Thursday, February 18, 2010

Industrial Stormwater Control Requirements - All Minnesota Sites

The Minnesota Pollution Control Agency has released 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.

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 May, August or October, 2010 depending on their industrial sector.

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

Some of the requirements in the revised permit affect ALL PERMITTED FACILITIES regardless of industrial sector. These requirements include:

Stormwater Pollution Prevention Requirements:
All facilities are required to prepare and implement a site-specific Stormwater Pollution Prevention Plan (SWPPP). The permit includes specific information required in the SWPPP, as well as areas that need to be evaluated to determine if potential pollution sources exist. The SWPPP develops a set of Best Management Practices (BMPs) to address each of the potential source areas identified during the assessment.

Click here for information on MPCA Permit SWPPP Template

Routine Inspections:
All facilities are required conduct and document inspections at least monthly. At least one of these inspections needs to be conducted during a rainfall event.

Preventive Maintenance:
All facilities are required to prepare a Preventive Maintenance schedules for stormwater BMPs used by the site. In addition, each site will have to prepare a written equipment preventive maintenance program, including regular inspection, maintenance, and repair of industrial equipment and systems to identify conditions that could cause breakdowns or failures that may result in leaks, spills, and other releases.

Elimination of Non-stormwater Discharges:
Any facility covered under the MSGP must evaluate the potential of non-stormwater discharges from the site and to either eliminate the discharge or obtain a separate permit to discharge.

Spill Prevention and Response Procedures:
All sites must evaluate risks for spills and develop a Spill Prevention and Response procedure. This requirement applied to all facilities, and not limited to those already required to have equivalent procedures under SPCC Rules (40 CFR 112) or the Minnesota Spill Bill.

Mercury Minimization Plan:
All sites must document an evaluation of the facility to determine if any sources containing mercury are exposed to stormwater. If potential mercury sources or devices are found to be exposed to stormwater, a Mercury Minimization Plan must be developed. Mercury sources and devices shall be removed from stormwater exposure and managed in accordance applicable state and federal rules.

Employee Training Program:
Employers must develop an employee training program. Training will need to be provided to affected employees at least once each year.

Stormwater Monitoring Requirements:
All sites covered under the permit will have to collect stormwater samples and have samples analyzed by a Minnesota certified laboratory. Samples are collected at all affected discharge points from the site within the first 30 minutes of stormwater discharge. The results will be reported to MPCA on a quarterly basis. Results will be compared to stormwater “benchmark” values for each industrial sector.

[Read about MPCA industrial stormwater monitoring requirements]
[See flowchart summarizing MPCA industrial stormwater monitoring requirements]

Sector Specific Requirements:
Some of the key elements of the permit are the Sector Specific requirements. Each sector has additional compliance requirements that are in addition to the requirements described above.

Click here to review the industrial sector stormwater 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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