EPA Issues 2015 MSGP for Industrial Stormwater Discharge

 

Photo by Roger Winstead
Photo by Roger Winstead

On June 4, 2015, the United States Environmental Protection Agency (EPA) issued a revised NPDES Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The 2015 MSGP replaces the 2008 MSGP.

While the 2015 MSGP provisions are largely similar to the 2008 MSGP, EPA has made some changes to streamline the permit, enhance environmental protections, and improve clarity. The most significant changes are as follows:

  • Revised threatened and endangered species eligibility procedures.
  • Additional specificity for several of the technology-based effluent limits (i.e., control measures) for clarity.
  • A requirement that facilities discharging to a small number of federal Superfund sites notify their EPA regional office prior to filing their Notice of Intent (NOI).
  • Streamlining of Stormwater Pollution Prevention Plan (SWPPP) documentation (i.e., facilities do not have to expound on their compliance with certain effluent limits).
  • Public accessibility to SWPPP information, either by posting on the internet or by incorporating salient information into the NOI.
  • Electronic submission for the NOI, Notice of Termination, annual report, and monitoring.
  • Reduced requirements for inspections (i.e., facilities no longer have to conduct a separate comprehensive site inspection).
  • Specific deadlines for taking corrective actions.
  • Inclusion of saltwater benchmark values for metals.
  • Inclusion of the Airport Deicing Effluent Limitation Guideline for the air transportation sector.

EPA’s MSGP applies in areas of the country where EPA remains the NPDES permitting authority and has made the permit available for coverage, which includes the following:

  • Four states: Idaho, Massachusetts, New Hampshire and New Mexico;
  • The District of Columbia;
  • All U.S. territories except for the Virgin Islands;
  • Federally operated facilities in Colorado, Delaware, Vermont and Washington;
  • Most Indian Country lands; and
  • Various other designated activities in specific states.

For additional information on the 2015 MSGP, visit EPA’s website here.

For additional questions, or if you need assistance with the 2015 MSGP, please contact us.

Canaan Gets $4.8 Million for Water Upgrades from USDA

Originally published in Caledonian Record, May 29, 2015
By Robin Smith, Staff Writer

USDA Rural DevelopmentCANAAN, VT, May 29, 2015 — The federal government has awarded $2.6 million grant to Canaan to address chronic drinking water problems that especially plagued this northeasternmost Vermont community this winter. The grant is part of a major package, including a $1.9 million loan, given by U.S. Department of Agriculture Rural Development Wednesday to the Canaan Fire District Number One for a major water quality upgrade.

Funds will be used to purchase and install a 150,000-gallon water storage tank and construct a new water filtration and treatment facility, as well as upgrade the existing water distribution system serving the people of Canaan and West Stewartstown, N.H. The upgrades will eliminate the use of springs located in Canada as a source and replace them with an existing groundwater well located within the district. A new storage tank will be constructed along with a new treatment/ filter facility for the removal of manganese and arsenic. Portions of the distribution system will also be replaced as part of the funded project. This winter, residents of Canaan experienced multiple incidents of water discoloration and low water pressure because of current water distribution system and treatment inefficiencies.

“This assistance from USDA Rural Development will help some of the most rural and remote communities of Northern Vermont and Northern New Hampshire ensure their residents have clean, healthy and safe water for decades to come,” said Ted Brady, director of USDA Rural Development for Vermont and New Hampshire. “USDA Rural Development has not only invested in essential water infrastructure with this project, but also in the health of Canaan’s people and our region’s economy. This project will put people to work in the Kingdom.”

Engineering for the improvements will be provided by Tata & Howard Engineering of St. Johnsbury. It is estimated the project will commence construction in May 2015 with completion of summer 2016. Canaan was able to access a portion of the $2.6 million in grant funds due to the Rural Economic Area Partnership (REAP) Zone designation accorded to three counties of the Northeast Kingdom of Vermont – Caledonia, Essex and Orleans counties. The designation provides five regions of the country additional grant resources through USDA Rural Development. Sen. Patrick Leahy spearheaded the effort to designate the Northeast Kingdom as a REAP Zone in 2000, and led in renewing the NEK REAP Zone in the newly enacted 2014 Farm Bill.

“By improving water quality, these investments will tangibly improve the quality of life in these Vermont communities,” said Leahy, Sen. Bernie Sanders and Rep. Peter Welch in a joint statement. “With the passage of the Farm Bill earlier this year, the REAP Zone program will continue to bring millions of investment dollars to the Northeast Kingdom. Partnering federal agencies and their resources with rural communities in ways like this is a catalyst for economic growth and quality of life improvements in the NEK and other rural areas.”

WEP loans and grants may be made to develop, extend or improve water and wastewater systems, including solid waste disposal and storm drainage systems, in rural communities with a population of 10,000 or less.

60 Minutes Water Episode Sparks Some Debate

drought_californiaOn May 31, 2015, 60 Minutes aired an episode on water that discussed the depletion of our nation’s groundwater. 60 Minutes reporter Leslie Stahl met with Jay Famiglietti, a leading groundwater expert and Earth sciences professor at the University of California, Irvine, in an effort to shed some light on the drought affecting California. The report was alarming, noting that we are pumping out our nation’s groundwater faster than it can replenish itself. And while reclaimed water was discussed as a possible solution, with Ms. Stahl dramatically drinking water that had been wastewater just 45 minutes earlier, at least one reporter thinks the 60 Minutes water report fell somewhat flat.

Clark Wolf, a contributor for Forbes Magazine, accused the popular Sunday evening news show of only showing half the story. While 60 Minutes successfully explained the realities of groundwater and aquifers, Wolf notes, the popular news program failed to illustrate the greater implications or, beyond reclaimed water, provide any type of long-term, viable solution. In addition, Wolf notes that California’s agricultural sector needs to look towards more sustainable growing methods.

So who is right? You can find the 60 Minutes video and transcript here and Wolf’s article here in order to form your own opinion. But no matter which news piece is perceived as more accurate, one thing is certain: people are finally talking about water, its scarcity, and how we can protect it for future generations. And we can all agree that that is a good thing.

EPA Announces 2015 MSGP Available Soon, Advises Preparation

Photo by Roger Winstead
Photo by Roger Winstead

On May 27, 2015, the EPA announced that the new Multi-Sector General Permit (MSGP), originally proposed in 2013 and referred to as the 2015 MSGP, will be available soon for operators seeking permit coverage to discharge stormwater associated with industrial activity. Filing to renew coverage under the 2015 MSGP must be done electronically using EPA’s new NPDES eReporting Tool (NeT), and, once covered by the new permit, all monitoring data will be submitted electronically using NetDMR.

To prepare for the new 2015 MSGP, EPA recommends taking the following steps:

  1. Visit EPA’s MSGP webpage (https://water.epa.gov/polwaste/npdes/stormwater/EPA-Multi-Sector-General-Permit-MSGP.cfm) to learn about the status of the 2015 MSGP, your eligibility, NeT and NetDMR training, and to obtain guidance on complying with the new permit.
  2. Determine if your facility qualifies for a conditional “no exposure” permit exclusion.
  3. Review your Notice of Intent (“NOI”) submitted for coverge under the 2008 MSGP for information that will help you file a new NOI for the 2015 MSGP.
  4. Discuss internally who will prepare and certify the documents submitted through the NeT and NetDMR tools for your facility.
  5. Review your existing Stormwater Pollution Prevention Plan (SWPPP) to identify the revisions necessary to make it current and consistent with the 2015 MSGP requirements. Your SWPPP must be prepared and ready to implement prior to filing an NOI for the 2015 MSGP.

If you need assistance with your 2015 MSGP, please contact us at contact@tataandhoward.com or 800-366-5760.

White House Finalizes Clean Water Act Rule

clean water infographic
An infographic created by the EPA aims to clarify the rule

On May 27, 2015, the White House finalized the EPA’s “Waters of the United States” rule amid both praise and protest. According to the EPA, the rule is intended to strengthen the Clean Water Act by clarifying which bodies of water fall under the control of the Clean Water Act of 1972.

Gina McCarthy, Administrator of the U.S. EPA, praised the rule by saying, “The Clean Water Act has protected our health for more than 40 years – and helped our nation clean up hundreds of thousands of miles of polluted waterways…Using the latest science, this rule clears up the confusion, providing greater certainty for the first time in more than a decade about which waters are important to protect.”

And White House Senior Advisor Brian Deese, who announced the rule with EPA and Army Corps officials, had very strong words in favor of the rule: “There is a lot of misinformation about what this rule does and doesn’t do. But what becomes clear…is that the only people with reason to oppose the rule are polluters who knowingly threaten our clean water.”

However, the rule does have some strong opposition. Republicans and developers, along with the agricultural and oil industries, have vehemently opposed the ruling since its initial draft, saying that it is a massive power grab by Washington.

“The administration’s cavalier attitude toward expanding the federal government’s authority into our backyards is absolutely outrageous,” said Sen. David Vitter (R-La.) in a statement. “Not only were small businesses – who will be dramatically impacted by expanding of the definition of ‘waters of the United States’ – inappropriately excluded from the rule-making process, but the federal government shouldn’t be regulating puddles on private property in the first place.”

Although this is a final rule, there is legislation to block it that has passed the House and is waiting in the Senate.

We are growing!

Tata & Howard's Jack O'Connell, P.E., Senior Vice President, who is overseeing construction, speaks with Seaver Construction's Mark Pelland, Superintendent of Construction
Jack O’Connell, P.E., Senior Vice President, who is overseeing construction, speaks with Seaver Construction’s Mark Pelland, Superintendent of Construction, in the new space.

Tata & Howard continues to grow at a pace where we have now outgrown our offices! Therefore, we have begun construction on an additional 4,645 square feet of space in our Marlborough, MA corporate headquarters. The additional square footage will add workspace for 18 employees as well as an additional conference room, modeling room, and printing/plotting room. ACTWO Architects from Wayland, MA designed the space, and Seaver Construction from Woburn, MA is handling the construction. Construction is expected to be completed in June.

U.S. Government Recommends Lower Level of Fluoride in Drinking Water

The United States government has recommended a lower level of fluoride in drinking water for the first time in 50 years.

The Department of Health and Human Services (DHHS) has suggested that public water supplies contain between 0.7 and 1.2 milligrams of fluoride per liter since 1962. However, on Monday, DHHS made an announcement that they now recommend that fluoride not exceed 0.7 milligrams per liter. The new recommendation has been in the works since 2011.

fluorosis
Degrees of fluorosis

Two-thirds of American water utilities add fluoride to drinking water in an effort to reduce cavities. However, because fluoride is now found in so many other sources, including toothpastes and fluoride rinses, many people are receiving too much fluoride, which can result in fluorosis. Fluorosis causes tooth staining, from mild cases which produce white spots, to severe cases which produce brown spots and mottled teeth. Today, 41% of adolescents between the ages of 12 and 15 have some degree of fluorosis, and the number is rising. When the initial fluoride recommendation was made in 1962, fluoride was found in far fewer sources.

Fluoridation of water has come under fire recently, with experts weighing in on both sides of the argument. Deputy Surgeon General Rear Admiral Dr. Boris Lushniak supports fluoridation. “Community water fluoridation continues to reduce tooth decay in children and adults beyond that provided by using only toothpaste and other fluoride-containing products,” he commented.

Fluoride is now found in almost all toothpastes and rinses
Fluoride is now found in almost all toothpastes and rinses

But Dr. Philippe Grandjean, an environmental health researcher and physician at Harvard University, disagrees, stating that there has been insufficient research in recent years to support the benefits of widespread fluoridation. “We need to revisit those benefits to make sure that the old reports are still valid for the current fluoride exposure situation,” Grandjean stated.

Dr. Grandjean is one of a growing group who advocates only using fluoride topically, and to avoid swallowing it. He notes that fluoride produces the bulk of its benefits topically, and that ingestion exposes the internal organs to unnecessary chemical burden. Recent studies have suggested a possible link between drinking water fluoridation and ADHD, as well as hypothyroidism. Some Chinese studies have even suggested a link between high fluoride levels in drinking water and reduced IQ.

“I’d say it’s a reasonable concern that fluoride can affect brain development,” Grandjean says. “Lowering the recommended fluoridation level to 0.7 mg per liter is very well-justified. I would in fact recommend that the level be reduced even further,” stated Dr. Grandjean, adding that cavities have declined at similar rates in countries with and without public drinking water fluoridation.

AWWA submits comments on EPA’s draft CCL4

glass of waterAWWA has submitted comments to the EPA on the draft Fourth Contaminant Candidate List (CCL4). The draft CCL4, originally published in the Federal Register on February 4, 2015, listed 100 chemicals and 12 microbial contaminants. However, AWWA has recommended that the final CCL4 only include 20-50 compounds and that the EPA “use an alternative contaminant identification process to select a shorter list of compounds of greatest potential concern”.

To read the AWWA’s full comments, click here.

AWWA and EFCN partner to offer no-cost webinars for small water systems

small water utility eventsAs part of the EPA Competitive Assistance Award process, AWWA and the Environmental Finance Center Network are partnering to offer the following no-cost web trainings designed specifically to meet the needs of small water systems. You do not need to be an AWWA member to participate – but advance registration for each event is required.

April 14, 2015 | 1:30–2:30PM (eastern)

Key Financial Indicators

Is your water system financially healthy? This webinar will discuss and examine the key financial indicators that allow small systems to make informed decisions in planning and investment. The webinar will include training on how to calculate and interpret your system’s operating ratio, debt service coverage ratio, current ratio, and days of cash on hand. The webinar will also discuss how funders use these numbers in deciding whether or not to loan your system money needed for capital improvements.

Attending this webinar will help you to:

  • Better understand your system’s operating ratio, debt service, coverage ratio, current ratio, and days of cash on hand
  • Understand your costs and revenues
  • Move from “paycheck to paycheck” to longer term planning

Click here to register for this event.

April 16, 2015 | 1:00–2:00PM (eastern)

Asset Management IQ: How much do you know about AM tools and resources?

This interactive webinar will include an overview of Asset Management core principles and community/organization level of engagement with Asset Management. There are many tools and resources that communities can use as they move through the process of developing an Asset Management plan. This webinar will also provide an overview of available tools and resources.

Attending this webinar will help you to:

  • Understand the concepts and practices of Asset Management
  • Gauge system-wide level of understanding and engagement in Asset Management planning
  • Understand how to conduct asset management using simple and complex tools
  • Be presented with a breadth and depth of resources that support community asset management efforts

Click here to register for this event

Please direct any webinar-specific questions to Khris Dodson at kdodson@syracusecoe.org.

Please direct all other small system training questions to Kami Johle Butt at kbutt@awwa.org.

In-Person Workshops

These training partners are also offering several in-person training opportunities for small water systems:

  • Oregon, Financial Management Workshop, April 8, 2015
  • Louisiana, Asset Management and Water Loss Workshop, April 14, 2015
  • Rhode Island, Management and Finance Tools and Techniques, April 14, 2015
  • New Jersey, Small System Operator Training: Achieve and Maintain Compliance with SDWA, April 14 and April 21, 2015 (Two half day workshop)

Click 2015 Workshops for more information about these and other no-cost small system workshops sponsored by these training partners.

EPA Launches Water Utility Response On-The-Go Mobile Site

Water Utility Response On-The-GoThe US Environmental Protection Agency (EPA) has launched a brand new field-accessible mobile website. Water Utility Response On-The-Go is an innovative tool that consolidates information and tools that water utility operators and their response partners may need during an emergency. The tool is ideal for small systems that lack a large support network in place when natural disasters strike.

Water Utility Response On-The-Go allows users to accomplish the following:

  • identify and contact emergency response partners
  • monitor local and national severe weather conditions
  • review and complete incident-specific checklists; and populate
  • save and email both generic damage assessment forms and FEMA incident command system forms.

The Water Utility Response On-the-Go Mobile Website is available at epa.gov/responseotg.

For more information or questions about this tool, please contact Bailey Kennett at 202-566-1344 or Brian Pickard at 202-564-0827 of EPA’s Water Security Division.