Thursday, February 18, 2010

Food Product Industry - MPCA Compliance Requirements

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 either June 1, August 1 or October 1, 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 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.

Review requirements that apply to all sectors

Employee Training:
SWPPP training programs must include information on:
1) used oil and spent solvent management;
2) segregation of organic materials, raw materials, and products from contact with stormwater and precipitation; and
3) pest control

[Read more about Minnesota stormwater training]

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.

At least two of the monthly inspections must be conducted during runoff events. One of the inspections must be performed during a snow melt runoff event.

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 25 mg/L
COD 120 mg/L
Ammonia 34.8 mg/L
Total nitrogen None

All Other Food Sectors:
TSS 100 mg/L
BOD 25 mg/L
COD 120 mg/L
Ammonia 34.8 mg/L
Total nitrogen 10 mg/L
Phosphorus 1.0 mg/L

Note: Benchmarks for ammonia and nitrate 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]
[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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