Welcome to the Industrial Stormwater Program, September 2012 Newsletter! 

In this issue:

• Featured Article: Outdoor Stockpile Management: Get Ready for Fall and Winter!
• 2015 Permit Update
• Electronic Administrative Change Form
• University of Minnesota Industrial Stormwater Training
• Sampling Results
• Construction Activities at Facilities with the No Exposure Exclusion – Don’t Lose Your Certification Status!
• Silica Sand Update

Featured Article: Outdoor Stockpile Management: Get Ready for Fall and Winter!

Do you stockpile materials at your facility, or have questions about whether you do?  Some of the more common examples of material stockpiling include:

• Auto parts in salvage yards;
• Appliances at solid-waste facilities;
• Logs and lumber at sawmills, flooring mills or wood-preserving facilities;
• Corn, sugar beets or potatoes at food-processing or land-transportation and warehousing facilities;
• Sand or salt for road de-icing at government or transportation facilities;
• Topsoil/soil/gravel from excavations at sand and gravel facilities; and,
• Coal from steam-generating facilities

If your facility stockpiles these or similar raw materials, proper management and implementation of BMPs is necessary to prevent  stormwater from washing across the exposed stockpile, becoming contaminated and carrying particulates and contamination off the facility property.

Some of the easiest BMPs to implement can be the most effective in managing any type of raw material stockpile:

• Impermeable berms or channels located ‘upstream’ to route surface flows away from the stockpiled material;
  
• Berming the stockpile on all sides with a ramp for truck and equipment access;
  
• Curbing along the perimeter of the area to prevent the run-on of uncontaminated stormwater from adjacent areas as well as runoff of stormwater from the stockpile areas;
  
• Covering small stockpiles at all times when work with the stockpiles is not occurring;
  
• If the stockpiles are so large that they cannot feasibly be covered and contained, implement erosion control practices at the perimeter of your site and at any catch basins to prevent erosion of the stockpiled material off-site

Sample BMPs for managing salt storage:     

• Place an impervious pad under salt storage and work areas  and cover the salt piles
• Sweep up any salt that is tracked out of the salt-storage area;
• For cold weather activities, manually clear sidewalks, driveways and parking lots prior to applying a   de-icer; this activity may reduce or eliminate the need for de-icing products;

If you will be stockpiling materials only for a very short duration of time (< 30 days), temporary BMPs may be appropriate:

• Tarps
• Silt fence filters installed around the perimeter of stockpiles

Note: These temporary measures are not substitutes for adequate long-term coverage.

2015 Permit Update

Though there are no major updates to report for the 2015 Industrial Stormwater Multi-Sector General Permit (see the June 2013 newsletter article for the latest information), here are some developments related to guidance and forms:

• Stormwater Monitoring Report forms:  We expect to offer electronic reporting (though this likely won’t happen before 2015). 
• Application:  We are encouraging permittees to apply electronically; this process will provide a faster turnaround for permit coverage. We are adding commonly-asked questions and examples for permittees applying for the No Exposure exclusion in order to clarify exposure sources that actually occur at existing facilities.
• Administrative Change Form: We are evaluating whether this form may used only for truly administrative changes such as facility name and contact information.  Technical/non-administrative changes may require a new application, such as adding/removing SIC codes, adding/removing monitoring locations (stay tuned; this is still being discussed).
• Sampling Manual: We want to clarify requirements for holding times, temperatures, instructions on what to do if a sample jar breaks after sample is collected and before it is sent to the lab (and it stops raining).

 If there are other guidance/form changes you would like to have us consider, please contact Melissa Wenzel or call: 651-757-2816.  We would like to hear from you and learn what it could take to make compliance with the Industrial Stormwater Multi-Sector General Permit easier!

Electronic Administrative Change Form

IMPORTANT! Use the Administrative Change form when your facility has a contact change, a monitoring location change or has new industrial activities. Find this form here Administrative Change Form.  Take time now to review your “Facility Details/Virtual Permit Information” page of the Industrial Stormwater Permit Information Access page to make sure your permit application information is up to date. If not, fill out the administrative change form today.

NEW!  The administrative change form may now be submitted electronically!  Just like the 2012 Annual Report for permittees, the administrative change form is a fill-inable PDF document with a “Submit” button at the end.  If the “Submit” button doesn’t respond (which is usually related to the permittee’s computer firewall settings), follow the form’s instructions to save and email the document to the program.

Because the Industrial Stormwater Program communicates via email, up-to-date facility site contact and email address information is very important.  Critical messages (annual report mailings, “time to re-apply for permit coverage” messages) will still be sent via the U.S. postal service in addition to email.

University of Minnesota Industrial Stormwater Training

The University of Minnesota continues to offer Industrial Stormwater workshops for permittees, those certified for the No Exposure exclusion and interested others.

Upcoming workshops:

• September 10, 2013- half day ISW4201 "response to exceedances" class (Duluth, in response to requests from facility staff in the northern part of the state )
  
• November 18, 2013- half day ISW4201"response to exceedances" class (Metro)
  
• March 4, 2014- full day ISW2202 "everything" class (Prior Lake – MECA conference, which gives permittees a greater chance to learn from others in the industry and network with exhibitors, vendors and others experienced with stormwater management and control measures).
  
• April 9, 2014 - half day ISW5001 "Managing TSS exceedances" - placeholder (Metro)

Seventy percent of permittees have finished with “Year 2” sampling requirements and now must conduct “Year 4” sampling requirements.

That’s why the popular “response to exceedances” workshops are expected to fill up fast. 

The “everything” workshops are for those staff new to Industrial Stormwater  permit requirements; it covers everything from SWPPP development, how to collect a sample and what to do if there are exceedances (hint: what to do right to hopefully avoid sampling exceedances portion of the workshop). 

For more information or to register for these workshops, download the registration brochure.

Sampling Results

Industrial Stormwater program staff have been reviewing sampling data averages three different ways:  per pollutant, per sub-sector and per permittee. 

Results, per pollutant:  Generally speaking, the state-wide pollutant averages of sampling results are good and fairly similar, especially based on the number of samples received for the averaged results:

The one exception was for iron.  Averaged results for all industries through December 2012 were 15.38 mg/L and had risen to 33.67 mg/L through June 2013.

That’s why program staff are looking more closely at subsectors and permittees; we want to determine what caused the iron average to more than double. 

We will communicate with facilities with high iron values (facility averaged results of 10 mg/L or higher which is 10 times the benchmark value) to determine whether the iron numbers were reported correctly, and, if they were, to remind these facilities to consider different Best Management Practices as required in the permit. 

The message will also include a reminder to get ready for “Year 4” sampling requirements. 

Important reminder about lab reporting:  All permittees should double-check the accuracy of reported sampling results.  All values except pH should be reported in mg/L. It’s critical to know that many labs report in ug/L (micrograms, or 1000 times smaller than mg/L).  For example, if a permittee reported 767 mg/L for iron but the lab result really was 767ug/L, the actual value is under the benchmark value of 1 mg/L instead of 767 times over it!  Reporting correctly can obviously make a huge difference.

What to do:  If you determine you reported your results incorrectly, 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.

If your sampling results are high and correct, look at Step 12 of the Industrial Stormwater Steps to Compliance.  Also, review EPA’s sector-specific fact sheets.  The documents sort by pollutant and activity and offer BMP suggestions for those pollutants and activities.  Check out Parts 6 and 7 of the Industrial Stormwater Best Management Practices Guidebook for non-structural and structural BMP ideas. 

Construction Activities at Facilities with the No Exposure Exclusion – Don’t Lose Your Certification Status!

Is your facility certified for the ISW No Exposure exclusion and are you planning a construction activity on your property?   If so, don’t let the construction activity negate your No Exposure Certification. 

How your No Exposure Exclusion is impacted depends upon the size of your construction project.  Construction activities generally fall into two different categories, disturbing land < 1 acre in size and disturbing land >= 1 acre in size.  Here are some tips for staying in compliance during your construction project. 

Construction projects <1 acre:  If you are a facility certified for a No Exposure exclusion and are planning this size construction project, you fall into an unregulated category. The MPCA will continue to help you on a case-by-case basis to determine which construction stormwater BMPs you can implement to reduce the discharge of pollutants from your facility. Current EPA guidance allows the consideration of temporary shelters during facility renovation or construction and we will work with you to determine whether your chosen temporary covers will meet the No Exposure exclusion requirements. 

Construction projects >=1 acre:  If you are a facility certified for a No Exposure exclusion with this size construction project, you are required to apply for the Construction Stormwater General Permit for that land disturbance activity. You must apply seven days prior to the beginning of your construction project. Details and additional information can be found at the Construction Stormwater General Permit page http://www.pca.state.mn.us/y3dqf96 and in MN Rules Chapter 7090.3060, 7090.2010 and 7090.3010.

For the upcoming 2015 Industrial Stormwater General permit reissuance, the MPCA intends to develop guidance to address temporary construction activities by facilities with the No Exposure exclusion certification.

Silica Sand Update

During the past 18 months, the MPCA has worked with the public, local government units, industry and state agencies to better understand the industrial sand industry.  We want to ensure adequate regulation of air and water discharges from these facilities in order to protect human health and improve the environment.

One critical partner in this effort is the Minnesota Department of Health. Its staff develop health-based rules and guidance so MPCA air quality monitoring staff can evaluate potential human health risks from exposures to chemicals in ambient air. MDH recently developed a health- based value of 3 micrograms/ cubic meter for crystalline silica in ambient air; MPCA staff will compare ambient air quality at facilities with this health-risk threshold.

Additionally, MPCA water quality permitting staff are currently formulating a specific chemical additive approval strategy for permittees who request the use of flocculants at their facilities.

Finally, the Environmental Quality Board is currently requesting comments for possible amendments to rules governing the Environmental Review Program for silica sand mining and processing facilities. See the following link for more detail. http://www.eqb.state.mn.us/documents/EQB%20Silica%20Sand%20-%20RFC-R04196.pdf

Regarding stormwater issues at industrial sand facilities, these facilities face challenges that construction sand and gravel operations and other aggregate mining facilities have faced for many years: limiting the mobility and discharge of total suspended solids (TSS) from their facility.

In Minnesota, there are more than 306 waterbodies that are impaired for turbidity. Although turbidity and TSS are not one in the same, the MPCA notes that there is a correlation between the two. Additionally, MPCA staff are currently working on a water quality standard for TSS.

Permittees should investigate the options below to help mitigate stormwater discharges with high TSS concentrations:

1. Stormwater Pollution Prevention Plan. Ensure the facility’s SWPPP is up to date and accurate. Mineral mining and dressing facilities are often expanding and stockpiling/ storing product in numerous areas; ensure your facility’s SWPPP reflects the conditions at your site.
2. Documented Inspections. Ensure the facility staff are performing the necessary inspections. Inspections  document site conditions and help determine the effectiveness of best management practices utilized.
3. Good Housekeeping and Eliminating or Reducing Exposure. Areas that may contribute TSS to stormwater shall be kept orderly to reduce or eliminate contaminated stormwater runoff. Evaluate materials management practices to determine if and how exposure of significant materials to stormwater runoff can be reduced or eliminated.

Program Contact Information:

• Industrial Stormwater Program Website
• Industrial Stormwater Monitoring (SWMR) Forms/Permit Information Access
  
• 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 or Mary West, 651-757-2818
  
• Engineering Questions: Todd Smith, 651-757-2732