Sunday, March 15, 2009

Proposed MPCA SWPPP Requirements for Electric Generating Facilities

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, 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]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Steam Electric Generating Facilities (Sector O). Sector O covers three primary types of facilities, 1) steam electric power generation using coal, natural gas, oil, nuclear energy, etc., to produce a steam source; 3) dual fuel co-generation facilities; and 3) alternative fuel generating facilities used to produce steam.

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

Good Housekeeping Practices:
The SWPPP must describe and implement procedures to reduce or control the tracking of ash and residue from ash loading areas. Clear the ash building floor and immediately adjacent roadways of spillage, debris, and any excess water before departure of each loaded vehicle.

Inspections must include:
a) coal handling areas,
b) switchyards,
c) ash handling areas,
d) areas adjacent to disposal ponds and landfills.

Inspections must include all residue-hauling (i.e. ash) vehicles for proper covering over the load, adequate gate sealing, and overall integrity of the container body. Dischargers must repair, as soon as practicable, vehicles without load covering or adequate gate sealing, or with leaking containers or beds. Two of the monthly inspections must be conducted during runoff events and one of the inspections shall be performed during a snow melt runoff event.

Preventative Maintenance:
The SWPPP must describe and implement measures that prevent or minimize stormwater from contacting fugitive dust emissions from coal handling areas and to prevent or minimize contamination of stormwater runoff from delivery vehicles carrying significant materials arriving at the facility. The SWPP must have procedures ensuring overall integrity of the body or container and procedures to deal with leakage or spillage from vehicles or containers.

The SWPPP must also describe and implement measures that prevent or minimize contamination of surface runoff from oil-bearing equipment in switchyard areas and to retard flows and limit the spread of spills from oil-bearing equipment in switchyards, or collecting runoff in perimeter ditches from these areas.

Spills and Leaks:
The SWPPP must describe and implement measures to reduce the potential for an oil or chemical spill, or reference an SPCC plan, and to visually inspect the structural integrity of all above-ground tanks, pipelines, pumps, and related equipment, and conduct any necessary repairs immediately.

Management of Runoff:
The SWPPP must describe and implement measures that prevent or minimize contamination of surface runoff from areas adjacent to disposal ponds or landfills, and must include procedures to reduce ash residue that may be tracked on to access roads traveled by residue handling vehicles, and reduce ash residue on exit roads leading into and out of residue handling areas.

SWPPP Contents:
The SWPPP must identify:
1) scrap yards, and general refuse areas;
2) short- and long-term storage of construction materials, paint equipment, oils, fuels, used and unused solvents, cleaning materials, paint, water treatment chemicals, fertilizer, and pesticides);
3) landfills and construction sites; and
4) stockpile areas (e.g., coal or limestone piles).

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

Coal Fired and Oil Fired Steam Electric Generating Facilities:
TSS 100 mg/L
Iron 1.0 mg/L

Nuclear and Natural Gas Fired Co-Generation Facilities:
TSS 100 mg/L

[Read more about how benchmarks are used under the proposed MPCA industrial permit]
[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
Caltha LLP Website

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