Saturday, April 4, 2009

Water Transportation 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 Water Transportation Sector (Sector O). Sector O 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.

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, and final cleanup 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 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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