Saturday, April 4, 2009

Rubber - Plastic Manufacturing Sector - SWPPP - Stormwater Permit Proposed Requirements

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 Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Sector (Sector Y). Sector Y covers a very broad range of product types, including manufacturing of tires and inner tubes; rubber and plastic footwear; gaskets, packing and sealing devices; and rubber hose and belting; fabricated rubber products; Manufacturing of miscellaneous plastics products; musical instruments; dolls, toys, games and sporting and athletic goods; pens, pencils, and other artists’ materials; costume jewelry, costume novelties, buttons, pins and needles and miscellaneous notions. These requirements are in addition to permit requirements that apply to all sectors.

The facility must conduct inspections addressing air pollution control equipment (e.g., baghouses, electrostatic precipitators, scrubbers, and cyclones) for any signs of degradation (e.g., leaks, corrosion, or improper operation) that could limit their efficiency and lead to excessive emissions. The operation must monitor air flow at inlets and outlets (or use equivalent measures) to check for leaks (e.g., particulate deposition) or blockage in ducts. Also inspect all process and material handling equipment (e.g., conveyors, cranes, and vehicles) for leaks, drips, or the potential loss of material.

In addition to routine inspection requirements, the operation must conduct two of the monthly inspections during runoff events. One of the inspections must 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.

Preventive Maintenance:
Each site must implement specific controls to minimize contact of zinc with stormwater discharges by:

a) using chemicals purchased in pre-weighed, sealed polyethylene bags,
b) storing in-use materials in sealable containers,
c) ensuring an airspace between the container and the cover to minimize “puffing” losses when the container is opened,
d) using automatic dispensing and weighing equipment, and
e) replacing or repairing improperly operating dust collectors or baghouses.

The operation must also implement specific controls to minimize contact of plastic resin pellets with stormwater discharges.

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:

Rubber Manufacturing (SIC 3011-3069):
TSS 100 mg/L
Total Lead 0.164 mg/L
Total Zinc 0.234 mg/L

TSS 100 mg/L

Note: Benchmarks for zinc 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 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 a link to all sector requirements

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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