Key Changes To New MPCA General Permit

The Minnesota Pollution Control Agency (MPCA) has issued a draft NPDES/SDS permit to control pollution generated from runoff associated with construction activities discharging into waters of the State of Minnesota.The draft permit will replace the current general permit which will expire on August 1, 2018. Some of the key revisions in the draft permit include:

Application and permit coverage effective date

MPCA is proposing to omit the mandatory 7 day waiting period. However, payment confirmation is required before the MPCA can issue permit coverage. The waiting period of “seven (7) calendar days” has been replaced with “upon completing the payment process”. All project proposers must obtain NPDES coverage electronically. The online application assures that all of the questions are completed and requires the user to certify that a SWPPP has been prepared for the project. MPCA is also proposing to omit the mandatory 30 day waiting period. For projects that require a SWPPP review before coverage is issued, the MPCA will grant coverage upon the completion of the application and payment process and after the MPCA has made a determination that the SWPPP meets all of the permit requirements. Stormwater Pollution Prevention Plan content The requirements for SWPPP content have been re-written and re-ordered for clarity.

SWPPP Amendments

In order to prevent contractors from deviating from the SWPPP and selecting inappropriate BMP option with no regard to the specific site conditions, the MPCA has added the following language regarding SWPPP amendments: “All SWPPP changes must be done by one of the individuals described in item 21.4 or item 21.5 or another qualified individual. Changes involving the use of a less stringent BMP must include a justification describing how the replacement BMP is effective for the site characteristics.”

Documentation when the volume control standard cannot be achieved

For those projects where the full volume reduction requirement cannot be met on site, (e.g., the site has infiltration prohibitions), the permittee must document the reasons in the SWPPP.

Documentation of infeasibility

For projects adjacent to surface waters, the current permit requires the preservation of a 50’ buffer unless infeasible. For projects adjacent to special waters or impaired waters, a 100' buffer zone must be preserved. The proposed permit requires permittees to document in the SWPPP why the buffer was not preserved.

Impaired waters and TMDL’s

This section was deleted. MPCA has made a programmatic decision not to include specific implementation activities or BMP’s in TMDL implementation plans for construction activity.

Permanent stormwater management

This section was deleted. The current permit offers permittees an option to follow a municipalities (or other plan approval authority such as a watershed district) stormwater ordinance in lieu of the permit requirements if that municipality is regulated by the state through the Municipal Separate Storm Sewer System (MS4) program. This provision was intended to reduce duplicate regulations as all regulated MS4 communities should have an ordinance in place that is at least as stringent as the state permit. However, MPCA’s determined many of the ordinances have not been written such that the requirements were at least as stringent as the state requirements and prevented the MPCA from taking any action if the permittees plans were approved by the municipality.

Permanent stormwater management

Projects that will result in a net increase in impervious surfaces of one acre or more must include plans for a permanent stormwater treatment system. Permittees are still expected to provide some type of volume reduction treatment if the site is conducive for stormwater infiltration. If the site is not conducive to stormwater infiltration (see item 16.14 through 16.22) other types of systems must be utilized such as a wet sedimentation basin. The permit will still offer flexibility for linear projects or projects where bedrock limits any type of stormwater management.

Infiltration prohibition

The proposed permit would prohibit infiltration systems constructed as part of the project regardless of whether or not the CSW permit requires stormwater management if the site receives runoff from vehicle fueling and maintenance areas. Infiltration requirement The current permit requires “appropriate on-site testing consistent with the recommendations found in the Minnesota Stormwater Manual to verify soil types…”. The manual recommends a certain number of on-site soil tests depending on the size of the system. The proposed permit specifically requires permittees to provide at least one soil boring, test pit or infiltrometer test in the area of each infiltration system for determining infiltration rates. The proposed permit allows field tested rates to be used with a safety factor of 2 or permittees may use the infiltration rate chart found in the Minnesota Stormwater Manual to determine design infiltration rates based on soil type.

Infiltration prohibition

The current permit prohibits constructing infiltration systems in areas with contaminated soil or groundwater. The current language states that infiltration is prohibited in: “areas where high levels of contaminants in soil or groundwater will be mobilized by the infiltrating stormwater.” The proposed permit includes additional language describing the steps permittees are expected to take to demonstrate compliance with this requirement. The proposed language is as follows: "Permittees are prohibited from constructing infiltration systems where high levels of contaminants in soil or groundwater may be mobilized by the infiltrating stormwater. Permittees must either complete the MPCA's site screening assessment checklist or conduct their own assessment to determine the suitability for infiltration. The assessment must be retained with the SWPPP. For more information and to access the MPCA's screening assessment tool see the Minnesota Stormwater Manual”.

Infiltration prohibitions for Drinking Water Supply Management Areas (DWSMA)

The current permit prohibits infiltration anywhere within a DWSMA. The proposed permit limits the prohibition to "within an Emergency Response Area (ERA) as defined by the Department of Health" and "areas within a Drinking Water Supply Management Area (DWSMA) as defined in Minn. R. 4720.5100, subp. 13, classified as having high or very high vulnerability, unless a regulated MS4 Permittee has performed a higher level of engineering review sufficient to provide a functioning treatment system and to prevent adverse impacts to groundwater."

Filtration systems

The following requirement has been added to the filtration system item: "The filter media must not be installed until the contributing drainage area has been constructed and fully stabilized unless rigorous erosion prevention and sediment controls (e.g., diversion berms) are provided to keep sediment and runoff completely away from the filtration area."

Wet sedimentation basin requirement

A new requirement was added to the proposed permit requiring an impermeable liner to be included in the design of a basin located in active karst terrain.

Ditch stabilization methods

The current permit specifically states that some less effective stabilization methods such as mulch cannot be used in ditches or swales for stabilization and permittees must rely on more robust practices such as erosion control blankets. The proposed permit allows permittees more flexibility for the type of stabilization chosen for a ditch bottom if the slope is less than 2%. Additionally, as with all BMP requirements in the permit, If the selected BMP is found to be inadequate at minimizing erosion from ditches or swales, another more effective BMP must be utilized.

Sediment controls near stockpiles

The proposed permit specifically states that perimeter controls are required near the base of stockpiles. This change in language better clarifies that stockpile perimeter controls are required in addition to the perimeter sediment controls required in item 9.2. This does not represent a change in MPCA policy regarding stockpile management.

50 foot buffer

The current permit requires redundant sediment controls around surface waters if a 50 foot natural buffer cannot be maintained. The proposed permit requires that the sediment control practices must be spaced at least 5 feet apart. The MPCA believes that proper spacing for sediment storage between the practices is necessary in order to function properly. Language was also included to relieve permittees of the spacing requirement if there are site constraints.

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

   

Construction SWPPP And Contractor SWPPP Training, Spill Training

Caltha LLP Project Summary

Project: Construction Stormwater Permitting, SWPPP & Contractor Training 
Client: National Home Builder
Location(s): Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training, Spill Control Plan

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 8-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, spill control plan and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.


 
SWPPP and SWPPP Training For Residential Site Construction

For more information on Caltha LLP construction stormwater services, go to the Caltha Storm water Permitting and Compliance Page

   

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

State Spill Plan, SPCC Plan, Contingency Plan Requirements

Caltha LLP maintains a library of SPCC Plan Templates developed to meet the above ground tank and spill prevention and response requirements of individual States and the Federal SPCC Rule. An SPCC Plan is require for any facility that exceeds an oil storage capacity of 1,320 gallons. Facilities potentially subject to the SPCC Rules (40 CFR 112) are not limited to industrial sites, but can include municipal, commercial, retail, institutional sites, construction sites, and even farms.

Leaking Fuel Tanks And Refueling Area 

Without Properly Sized Secondary Containment

The revised SPCC Rule now allows the use of streamlined SPCC plan formats if facilities meet certain criteria. These streamline SPCC Template plans do not need to be signed by a professional engineer in most States. Other SPCC plans may need to be reviewed and signed by an engineer. Caltha LLP also provides SPCC training for companies subject to the SPCC Rule and conducts SPCC inspections.

Caltha prepares SPCC Plans for the following States: [Click on a State to request information and options]

Alabama SPCC Plan

Alaska SPCC Plan
Arkansas SPCC Plan
California SPCC Plan
Connecticut SPCC Plan
Florida SPCC Plan
Georgia SPCC Plan
Illinois SPCC Plan
Indiana SPCC Plan
Iowa SPCC Plan
Kansas SPCC Plan
Kentucky SPCC Plan
Louisiana SPCC Plan
Maine SPCC Plan
Massachusetts SPCC Plan
Michigan SPCC Plan
Minnesota SPCC Plan
Mississippi SPCC Plan
Nebraska SPCC Plan
Nevada SPCC Plan
New Jersey SPCC Plan
New York SPCC Plan
North Carolina SPCC Plan
North Dakota SPCC Plan
Ohio SPCC Plan
Oklahoma SPCC Plan
Oregon SPCC Plan
Pennsylvania SPCC Plan
South Carolina SPCC Plan
South Dakota SPCC Plan
Tennessee SPCC Plan
Texas SPCC Plan
Utah SPCC Plan
Virginia SPCC Plan
Washington SPCC Plan
Wisconsin SPCC Plan

Large Development Site Permitting, SWPPP and Storm Water Training

Caltha LLP Project Summary

Project: Construction Permitting, SWPPP & Training
Client: National Home Builder
Location(s): Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 49-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.

Stormwater Controls And Waste Management 

At Construction Site

For more information on Caltha LLP services, go to the Caltha Contact Page

Annual Storm Water Training For Minnesota Permit

Caltha LLP Project Summary

Project: Annual SWPPP Training For Food Sector Facility
Client: Food Sector SIC 20 Facility
Location(s): Minnesota

Key Elements: Stormwater training, Permit compliance, Stormwater BMPs, Employee training

Overview: Caltha LLP was retained by this food manufacturing corporation to prepare and present annual SWPPP training, as required under the Minnesota Pollution Control Agency multisector general stormwater discharge permit. The training includes all required elements for employee training in the discharge permit:

• Overview of Discharge Permit
• Components and Goals of the SWPPP
• Stormwater Monitoring
• Monthly Facility Inspections
• Other Tasks Required By Permit

Training was presented to all affected employees by a qualified SWPPP trainer.For more information on Caltha LLP services, go to the Caltha Contact Page

Compliance With State Multi-sector Industrial General Permit | Seminar Module

The link below provides training slides from a training module on basic compliance strategies to address general permit requirements. The emphasis of the training module is to provide photograph examples of key areas which should be concerned in developing a site-specific SWPPP.

Presentation Slides: Complying with State Industrial Storm Water 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 info@calthacompany.com or Caltha LLP Website

How Were Stormwater Benchmark Values Developed? Historical Monitoring Data Compared To Industial Bench Marks

The following link provides a technical review of State Stormwater Benchmark values compared to historical industrial sector monitoring data.

Presentation Slides: Comparison of State Stormwater Benchmarks to Historical Industrial Sector Monitoring Results

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 info@calthacompany.com or Caltha LLP Website

List of Industrial Stormwater Training Providers in Minnesota | SWPPP Trainer

Caltha staff are stormwater experts, having worked with stormwater permitting and development of stormwater discharge permit compliance programs and SWPPP since the first stormwater rules were drafted in the 1980s. With this deep foundation in the stormwater rules, Caltha provides expert and cost effective storm water consultant services to clients across the US.


One of the key compliance elements is development of an Employee Training Program. Based on an individual employees job responsibilities, different level of training may be required, included training certification. Caltha provides stormwater training in a number of flexible formats, including “train the trainer”. Caltha also offers "real time" web-based training. Trainees log into a webinar format at their own work station and can interact with the trainer in real time. Training sessions are individualized for each facility.


For more information on options available for EH&S training and to request a quote, go to Caltha's Employer Environmental Health & Safety Training Center


Caltha also maintains a library of stormwater permit compliance plan templates to assist permitted sites in developing and managing their overall compliance program. Compliance plan templates incorporate State-specific requirements, such as inspections, monitoring, reporting and training, and provide an easy way to allocate resources and to develop a compliance tracking system. Caltha also conducts Non Stormwater Discharge Evaluations and provides Non Stormwater Discharge Certifications.


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
info@calthacompany.com or Caltha LLP Website

Industrial Stormwater SWPP and MPCA Permit Compliance Program Development For Transportation Facility

Caltha LLP Project Summary

Project: SWPPP and MPCA Permit Compliance Program For Transportation Facility
Client: Transportation Company
Location(s): Minnesota

Key Elements: MPCA industrial stormwater discharge permit compliance, SWPPP, Facility inspections, Storm water BMP

Overview: The national transportation company selected Caltha to conduct a facility assessment to determine if the operations could meet "No Exposure" requirements under the MPCA general industrial permit. Caltha prepared a list of corrective actions which would be required to comply with MPCA requirements and discussed potential costs with facility managers. Upon consideration of costs, facility management determined that applying for coverage under the Minnesota industrial permit was the preferred alternative. Caltha then prepared the storm water pollution prevention plan (SWPPP) using Caltha's SWPPP template designed to meet permit requirements. Caltha also prepared a permit compliance plan and site-specific inspection checklists to streamline on-going permit compliance tasks that the facility staff would be conducting.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

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
info@calthacompany.com or Caltha LLP Website

Technical Consultant Support To Address Stormwater Benchmark Exceedance for TSS, Iron, Zinc, Aluminum

Caltha LLP Project Summary

Project: Consulting Support To Address Stormwater Benchmark Exceedance
Client: Manufacturer
Location(s): Minnesota

Key Elements: Stormwater monitoring; MPCA stormwater permit compliance; Industrial storm water BMPs

Overview: This manufacture retained Caltha to provide technical support and guidance in addressing exceedance of MPCA industrial storm water benchmark concentrations. Monitoring data collected in Permit Cycle Year 2 exceeded limits for total suspended solids (TSS), zinc, iron and aluminum. Caltha staff reviewed past data, monitoring procedures and conducted a site inspection to determine root causes for the exceedance as part of a formal corrective action process. Based on recommendations, the facility began implementation of revised stormwater controls and began preparations for subsequent year 4 monitoring activities.

For more information on Caltha LLP services, go to the Caltha Contact Page

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
info@calthacompany.com or Caltha LLP Website

Response To Notice Of Violation For Industrial Stormwater Discharges and Non-Storm Water Discharge

Caltha LLP Project Summary

Project: Response To MPCA NOV For Industrial Stormwater Discharges and Non-Storm Water Discharge
Client: Transportation Sector
Location(s): Minnesota

Key Elements: Compliance with No Exposure Certification, Compliance with prohibition of unauthorized non storm water discharge

Overview: In a routine compliance inspection of industrial sites which had submitted no exposure certifications (NEC) being conducted by the State, this facility was found to be in non-compliance with both the conditions of the NEC and was also found to be discharging wash water without a permit. The facility was placed in enforcement action to resolve these issues. Caltha LLP was retained by the facility to assist them in evaluating requirements to meet the NEC and to identify options for addressing unpermitted discharge. Working with facility management, it was determined that costs for necessary corrective actions to comply with the NEC were too high compared to costs to obtain and comply with an industrial stormwater discharge permit. The facility terminated its NEC and applied for permit coverage. Caltha assisted the facility in preparing a facility SWPPP using our Minnesota SWPPP template and a permit compliance plan. Alternate off-site facilities were found to eliminate the discharge of unauthorized wastewater releases from the facility.

For more information on Caltha LLP services, go to the Caltha Contact Page

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
info@calthacompany.com or Caltha LLP Website

New or Expanded Stormwater Discharges Under Proposed MPCA Nondegradation Policy

The Minnesota Pollution Control Agency (MPCA) has been attempting to revise the Minnesota Nondegradation Policy for several years. One major issue has been how rule will apply to stormwater discharges, because the existing policy was developed to apply to traditional point source discharges.

In September 2012, MPCA released its proposed revision to the State Nondegradation Policy. Under the proposed rule, MPCA will address future nondegradation requirements for stormwater discharges as new permits are issued. For new, reissued, or modified stormwater permits, agency will conduct nondegradation review. This review will include an analysis of prudent and feasible alternatives that avoid and minimize net increases in loading or other causes of degradation. The agency will then select the least degrading prudent and feasible alternatives identified. Therefore, with the final revision of the Nondegradation Policy, as currently proposed, the requirements for new or expanded stormwater discharges will not be clarified. These requirements will be incorporated into various permits (e.g, industrial, construction, MS4) issued in the future.

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 info@calthacompany.com or Caltha LLP Website

Industrial Storm Water Training Seminar - Eagan, MN Nov. 30, 2012

Complying with Minnesota Industrial Stormwater Requirements
Eagan, MN
Friday, November 30, 2012

This full day training seminar will cover the requirements of the Minnesota Pollution Control Agency (MPCA) Multi-Sector General Permit (MSGP) for industrial storm water discharges. The course will begin with a discussion of the regulation of stormwater discharge under the Federal Clean Water Act, and then the specific requirements under the MPCA industrial permit, issued in 2010. This will include sector specific requirements, use of benchmark monitoring, effluent guideline monitoring and corrective action requirements. The morning session will include a discussion of additional requirements for stormwater discharges to impaired waters and other special waters identified in the MSGP.

The afternoon session will focus on implementing best managemt practices and development of a stormwater pollution prevention plan (SWPPP) at individual facilities. This will include a discussion of monitoring and reported requirements to comply with the Minnesota MSGP.

For more information or to register, go to:
Training Seminar - Complying with Minnesota Industrial Stormwater Requirements, November 30, 2012

Agenda

Industrial Stormwater Laws and Regulations

• Federal Clean Water Act overview
• Application of Clean Water Act to stormwater discharges

Minnesota industrial stormwater permitting process

• Overview of permit requirements
• Industrial sector-specific requirements
• Benchmark monitoring/effluent monitoring
• Corrective action triggers

Application of Rules/Permit to Individual Facilities

• Impaired waters/TMDLs
• Nondegradation/antidegradation requirements
• Special waters
• Wetlands
• Industrial sites with potential soil/groundwater contaminants
• Local and regional requirements

Creating Stormwater Pollution Prevention Plan (SWPPP)

• Complying with stormwater control measure requirements
• Describing facility
• Providing assessment of activities and materials
• Modification and reporting requirements
• Availability requirements
• Construction site runoff control

Implementing Best Management Practices (BMPs)

• BMPs to achieve “no exposure”
• Stormwater reduction
• Reuse of stormwater
• Stormwater control/management
• Structural BMPs for treating stormwater
• Contingency planning for extreme weather

Sampling and Annual Reporting

• Setting up monitoring procedures
• Collecting and evaluating samples
• Submitting annual reports
• Modifying BMPs

Revised Small MS4 General Permit Released By MPCA

The Minnesota Pollution Control Agency (MPCA) intends to issue the National Pollutant Discharge Elimination System (NPDES) State Disposal System (SDS) General Permit (MNR040000) for discharges of stormwater associated with small Municipal Separate Storm Sewer Systems (MS4s). MPCA will host a public information meeting to discuss the draft MS4 General Permit on June 21, 2012, at the MPCA St. Paul office. MPCA also intends to establish an e-mail list for the purpose of providing notification to persons interested in receiving notice of the public notice dates for the Stormwater Pollution Prevention Program (SWPPP) documents submitted pursuant to the MS4 General Permit. The draft permit is open for public comment from May 21 - July 23, 2012. The MPCA is requesting written comments on the draft permit.
This MS4 General Permit was issued first in 2006 to address new federal Phase II National Pollutant Discharge Elimination System (NPDES) stormwater regulations for small MS4s. These federal rules identified an iterative process for improved stormwater management where MS4 programs are strengthened with each five year permit cycle. This current permit reissuance effort shifts from the initial focus on permit program development to measuring program implementation. The next MS4 General Permit reissuance in 2017 will need to comply with the new federal NPDES stormwater rules expected to be final in December 2012.

Caltha LLP provides expert consulting services to public and private sector clients in MInnesota and nationwide to address Stormwater Permitting and Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

MPCA Reports Low Compliance Rates With New Industrial Stormwater Permit

In 2010, the Minnesota Pollution Control Agency (MPCA) finalized a new industrial stormwater discharge general permit. The new permit had numerous new requirements that facilities are required to meet. One of the most significant changes was that facilities are now required to collect samples of their stormwater discharge, send the samples to a laboratory for testing, and to report the results to MPCA on a Stormwater Monitoring Report Form (SWMR).

[Read a summary of MPCA industrial stormwater monitoring requirements]

[Read a summary of the revised MPCA permit]

According to information now being circulated by MPCA, as of November 2011, about 50% of all permitted facilities in Minnesota that are required to collect a sample and submit results had failed to do so. In addition, another 25% are missing results/data on a previously-submitted SWMR. In summary, according to MPCA, only about 25% of permitted facilities were in compliance with stormwater monitoring requirements of the general permit.

MPCA indicated that it is currently considering options it can take to improve compliance rates with industrial stormwater discharge permit.

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

info@calthacompany.com or Caltha LLP Website

Draft Minnesota Permit for Small Municipal Separate Storm Sewer Systems MS4s

The Minnesota Pollution Control Agency (MPCA) has released a draft the National Pollutant Discharge Elimination System (NPDES) State Disposal System (SDS) General Permit (MNR040000) for discharges of stormwater associated with small Municipal Separate Storm Sewer Systems (MS4s). The permit applies to any small MS4 in the State of Minnesota that is located within the boundaries of a Federal Bureau of Census-delineated “urbanized area” based on the latest decennial census pursuant to 40 Code of Federal Regulations § 122.26 or an MS4 designated by the MPCA for permit coverage under Minnesota Rules Chapter 7090.

Approximately 235 MS4s will be subject to the reissued NPDES/SDS General Permit. The permit requires MS4s to develop and implement a Stormwater Management Plan (SWMP) that is designed to reduce the discharge of pollutants from their storm sewer system and to protect water quality. The SWMPs must include Best Management Practices (BMPs) for six minimum control measures that are set forth in the NPDES Program regulations 40 Code of Federal Regulations § 122.34 (a) and (b). NPDES/SDS General Permit for Small Municipal Separate Storm Sewer Systems (or MS4s)

The draft general permit that MPCA proposes to reissue includes several modifications from the existing general permit, which expires on May 31, 2011. The MPCA has modified the existing NPDES/SDS General Permit to meet federal and state requirements for impaired waters and to address several main issues the MPCA identified as needing revision and/or clarification. The draft permit includes revised requirements for MS4 mapping, illicit discharge detection and elimination, construction stormwater erosion and sediment control, and post-construction stormwater management. The draft permit also includes new requirements for impaired waters covered by an EPA approved Total Maximum Daily Load (TMDL).

There are four formal opportunities for public participation in the MPCA’s consideration of the permit reissuance. Interested persons may (1) submit written comments on the draft permit; (2) request that the MPCA hold a public informational meeting; (3) request that the MPCA hold a contested case hearing; and (4) submit a petition to the Commissioner requesting that the MPCA Citizens’ Board consider the permit matter. The public comment period begins May 31, 2011 and ends on July 15, 2011.

Caltha LLP provides expert consulting services to public and private sector clients in Minnesota and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

MPCA Storm Water Benchmarks, Comparison To Historic Sector Monitoring Data

In 2010, the Minnesota Pollution Control Agency (MPCA) reissued the Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The reissued permit included significant changes to stormwater discharge requirements for permitted sites, which are now divided into 29 industrial sectors. One of the most significant changes was the requirement for sampling stormwater and reporting results to MPCA. Each sector has been assigned sector-specific stormwater benchmark concentrations. Beginning in June 2011, all sites permitted under the MSGP will have to collect stormwater samples and have samples analyzed for their sector-specific benchmark parameters. If one or more benchmarks are exceeded, sites will be required to upgrade their pollution prevention measures and will need to do further stormwater monitoring.

Since the 1980s, the U.S. Environmental Protection Agency (USEPA) has collected industry-sector data on stormwater discharge. The linked presentation provides a comparison of these historic industrial stormwater results to the current MPCA stormwater benchmark concentrations. The results are discussed in context of which stormwater benchmark parameters have a higher potential for exceedance of benchmark values. This presentation also discusses which of the industrial sectors have a higher potential for exceedance of their specific benchmark values.

Note: Because many States use the same benchmark concentrations used by Minnesota, this analysis and conclusions can be applied to most States.
Link to presentation slides:

Industrial Stormwater Benchmarks – Comparison of New Minnesota Benchmark Concentrations To Historic Industry-specific Testing Results
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
info@calthacompany.com or Caltha LLP Website

Stormwater Seminar in MN & ND Permiting and Design

Minnesota and North Dakota Stormwater Management Seminar
Fargo, North Dakota
Friday, November 19, 2010


Purpose:

• Examine federal, state, and local rules on stormwater management
• Review municipal, industrial and construction permits and the permitting process
• Explore green stormwater practices
• Examine site selection, sizing, and design
• Evaluate erosion and water quality

Agenda:

Understanding Federal and State Rules on Stormwater Management
Federal statutes and regulations, National Pollutant Discharge Elimination System (NPDES) requirements, State statutes and regulations, North Dakota Department of Health NDDH stormwater requirements, Minnesota Pollution Control Agency MPCA stormwater requirements, Local requirements and procedures, Storm water permits and permit application process, Special waters and impaired waters

Stormwater Management Using Wet and Dry Detention Facilities
Detention/retention pond overview, Advantages and disadvantages, Design considerations, Hydrology, Permitting, Site selection, Water quality, Pond sizing, Safety considerations, Outlet structures, Good design practices, Pond routing theory, Interconnected ponds, Steps for detention design

Stormwater Quality Best Management Practices
Bioretention and rain-leader disconnect raingardens, Cisterns, Permeable pavers/pervious concrete, Disconnecting impervious area/vegetated swales, Soil amendments, Rainwater harvesting, Green roofs

Bioretention Design and Maintenance
Costs and consequences of poor design, Site evaluation, Cell configuration and soils, Siting, ponding depth, vegetation, Installation specifications, Maintenance program, Overview of maintenance activities, Costs, Case Study: City of Plymouth, Minnesota, residential raingarden and maintenance program

Download Seminar brochure

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 info@calthacompany.com or Caltha LLP Website

Minnesota South Dakota Stormwater Training Seminar

Stormwater Management
Sioux Falls, South Dakota
Tuesday, September 28, 2010


Purpose:

• Examine federal, state, and local rules on stormwater management
• Review municipal, industrial and construction permits and the permitting process
• Explore green stormwater practices
• Examine site selection, sizing, and design
• Evaluate erosion and water quality

Agenda:

Understanding Federal and State Rules on Stormwater Management
Federal statutes and regulations, National Pollutant Discharge Elimination System (NPDES) requirements, State statutes and regulations, South Dakota Department of Environment and Natural Resources, Minnesota Pollution Control Agency, Local requirements and procedures, Permits and permitting process, special waters and impaired waters

Stormwater Management Using Wet and Dry Detention Facilities
Detention/retention pond overview Advantages and disadvantages Steps for detention design, Hydrology, site selection, water quality, Pond sizing, safety considerations, outlet structures, Pond routing and interconnected ponds, emerging issues

Green Stormwater Practices
Bioretention basics What are others doing? (Twin Cities, Omaha, Kansas City, Denver), LEED Specific practices, Constructed wetland, vegetated swale, Vegetated filter strip, rain gardens, rain barrels, BioRetention, pervious/permeable pavement Sustainable landscaping, plant selection, grass selection, amenities to showcase site

Pond Maintenance Issues
Pond access & easement issues, Evaluating water quality, Sediment management, Vegetation management, Emerging pollutant problems, Pretreatment Issues

Download Seminar brochure

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 info@calthacompany.com or Caltha LLP Website

Minnesota Restrictions on Coal Tar-Based Sealants

In 2009, the Minnesota Legislature enacted a law restricting to use of coal tar-based asphalt sealants in Minnesota. The bill prohibited state agencies from purchasing undiluted coal tar-based sealant, and directed the Pollution Control Agency (MPCA) to study its environmental effects and develop management guidelines.

The 2009 legislation was contained in House File 1231. The main requirements outlined in the legislation are:

• Notify state and local government units
By January 15, 2010 the MPCA must notify state agencies and local governments of the potential for contamination of stormwater ponds and wetlands by coal tar-based sealants.
• Inventory stormwater ponds
The MPCA must complete a plan to inventory stormwater ponds in the state by January 15, 2010.
• Use by State agencies restricted as of July 1, 2010
State agencies may not purchase undiluted coal tar-based sealant after this date.
• Develop best management practices and develop model ordinance on use of sealants for local units of government (LUGs)
The MPCA must develop and make available best management practices that can avoid or mitigate environmental impacts of coal tar-based sealants.
• Develop grant process
MPCA will develop a process by July 2010 for awarding grants to LUGs for treatment of contaminated sediment.

By the next cycle of municipal stormwater permitting, beginning June 2011, all MS4 permittees will be required to comply by all provisions of the legislation.

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 info@calthacompany.com or Caltha LLP Website