Trade Group Needed Technical Support For Public Comments In Water Standard

Caltha LLP Project Summary

Project: Water Quality Standards Development Public Comment Support
Client: Agricultural Products Sector Trade Group
Location(s): Kansas


Key Elements: Water quality standards development, Public testimony, Public comments


Overview: Caltha LLP provided technical support to the trade group and its members to address proposed water quality standards for atrazine, a widely used herbicide. A draft ambient water quality standard for atrazine was being proposed by the US EPA Office of Water and was being reviewed by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Science Advisory Panel, convened in Washington DC. Caltha reviewed underlying studies and other research which were being used to derive the proposed standards, and provided oral testimony before the SAP on technical concerns regarding the calculation of the proposed standards.


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Iowa Food Processing Plant Needed Water Reduction Management Plan

Caltha LLP Project Summary

Project: Water Use Reduction Audit / Water Usage Management Program
Client: International Food Processor
Location(s): Iowa


Key Elements: Water use reduction audit, Water use process control limits, Water use management plan


Overview: This large facility wished to reduce overall water usage as a corporate initiative to reduce environmental impacts of its operations and because the facility was approaching permitted limits for wastewater discharge to the local POTW. Water was used in a wide variety of processes around the facility, and water usage inside the plant was monitored by a set of water meters collecting daily total usage at various points around the water distribution system. Project elements included:

• Developing a Water Use Map for the facility,
• Review and statistically analysis of previous five years of water meter  and daily processing throughput data,
• Identification of specific processes determined to be “out-of-control”, defined as those process areas where variations in water usage were poorly correlated to production.

Once targeted processes were identified, control limits were calculated for each process so that daily water use could be quickly evaluated by facility staff to determine if immediate corrective action(s) were needed. Using this system, incremental improvements on water use reduction were realized.


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Constructed Wetland Annual Inspection And Monitoring Report

Caltha LLP Project Summary

Project: Constructed Wetland – Wetland Mitigation Annual Inspection and Monitoring Report
Client: Metropolitan Council
Location(s): Minnesota


Key Elements: Constructed wetland inspection, Preparation of annual wetland monitoring report


Overview: Caltha was contracted to provide inspection services to review the condition, hydrology and wetland plant species diversity for this constructed wetland project. Caltha conducted a site inspection to identify prevalent wetland plant species and their relative abundance. The wetland survey also identified invasive species and made recommendations for enhanced control of specific invasive wetland plants which were identified at the site. An annual wetland monitoring report was prepared to be submitted to the local watershed district, which permitted the wetland mitigation, local city officials, and the Minnesota Department of Natural Resources.


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Permitting of Waste Discharge Permit To Pennsylvania Designated Trout Stream

Caltha LLP Project Summary

Project: Waste Discharge Permit To Pennsylvania Designated Trout Stream
Client: National manufacturer
Location(s): Pennsylvania

Key Elements: Preparation of waste discharge application; Preparation of public notice and local government notification

Overview: This project was to prepare application materials and other required submittals to apply for an NDPES discharge permit for discharge of industrial wastes to a designated cold water fishery in Pennsylvania. Work included sampling and analysis of wastewater discharges and a non-stormwater discharge survey to certify the elimination of all illicit discharges. Permit was issued for discharge which maintained quality of receiving water .

For more information on Caltha LLP services, go to the Caltha Contact Page

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. Caltha LLP Aquatic Toxicology / WQ Standards Services Website

Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment

Caltha LLP Project Summary

Project: Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment
Client: Agricultural Chemical Manufacturer
Location(s): California, Illinois, Texas, Minnesota

Key Elements: Acquisition and review of state water quality monitoring data; statistical analysis of the occurrence and concentrations of herbicide in surface water, preparation and submittal of public comments to Department of Agriculture Draft Environmental Assessment

Overview: Caltha was contracted by this multinational agricultural chemical company to prepare a review and analysis of the occurrence of a specific common use herbicide, 2,4-D, in waters of the United States. Caltha first reviewed and summarized nationwide data in the US EPA STORET database and U.S Geological Survey (USGS) National Water-Quality Assessment (NAWQA) Program database. Caltha staff then contacted State agencies which implemented long-term Statewide water quality monitoring programs, including California, Texas, Illinois and Minnesota. All data were then compiled to provide a summary of 2,4-D concentrations in surface waters dating from the 1970s through 2012. Caltha then conducted a review of federal and state regulatory standards for 2,4-D in surface waters, including:

• Federal Water Quality Criteria
• State Water Quality Standards
• Federal Safe Drinking Water Act Maximum Contaminant Level
• Office of Pesticide Program Aquatic Life Benchmarks

Finally, Caltha conducted an analysis of the exceedance of applicable regulatory standards based on the comprehensive analysis of reported herbicide concentrations. All analyses were summarized in a report which was submitted to the US Department of Agriculture through its public comment process for a Draft Environmental Assessment document.

For more information on Caltha LLP services, go to the Caltha Contact Page

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. Caltha LLP Aquatic Toxicology / WQ Standards Services Website

EPA Proposes Rule Requiring Electronic Submittal For NPDES Permit Information and Data

EPA is proposing rules that would require electronic reporting in place of the current paper-based NPDES reports. The proposed regulation would require permittees and regulators to use existing, available information technology to electronically report information and data related to the NPDES permit program in lieu of filing written reports. EPA believes the proposal will allow better allocation and use of limited program resources and enhance transparency and public accountability by providing regulatory agencies and the public with more timely, complete, accurate, and nationally-consistent sets of data about the NPDES program and potential sources of water pollution.

Given the large scope of the proposal, EPA has committed to publishing a supplemental notice should the agency receive comments on the proposed rule that require significant changes. EPA plans to publish the supplemental notice within 180 days after the public comment period for this proposed rule has closed. Comments on this proposed action must be received on or before October 28, 2013.

This proposed rule would require that reports submitted in writing now be submitted electronically by NPDES-permitted facilities to EPA through the National Environmental Information Exchange Network or to the authorized state, tribe, or territory NPDES program. This can include:

• Discharge Monitoring Reports (DMRs),
• Notices of Intent (NOI) to discharge in compliance with a general permit,
• other general permit waivers,
• certifications,
• notices of termination (NOT) of coverage,
• program reports

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.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website

2006 NPDES Pestides Rule And Related Excemptions Removed

In response to a 2009 Sixth Circuit Court of Appeals ruling that vacated the 2006 NPDES Pesticides Rule, EPA has revised regulations to remove language added by the that rule. This language had exempted the application of pesticides from National Pollutant Discharge Elimination System (NPDES) permit requirements in two circumstances:

1. When the application of the pesticide is made directly to waters of the United States to control pests that are present in the water, and
2. when the application of the pesticide is made to control pests that are over, including near, waters of the United States.

The final rule removes this exemption and is effective on June 27, 2013.

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.

Caltha LLP Aquatic Toxicology / WQ Standards Services Website