Industrial Stormwater News: March 2012

Minnesota Pollution Control Agency sent this bulletin at 03/05/2012 01:00 PM CST

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Welcome to the Industrial Stormwater Program, March 2012 Newsletter!

In this issue:

Featured Article: The latest on sampling
New permit documents and guidance
Calendar of events & due dates
Wastewater corner/update
Have you certified for the No Exposure exclusion? Are you sure you are in compliance?
Minnesota Technical Assistance Program: free assistance available for permittees
Notes from the compliance & enforcement desk
Welcome new inspectors!

Featured article: The latest on sampling

If two samples are required, two Stormwater Monitoring Reports are required

Given the statewide drought, it’s not unexpected to have 55 percent of permittees submitting Stormwater Monitoring Reports with a “No Flow” record.

If you’re reporting “No Flow” for a monitoring interval:

Submit a SWMR for the monitoring period for which you were unable to collect a sample. Provide an explanation in the "If NO flow occurred during monitoring period, explain why" box and mail the form to the MPCA.
Collect two samples during the next sampling interval. Samples may be taken at any time during an interval, except that sampling events have to be at least 72 hours apart.
Two SMWRs are required to be submitted during the “substitute sample interval” even if you are unable to collect two samples during that interval.
If you are unable to collect any samples, or only able to collect one sample when two are required, the “substitute sample” carries forward to the next interval.

If you are unable to collect samples for more than one interval, the permit requires a maximum of 2 required samples in any interval.

Tip: A snowmelt or winter/spring thaw event can count as a "measurable runoff event."

Data reporting: double-checking your work

Industrial Stormwater Program staff have noticed that permittees’ reported sampling data may not be correct. Please make sure you are reporting the correct values from lab analysis documents. Some testing laboratories may not provide results in mg/l (milligrams per liter). If the data you receive from your testing lab is not using mg/l, you must correctly convert the numbers.

To see the results that have been entered for your facility:

Go to the Industrial Stormwater Permit Information Access page.
Type in the facility’s Permit ID number or facility name. Click on the "search" button.
Once the results have loaded, click on that ID number in the lower left to view the "Facility Information Menu."

Click on the “Monitoring Results” link. If the results are what you reported, do nothing.

If the values within the “Monitoring Results” link are incorrect, then submit an amended Stormwater Monitoring Report to the agency. The amended report should contain the missing or corrected data along with a cover letter explaining the circumstances of the incomplete or incorrect report.

New Permit Documents and Guidance

Now Available: Industrial Stormwater Sampling FAQ: You’ve asked and we’re answering – industrial stormwater program staff have created the “Stormwater Sampling Frequently Asked Questions” guidance document. It contains the questions and answers to the top 13 most frequently asked questions by permittees and consultants.

2011 Annual Report: All permittees should have received the 2011 Annual Report in the mail. Please fill out and mail it to the address on the form by March 31. Copies are also available online.

FUTURE - 2012 Annual Report: The 2012 Annual Report will be available ONLY electronically and will not be mailed out. You will also be able to submit the 2012 Annual Report electronically, too!

2012 Industrial Stormwater Compliance Calendar: Download your copy of the 2012 Compliance Calendar today!

Calendar of events/due dates:

March 8-9, 2012: Minnesota Erosion Control Association Conference
March 21-23, 2012:Wastewater Operations Conference
Middle of March 2012: Fee invoices mailed, due 30 days later
March 31, 2012: 2011 Annual Report Due
April 28, 2012: Automotive Recyclers of MN Meeting
June 5, 2012: next U of M “How to collect a sample/submit results” training. For more information or to register, download the registration form.
Late June 2012 (tentative): U of M “I exceeded my benchmark values, now what?” training

For more information or registration of U of M workshops, or if your company/organization would like to host or offer training or can offer space for future trainings, please contact the Erosion and Stormwater Management Certification Program.

Wastewater corner/update

The Nonmetallic Mining and Associated Activities permit (formerly called the “General Permit for Construction Sand and Gravel, Aggregate and Hot Mix Asphalt Facilities” or “MNG49 Permit”) was recently updated, and now includes some types of concrete-related activities. If you have coverage under both the Nonmetallic Mining Permit and Industrial Stormwater Multi-Sector General Permit and would like to see if you can have all activities covered within the Nonmetallic Mining Permit, please see the program webpage. For more information or assistance with the permitting for Nonmetallic Mining and Associated Activities facilities, call Theresa Haugen at 218-316-3920.

Have you certified for No Exposure? Are you sure you are in compliance?

Fifty-seven percent of all Industrial Stormwater Multi-Sector General Permit applicants have certified for the No Exposure exclusion. Recent MPCA staff inspections at several facilities that had certified for the No Exposure exclusion were found to have industrial stormwater exposure. This violates the permit’s No Exposure requirements and these facilities are out of compliance.

Here are nine of the most common violations found during inspections at facilities that had certified for No Exposure:

Open/unplugged dumpsters: These containers can leak out “garbage juice” when stormwater gets in them.
Storing significant materials outdoors: These materials include corrodible metals, used appliances, etc.
Activities being conducted outdoors: Examples include fueling of vehicles/equipment, loading/unloading of wastes, etc.
Dust/particulates: These facilities are operating under an air permit but have particulate matter or visible deposits of residuals on the ground.
Pollutants potentially mobilized by wind: Windblown raw materials can cause a condition of exposure. Materials sheltered from precipitation can still be deemed exposed if mobilized by wind.
Facilities with “partial” No Exposure: The No Exposure exclusion requires a facility to shelter 100 percent of its materials and activities.
Metal processing facilities: Examples include bins outside that are uncovered and contain scrap metal.
Trash compactors: Exposure occurs from hydraulic leaks, contents falling out of the compactor or during loading or unloading.
“Bag houses” or other particulate matter collection devices: Examples include situations when particulate matter exposure can occur.

If you determine that your facility CANNOT maintain the No Exposure exclusion and you do have sources of exposure with your activities and/or materials, you have two options to return to compliance:

1. Immediately move activities indoors or within storm-resistant shelters. If devices such as temporary tarps need to be utilized, you may use these temporarily (generally, less than 30 days) until the permanent shelters are in place.

2. If you unable to maintain No Exposure status immediately, you must apply permit coverage. You can apply online (or fill out the paper application) at: www.pca.state.mn.us/industrialstormwater.

Minnesota Technical Assistance Program: free assistance available for permittees

The Minnesota Technical Assistance Program (MnTAP) is available to help Industrial Stormwater facilities develop and implement industry-tailored solutions that prevent pollution at the source, maximize efficient use of resources and reduce energy use and costs to improve public health and the environment. MnTAP has a staff of 12 scientists and engineers who are here to help your business reduce waste, increase energy efficiency, and prevent pollution.

Industry sectors MnTAP works with:

Dry cleaning
Ethanol production
Fiber-reinforced plastics
Food processing
Healthcare
Iron mining
Laboratories
Machining and metal fabrication
Medical devices
Metal finishing
Metal casting
Painting and wood finishing
Pulp and paper mills
POTWs
Printing
Vehicle maintenance

For more information, visit: http://www.mntap.umn.edu or mntap@umn.edu or call them at: 612-624-1300 or 800-247-0015.

Notes from the compliance & enforcement desk

We have had a pretty busy season; this last past fall we began to receive our first benchmark monitoring data and our program staff were very busy entering this into our data systems. On a high level, we hope to use this data to help determine where problems at a facility might exist or where surface waters might be having stormwater impacts. This will ensure that we get the right kind of help to the facilities that need it the most. There will be some additional training on BMP options which may need to be installed or maintained. We are working with our partners and internal staff to help build these capacities for outreach. Facilities can check their monitoring data submitted in the Industrial Stormwater Permit Information Access on the web to quickly view one or several monitoring events and even see trends. They can also view how other facilities in their area or, in their sector, are doing as well. Of course, all this analysis and comparison only works when everybody submits their required monitoring data. We have sent reminders out to facilities that need to submit their benchmark monitoring data and have noticed that these reminders have helped get the word out and the data in (even if there was no flow, stormwater monitoring reports, SWMRs need to be submitted). Thanks to those who have complied! There will be many more facilities with SWMRs coming due soon, and with spring around the corner, and maybe even a winter melt; now is the time to plan to collect a sample. There is a lot of help available on the ISW website from how to download your SWMR, to viewing and printing your facility-specific monitoring calendar.

We will continue to remind non-complying sites of the need to follow their permit conditions and hopefully avoid any consequences for failing to do so.

~Ken Moon , Supervisor of the ISW Compliance and Enforcement Unit

Welcome new inspectors!

The industrial stormwater/wastewater unit welcomes three new inspectors:

Dave Bodovinitz, construction and industrial stormwater inspections, Rochester, david.bodovinitz@state.mn.us, 507/206-2654
Adam Gulsvig, industrial stormwater and wastewater inspections, Metro area, adam.gulsvig@state.mn.us, 651/757-2179
Craig Weingart, industrial stormwater & wastewater inspections, Rochester, craig.weingart@state.mn.us, 218/316-3921

Program Contact Information:

Website: www.pca.state.mn.us/industrialstormwater

Email the Program: iswprogram.pca@state.mn.us

Call the Stormwater Hotline: Call 651-757-2119 or 800-657-3804 (non-metro only) for questions related to Industrial, Construction and Municipal Stormwater.

Application questions/Administrative Lead: 651-757-2089

Permit Compliance/No Exposure: Melissa Wenzel, 651-757-2816

Engineering Questions: Todd Smith, 651-757-2732

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