Monday, February 22, 2010

Airport Sector Requirements Under MPCA 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 by between June and October 2010, depending on their industrial sector.

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

The revised permit details requirements for 29 different industrial sectors. The requirements described below are for the Air Transportation Facilities Sector (Sector S). Sector S facilities include only those portions of the site that are engaged in servicing, repairing, or maintaining aircraft and ground vehicles, equipment cleaning and maintenance, or deicing/anti-icing operations.. These requirements are in addition to permit requirements that apply to all sectors.

Review requirements that apply to all sectors

Permit requirements can apply to both Airport Authority and to individual tenants, including airline carriers, fixed- base operators (e.g. fueling companies and maintenance shops), and others that have leases/agreements with the airport authority to conduct business on airport property. The effected tenants may not necessarily conduct activities that, on their own, would require an industrial stormwater permit.

Employee Training:
In addition to other training requirements, employee training programs need to include training:
1. Proper handling of deicing materials and fuels.
2. Spill and leak prevention.
3. Proper recordkeeping of deicing fluids applied and stored.

[Read more about Minnesota stormwater training]

Good Housekeeping:
For agricultural aviation operations occur, the facility must prevent contact of stormwater with pesticides, herbicides, and other agricultural chemicals.

In addition to the routine inspection requirements, facilities must conduct two inspections per month during the deicing season. Operations 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:
All facilities must evaluate whether over application of deicing chemicals on runways occurs by analyzing and adjusting application rates as necessary, consistent with considerations and requirements of flight safety The site SWPPP must include measures to prevent or minimize contamination of stormwater from all areas used for aircraft, ground vehicle and equipment maintenance, and must store all aircraft, ground vehicles and equipment awaiting maintenance in designated areas only.

Potential Pollutant Sources:
The site SWPPP must also describe potential pollutant sources including aircraft, runways, ground vehicle and equipment maintenance and cleaning, aircraft and runway deicing operations, runways and loading areas where agricultural aviation operations occur.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. The benchmark concentrations are based on deicing chemical usage:

>100,000 gallons of glycol-based deicing/anti-icing chemicals and/or >100 tons of urea on an average annual basis:
TSS 100 mg/L
BOD 25 mg/L
COD 120 mg/L
Total Ammonia 2.8 mg/L
pH 6-9

Less than 100,000 gallons
TSS 100 mg/L
BOD 25 mg/L
COD 120 mg/L
Total Ammonia 2.8 mg/L

Note: Benchmark for ammonia 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]

Looking for information on Minnesota SWPPP - Industrial Stormwater Training?, go to:
MPCA Industrial Stormwater Training - SWPPP Training - Stormwater Inspection Training

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
Caltha LLP Website

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