Tag Archives: storm water

The Trajectory of Industrial Stormwater Regulations in the US

October 12, 2020

Stormwater Pollution Planning and Preparation SWPPP

Industrial stormwater discharge regulatory compliance defined by the National Pollutant Discharge Elimination System – NPDES, and the Federal Multi-Sector General Permit – MSGP, slated for implementation in January 2021, will affect state Industrial General Permits. In the states where the EPA is the regulating body (New Mexico, New Hampshire, and West Virginia), the impact will be immediate.

California on the Rise, by Jonathan Meronek and Alissa Barrow, discusses the emerging general commonalties of “lessons learned” that can help dischargers successfully manage their stormwater programs.

Jonathan and Alissa explain best practices that help businesses understand and prepare ahead of the expected changes. The strategies can streamline preparation and response to minimize risk and help prevent fines and lawsuits.


 

About the Authors: Jonathan Meronek is a State of California IGP Qualified Industrial Stormwater Practitioner – QISP. With SCS Engineers for over 17 years, he leads Stormwater Management in the Southwest U.S. Alissa Barrow has 10 years of experience as an environmental professional specializing in environmental assessment, remediation, and compliance. Find a stormwater professional near you.

Learn more:

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Ann O’Brien publishes annual environmental reporting tables

February 12, 2020

The environmental reporting season is just around the corner.  Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.

Table: environmental regulatory agencies in Illinois, Indiana, and Wisconsin

The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry.  Contact us at or find a professional like Ann, nearest you.

Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.

Thanks, Ann!

 

 

 

 

Posted by Diane Samuels at 6:01 am
Tag Archives: storm water

A New ERA in Industrial Stormwater Regulation

February 18, 2019

Read Considerations, Strategies and Lessons learned for NPDES Regulated Industrial Dischargers within the Exceedance Response Action Models of Stormwater Regulation

Stormwater Regulation is evolving, pushing more responsibility on to the dischargers by holding them accountable through categorization based on a discharger’s ability to meet numeric benchmarks. Additionally, how a discharger responds and applies effective BMPs determines their status. Ultimately, it is up to the industrial permittee to take the initiative, with an eye to priorities and feasibility for the future of their stormwater compliance program.

Stormwater managers and facility compliance personnel have only just begun to come to terms with the tiered ERA Response paradigm. However, as the tiered escalation becomes more common and ERA Level 1 and Level 2 reporting is performed, facilities are beginning to reach an equilibrium of stormwater compliance in terms of strategy, feasibility, budget and allocation of resources.

Jonathan Meronek of SCS Engineers.

In his whitepaper, Jonathan Meronek, QISP, ToR, takes readers through the fundamental components of the ERA, Exceedance Response Action, or tiered Corrective Action compliance mechanism already in place, and currently being implemented in the States of California, Washington and the most recent General Permit in Oregon. ERA has wide-reaching implications for future NPDES permittees of industrial stormwater discharges. The escalation or “tiered” response standards is based on EPA Benchmark Levels and potential for future Numeric Effluent Limits (NELs). The three western states are viewed as “precursors” of what may be expected throughout the United States, as several key components of the forthcoming Multi-Sector General Permit  (MSGP) will push other states to move towards similar ERA response scenarios and regulations.

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Webinar Deadline: NPDES Industrial Stormwater Compliance Regulations

November 29, 2018

Recommended for Managers and Facility Compliance Personnel Responsible for NPDES Industrial Stormwater Compliance

The new Exceedance Response Action (ERA) paradigm has wide-reaching implications for future NPDES permittees of industrial stormwater discharges. This growing regulatory compliance mechanism is already being implemented in California, Washington, and most recently in Oregon. These states are viewed as precursors of future trends throughout the United States, as several key components of the forthcoming Multi-Sector General Permit (MSGP) will influence other states to move toward similar ERA response scenarios and regulations.

Join Forester University for this live, educational, two-part webinar as speaker Jonathan Meronek, QISP ToR, CPESC, QSDP/D, of SCS Engineers discusses the future of the tiered ERA paradigm and why stormwater managers and facility compliance personnel have only begun to come to terms with it. He will help you better understand if your site is covered and how an Industrial Permittee can come into compliance.

The webinar will examine past lessons, including the implementation of effective best management practices, water quality characterizations, and successful compliance strategies. It will also project what the compliance paradigm will look like during the first years of an industrial General NPDES Permit.

Attendees can expect to learn to:

  • Identify your enemy: Keys to effective industrial facility site pollutant source assessments and water quality characterization
  • Observe the successful components of a stormwater management program, including a strong foundational Stormwater Pollution Prevention Plan (SWPPP)
  • Learn how to select and implement effective BMPs using a tiered approach to compliance, especially under a compliance level escalation scenario
  • Analyze the ever-increasing effects of Non-Governmental Organizations (NGOs) on industrial discharges and permittees
  • Discover emerging alternative regulatory compliance options under Industrial Permits and what they might mean for the future
  • Understand Total Maximum Daily Loads (TMDLs) and potential applications of additional Numeric Effluent Limits (NELs)

Attendees can expect to earn credits: 2 PDH / 0.2 CEU

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Storm Water Regulatory Changes and Industry Trends

November 28, 2018

We will continue to see changes on the federal, state and local regulatory front that together will help us manage storm water in a smart, cost-effective manner preserving our water resources. Betsy Powers of SCS Engineers provides an update in her most recent article.

Until a new WOTUS definition is finalized, the U.S. EPA and the U.S. Department of the Army have indicated their intent to re-codify the pre-Obama regulations. The revised WOTUS rule is expected to include looser regulatory requirements, meaning fewer waters will qualify, and therefore, fewer permits will be required.

To speed up approvals of permits for highways, bridges, pipelines and other major infrastructure, an Obama-era executive order aimed at reducing exposure to flooding, sea level rise and other consequences of climate change were rolled back reducing the environmental reviews and restrictions on government-funded building projects in flood-prone areas.

Removing phosphorus from storm water runoff is a hot topic, with partners exploring alternative opportunities to reduce the introduction of phosphorus in runoff, remove it or manage it in watersheds.

More proprietary filters are being used for pretreatment before underground infiltration for redevelopment sites for total suspended solids (TSS) control and where land is limited. The performance of proprietary devices continues to be studied and improved to meet regulatory requirements. Increasing general attention is being paid to emerging contaminants that are problematic in storm water runoff. Among the emerging contaminants of concern are pharmaceutical and personal care products, pesticides, hydrocarbons, and hormones. Many of which are now included within the Endocrine Disrupting Chemicals group.

Read the article here.

Betsy Powers, PE, SCS Engineers

Betsy Powers is a civil and environmental engineer with SCS Engineers.

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Get ahead of the environmental reporting curve.

November 28, 2017

Ann O’Brien of SCS Engineers has pulled together a list of questions that printers should be asking themselves before the environmental reporting season is upon us.

Use Ann’s questions as a guide to find out how ready your company is, and decrease your risk of non-compliance by being more organized.

If you don’t know the answers, ask Ann. She’s one of our air and water permitting, monitoring, and reporting experts at SCS. Ann specializes in printing industry compliance.

Read the full article.

Contact and we’ll direct you to an air, storm water, wastewater, or groundwater expert near you and in your industry.

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Brownfields and Remediation: Restoring Properties with a Past

November 20, 2017

It is challenging to restore properties with a past, but you can do it on time and on budget if you plan ahead to address contaminated historic fill. Follow these tips and use the brownfield redevelopment checklist to keep your next redevelopment on track.

Design Phase
Consider how contaminated historic fill impacts the following:

Site feature locations – You can reduce or even eliminate landfill disposal costs by carefully selecting locations for your building, underground parking, parking lot, utility, and green space.

Storm water infiltration – Do you know that storm water infiltration devices must be located in areas free of contaminated historic fill? Infiltration devices cannot be located where contaminants of concern (as defined in s. NR 720.03(2)) are present in the soil through which the infiltration will occur.

Subslab vapor mitigation system – Already know you have contaminated historic fill on site? Consider adding a subslab vapor mitigation system to the design of your new building. It is usually much cheaper to install this system in a new building than to retrofit one into an existing building. It can also mitigate radon gas.

Planning & Design
Determine if contamination requires the following plans to manage the construction phase:

Material management plan – It establishes how you will separate excavated contaminated material from material that is not contaminated. It also outlines how you will handle contaminated material, either by disposing of it off site in a landfill or reusing it on site in an approved area such as a paved parking lot. This plan also covers screening, sampling, and testing contaminated materials, if required.

Dewatering plan – If the development requires excavation through contaminated historic fill to depths below groundwater, you will need a dewatering plan to properly manage discharge of the water. You may be able to discharge the water to the storm sewer or the sanitary sewer depending on the type and concentration of contaminants. You must determine local and state permit requirements before implementing your dewatering plan.

Demolition plan – The demolition plan for removing existing structures during redevelopment should include handling, removal, and disposal of potential contaminants such as lead and asbestos. The demolition plan should also address recycling and reuse of existing on site materials like concrete. You may be able to save money by crushing and reusing concrete on site as fill material, or by hauling and crushing it off site to reuse it as fill at another property. This approach can save you considerable money compared to landfill disposal.

 

Ready to start saving time and money addressing contaminated historic fill at your next redevelopment? Contact Ray Tierney  for help evaluating your options in the Upper Midwest, or using the SCS Brownfield Redevelopment Checklist .

Live in another part of the country? SCS Engineers offers brownfields, remediation, due diligence, and all appropriate inquires services nationwide. Contact us today at .

Learn more about these services at SCS Engineers; read our case studies and articles:

Brownfields and Remediation
Due Diligence and All Appropriate Inquiries

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Stormwater Compliance for Craft Brewers

November 8, 2017

How to stay in compliance, do what is right and avoid costly fines and litigation.

The State of California passed regulations in 2015 that impact all craft brewers (SIC Code 2082) who must comply with these regulations by either preparing and implementing a plan or certifying “no exposure” for their facility. While enforcement has so far been limited, the State maintains a searchable database by SIC code, and compliance determinations by government officials, environmental groups and other non-government organizations is comparatively easy.

Based on our research, the current compliance rate for craft brewers in California is relatively low. Those who don’t comply run the risk of fines or citizen suits by non-profits, which can be costly and time-consuming. Find out about the different types of compliance, what is involved, and how to stay in compliance.

A Qualified Industrial Storm Water Practitioner (QISP) can help you answer the following questions:

  • Do I need to comply with these requirements?
  • What if I am brewpub/restaurant, do I still need to comply?
  • What steps do I need to take to be in compliance?
  • Can I do the compliance work myself or should I get help?
  • What are the tips or strategies to attempt to stay out of the more stringent aspects of compliance?
  • What is my exposure and what are the fines and penalties for not complying?
  • What strategies can I use to avoid citizen suits and what do I do if I am targeted by a citizen’s suit?

For more information or help with stormwater compliance in California, contact Dan Johnson at or the California Craft Brewers Association. If you are a CCBA member, you may access slides from a recent Webinar relating to Stormwater Compliance for Craft Brewers here. To sign up for our e-newsletter on stormwater and compliance tips send an email to .

Contact for stormwater compliance services in all 50 states.

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

Safe, Compliant Alternative for SPCC Secondary Containment

September 28, 2017

If your company stores oil-based inks and manages them as part of your facility’s Spill Prevention, Control and Countermeasures (SPCC) Plan, it may be feasible to use an impracticability determination as an alternative approach to comply.

Read the article by Chris Jimieson of SCS Engineers.

The high viscosity of oil-based inks can provide an opportunity for an alternative means of complying with the secondary containment requirements of the SPCC Rule. An impracticability determination can be an appropriate option for oil-based ink you store in single walled containers at  print or similar facilities.

 

SPCC Services – SCS Engineers

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: storm water

What you need to know if you received a notice from the Water Board that your facility is ERA Level 1 or Level 2 Status

September 13, 2017

ERA Level 1 Status

Your facility will need a Qualified Industrial Stormwater Practioner (QISP) to perform an ERA Level 1 Assessment, on or before October 1, 2017, and follow up with an ERA Level 1 Technical Report by January 1, 2018, or as soon as is practicable.  We recommend that this assessment and report be performed prior to the wet season of the 2017-18 permit cycle year, to assist dischargers in reviewing their minimum required BMPs and if needed, implement additional BMPs.

ERA Level 2 Status

Review your ERA Level 1 Action Plan now. Is it correct given the additional NAL exceedances?  You should review all items needed for a successful ERA Level 2 Action Plan and Technical Report to successfully reduce and/or eliminate pollutants of concern in stormwater discharge.

 

Requirements, Actions, Deadlines

Your facility is required to submit an ERA Level 2 Action Plan, prepared by a QISP, which addresses each Level 2 NAL exceedance via SMARTs. This Action Plan must identify which of the three options below (or a combination thereof) of demonstration(s) the Discharger has selected to perform:

  • Industrial Best Management Practice (BMP) Demonstration – Description/evaluation of relevant potential pollutant sources whereby additional Facility BMPs are implemented to comply with all applicable effluent limitations (BAT/BCT, ELGs and/or TMDLs) and to prevent future NAL exceedances (If this is not feasible to implement, you must provide estimated cost and rationale);

 

  • Non-industrial Pollutant Source Demonstration (run-on from adjacent facilities, aerial deposition). This option allows for a Discharger to demonstrate that the pollutants causing the NAL exceedances are not related to industrial activities conducted at the facility, and additional BMPs at the facility will not contribute to the reduction of pollutant concentrations.  The determination that the sources are not from industrial activity or natural background must be done by a QISP; and

 

  • Natural Background Pollutant Source Demonstration (e., iron in soils). This option takes its cue from the 2008 Multi-Sector General Permit (MSGP) whereby and if a Discharger can determine that the exceedance of a benchmark (NAL) is attributable to the presence of that pollutant in the natural background. A Site Plan(s) is very important in this regard which should include, but not limited be to facility locations, available land cover information, reference site and test site elevation, available geology, and soil information for reference and test sites, photographs showing site vegetation, site reconnaissance survey data, and records.

 

The State Water Board acknowledges that there may be cases where a combination of the demonstrations may be appropriate; therefore a Discharger may combine any of the three demonstration options in their Level 2 ERA Technical Report, when appropriate.

It is important to note that Level 2 is a serious situation under the IGP and you should start working immediately on your stormwater management goals for the ERA Level 2 Action Plan, which is due by January 1, 2018. For the BMP demonstration option, Dischargers may have to implement additional BMPs, which may include physical, structural, or mechanical devices that will reduce and/or eliminate pollutants in stormwater discharge.

The ERA Level 2 Technical Report, which summarizes the option(s) chosen and all relevant technical information, including design storm standards for treatment control BMPs, must be overseen and signed by a California Professional Engineer (PE) and submitted by January 1st, 2019.

 

Four important considerations in light of the ERA Level 2 exceedances:

    • Your facility Pollution Prevention Team (PPT) and/or consultant hopefully reviewed all the relevant 2016-17 storm water sampling analytical results during the annual report process. It is worth taking another look and reviewing each and every lab report, and look for j-flags, and potential issues during sampling to make sure it is truly an NAL exceedance. If this is an issue, training should also be done fairly soon to ensure proper sampling techniques during the 2017-18 stormwater season.

 

    • Budgetary: Capital expenditures can take time to get approved. The earlier the compliance-based BMP items are submitted for budgetary approval, the better. This will give the Discharger more flexibility and options for a tiered approach for implementation.

 

    • Non-government Organizations (NGOs) and Environmental Groups (EGs) are a “de facto” regulatory mechanism, and there has been a proliferation of citizen suits under the Clean Water Act recently. ERA Level 2 Dischargers could be on a short list for non-compliance and have greater exposure.

 

  • Remember, if you return to Baseline status under the IGP and breach the former ERA Level 2 NALs with a yearly average or instantaneous maximum exceedance(s), your facility returns directly to ERA Level 2. Make sure your BMPs are implemented for the long-term to prevent returning to Level 2 status.

 

 

Get help now by contacting an SCS Stormwater Professional near you.

 

 

 

 

Posted by Diane Samuels at 6:03 am