Managing Industrial Stormw ater In Minnesota For Aggregate and Ready Mix Association of Minnesota Cindi Kahrmann MPCA Industrial Stormwater Program Coordinator 651-757-2481
What is Stormw ater? Stormw ater is site runoff or runon from: ● Rain ● Snow , sleet, hail ● Snow melt When contaminated with site materials, stormwater affects water quality 2
Who Must Apply for a Stormw ater Permit? ● Facilities with activities that fall into one of ten categories, most with specific SIC codes – these are organized into 30 sectors ● Examples from Aggregate & Ready Mix Industry Sectors • Sector J: Mineral mining and dressing • Sector D: Asphalt paving and complete list in roofing materials and lubricants application instructions • Sector E: Glass, clay, cement, concrete and gypsum products 3
Why Do We Care about Stormw ater? ● Processing the materials for these sectors may produce sediment that is easily transportable by stormwater and is then carried into rivers and lakes ● Some of these particles also become suspended in stormwater that is carried into rivers and lakes ● These particles accumulate and then affect fish spawning areas and food source habitat ● These particles also can transport other pollutants from small spills or from vehicles such as oil and grease or acid cleaning solutions 4
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Industrial Stormw ater Work Group ● Aggregate and Ready Mix Association ● Aggregate Industries ● Salvage yards ● Auto recyclers ● Electrical companies ● Mining ● Petroleum refining ● Manufacturing ● Minnesota Chamber of Commerce ● Government agencies (MNDOT, MAC) ● Cities that receive industrial stormwater ● Consultants ● Environmental Group ● MPCA staff, supervisor, manager 9
Industrial Stormw ater Multi-Sector General Permit Focus on sector specific requirements for stormwater management on a site through: ● Development of a Stormwater Pollution Prevention Plan ● Implementation of Best Management Practices ● Benchmark monitoring for stormwater discharges — this is new 10
What is Required? ● A Stormwater Pollution Prevention Plan (SWPPP) that includes Best Management Practices (BMPs) for managing industrial materials and activities ● Eliminating or reducing stormwater contact with potentially polluting materials and/or treating stormwater ● Monitoring stormwater discharges four times in first year, passing benchmarks within three years -- this is new 11
Sector Specific Requirements Each sector included in the permit would have specific requirements for: ● What pollutants to monitor for and how often ● Sector specific benchmarks to compare monitoring results against ● Some Best Management Practices may be specified ● Only a few sectors are expected to have effluent limitations ● If you have industrial activity in more than one sector, all requirements for those sectors apply 12
What is a Benchmark? This is New ● A benchmark is an action level to compare against the test result for monitoring ● Example: an industrial sector might be required by the permit to monitor for Total Suspended Solids (TSS) and might have a benchmark of 100 milligrams / liter TSS ● The average of four test results from a facility in the first year is 150 mg/liter TSS ● The facility would need to make management or structural BMP changes, and test again, intending to pass the benchmark by end of year three 13
EPA Model Permit ● The federal Environmental Protection Agency has a draft model permit ● The examples that follow are from the proposed requirements for Sector J, Mineral Mining and Dressing, in EPA’s draft permit ● MPCA is evaluating these requirements and has not yet determined how closely we will follow this in the Minnesota Multi- Sector General Permit 14
What’s Included in EPA Sector J ● Exploring for minerals (stone, sand, clay, chemical and fertilizer minerals, nonmetallic minerals), developing mines, and the mining of these materials ● Discharge of stormwater, not including mine drainage or process wastewater ● Dewatering composed entirely of stormwater or groundwater seepage from construction sand and gravel, industrial sand, and crushed stone mining 15
BMPs Required for EPA Sector J ● Combination of sediment and erosion control Best Management Practices (dikes, swales, curbs or berms, subsurface drains) ● Good Housekeeping: preventing litter, debris and chemicals from coming into contact with stormwater ● Slowing down speed of stormwater runoff ● Sites more than 1 acre: sediment basins or traps (silt fences, vegetated buffer strips) for down slope boundaries ● Temporary stabilization and permanent stabilization where activities have stopped 16
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Self-Inspections for EPA Sector J: ● At least once every 14 days and within 24 hours of the end of a storm event of 0.5 inches or more ● If the site is temporarily stabilized, and if runoff is unlikely because of winter conditions, then once per month instead ● Include all disturbed areas and areas used for storage, if exposed to stormwater ● Include discharge locations and vehicle access locations 19
Monitoring: EPA Sector J Benchmark Monitoring (4 times first year, repeat if cannot meet the benchmark) ● Total Suspended Solids (TSS) : 100 mg/l average of 4 samples taken once per quarter or at least 2 weeks apart) Effluent Limit Monitoring (once per year) SIC (1422-29, 1442, 1446) ● TSS 25 mg/l monthly average 45 mg/l daily max ● pH 6-9 20
If the Monitoring Results are Higher than Benchmark ● Inspect, manage, maintain BMPs ● If the average of the four samples within a year exceed the benchmark, then make changes to BMPs, document in the SWPPP, repeat the benchmark monitoring (4 samples taken once per quarter) ● If the benchmark is exceeded again, a Nondegradation Analysis Report must be submitted and possibly an individual permit will be required ● Exceedance of an effluent limit requires immediate corrective action and reporting 21
If Receiving Water is Listed as Impaired ● Monitoring for the pollutant of impairment is required each year ● If monitoring results exceed a benchmark, Nondegradation Report is not done but BMP management and monitoring continue until results are below the benchmark ● If a Total Maximum Daily Load (TMDL) has been completed, follow the TMDL if it requires more than the general permit 22
How Do I Obtain the Permit? ● Apply now, if you currently do not have coverage, and follow 2002 draft permit ● MPCA is currently drafting a revised permit and may be ready to receive comments on the permit in 2008 ● Apply for this revised permit when MPCA announces the permit is ready for applications ● No permit fee for applying; there will be a $400 annual fee, annual reports, inspections ● If your facility has an individual wastewater treatment permit, these stormwater conditions will be included there 23
What if I Have the MNG 490000 permit? ● MPCA is considering taking all of the Industrial Stormwater Multi-Sector General requirements for Sectors D, E, and J and combining them with MNG 490000 at a future date, possibly at the same time as the MSGP ● In the near term, MPCA may combine Sectors D and or J with MNG490000, and add Sector E later ● Until then, industries would need to follow the MSGP, when it is issued, for discharges that are not authorized by MNG 490000 24
Timeline ● Developing the permit, asking for input now through June ● Industrial Stormwater Multi Sector General Permit should be on public notice with a request for comments around June 2008 ● Resolution of comments and issuance of the permit should be by the end of 2008 25
What is No Exposure? All significant industrial materials and activities are protected from: • Rain • Snow • Snowmelt • Run-off by a storm resistant shelter 26
What Advantage is Achieving No Exposure? ● Conditional exclusion from the industrial stormwater permit ● No application fee, no annual fee, no annual reports ● Stormwater contamination is avoided ● MPCA recommends three inspections per year (must maintain condition of no exposure and apply every 5 years) ● MPCA recommends having, updating SWPPP 27
How Do I Obtain No Exposure Exclusion? ● All significant materials and industrial activity protected from stormwater by storm resistant shelter ● Submit the permit application and complete the No Exposure Certification Section every 5 years ● Submit a copy of the certification, upon request, to the municipality in which the facility is located 28
THANK YOU! Questions? General Cindi Kahrmann 651-296-7700 Technical, Sector Conditions Don Kriens 651-296-7734 29
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What Are Industrial Materials and Activities? MATERIALS ● Material and equipment handling ● Machinery ● Raw materials ● By-products ● Waste products ● Intermediate and final products ACTIVITIES ● Storage ● Loading and unloading ● Transportation 31
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