Archive for the ‘Water’ Category

Stormwater SWPPP Plan For Arizona Industrial Facility

Monday, August 28th, 2017

Caltha LLP Project Summary

Project: Storm Water Pollution Prevention Plan
Client:
Food Processing Facility
Location(s):
Arizona

Key Elements: Industrial storm water discharge, SWPPP, Spill prevention procedures, Stormwater sampling

Overview: Caltha LLP was retained by this Arizona food processing plant covered under the AZPDES general permit for industrial stormwater discharges, Sector U3. Caltha used an existing SWPPP template we had previously prepared to meet the ADEQ permit requirements. Caltha staff conducted a site review to gather site specific information needed to prepare the facility SWPPP. The plan incorporated inspection, training, stormwater monitoring and reporting requirements contained in the general permit.

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

Industrial Wastewater Discharge Compliance Support For Chemical Processing Plant

Monday, August 28th, 2017

Caltha LLP Project Summary

Project: Compliance Review & Waste Water Management Procedure Development
Client:
Chemical Processing Facility
Location(s):
Arizona

Key Elements: Industrial waste water discharge, Waste management procedures, POTW industrial user rule, Wastewater sampling

Overview: Caltha LLP was retained by this Arizona chemical plant to conduct an assessment of wastewater management practices. The review included an evaluation of raw materials and waste products which could be discharged to the sanitary sewer from the process. Caltha staff met with POTW to determine waste acceptance criteria and developed key parameters which would be used to determine if specific waste streams were suitable for discharge to the POTW, or required alternate disposal methods. Caltha then prepared a written procedure for facility operators to use to screen waste streams to determine if discharge to the POTW was allowed. The procedure was provided to the POTW for review and concurrence.

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

Multimedia HSE Compliance Audit of Chicago Area Industrial Facility

Friday, July 21st, 2017

Caltha LLP Project Summary

Project: Compliance Audit
Client:
High Tech Manufacturer
Location(s):
Chicago, Illinois

Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, PPE assessment, hazard communication

Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this manufacturing facility located in Cook County. The scope of the audit included:

  • EPCRA
  • Hazardous and Solid Waste Management
  • Current IEPA Air Permit
  • Cook County Air Emission Ordinance
  • Current wastewater discharge permit
  • TSCA
  • Tanks
  • Hazard communication
  • DOT Hazardous material transportation

The audit was led by a IIA-certified professional auditor.

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

Storm Water Permitting, SWPPP and Training For Residential Development

Tuesday, July 18th, 2017

Caltha LLP Project Summary

Project: Construction Permitting, SWPPP & Training
Client:
National Home Builder
Location(s):
Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 49-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.

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

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
Client:
Food Sector SIC 20 Facility
Location(s):
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
Client:
Food Sector SIC 20 Facility
Location(s):
Minnesota

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.