MPCA Infiltration Device - Pond Requirements

The use of stormwater infiltration has been a popular choice for stormwater management for many years. The benefits of infiltration include reducing overall run-off volume, reducing stormwater and channel run-off rates, and reducing pollutant loading.

However, infiltration can also create other issues, including groundwater contamination. Infiltration of stormwater (and the wastes it carries) may also invoke other environmental regulations.

The Minnesota Pollution Control Agency has incorporated requirements for the use of both infiltration devices and stormwater ponds used to manage industrial site runoff. These requirements include:

1. Industrial stormwater ponds and infiltration devices located in areas where high levels of contaminants exist in the soil or in the shallow aquifer, must not contribute to contaminant(s) spreading to a greater extent or rate. At any contamination site, a site analysis shall be conducted and a report filed with the SWPPP.

a. If industrial stormwater ponds and infiltration devices are found to be a contributor to contaminant increase or movement, the site must submit a plan to MPCA that describes how they will be reducing contaminants, redesigning, relocating, or eliminating the industrial stormwater ponds and infiltration devices, as needed, to eliminate the contribution to contaminant problems.

2. Industrial stormwater ponds and infiltration devices can not be used in any high risk karst area unless a professional geotechnical evaluation is conducted to ensure that they do not present a significant risk to groundwater.

a. If the industrial stormwater ponds and infiltration devices present a risk, appropriate measures, such as sealing or removal of the industrial stormwater ponds or infiltration devices, must be taken to eliminate or minimize the risk. Evaluations shall be documented with the SWPPP.

3. Use of industrial stormwater ponds and infiltration devices in vulnerable wellhead protection areas must be coordinated with local drinking water authorities and shall be designed to not adversely affect drinking water supplies. The facility must contact the appropriate local drinking water authorities and document coordination efforts with the SWPPP.

4. Facilities using any infiltration device defined as a “Class V injection well” shall contact the US EPA Region HQ to determine the need to register as a “Class V injection well”. Contacts and USEPA response need be documented with the SWPPP.

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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

MPCA Stormwater Permit Application - Due Dates By Industry Sector

The Minnesota Pollution Control Agency is in the final stages of releasing a revised industrial stormwater general permit. The revised permit will replace the current permit that was issued in 1997. The revised permit represents a significant departure from compliance requirements Minnesota industrial and “industrial-like” facilities have had.

MPCA’s tentative schedule is to present findings on the revised permit to Citizens’ Board and request Board approval of permit on March 23, 2010. Assuming that the permit is approved, MPCA anticipates the final permit with be effective April 1, 2010.

All facilities subject to the stormwater rules must submit an application for coverage under the revised permit, even if already covered under the expired permit. Existing facilities must have prepared and implemented a new SWPPP and be in compliance with the new permit before they apply for permit coverage. New facilities must submit applications at least 180-days before beginning construction or operation.

Because of the volume of applications that MPCA expects to receive, the due date for applications is staggered over six months. Application due dates will be based on the industrial sector a given facility falls into:

Sector Group 1
Applications due by June 1 (tentative)

Sector A - Timber Products
Sector C - Chemical and Allied Products Manufacturing
Sector D - Asphalt Paving and Roofing Materials and Lubricant Manufacturing
Sector E - Glass, Clay, Cement, Concrete, and Gypsum Products
Sector F - Primary Metals & Foundries
Sector G - Metal Mining
Sector I - Oil and Gas Extraction and Refining
Sector J - Mineral Mining
Sector L - Landfills, Land Application Sites, and Open Dumps
Sector M - Automobile Salvage Yards
Sector N - Scrap Recycling and Waste Recycling Facilities
Sector Q - Water Transportation
Sector Y - Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
Sector AA - Fabricated Metal Products

Sector Group 2
Applications due by August 1 (tentative)

Sector H - Coal Mining
Sector K - Hazardous Waste Treatment, Storage, or Disposal Facilities
Sector O - Steam Electric Generating Facilities
Sector P - Land Transportation and Warehousing
Sector R - Ship and Boat Building and Repair Yards
Sector S - Air Transportation Facilities
Sector Z - Leather Tanning and Finishing
Sector AC - Electronic and Electrical Equipment and Components


Sector Group 3
Applications due by October 1 (tentative)

Sector B - Paper and Allied Products Manufacturing
Sector T - Treatment Works
Sector U - Food and Kindred Product
Sector V - Textile Mills, Apparel, and Other Fabric Products
Sector W - Furniture and Fixtures
Sector X - Printing and Publishing
Sector AB - Transportation Equipment, Industrial and Commercial Machinery

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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

Paper Products Industrial Sector - Draft Arizona Permit

The Arizona Department of Environmental Quality (ADEQ) recently released an updated draft of its proposed multisector industrial stormwater discharge general permit, known officially as the AZPDES Multi-Sector General Permit, or MSGP 2010. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in 2005.

Review a summary of the ADEQ Industrial Stormwater Permit

Some key changes in the proposed permit are the additional requirements for 30 different sector specific requirements. The requirements described are proposed for the Paper and Allied Products Manufacturing Sector (Sector B). Sector B covers a fairly broad range of facility types, including paperboard mills, pulp mills, paper mills, paperboard containers and boxes, converted paper and paperboard products. These requirements are in addition to permit requirements that apply to all sectors.


Stormwater Monitoring Benchmarks:
Some facilities are required to conduct both visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values apply to Paper Board Mills (SIC 2631):

COD 120 mg/L

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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

Food Products Sector U - ADEQ Draft Industrial Stormwater Requirements

The Arizona Department of Environmental Quality (ADEQ) recently released an updated draft of its proposed multisector industrial stormwater discharge general permit, known officially as the AZPDES Multi-Sector General Permit, or MSGP 2010. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in 2005.

Review a summary of the ADEQ Industrial Stormwater Permit

Some key changes in the proposed permit are the additional requirements for 30 different sector specific requirements. The requirements described are proposed for the Food and Kindred Products Sector (Sector U). Sector U covers a fairly broad range of facility types, including meat products, dairy products, bakeries, beverage products, and many others. These requirements are in addition to permit requirements that apply to all sectors.

Employee Training:
SWPPP training programs must include information on pest control

Inspections:
Quarterly inspections must include:
a) waste management units;
b) vents and stacks associated with industrial activities;
c) spoiled product and broken product container holding areas;
d) animal holding pens;
e) staging areas; and
f) air pollution control equipment.


Stormwater Pollution Prevention Plan (SWPPP) Content:
The SWPPP must identify:
1) vents and stacks from cooking, drying, and similar operations;
2) dry product vacuum transfer lines;
3) animal holding pens;
4) spoiled product; and broken product container storage areas.

Potential Pollutant Sources:
The SWPPP must describe application and storage of pest control chemicals (e.g., rodenticides, insecticides, fungicides) used on plant grounds.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on product type:

Grain Mill Products:
TSS 100 mg/L

Fats and Oils Products:
TSS 100 mg/L
BOD5 30 mg/L
COD 120 mg/L
Nitrate 0.68 mg/L

[Read more about what a 100 mg/L benchmark for TSS relates to]

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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

SWPPP Employee Training - Stormwater Training Requirements FAQ

Stormwater regulations and most State and EPA NPDES stormwater discharge permits require some form of EMPLOYEE SWPPP TRAINING. Below are some common questions, or FAQ, Caltha receives regarding industrial stormwater pollution prevention training.



1. What Kind of Training is Required?
The answer will depend on the State your facility is located in – different States will have different training requirements. However, Caltha generally sees three categories for training:
a) SWPPP Awareness Training. This is “high-level” training which may be given to all employees, and covers basics of stormwater program and facility controls that would apply to any employee.
b) Stormwater Training. This training would be addressing employees whose day-to-day work activities relate to the specific controls and procedures the facility has established in its SWPPP, such as dock workers who might be involved with spills.
c) Stormwater Permit Compliance Training. Employees who have been assigned specific compliance tasks, such as conducting inspections, collecting stormwater samples, need to be trained to conduct their tasks.

2. Can I Use Generic Training Materials?
Many good training resources are available, including video training and “on-line” courses. Caltha often recommends these resources as a element of a facility’s training program. Whether or not these types of “off-the-shelf” training resources meet the training requirements will depend on the specific requirements for your State. In many cases, training needs to include information on the facility SWPPP, and therefore the “off-the shelf” resources need to be augmented with facility-specific training.

3. Does Every Employee Need to be Trained?
Possibly. However, as described in #1 above, not all employees need to have the same level of training. In addition, other factors, such as ISO 14001 registration, may require that you consider training contractors working at your facility.

4. How Often Does Training Need to be Presented?
Many States require annual refresher training; however, some training might only be presented once, such as Permit Compliance Training.

5. Does Stormwater Training Need to be Documented?
Yes, because training is a requirement of an NPDES discharge permit, records need to be maintained to demonstrate that all affected employees received the appropriate training.

6. Do Our Trainers Need Special Training?
This is not addressed in most States; however, effective trainers need to understand their subject matter. Caltha offers a number of “train-the-trainer” options.


Click here for more information on Caltha's Employee Stormwater and SWPPP Training Services

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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

Transportation Equipment Industrial Commercial Machinery Sector AB - ADEQ Draft Permit

The Arizona Department of Environmental Quality (ADEQ) recently released an updated draft of its proposed multisector industrial stormwater discharge general permit, known officially as the AZPDES Multi-Sector General Permit, or MSGP 2010. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in 2005.

Review a summary of the ADEQ Industrial Stormwater Permit

The proposed permit details requirements for 30 different industrial sectors. The requirements described below are proposed for the Transportation Equipment, Industrial and Commercial Machinery Manufacturing Sector (Sector AB). Sector AB facilities are engaged in a wide range of product manufacturing, including:
a. manufacturing engines and turbines,
b. manufacturing farm and garden machinery and equipment,
c. manufacturing construction, mining, and materials handling machinery and equipment,
d. manufacturing metalworking machinery and equipment,
e. manufacturing special industry machinery, except metalworking machinery,
f. manufacturing general industrial machinery and equipment,
g. manufacturing refrigeration and service industry machinery,
h. manufacturing miscellaneous industrial and commercial machinery and equipment,
i. manufacturing motor vehicles and motor vehicle equipment,
j. manufacturing aircraft and parts,
k. manufacturing motorcycles, bicycles, and parts,
l. manufacturing guided missiles and space vehicles and parts, and
m. manufacturing miscellaneous transportation equipment.

These requirements are in addition to permit requirements that apply to all sectors.


Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual monitoring. For benchmark monitoring, the benchmark concentrations or values are:

None


Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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

Fabricated Metal Products Sector AA - Draft Arizona Permit

The Arizona Department of Environmental Quality (ADEQ) recently released an updated draft of its proposed multisector industrial stormwater discharge general permit, known officially as the AZPDES Multi-Sector General Permit, or MSGP 2010. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in 2005.

Review a summary of the ADEQ Industrial Stormwater Permit

The proposed permit details requirements for 30 different industrial sectors. The requirements described below are proposed for the Fabricated Metal Products Sector (Sector AA). Sector AA facilities include fabricated metal products (except machinery and transportation equipment) jewelry, silverware, and plated ware, and fabricated metal coating, engraving and allied services. These requirements are in addition to permit requirements that apply to all sectors.

Inspections:
The facility must conduct inspections addressing areas associated with spent solvents, chemical storage areas, and outdoor paint areas.

Good Housekeeping:
The pollution prevention program must implement measures for controlling or recovering scrap metals, fines, and metal dust. The SWPPP must include measures for containing materials within storage handling areas. The SWPPP must describe and implement measures for storage of metal working fluids.

Leaks and Spills:
The spill prevention program must address chromium, toluene, pickle liquor, sulfuric acid, zinc and other water priority chemicals, and hazardous chemicals and wastes.

The spill prevention plan must describe and implement measures to control and clean up spills of solvents and other liquid cleaners, control sand buildup and disbursement from sand-blasting operations, and prevent exposure of recyclable wastes including rinse waters. Each operation must use monitoring equipment or other devices to detect and control leaks and overflows of lubricating oil and hydraulic fluid operations and install perimeter controls, or equivalent measures.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on product type:

Fabricated Metal Products, (SIC 3411-3499; 3911-3915)
Total Aluminum 0.75mg/L
Total Iron 1.0 mg/L
Total Zinc 0.04 to 0.26 mg/L, depending on hardness

Fabricated Metal Coating and Engraving (SIC 3479):
Nitrate 0.68 mg/L
Total Zinc 0.04 to 0.26 mg/L, depending on hardness



Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide 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