Posts Tagged ‘Monitoring’

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

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
Chemical Processing Facility

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

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.

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.

Where Does Zinc In Stormwater Come From? Reducing Zinc To Meet Benchmarks

Wednesday, August 24th, 2016

Many facilities required to monitor metal concentrations under their industrial stormwater permit have found high levels of zinc in their stormwater discharges. Work conducted by the State of Washington found the major sources of zinc were galvanized materials, particularly on roof surfaces, as well as motor oil and hydraulic fluid accumulated on parking areas, loading docks, and paved grounds. Tire dust in areas with high volumes of trucks and forklifts may also be an important source. Zinc concentrations in runoff from roofs with galvanized ductwork were about 10-fold greater than found from the roofs without galvanized materials.

Both motor oil and hydraulic fluid contain high concentrations of zinc, about 0.1% by weight. As an example, as little as ½ cup of motor oil spilled on a small paved parking lot could result in 250 µg/L of zinc in runoff during a small rain event.

Wisconsin DNR Revised Tier 2 Permit Compliance Support And Facility SWPPP

Tuesday, August 23rd, 2016

Caltha LLP Project Summary

Project: SWPPP and Permit Compliance Documentation To Meet Tier 2 Permit
Concrete manufacturer
Location(s): Wisconsin

Key Elements: Facility SWPPP, stormwater inspection, visual stormwater monitoring

Overview: Caltha LLP was retained by this regional concrete manufacturer to conduct compliance reviews and prepare updated SWPPPs for two of its facilities located in Wisconsin. Both sites were covered under the WDNR Tier 2 General Permit for discharge of industrial stormwater.

Caltha staff conducted a site visit and met with plant personnel to determine what updates were required to the existing facility SWPPP to meet the newly revised WDNR permit. A revised SWPPP was issued to each location which included updates to quarterly monitoring procedures, spill prevention measures, routine employee training and monthly housekeeping inspections.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Revised Texas Stormwater Permit Summary – Industrial Stormwater Discharge Rule

Monday, February 29th, 2016

The Texas Commission on Environmental Quality (TCEQ) has proposed to revise the current TPDES Multi Sector General Permit (MSGP) TXR050000, issued August 14, 2011 and expires on August 14, 2016. This permit authorizes the discharge of stormwater associated with industrial activity. The revised draft MSGP specifies which facilities must obtain permit coverage, which are eligible for exclusion from permit requirements, which may be automatically authorized, and which may be required to obtain individual permit coverage.

The principal changes to the existing MSGP include:

A. Changed the Standard Industrial Classification (SIC) code and sector format in Part II Section A to clarify what facilities are regulated under the general permit by adding more details to the existing SIC codes and industrial activity descriptions.

B. Added narrative and numeric effluent limitations guidelines under Part V, Sector S (Air Transportation) to include deicing requirements based on final federal Effluent Limitation Guidelines at 40 Code of Federal Regulations (CFR) Part 449 for airport and airplane deicing operations.

C. Changes to benchmark values and sampling:

  •  Lowered Ammonia Nitrogen value from 2.5 milligrams per Liter (mg/L) to 1.7 mg/L.
  •  Lowered Total Suspended Solids (TSS) values from 100 mg/L to 50 mg/L for sector A (SIC codes 2426 – 2499), sector C (SIC codes 2873 – 2879), sector F (SIC codes 3321 -3325), and sector H (SIC codes 1221 – 1241).
  • Lowered Biochemical Oxygen Demand (BOD) values from 30 mg/L to 20 mg/L for Sector T (Activity code TW)
  • Added language to Part IV, Section B.1.(a) clarifying the sampling requirements for the waiver option for benchmark sampling during Years 3 and 4. If sampling during Years 1 and 2 demonstrates that the annual average result for all benchmark parameters is below the benchmark level for the regulated sector, then permitees can waiver out of sampling for Years 3 and 4.

D. Added SIC code 7699 (Ship scaling services not done at a ship yard; Motorboat repair and maintenance services) to Sector R (Ship and Boat Building or Repairing Yards) .

E. Clarified permit language in Part V, Sector P (Land Transportation and Warehousing) and Sector I (Oil and Gas Extraction Facilities)

G. Clarified permit language in Part II, Section C.1(a) for above ground storage tanks (ASTs) requirements.

H. Added language to Part III, Section D.1 (c) to clarify how permittees should document zero rainfall totals, or no rain for sampling requirements.

I. Added clarification to the section “Impaired Water Bodies and Total Maximum Daily Load Requirements” to address when discharges are considered discharging to an impaired water body.

Caltha LLP provides technical support to Texas facilities to comply with State general stormwater discharge permit, and other regulatory compliance issues.

Revised Pennsylvania DEP Stormwater Discharge Permit

Monday, February 29th, 2016

The Pennsylvania Department of Environmental Protection’s National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03) expired on December 5, 2015.

The Department published a draft revised permit on October 18, 2015. The PAG-03 General Permit is intended to provide NPDES permit coverage to facilities discharging stormwater associated with industrial activity to waters of the Commonwealth that are not considered High Quality or Exceptional Value. If a facility is not eligible for coverage under the PAG-03 General Permit because it is located in a High Quality or Exceptional Value watershed, it may apply for an individual NPDES permit.

The draft PAG-03 General Permit included some significant changes in comparison to the expired permit: 

  • The revised General Permit is consistent with the EPA National Multisector General Permit (MSGP) for stormwater associated with industrial activity, which was reissued in 2015.  
  • The Department proposed the addition of nine appendices to PAG-03, which had been consolidated in the expired version of the permit. An appendix prescribes the sector-specific monitoring and best management practice requirements for permittees. 
  • DEP proposed new eligibility criteria in the draft PAG-03. The Department may deny coverage under the General Permit for stormwater discharges to impaired waters where the discharges contain or are expected to contain parameters that have the potential to cause or contribute to the impairment, regardless of whether a Total Maximum Daily Load has been developed and approved for those impaired waters.  
  • Benchmark concentrations for certain pollutants were proposed in the draft PAG-03. Two consecutive benchmark exceedances would trigger the need to develop and submit a corrective action plan to the Department and implement corrective measures to ensure no additional benchmark exceedances. Monitoring frequency has been standardized for all permittees to once every 6 months. 
  • All permittees will need to conduct quarterly visual inspections of areas and activities exposed or potentially exposed to precipitation, and submit a summary of inspection findings in an annual report due by May 1 each year.  
  • All permittees would be required to submit an annual report due on May 1 that would also serve as the ongoing notice of intent to continue operating under PAG-03.

Facilities seeking new or reissued No Exposure Certification approvals from the Department would need to complete and submit the PAG-03 Notice of Intent (NOI) which must be renewed every five years. In general, all industrial materials and activities must be stored and conducted indoors or under roof for a facility to qualify for No Exposure Certification. The No Exposure Certification alternative is not available to facilities in High Quality or Exceptional Value watersheds.

As of February 29, 2016, the draft general permit had not been finalized.

Caltha LLP provides technical support to industrial facilities located in Pennsylvania to obtain coverage under the General Permit and to assist in development of compliance programs.

Response Action Plan To Address Soil Contamination During Site Redevelopment

Monday, November 9th, 2015

Caltha LLP Project Summary

Project:Site Investigation, Response Action Under Voluntary Site Cleanup Program
Site Redevelopment Company

Key Elements: Phase 1 Environmental Site Assessment, Phase 2 Limited Site Investigation, Response Action Plan

Overview: Caltha LLP was retained by a site redevelopment company to conduct a Phase I ESA on this previously developed property. The assessment determined that past chemical releases had occurred on the property due to historical industrial activity on the property. A Phase 2 investigation was conducted which confirmed that contamination was present which would need to be addressed during the demolition and redevelopment of the site. Caltha prepared a Response Action Plan to be implemented during site redevelopment, which as approved by the State agency. Caltha then oversaw implementation of the RAP in coordination with the redevelopment contractor.

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

SWPPP For Louisiana Scrap Processing Facility

Monday, January 5th, 2015

Caltha LLP Project Summary

Project: Stormwater Pollution Prevention Plan
Metal Processing – Metal Recycler

Key Elements: SWPPP, Industrial Stormwater BMPs, Benchmark Monitoring

Overview: Caltha LLP was retained by this scrap processing facility to prepare a stormwater pollution prevention plan (SWPPP) to meet the requirements of the Louisiana general industrial permit. The SWPPP incorporated Best Management Practices (BMP) and a stormwater monitoring plan. Caltha prepared the SWPPP using our SWPPP template specifically designed to meet the permit requirement.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.