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Spring Brings Change and Renewal


By Kelley Fetter - April 13, 2017

E2RC has revamped its website.  This renewal of our outreach to the stormwater, erosion control, and compliance world matches the calendar; it’s Spring!  Spring marks Nature’s reminder our world functions best with clarity, preservation, and order.

E2RC recognizes it is impossible to overcome Nature.  Stormwater Management is an activity geared towards promoting clarity.  If we minimize disturbance, retain sediment and remove pollutants, the water we have has a great chance to be clean water to use – clarity.

Reclamation and preservation parallel what we see when Spring returns each year.  The environment works to restore what was lost through Winter.  New growth from last year’s reclamation efforts confirms that the energy invested is warranted and worthwhile - preservation.

E2RC is vested in supporting environmental compliance.  All the elements in MS4, Industrial, and Construction activities are driven by order.  Our turnkey services help client’s in every NPDES demonstrate compliance to deliver defendable and defensible results.  Performance based engineering, outcome focused BMP implementation linked with the industry’s most comprehensive, web-based compliance management tools from Comply26, LLC, deliver sound, reliable, and dependable compliance – order.

Happy Spring!  Thanks for reading and check back soon for the next posting.
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Changes with the 2017 Construction General Permit


The 2017 Construction General Permit (“CGP”) is effective today. It’s 171 pages of heart pounding, can’t put it down literature. Just kidding.
There are few significant changes to the 2017 CGP. Although a bit longer, the Environmental Protection Agency did a nice job of streamlining and refining the language to be easier to read and understand. However, they did remove several of the ever ambiguous ‘if unfeasible’ options for the permit requirements. But, if you continue with good housekeeping habits and follow your SWPPP, you’ll be in good shape.

Changes to note:
  1. New Prohibited Non – Stormwater Discharges:
    The 2017 permit prohibits discharging external building washdown waters containing hazardous substances. Hazardous substances include soap, solvents, detergents, paint, caulk containing polychlorinated biphenyls (PCBs) and related materials. If the external building washdown does not contain these items, it is an authorized non – stormwater discharge under the permit but must continue to comply with the stormwater, erosion/sediment and pollution control requirements with which you are familiar.
  2. NPDES Permit Notification:
    The NPDES Permit Coverage Notification (e.g. the SWPPP Board) must now include instructions the public may use to contact the EPA to receive a copy of the project’s SWPPP, and how to contact the EPA if they see stormwater pollution discharging from the site. The notification must continue to be located at a readily accessible location near the construction site.
  3. Stockpiles and Land Clearing Debris Piles:
    The Operator must cover or temporarily stabilize all inactive stockpiles and land clearing debris piles that will not be used for 14 days or more. See #5 for deadline requirements.
  4. Stabilization Deadlines:
    The requirement to ‘immediately’ initiate stabilization measures triggers when you know the site or area will be inactive for 14 days or more or as soon as you know the earth – disturbing activities have stopped. 
    • Sites disturbing ≤ 5 acres must initiate stabilization measures immediately and complete the stabilization as soon as possible, but no later than 14 days after initiating the stabilization.
    • Sites disturbing > 5 acres must initiate stabilization measures immediately and complete the stabilization area as soon as possible but no later than seven days after initiating the stabilization.
    The EPA’s goal is to incentivize limiting earth disturbance through phasing by offering longer stabilization time frames for smaller disturbed areas. As such, if your total project is more than five acres but you disturb fewer than five acres at a time, the stabilization requirements follow the 14 – day time frame.
  5. Construction and Domestic Waste:
    Operators must close or cover actively used waste containers when not in use and at the end of each business day. If the container does not have a lid, the Operator must cover the container with a similarly effective method as a lid.
  6. Discharge Limitations to Sensitive Waters:
    If the site discharges to a U.S. water that is impaired for PCBs, and the site is engaging in demolition of any structure with at least 10,000 square feet of floor space built or renovated before 01/01/1980, you must (1) implement controls to minimize precipitation/stormwater exposure to PCB containing materials (e.g. paint, caulk, pre-1980 fluorescent light fixtures), and (2) dispose of those materials in compliance with local, state and federal laws.
  7. Notice of Intent and CDX System:
    The EPA added a few new questions to the NOI form. E2RC will handle those questions for you. However, all NOI certifiers will use a new CDX system and NOI certification process. We’ll send more comprehensive information and instructions to access the new system to all NOI certifiers in a couple of days.
  8. Indian Country Requirements:
    Section 9.4 of the 2017 CGP outlines additional requirements applicable to work or discharges occurring on specific pueblos in New Mexico. If your project will take place on pueblo land, give us a call to go over any additional requirements. Likely, you are already performing these tasks, but it never hurts to check.
That’s it. No big deal. If you have any questions about the new CGP or its requirements, please call our office at (505) 867-4040. We wish you best on current and future projects, and look forward to partnering with you for a successful 2017.

Best,
E2RC, LLC
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How to Certify with the 2017 Construction General Permit


The 2017 Construction General Permit (“CGP”) took effect on February 16, 2017. One item the EPA has implemented with the new CGP is a new NOI management system and certification process. The new system certainly is steps above the eNOI system and NOI certifiers will encounter a more straight-forward process to review and certify each NOI, Low Erosivity Waiver (“LEW”) and Notice of Termination (“NOT”).  

CDX Net E-Reporting System

The EPA will now utilize the CGP NeT system through which it will accept, review and approve each NOI, LEW and NOT. Fortunately for existing users, the steps you will need to perform to be able to certify your project permits are quick and simple.
  1. Go to: https://npdes-ereporting.epa.gov/cgp
  2. Login with the same username and password you used for the CDX eNOI system.
  3. Add the NeT Program:
    1. On the MyCDX Homepage click ‘Add Program’.
    2. Select ‘NeT: NPDES eReporting Tool’; and then
    3. Select ‘NeT – EPA Stormwater Construction General Permit’.
    4. Select the ‘Certifier’ role
  4. Complete the Electronic Service Agreement (“ESA”)If you previously completed the ESA you will only need to answer the security questions you created during the initial account set-up to authenticate your account. If you have not completed the ESA, you will need to provide certain pieces of information which will be verified via LexisNexis. This information is for verification purposes only and is not saved or stored. You can choose to complete a paper ESA, but this will delay your account authentication.

Certification Process

The certification process will no longer require a certification key. Instead, after E2RC has prepared your NOI, LEW or NOT, we will route the document to you for review and certification. When we do this, you will receive an email notification indicating you have a form to review. After you log in to your CDX NeT account, the form will be ready to certify.

Ongoing Construction Projects

The 2017 CGP provides a May 17, 2017 deadline to transfer all NOIs for ongoing projects under the 2012 CGP to the NeT system. E2RC will do this for you. After the transferred NOI is active, we will then file the NOT for the previous NOI. This will prevent any gap in coverage and tie up loose ends. Note, however, the 14 - day activation period is still in effect for any new projects that will start under the 2017 permit. 
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