the management of wastes. This holds true for both facilities that have a stormwater discharge permit, and facilities that have a conditional No Exposure Certification exemption.

Facilities that operate under a No Exposure Certification (NEC) find waste management particularly challenging because they have certified that wastes are not exposed to stormwater and that any wastes stored outdoors are managed in covered, water tight containers. In some States (e.g., Washington, New Jersey and others), all wastes must be stored inside a permanent building to qualify for the NEC exemption. Facilities that utilize roll-off containers find it challenging to either move containers indoors, or to use covered and water tight containers.

NEC facilities also have to address contractor wastes. As construction or renovation projects proceed, contractors need to meet the same requirements for waste storage. [Read more about NEC compliance]

Facilities that manage their stormwater impacts through a stormwater pollution prevention plan also need to address waste generation and storage. These facilities may elect to move wastes indoors or to use covered containers. However, in general, permitted facilities have more options available for waste management. They simply need to develop procedures to minimize the potential impacts of waste storage on their stormwater discharge.

Caltha LLP helps permitted and NEC facilities to develop cost effective waste management procedures to comply with regulatory requirements and to minimize their environmental footprint. Click here to request further information on Stormwater and SWPPP Services.

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

State SWPPP Template Virtual Library

Caltha LLP maintains a library of SWPPP Templates developed to meet the requirements of individual States. Separate stormwater plan templates are provided to Industrial, Municipal (MS4) and Construction stormwater dischargers.

Using a SWPPP Template, the level of effort required to complete a stormwater pollution prevention plan meeting State permit requirements is significantly reduced. The quality, ease-of-use, and effectiveness of the plan are also enhanced.

[Read more about what makes a good SWPPP template]

Caltha provides State-specific SWPPP templates for the following States:
[Click on a State to request information and options]

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

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

Looking for information on SWPPP - Stormwater Training in these States?

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

Pennsylvania DEP PPC Plan Requirements Compared to SWPPPs

The general permit for industrial stormwater discharges in Pennsylvania requires dischargers to prepare and implement a “Preparedness, Prevention and Contingency (PPC) Plan. This plan is unique to Pennsylvania dischargers; however, other States and the US EPA refer to a Stormwater Pollution Prevention Plan (SWPPP) to fill the same planning function.

The PPC Plan is equivalent to a typical SWPPP in many respects. Both PPC Plans and SWPPP include:

• Stormwater Management Practices
• Erosion and Sedimentation Control Practices
• Control of Non Stormwater Discharges
• Site Inspections
• Stormwater Monitoring
• SWPPP Training
• Special Requirements Applicable to SARA 313 Facilities

However, the PPC Plan has some unique requirements that are not typically part of SWPPP compliance requirements. One of the key differences includes the specific requirements for stormwater controls to be included in the PPC:

• Specific Best Management Practices (BMPs) or stormwater controls need to be “considered” by all dischargers (e.g., “Consider installing spill and overfill prevention equipment”)
• Specific Best Management Practices (BMPs) or stormwater controls required for all dischargers (e.g., “Install oil/water separators or oil and grease traps in fueling area storm drains.”, “Do not dispose of oil filters in trash cans or dumpsters”)
• Specific Best Management Practices (BMPs) or stormwater controls required for individual industrial sectors (e.g., “use drip pans when loading or unloading liquids”, “eliminate the use of chlorine products”, “install and use dust control/collection systems”)

Contact Caltha LLP for more information on PPC templates for industrial sectors in Pennsylvania.

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

SWPPP Certifications - What Is Certified and Who Needs to Sign?

Under 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, some 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 – What is Being Certified?
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, but here is an example:

"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."


Who needs to 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.

Click here for more information on State-specific SWPPP Templates.

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

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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SWPPP Template - What Makes a Good Stormwater Pollution Prevention Plan Template?

Caltha LLP uses SWPPP Templates to prepare stormwater pollution prevention plans each day. Templates can be used to prepare stormwater pollution programs for industrial sites, municipal dischargers (MS4) and for construction sites. In additon, SWPPP Templates can be augmented by Stormwater Monitoring Plan Templates, Sediment and Erosion Control Templates, Compliance Plan Templates, if needed.

Good SWPPP templates guide the user through a thoughtful self assessment, and not a “rush” to select BMPs. It has been our experience that using SWPPP templates is an excellent method to cost-effectively develop a site-specific pollution prevention program. However, the SWPPP templates needs to be more than a “fill-in-the-blank” exercise. By simplifying the process of preparing the plan, users often minimize the assessment process and move quickly to selecting BMPs.

Effective SWPPPs need to start with a thorough assessment of potential pollutant sources, which then can be carried forward through evaluation of potential controls, selection of BMPs, and all the way through on-going inspections and program improvements. An effective SWPPP template guides the user thorough the assessment process and creates a transparent and logical path to how potential pollutant sources will be controlled.

Based on our experience, some key features of an effective SWPPP template are:

• SWPPP template should guide the user through a thoughtful assessment process, which then serves as the basis for selecting SWPPP program elements and long-term implementation and permit compliance;
• The format of the SWPPP template should not detract from the final SWPPP product; the final SWPPP needs to be a well written plan that is easily read and understood. Unnecessary “remnants” of the template should not be included in the final SWPPP;
• The SWPPP template should incorporate requirements of the stormwater discharge permit. Because each State and Federal permit has unique requirements, a different SWPPP template needs to be used for each State.

Read more about SWPPP - Stormwater Compliance Document Virtual Library.

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

Revised Arizona ADEQ Stormwater Permit Requirements for Dischargers Near Impaired Waters or Unique Waters

On February 29, 2008, the revised Arizona Department of Environmental Quality (ADEQ) general permit for the discharge of stormwater from construction sites became effective. This permit replaced an earlier general permit which had expired. The revised general permit now applies to all construction sites greater than one acre in size, with the exception of sites located on Indian lands within the State. For these sites, a different permit, issued by U.S. EPA, applies.

The requirements under the ADEQ permit will change substantially depending on the location of the project. The key criteria will be whether the site is within ¼-mile of:

• An impaired water
• A listed unique water (also known as an “Outstanding Arizona Water”, or OAW)

For project sites located within this radius, significantly more stringent permit compliance requirements may apply which include:

• Submittal of SWPPP with NOI, and extended waiting period for permit coverage
• Additional prohibitions on non-stormwater discharges
• Additional prohibitions on post-construction discharges
• Additional inspection requirements
• Stormwater monitoring

For project sites located with ¼-mile of either an impaired water or a listed unique water, a Stormwater Monitoring Plan must be developed and implemented. Monitoring of stormwater includes visual monitoring each week and collection and analysis of samples when stormwater is discharged. Monitoring results are then reported to ADEQ on Discharge Monitoring Report (DMR) forms.

For more information on this permit, go to:

Summary of Revised ADEQ Permit

Stormwater Permit and SWPPP Requirements - Summary Trends and Changes

Here is a link to a presentation given at the ACHMM Annual Conference in August 2007:

Trends and Changes in Stormwater Permitting and SWPPP Requirements Across US

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