Posts Tagged ‘Water Quality Standards and Regulations’

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

Storm Water Permitting, SWPPP and Training For Residential Development

Tuesday, July 18th, 2017

Caltha LLP Project Summary

Project: Construction Permitting, SWPPP & Training
National Home Builder

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.

SPCC Plan Five Year Review | SPCC Plan Update For Wisconsin Transportation Terminal

Saturday, February 11th, 2017

Caltha LLP Project Summary

Project: SPCC Plan 5-Year Review, Plan Update & Management Compliance Training
Transportation Terminal
Location: Wisconsin

Key Elements: Regulatory compliance training, SPCC Plan

Overview: Caltha LLP was retained by this multimodal transportation terminal to conduct the five-year review of its Spill Prevention, Control & Countermeasure (SPCC) Plan. Under 40 CFR 112, SPCC Rule regulated facilities are required to conduct and document a review of their SPCC Plan at least every five years, independent of the requirement to keep the facility SPCC Plan updated to reflect changes at the facility. In conjunction with this review, Caltha staff provided ad hoc compliance training to selected facility staff on SPCC Rule requirements. Finally, Caltha prepared an updated facility SPCC Plan to reflect administrative changes at the facility.

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.

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.

What Is The Negotiated Rulemaking Process | Negotiated Rulemaking Committee ?

Wednesday, January 11th, 2017

The Negotiated Rulemaking Act (NRA) of 1996 created the Negotiated Rulemaking Committee. The NRA was “to encourage agencies to use negotiated rulemaking when it enhances the informal rulemaking process.” The purpose of the Negotiated Rulemaking Committee is to conduct discussions in a good faith attempt to reach consensus on proposed regulatory language. Negotiated rulemaking is a process in which a proposed rule is developed by a committee composed of representatives of all those interests that will be significantly affected by the rule. Decisions are made by consensus, which the NRA defines as the unanimous concurrence among interests represented on a Negotiated Rulemaking Committee, unless the Negotiated Rulemaking Committee itself unanimously agrees to use a different definition. To start the process, the Agency identifies all interests potentially affected by the rulemaking under consideration. The Agency then establishes a committee representing these various interests to negotiate a consensus on the terms of a proposed rule.

If a regulatory negotiation advisory committee reaches consensus on the provisions of a proposed rule, the Agency would use such consensus as the basis of a proposed rule