v>EPA
                       United States
                       Environmental Protection
                       Agency
                       Off ice of Water
                       Washington, D.C.
EPA 832-F-99-009
September 1999
Storm  Water
Management  Fact  Sheet
Coverings
DESCRIPTION

Covering is the partial or total enclosure of raw
materials, byproducts, finished products, containers,
equipment, process operations, and material storage
areas that,  when exposed to rain and/or runoff,
could contaminate storm water. Tarpaulins, plastic
sheeting, roofs, buildings, and other enclosures are
examples of temporary or permanent coverings that
are  effective  in  preventing  storm  water
contamination. The most prominent advantage of
covering is that it is inexpensive in comparison to
other BMPs.

APPLICABILITY

A review of numerous NPDES group applications
indicates that covering is a commonly implemented
BMP. As more facilities identify potential sources
of storm water contamination, the use of coverings
will increase significantly due to their effectiveness
from a performance and cost perspective.

Covering is appropriate for loading/unloading areas,
raw material, byproduct, and final product outdoor
storage areas, fueling  and  vehicle  maintenance
areas, and other high risk areas.

ADVANTAGES AND DISADVANTAGES

Covering is a simple and effective storm water
management BMP. Its advantages relative to other
storm  water  management  BMPs  include  its
comparative ease of implementation, its potential
low cost, and its widespread applicability.

Disadvantages associated with covering as a BMP
include:
                      •      Temporary  covering  methods,  such  as
                            plastic sheeting, can become torn or ripped,
                            exposing the contaminant to precipitation
                            and/or storm water runoff.

                            Costs may prohibit the building of complete
                            enclosures.

                      •      Health or safety problems may develop with
                            enclosures built  over certain materials or
                            activities.

                      •      Coverings require frequent inspection.

                      •      A structure with only a roof may not keep
                            out all precipitation.

                      The impact from a covered area depends on the
                      degree of complexity  in the covering design.
                      Simple plastic sheeting can possibly create a storm
                      water  diversion, and  allow for  disposal  of
                      uncontaminated  water  to a  storm  sewer.   An
                      appropriate structure with a permanent roof may be
                      less effective,   if  the  material  inside is  not
                      sufficiently protected from contact with runoff. An
                      enclosed  structure may need to have internal
                      drainage.   However, if the  stored material is
                      considered hazardous, it must not be connected to
                      the storm sewer. Depending on the site's NPDES
                      permit, connection to a sanitary sewer may also be
                      unsuitable. The internal drains would then need to
                      be connected to some suitable containment area for
                      later pretreatment and disposal.

                      IMPLEMENTATION

                      When implementing a program to cover materials
                      to reduce their exposure to runoff, one must first

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choose the proper covering.  When deciding on a
covering, it is necessary to evaluate the integrity
and  durability  of  the  covering,  as  well  as  its
compatibility with  the  material or activity being
covered.

Covering alone may not protect exposed materials
from storm water contact.  Placing material on an
elevated impermeable surface or building curbing
around the outside of the materials may be required
to prevent contact  with storm water  runoff from
adj acent areas. If the program calls for a material to
be enclosed, the designer should consider materials
access, handling, and transfer during the design of
the enclosure. Materials that pose environmental
and/or safety dangers because they are radioactive,
pathogenic,  flammable, explosive, or  reactive,
require special ventilation and temperature design
considerations.

In addition to properly  designing an enclosure or
cover,  practicing proper materials  management
within an enclosure or underneath a covered area is
essential.  For example, floor drainage within an
enclosure   should  be  properly  designed  and
connected to a sanitary  sewer.  The local publicly
owned treatment works should be consulted to
determine   if   there  are   any  pretreatment
requirements,  restrictions,   or   compatibility
problems prior to discharge of the storm water.

Based on data currently available,  it is difficult to
quantify the  mitigation of runoff contamination
when covering is used. However, significant runoff
water quality benefits  are expected  by simply
reducing   the  contact   between   potential
contaminants and  precipitation or  storm  water
runoff. One source  has estimated that 80 percent of
the environmental damage from de-icing chemicals
is caused by inadequate storage facilities.

Inspecting coverings must be part of an overall
preventive  maintenance program.  Maintenance
involves frequent inspection of the covering  for
rips,  holes, and general wear.

COSTS

Covering costs vary in proportion to the degree of
protection desired, and the required life span. The
most inexpensive covering is plastic sheeting, but it
is not suitable where a high degree of protection is
desired for a long period.  An enclosed building is
the most expensive type of covering when materials
for the  structure,  lighting,  and ventilation  are
considered, but it  offers  the highest degree  of
protection for the longest period.

REFERENCES

1.     Minnesota Pollution Control Agency, 1989.
      Protecting  the  Water Quality in  Urban
      Areas.

2.     U.S.  EPA,  1992.  Summary  Guidance:
      Storm Water  Management for Industrial
      Activities: Developing Pollution Prevention
      Plans and Best Management Practice. EPA
       833-R92-002, U.S. EPA, Washington, DC.

3.     Washington State  Department of Ecology,
       1992.  Storm Water Management Manual
      for Puget Sound.

ADDITIONAL INFORMATION

Center for Watershed Protection
Tom Schueler
8391 Main Street
Ellicott City, MD21043

Northern Virginia Planning District Commission
David Bulova
7535 Little River Turnpike, Suite 100
Annandale, VA 22003

Oklahoma Department of Environmental Quality
Don Mooney
Water Quality Division, Storm Water Unit
P.O. Box 1677
Oklahoma City, OK 73101-1677

Southeastern  Wisconsin  Regional   Planning
Commission
Bob Biebel
916 N. East Avenue, P.O. Box 1607
Waukesha, WI53187

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United States Postal Service
Charles Vidich
6 Griffin Road North
Windsor, CT  06006-7030

The  mention  of trade  names  or commercial
products  does  not  constitute  endorsement  or
recommendation  for  the  use   by  the  U.S.
Environmental Protection Agency.
                                                           For more information contact:

                                                           Municipal Technology Branch
                                                           U.S. EPA
                                                           Mail Code 4204
                                                           401 M St., S.W.
                                                           Washington, D.C., 20460


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