Posts Tagged ‘Industrial Storm Water’

Stormwater SWPPP Plan For Arizona Industrial Facility

Monday, August 28th, 2017

Caltha LLP Project Summary

Project: Storm Water Pollution Prevention Plan
Food Processing Facility

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

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.

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.

Pennsylvania DEP Reissues Industrial General Permit For Eligible Facilities

Saturday, December 17th, 2016

The Pennsylvania Department of Environmental Protection (DEP) has reissued the State General Permit for industrial facility stormwater discharge. The PAG-03 General Permit was reissued on September 24, 2016 for a new 5-year term. The federal regulations identify specific classes of industrial facilities that must apply for NPDES permit coverage; in addition, DEP may require any other facility not identified in the federal regulations to obtain a permit if DEP finds that the facility or activity is resulting in the discharge of pollutants to waters of the Commonwealth.

If a facility is not eligible for coverage under the PAG-03 General Permit, it may apply for an individual NPDES permit, using DEP’s industrial waste NPDES permit application package. The most common reason that a facility may not be eligible for general permit coverage is if it is located in a High Quality or Exceptional Value watershed, according to designated uses under Chapter 93 or existing uses determined by DEP.

Coverage under the PAG-03 General Permit does not expire; however, facilities with coverage must submit annual reports by May 1st each year to document activities in the previous calendar year and to indicate intent to continue operating under the PAG-03 General Permit.

For those facilities that qualify for PAG-03 General Permit coverage, an alternative to obtaining permit coverage is to request No Exposure Certification if the facility qualifies. The No Exposure Certification alternative is not available to facilities in High Quality or Exceptional Value watersheds, and must be renewed every five years. For facilities not located in a High Quality or Exceptional Value watershed, all industrial materials and activities must be stored and conducted indoors or under roof for a facility to qualify for No Exposure Certification.

Oregon DEQ Combines Industrial Stormwater Discharge Permits Effective July 1, 2017

Saturday, December 17th, 2016

DEQ has begun the process to renew and reissue the NPDES 1200-COLS and NPDES 1200-Z industrial stormwater general permits. The DEQ has maintained different permits covering different geographical areas. The NPDES 1200-COLS permit expired Sept. 30, 2016 and the NPDES 1200-Z expires June 30, 2017. DEQ intends to combine the 1200-COLS and 1200-Z permits into a single industrial stormwater permit. DEQ believes this will reduce the number of general permits requiring renewal, improve the agency’s efficiency in issuing permits, and improve consistency for permit registrants. DEQ intends to reissue the 1200-Z (with basin-specific conditions for the 1200–COLS) on or before June 1, 2017, with an effective date of July 1, 2017.

However, current 1200-COLS permit registrants were required to submit a renewal form by August 1, 2016, and current 1200-Z permit registrants must submit a renewal form by January 3, 2017. For existing registrants that submit a renewal form, coverage under their permit will be administratively extended until they receive coverage under the new permit.

Because the 1200-COLS expired before the combined permit will be available, DEQ issued the 1200-COLSB “bridge permit” for the period between when the 1200-COLS expires and a new combined permit is issued. The reissued 1200-COLSB permit is identical to the expired permit, and became effective on Oct. 1, 2016. This permit will expire on July 1, 2017, when the new combined permit takes effect.