Archive for the ‘Water’ Category

All Industrial Facilities Required To Reapply For Georgia General Permit In 2017

Tuesday, March 21st, 2017

The current Georgia industrial stormwater general discharge permit expires on May 31, 2017. The revised NPDES General Storm Water Permit For Discharges of Stormwater Associated With Industrial Activity (2017 IGP) was finalized in 2016 and becomes effective on June 1, 2017. The revised permit made some modifications to requirements permitted facilities must meet, but not as substantial changes compared to the release of the 2012 IGP.

Summary of 2012 IGP

What If My Facility Is Already Covered Under the Existing Permit?

Current permittees are required to submit a new Notice of Intent (NOI) to obtain coverage under the 2017 IGP and to maintain coverage for discharging stormwater associated with industrial activities. Facilities previously covered under the 2012 IGP will have up to 30 days to submit the new NOI for coverage under the updated 2017 IGP after the effective date.

What If I Exceeded Benchmarks Under Current Permit?

If a facility exceeded the impaired waters benchmark based on the criteria presented in 2012 IGP permit,  the facility has the option to conduct 12 months of flow-weighted composite sampling to demonstrate the discharge does not cause or contribute to an exceedance of water quality standards, or make the necessary improvements to the facility to achieve the instream water quality standard as an effluent limit within 36 months. If the facility still is unable to meet the impaired waters benchmark(s), they may not be authorized to discharge stormwater under the 2017 IGP and may be required to apply for an individual NPDES permit or alternative general permit.

Facilities that failed to meet the applicable benchmarks of the 2012 IGP permit have the option to sample their discharge(s) for 12 months to confirm whether the facility causes or contributes to an exceedance of the applicable Water Quality Standard, or prevent all exposure of industrial processes, materials, and equipment to stormwater, and/or capture and treat storm events of up to 1.2 inches within industrial areas exposed to stormwater within 36 months.

What If I Am Covered Under A No Exposure Exclusion?

Existing facilities that filed under the ‘No Exposure Exclusion’ (NEE) of the 2012 IGP must submit a new NEE form no later than 30 days after the effective date of the 2017 IGP to retain NEE status.

Annual Storm Water Training Program For Employees At North Dakota Food Processing Plant

Sunday, February 5th, 2017

Caltha LLP Project Summary

Project: Annual Employee Stormwater Training For Food Sector Facility
Food Sector SIC 20 Facility
North Dakota

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training, Webinar

Overview: Caltha LLP was retained by this food manufacturing company to prepare and present annual SWPPP training, as required under the North Dakota Department of Health (NDDH) multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

  • Overview of discharge permit
  • Overview of the contents of the SWPPP;
  • Spill prevention and response procedures
  • Good housekeeping practices;
  • Maintenance requirements
  • Material management practices
  • Location and maintenance of on-site stormwater pollution prevention controls;
  • Operating procedures for preventing pollution; and
  • Inspection procedures and records maintenance.

Training was presented by “live” webinar to all affected employees by a qualified SWPPP trainer.

For more information on Caltha LLP services, go to the Caltha Contact Page

Annual SWPPP Employee Training For Minnesota Manufacturing Facility

Sunday, February 5th, 2017

Caltha LLP Project Summary

Project: Annual SWPPP Training For Food Sector Facility
Food Sector SIC 20 Facility

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training

Overview: Caltha LLP was retained by this food manufacturing corporation to prepare and present annual SWPPP training, as required under the Minnesota Pollution Control Agency multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

  • Overview of Discharge Permit
  • Components and Goals of the SWPPP
  • Stormwater Monitoring
  • Monthly Facility Inspections
  • Other Tasks Required By Permit

Training was presented to all affected employees by a qualified SWPPP trainer.

For more information on Caltha LLP services, go to the Caltha Contact Page

Compliance Deadline For New Industrial Stormwater BMPS In Pennsylvania

Wednesday, January 25th, 2017

The Pennsylvania DEP General Industrial Stormwater Permit General PAG-03 was revised in September 2016. This latest version of the permit updated the Best Management Practices (BMP) that apply to all industrial sectors to conform to the general BMPs contained in EPA’s most recent Multisector General Permit (MSGP), which was released in 2015.

The reissued General Permit identified several new BMPs to reduce pollutants in the stormwater discharges of industrial facilities and  expanded the 12 industrial sectors that were included in the prior version to 30 specific industrial sectors. The new BMPs requirements included:

  • Use of spill/overflow protection equipment,
  • Control discharges through secondary containment or treatment for open dumpsters and roll off boxes,
  • Install velocity dissipation devices at discharge sites, and
  • Maintain readily accessible spill kits in locations where spills may occur.

Because some of the new BMPs may not have been required for previously permitted facilities, DEP provided a one year “transition period” for any required BMPs that existing permittees must implement that were not part of the previous General Permit. DEP included a provision that alternatives to the sector-specific BMPs may be implemented, if authorized by DEP.

The deadline for implementing new BMPs is September 24, 2017.

Changes To Requirements For Preparedness, Prevention and Contingency Plan PPC

Wednesday, January 25th, 2017

In the revised General Industrial stormwater discharge permit issued in September 2016, Pennsylvania DEP has updated the requirements for Preparedness, Prevention and Contingency (PPC) Plan. The purpose for the update was to make the General Permit consistent with the current language being used for individual NPDES permits for industrial stormwater discharges.

Compared to the previous PAG-03 General Permit, several significant changes were made:

  1. removal of the requirement for engineering certification of PPC Plans every year for facilities subject to SARA Title III, Section 313, and
  2. requires annual review and update, if necessary, of the PPC Plan to be documented in the annual report.

In addition, a PPC Plan will be required as part of each complete NOI submission, including No Exposure Certification submissions.

Proposed Changes To Washington 2015 Construction Stormwater Permit

Wednesday, January 25th, 2017

On November 18, 2015, Ecology issued an updated Construction Stormwater General Permit (CSWGP). The permit became effective January 1, 2016. One appeal was filed with the Washington Pollution Control Hearings Board on December 17, 2015. To resolve the case, Ecology has proposed several revisions to the permit and has posted these revisions for public comment. Comments are due by February 10, 2017.

The proposed changes are to dust control (S1.C.3.i), pH sampling requirements (S4.D), engineering calculation requirements (S9.B.1.f), and concrete washout (S9.D.9.h). The proposed changes are:

  • S1.C.3.i – Uncontaminated or potable water used to control dust. Permittees must minimize the amount of dust control water used.
  • S4.D – pH Sampling Requirements – Significant Concrete Work or Engineered Soils
    If construction activity results in the disturbance of 1 acre or more, and involves significant concrete work (significant concrete work means greater than 1000 cubic yards poured concrete or recycled concrete used over the life of a project ) or the use of recycled concrete or engineered soils (soil amendments including but not limited to Portland cement-treated base [CTB], cement kiln dust [CKD], or fly ash), and stormwater from the affected area drains to surface waters of the State or to a storm sewer system that drains to surface waters of the State, the Permittee must conduct pH sampling as set forth below. Note: In addition, discharges to segments of water bodies on Washington State’s 303(d) list (Category 5) for high pH are subject to a numeric effluent limit for pH; refer to Special Condition S8.
    1. For sites with significant concrete work, the Permittee must begin the pH sampling period when the concrete is first poured and exposed to precipitation, and continue weekly throughout and after the concrete pour and curing period, until stormwater pH is in the range of 6.5 to 8.5 (su).
    2. For sites with recycled concrete where monitoring is required, the Permittee must begin the weekly pH sampling period when the recycled concrete is first exposed to precipitation and must continue until the recycled concrete is fully stabilized with the and stormwater pH is in the range of 6.5 to 8.5 (su).
  • S9.B.1.f – Engineering calculations for ponds, treatment systems, and any other designed structures. When a treatment system requires engineering calculations, these calculations must be included in the SWPPP. Engineering calculations do not need to be included in the SWPPP for treatment systems that do not require such calculations.
  • S9.D.9.h – Assure that washout of concrete trucks is performed off-site or in designated concrete washout areas only. Do not wash out concrete trucks drums or concrete handling equipment onto the ground, or into storm drains, open ditches, streets, or streams. Do not dump excess concrete on site, except in designated concrete washout areas. Concrete spillage or concrete discharge directly to groundwater or to surface waters of the State is prohibited. Do not wash out to formed areas awaiting LID facilities.

Rulemaking To Prevent Releases Of Hazardous Substances To Waters Of US

Saturday, January 14th, 2017

In 2016, the USEPA issued a letter of intent to initiate rulemaking to implement Section 311(j)(1)(C) of the CWA. This Clean Water Act (CWA) provision authorizes USEPA to enact rules to protect the waters of the US from releases of hazardous substances, similar to existing rules regarding oil pollution prevention. The letter was issued in response to a lawsuit alleging the agency’s failure to implement Section 311(j)(1) of the CWA, which was settled through a consent agreement. The consent agreement requires USEPA to issue a hazardous substances spill response rule after collecting additional information.

The USEPA expects to issue an information collection rule (ICR) to support the hazardous substances spill rule development and submit it to the Office of Management and Budget (OMB) for review in early 2017.

EPA Revised Methods For Analysis Of Certain Organics and Microbes

Saturday, January 14th, 2017

EPA has finalized specific changes to analytical test procedures that are used by industries and municipalities to analyze the chemical, physical, and biological components of wastewater and other environmental samples that are required by Clean Water Act regulations and their NPDES permit. The changes include revised EPA methods and revised methods published by voluntary consensus standard bodies, such as ASTM International and the Standard Methods Committee. EPA added certain methods reviewed under the Alternate Test Procedures (ATP) program to Code of Federal Regulations (CFR), Title 40 Part 136 and clarifying the procedures for EPA approval of nationwide and limited use ATPs.

New EPA Methods finalized include 608.3, 611, 624.1 and 625.1

  • EPA Method 608.3, Organochlorine Pesticides and PCBs
  • EPA Method 611, Haloethers.
  • EPA Method 624.1, Purgeables by GC/MS.
  • EPA Method 625.1, Base/Neutrals and Acids by GC/MS.

EPA revised existing Methods 1600, 1603, 1680, and 1682. This rule implements changes for EPA microbiological methods 1600, 1603, 1680, and 1682 that correct typographical or other errors that EPA identified in the methods after publication.

Update On Reissue Of Oklahoma Industrial Multi-Sector General Permit

Saturday, December 17th, 2016

The current Oklahoma Industrial Multi-Sector General Permit (MSGP) OKR05 expired on September 4, 2016. In accordance with Part 8.2 of the OKR05 permit, if the permit is not reissued or replaced prior to the expiration date, it will be administratively continued and remain in force and effect.

A draft Industrial MSGP OKR05 is currently going through the DEQ internal review process. Once the internal review is complete, the draft permit will be sent to EPA for review and approval. DEQ will publish a public notice and make it available for public review and comment after receiving approval from EPA. Once the public notice period is over, DEQ will issue the permit with an effective date. Completing the permitting process will likely occur between November 2016 and January 2017.

All existing permittees under the current Industrial MSGP OKR05 will have 90 days from the effective date of the new permit to update their Stormwater Pollution Prevention Plans (SWP3) and submit new NOIs to DEQ along with required permit fees for permit renewal. Industries/facilities with No Exposure Certifications will follow the same timeline.

New South Carolina Permit – Eight Changes From Prior General Permit

Saturday, December 17th, 2016

The South Carolina Department of Health & Environmental Control has issued as final the Industrial Stormwater General Permit (SCR000000) on September 1, 2016, and became effective on October 1, 2016. Some of the key changes compared to the South Carolina Permit issued in 2010 are:

  1. Saltwater/Freshwater benchmark metal concentrations are set for all facilities covered by the permit as applicable. The 2010 permit had only Freshwater values.
  2. The permit added bacteriological parameter monitoring based on a site’s receiving waterbody classification. This is in the form of a benchmark for domestic wastewater treatment plants, meat packing (animal killing) plants, wool scouring (textile) plants, and rawhide (leather) plants only. The previous permit had only the old (pre-2013 change) Freshwater bacteriological standard for these types of industrial activity covering the entire stateand did not take into account any given site’s receiving water classification.
  3. A numeric effluent limit has been added for Sector S. The limit is for ammonia analyzed as nitrogen and pertains to de-icing compounds used at airports with a 1000 or more annual departures. The New Source Performance Standard (NSPS) that has this limit was promulgated mid-term of the IGP in 2012. The permit incorporated this requirement.
  4. The inclusion of the unauthorized non-stormwater discharges evaluation into the comprehensive inspection requirements. The previous permit gave no frequency for the evaluation; including the evaluation in the comprehensive inspection eliminated that ambiguity.
  5. While the permit continues the exemption from monitoring for discharges that are determined to be natural background or would not contribute the pollutant of concern to an impaired receiving waterbody, it will also extend those exemptions to the TMDL level as well.
  6. The permit also has an additional “out” from monitoring for discharges into a TMDL watershed. If the water quality monitoring station immediately downstream of a site (and upstream if in tidally-influenced waters) is fully supporting the water quality standard for the impaired parameter(s), then the site is exempt from the TMDL monitoring.
  7. The permit continues to require that each permittee check the South Carolina list of approved TMDL during each comprehensive site inspection. The permit now adds a check of the 303(d) list as well. The 303(d) list is reviewed and updated biennially by the Department. Inclusion of a check of the 303(d) list in the comprehensive inspection along with the TMDL check offers a streamlined, complete review of a site’s water quality status.
  8. TSS benchmarks have been added for Sectors F and N. These requirements were removed in the 2010 version of the IGP and are added back due to the MSGP continuing to have them in the Sectors.