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.
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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.
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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.
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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.

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Chemicals Added To Safe Drinking Water Act Monitoring

U.S. Environmental Protection Agency (EPA) is proposing 30 currently unregulated contaminants for monitoring in water systems. Sampling will take place at all systems serving more than 10,000 people and at a representative sampling of systems serving less than 10,000 people.

Under the Safe Drinking Water Act (SDWA), EPA currently regulates more than 90 contaminants in drinking water. The SDWA requires that EPA identify up to 30 unregulated contaminants for monitoring every five years. This current proposal is the third Unregulated Contaminant Monitoring Regulation and includes requirements to monitor for two viruses and 28 chemical contaminants that could be present in drinking water and do not currently have health-based standards.

EPA is requesting public comment on the proposed list of 30 contaminants until May 2, 2011. EPA anticipates finalizing the list in 2012, with sampling to be conducted from 2013 to 2015.

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

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Certified Water Efficiency Homes WaterSense Certification

EPA has recognized the first WaterSense labeled homes in the country. WaterSense is a partnership program sponsored by EPA that seeks to promote water efficiency. The program helps homebuyers cut water and energy use and reduce utility bills. Four WaterSense labeled new homes have been built by KB Home in Roseville, California, and will save an average of 10,000 gallons of water and at least $100 on utility costs each year.

Each house includes WaterSense labeled plumbing fixtures, an efficient hot water delivery system, water-efficient landscape design, and other water and energy-efficient features. Each WaterSense labeled new home is independently inspected and certified to ensure EPA’s criteria are met for both water efficiency and performance. A WaterSense labeled new home is built to use about 20 percent less water than a typical new home.

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

Great Lakes Initiative Action Plan

U.S. Environmental Protection Agency (EPA) , in collaboration with 15 other federal agencies, have made restoring the Great Lakes a national priority and is proposing a budget of $475 million for a Great Lakes Restoration Initiative (Initiative). The EPA Action Plan, recently released, describes how the Initiative will be executed from 2010 through 2014.

The Plan builds on the Great Lakes Regional Collaboration Strategy (GLRC Strategy). The GLRC Strategy provides a framework for the Action Plan. The Action Plan has five major focus areas:

1. Toxic Substances and Areas of Concern, including pollution prevention and cleanup of the most polluted areas in the Great Lakes
2. Invasive Species, including efforts to institute a “zero tolerance policy” toward new invasions, including the establishment of self-sustaining populations of invasive species, such as Asian Carp
3. Nearshore Health and Nonpoint Source Pollution, including a targeted geographic focus on high priority watersheds and reducing polluted runoff from urban, suburban and, agricultural sources
4. Habitat and Wildlife Protection and Restoration, including bringing wetlands and other habitat back to life, and the first-ever comprehensive assessment of the entire 530,000 acres of Great Lakes coastal wetlands for the purpose of strategically targeting restoration and protection efforts in a science-based manner
5. Accountability, Education, Monitoring, Evaluation, Communication and Partnerships, including the implementation of goal- and results-based accountability measures, learning initiatives, outreach and strategic partnerships

The Action Plan identifies goals, objectives, measurable ecological targets, and specific actions for each of the five focus areas identified above. The Action Plan will be used by federal agencies in the development of the federal budget for Great Lakes restoration in fiscal years 2011 and beyond. As such, it will serve as guidance for collaborative restoration work with participants to advance restoration. EPA believes that the Plan will also help advance the Great Lakes Water Quality Agreement with Canada.

Caltha Water Quality and Water Standards Website

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OH EPA Proposed Water Quality Standards and Antidegradation Rules

The Ohio Environmental Protection Agency (OEPA) is currently in the process of revising State Rules relating to Water Quality Standards and Antidegradation (Non-Degradation) Rules. The draft Rules are being published independently; however, because all the Rules are interrelated, OEPA has extended the public comment period.

The draft Rules applying to Antidegradation were released for comment near the end of 2008. Some of the key revisions being proposed include:

• The definition of “best available demonstrated control technology” (BADCT) is being updated to include new design criteria and effluent limits for nitrogen and phosphorus.


• Definitions for “designated uses”, “existing uses”, and “threatened species” are being removed since these definitions are located in the Water Quality Standards Rule.


• Definitions for “local and regional drainage pattern”, “loss of use”, “preferred alternative”, and “40 C.F.R.” are being added.


• The types of alternatives to be considered under the definitions for “minimal degradation alternative” and “non-degradation alternative” are being clarified.


• The definition of “regulated pollutant” is being revised to clarify that parameters include narrative and numeric water quality criteria and those limited by best professional judgment in a NPDES permit.


• The rule exemption in paragraph for net increases from existing sources is being clarified.
  Applications for Section 401 water quality certifications for wetlands will be exempt from the submital of alternatives analysis and social and economic justification information


• Section 401 water quality certifications impacting Lake Erie or its shoreline will be exempt from the mandatory public hearing


• New language is included regarding what constitutes the loss of a beneficial use.


• The set aside revision process for special high quality waters in is being clarified.


• The tables of special high quality waters are being updated.

The deadline for comments on the draft rule has not been determined yet. A draft rule addressing mitigation requirements or impacts on streams will be made available for review and comment in early 2009. Because the content of that rule relates to part of the antidegradation rule, the comment deadline for both rules will be 60 days after the stream mitigation rule is made available.

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

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

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Great Lakes Inland Waters Beach Water Quality Standards

The Beaches Environmental Assessment and Coastal Health Act (“Beaches Act”) amended the Clean Water Act to address the special water quality concerns associated with the recreational uses of coastal waters. The Beaches Act requires US EPA to conduct studies concerning pathogen indicators in coastal recreation waters (Section 104(v)), and to publish new or revised water quality criteria for pathogens and pathogen indicators (Section 304(a)).

In response to the Beaches Act, US EPA adopted a Critical Path Science Plan (CPSP) for the new/revised criteria. The CPSP describes research and science for establishing the scientific foundation for new/revised criteria and outlines research to be completed by to publish new or revised criteria in 2012. The major CPSP research areas include:

• Epidemiology Studies and Quantitative Microbial Risk Assessment (QMRA)


• Site Characterization


• Indicators/Methods Development and Validation Modeling


• Application of Criteria to Inland Waters

Between now and 2010 EPA will be conducting additional research into indicators, methods, fate & transport studies, and predictive modeling. Between 2010 and 2012, work will begin on developing the new recreational water quality criteria. EPA plans to publish the water quality criteria in 2012.

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

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

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NEIWPCC Petitions EPA To Control Ohio Mercury Emissions

The New England Interstate Water Pollution Control Commission has petitioned that EPA regarding Section 319(g) of the Clean Water Act, which requires controls on air emissions of mercury. EPA is being asked to bring together a management conference with eleven States that contribute much of the mercury emissions that end up in water bodies in the Northeast.

The petition prepared by the New England Interstate Water Pollution Control Commission says that Ohio, Pennsylvania, Virginia, New Jersey, West Virginia, Maryland, Michigan, Indiana, Kentucky, North Carolina and Illinois each contribute significant nonpoint source mercury pollution that prevent them from meeting their goals.

The EPA approved a Northeastern regional mercury TMDL last year that the States beleive can only can be achieved through stricter federal air emission controls on mercury. Under Section 319(g) of the Clean Water Act, States can petition the EPA to bring together "a management conference of all states which contribute significant pollution resulting from nonpoint sources,".


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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

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For further information contact Caltha LLP at
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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]

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