Welcome to the Industrial Stormwater Program, December 2013 Newsletter! 

In this issue:

• Featured article: 2015 Permit Reissuance Update
• Current Sampling Year Requirements
• Snow pile and snow melt management at industrial facilities
• ISW Benchmark Monitoring Results – How are We Doing?
• Hennepin County Industrial Stormwater Award
• Zinc Exceedances
• Coal Tar Sealants Update

Featured article: 2015 Permit Reissuance Update

The 2015 MPCA Industrial Stormwater Permit Reissuance Team has been hard at work drafting potential changes to the Industrial Stormwater Permit.  EPA announced their draft Multi-Sector General Permit and the MPCA Team has been comparing changes with the MPCA’s 2010 Permit and EPA’s draft 2013 Permit.  Based on reviewing sampling data, performing a comprehensive program overview, and reviewing the tentative changes to EPA’s Permit, the Team is proposing the following changes for the 2015 Permit Reissuance:

• Streamlining the sampling calendar:  We are phasing out unique sampling calendars to better serve Permittees and streamline our messaging. Your facility, along with all other current Permittees, will begin sampling on a concurrent, quarterly calendar that is based upon the new, concurrent permit application date. For example, the tentative permit application deadline is expected to fall between July-October 2014 (the current permit expires in April 2015). Permittees who apply between July and October 2014 would begin to conduct quarterly sampling starting July 1, 2015. This should simplify messaging and tracking versus constantly calculating each Permittee’s sampling calendar based upon their original permit application date.
• Requiring four samples before averaging: This proposed change would make Minnesota’s permit consistent with the EPA permit. It requires a minimum collection of four samples, during four separate quarters, before averages could be calculated and compared with the permit benchmark value(s).
• Quarterly sampling until results fall under benchmark values: Again, to maintain consistency with EPA’s permit and other MPCA water quality sampling requirements, it is proposed that Permittees with the four quarters’ averaged results falling above the benchmark value will be required to continue sampling quarterly until four quarters of averaged results are below the benchmark value.
• Sampling parameters:  Based on EPA’s suggested permit changes and Minnesota water quality standards, the draft permit requires a review and modification, if necessary, for monitoring of pollutant parameters and benchmark values.
• “Technical” (non-administrative) changes require a new monitoring calendar: Any change to a facility’s application that is not truly administrative in nature, such as changing a SIC code/Narrative Activity, monitoring location, or discharge to water body, will trigger a permittee’s monitoring calendar to “start over” for all monitoring locations and all pollutant parameters, beginning the next calendar quarter.
• Limitations on infiltration:  The construction of a new infiltration device is prohibited in:

1. Areas that receive discharges from vehicle fueling and maintenance activity.
2. Areas with less than three (3) feet of separation distance from the bottom of the infiltration device to the elevation of the seasonally saturated soils or the top of bedrock.
3. Areas of predominately Hydrologic Soil Group D (clay) soils unless allowed by a local unit of government with a current MS4 permit.
4. Areas where soil infiltration rates are more than 8.3 inches per hour unless soils are amended to slow the infiltration rate below 8.3 inches per hour or as allowed by a local unit of government with a current MS4 permit

Many of these proposed changes will allow Minnesota’s permit to become more consistent with EPA’s permit. The changes also reflect a thoughtful review of current sampling data, including the number of samples required of Permittees, sampling results and timeliness of submittals. They will also help maintain greater consistency with other parts of the Stormwater Program.

We welcome your comments!  While formal comments will be accepted during the public comment period, tentatively scheduled for March 2014, you can send questions and concerns now by email to Melissa Wenzel. 

Sincerely, Ken Moon, Industrial Stormwater/Wastewater Supervisor

Current Sampling Year Requirements

sampling requirements. The message included related requirements about collecting and reporting sampling results or legitimate “no flow” explanations. These are quarterly requirements for one sampling year.

To determine when your facility is required to comply with “Year 2” or “Year 4” sampling requirements, visit this page:  Industrial Stormwater Permit Information Access, type in your Permit ID # and click “search.”    

If you need additional information about how to collect stormwater samples or submit the results, visit the MPCA’s Step 10: Sampling or Step 11: Evaluate and submit sampling results web pages. You may also want to consider attending a future University of Minnesota training workshop. For more information about upcoming workshops or to register, download the registration brochure.

Snow pile and snow melt management at industrial facilities

In many areas, stormwater flows to waterways without any additional treatment. This is often the case with snow. Snow often contains contaminants such as salt, sand, gravel, oil, antifreeze and broken pavement. As a result, snowmelt runoff and rain-on-snow events present some of the highest pollutant loading and most difficult management challenges during the year.

Effective management strategies for winter in involve appropriate snow storage measures. The industrial stormwater program staff recommend you plan ahead - now - for snow storage sites and management techniques. 

Keeping salt, sand, and other pollutants in winter snow piles out of waterway is vital in order to conserve and protect our natural resources.

It is illegal (and unsightly) to dump plowed snow directly into water bodies. “Dumping contaminated snow into lakes, rivers and other water bodies is the same as dumping contaminated rainwater into those waterways,” says Julie Congdon, EPA Stormwater Compliance Assistance Coordinator. “Sand and gravel in the snow can cloud the water and smother aquatic habitats; debris accumulated in the snow can harm wildlife.”

Consider doing the following:

• Avoid storing snow near water supply wells, stormwater drains, aquifer recharge areas or surface waters; Maintain a minimum vegetated buffer strip of 50 feet between your snow storage site and any surface water;
• Make sure you have adequate space for a snow storage site in case of excessive amounts of snowfall;
• Be sure to clean up solids/litter when the snow thaws in the spring;
• Store snow piles in an area where solids can be recovered after the snow melts;
• Store salt or sand piles where it is protected from rain, snow, and melt water and on an impervious surface;
• Store salt or sand piles away from lakes, rivers, ditches, storm drains and wetland edges; and,
• Store salt bags away from rain or snow, dispose of bags properly and seal open bags.

Store snow on impervious surfaces whenever possible and store it downhill from any significant industrial materials and/or activities. Avoid pushing snow into lakes, ponds, wetlands, rivers or other natural areas. If snow or snowmelt runoff has come into contact with industrial materials and/or activities, its melt-water discharge is regulated under the ISW permit and should be routed to treatment systems.

It is best to plan in advance on how to manage snow storage, says Congdon. “By having systems and practices in place when the snow comes, pollution to the waterways can be avoided.”

For more information, visit the Local Highway Technical News-Local Highway Technical Assistance Council from Boise, Idaho, PANHANDLE Stormwater and Erosion Education Program and the MPCA’s Industrial Stormwater Best Management Practices Guidebook.

ISW Benchmark Monitoring Results – How are We Doing?

Approximately 65 percent of permittees are in a sampling year (Year 2 or Year 4 of their permits) and many have asked “do best management practices really work to lower our benchmark monitoring exceedances?”  Based on an initial review of the monitoring results we’ve received to date, the answer is YES!

The first table below provides a snapshot of sampling results for the most common permit pollutants.  Though the reported statewide averages exceed the permit benchmark values, we can see a marked decrease in pollutant levels for facilities able to sample in both of the required sampling years.

The second table highlights the industry sectors where BMP management, in response to exceedances, reduced monitoring results to values below the permit benchmarks.

If your sampling results exceed your permit’s benchmark values, and you’d like to finding out what BMPs other industries are using successfully, see Step 12.e: “Review facility-specific suggestions”.

Hennepin County Industrial Stormwater Award

In 2011, Hennepin County hazardous waste inspectors took the initiative to provide enhanced services to their generators that also impacted their collective environmental protection activities:  They asked the county’s hazardous waste generators about industrial stormwater management.   

Next, Hennepin County and MPCA Program staff developed a plan to help educate those generators about:

• Who needs Industrial Stormwater permits and how do they obtain ermit coverage
• What the permit’s” No Exposure” exclusion conditions are, and for those already certified, confirming their status
• How to manage industrial stormwater compliance issues for already-permitted facilities.

 Then, MPCA staff: developed:

• A plan to help County staff with industrial stormwater compliance training and outreach information
• Related newsletter articles tailored to county generators, and,
• Phone and email access for related questions from county staff or generators. 

 And Hennepin County’s efforts included:

• Sharing industrial stormwater permit information
• Verifying  whether a generator’s facility needed an industrial stormwater permit
• Providing the MPCA’s Stormwater Hotline telephone number, staff contacts, and web resources
• Requiring generators to let County staff know the results of any contact with the MPCA.

 The result? Success!

During 2011 and 2012, Hennepin County staff conducted 1,722 hazardous waste facility inspections that included industrial stormwater permit coverage and related information. 

Plus, a benefit to permittees:

This collaborative initiative led to four benefits:   greater compliance and understanding about the industrial stormwater permit requirements among potentially-affected generators, allowed for more open dialog about industrial stormwater, and, allowed for non-penalty compliance checks. It also saved generators time, by having one, instead of two, regulatory inspections.

In November, MPCA Industrial Division Director Jeff Smith awarded Hennepin County with a plaque and thanked them for their efforts.  Hennepin County Hazardous Waste Inspector Supervisor Mike Risse accepted the award during a (county?) division-wide meeting.  Both organizations agree that the partnership has been highly successful and plan to continue the partnership.  One last benefit?  Other metro counties are considering similar partnerships.

Zinc Exceedances

Zinc is one of the more common pollutants permittees are required to sample.  A recent data review of sample results indicated an average for zinc at six time higher-than-allowed benchmark levels. More specifically, the benchmark value averages are .234 mg/L and the average for permittees is 1.4 mg/L. 

As a result, the Industrial Stormwater Program staff contacted all permittees whose data indicated an average benchmark value above 1 mg/L. 

Though it is not a violation to have an average exceedance over .234 mg/L, it is a violation for permittees to not react to the exceedance by modifying or adding new Best Management Practices  before you start sampling again in “Year 4.” 

IMPORTANT!  If you have zinc exceedances, please double-check your lab sheets to make sure you recorded and submitted the correct information to the MPCA. It may be that test results were reported in micrograms (ug) and not in milligrams (mg).  If the data was incorrectly reported, amend and re-submit the 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.

COMMON SOURCES:

Common galvanized items:

• Roofs, chain link fences
• Roof HVAC, ductwork, turbines, equipment boxes
• Downspouts, roof gutters, storm sewer pipe, light poles
• Bay doors , steps, truck trailer panels

Sources of zinc from non-galvanized surfaces:

• Spewing of material like tire wear debris
• Tire dust from forklifts and trucks
• Zinc-content de-icing chemicals
• Sediments in gutters/drainage systems (zinc levels don’t drop until these are flushed)
• Fertilizers
• Wood treated with preservatives containing zinc
• Anticorrosion paint
• Zinc moss killers applied on walkways, decks, and roofing
• Air deposition from local air emissions sources
• Cleaners/surface preparation chemicals used before painting

COMMON REDUCTION PRACTICES:

• Maximize non-exposure
• Replace galvanized items.
• Paint galvanized surfaces as an alternative to replacing them.
• Place chain-link fence on vegetated, not paved areas to reduce runoff and absorb metals.
• When galvanized chain-link is on a paved surface, consider replacing it with aluminum chain-link.
• Consider using forklift tires made from non-rubber materials.
• Use vacuum sweepers to remove motor oil on particles and debris as well as tire dust.

For more information, review EPA’s sector-specific fact sheets.  Also, read Parts 6 and 7 of the Industrial Stormwater Best Management Practices Guidebook for non-structural and structural BMP ideas. 

ONE MORE TIP

If you also have high Total Suspended Solids values, consider BMPs for sediment removal such as vegetative buffers or filter strips. 

Coal Tar Sealants Update

The Minnesota Legislature passed a law during the 2013 session banning the use and sale of coal tar-based sealants, also known as sealcoats, throughout Minnesota. The new law and statewide ban go into effect January 1, 2014.

Its purpose is to prevent the release of harmful and persistent chemicals (polycyclic aromatic hydrocarbons, or PAHs) into our lakes and rivers and will also help minimize taxpayer costs for contaminated sediment cleanup in stormwater ponds.

Please visit MPCA’s “Restriction on Coal Tar-Based Sealants” web page to learn more about coal tar-based sealants, or read the Minnesota legislation in Minnesota Statutes section 116.202. To learn more about preferred alternatives, see the “Moving to safer alternatives to coal tar sealcoats” web page or contact Al Innes, MPCA Resource Management and Assistance unit, at alister.innes@state.mn.us, 651-757-2457 or 800-657-3864.

Another resource is the provider company list and map at the “Find companies selling or applying safer sealcoat” web page. Although no suppliers and contractors may sell or apply coal tar sealcoat starting in 2014, the early-adopting companies on this page can be expected to have more experience using the alternatives, which can require more careful application techniques than coal tar. For a fuel-resistant alternative to coal tar sealcoat, contact a company near you labeled “Supplier” in the list or one which is represented by a black triangle on the interactive map.

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 or Mary West, 651-757-2818
• Engineering Questions: Todd Smith, 651-757-2732