SWPPP | Stormwater Pollution Prevention Plans | Stormwater Permits | Stormwater Training

Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits,multisector general permits, impaired waters requirements, water quality standards, SWPPP, Stormwater Pollution Prevention Plans, stormwater monitoring, stormwater training, SWPPP training, spill prevention and control, SPCC compliance, site inspections, reporting and recordkeeping

Saturday, April 4, 2009

Primary Metals - Foundry Sector - SWPPP - Stormwater Permit Proposed Requirements

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, 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]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Primary Metals Sector (Sector F). Sector F covers a fairly broad range of facility types, including steel works, blast furnaces, and rolling and finishing mills, iron and steel foundries, primary smelting and refining of nonferrous metals, secondary smelting and refining of nonferrous metals, rolling, drawing, and extruding of nonferrous metals, nonferrous foundries and other primary metal products These requirements are in addition to permit requirements that apply to all sectors.

Inspections:
The facility must conduct inspections addressing air pollution control equipment (e.g., baghouses, electrostatic precipitators, scrubbers, and cyclones) for any signs of degradation (e.g., leaks, corrosion, or improper operation) that could limit their efficiency and lead to excessive emissions. The operation must monitor air flow at inlets and outlets (or use equivalent measures) to check for leaks (e.g., particulate deposition) or blockage in ducts. Also inspect all process and material handling equipment (e.g., conveyors, cranes, and vehicles) for leaks, drips, or the potential loss of material.

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.

Good Housekeeping:
Good housekeeping practices must include a cleaning and maintenance program for all impervious areas of the facility where particulate matter, dust, or debris may accumulate, especially areas where material loading and unloading, storage, handling, and processing occur. The operation must also implement a cleaning program which includes regular sweeping for the paving of areas where vehicle traffic or material storage occur but where vegetative or other stabilization methods are not practicable. For unstabilized areas where sweeping is not practicable, the operation must select an alternative stormwater management devices that effectively trap or remove sediment.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on facility type:

Steel Works, Blast Furnaces, and Rolling and Finishing Mills (SIC 3312-3317):
TSS 100 mg/L
Total Aluminum 1.5 mg/L
Total Zinc 0.234 mg/L

Iron and Steel Foundries (SIC 3321-3325):
TSS 100 mg/L
Total Aluminum 1.5 mg/L
Total Iron 1.0 mg/L
Total Zinc 0.234 mg/L
Total Copper 0.028 mg/L

Rolling, Drawing, and Extruding of Nonferrous Metals (SIC 3351-3357):
TSS 100 mg/L
Total Zinc 0.234 mg/L
Total Copper 0.028 mg/L

Nonferrous Foundries(SIC 3363-3369):
TSS 100 mg/L
Total Zinc 0.234 mg/L
Total Copper 0.028 mg/L

Others:
TSS 100 mg/L

Note: Benchmarks for zinc, copper, aluminum, iron 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 proposed 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 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

Glass-Clay-Cement-Concrete-Gypsum Products Sector - SWPPP - Stormwater Permit Proposed Requirements

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, 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]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Glass, Clay, Cement, Concrete, and Gypsum Products Sector (Sector E). Sector E covers a fairly broad range of product types, including flat glass, glass containers, pressed and blown glass, hydraulic cement, structural clay products, pottery and related products, concrete, gypsum, and plaster products, glass products, cut stone and stone products, abrasives, asbestos products, and miscellaneous non metal mineral products, mineral wool and mineral wool insulation products, and non-clay refractories. These requirements are in addition to permit requirements that apply to all sectors.

Inspections:
The facility must conduct inspections of dust collection and containment systems.

Good Housekeeping:
The facility must prevent or minimize the discharge of spilled cement, aggregate (including sand or gravel), kiln dust, fly ash, or settled dust from paved portions of the facility that are exposed to stormwater. Each facility must determine the frequency of sweeping or equivalent by the amount of industrial activity occurring in the area and the frequency of exposure to stormwater, but it must be performed at least once a week, if cement, aggregate, kiln dust, fly ash, or settled dust are being handled or processed. The operation must also prevent the exposure of fine granular solids (cement, fly ash, kiln dust, etc.) to stormwater.

Preventative Maintenance:
For facilities producing ready-mix concrete, concrete block, brick, or similar products preventive measures must be implemented that ensure that process wastewater resulting from washing trucks, mixers, transport buckets, forms, or other equipment are discharged in accordance with a separate applicable NPDES permit..

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:

Clay Products Manufacturers (SIC 3251-3259, 3261-3269):
Total Aluminum 1.5 mg/L
TSS 100 mg/L

Concrete and Gypsum Product Manufacturers (SIC 3271-3275):
TSS 100 mg/L
Total Iron 1.0 mg/L

Cement Manufacturing Facility, Material Storage Runoff:
TSS 100 mg/L
pH 6 - 9

Others:
TSS 100 mg/L

Note: Benchmark for aluminum 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 proposed 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 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

Asphalt - Lubrication Products Sector - SWPPP - Stormwater Permit Proposed Requirements

Chemical Products Sector - SWPPP - Stormwater Permit Proposed Requirements

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, 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]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Chemical and Allied Products Manufacturing Sector (Sector C). Sector C covers a fairly broad range of product types, including industrial inorganic and organic chemicals, plastic materials and synthetic resins, synthetic rubbers and human-made fibers, soap and detergents, specialty cleaning, polishing, and sanitation preparations, surface active preparations, perfumes, cosmetics, paints, wood fillers and sealers, paint and varnish removers, adhesives, glues, caulking compounds, explosives, inks, fertilizers, pesticides, and other agricultural chemicals, medicinal and pharmaceutical chemicals. These requirements are in addition to permit requirements that apply to all sectors.

Inspections:
The facility must conduct two of the monthly inspections during runoff events. One of the inspections shall 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.

Potential Pollutant Sources:
The SWPPP must document describe the following potential pollutant sources: outdoor storage of salt, pallets, coal, drums, containers; access roads, rail cars, and tracks, areas where the transfer of substances in bulk occurs, and areas where machinery operates.

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:

Agricultural Chemicals (SIC 2873-2879):
COD 120 mg/L
TSS 100 mg/L
Total Zinc 0.234 mg/L
Total Lead 0.164 mg/L
Total Iron 1.0 mg/L
Phosphorus 1.0 mg/L

Industrial Inorganic Chemicals (SIC 2812-2819):
TSS 100 mg/L
Total Aluminum 1.5 mg/L
Total Iron 1.0 mg/L
Total Zinc 0.234 mg/L

Soaps, Detergents, Cosmetics, and Perfumes (SIC 2841-2844):
TSS 100 mg/L
Total Zinc 0.234 mg/L

Plastics, Synthetics, and Resins (SIC 2821- 2824):
TSS 100 mg/L
BOD 25 mg/L
Total Zinc 0.234 mg/L

All Others:
TSS 100 mg/L

Note: Benchmarks for zinc, copper, aluminum, iron, arsenic 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 proposed 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

Paper Products Sector - SWPPP - Stormwater Permit Proposed Requirements

Timber Products Sector - SWPPP - Stormwater Permit Proposed Requirements

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, 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]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Timber Products Sector (Sector A). Sector A covers a fairly broad range of facility types, including log storage or handling areas, mills, producing lumber and wood basic materials, wood preserving, manufacturing finished articles made entirely of wood or related materials, and manufacturing wood buildings or mobile homes. These requirements are in addition to permit requirements that apply to all sectors.

Inspections:
If the facility performs wood surface protection and preservation activities, inspections must include processing areas and treated wood storage areas to assess the effectiveness of practices to eliminate the deposit of treatment chemicals on unprotected soils and eliminate all contact with stormwater discharges. 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.

Industry-Specific Stormwater Controls:
The facility must have secondary containment for all significant materials stored indoor and outdoor, (e.g. arsenic, chromium, zinc, copper, and phenolic solution storage tanks and structures). Facility must also drain containment stormwater for outdoor storage tanks and structures only after inspection demonstrates that no stormwater contact with solutions has occurred.

Potential Pollutant Sources:
If the operation uses chlorophenolic, creosote, or chromium-copper-arsenic formulations for wood surface protection or preserving, the SWPPP must document 1) areas where contaminated soils, treatment equipment, and stored materials still remain, and 2) the management practices employed to minimize the contact of these materials with stormwater runoff.

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:

General Sawmills and Planing Mills (SIC 2421):
COD 120 mg/L
TSS 100 mg/L
Zinc 0.234 mg/L

Wood Preserving (SIC 2491):
TSS 100 mg/L
Total Arsenic 0.680 mg/L
Total Copper 0.028 mg/L
Total Chromium III 3.5 mg/L
Total Phenols 4.4 mg/L

Log Storage and Handling (SIC 2411):
TSS 100 mg/L

Wet Decking:
pH 6 - 9

Discharges at Log Storage and Handling Areas (SIC 2411):
TSS 100 mg/L

Hardwood Dimension and Flooring Mills and others:
TSS 100 mg/L
COD 120 mg/L

Nailed Wood Boxes and Shook (SIC 2441-2449):
TSS 100 mg/L

Note: Benchmarks for zinc, copper, chromium, phenols, arsenic 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 proposed 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

Friday, April 3, 2009

CT DEP Stormwater Target Values, Action Levels and Benchmarks

The Connecticut Department of Environmental Protection (“DEP”) has proposed to revise and renew its General Permit for the Discharge of Stormwater Associated with Industrial Activity. The previous General Permit was adopted in 2002, modified in 2003, and expired on September 30, 2007. It was extended on October 1, 2007 and October 1, 2008 through March 31, 2008 without change by DEP to provide ongoing coverage to approximately 1,500 registrants.

The 2002 permit required annual monitoring of stormwater discharges from qualifying storm events for an expansive list of chemical and physical parameters, including whole effluent toxicity, and a set of Target Values for the parameters based on the 80th percentile of the monitoring data collected in previous years.

In 2008, DEP announced that it would be revising the permit. It proposed to update its 80th percentile Target Values to reflect the monitoring data acquired since the prior permit was adopted in 2002. DER also proposed Action Levels at the 95th percentile of prior monitoring results which would require follow-up action by registrants to investigate the source of the exceedances and modify their BMPs and SWPPP.

On February 4, 2009, DEP issued a new proposed draft which adopts ten sectors modeled on the EPA “MSGP-2008” Multisector permit, with semi-annual monitoring. The previously proposed “Action Levels” have become “Benchmarks” to track the federal language. DEP’s proposal retains the broad spectrum of parameters to be included in the monitoring program, including toxicity, but makes some sector specific adjustments. The toxicity monitoring requirement carries with it no Benchmark. The draft also adds annual monitoring for parameters for which receiving waters have been designated impaired or subject to Total Maximum Daily Load restrictions.

The Benchmark values for copper, lead and zinc are based on Connecticut’s State Water Quality Standards. The Benchmarks for remaining parameters (pH, O&G, COD, TSS, TP, TKN, and NO3), are based on the 50th percentile of the previously acquired monitoring data.

DEP expects to go to notice on a new proposal in April 2009. In the meantime, the DEP has published notice that it intends to extend the 2002 General Permit once again until September 30, 2010.