OEPA Issues New Industrial Storm Water Permit For Marinas

The Ohio Environmental Protection Agency (OEPA) has issued an industrial stormwater discharge permit specifically to cover marinas which would otherwise need to apply for coverage under the Ohio multisector general permit (MSGP). Marinas nationwide are subject to industrial stormwater under the Transportation Sector. OEPA under General Permit No. OHRM00002 became effective on January 22, 2013. Marinas that wish to be covered under this permit are required to submit an application (“Notice of Intent, or NOI”) to OEPA.

Compliance requirements under the Marina general permit are similar in many ways to the Ohio MSGP, including:

• Requirement to prepare and implement a stormwater pollution prevention plan (SWPPP) meeting the requirements listed in the permit
• Requirement to eliminate non-stormwater discharges
• Requirement to conduct regular facility inspections
• Requirement to develop and implement an employee training program
• Requirement to conduct regular visual monitoring of stormwater discharges.

Read a summary of the Ohio Multisector General Permit

There are some important differences also:

• Marinas are allowed to discharge wash water from boat cleaning, although cleaning of engines or other oily parts is prohibited; use of detergents or other chemical cleaning agents is prohibited.
• Larger marinas (greater than 200 total slips) must conduct chemical monitoring of stormwater discharges on an annual basis.

Read a summary of Ohio general permit monitoring requirements for marinas

Read about Caltha’s new SWPPP Template and Compliance Plan Template for the Ohio marina general permit


Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Salt Storage Guidelines and Permit Requirements Issued By Ohio EPA

Ohio EPA has released a guidance document on the elements of salt storage that are relevant to preventing contamination include siting, design, and operation. The document provides guidance on salt storage practices to prevent the contamination of ground water and surface water. “Salt”, as used here, includes solids such as the popular sodium chloride (NaCl), as well as potassium chloride (KCl), calcium chloride (CaCl2), and magnesium chloride (MgCl2). It also includes mixtures of the same substances with abrasives such as sand, cinder, slag, etc.

Recently, several salt storage operations have been identified by Ohio EPA as the source of high chlorides in public or private ground water supplies. While Ohio has no rules specifically governing the storage of salt, ORC 6111 prohibits unauthorized discharge of pollutants to waters of the state, including runoff from salt storage. Ohio EPA considers brine created from rainfall passing through salt piles to be an industrial wastewater that is subject to permitting requirements. For a new salt storage site, Ohio EPA’s Division of Surface Water (DSW) can require a permit-to-install (PTI) to ensure adequate protection of water quality resources. When complaint investigations or routine audits for existing facilities indicate impacts to water resources due to poor management practices, DSW can take action to address any problems identified. Storm water permitting requirements pursuant to 40 CFR 122.26 and OAC 3745-39 must be met, as well as any local zoning requirements. For salt piles in designated urban areas, best management practices can be required under a Municipal Separate Storm Sewer System Permit (MS4), although there are no specific siting or design criteria. For salt stored at an industrial site, the Industrial Multi-Sector General Storm Water Permit would apply and would require the salt to be properly covered/enclosed. Ohio EPA-DSW can require a National Pollutant Discharge Elimination System (NPDES) permit for any site, regardless of location, if it is aware of pollution. Additionally, characterization and abatement of a release from a salt facility can be required under ORC 6111.04.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Lake Erie Great Lakes Restoration Initiative Grants Awarded To Ohio

The U.S. Environmental Protection Agency has awarded Great Lakes Restoration Initiative grants for projects in Ohio to improve water quality and reduce excess nutrients that contribute to harmful algal blooms in Lake Erie and to to reduce nutrients in the Lake Erie basin. The Lake Erie projects awarded are:

• $780,745 to the Ohio Environmental Protection Agency for a Lucas County Stormwater Demonstration Project: This project expands ongoing efforts to improve urban stormwater management throughout the Ohio portion of the Lake Erie watershed. This project will demonstrate the use of green infrastructure (bioswales, pervious pavement, community rain gardens and bio-retention cells) at nine highly visible locations and assess the effectiveness of these measures to reduce nutrient and sediment loads in the Maumee River watershed.
• $414,765 to the Nature Conservancy for Nutrient Reduction in the South Findlay Area of the Upper Blanchard Watershed: The project will reduce nutrient loading to the Upper Blanchard River Watershed, south of Findlay, Ohio, through the use of two-stage ditches, buffer strips and cropping systems which will filter nutrients and trap sediment. This project is expected to prevent 1,644 tons of sediment, 5,647 pounds of nitrogen and 3,406 pounds of phosphorus from reaching Lake Erie during the first three years after the erosion control measures are implemented.
• $472,491 to the University of Toledo for Reduction in Nutrient, Sediment and Bacterial Loading in Maumee Bay State Park: The project will make Maumee State Park Beach safer by reducing bacteria, sediment and nutrient loading from Wolf Creek. A bed-load sediment collector and a sedimentation pond will be installed adjacent to Wolf Creek. A wetland will also be constructed to restore riparian habitat.
• $527,152 to the Ohio Environmental Protection Agency for a Powell Creek Nutrient Reduction Project: This project will implement nutrient reduction practices recommended in the approved Total Maximum Daily Load for Powell Creek within the Maumee River basin and demonstrate the environmental benefits of targeting nutrient reduction actions in small geographical areas. These practices include replacing failing septic systems, planting 3,600 acres of cover crops, managing controlled drainage on 320 acres, and restoring or installing 20 acres of wetlands. This project is expected to prevent 9,077 pounds of nitrogen, 2,586 pounds of phosphorous and 908 tons of sediment from reaching Lake Erie each year.
• $193,923 to The Ohio State University to Increase Nutrient Management Plan Expertise in the Blanchard Watershed: The project will increase the technical skills of agricultural professionals working in the Blanchard River watershed in Ohio, particularly pertaining to the development of Nutrient Management Plans (NMPs) for farms. NMP implementation will be focused on fields with the greatest potential to address dissolved reactive phosphorus loading in the Blanchard Watershed.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Proposed Changes To Training For Water and Wastewater Treatment Plant Operators

The Ohio EPA has proposed rules that will eventually allow a third party provider to sponsor and administer certifications exams for Water and Wastewater treatment plant operators. By using the third party, Ohio EPA hopes to provide examinations more often, in more locations throughout the state, using computer based testing. The Agency also believes that by using the third party, the pool of questions will expand and the third party will be responsible for verifying the validity of those test questions.

The cost of the third party administration may be passed on to applicants in the form of higher fees. In the interim, State-Sponsored exams will continue to be held twice per year in order to give operators the choice of the computerized approved exam-provider or the additional state examination. The Ohio EPA hopes to eventually eliminate the state sponsored exam and rely solely on the examinations provided by the approved exam provider.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Amendments To Ohio Water Quality Trading Rules

The Ohio Environmental Protection Agency (OEPA) has proposed changes to the rules that govern trading programs for wastewater discharge permits issued by the State. Ohio Administrative Code (OAC) 3745-5 provides the administrative requirements for the development and implementation of water quality trading programs in Ohio. A majority of the revisions consist of minor updates to references and grammatical edits. In addition, the following specific changes are being considered:

Rule 03 – Revising rule to state that use of a water quality credit shall not cause or contribute to a violation of water quality standards. Adding provision that nonpoint source load reductions funded through Ohio EPA’s Water Resource Restoration Sponsor Program are not eligible to generate water quality credits
Rule 04 – Adding date by which two existing trading programs must submit water quality trading management plans
Rule 06 – Changing the size of the hydrologic unit codes that must be used when identifying areas where nonpoint source projects might be located
Rule 11 – Identifying additional compliance-related provisions that will be included in NPDES permits when the permittee is participating in a water quality trading program.
Rule 14 – Revising language to include biological and stream habitat parameters in ambient water quality monitoring plans

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Summary of Revised Industrial Stormwater Permit Requirements In Ohio

Ohio EPA has completed public comment on its proposed draft industrial multi-sector permit, and plans to issue the NPDES industrial general permit renewal in May with an effective date of June 1, 2011.

Currently, Ohio EPA plans to mail renewal notices to all permittees of the current industrial general permit (OHR000004) in mid-June. The renewal notice will include a blank NOI application form to submit to Ohio EPA within 90 days to continue general permit coverage until May 31, 2016.

The 90-day period is intended to allow permitted facilities with sufficient time to:

1. Select, design, install, and implement control measures to meet numeric and non-numeric effluent limits in the new permit;and
2. Develop a new SWPPP according to the requirements in the new permit.

[click here to review a Regulatory Briefing on the new SWPPP and permit compliance requirements]

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

OEPA Draft Industrial Permit - Storm Water Benchmark Sampling

The proposed stormwater monitoring requirements in the proposed General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP) include both effluent monitoring requirements for some facilities and benchmark monitoring requirements for most permitted facilities in Ohio. Consistent with the US EPA MSGP, the OEPA draft permit contains numeric effluent limitations based on Effluent Limitations Guidelines for Sectors A, C, D, E, J and O. [more information on difference between effluent limitations and benchmark concentrations]

The Ohio MSGP requires benchmark monitoring, specific for each industrial sector, for pollutant parameters which US EPA has determined to be of concern by industrial sector. The draft Ohio general permit requires that 19 of the 29 industrial sectors perform benchmark analytical monitoring. The benchmark monitoring requirements are not effluent limitations. Benchmark values represent a level to determine whether a facility’s SWP3 is effective.

The benchmark monitoring is based on a collection of 4 quarterly samples. If the average of the 4 monitoring values for any parameter does not exceed the benchmark value, the permittee has fulfilled their monitoring requirements for that parameter for the permit term. If this average exceeds the benchmark for a parameter, then the permittee will need to review their SWP3 and control measures and modify accordingly. Additional monitoring would be required. The US EPA MSGP’s primary source of benchmark concentrations is derived from EPA’s National Water Quality Criteria. For a majority of the benchmarks, USEPA used the acute aquatic life, fresh water ambient water quality criteria. USEPA believes these acute freshwater values best represent the highest concentrations at which typical fresh water species can survive exposures of pollutants for short durations, such as a storm discharge event.
[read recent comparison of benchmark concentrations to typical industrial sector monitoring data]

Ohio EPA evaluated each benchmark monitoring parameter and followed US EPA’s methodology, but used Ohio Water Quality Criteria when available. As such, some US EPA benchmark values have been changed to be consistent with Ohio Water Quality Criteria. The benchmark values of some metals are dependent on water hardness. For these parameters, permittees will need to determine the hardness of the receiving water to determine the benchmark concentration that applies to their facility. Depending on the condition of the receiving water, benchmark values for heavy metals can vary widely between facilities.

Caltha LLP provides expert consulting services to public and private sector clients in Ohio & nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWP3), Stormwater Monitoring (including determination of the effects of receiving water hardness on benchmark concentrations), and Stormwater Training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Benchmarks For Metals In Ohio Industrial MSGP

The Ohio Environmental Protection Agency (OEPA) has released its draft Multi-sector General Permit (MSGP) which, once finalized, will replace the existing industrial stormwater discharge general permit, which will expire on May 31, 2011. The draft MSGP is modeled after the US EPA MSGP, released in 2008, and is significantly different compared to the existing Ohio permit.

One of the key changes is the requirement for most permitted facilities to conduct benchmark monitoring of their industrial storm water discharge. Results are compared to a list of sector-specific benchmark concentrations to determine if improvements to the stormwater pollution prevention program are needed, and whether or not further benchmark monitoring is needed.

The benchmark concentrations for each sector are listed in the permit, with several important exceptions. These are benchmarks for seven metals:

• Beryllium




• Cadmium




• Copper




• Lead




• Nickel




• Silver




• Zinc
  

The benchmarks for these chemicals must be calculated for each individual facility based on the hardness of the receiving water, which each facility must determine. This will require individual facilities or groups of facilities to collect additional samples and do additional testing prior to starting their benchmark monitoring program.

The necessity to determine site-specific stormwater benchmarks only affects certain Ohio discharges, includes some or all facilities in fall into ten of the industrial sectors:

Sector A – Timber Products
Sector C – Chemical and Allied Products Manufacturing, and Refining
Sector F – Primary Metals
Sector G – Metal Mining
Sector K – Hazardous Waste Treatment, Storage, or Disposal Facilities
Sector M – Automobile Salvage Yards
Sector N – Scrap Recycling and Waste Recycling Facilities
Sector Q – Water Transportation Facilities
Sector Y – Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
Sector AA – Fabricated Metal Products

Caltha LLP provides expert consulting services to public and private sector clients in Ohio and nationwide to address stormwater permitting & regulatory support, including determination of stormwater benchmarks for water hardness dependant metals, development of Stormwater Pollution Prevention Plans (SWPPP) using a SWPPP template prepared to meet the new permit requirements, stormwater monitoring and stormwater training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Storm Water Plan Template and Compliance Plan To Meet New OEPA General Permit

The Ohio Environmental Protection Agency (OEPA) has proposed a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP. This permit will replace the existing Ohio general permit, which expires on May 31, 2011. The draft Ohio general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For most facilities subject to the existing general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP.


To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on Ohio permit requirements, including Ohio specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Ohio Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the OEPA general permit.


For further information on Caltha's Ohio SWPPP Templates, email: info@calthacompany.com


Caltha LLP provides expert consulting services to public and private sector clients in Ohio and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.




For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Cleveland Airport Targeted for Discharge Regulation

U.S. Environmental Protection Agency has proposed regulations requiring airports to collect at least some of the deicing fluid after it is used on aircrafts with a goal of cutting chemical discharge by 22%. The regulations would require six of the 14 major U.S. airports that are the biggest users of deicing fluid to install deicing pads or other collection systems to capture 60% of fluid sprayed and to install deicing pads or other collection systems. Some of the targeted airports include:

• New York's John F. Kennedy and LaGuardia airports,
• Chicago's O'Hare,
• Boston Logan International,
• Cleveland-Hopkins International, and
• New Jersey's Newark Liberty International

It would then be the airports' responsibility to ensure that the collected fluid was treated and handled in accordance with requirements. Some 200 smaller facilities around the US would have to collect 20 percent of the fluid by using technologies such as a glycol recovery vehicle, while airports with fewer than 1,000 yearly jet departures would not be impacted.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Ohio Environmental Consultant - EHS Consulting Services -

Caltha LLP provides expert technical consulting services to private and public sector clients across Ohio. For further information, click on links below:

Ohio (OEPA) Water Quality - NPDES Permitting Services
Ohio (OEPA) Stormwater Permit Compliance – Storm Water Permitting Services
Ohio SPCC – Spill Plan Services
Ohio Product Stewardship - Product Compliance Services
Ohio Haz Com – Hazard Communication Compliance Services
Ohio EHS Staffing - Contract Employee Services
Ohio Wastewater Compliance - NPDES Permitting Services

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

GLI Water Quality Standards - Use of Secondary Values

The Water Quality Guidance for the Great Lakes System, also known as the Great Lake Initiative (40 CFR 132), promulgated ambient water quality criteria that applied to waters in the Great lakes basin. The methodologies used to calculate these water quality standards were essentially the same as those used by US EPA since 1994 to calculate National Water Quality Criterion, with the addition of several new types of standards, such as wildlife-based criteria.

[Read more about GLI Wildlife-based Water Quality Criteria]

A minimum data set is required to calculate water quality criteria for both National and GLI (“Tier I”) standards. However, the GLI did provide for methodology States could use to calculate standards for other chemicals which may not have enough data to fulfill these minimum requirements. The resulting standards are referred to as “Tier II” values, or “secondary” values.

Under the GLI, if all minimum data requirements for calculating Tier I are not met, a “safety factor” or “adjustment factor” is applied to the existing data to calculate a water quality standard. All the same requirements for test data acceptability apply equally to Tier I and Tier II standards.

Because the Tier II values use conservative adjustment factors and assumptions, and rely on a limited data set, standards derived using Tier II methodologies will typically result in much lower concentrations compared to Tier I standards.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address water quality standards, wastewater permitting and assessing potential impacts of chemicals in the aquatic environment.

[Read more about water quality standards, aquatic toxicology, and site specific water quality standards]

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website