Ports - Water Transportation Sector Requirements Under MN Permit

The Minnesota Pollution Control Agency (MPCA) has issued its revised multi-sector industrial stormwater discharge general permit (MSGP). This permit will replace the existing industrial stormwater permit, which expired in October of 2002.

[Read a summary of the overall Minnesota permit, stormwater monitoring, and sector requirements]

All manufacturing, industrial and “industrial-like” sites that require a permit to discharge stormwater will be required to come into compliance with the revised permit, and to submit an application for permit coverage between June & October 2010, depending on their industrial sector.

Click here to review a list affected industrial sectors and application deadlines for each sector

The revised Minnesota permit details requirements for 29 different industrial sectors. The requirements described below are for the Water Transportation Sector (Sector Q). Sector Q includes SIC Code Major Group 44 that have maintenance shops and/or equipment cleaning operations, including water transportation industry, marine cargo handling operations, ferry operations, towing and tugboat services, and marinas. These requirements are in addition to permit requirements that apply to all sectors.

Inspections:
The facility must inspect all the following areas/activities: pressure washing area; blasting, sanding, and painting areas; engine maintenance and repair areas; drydock area; and general yard area.

The facility must conduct two of the monthly inspections during runoff events. One of the inspections shall be performed during a snow melt runoff event. Each inspection must include a visual assessment of the runoff to identify any visible sheens or films that indicate the presence of oil or grease in the discharge.

Good Housekeeping:
Each facility must implement a schedule for routine yard maintenance and cleanup. Regularly remove from the general yard area scrap metal, wood, plastic, miscellaneous trash, paper, glass, industrial scrap, insulation, welding rods, and packaging.

Each facility must implement procedures for routinely maintaining and cleaning the drydock area to prevent or minimize pollutants in stormwater runoff, and address the cleaning of accessible areas of the drydock prior to flooding following removal of the vessel and raising the dock. Include procedures for cleaning up oil, grease, and fuel spills occurring on the drydock.

The site must regularly clean deposits of abrasive blasting debris and paint chips.

Employee Training:
The employee training program must include used oil management, spent solvent management, disposal of spent abrasives, fueling procedures, painting and blasting procedures, and used battery management.

Preventive Maintenance:
The SWPPP must describe measures to prevent spent abrasives, paint chips, and overspray from coming into contact with stormwater. The operations must contain all blasting and painting activities, or use other measures to prevent the discharge of the contaminants (e.g., hanging plastic barriers or tarpaulins during blasting or painting operations to contain debris).

Each site must also implement and describe measures to prevent or minimize the contamination of stormwater from all areas used for engine maintenance and repair, and measures to prevent or minimize the contamination of stormwater from material handling operations and areas (e.g., fueling, paint and solvent mixing, disposal of process wastewater streams from vessels).

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations are:

TSS 100 mg/L
Total Aluminum 1.5 mg/L
Total Lead 0.164 mg/L
Total Iron 1.0 mg/L
Total Zinc 0.234 mg/L

Note: Benchmark for aluminum were derived based on the Aquatic Life Standards for these parameters in Minnesota Rules.

[Read more about use of Aquatic Life Standards to derive stormwater benchmarks]
[Read more about how benchmarks are used under the revised MPCA industrial permit]
[Read more about what a 100 mg/L benchmark for TSS relates to]


Looking for other sector information?
Click here for a link to all sector requirements

Caltha LLP provides expert consulting services to public and private sector clients in Minnesota to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Visual - Benchmark Stormwater Monitoring Compared To Wet Weather Inspections

Overtime, the requirements for stormwater discharge monitoring have shifted. During the 1990s, when stormwater discharge permitting requirements began to develop, “wet weather inspections” were incorporated into many State general permits. These inspections were to be conducted during a rain event and required the discharger to make certain observations about the stormwater being discharged at each of the stormwater outfalls. In most cases, wet weather inspections could be conducted without actually collecting a sample of the stormwater discharge.

Subsequently, the US EPA Multisector General Permit (MSGP) became more detailed and the Visual Monitoring requirement was developed. Overtime, State permits also incorporated a requirement to conduct visual monitoring. However, in some cases permits were not clear as to whether or not a sample of stormwater needed to be collected. Because of this ambiguity, some dischargers believed that the same protocol they were using for wet weather inspections still applied.

Recently, the EPA MSGP was revised to eliminate any uncertainty regarding the protocol to be used for Visual Monitoring:
“The visual assessment must be made:
- Of a sample in a clean, clear glass, or plastic container, and examined in a well-lit area;
- On samples collected within the first 30 minutes of an actual discharge from a storm event.”

Benchmark monitoring is also required of some industrial sectors. Benchmark monitoring becomes an extension of Visual Monitoring. Rather than documenting the visual characteristics of the sample, it is simply sent to an analytical laboratory for chemical analysis.

Therefore, in practice the same basic protocol is required to collect stormwater samples for both visual monitoring and benchmark monitoring.

[Read more about benchmark monitoring]
[Read more about selected stormwater monitoring techniques and equipment]

Caltha LLP provides a range of stormwater monitoring services, from development of a written Stormwater Monitoring Plan, to conducting stormwater monitoring training, to supplying equipment and sampling personnel to collect samples.
[Read more about Stormwater Monitoring Services]

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Monitoring – Storm Water Sampling Services

An increasing number of States require routine sampling of stormwater discharges to demonstrate compliance with NPDES discharge permits. Whether samples are needed for visual monitoring, chemical monitoring, or benchmark monitoring, one of the more challenging tasks a permitted facility must address is how to collect valid stormwater samples.

Caltha LLP provides expert technical support to permitted facilities and/or their consultants and engineers to develop stormwater monitoring programs developed to meet the requirements of individual States. Storm water programs are provided to meeting the needs of both Industrial and Municipal (MS4) stormwater dischargers.

[Read more about selecting the right stormwater monitoring approach]
[Read more about stormwater benchmark monitoring]

Caltha LLP provides a range of stormwater monitoring services, from development of a written Stormwater Monitoring Plan, to conducting stormwater monitoring training, to supplying equipment and sampling personnel to collect samples.
[Read more about Stormwater Monitoring Services]

Caltha provides State-specific stormwater training for the following States:
[Click on a State to request more information]

Alabama Stormwater Monitoring
Arizona Stormwater Monitoring
Arkansas Stormwater Monitoring
California Stormwater Monitoring
Connecticut Stormwater Monitoring
Florida Stormwater Monitoring
Georgia Stormwater Monitoring
Illinois Stormwater Monitoring
Indiana Stormwater Monitoring
Iowa Stormwater Monitoring
Kansas Stormwater Monitoring
Kentucky Stormwater Monitoring
Louisiana Stormwater Monitoring
Massachusetts Stormwater Monitoring
Michigan Stormwater Monitoring
Minnesota Stormwater Monitoring
Mississippi Stormwater Monitoring
Nebraska Stormwater Monitoring
Nevada Stormwater Monitoring
New Jersey Stormwater Monitoring
New York Stormwater Monitoring
North Carolina Stormwater Monitoring
North Dakota Stormwater Monitoring
Ohio Stormwater Monitoring
Oklahoma Stormwater Monitoring
Oregon Stormwater Monitoring
Pennsylvania Stormwater Monitoring
South Carolina Stormwater Monitoring
South Dakota Stormwater Monitoring
Tennessee Stormwater Monitoring
Texas Stormwater Monitoring
Utah Stormwater Monitoring
Virginia Stormwater Monitoring
Washington Stormwater Monitoring
Wisconsin Stormwater Monitoring

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Substantially Identical Outfalls - Substantially Identical Effluents

One option potentially available to dischargers required to conduct stormwater monitoring is the use of "Substantially Identical" outfalls. This is particularly useful to facilities with many outfalls that need to be monitored.

The selection of substantially identical outfalls does not have to be "pre-approved" in many cases. However, the risk to dischargers is that if the permitting agency does not agree with the determination of substantially identical outfalls, the discharger may be subject to enforcement action. Therefore, careful consideration and documentation that the selected identical outfalls are valid is important.

The criteria used to determine if the "Substantially Identical" option applies will change from State-to-State. Generally, the factors used can include:

• Location ;
• Industrial activities conducted in the drainage area of each outfall;
• Control measures implemented in the drainage area of each outfall;
• Materials used or stored;
• Runoff coefficient of the drainage areas.

Caltha LLP assists dischargers nationwide in developing and implementing cost effective stormwater monitoring programs, including determination and documentation of substantially identical outfalls. To request further information, go to SWPPP and SPCC website.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Substantially Identical Outfalls - Potential Option To Reduce Sampling Costs

One option potentially available to dischargers required to conduct stormwater monitoring is the use of "Substantially Identical" outfalls. This is particularly useful to facilities with many outfalls that need to be monitored.

The availability of this option will change from State-to-State, as will the exact requirements. However, generally if the facility has two or more outfalls that discharge substantially identical effluents, the facility may be allowed to conduct visual and/or benchmark monitoring at one of the outfalls and report that the results also apply to the substantially identical outfall(s). In many cases, the facility will need to perform monitoring on a rotating basis of each substantially identical outfall. However, if stormwater contamination is identified at any substantially identical outfall, control measures may need to be installed for all identical outfalls.

In many cases, selection of substantially identical outfalls does not have to be "pre-approved". However, the risk to dischargers is that if during subsequent compliance inspections the permitting agency does not agree with the determination of substantially identical outfalls, the discharger may be subject to enforcement action. Therefore, careful consideration and documentation that the selected identical outfalls are valid is important.

[Read more about factors used to determine substantially identical outfalls]

Caltha LLP asssists dischargers nationwide in developing and implementing cost effective stormwater monitoring programs, including determination and documentation of substantially identical outfalls. To request further information, go to SWPPP and SPCC website.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Monitoring - Considerations for Selecting Sampling Technique

Selecting the optimum stormwater sampling approach is a key element to managing costs for stormwater compliance monitoring.

[read more about three basic approaches to collecting stormwater samples]

Selecting the appropriate option for a given discharger requires consideration of all the outfalls that need to be sampled. For example, some outfalls may not be conducive for installing automated sampling equipment, and might require a different technique. Therefore, if a facility has four outfalls to sample and one can not be effectively sampled with automated equipment, staff may need to be trained to collect samples at that outfall anyway, and therefore it may not make much sense to install automated equipment at the other outfalls, unless other factors prevail.

The bottom line is that selecting a reliable and cost effective sampling method is dependant on a number of factors, including:

• Frequency of monitoring
• Types of parameters to be tested for
• Physical layout and constraints of the outfalls
• Safety considerations
• Availability of on-site staff
• Availability of contract sampling vendors
• Availability of equipment

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. Click here to request further information on Stormwater and SWPPP Services.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Cost for Stormwater Monitoring - Managing Costs By Selecting Optimum Sampling Stategy

Many States now require dischargers to collect stormwater samples to demonstrate that their stormwater pollution prevention measures are effective. Samples are either visually examined on-site, or sent to a laboratory for chemical analysis. Either way – samples need to be collected.

Because in most States samples need to be collected within the first 30 minutes of discharge, stormwater monitoring presents some special challenges. To further complicate this requirement, rain events may also need meet specific requirements (i.e., 0.25 inch total rain fall, dry for previous 3 days, etc.). There are three basic options available to dischargers:

1. Train Facility Staff to Collect Samples. In this case, a few staff are trained on how to collect and handle samples.
2. Contract Third-party Sampler. Here, you would need to contract with a vendor who is located close enough to be at the site and ready to sample within 30 minutes of the start of a rain fall event.
3. Buy or Lease Automated Sampling Equipment. In this case, equipment is installed at each outfall and samples are collected automatically when water begins to flow. In most cases, equipment would need to be installed by trained personnel.
   

Each of these options has its unique benefits and drawbacks. Using a third-party sampler has some logistically problems, as most facilities find it difficult to have someone on-site within 30 minutes, especially considering that the vendor may also be providing this service to others. Using automatic equipment eliminates this logistical problem; however, automated equipment tends to be more costly, and often needs to be reset after small rain events or if any other water gets inadvertently discharged to the storm sewer. Therefore many dischargers opt to train their own staff to collect samples, as it is the least expensive and most reliable method.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules, including Development of Stormwater Monitoring Plans and Training Facility Staff to Collect Stormwater Samples. Click here to request further information on Stormwater and SWPPP Services.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

MPCA Stormwater Monitoring Requirements - Proposed Requirements

The Minnesota Pollution Control Agency has released its revised general permit for stormwater discharges from industrial sites. The current general permit was written in 1997, and the upcoming revision will reflect major changes in stormwater permitting requirements.

Review a summary of the MPCA industrial permit

The most important proposed change in the draft permit compared to the current MPCA general permit is the requirement to sample stormwater discharges.

Flowchart of Draft MPCA Stormwater Monitoring Requirements


All permittees will collect and analyze at least four quarterly samples during Year 2 of permit coverage. These samples will be compared to “benchmark” concentrations. Depending on the results, further quarterly samples may need to be collected in Year 4 and 5, and corrective actions may be required. Additional reporting, including a “Benchmark Exceedence Report” and evaluations will be required for dischargers who continue to exceed benchmark concentrations. All sample results will be reported to MPCA.

Related Links:

Further information on stormwater benchmarks

Further information on selecting stormwater monitoring techniques

Comparison of stormwater benchmarks to typical discharge data

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Stormwater Monitoring - Selecting Appropriate Technique and Equipment

Many States now require dischargers to collect stormwater samples to demonstrate that their stormwater pollution prevention measures are effective. Samples are either visually examined on-site, or sent to a laboratory for chemical analysis. Either way – samples need to be collected.

Because in most States samples need to be collected within the first 30 minutes of discharge, stormwater monitoring presents some special challenges. To further complicate this requirement, rain events may also need meet specific requirements (i.e., 0.25 inch total rain fall, dry for previous 3 days, etc.). There are three basic options available to dischargers:

1. Train Facility Staff to Collect Samples. In this case, a few staff are trained on how to collect and handle samples.
2. Contract Third-party Sampler. Here, you would need to contract with a vendor who is located close enough to be at the site and ready to sample within 30 minutes of the start of a rain fall event.
3. Buy or Lease Automated Sampling Equipment. In this case, equipment is installed at each outfall and samples are collected automatically when water begins to flow. In most cases, equipment would need to be installed by trained personnel.
   

Each of these options has its unique benefits and drawbacks. Using a third-party sampler has some logistically problems, as most facilities find it difficult to have someone on-site within 30 minutes, especially considering that the vendor may also be providing this service to others. Using automatic equipment eliminates this logistical problem; however, automated equipment tends to be more costly, and often needs to be reset after small rain events or if any other water gets inadvertently discharged to the storm sewer. Therefore many dischargers opt to train their own staff to collect samples, as it is the least expensive and most reliable method.

Selecting the appropriate option for a given discharger requires consideration of all the outfalls that need to be sampled. For example, some outfalls may not be conducive for installing automated sampling equipment, and might require a different technique. Therefore, if a facility has four outfalls to sample and one can not be effectively sampled with automated equipment, staff may need to be trained to collect samples at that outfall anyway, and therefore it may not make much sense to install automated equipment at the other outfalls, unless other factors prevail.

The bottom line is that selecting a reliable and cost effective sampling method is dependant on a number of factors, including:

• Frequency of monitoring
• Types of parameters to be tested for
• Physical layout and constraints of the outfalls
• Safety considerations
• Availability of on-site staff
• Availability of contract sampling vendors
• Availability of equipment

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website