Friday, February 19, 2010

Oil - Gas Extraction & Refining Sector Permit Conditions - MN

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 March 1, July 1 or September 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 Oil and Gas Extraction and Refining Sector (Sector I). Sector I covers a fairly broad range of facility types, including crude petroleum and natural gas, natural gas liquids, oil and gas field services, drilling oil and gas wells, and petroleum refining. These requirements are in addition to permit requirements that apply to all sectors.

The facility must conduct inspections addressing equipment and vehicles that store, mix, or transport chemicals or hazardous materials.

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:
The pollution prevention program must implement measures that prevent or minimize contamination of stormwater from chemical mixing areas, and take measures necessary to prevent discharge of stormwater coming into contact with wastewater pollutants from any sources associated with production, field exploration, drilling, well completion, or well treatment.

Potential Pollutant Sources:
The pollution prevention program must describe the following sources that have pollution potential: chemical, cement, mud, or gel mixing activities; drilling or mining activities; equipment rehabilitation activities.

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:

Oil and Gas Extraction (SIC 1311, 1321, 1381-1389):
TSS 100 mg/L
pH 6-9

Oil Refining (SIC 2911):
Ammonia 34.8 mg/L
Total Zinc 0.234 mg/L

Note: Benchmarks for zinc and 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]
[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 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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