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.
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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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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.
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Brownfields Grants To Investigation and Cleanup Ohio Sites

The U.S. Environmental Protection Agency (EPA) has announced $2.8 million in grants to redevelop contaminated properties, create jobs and protect public health in Ohio. These “brownfield grants” are used to assess and clean up abandoned industrial and commercial properties.
The Ohio brownfield grants were distributed as follows:

• Lockland, Site Assessment, Hazardous Substances, $200,000
• Lorain Port Authority, Site Assessment, $400,000
• Newark, Site Assessment, Hazardous Substances, $200,000
• Northeast Ohio Four County Regional Planning & Development Organization, Site Assessment, $600,000
• Ottawa County, Site Assessment, $400,000
• Toledo, Site Assessment, $800,000
• Vinton Baptist Church, Cleanup, Field of Hope Community Campus, $200,000

The Ohio grants are part of the EPA’s $69.3 million 2012 nationwide brownfields grants to clean up and redevelop contaminated properties, boost local economies, create jobs and protect public health.

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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Use of Diesel Fuel In Fracking Operations

US EPA has released draft underground injection control (UIC) program permitting guidance for Class II wells that use diesel fuels during hydraulic fracturing activities. EPA developed the draft guidance to clarify how companies can comply with a law passed by Congress in 2005, which exempted hydraulic fracturing operations from the requirement to obtain a UIC permit, except in cases where diesel fuel is used as a fracturing fluid.

The draft guidance outlines for EPA permit writers, where EPA is the permitting authority, requirements for diesel fuels used for hydraulic fracturing wells, technical recommendations for permitting those wells, and a description of diesel fuels for EPA underground injection control permitting. The draft guidance describes diesel fuels for these purposes by reference to six chemical abstract services registry numbers. The agency is requesting input on this description.

According to EPA, while this guidance undergoes public notice and comment, decisions about permitting hydraulic fracturing operations that use diesel fuels will be made on a case-by-case basis, considering the facts and circumstances of the specific injection activity and applicable statutes, regulations, and case law, and will not cite this draft guidance as a basis for decision. EPA will take public comment on the draft guidance for 60 days upon publication in the Federal Register to allow for stakeholder input before it is finalized.

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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Proposed GHG Prevention of Significant Deterioration Rule

U.S. Environmental Protection Agency (EPA) is proposing not to change the greenhouse gas (GHG) permitting thresholds for the Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs, and also proposing steps the agency believes would streamline the permitting process for large sources. EPA has proposed not to include additional, smaller sources in the permitting program at this time. EPA will be accepting comments on the proposal for 45 days after it is published in the Federal Register.

The GHG Tailoring Rule would continue to address a group of six greenhouse gases. Under the approach maintained in the current proposal, new facilities with GHG emissions of at least 100,000 tons per year (tpy) carbon dioxide equivalent (CO2e) continue to be required to obtain PSD permits. Existing facilities that emit 100,000 tpy of CO2e and make changes increasing the GHG emissions by at least 75,000 tpy CO2e, must also obtain PSD permits. Facilities that must obtain a PSD permit, to include other regulated pollutants, must also address GHG emission increases of 75,000 tpy or more of CO2e. New and existing sources with GHG emissions above 100,000 tpy CO2e must also obtain operating permits.

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