Welcome to the Industrial Stormwater Program, December 2018 Newsletter! 

In this issue:

• Featured article: 2020 permit issuance update
• Fully online industrial stormwater training now available!
• U of M announces first training workshop of 2019
• Upcoming industrial stormwater compliance webinar
• More salt = more pollution
• National Pollution Prevention Conference: an update
• Stormwater Pollution Prevention Tips and suggestions

Featured article: 2020 permit issuance update

The 2020 permit developments are in full swing. Changes are being refined, new language is being drafted, and staff recently updated the reissuance timeline: November 2018 - mid-January 2019: Draft changes Mid-January – mid-February 2019: submit draft to EPA and MPCA legal staff for review. March 2019: Public notice draft permit April- May 2019: Review, respond to comments May 31, 2019: Finalize permit language June 30, 2019:  MPCA commissioner approval July 5 - October 5, 2019: Apply for coverage; all applicants must apply 180 days before the current permit expires April 5, 2020: “New” permit is reissued and effective Change in format One of the biggest changes has nothing to do with any changes to permit requirements. MPCA has a new agency-wide database called Tempo, and this general permit must be completely re-formatted to “fit” that new database. The entire permit will have language inserted into table format, one row per requirement. To see an example of a before-and-after stormwater permit, compare our Construction Stormwater 2013 general permit to the newly issued 2018 general permit. Changes to permit requirements Staff continues to spend time on additional training requirements, vehicle tracking issues, and adding construction stormwater requirements to certain sectors (thus eliminating the need of a separate construction stormwater permit). Anti-degradation requirements are being thoroughly researched for possible changes. Also, additional salt management requirements are being considered for all permittees with salt storage onsite, outside. To keep up-to-date with the latest changes, visit the Industrial stormwater: Permit development and program history web page.

Fully online industrial stormwater training now available!

MN Industrial Stormwater staff are proud to present their first-ever fully online training module. This training course is meant to supplement formal training, but it’s great as a refresher, for new staff, or for anyone wanting an overview in between formal training sessions like the U of M workshops.

The online course covers:

1. Permit and rule history
2. Applicability
3. Permit or No Exposure?
4. Permit requirements
5. Sampling requirements
6. Guidance and training
7. Compliance and enforcement
8. 2020 permit issuance

The online training module takes approximately 1 hour to complete.

There is no charge for this online training module. Please follow along and fill out survey questions embedded in the training module so MPCA staff can learn how to make the training module better.

If you have any questions or feedback/suggestions, please contact melissa.wenzel@state.mn.us.

U of M announces first training workshop of 2019

The U of M is offering its first workshop of 2019. Their most popular workshop, the "permit overview" workshop, is scheduled for March 14, 2019. It will be held at the Best Western Plus White Bear Country Inn, White Bear Lake. Register today; this class will fill up soon!

IS2202 - Industrial Stormwater Regulations, SWPPPs, Sampling and Monitoring

The registration fee is $170 and the workshop will be from 8am to 4:30pm.

Topics include:

• Industrial Stormwater Regulatory history
• SWPPP requirements
• SWPPP implementation
• Stormwater monitoring, sampling and reporting requirements
• Annual reporting and fees
• Case studies
• Compliance & enforcement information

Visit the U of M Erosion and Stormwater Management Certification Program’s website for more information or to register.  Register online or view and fill out the paper registration form.

Upcoming industrial stormwater compliance webinar

Want to know how other facilities successfully comply with industrial stormwater permit requirements? Learn how MPCA staff has been able to engage with facilities to achieve positive outcomes. Join us for a webinar that will highlight the importance of regulatory interactions and how BMPs can be changed to have improved water quality results. Often, companies feel regulatory agencies are only out to get them, so presenters will give concrete examples of outreach and engagement, tools that are key to building the trust on both sides.

Wednesday, January 9, 2019, 12-1pm Central Time Zone

Register today for this free industrial stormwater webinar

More salt = more pollution

You might have read above that future general industrial stormwater permit will likely contain more salt management requirements. While salt helps to keep our roads, driveways, and sidewalks safe in the winter, it contains chloride, a water pollutant.

Salt pollutes. It takes only one teaspoon of road salt to pollute five gallons of water permanently. There is no easy way to remove the chloride, and at high concentrations, chloride can harm fish and plant life. Less is more when it comes to applying salt to our roads, driveways, and sidewalks.

Tips to minimize salt use:

• 15°F is too cold for salt. Most salts stop working at this temperature. Use sand instead for traction, but remember that sand does not melt ice. Use the reference table below to apply the correct product for the conditions.
• Shovel. The more snow and ice you remove manually, the less salt you will have to use and the more effective it can be. Whether you use a shovel, snow blower, snow plow, or ice scraper, get out there as early as you can and keep up with the storm. You may even decide that salt isn't needed.
• Slow down. Drive for the conditions and make sure to give plow drivers plenty of space to do their work.
• Be patient. Just because you don't see salt on the road doesn't mean it hasn't been applied. These products take time to work.
• More salt does not mean more melting. Use less than 4 pounds of salt per 1,000 square feet (an average parking space is about 150 square feet). One pound of salt is approximately a heaping 12-ounce coffee mug. Consider purchasing a hand-held spreader to help you apply a consistent amount.
• Sweep up extra. If salt or sand is visible on dry pavement, it is no longer doing any work and will be washed away. Use this salt or sand somewhere else or throw it away.
• Watch a video. This video, produced by the Mississippi River Watershed Management Organization, provides tips to homeowners about more environmentally friendly snow and ice removal: Improved Winter Maintenance: Good Choices for Clean Water

For more information, visit the MPCA’s “Snow removal: Do it better, cheaper and pollution-free” web page.

National Pollution Prevention Conference: an update

Earlier this year, industrial stormwater program staff received the following message from a Mapistry staff member: “Our team stumbled onto the Minnesota Pollution Control Agency's website and were blown away with what you guys are doing with Industrial stormwater!  We would love to have you speak at our national conference. We look for innovative and progressive approaches to stormwater management and think you'd fit in great.” It was a great honor for Melissa Wenzel to attend and present at this conference. In case you’re curious, Mapistry is a company that creates cloud-based compliance management for stormwater, SPCC, and hazardous materials to help facilities can capture, manage, and track all stages of the compliance lifecycle. The company focuses on preventing problems and seeking solutions when problems arise, just like companies around the world. These are the same goals from the MPCA’s industrial stormwater program, which is why they were asked to present about their successes of working with facilities to achieve environmental compliance and prevent contaminated discharges going to surface waters and groundwater sources.

3M, Minnesota: Minnesota’s own Carie Mathison from 3M spoke about solutions to a potentially politically and financially costly issue. Sediment runoff from 3M and Kraft Foods was discharging to a nearby neighbor’s lake in another state. The companies worked together to solve the complex runoff issue. They navigated both organizations’ internal politics, procurement processes and priorities ‑- plus city and community concerns for a successful outcome.

Maryland state leaders: Staff from Maryland spoke about the evolving challenge of stormwater, but also how stormwater is a resource. Principles of green engineering for stormwater management goes back to the manufacturing process. Topics included prevention instead of treatments and customized BMPs, with customized plant species. They spoke about the consequences of BMPs; for example, when adding compost for plant material growth, it could release phosphorus when decomposing.

Waste hauling: A waste hauling company spoke about implementing infiltration at their vehicle maintenance location. They broke down their BMPS into 3 different categories:

• Basic: rumble strips, permeable pavement, curb cuts or drainage holes to allow parking lot runoff to go to landscaped areas.
• More structural: Cover fueling areas and industrial wash pads with berms, some have a drain that goes to sanitary sewer system or holding tank 
• Advanced: aboveground treatment systems can be used in the right situations/conditions.

What this company did: staff installed an underground infiltration device beneath a parking lot for trucking parking, washing, fueling, and maintenance. “It works great!” the speaker said. “If it’s installed right and maintained, that is. The stormwater practice better be designed right; once it’s underground, you can’t really do much afterward." Staff installed an inspection cover with storm chamber sediment trap. Lessons learned: preventative maintenance is everything. They do a lot of things aboveground to make sure pollution is prevented whenever possible, such as manual sweeping daily. They have a regular schedule for using a sweeper truck, 1-2 times a week, and clean their inset filter monthly. They clean the 3-stage clarifiers with a vacuum 2 times a year or more frequently, as needed. They clean the stormwater sumps once per year or more frequently, and conduct visual inspections of all of these BMPs at least monthly.

Tesla Manufacturing: A speaker from Tesla talked about how they managed metal exceedances at one of their manufacturing locations. At their San Joaquin Valley, California location, it rains 38 days of the year. Sampling revealed Iron and Aluminum exceedances. An assessment of their outdoor activities and materials showed uncovered containers, old equipment, and uncompleted landscaping. Sediment was determined to be the greatest contributor of metals, with discharges coming from their roof and unpaved areas. Telsa then rented a pavement sweeper, and used it DAILY! They increased their number of sampling events, including analysis of process-vents emissions and roof-location sampling. They conducted most of their visual inspections during rain events, and set up a routine cleaning schedule. A landscaping update included drought-resistant plants, a tree removal that was cracking pavement, and a new in-ground sprinkler system. Facility staff was taught NOT to apply pesticides to newly-planted plants (they were thinking they were weeds and trying to kill them!). Rusty bins were changed out for bins with covers, and booms were used when container is tilted. They changed loading procedures to not go above the top of the container. Also, they obtained close-able containers when possible. To avoid dispersing debris into that area, they signed and coned the sampling point. A cleaning and maintenance plan for storm drains quarterly was set up. How did the sampling results go?  SUCCESS!! Tesla met their benchmarks in one year after several quarters of exceedances! Keys to success? Engagement of management and employees. They have a “message of the day” to all staff that rotates between environmental and health. And finally, a “prevent pollution” email goes out before every rain event to keep the new policies top of mind.

EPA inspectors: EPA compliance & enforcement staff spoke about the inspection process and results from their perspective. During an EPA inspection, facilities can expect the following topics to be reviewed: SWPPPs up-to-date & being used/useful, choosing & implementing BMPs that are pollutant-specific, properly maintained and correctly installed. Recordkeeping: inspectors are looking for documentation on training, monitoring, and sampling. What happens when these details are requested and there’s no response from the facility? That’s the quickest way to get a re-inspection, EPA inspectors said.

Mapistry, online training: Finally, there was a session on online training courses. Speakers from Mapistry indicated that there are three types of learners: visual, auditory, kinesthetic (learning by doing, touching, practicing, and rehearsing). One of the initial goals to a successful online training is to engage the adult learner, getting buy-in on the values that the instructor is trying to teach. Online training is more like “micro-learning,” providing “digestible” information at a self-paced learning approach. It’s recommended to obtain stories from regulated parties to imbed their perspectives; it may add to a more enriched experience. There are more indirect savings if facilities create online training courses for their staff: fewer fines, lower liability, and higher productivity. A question was asked after viewing a demonstration of Mapistry’s online training course: “have you thought about marketing these training sessions to trade associations, for their members?” Mapistry is curious to know if any MN trade associations would be interested in this option.

For more information about Mapistry or their annual Pollution Prevention summit, visit Mapistry’s website.

Stormwater Pollution Prevention Tips and suggestions

Is your Stormwater Pollution Plan (SWPPP) is up-to-date? Do you review it annually? Do you even know where your SWPPP is? Every permittee is required to create and update their SWPPP as needed, and must be reviewed at least once a year. When inspectors are at a facility, they see that some facility’s SWPPPs have outdated contacts, no documented training information, and spotty monthly visual inspection documentation.

To be sure that your SWPPP is complete and up-to-date, check out this SWPPP blog written by MPCA industrial stormwater staff.

Minnesota Technical Assistance Program (MnTAP) intern program: have experts and interns tackle your waste and energy projects!

Your business or facility may be able to address waste reduction and energy efficiency projects sooner and faster with the help of a MnTAP intern. An intern can make suggestions that improve efficiency, save money, reduce waste, or decrease regulatory compliance burden. Also, an intern has the time and creativity to research alternative equipment, procedures, chemicals, and raw materials. As with all of MnTAP’s projects, all proprietary information at your facility is kept confidential during and after the intern project. Additionally, you will benefit from: A new set of eyes looking at your waste or energy project Your intern being mentored and guided by a MnTAP engineer or scientist A full report and presentation detailing the intern’s work and next steps for your company MnTAP managing the recruiting, hiring, and training processTo qualify for the intern program, your facility must be: Located in Minnesota Committed to reducing or eliminating industrial waste (air emissions, water, energy, solid or hazardous waste) Willing to make operational or procedural improvements to accomplish a waste reduction or energy efficiency goal, such as substituting equipment or raw materials Able to develop a project idea that applies to other Minnesota businesses and facilities For more information or to apply to participate in the MnTAP intern program, visit the MnTAP intern project proposal page or contact Nathan Landwehr, MnTAP’s intern program administrator at 612-624-4697.

Program Contact Information:

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

Monitoring Forms/Permit Information Access: http://cf.pca.state.mn.us/water/stormwater/isw/search.cfm

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

Call the Stormwater Hotline: Call 651-757-2119 or 800-657-3804 (non-metro only) 

Permit Compliance/No Exposure:

• Melissa Wenzel, 651-757-2816
• Mary West, 651-757-2818
• Dave Bodovinitz, 507-206-2654
  

Engineering Questions: Brian Schweiss, 651-757-2709