United States Office Of Water EPA833-R-91-101
Environmental Protection (EN-336) July 1991
Agency
c/EPA Analysis Of Implementing
Permitting Activities For Storm
Water Discharges Associated
With Industrial Activity
Staff Analysis, July 1991
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ANALYSIS OF IMPLEMENTING PERMITTING ACTIVITIES FOR STORM WATER
DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
Staff Analysis
Storm Water Section
United States Environmental Protection Agency
July 1991
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TABLE OF CONTENTS
1.0 Introduction
2.0 Methods
3.0 Facilities Covered
4.0 Nature and Extent of Pollutants in Storm Water Discharges
Associated with Industrial Activity
5.0 Options for Controlling Pollutants in Storm Water Discharges
6.0 Description of Draft Permit Conditions
7.0 Cost Estimates
Appendix A - Causes of Spills
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1.0 INTRODUCTION
1.1 BACKGROUND
The 1972 amendments to the Federal Water Pollution Control
Act (FWPCA, also referred to as the Clean Water Act or CWA),
prohibited the discharge of any pollutant to navigable waters
from a point source unless the discharge is authorized by a NPDES
permit. Efforts to improve water quality under the NPDES program
have focused traditionally on reducing pollutants in discharges
of industrial process waste water and from municipal sewage
treatment plants. This program emphasis has developed for a
number of reasons. At the onset of the program in 1972, many
sources of industrial process waste water and municipal sewage
were not controlled adequately, and represented pressing
environmental problems. In addition, sewage outfalls and
industrial process discharges were easily identified as
responsible for poor, often drastically degraded water quality
conditions. However, as pollution control measures were
developed initially for these discharges, it became evident that
more diffuse sources (occurring over a wide area) of water
pollution, such as agricultural and urban runoff, were also major
causes of water quality problems. Some diffuse sources of water
pollution, such as agricultural storm water discharges and
irrigation return flows, are exempted statutorily from the NPDES
program. Controls for other diffuse sources have been slow to
develop under the NPDES program.
Since enactment of the 1972 amendments to the CWA,
considering the rise of economic activity and population,
significant progress in cleaning up water pollution has been
made, particularly with regard to industrial process waste water
and municipal sewage. Expenditures by EPA, the States, and local
governments to construct and upgrade sewage treatment facilities
substantially have increased the population served by higher
levels of treatment. Continued improvements are expected for
these discharges as the NPDES program increases emphasis on
control of toxics and water quality-based permit limits.
Several National assessments have been conducted to evaluate
impacts on receiving water quality. For the purpose of these
assessments, urban runoff was considered to be a diffuse source
or nonpoint source pollution, although legally, most urban runoff
is discharged through conveyances such as separate storm sewers
or other conveyances which are point sources under the CWA and
subject to the NPDES program. The "National Water Quality
Inventory, 1988 Report to Congress" provides a general assessment
of water quality based on biennial reports submitted by the
States under Section 305(b) of the CWA. In preparing Section
305(b) Reports, the States were asked to indicate the fraction of
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the States' waters that were assessed, as well as the fraction of
the States' waters that were fully supporting, partly supporting,
or not supporting designated uses. The Report indicates that of
the rivers, lakes, and estuaries that were assessed by States
(approximately one-fifth of stream miles, one-third of lake acres
and one-half of esturine waters), roughly 70 percent to 75
percent are supporting the uses for which they are designated.
For waters with use impairments, States were asked to determine
impacts due to diffuse sources (agricultural and urban runoff and
other categories of diffuse sources), municipal sewage,
industrial (process) wastewaters, combined sewer overflows, and
natural sources, then combine impacts to arrive at estimates of
the relative percentage of State waters affected by each source.
In this manner, the relative importance of the various sources of
pollution causing use impairments was assessed and weighted
national averages were calculated. Based on 37 States that
provided information on sources of pollution, industrial process
wastewaters were cited as the cause of use impairment for 7
percent of rivers and streams, 10 percent of lakes, 6 percent of
estuaries, 41 percent of the Great Lakes shoreline and 6 percent
of coastal waters. Municipal sewage was the cause of use
impairment for 13 percent of rivers and streams, 5 percent of
lakes, 48 percent of estuaries, 41 percent of the Great Lakes
shoreline and 11 percent of coastal waters.
The Assessment also concluded that pollution from diffuse
sources such as runoff from agricultural, urban areas,
construction sites, land disposal activities, and resource
extraction activities is cited by the States as the leading cause
of water quality impairment.1 Diffuse sources appear to be
increasingly important contributors of use impairment as
discharges of industrial process wastewaters and municipal sewage
plants come under control and intensified data collection efforts
provide additional information. Some examples where use
impairments are cited as being caused by diffuse sources include:
rivers and streams, where 9 percent are caused by separate storm
sewers, 4 percent are caused by construction and 11 percent are
caused by resource extraction; lakes where 8 percent are caused
by separate storm sewers and 7 percent are caused by land
disposal; the Great Lakes shoreline, where 35 percent are caused
by separate storm sewers, 46 percent are caused by resource
extraction, and 19 percent are caused by land disposal; for
estuaries where, 41 percent are caused by separate storm sewers;
and for coastal areas, where 20 percent are caused by separate
storm sewers and 29 percent are caused by land disposal.
1 Major classes of diffuse sources that include, in part,
storm water point source discharges are: urban runoff conveyances,
construction sites, agriculture (feedlots), resource extraction
sites, and land disposal facilities.
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The States conducted a more comprehensive study of diffuse
pollution sources under the sponsorship of the Association of
State and Interstate Water Pollution Control Administrators
(ASIWPCA) and EPA. The study resulted in the report "America's
Clean Water - The States' Nonpoint Source Assessment, 1985" which
indicated that 38 States reported urban runoff as a major cause
of beneficial use impairment. In addition, 21 States reported
construction site runoff as a major cause of use impairment.
Studies conducted by the National Oceanic and Atmospheric
Administration (NOAA)2 indicate that urban runoff is a major
pollutant source which adversely affects shellfish growing
waters. The NOAA studies identified urban runoff as affecting
over 578,000 acres of shellfish growing waters on the East Coast
(39 percent of harvest-limited area); 2,000,000 acres of
shellfish growing waters in the Gulf of Mexico (59% of the
harvest-limited area); and 130,000 acres of shellfish growing
waters on the West Coast (52% of harvest-limited areas).
II. FRAMEWORK OF NPDES SYSTEM
Congress established the NPDES program with the 1972
Amendments to the FWPCA. Section 402 of the Act requires EPA to
administer a national permit program to regulate point source
discharges of pollutants to waters of the United States and sets
out the basic elements of the program.
A. STATE PROGRAMS
The Act allows States to request EPA authorization to
administer the NPDES program instead of EPA. Under Section
402(b), EPA must approve a State's request to operate the permit
program once it determines that the State has adequate legal
authorities, procedures, and the ability to administer the
program.
EPA is also directed by section 304(i) of the FWPCA to adopt
procedural and programmatic requirements for State NPDES
programs, including guidelines on monitoring, reporting,
enforcement, personnel and funding, and to develop uniform
national forms for use by both EPA and approved States. At all
times following authorization, State NPDES programs must be
consistent with minimum Federal requirements, although they may
always be more stringent.
See "The Quality of Shellfish Growing Waters on the East
Coast of the United States", NOAA, 1989; "The Quality of Shellfish
Growing Waters in the Gulf of Mexico", NOAA, 1988; and "The Quality
of Shellfish Growing Waters on the West Coast of the United
States", NOAA, 1990.
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Upon authorization of a State program, the State is
primarily responsible for issuing permits and administrating the
NPDES program in that State. At the same time, EPA suspends the
issuance of Federal permits for those activities subject to the
approved State program.
State NPDES authority is divided into four parts: the core
program (POTW and industrial permitting), Federal facilities,
pretreatment, and general permitting. At this point in time, 39
States or Territories are authorized to, at a minimum, issue
NPDES permits for municipal and industrial sources. Of these 39
States, 23 are currently authorized by EPA to issue NPDES general
permits. In the 12 States (MA, ME, NH, FL, LA, TX, OK, NM, SD,
AZ, AK, and ID) and 6 territories (District of Columbia, the
Commonwealth of Puerto Rico, Guam, American Samoa, the
Commonwealth of the Northern Mariana Islands, and the Trust
Territory of the Pacific Islands) without NPDES authorized
programs, EPA issues all NPDES permits. In 5 of the 39 States
that are authorized to issue NPDES permits for municipal and
industrial sources, EPA retains authority to issue permits for
discharges from Federal facilities.
B. REQUIREMENTS IN NPDES PERMITS
The CWA establishes two types of standards for conditions in
NPDES permits, technology-based standards and water quality-
based standards. These standards are used to develop effluent
limitations, special conditions, and monitoring requirements in
NPDES permits. Numeric effluent limitations that establish
pollutant concentration limits for effluents at the point of
discharge (end-of-pipe conditions) are generally at the heart of
permits for discharges from POTWs and industrial process
discharges. More recent permitting efforts have also addressed
limiting the toxicity of effluents through specific toxicity
limitations included in permits. Section 402(a)(1) authorizes
the inclusion of other types of conditions that are determined to
be necessary, known as special conditions, in NPDES permits.
Special conditions include requirements for best management
practices (BMPs).
1. Technology-Based Standards
Technology-based requirements under section 301(b) of the
Act represent the minimum level of control that must be imposed
in a permit issued under section 402 of the Act. Two technology-
based requirements are appropriate for existing storm water
discharges associated with industrial activity: (1) best
conventional pollutant control technology (BCT); and (2) best
available technology economically achievable (BAT). The BCT
standard applies to the control of conventional pollutants, while
the BAT standard applies to the control of all toxic pollutants
and for all pollutants which are neither toxic nor conventional
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pollutants. Section 306 of the CWA provides for EPA to establish
new source performance standards for new sources.
Technology-based requirements may be established through one
of two methods: (1) application of national BAT/BCT effluent e
limitations guidelines promulgated by EPA under section 304 of
the CWA and new source performance standards promulgated under
section 306 of the CWA applicable to dischargers by category or
subcategory; and (2) on a case-by-case basis under section
402(a)(1) of the Act, using best professional judgement (BPJ),
for pollutants or classes of discharges for which EPA has not
promulgated national effluent limitations guidelines. (Note: EPA
only establishes new source performance standards under Section
306 of the CWA when developing national effluent limitations
guidelines, and not when establishing permit conditions on a
case-by-case basis).
In addition to these factors, section 40 CFR 125.3(c)(2)
requires that, in setting permit case-by-case limitations, the
permit writer shall consider the appropriate technology for the
category or class of point sources of which the discharge is a
member, based upon all available information, and any unique
factors relating to the discharge.
2. Water Quality-Based Standards for Controls
In addition to technology-based controls, Section 301(b) of
the CWA also requires that NPDES permits must include any
conditions more stringent than technology-based controls
necessary to meet State water quality standards. Water quality-
based requirements are established under this provision on a
case-by-case basis.
III. PRIOR STORM WATER PERMITTING EFFORTS
Between 1976 and 1984, EPA regulations required that permit
applications be submitted for a wide range of storm water
discharges. Many facilities that were required to submit
applications for storm water discharges did not apply. In
addition, many of the permit applications received by EPA and
authorized NPDES States were never acted upon for a number of
reasons, including: lack of resources for permitting, lack of
technical understanding of the causes and controls for pollutants
in storm water, reluctance of industrial dischargers to accept
requirements for best management practices (BMPs) in NPDES
permits, and a general perception that storm water discharges,
when considered one at a time, were of low priority. In 1984,
EPA again promulgated permit application requirements and
deadlines for storm water discharges. However, these regulations
were subject to extensive litigation which resulted in their
being remanded to EPA in December 1987. In February of that
year, Congress enacted the Water Quality Act (WQA) of 1987 which
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directly specified a new national strategy for storm water
control.
Despite the lack of a comprehensive permitting program for
all storm water discharges prior to the passage of the WQA of
1987, permitting efforts nonetheless proceeded in some areas.
Between 1974 and 1982, EPA promulgated effluent limitations
guidelines for storm water discharges from ten categories of
industrial discharges:
o Cement Manufacturing
o Feedlots
o Fertilizer Manufacturing
o Petroleum Refining
o Phosphate Manufacturing
o Steam Electric
o Coal Mining
o Ore Mining and Dressing
o Mineral Mining and Processing
o Asphalt Emulsion
Permitting efforts for storm water discharges have focussed
on industrial facilities subject to these effluent limitation
guidelines. In addition, some EPA Regions and States with
authorized State NPDES programs have, to varying degrees, written
permits for storm water discharges from other industrial
facilities. For example, in some States and Regions, storm water
discharges from industrial facilities are often addressed when
NPDES permits for process wastewaters of a facility are reissued.
IV. PERMIT APPLICATION REGULATIONS
On November 16, 1990, (55 £B 47990), EPA published NPDES
permit application requirements for: storm water discharges
associated with industrial activity; and discharges from
municipal separate storm sewer systems serving a population of
100,000 or more. The rulemaking accomplished three major tasks:
(1) the rule defined the initial scope of the NPDES storm water
program; (2) the rule established a permitting scheme with
respect to storm water discharges associated with industrial
activity through municipal separate storm sewer systems; and (3)
the rule established permit application requirements for those
storm water discharges which are initially subject to the
program.
A. SCOPE OF NPDES STORM WATER PROGRAM
The initial scope of the NPDES storm water program is
defined by two key regulatory definitions, "storm water
discharges associated with industrial activity" and "large and
medium municipal separate storm sewer systems". The term "storm
water discharge associated with industrial activity" is defined
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at 40 CFR 122.26(b)(14) and addresses point source discharges of
storm water from eleven major categories of facilities.
The terms "large and medium municipal separate storm sewer
systems" (systems serving a population of 100,000 or more) are
defined at 40 CFR 122.26(b)(4) and (7) to include municipal
separate storm sewers located in: 173 incorporated places
(cities) with a population of 100,000 or more; unincorporated
portions of 47 counties identified as having large populations in
unincorporated, urbanized portions of the county; and other
municipal storm sewers which are designated by the Director on a
case-by-case basis.
The definitions of "storm water discharge associated with
industrial activity" and "large and medium municipal separate
storm sewer system" only address point source discharges.
Section 502(14) of the CWA defines the term "point source"
broadly to include "any discernible, confined and discrete
conveyance, including but not limited to any pipe, ditch,
channel, tunnel, conduit, well, discrete fissure, container, . .
. from which pollutants are or may be discharged."
In most court cases, the term "point source" has been
interpreted broadly. For example, the holding in Sierra Club v.
Abston Construction Co.. Inc.. 620 F.2d 41 (5th Cir., 1980)
indicates that changing the surface of land or establishing
grading patterns on land will result in a point source where the
runoff from the site ultimately is discharged to waters of the
United States:
"Simple erosion over the material surface, resulting in the
discharge of water and other materials into navigable
waters, does not constitute a point source discharge, absent
some effort to change the surface, to direct the water flow
or otherwise impede its progress . . . Gravity flow,
resulting in a discharge into a navigable body of water, may
be part of a point source discharge if the [discharge] at
least initially collected or channeled the water and other
materials. A point source of pollution may also be present
where [dischargers] design spoil piles from discarded
overburden such that, during periods of precipitation,
erosion of spoil pile walls results in discharges into a
navigable body of water by means of ditches, gullies and
similar conveyances, even if the [dischargers] have done
nothing beyond the mere collection of rock and other
materials . . . Nothing in the Act relieves [discharges]
from liability simply because the operators did not actually
construct those conveyances, so long as they are reasonably
likely to be the means by which pollutants are ultimately
deposited into a navigable body of water. Conveyances of
pollution formed either as a result of natural erosion or by
material means, and which constitute a component of a ...
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drainage system, nay fit the statutory definition and
thereby subject the operators to liability under the Act."
(emphasis added) 620 F.2d 41, 45 (1980).
Under this approach, point source discharges of storm water
result from structures that increase the imperviousness of the
ground that acts to collect runoff, with runoff being conveyed
along the resulting drainage or grading patterns.
The Agency will embrace the broadest possible definition of
point source consistent with the legislative intent of the CWA
and court interpretations to include any identifiable conveyance
from which pollutants might enter the waters of the United
States.
B. INDUSTRIAL STORM WATER DISCHARGES THROUGH MUNICIPAL SEPARATE
STORM SEWER SYSTEMS
The November 16, 1990 notice clarifies that storm water
discharges associated with industrial activity to waters of the
United States, including those through municipal separate storm
sewers to waters of the United States, must obtain NPDES permit
coverage. However, storm water discharges associated with
industrial activity to municipal sanitary sewer systems (i.e.
those systems which are part of a POTW collection system),
including combined sewer systems, do not need to obtain NPDES
permit coverage, although they may be subject to pretreatment
requirements.
C. PERMIT APPLICATION REQUIREMENTS
The November 16, 1990 rule established individual (40 CFR
122.26(c)(1)) and group (40 CFR 122.26(c)(2)) application
requirements for storm water discharges associated with
industrial activity. The requirements associated with individual
application requirements for storm water discharges associated
with industrial activity are incorporated into Forms 1 and 2F,
which are generally to be submitted to the Director by November
18, 1991. In addition, operators of storm water discharges
associated with industrial activity through large and medium
municipal separate storm sewer systems are required submit a
notification of their discharge to the operator of the municipal
separate storm sewer system receiving the discharge by no later
than May 15, 1991 or 180 days prior to commencing such discharge
(40 CFR 122.26(a)(4)).
The rule also established permit application requirements
for discharges from large and medium municipal separate storm
sewer systems at 40 CFR 122.26(d).
To provide a reasonable and rational approach to addressing
this permitting task, the Agency is developing a Strategy for
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issuing permits for storm water discharges associated with
industrial activity. In developing this Strategy, the Agency
recognizes that the CWA provides flexibility in the manner in
which NPDES permits are issued, and will use this flexibility to
design a workable permitting system. In accordance with these
considerations, the draft permitting Strategy (described in more
detail earlier in today's notice) describes a four-tier set of
priorities for issuing permits for these discharges. The four-
tier set of priorities for issuing permits under the policy are:
o Tier I - Baseline Permitting; One or more general permits
will be developed to initially cover the majority of storm
water discharges associated with industrial activity;
o Tier II - Watershed Permitting; Facilities within watersheds
shown to be adversely impacted by storm water discharges
associated with industrial activity will be targeted for
individual or watershed-specific general permits.
o Tier III - Industry-Specific Permitting; Specific industry
categories will be targeted for individual or industry-
specific general permits; and
o Tier IV - Facility-Specific Permitting; A variety of factors
will be used to target specific facilities for individual
permits.
The draft general permits accompanying this fact sheet will
initiate Tier I activities for storm water discharges associated
with industrial activity in the 12 States and 6 territories which
do not have authorized State NPDES programs*; Federal facilities
The court in NRDC v. Train. 396 F.Supp. 1393 (D.D.C. 1975)
aff'd. NRDC v. Costle. 568 F.2d 1369 (D.C.Cir. 1977), has
acknowledged the administrative burden placed on the Agency by
requiring permits for a large number of storm water discharges.
The courts have recognized EPA's discretion to use certain
administrative devices, such as area permits or general permits,
to help manage its workload. In addition, the court recognized
flexibility in the type of permit conditions that can be
established, including the use of requirements for best management
practices.
* Currently, the 12 States without authorized State NPDES
programs are: Alaska, Arizona, Florida, Idaho, Louisiana,
Massachusetts, Maine, New Hampshire, New Mexico, Oklahoma, South
Dakota, and Texas. The 6 territories without authorized NPDES
programs are: District of Columbia, the Commonwealth of Puerto
Rico, Guam, American Samoa, the Commonwealth of the Northern
Mariana Islands, and the Trust Territory of the Pacific Islands.
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and Indian lands in Colorado and from Indian lands in North
Dakota, Minnesota, Michigan, Montana, Utah, Wisconsin and Wyoming
by proposing baseline general permits for the majority of storm
water discharges in these States and Federal facilities in
Delaware. (Note that these permits are intended to initially
cover the majority of storm water discharges associated with
industrial activity in the States and on the Indian lands
addressed by these permits. In addition to establishing baseline
requirements for the majority of storm water discharges
associated with industrial activity in these States, the draft
general permits have some of the features of Tier III permitting
activities in that they establish requirements for specific
industries.
In 6 of the 39 States that are authorized to issue NPDES
permits for municipal and industrial sources, EPA issues permits
for discharges from Federal facilities. State programs do not
generally address permitting of discharges from Indian lands, as
EPA retains this responsibility. However, this fact sheet only
addresses general permits as indicated above. Where EPA is the
permit issuing authority for other storm water discharges, either
individual permits or a different general permit will be issued.
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2.0 METHODS
2.1 Characterizing the Nature and Extent of Pollutants in Storm
Sewer Discharges
Data describing the nature and extent of pollutants in storm
water discharges from individual facilities came from a number of
sources, including effluent limitations guidelines development
documents, Reports to Congress, EPA studies and studies. In
addition, a search was made .of the EPA Permit Compliance System
(PCS) data base. The PCS data base contains reported
characteristics of certain discharges subject to NPDES permits.
The data in the PCS system represents discharges which are
subject to regulation and which may have undergone treatment
prior to discharge.
Additional evaluation of pollutants in storm water
discharges associated with industrial activity were based on a
consideration of the pollution potential of storm water
discharges by expert industry consultants involved consideration
of several factors, including: 1) loading or unloading of dry
bulk materials or liquids, 2) outdoor storage of raw materials or
products, 3) outdoor process activities, 4) dust or particulate
generating processes, 5) illicit connections or management
practices, and 6) waste disposal practices.
2.2 IDENTIFYING SOURCES OF STORM WATER
In this study EPA has attempted to provide estimates of the
number of storm water discharges associated with industrial
activity.
The Standard Industrial Classification (SIC) system provided
the initial framework for identifying individual facilities.
Facilities which are addressed by the regulatory definition of
"storm water discharges associated with industrial activity" were
identified.
After an initial evaluation, it was determined that the SIC
system did not provide an appropriate classification of several
classes of activities such as, construction and waste management
activities. Alternative methods were used to estimate the number
of facilities in these groups. Estimates of the number of
construction sites for residential development were projected
from data describing a portion of the entire set of sites. Data
from Housing and Urban Development (HUD) was used to provide
estimates of the number and size of construction activities for
residential subdivisions. The HUD data was based on the review
of applications for Federal insurance. HUD officials also
provided estimates for the number of subdivisions which were not
covered by an application for insurance. Various EPA studies
provided data on the number and size of landfills and other waste
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disposal facilities.
Drainage is provided by combined sewers in portions of many
municipalities with areas of older development. These combined
sewer systems are not the primary subject of this study, but need
to be evaluated to determine the number of facilities which
discharge to a combined sewer. Estimates of the area and
population served by combined sewer systems were based on data
from the 1984 "Needs Survey". The 1984 Needs Survey reported
estimates for each urbanized area that was thought to have
combined sewers.
2.3. Review of Options and Costs of Controls
In 1979, EPA completed a technical survey of industry best
management practices (BMPs) which was based on a review of
practices used by industry to control the non-routine discharge
of pollutants from non-continuous sources including runoff,
drainage from raw material storage area, spills, leaks, and
sludge or waste disposal. This review included analysis and
assessment of published articles and reports, technical
bulletins, and discussions with industry representatives through
telephone contacts, written questionnaires and site visits.
The review identified two classes of pollution control
measures. The first class of controls are those management
practices generally considered to be essential to a good BMP
program, are low in cost, and applicable to broad categories of
industry and types of substances. These practices are
independent of the type of industry, ancillary sources, specific
chemicals, group of chemicals, or plant-site locations. The
survey concluded that these controls were broadly applicable to
all industry types and activities, and should be viewed as
minimum requirements in any effective BMP program. The second
class of controls are those management practices controls which
provide a second line of defense against the release of
pollutants and included prevention measures, containment
measures, mitigation and cleanup measures, and treatment
methods .
Since that time, EPA has, on a case-by-case basis, imposed
BMP requirements in NPDES permits. The Agency has also continued
1 For a complete description of the BMP survey, see "NPDES
Best Management Practices Guidance Document", U.S. EPA, December
1979, EPA-600/9-79-045. See also the 1981 document of the same
name, "NPDES Best Management Practices Guidance Document" which
provides a more complete discussion of baseline BMPs.
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to review and evaluate case studies involving the use of BMPs2
and the use of pollution prevention measures associated with
spill prevention and containment measures for oil and hazardous
substances. In addition, the Agency has evaluated the various
control options for hazardous waste tank systems . During the
development of NPDES permit application requirements for storm
water discharges associated with industrial activity, the Agency
evaluated appropriate means for identifying and evaluating the
potential risk of pollutants in storm water from industrial
sites. Public comments received during the rulemaking provided
additional insight regarding storm water risk assessment, as well
as appropriate pollution prevention and control measures and
strategies. During this time, the Agency again reviewed storm
water control practices and measures . These experiences have
shown the Agency that pollution prevention measures such as BMPs
can be appropriately used and that permits containing BMP
requirements can effectively reduce pollutant discharges in a
cost-effective manner.
Permit Compliance Costs
Cost data was obtained from a variety of sources, including
background documents for effluent limitations guidelines,
technical literature, the Means Construction Cost Index, public
comments on previous storm water rulemakings, surveys of
industrial representatives, and comparisons with contractor
charges. The Information Collection Request (ICR) document for
the storm water implementation package provides additional
consideration of the costs of monitoring requirements and notice
of intent requirements. In addition, the ICR for the revisions
to the NPDES storm water permit application regulations was used
to evaluate the costs of many of the source identification
2 For example, see: "Best Management Practices: Useful Tools
for Cleaning Up", Thron, H., Rogoshewski, P., 1982, Proceedings
of the 1982 Hazardous Material Spills Conference; "The Chemical
Industries' Approach to Spill Prevention" Thompson, C., Goodier,
J., 1980, Proceedings of the 1980 National Conference on Control
of Hazardous Material Spills; and a series of EPA memorandum
entitled "Best Management Practices in NPDES Permits - Information
Memorandum", 1983, 1985, 1986, 1987, 1988.
3 See Oil Pollution Prevention requirements, including Spill
Prevention, Control, and Countermeasure Plan requirements, at 40
CFR 112.
u See July 14, 1986 (51 IE 25422).
5 Draft "Analysis of Implementing Permitting Activities for
Storm Water Discharges Associated with Industrial Activity" (EPA,
1991).
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provisions of the storm water pollution prevention plans as well
as requirements to certify outfalls have been tested for illicit
connections.
The pollution potential for discharging storm water from
industrial facilities is primarily related to specific plant site
configurations, such as the presence of outdoor material storage
or indoor process areas. To address this, the approach taken
with several types of controls such as baseline pollution
prevention measures and spill prevention and containment
provisions provides flexibility in the manner in which they are
implemented for a given facility. It is anticipated that various
facilities will implement various provisions in different ways,
and will emphasize different provisions of their comprehensive
plans, resulting in varying costs between facilities. In this
analysis, to address this variability, a number of control
scenarios were used to establish the range of costs likely to be
encountered by industries. Under this approach, the action taken
to respond to requirements were assumed to correspond to the
configurations of facilities with different ancillary industrial
activities, such as loading and unloading, conducted on site.
Examples of different types of plant configurations include:
• facilities which process all or partially outdoors with
existing controls,
• facilities which process all or partially outdoors
without existing controls,
• facilities which process indoors and have no outdoor
storage,
facilities which process indoors and have outdoor tank
storage, and
facilities which process indoors and have outdoor
material storage.
Outdoor storage of materials includes storage of final
products or raw materials as drums, piles, bags, parts, or other
stock piles.
Five ancillary industrial activities may also contribute
pollutants to storm water. These activities include loading and
unloading, transportation-related activities such as engine
maintenance, outdoor electrical activities including substations,
industrial waste management, and air deposition. The ancillary
activities may occur at some or all of the industrial facilities
distributed among the six model plant configurations. The
percentages of industrial facilities estimated to conduct these
activities (based again on Agency expertise and professional
engineers' experience with the regulated populations) are as
follows:
loading and unloading: 90 percent,
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2-5
transportation: 50 percent,
outdoor electrical: 50 percent,
Subtitle D waste management: 5 percent, and
air deposition of pollutants regulated: 12 percent.
Since one facility may perform more than one ancillary
activity, the sum of the percentages of facilities performing
each ancillary activity exceeds 100%.
Storm water controls are assumed to be complimentary. For
example, smaller detention ponds may be needed if infiltration
areas are used to collect a portion of storm runoff, and curbing
around loading areas will minimize contact of storm water with
pollutant sources, and screens will require less frequent
cleaning if slope protection and swales are installed at
construction sites to minimize sediment in storm water. Further,
good housekeeping by industry may limit the need for treatment
plants by ensuring that toxic or hazardous materials do not
contaminate storm water.
Cost estimations were made assuming that some required
control measures, such as material inventory, employee training,a
nd preventive maintenance, have already been implemented to some
degree by some of the affected facilities to reduce chemical
losses, increase overall productivity, profitability, and safety,
or as part of compliance with other regulations. Industry costs
for control measures that the facility already provided were not
included in the analysis.
In some scenarios, both capital and O&M costs, for certain
types of controls are projected to be zero. This is because
appropriate controls for many SARA Title III facilities, such as
diked tank storage or indoor material storage, are likely to be
in place already.
The methodology used in this analysis was based on the
"model plant" approach often used by the Office of Water's
Industrial Technology Division in its development documents for
Industrial Effluent Limitation Guidelines and Pretreatment
Standards. Under this approach, model plants are selected that
characterize the range of production processes, materials, and
scale of operations within that industry. For each model plant,
varying levels of control technology are specified for each flow.
The model plant approach was adapted to the storm water
problem as follows:
Costs for Industrial Activities
For industrial activities, factors were developed to
represent the initial and annual costs of preparing and
implementing a Storm Water Management Plan. "Minimum"
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2-6
and "maximum" costs were estimated, representing
different judgement regarding the scale and complexity
of the operations.
Six model plants were selected to represent industrial
activities. Five of the model plants were
differentiated by the degree to which manufacturing
facilities and material storage are indoors or
outdoors, and whether storm water controls currently
exist on site. The sixth model represented oil and gas
extraction facilities. Separate models were specified
to represent ancillary activities such as
transportation, materials handling, and waste
management.
Storm water controls and their respective cost factors
were estimated by professional engineers having
experience in industrial storm water management. For
both groups of industries, "maximum" and "minimum"
control scenarios were analyzed. Each scenario
represents an engineering judgement regarding the size
of the activity, the volume of storm water handled, the
amount of contamination, and the nature of the
contaminants.
A unique set of storm water requirements and controls
was chosen for each scenario and for each of the six
model plant configurations. For the analysis the
following storm water requirements and controls were
used:
Storm water management plans,
Dye testing for illicit connections,
Certification that outfalls have been tested for
non-storm water discharges,
Employee training,
Preventive maintenance/housekeeping,
Discharge monitoring,
Runoff diversion trenches, ditches, and curbing,
and
• Treatment.
All costs were converted to 1990 dollars.
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3.0 FACILITIES COVERED
Facilities addressed by the regulatory definition of storm
water associated with industrial activity can be broken into the
following categories:
o Resource extraction
o Manufacturing
o Construction
o Land disposal
o Transportation
o Power generation
3.1 Resource extraction
3.1.1 Mines - Total number of facilities
The number of active mines varies from year to year,
depending on economic factors. In 1980, the U.S. Bureau of Mines
estimated that there were 600 metal mines. Over 90 percent of
the metal mines are west of the Mississippi River, and over 60
are concentrated in 10 States with 20 or more mines each. There
are about 6,045 non-metal mines (except fuels). Most of the
nonmetal mines are clay, sand and gravel, and stone mines.
The Energy Information Administration of the Department of
Energy (DOE) estimated that about 3,900 coal mines were active in
1987. The trend over the last ten years has been towards fewer
small mines as more efficient mining methods for large mines
(e.g. longwall and continuous mining) allow for greater
production and productivity for the larger mines. DOE estimates
that under 900 active mines produce less than 10,000 short tons
of coal during the year, compared to over 3,000 active mines
which produce more than this amount. The greatest number of
mines are situated in the Appalachian region, which has about 90
percent of the national total. The number of underground versus
surface operations in the Appalachian region are fairly close,
but in both the Interior and Western regions there are many more
surface than underground operations (about three times as many
surface mines in the Interior region, and about twice as many
surface mines as underground in the Western region).
Estimates of the number of inactive or abandoned mines vary
considerably, with most estimates in the range of 400,000 to
1,000,000 sites. The present condition of these sites varies
considerably with some site having been totally reclaimed, while
other sites closely resemble the condition of active sites.
3.1.2 Oil and gas operations - Total number of Facilities
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3-2
The oil and gas industry is extremely large and varied. The
American Petroleum Institute estimates that in 1986, there were
approximately 880,000 producing oil and gas wells in the United
States, distributed throughout 38 States. About 30,000 wells are
drilled each year. Texas has about 250,000 producing wells.
Production from a single well can vary from a high of about
11,500 barrels per day (the 1985 average for wells on Alaska
North Slope) to less than 10 barrels per day in many thousands of
"stripper" wells. Overall, 70 percent of U.S. oil wells are
strippers, accounting for roughly 14 percent of total U.S.
production). On average, 3 to 4 wells are located at one site,
with an estimated 240,000 sites nationwide. About 130,000 of
these facilities have been required to develop spill prevention
plans, generally after having reported releases of oil under the
reporting requirements of the CWA. There are an estimated
1,200,000 abandoned oil or gas wells in the United States.
The "Census of State and Territorial Subtitle D Non-
hazardous Waste Programs" estimates that there are more than
145,000 oil and gas waste or mining waste units.
3.1.3 Facilities with Contaminated Runoff
Section 402(1)(2) of the CWA provides that EPA shall not
require an NPDES permit for discharges of storm water runoff from
mining operation or oil and gas exploration, production,
processing, or treatment operations or transmission facilities if
the storm water discharge is not contaminated by contact with, or
does not come into contact with, any overburden raw material,
intermediate product, finished product, byproduct, or waste
product located on the site of such operation.
The operator of a storm water discharge from an oil or gas
operation is not required to submit a permit application unless
the facility:
o has had a discharge of storm water resulting in the
discharge of a reportable quantity for which notification is
or was required pursuant to 40 CFR 117.21 or 40 CFR 302.6 at
any time sine November 16, 1987;
o has had a discharge of storm water resulting in the
discharge of a reportable quantity for which notification is
or was required pursuant to 40 CFR 110.6 at any time sine
November 16, 1987; or
o contributes to a violation of a water quality standard.
NPDES permit applications are required when discharges of
storm water runoff come into contact with any overburden, raw
material, intermediate product, finished product, byproduct, or
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3-3
waste product located at the site. However, only mining
operations with 'contaminated1 storm water discharges are
required to obtain NPDES permit coverage. The determination of
whether a mining operations' runoff is contaminated will be made
in the context of permit issuance proceedings.
3.2 Manufacturing
3.2.1 Total number of manufacturing facilities
Manufacturing industries include the industries covered by
SIC codes 20 to 39. Table 3-1 provides estimates of the number
of manufacturing facilities from the 1987 Census of
Manufacturers.
3.2.2 Manufacturing facilities with Storm Water Discharges
Associated with Industrial Activity
The regulatory definition of storm water discharge
associated with industrial activity divides manufacturing
facilities into two groups. Under the definition, facilities
addressed by (SIC codes 20, 21, 22, 23, 2434, 25, 265, 267, 27,
283, 285, 30, 31 (except 311), 323, 34 (except 3441), 35, 36, 37
(except 373), 38, 39, and 4221-25 are only addressed by the
regulatory definition if certain materials are exposed to storm
water (see 40 CFR 122.26(b)(14)). Estimates of these facilities
are provided in Table 3.2.
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3-4
TABLE 3.1
1987 CENSUS OF MANUFACTURERS
TOTAL NUMBER OF MANUFACTURING FACILITIES
NUMBER OF
SIC GROUP ESTABLISHMENTS
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
food
tobacco
textile
apparel
lumber and wood
furniture
paper
painting
chemicals
petroleum
rubber and plastic
leather
stone, clay and glass
primary metal
fabricated metal
industrial machinery
electronic
transportation equip.
instruments
- misc, manu.
20,624
138
6,421
22,872
33,962
11,613
6,342
61,774
12,109
2,254
14,515
2,193
16,166
6,771
36,105
52,135
15,962
10,500
10,326
16,544
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3-5
TABLE 3.2
NUMBER OF MANUFACTURING FACILITIES WITH
STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SIC
GROUP
NUMBER OF ESTABLISHMENTS
24 (except 2434)
26 (except 265, 267)
28 (except 283)
29
311
32 (except 323)
33
3441
373
subtotal
lumber and wood 30,268
paper 519
chemicals 10,753
petroleum 2,254
leather tanners 344
stone,clay and glass 14,7.34
primary metal 6,771
fabrated, struct, metal 2,452
ship and boat build. 2,766
70,861
category (xi)
facilities
14,000
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3-6
3.3 Construction
About 1.6 million acres of land are disturbed annually
throughout the nation, much of it in building highways and other
heavy development. About 80,000 acres a year are disturbed for
urban housing and another 80,000 acres for urban non-residential
development. The regulatory definition of storm water discharge
associated with industrial activity addresses storm water
discharges from construction activities that disturb over 5 acres
of land.
3.3.1 Residential Construction
The majority of detached single family residential homes, as
well as duplexes, or townhouses are built as part of a larger
subdivision project. The number of subdivisions reviewed by
Housing and Urban Development (HUD) for approval of federal
insurance are provided in Table 3-3. The average number of lots
or housing units within a subdivision reviewed by HUD was 64.
These data were used to estimate that the total number of
subdivision projects occurring annually equalled 13,000 (see
Table 3-4).
3.3.2 Other Construction Activity
The amount of land disturbed by construction activities for
non-residential projects is about equivalent to the amount of
land disturbed for residential projects. EPA estimates that the
number of non-residential projects annually is about 13,000.
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TABLE 3-3. HUD REVIEWS - AVERAGE ANNUAL CHARACTERISTICS
FOR SUBDIVISIONS APPLYING FOR FEDERAL INSURANCE DURING 1983-
1985
Number of Number Lots per
Subdivisions of Lots Subdivision
Northeast
South
Midwest
West
52
1,751
332
1.435
6,501
116,298
18,385
81.766
138
77
55
58
Total 3,570 222,950 64
SOURCE: Housing and Urban Development (HUD)
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3-8
Table 3-4. National Projection of the Number and Size
Distribution of Single Family Detached and Townhouse Construction
Operations.
Number of
Units per
Site
more than 400
300 - 399
250 - 299
200 - 249
150 - 199
100 - 149
75 - 99
50 - 74
35 -
25 -
10 -
5 -
49
34
24
9
4 or less
Number
of Sites
60
120
260
325
650
780
1,500
3,250
2,470
3,540
2,500
750
8,000
Average Area
of Subdivision
or lot (acres)
over 100
87
69
56
44
31
21
16
10
8
4
2
1
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3.4 Land disposal
The regulatory definition of storm water discharge
associated with industrial activity addresses storm water
discharges from the following four groups of facilities in the
regulatory definition of "storm water discharge associated with
industrial activity":
o Hazardous waste treatment, storage, and disposal facilities
(TSDFs) subject to RCRA Subtitle C permitting or interim
status;
o Landfills, land application sites, and open dumps that
receive industrial wastes and are subject to regulation
under RCRA Subtitle D;
o Recycling facilities, including metal scrapyards, battery
reclaimers, salvage yards, and automobile junkyards; and
o On-site POTW lands used for land application treatment
technologies, sludge disposal, handling or processing areas,
and chemical handling and storage areas.
3.4.1 RCRA Subtitle C
RCRA Subtitle C regulates facilities that treat, store, or
dispose of RCRA-defined hazardous wastes. The National Screening
Survey of Hazardous Waste Treatment, Storage Disposal, and
Recycling Facilities (1986) estimated that there are 2,959 active
treatment, storage, and disposal facilities (TSDFs). The
majority of these facilities receive waste from on-site a
manufacturing plant, and are counted as a manufacturing facility
in this report. Commercial facilities (facilities receiving
waste from off site) included 205 treatment facilities, 58 land
disposal facilities and 220 recycling facilities.
3.4.2 Subtitle D Facilities (Excluding Mining and Oil and Gas
Wastes)
Disposal of "nonhazardous" wastes is regulated under
Subtitle D of the Resource Conservation and Recovery Act (RCRA).
These wastes include many different types of waste streams, such
as municipal solid waste, industrial waste, and construction and
demolition debris.
EPA estimates that there are 35,163 active landfills, land
application units and waste piles that receive Subtitle D wastes
including municipal solid wastes, industrial wastes, municipal
sewage sludge, construction and demolition debris and other
miscellaneous wastes. These totals do not include units which
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receive mining waste, and oil and gas wastes. In addition, these
totals do not include surface impoundments. Discharges from
surface impoundments which receive Subtitle D wastes to waters of
the United States are required to receive NPDES permits
independently of the storm water regulations.
The State Census indicated that there are about 16,500
landfills and 19,000 land application units. Of the estimated
16,500 landfills, the States estimated that 6,034 are municipal
solid waste landfills. The State Census indicates that an
additional 32,000 closed solid waste disposal facilities are
located across the United States. However, EPA is unable to
determine how many of these facilities are municipal landfills,
or industrial landfills.
Landfills or other waste disposal units are only addressed
by the regulatory definition of storm water discharges associated
with-industrial activity if they receive industrial wastes.
Municipal Solid Waste Landfills
Table 3.5 provides estimates of the ownership of landfills.
According to the State Census, landfills receiving municipal
waste are distributed throughout the country, occurring in
virtually every hydrogeologic setting, and generally concentrated
near or in populated areas. Landfills receiving municipal wastes
are owned predominantly by local governments (80 percent), with
the remainder owned by private entities (15 percent), the Federal
Government (4 percent) and State governments (1 percent).
Approximately 42 percent are small (less than 10 acres) and 52
percent dispose of small amounts of waste (less than 17.5 tons
per day).
The majority of Subtitle D facilities are both owned and
operated by the same entity. However, some facility owners
contract out the operation of their facility. Approximately 5
percent of publicly owned municipal solid waste landfills are
operated by private entities. In addition, certain Federal
agencies lease land to local governments for the operation of
municipal solid waste landfills.
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insert Table 3-5
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3-12
Industrial Landfills
In 1985, about 14,000 industrial solid waste land disposal
facilities (other than surface impoundments) handled
approximately 7.6 billion tons of waste. Results of the "Census
of State and Territorial Subtitle D Non-Hazardous Waste Programs"
indicate only sporadic use of design and operation controls at
industrial solid waste landfills. Study findings also revealed
that few of these facilities have monitoring systems. •
Recycling Facilities
Resource Recycling Magazine estimates that there are about
6,000 scrap metal and automobile salvage yards nationwide. Many
other facilities involved in recycling activities are also
involved in the manufacture of goods. For example, the estimated
1,800 facilities which recycle waste paper are addressed as paper
manufacturers above. 200 of these paper mills use only waste
paper as a raw material. An estimated 95 glass manufactures
recycle glass. In addition, about 1,000 communities have
recycling programs which involve curbside pickup. Over 60
percent of the recycling facilities are located in the following
ten states: PA, NY, CA, OH, IL, TX, MI, NJ, IN, and FL.
POTWs
The 1988 Needs Survey indicates that 2,107 POTWs are
required to have pretreatment programs. In addition, another
1,466 POTWs which are not required to have pretreatment programs
under the NPDES program have flows of over 1.0 million gallons
per day.
3.5 Transportation
The regulatory definition of storm water discharges
associated with industrial activity addresses certain
transportation facilities in SIC codes 40, 41, 42 (except 4221-
25), 43, 44, 45, and 5171. Based on data from the 1987 Census of
Manufacturers, EPA estimates that there are 102,000 facilities in
these SIC categories. However, facilities in these SIC codes are
only addressed by the regulatory definition of storm water
discharge associated with industrial activity if they have
vehicle maintenance shops, equipment cleaning operations or
airport deicing.
3.6 Power generation
Coal, petroleum, and natural gas are the most common fossil
fuels used in electrical power generation. Hydroelectric and
nuclear are the other major types of electrical generation
plants. (Hydroelectric plants are not considered steam electric
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facilities, and hence are generally not addressed by the
regulatory definition of storm water discharge associated with
industrial activity). Electrical power plants typically have 1
to 10 units. Table 3-6 provides estimates of the number of
electrical units by the type of fuel used for power generation,
as well as the number of generating units.
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TABLE 3-6. Operable Capacity by Energy Source in the United
States, as of December 1987
Primary Energy Estimated Generator
Source Number of Capacity
Plants (nameplate)
Coal 163 718,056
Petroleum 432 315,697
Gas 257 84,215
'Hydroelectric 1,234 125,911
Nuclear 71 101,604
*Other 113 4,718
TOTALS 2,270 718,056
* Generally not addressed by EPA's regulatory definition of
storm water discharge associated with industrial activity
SOURCE: Energy Information Administration, Department of Energy,
Inventory of Power Plants in the United States 1987
NOTE: Many fossil-fuel burning units can use alternative sources
of energy which are not accounted for here. (e.g. a unit using
petroleum as the primary fuel, may use coal as an alternative
unit)
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3.7 Discharges to Combined Severs
Storm water discharges associated with industrial activity
that discharge to combined sewer systems or separate sanitary
sewer systems are not addressed in the regulatory framework
established under section 402(p) of the CWA. These discharges
are generally not required to obtain an NPDES permit, but may be
subject to local pretreatment limits established by the POTW.
Based on Need Survey data, about 25% of the population of
the United States is served by combined sewers. The percentage
of facilities discharging storm water to municipal storm sewers
or combined sewers will vary depending on the type of activity.
For example, many chemical industries and most metal products
industries are located in or close to urbanized centers, and have
a high probability of discharging storm water to municipal
separate storm sewers or combined sewers. Other activities such
as mining facilities, wood preservers, pulp and paper mills, and
fertilizer manufacturers, and resource extraction are more rural
in nature and are less likely to discharge storm water to
municipal separate storm sewers or combined sewers.
The Agency estimates that about 40,000 facilities discharge
storm water associated with industrial activity to combined sewer
systems. These facilities are not included in EPA estimates of
facilities that have storm water discharges associated with
industrial activity which require NPDES permit coverage.
3.8 Summary - Facilities with Storm Water Discharges Associated
with Industrial Activity
Table 3-7 provides estimates of the number of facilities
with storm water discharges associated with industrial activity
that are expected to have to obtain NPDES permit coverage. These
estimates exclude facilities which discharge storm water to
combined sewers. Based on an assessment of the various estimates
used to reach these numbers, an error of plus or minus 50,000 can
be expected.
For the following categories, estimates of the total number
of facilities were reduced to only address facilities with storm
water discharges associated with industrial activity:
Resource Extraction - The estimates provided in Table 3-7 only
address facilities with contaminated storm water discharges which
are required to submit permit applications under 40 CFR
122.26(c).
Waste Disposal - Estimates of facilities in the waste disposal
category only addresses facilities which are not otherwise
addressed under the manufacturing category. The majority of
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waste disposal facilities receive waste from on-site a
manufacturing plant, and are counted as a manufacturing facility
in this report.
Subtitle D landfills or other waste disposal units are only
addressed by the regulatory definition of storm water discharges
associated with industrial activity if they receive industrial
wastes.
POTWs which route storm water from the facility through the
treatment works are not included in these estimates.
Transportation Only transportation facilities in the identified
SIC codes are only addressed by the regulatory definition of
storm water discharge associated with industrial activity if they
have vehicle maintenance shops, equipment cleaning operations or
airport deicing.
Power Plants Coal pile runoff from steam electric facilities is
subject to an effluent limitations guidelines. These facilities
should have permits for these discharges. Only facilities with
storm water discharges associated with industrial activity that
is not covered by an existing NPDES permit are addressed.
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TABLE 3-7
TOTAL NUMBER OF FACILITIES ADDRESSED BY REGULATORY DEFINITION
OF STORM WATER DISCHARGE ASSOCIATED WITH INDUSTRIAL ACTIVITY
(Excluding facilities which discharge to combined sewers)
Category • Number of facilities
Resource Extraction
Mining with contaminated runoff 10,500
Oil and gas operations with 23,000
contaminated runoff
Manufacturing (SIC codes 24(except 2434), 53,100
(26 (except 265 and 267), 28
(except 283), 29, 311, 32 (except 323),
33, 3441, 373)
Manufacturing (SIC codes 20, 21, 22, 23, 10,000
2434, 25, 265, 267, 27, 283, 285, 30,
31 (except 311), 323, 34 (except 3441),
35, 36, 37 (except 373), 38, 39, 4221-25)
Construction
Residential 13,000
Non-residential 13,000
Waste Disposal facilities
Subtitle C RCRA facilities which receive 450
wastes generated offsite
Subtitle D RCRA facilities 6,500
Recycling facilities 2,300
POTWs 1,500
Transportation facilities 19,000
Power generation 650
TOTAL 153,000
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3-18
3.9 Special Classes of Facilities
3.9.1 Small Businesses
There is no standard size definition of a small business1.
For the purposes of developing permit application requirements,
EPA defines small businesses at 40 CFR 122.21(g)(8) as coal mines
with a probable total annual production of less than 100,000 tons
per year, and for all other applicants, businesses with gross
total annual sales averaging less than $100,000 per year (in
second quarter 1980 dollars or approximately $150,000 in 1990
dollars). This provision exempts small businesses from permit
application monitoring requirements for certain organic
chemicals.
Alternatively, small business can be defined in a number of
ways, including in terms of gross total annual sales and number
of employees. Around 32 percent of business have gross total
annual sales of $220,000 or less, and 55 percent have gross total
annual sales of $575,000 or less (see "The Annual Report on Small
Business and Competition" (1989), The U.S. Small Business
Administration).
Some statistics on distribution of manufacturing facilities
within different SIC codes and the number of employees are
presented in Table 3-8. Note that all facilities identified in
Table 3-8 are not addressed by the regulatory definition of storm
water discharge associated with industrial activity.
SARA Title III, Section 313 only.applies to facilities with
10 or more full time employees. Therefore no small businesses
with less than 10 or more full time employees are subject to the
special requirements of these permits for these facilities. In
addition, SARA Title III, Section 313 establishes thresholds for
the amount of chemical that the facility manufactured (including
imported), processed, or otherwise used a toxic chemical. After
1989, the threshold quantity of listed chemicals that the
facility must manufacture, import or process in order to be
required to submit a release report is 25,000 pounds per year.
The threshold for a use other than manufacturing, importing or
processing of listed toxic chemicals is 10,000 pounds per year.
EPA believes that the amount of toxic chemical a facility
manufactures, processes or otherwise uses generally correlates
well with the size of the facility. For this reason, the Agency
believes that the number of facilities with toxic chemicals
subject to SARA Title III, Section 313 is disproportionately
distributed towards larger facilities.
1 "The Annual Report on Small Business and Competition",
1989, U.S. Small Business Administration.
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3-19
TABLE 3.8
1987 CENSUS OF MANUFACTURERS
TOTAL NUMBER OF MANUFACTURING FACILITIES
AND FACILITIES WITH LESS THAN 20 EMPLOYEES
ESTABLISHMENTS ESTABLISHMENTS ESTABLISHS,
NUMBER OF WITH LESS THAN
THAN
SIC GROUP ESTABLISHMENTS 20 EMPLOYEES
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
2m
37
38
39
40
41
42
44'
45
food
tobacco
textile
apparel
lumber and wood
furniture
paper
painting
chemicals
petroleum
rubber and plastic
leather
stone, clay and glass
primary metals
fabricated metal
1 industrial machinery
electronic
transportation equip.
instruments
misc, manu.
railroad trans.
local & iu transp.
trucking & warehou
water transportat
air transport.
20,624
138
6,421
22,872
33,982
11,613
6,342
61,774
12,109
2,254
14,515
2,193
16,166
6,771
36,105
52,135
15,962
10,500
10,326
16,544
255
9,889
69,106
6,638
5,505
10,930
55
2,975
13,335
26,594
7,559
2,179
49,179
7,192
1,500
7,247
1,283
11,047
3,083
22,198
38,243
8,398
6,248
6,242
12,890
151
6,694
58,868
5,605
4,684
WITH LESS THAN WITH LESS
10 EMPLOYEES 5 EMPLOYEES
8,045
34
2,514
10,127
16,055
7,260
1,429
41,446
6,154
750
5,084
1,615
7,726
2,272
16,358
35,272
8,714
5,572
6,357
14,954
108
4,865
49,013
4,765
3,995
4,167
22
1,993
6,358
9,686
4,259
675
24,417
3,240
358
2,730
1,111
4,366
1,112
8,725
20,281
4,906
3,268
3,660
9,574
43
2,872
34,200
3,278
2,547
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3.9.2 Facilities subject to RCRA
All 4,484 facilities classified as hazardous waste
treatment, storage, or disposal facilities (TSDFs) under RCRA
Subtitle C are addressed by the regulatory definition of storm
water discharge associated with industrial activity. An
estimated additional 9,500 to 12,500 facilities which have
notified EPA as generators of hazardous waste are addressed by
the regulatory definition of storm water discharge associated
with industrial activity.
3.9.3 Facilities subject to SARA Title III, Section 313
The Superfund Amendments and Reauthorization Act (SARA) of
1986 resulted in the enactment of Title III of SARA, the
Emergency Planning and Community-Right-to-Know Act. Section 313
of Title III of SARA requires operators of certain facilities
that manufacture, import, process, or otherwise use listed toxic
chemicals to report annually their releases of those chemicals to
any environmental media. Listed toxic chemicals include 329
chemicals listed at 40 CFR 372.
Facilities that meet all of the following criteria for a
calendar year are subject to Title III reporting requirements for
that calendar year and must report under 40 CFR 372.30:
o The facility has 10 or more full-time employees;
o The facility is a multi-establishment complex where all
establishments have a primary SIC code of 20 through 39;
o The facility is a multi-establishment complex in which one
of the following is true:
- The sum of the value of products shipped and/or
produced from those establishments that have a primary
SIC code of 20 through 39 is greater than 50 percent of
the total value of all products shipped and/or produced
from all establishments at the facility;
- One establishment has a primary SIC code of 20 through
39 and contributes more in terms of value of products
shipped and/or produced than any other establishment
within the facility;
o The facility manufactured (including imported), processed,
or otherwise used a toxic chemical in excess of an
applicable threshold quantity of that chemical set forth in
40 CFR 372.25.
After 1989, the threshold quantity of listed chemicals that
the facility must manufacture, import or process in order to be
-------
3-21
required to submit a release report is 25,000 pounds per year.
The threshold for a use other than manufacturing, importing or
processing of listed toxic chemicals is 10,000 pounds per year.
EPA estimates that 35,000 facilities nationwide will be subject
to SARA Title III reporting requirements after 1990. EPA
promulgated a final regulation clarifying these reporting
requirements on February 16, 1988 (53 FR 4500).
SARA Title III, Section 313 facilities are subject to
special requirements in the NPDES storm water general permits if
they meet the following two criteria:
o The facility has a "storm water discharge associated with
industrial activity".
- Many SARA Title III, Section 313 facilities will not
have a storm water discharge associated with industrial
activity because areas where industrial activity occur
are not exposed to storm water.
o The facility has a "Section 313 water priority chemical" in
amounts above threshold levels established by SARA Title
III, Section 313.
- Section 313 water priority chemicals include 175 of the
329 chemicals or chemical categories which are both:
listed under Section 313 of Title III of SARA; and are
on one of three lists of chemicals developed under the
NPDES program (e.g. priority pollutants and certain
other toxic and hazardous pollutants).
Information from the 1989 TRIS data base indicates that
about 22,000 facilities are subject to SARA Title III, Section
313. The Agency estimates that 12,000 of these facilities are
subject to SARA Title III, Section 313 for water priority
chemicals. EPA estimates that, nationwide, 5,700 of the 22,000
facilities subject to SARA Title III, Section 313 for water
priority chemicals will also have storm water discharges
associated with industrial activity. Of these 5,700 facilities,
about 4,275 facilities will have to obtain NPDES permit coverage
for their storm water discharges associated with industrial
activity, as about 25% of the facilities will discharge to
combined sewers and do not need NPDES permits.
3.9.4 Facilities with coal piles
Coal is used as a boiler fuel in a number of industries
which require large amounts of steam such as electric power
generation, metal manufacturing, and certain chemical processes.
Coal is also used as a source of carbon in certain metallurgical
and chemical processes. Nationwide, electric utilities use about
-------
3-22
77% of the coal produced, coke plants about 4%, other industries
about 7.5% (see "Coal Distribution, January-December 1988",
Energy Information Administration, DOE/EIA-0125(88/4Q). Over 50%
of domestic distribution of coal in the United States is by rail,
12% by truck, 13% by tramway or slurry pipeline and 15% by water
(IBID).
Coal mines and other production facilities are discussed in
detail in the "Development Document for Effluent Limitations
Guidelines and Standards for the Coal Mining Point Source
Category". Over 940 coal distribution companies are identified
in that reference.
3.9.5 Facilities with salt piles
Salt is used by industrial facilities for a number of
purposes including as a raw material (e.g. food industry), as a
catalyst, and for deicing purposes. Brine solutions can also be
used for restoring resins.
3.9.6 Facilities with effluent limitations guidelines for storm
water
EPA has developed effluent limitations guidelines for storm
water discharges from a number of industrial subcategories.
These subcategories, and a description of the effluent
limitations guidelines are provided in Table 3-9.
-------
SUMMARY OF POINT SOURCE CATEGORIES SUBJECT TO STORM WATER EFFLUENT LIMITATIONS GUIDELINES
Catafory
Cemenl
Manufacturing
PeedloU
Fertilizer
Manufacturing
Regulatory
CiUtioo
40CFR411
40 CFR 412
40 CFR 418
Cofcrcd Discharges
Runoff from material
stora(o piles
Any pncipiutioa which
come* into contact with
manure, bedding, or
any other raw material
or intermediate or final
material or product
used in or resulting
from the production of
animals or poultry or
direct products (e.g.,
milk, eggs)
Precipitation runoff
which has come into
contact with any raw
material, intermediate
product, by-product, or
waste product
•For Subparts 3 and P,
it is unclear whether or
not storm water is
intended to be included
in the definition of
process waslcwalcr
Applicable
Subparts
All Subparts
Subpart A - All
subcatcgories
excent ducks
•••s*|n uuuu
Subpart B -
Ducks
Subpart A -
Phosphate
Subpart B -
Ammonia
Subpart P -
Ammonium
suifate
production
Legal
Standard
BPT
BPT
BAT
BPT
BPT
BPT
BPT
Design
Storm
10 yr.
24 hr.
10 yr.
24 hr.
25 yr.
24 hr.
Not
Specified
Not
Specified
Not
Specified
Not
Specified
Parameter
TSS
PH
BODS
Fecal coliform
Total phosphorus
Fluoride
Ammonia
PH
f>*
CoaccotratBM
Not to exceed 50 0a/|
6.0 - 9.Q . _
VW'&P'
No discharge of proecM «B*stMlcr
poUutaoU
NodischarfD
Maximum for any I
o>j
'"'IHW ***•*«
1.66 0.91
Not to exceed mpn of 400/100 ml at any
lime
(units -kg/I. 000 ducks)
Maximum for any 1
day
I05mg/l
75mg/l
3O-d»y avenge
35mg/l
25mg/l
0.1175 0.0625
6.0 - 9.0 6.0 - 9.0
(units - kg/kkg of product)
No discharge
-------
Category
Fertilizer
Manufacturing .
(Continued)
Regulatory
CiUtira
Covered Dbcaarg.es
Precipitation runoff
from outside the battery
limiu of the manu-
ticfiifiiiff fmentinna
cwhidcd
Applicable
SubparU
Subpart C -
Urea
Legal
Standard
BPT
BAT
Dafea
Storm
Not
Specified
Not
Specified
Parameter
Urea produced a* a
solution:
Ammonia
Organic Nitrogen
Urea prilled or
granulated:
Ammonia
Organic Nitrogen
Urea produced a* •
solution:
Ammonia
Organic Nitrogen
Urea prilled or
granulated:
Ammonia
Organic Nitrogen
Coocrnlraliua
|H| aximiim for any 1
o;: ''day V T =
304»| average
o.9s ».a
0.61 r^A*J»|
(uniu - kg/I .000 k( of pradua)
Maximum for «ny I
day':
30-dj^Wwage
1.18 0.59
1.48 0.80
(uniu - kg/1,000 kg of product)
MAumum foi* my 1
day
30-day avenge
0.53 0.27
0.45 0.14
(uaiu - kg/1.000 kg of product)
WitomtHvni
i-^',?;'c4»y- "::
|ff JfVW
0.53 0.27
0.86 0.46
(unite - kg/I ,000 kg of product)
-------
Category
Fertilizer
Manufacturing
(Continued)
Petroleum
Refining
Regulatory
Cbatioa
40 CFR 419
Covered Discharge*
Runoff contaminated by
contact with any raw
material, intermediate
product, finished
product, by-product, or
waste product located
on petroleum refinery
property
Applicable
Subparto
Subpart D -
Ammonium
Nitrate
AUSubparU
Legal
Staadard
BPT
BAT
BPT
Data
Storm
Not
Specified
Not
Specified
Not
Specified
Parameter
Ammonia
Nitrate
Ammonia
Nitrate
For discharge*
composed entirely of
contaminated runoff
(not commingled or
treated with process
waslcwalcr)
Oil and grease
TOC
ConrnitratioD
MjMimum for any || Sff^ ifjlp"**
0.73 OJ»
0.67 f J|||
(units - kg/1 .000 kg cjfjpdbot)
:' . = .• • 'Ma%$$M®&.
Maximum for any 1 lifii^i&pK6
**** •- •• • . ; '.y.-'.fi-'. •• :'f •••'•: *'••'
0.08 0.04
0.12 0.07
(unit* - kg/1 ,000 kg of product)
15mg/l
llOmg/1
-------
Category
Petroleum
Refining
(Continued)
Regulatory
Citation
40 CFR 419
Covered Discharges
Applicable
SubparU
Legal
Standard
BPT
Design
Storm
Not
Specified
Parameter
If contaminated
runoff ii commingled
or treated with
process wastewalcr
or if wailcwaler
consisting solely of
contaminated runoff
which exceed* 15
mg/1 oil and grease
or 110 mg/1 TOCii
not commingled or
treated with any
other type of
wMtewaler. the
quantity of pollutant*
discharged shall ml
exceed the quantity
determined by
multiplying the How
of contaminated
runoff ai determined
by the permit writer
limes the
concentrations lined
below:
Concentration
-------
Category
Petroleum
Refining
(Continued)
Phosphate
Miniifetfliiriftff
•WB—*li""1 11M •"•
Regulatory
Citation
40CFR422
Covered Discharge*;
Runoff oonuminated by
contact with any nw
material, intermediate
product, finished
product, by-product, or
wade product located
on petroleum refinery
properly (Continued)
finruiff rk
|pin»|»«M»w •CT-H.
Subpart B-
Defluorinalcd
phosphoric acid
Legal
Standard
BPT
(Continued)
BAT
BPT
Design
Storm
Not
Specified
Not
Specified
Not
Specified
Parameter
BODS
TSS
COD
Oil and grease
Phenolic compounds
(4AAP)
Total chromium
Hexavalent
chromium
PH
Phenolic compounds
(4AAP)
Total chromium
Heuvalcnl
chromium
COD
.»»
Total phosphorus
Fluoride
pH
dmrmtr
Mtxiinvin f?r inv 1
4«y
48
33
360
15
0.35
0.73
0.062
6.0 - 9.0
(metric units - kg per
Maximum tor any 1
day
0.35
0.60
0.062
360
(metric units - kg per
Mf n unufh f*r *ny 1
day
I05mg/l
75mg/l
6.0 - 9.5
tt'f
30rd»)r »verage
*
26
} i*rtfl
^li9*pBn|v
"r.^lP
•
0.17
0.43
0.02S
6.0 - 9.0
1,000m* of How)
30-day avenge
0.17
0.21
0.02S
110
1 ,000m' of flow)
30-da|fvcragc
35mg/l
25mg/l
6.0 - 9.5
-------
Catafory
Phosphate
Manufacturing
(Continued)
Steam Electric
Power
Generating
Coal Mining
Regulatory
Citation
40CFR423
40CFR434
Covered Discharges
(Continued)
•For Subpart F it U
vnckrar whether or not
storm water is intended
to be included in the
definition of process
wastewatcr
Runoff from coal piles
Discharges from coal
refuse disposal piles
Applicable
Subparts
Subpart F -
Sodium
phofphatfft
Subpart B -
Coal
preparation
plants and coal
preparation
nytnf §|iocialfMfl
areas
Legal
Standard
BPT
BPT
BPT
Dots)
Storm
Not
Specified
10 yr.
24 hr
Less than
lyr.
24 hr.
Parameter
TSS
Total phosphorus
Fluoride
pH
TSS
PH
PCBs
Normal pH of less
than 6.0 prior to
treatment:
Iron, total
TSS
pH
Normal pH i 6.0
prior to treatment:
Iron, total
TSS
PH
roafcarrarioa
Maximum for any 1
day
0.50
0.80
0.30
6.0 - 9.5
$May average
••;;':plfe:;-
0.25
jt$
•'*eflL19
i
6.0 - 9.5
(units - kg/kkg of product)
50 mff/l maiimun
tat any time
6.0 - 9.0 at all limes
No discharge
Maximum for any 1
day
7.0 mg/1
4 0 mg/1
70 mg/1
30-day average
3.5 mg/1
2 0 mo/I
35 mg/1
6.0 • 9.0 at all times
Maximum tat any I
7.0 mg/1
70 mg/1
30-day avenge
3.5 mg/1
35 mg/1
6.0 - 9.0 at all times
-------
Category
Coal Mining
(Continued)
Regulatory
CiUtioo
Covered Discharge!
Discharges from
reclamation areas
Discharges from coal
preparation plants and
associated areas,
excluding coal refuse
piles; discharges from
steep slope areas and
mountain top removal
areas; discharges of
alkaline mine drainage
except discharges from
underground workings
of underground mines
that are not
commingled with other
discharges eligible for
alternate limitation*
Applicable
SubparU
Subpait B -
Post-mining
areas
Subpait B
Subpait D -
Alkaline mine
drainage
Legal
Standard
BPT
BPT
Design
Storm
Greater
than
lyr.
24 hr.
but less
than or
equal to
10 yr.
24 hr.
Greater
than
10 yr.
24 hr.
Less than
10 yr.
24 hr.
Greater
than
10 yr.
24 hr.
Less than
or equal to
10 yr.
24 hr.
Greater
than
10 yr.
24 hr.
Parameter
Senleable solids
pH
PH
SeUlcable solids
pH
pH
Scttkabk solids
PH
PH
Coocmlralion
0.5 ml/1 maximum not to be exceeded
6.0 • 9.0 at all times
6.0 - 9.0 at all times
0.5 ml/1 maximum not to be exceeded
6.0 - 9.0 at all limes
6.0 - 9.0 at all limes
0.5 ml/1 maximum not to be exceeded
6.0 - 9.0 at all limes
6.0 - 9.0 at all limes
-------
Category
Coal Mining
(Continued)
Regulatory
ChaUosi
Co? end Discharge*
Controlled discharges
of acid or ferruginous
surface mine drainage
and acid or ferruginous
doiaagefrom
underground workinp
of underground mines
which are commingled
with other discharges
eligible for these
alternate limitations
Non-controlled acid or
ferruginous surface
mine drainage (except
sleep slope and
mountain top removal
areas)
Discharges from
underground workinp
of underground mines -
not commingled
Applicable
Subparti
SubpartC-
Acid or
ferruginous
mine drainage
SubpartC
SubpartC
SubpartD
SubpartB
Legal
Standard
BPT
BPT
Design
Storm
Less than
10 yr.
24 hr.
Greater
tllaUl
10 yr.
24 hr.
Less than
or equal to
2yr.
24 hr.
Greater
than
2 yr.
24 hr.
but less
than
10 yr.
24 hr.
Greater
10 yr.
24 hr.
Parameter
Iron, total
Manganese, Total
TSS
pH
•T
pH
Iron, total
Sctllcable solids
PH
Scukable solids
pH
pH
Conceal ratio*
Maitnnim fnr anv 1
™7.~-V"™" *"• TT* •
day
7.0 mg/1
4.0 mg/1
70.0 mg/1
3
-------
Category
•• "•"" f
Mineral Mining
Regulatory
Citation
40CFR436
Covered Discharge*
Runoff which become*
commingled with any
waslcwater used in the
slurry transport of
mined matt ri*l fir
emissions control, or
processing exclusive of
mining. Also included
are mine dewalcring
discharges, defined as
any water that is
impounded or that
collects in the mine and
is pumped, drained, or
otherwise removed
from the mine.
Applicable
Subpftrts
Subpart B-
Crushed stone
Subpart C -
Construction
sand and gravel
Subpart R -
Phosphate rock
Subpart AL -
Graphite
Legal
Standard
BPT
BIT
BPT
Design
Storm
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
• • /•"
24 hr.
Parameter
PH
TSS
PH
TSS
Total Iron
PH
fnarfitratfo*
6.0 - 9.0
(pH limitation may be adjusted downward
criteria in water qp*)t$y atwtatd*
approved under the Afl| f^£|f|^ such
lower pH and if the di
tsokatf* (paltered
by man's activity would h*v» a pH of
less than 6.0)
Maximum for any }
day
60mg/l
6.0 - 9.0
aVJat*«n**im £*a* *MH 1
>-">dar: ••••
20mg/l
2mg/l
6.0 - 9.0
30-day avenge
30mg/l
6.0 - 9.0
30*d»y avenge
I0mg/l
1 mg/1
6.0 - 9.0
-------
CaUgon
Mineral Mining
Regulatory
Citation
Covered Discharges
•
Applicable
Subparta
SubpartD -
(i) Discharges
of process-
generated
wastewatcr
bom fscilflics
that recycle
waslewater
except
(ii) Discharges
from facilities
employing HP
flotation
(uj) All other
discharges of
process-
generated
waslewater
(iv)Mine
dewatering
discharges
Legal
Standard
BPT
BFT
Stem
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
24 hr.
Parameter
£££££»
TSS
TSS
Total fluoride
TSS
<*«-«*.
6.0 - 9.0
(see note under Subparta B and C above)
Msiimvin for anv 1 ::• ' ? M sail itlJSBSiui
F'PW- .'J™ ~? **V ? :.. jggBJSaHfclT^ *
I
Maximum for any 1 30~day average
day :: ;:: '!•.'•• .':' '
0.046 0.023
0.006 0.003
(units - kg/kkg final product)
No discharge
Muiouim for any } JO^lay average
day '
45 mg/1 25 og/1
10
-------
Category
Mineral Mining
(Continued)
Regulatory
Citation
Covered Discharges
Applicable
SubparU
SubputB-
Gypium
Subp.it F-
Aiphahic
mineral
Subp.it G-
Aibeilotand
Wollastonite
SubputM-
Bonx
Subp.it N-
Potaib
SubputO-
Sodium (ulfiue
SubputS-
Pratch sulfur
SubputW-
Magncaitc
Subp.it X -
DuOomitc
SubpartY-
Jade
SubpartZ-
Novaculite
Legd
Standard
BPT
Doigo
Storm
10 yr.
24 hr.
ParaBeter
CoBftBtratioa
Nodiicnarge
-------
Category
Mineral Mining
(Continued)
Ore Mining and
Dressing
Regulatory
CkalfeB
\
40CFR440
Covered Dischargca
Runoff from the
drainage area of the
facility
Applicable
SubparU
SubpartJ-
Barite
SubpartK-
Ruonptr
Subparl L -
Saline* from
brine lake*
Subpart V-
Bcnlonitc
Subpart AF-
Tripoli
All remaininf
SubparU
rctcrved
Subpart A -
Iron ore
Subpart D -
Mercury on
Legal
Standard
BIT
BPT
BPT
Doign
Storm
Not
Specified
10 yr.
24 hr.
10 yr.
24 hr.
Parameter
TSS
Iron (dissolved)
PH
TSS
Mercury *
Nickel
PH
CoocralralkM
No discharge
Maximum for any 1 30-day average
day
30 mg/1 20 mg/l
2.0mg/l |.0_ig/l
6.0 - 9.0 6.0 - 9.0
Maiimun for any 1 30-day tvctage
day ' ' ;"' '•''
30 mg/1 20 mg/l
0.002 mg/l 0.001 mg/l
0.2 mg/l O.I mg/l
6.0 • 9.0 6.0 - 9.0
12
-------
Category
Ore Mining and
Dressing
(Continued)
Regulatory
Ckaliosi
Covered Discharges
Runoff from the
drainage area of the
facility (Continued)
Surface runoff which
has commingled with
mine drainage or
waters resulting from
the bencficiation
process
Surface runoff
incorporated into mine
drainage
•Storm water only
indirectly included in
the phrase "mine
drainage'
Applicable
Subparts
Subpait J-
Copper, lead,
zinc, gold,
silver, and
molybdenum
ores
Subpait M -
Gold placer
mine
Subpait B -
Aluminum ore
Legal
Standard
BPT
BAT
BPT
BPT
Design
Stem
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
24 hr.
Parameter
TSS
Copper
Zinc
Lead
Mercury
PH
Copper
Zinc
Lead
Mercury
Cadmium
Settleabk solids
.t->
TSS
Iron
Aluminum
PH
Concentration
Lf •limiun fi** ftntf 1
; •'' 4»'-:"" .
0.30 mg/1 mliBffiEtfl
1.5 mg/1 ' OflVsag/1
0.6 mg/1 0 J sag/1
0.002 mg/1 0.001 mg/1
6.0 - 9.0 6.0 - 9.0
0.30 mg/
I.S mg/1
0.6 mg/1
0.002 mg/1
0.10 mg/1
0.15 mg/1
0.75 mg/1
0.3 mg/1
O.QOI mg/1
0.05 mg/1
0 2 ml/1 ifivtinitiinffTirf ouxioiuni
LfBVtfiniiii far AAV 1
. „„_ : .
34h*»» f Average
30 mg/1 20 mg/1
1 .0 mg/1 0.5 mg/1
2.0 mg/1 1.0 mg/1
6.0 - 9.0 6.0 • 9.0
-------
c^n
Ore Mining and
Dressing
{Continued^
I
Rcgulat4M7
ClUtio.
•
Surface runoff
beorporated into mine
drainan (Continued)
Applcabk
Subparti
SubpartC -
Uranium,
radium, and
vanadium ore*
SubpartB-
Tktuuufli on
si±^
BPT
BPT
BPT
Dolt*
Storm
10 yr.
24 hr.
10 yr.
24 hr.
10 yr.
24 hr.
far,—
Excluduiff minea
using in-iku leach
methods:
TSS
COD
ZINC
Ra 226 (dissolved)
Ra 226 (total)
Unniiun
pH
Mines using in-silu
Inch method* and
above except:
COD
All mine drainage*:
TSS
Iron
pH
Discharges from
milU-
TSS
Zinc
Nickel
pH
CoacoUr
Maximum for any 1
day '
30mg/l
200mg/l
l.Omg/l
IOpCi/1
30pCi/l
4mg/l
6.0 • 9.0
Maximum for ua 1
day
M
•lioai
Tsr"
2o*yi
yns^utuiii
,P;jiHBpy
0(1*1/1
SpCiA
lOpCiA
2mg/l
6.0 - 9.0
3Qsby*vc*>4C
500mg/l
;:.- •: • :•'. • . .... .V |
Maximum fw any 1 I 3Q-4*y avijngo
K':T *F":: 1
30mg/l
2.0mg/l
6.0 • 9.0
liijj^^^
30mg/l
l.Orog/1
0.2mg/l
6.0 - 9.0
20 o^
l.Omg/l
6.0 • 9.0
s
20 BBC/1
O.Smg/1
O.lmg/1
6.0 - 9.0
14
-------
Category
Ore Mining and
Dreaiing
•
Bcgublory
CftatkM
Covered Dbcbargtt
Surface runoff
•incorporated into mine
drainage (Continued)
Appicable
Subparti
Subpart P-
Tungatcnore
Subpart O -
Nickel ore
Subpart H -
Vanadium ore
LtMl
StaWard
BPT
Dcafci
10 yr.
24 br.
Parameter
Drainage* from
mince producing
5,000 metric loot or
more:
TSS
Copper
Zinc
Lead
Drainage from mine
producing 5,000
metric ton* or more
(Continued):
Anenic
pH
Mill* proccuing
5,000 metric loot or
more:
TSS
Cadmium
Copper
Zinc
Ancnio
•**:'
pH
producing leu tban
5,000 metric lom:
TSS
PH
fmuHMi,.
Mininimfrrtiirt*
•i
-$
30 mg/l
0.10mg/I
0.3 mg/l
l.Omg/1
0.6mg/l
Miijnunti for aay t
l.Omg/1
6.0 - 9.0
Maximum tnr anv 1
Mmg/l
0.10mg/l
O.Mmg/l
l.Omg/1
l.Omg/1
6.0 - 9.0
*•*-*•»»
50mg71
6.0 - 9.0
WfSS&r
0.5 Mi/1
0.3ng/l
ff =• < ••
-------
Category
Ore Mining and
DreMing
(Continued)
Paving tod
Roofing
Material*
Regulatory
Citation
40CFR443
Covered Dbeharga
All rainwater runoff
containing pollutant*
Appficabie
Subparta
Subp«rt K-
Platinum ore*
Subptrt 1 -
Antimony ore
(reserved)
SubpaitA-
Asphak
TjUvlriftii
Legal
Standard
BPT
BPT
BAT
DC*.
Storm
10 yr.
24 hr.
Not
Specified
Not
specified
Parameter
Mince other than
placer:
i*opp0
Zinc
Lead
Mercury
Cadmium
Mills, ume ai mine*
except:
yiiK1
Oil andgrcaae
pH
TSS
Oil andgrcaw
pH
CoacentratiM
MakimMm for any 1
da,
0.30 mg/1
l.Smg/1
0.6 mg/1
0.002 mg/1
0.10 mg/1
Matimuin tnt anv 1
•nTnirrinm w* »«^ f
•fey
1.0 mg/1
Maximum for any 1
•ivi •:"••'.;' ':day '.:.:':: ::- ' 4
0.020
6.0 - 9.0
3(May average
, ••,-: i^-
O.lSng/1
AiflSff^
'^^F1
0.091 *B/I
0.05 pi/1
««^4^^rP
IQ^yavencr
O.Smg/1
v^i.if^'6
HK-VjixJ-iSSiJin-;..:;- .
O.OIS
6.0 • 9.0
(unit* - kg/a* of nmofl)
Mutant for aay 1
4»»
0.023
0.015
6.0 • 9.0
aWiffWBiH*
O.OIS
0.010
6.0 • 9.0
(unit* - kg/m' of nmofl)
t >*
16
-------
dietary
taring tad .
Roofing
Material*
(OiNi(iiMM>*l)
Regulatory
Ckatkui
40CFR443
Covered Dbcaarga
Any water which coma
into direct contact with
•ay raw material,
loftfinBMiiate DtodiKi
M^MMMMMM^MW |r«MMWW«t
JjpajBdvct. or product
MM ip or resulting
pram production
•Tail definition of
itrnnm ian*t**wtar
only indirectly inctudet
•lorm water in the
phrase "any water"
Applicable
Subparts
SubpartB-
Aaphak
concrete
SubpartC-
Aaphafe roofing
SubpartD-
Linoleum and
printed uphak
feft
Legal
SUadard
BIT
BPT
BAT
BPT
BAT
Doico
Stora
Not
Specified
Not
Specified
Not
Specified
Not
Specified
Not
Specified
Parameter
TSS
PH
TSS
pH
TSS
pH
TSS
pH
•*•
Cooccatratioa
Nodttcharge
•laximuiB lor aar t T
' *> '1
ififr""
0.056 ^^iiM
I
6.0 - 9.0 6.0 - 9.0
(uniu - kg/kkg of product)
Mftvhnini ^^ >nv 1
daf
$Q*dajr average
0.021 0.019
6.0 - 9.0 6.0 - 9.0
(uniu - kg/kkg of product)
HtnHr"tn for any 1
:'"-' • *iy . :
'; 9
-------
CHAPTER 4 - NATURE AND EXTENT OF POLLUTANTS IN STORM WATER
DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
This chapter describes the nature and extent of pollutants
in discharges from storm sewer from industrial facilities. This
Chapter begins with a discussion of general factors which affect
pollutants in storm water discharges from industrial facilities
in section 4.1. Section 4.2 provides a summary description of
the nature and extent of discharges from separate storm sewers
from major classes of industrial facilities. The discussion in
section 4.2 addresses both a non-storm water component (illicit
connections, improper dumping, or spills) as well as a storm
water component to these discharges.
For the purposes of discussing the storm water component of
these discharges, the following major groups of facilities were
addressed:
o Mining and Oil and Gas Production Facilities
o Manufacturing. Industries
o Construction Industries
o Waste Management and Recycling Facilities
o Transportation Facilities
o Electric Power Generation
4.1 FACTORS AFFECTING POLLUTANTS IN DISCHARGES FROM SEPARATE
STORM SEWERS FROM INDUSTRIAL FACILITIES
For many non-industrial, non-municipal facilities and for
some industrial activities, the types and concentrations of
pollutants in storm water discharges will be similar to the types
and concentrations of pollutants generally found in storm water
discharges from residential areas. However, for other facilities
the potential for pollutants in storm water discharges from the
facility may be significantly higher than pollutant levels from
broader urban or developed areas. In addition, pollutant
loadings per unit area from some facilities may be high because
of a high degree of imperviousness.
Seven activities were identified for estimating the
potential for affecting pollutants in storm water discharges: 1)
loading or unloading of dry bulk materials or liquids, 2) outdoor
storage of raw materials or products, 3) outdoor process
activities, 4) dust or particulate generating processes, 5)
illicit connections or management practices, 6) waste disposal
practices, and 7) site specific or industry specific pollution
control requirements.
The potential for pollution from many of these activities
may be influenced by the use and presence of toxic chemicals.
4-1
-------
Table 4.1 provides estimates of the number of facilities which
have hazardous substances in amounts in excess of limits
established under SARA Title III Community Right-to-Know
requirements.
4-2
-------
M.I
Table f.1 • Facilities with 10,000 or mart pounds of
(azardous Chemicals or the loner of 500 or More pounds or. threshold planning quantities of Extremely Hazardous Substances
Proposed Reporting Units under Sections 311 and 312 of
Title III of the Superfund Amendments and Reauthorize!ion Act)
SIC CODE NUMBER OF FACILITIES
7 Agricultural Services 5,554
Manufacturers
20 Food Products 4.414
22 Tobacco Products 767
23 Textile Mill Products 520
24 Apparel Products 3,048
25 Lumber and Wood Products 1,746
26 Furniture and Fixtures 2,012
27 Printing and Publishing 4,111
28 Chemical and Allied Products 11,286
29 Petroleum and Coal Products 1,798
30 Rubber and Misc. Plastics Products 4,651
31 Leather Products 503
32 Stone, Clay and Glass Products 5,928
33 Primary Metal Industry 4,372
34 Fabricated Metal Products 13,660
35 Machinery, Except Electrical 5,951
36 Electric and Electronic Equipment 3,229
37 Transportation Equipment 1,676
38 Instrument and Related Products 1,658
39 Misc. Manufacturing 1,778
42 Trucking and Warehousing 119
45 Transporation by Air 3,043
46 Pipe Lines, Except Natural Gas 997
48 Comnunicietion 118
49 Electric, Gas and Sanitary Services 4,938
50 Wholesale Trade - Durable Goods 8,615
51 Wholesale Trade - Nondurable Goods 12,910
54 Food Stores 293
55 Auto Dealers and Service Stations 134,979
59 Miscellaneous Retail 72
72 Personal Services 2,875
73 Business Service 985
75 Auto Repair, Services and Garage 31,249
76 Miscellaneous Repair Services 3,337
80 Health Services 4,095
81 Legal Services 3,317
Total 290,604
Extremely hazardous substances and their respective threshold planning quantities are listed in 40 CFR 355. Extremely hazardous
substances have been identified pursuant to Section 302 of Title II as being particularly significant for emergency planning.
hazardous chemicals are defined under the Hazard Conmunication Standard promulgated by the Occupational Safety and Health
'Administration.
-------
1) Loading and unloading operations are typically performed
along facility access roads, railways, and at
loading/unloading docks and terminals. These operations
include pumping of liquids or gases from truck or rail car
to a storage facility or vice versa; pneumatic transfer of
dry chemicals to or from the loading or unloading vehicle;
transfer by mechanical conveyor systems; and transfer of
bags, boxes, drums, or other containers from vehicle by
fork-lift trucks or other materials handling equipment.
Material spills or losses in areas can discharge directly to
the storm drainage systems, or may accumulate in soils or on
surfaces, and be washed away during a storm event or
facility washdowns.
2) Outdoor storage activities include the storage of fuels, raw
materials, byproducts, intermediates, final products, and
process residuals. Storage can be accomplished in various
ways, for example, using storage containers (e.g., drums or
tanks), platforms or pads, bins, silos, boxes, or piles.
Materials, containers, and material storage areas that are
exposed to rainfall and/or runoff can contribute pollutants
to storm water when solid materials wash off or materials
dissolve into solution.
3) Other outdoor activities include certain types of
manufacturing and commercial operations, waste treatment,
and land-disturbing operations. Although many manufacturing
activities are performed indoors, some activities, such as
timber processing, rock crushing, and cement making,
typically occur outdoors. Processing operations can
result in liquid spillage and losses of material solids to
the drainage system or surrounding surfaces, or creation of
dusts or aerosols, which can be locally deposited.
Some outdoor industrial activities cause substantial
physical disturbance of land surfaces that result in soil
erosion and transport by storm water. Examples where
disturbed land occurs include construction, mining, and
feedlots. Disturbed land can result in soil losses and
other pollutant loadings associated with increased runoff
rates.
Facilities whose major process activities are conducted
indoors may still apply chemicals such as herbicides,
pesticides and fertilizer outdoors for a variety of
purposes.
4) Dust or particulate generating processes include industrial
activities with stack emissions or process dusts that settle
on plant surfaces. Localized atmospheric deposition is a
particular concern with heavy manufacturing industries. For
4-4
-------
example, monitoring of areas surrounding smelting industries
has shown much higher levels of metals at sites nearest the
smelter (Bearington 1977). Other industrial sites, such as
mines, cement manufacturing and refractories, will generate
significant levels of dusts.
5) Illicit connections or inappropriate management practices
result in improper non-storm water discharges to storm sewer
systems. In some cases, non-storm water connections to
sewer systems predate their legal prohibition, and facility
operators may be unaware of the actual configuration of
their systems. The likelihood of illicit discharges to
storm water collection systems is expected to increase for
older facilities as well as for those facilities that use
high volumes of process water or that dispose of significant
amounts of liquid wastes, including process waste waters,
cooling waters and rinse waters.
Pollutants from non-storm water discharges to the storm
sewer system of industrial facilities are typically caused
by a combination of improper connections, spills, improper
dumping and a belief that the absence of solids in a
discharge is equivalent to the absence of pollution.
Illicit connections are often associated with floor drains
that are connected to separate storm sewers. Rinse waters
used to clean or cool objects discharge to floor drains
which may be connected to separate storm sewers. Large
amounts of rinse waters may originate from industries that
utilize regular washdown procedures, for example, bottling
plants use rinse waters for removing waste product, debris
and labels. Rinse waters can be used to cool materials by
dipping, washing or spraying objects with cool water, for
example, rinse water is sometimes sprayed over the final
products of a metal plating facility for cooling purposes.
Condensate return lines of heat exchangers often discharge
to floor drains. Heat exchanges, particularly those used
under stressed conditions such as within the metal finishing
and electroplating industry, typically develop pin-hole
leaks, which may result in contamination of condensate by
process wastes. These and other non-storm water discharges
to a storm sewer may be intentional, based on the belief
that the discharge (in this case condensate), does not
contain pollutants, or it may be inadvertent, for example,
the operator may be unaware that a floor drain is connected
to the storm sewer.
Spills often accompany material management activities. The
Emergency Response Notification System (ERNS) indicated that
about 62% of spills of hazardous substances exceeding a
reportable quantity that were reported in 1989 were to land
or water (3,153 spills to water, 858 spills to land). The
4-5
-------
ERNS data base for 1988 that over half of the releases of
hazardous substances and oil reported were from fixed
facilities (18,824 releases from fixed facilities)
6) Waste management practices include the operation of
landfills, waste piles and land application sites which
involve land disposal. Outdoor waste treatment operations
also include waste water and solid waste treatment and
disposal processes, such as waste pumping, additions of
treatment chemicals, mixing, aeration, clarification, and
solids dewatering. Table 4-2 provides estimates of the
volume of wastes generated by various types of industrial
facilities. These types of facilities often conduct some
waste management on site. Other off-site waste management
units will be addressed as a distinct category of
facilities.
4-6
-------
ABLE /f-2. NUMBER OF LANDFILLS, LAND APPLICATION UNITS AND WASTE PILES RECEIVING INDUSTRIAL WASTES
Industry Type
(Organic Chemicals
(Primary Iron and Steel
(Fertilizer and
(Agricultural Chemicals
1
(Electric Power Generation
1
(Plastics and Resins
(Manufacturing
(inorganic Chemicals
(Stone, Clay, Glass,
(and Concrete
[Pulp and Paper
(Primary Nonferrous
(Metals
(Food and Kindred
(Products
(Water Treatment
(Petroleum Refining
(Rubber and Miscellanous
(Products
1
(Transportation
(Equipment
1
(Selected Chemicals
(and Allied Products
1
(Textile
(Manufacturing
i
1
(Leather and Leather
Ejcts
«
is
Landfills
number amount
of units of waste
17 263
201 3,687
31 5,789
155 53,449
32 86
120 3,220
1,257 7,571
259 5,873
111 1,375
194 3,595
121 157
61 272
77 520
63 172
21 112
28 69
9 9
2,757 86,219 |
Land Application
Units
number amount
of units of waste
27 1,827
76 76
160 756
43 331
17 1,166
24 108
309 51
'
139 8.942
9 373
3.128 75,938
147 8,955
144 396
16 52
11 0.3
17 428
72 763
0 0
4,308 99,160
Waste Piles
number amount
of units of waste
79 48
464 6,129
50 4,820
110 1,528
32 373
98 41,323
2,528 9.184
232 1,469
312 8.764
.540 460
48 9
158 79
•
123 58
362 708
41 8
103 18
54 11
5,335 76.936
TOTALS
number amount
of units of waste
123 2,138
741 9,892
241 11,365
308 55,308
81 1.625
242 44,651
4,094 16,806
630 16,284
432 10,512
3,862 79,993
316 9,121
.
363 747
216 630
436 880
79 548
203 850
63 20
12,400 262,315 |
-------
7) Technology based national effluent guideline limitations for
storm water discharges have played a significant role in
reducing pollutants from a limited number of industries.
EPA has promulgated effluent limitation guidelines which
address storm water from the following industries shown in
Figure 4-1: cement manufacturing; feedlots; fertilizer
manufacturing; petroleum refining; phosphate manufacturing;
steam electric; coal mining; ore mining and dressing;
mineral mining and processing; and asphalt emulsion. In
addition to these control standards, many States or local
governments have developed controls for runoff from
construction activities.
4-8
-------
Figure*v1. NPOES Effluent Guideline Limitations which Address Storm Water Discharges
CEMENT MANUFACTURING CATEGORY
Materials Storage Piles Runoff
FEEDLOTS
All Subcategories Except Ducks
Ducks
FERTILIZER MANUFACTURING
Phosphate
PETROLEUM REFINING
Topping
Cracking
Petrochemical
Lube
Integrated
PHOSPHATE MANUFACTURING
Defluorinated Phosphate Rock
Defluorinated Phosphoric Acid
STEAM ELECTRIC POWER GENERATING
Coal Pile Runoff
COAL MINING CATEGORY
Coal Preparation Plants and
Coat preparation Plant Associated
Areas
Acid or Ferruginous Mine Drainage
Alkaline Mine Drainage
Post-Mining Areas
ORE MINING AND DRESSING CATEGORY
Iron Ore TSS, iron, pH
Aluminum Ore
Uranium, Radium, and Vanadium Ores
Mercury Ore
Titanium Ore
Tungsten Ore
Nickel Ore
Vanadium Ore
Antimony Ore
Copper, Lead, Zinc, Gold, Silver, And Molybdenum Ores
-------
Platinum Ore
MINERAL MINING AND PROCESSING POINT SOURCE CATEGORY
Crushed Stone
Construction Sand and Gravel
Industrial Sand
Gvpsun
Asphaltic Mineral
Asbestos and Uollastonite
Borax
Potash
Sodium Sulfate
Trona
Phosphate Rock
Frasch Sulfer
Magnesite
Diatomite
Jade
Novaculite
Graphite
PAVING AND ROOFING MATERIALS
Asphalt Emulsion
-------
Typical activities that can impact the pollution potential
of storm water discharges were evaluated for classes of
facilities identified in this report. The pollution potential
of activities at industrial facilities were ranked as having a
high, medium, or equivalent pollution potential relative to
discharges of runoff from typical residential and commercial
areas. Rankings were based on a consideration of the seven
types of activities identified above. Based on these rankings
and a consideration of other factors, pollutants with the
potential for relatively high concentrations in storm water
discharges were identified for the classes of facilities.
Figure 4-2 presents a summary of the pollution potential of
evaluated activities at facilities that meet EPA's proposed
regulatory definition of "storm water discharges associated with
industrial activity". Figure 4-3 presents a summary of the type
of pollutants expected to be at relatively high concentrations in
the storm water discharges from these facilities. Figure 4-4
presents a summary of the pollution potential of evaluated
activities at other facilities evaluated in this Report. Figure
4-5 presents a summary of the type of pollutants expected to be
at relatively high concentrations in the storm water discharges
from these facilities. Since pollutants from each activity will
be specific to the type of facility, and the site-specific
importance of any given contribution may be dependent on the
particular pollutant involved, attempts at "totalling or
averaging" the rankings should be avoided.
4-10
-------
C/196P/Disk 17/Dbc. 127
IAHLB 4-8. SuBnry of Potential Pollutants in Stan feter Pom OBBercial
Oxygen- Pesticides,
Demanding PCBs, aid Persistent
Category Nutrients Materials Solids Metals Dicodn Organics Other
OTHER INDUSTRIES
Wholesale Trade
Automobiles and Other Motor Vehicles * X * PABs 0«0
Used Motor Vehicle Parts X * PAHs 0*G
Lumber and Building Materials Phenols
Goal and Other Minerals and Ores X TSS * pH
Recyclers/Scrapyards/Battery Reclaimers X TSS * pB
Food Products * X TSS Pathogens
Farm Product Raw Materials * X TSS
Chearfcal and Allied Products * X * * * *
Petroleum and Petroleum Products X Cc, &i Phenols, PAHs TOC, OtG
Farm Supplies * X TSS * Pathogens
Flowers and Nursery Stock and Supplies * X TSS *
Retail Trade
Lumber and Building Materials Phenols
Auto Dealers and Gasoline Service Stations X PABs 0*G
Fuel Dealers X PAHs 0*G
Auto Repair, Services, and Parking X PAHs 0*G
Lawn and Garden Service * X TSS * pH
Amusement Services * X TSS * * *
Hospitals Pathogens
Botanical and Zoological Gardens * X TSS * Pathogens
Military Bases * X * * * * *
*Ihe specific pollutant will depend upon the processes used at an industrial facility. ——
RET: N=Nitrogen TSS=Total Suspended Solids Cu=Cbpper PAHs=Polyaronatlc Hydrocarbons
P^Phosphorus TDS=Total Dissolved Solids Pb=Lead MBAS=Metnylene Blue Active Agents
Na.=Amnonia Nitrogen As=Arsenic SB=Tin CN=qvanide
BOO=Blochemlcal Oxygen Demand Ba=Barium &»=Zinc TOC=Total Organic Carbon
GDD=Chemical Oxygen Demand Cr=Oironium PCBs=Polychlorinated Biphenyls 0*G=Oil and Grease
-------
C/196P/Disk »7/Dbc. »28
Loading/lhloading
Category
Automobiles and Other Motor Vehicles
Used Motor Vehicle Parts
Auto Dealers and Gasoline Service Stations
Auto Repair, Services, and Parking
Lunber and Building Materials
Coal and Other Minerals and Ores
Recyclers/Scrapyards/Battery Reclaimers
Food Products
Farm Product Raw Materials
Chemical and Allied Products
Petroleun and Petroleum Products
Farm Supplies
Flowers and Nursery Stock and Supplies
Lunber and Building Materials
Fuel Dealers
lawn and Garden Service
Amusement Services
Hospitals
Botanical and Zoological Gardens
Dry Bulk
M
M
M
M
B
B
B
N
B
B
L
B
B
B
L
B
L
L
M
Liquids
L
L
B
L
N
L
L
M
M
B
B
L
L
H
B
B
M
L
M
Outdoor Storage
of Raw Material
Waste or Product
B
B
B
B
B
B
B
L
M
L
B
M
B
B
B
L
M
N
B
Outdoor
Industrial
Activity
B
B
M
H
M
B
B
L
M
L
B
M
B
M
B
B
B
L
H
Dust or Illicit
Particulate Connections/
Generating Industrial
•»
L
L
L
L
L
B
B
L
M
L
M
M
M
L
L
H
L
L
L
Practices
L
L
M
L
L
L
L
B
L
L
B
M
L .
L
L
L
L
fl
M
Land
Application
L
L
L
L
L
L
M
M
L
L
L
L
M
L
L
B
L
L
M
KETi B-There is a high potential for this industrial activity to contaminate stora tater.
H-lhere is a moderate potential for this industrial activity to contaminate storm vater.
L-There is a low to no potential for this industrial activity to contaminate storm waiter.
-------
TABLE 4-10. Sumy of Fbtentlal PoU^fcts in Stan teter Fro» Industrial Facilities
Oxygen- Pesticides,
Demanding PCBs, and Persistent
Category Nutrients Materials Solids Metals Dioxin Organics Other
PRIMAR7 INDUSmiES
Livestock Production
Poultry and Eggs N X TSS Pathogens
Mining Industries NH} X TSS, IDS * IDC, Sulfates, ph
Oil and Gas Extraction TSS Pb,Ba,As,Sb PPBs Chloride
OONb'lHJL'i'lON DOJSIWES
Building/Heavy Construction N,P TSS
MANUFACIIRING IMUSIRIES
Pood and Tobacco Manufacturing
Heat Products * X TSS Pathogens
Dairy Products * X TSS Pathogens
Canned/Preserved Fruits and Vegetables * X TSS
Grain Hill Products * X TSS
Canned/Preserved Seafood Processing * X TSS Pathogens
Textile Hill Products X
Luofcer and Wood Products
Logging TSS
Wood Preserving X Cr,As,Cu Phenols
Reconstituted Wood Products X TSS
Furniture and Fixtures
Metal Furniture and Fixtures *
Paper and Allied Products X Phenols TOC, pH, 0*G
Cheadcal and Allied Products
Industrial Inorganic Chemicals * X * * * * TOC, OX.
-------
»7/rl
TABLE 4-10. Sumy of Potential Pollutants In Stan feter From Industrial Facilities (continued)
Category
ftitrients
Oxygen-
Denanding
Materials Solids
Metals
Pesticides,
PCBs, and Persistent
Dioodn Organics
Other
Chemical and Allied Products (cont'd)
Inorganic Dyes and Pigments
Plastics and Synthetics
Drugs
Soap and Detergents
Industrial Organic Chaidcals N,P
Gum and (food Chemicals
Organic Dyes and Pigments
Fertilizer Chemicals N,P
Pesticide Chemicals
MiorellananK Dmirlralfi *
Explosives *
Ink Formulating
Carbon Black *
Petroleun Refining
Petroleum Refining
Paving and Roofing Materials
Rubber and Plastics Products
Leather and Leather Products
Leather Tanning, Curing, or Finishing
Stone, Clay, Glass, and Concrete Products
Hydraulic Cement
CUt Stone, Stone Products, and Abrasives
Asbestos
Primary Metal Products *
Fabricated Metal Products
Finished/ELectroplated/Cbated Metals
Porcelain Ehaneled Metals
Electrical and Electronic Equipnent
Batteries
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
TSS
TSS
TSS
TSS
*
TSS
TSS
TSS
TSS
TSS
TSS,TDS
*
Cr
*
*
Cr
*
*
Cr.Zh
Cr,Zh
Cr
*
*
*
*
*
Phenol
Phenols
* *
MBAS
* *
* Phenols
*
* *
*
*
Phenols, PABs
Phenols, PABs
TOC, 0*G
TOC, OtG
TOC, 0«Gf CN
TOC, 0«G
TOC, CM;
TOC, 0«G
TOC, 0*G
Sulfate, Fluoride, pH
TOC, OtG.pH
TOC, 0«G
TOC
TOC
TOC, 0+G
TOC, OtG
TOC
Pathogens
PH
0+G
-------
TABU 4-10.
of Potential Pollutants in Stan Ihter Proa Industrial
K)
Category
MlcrellarorviQ Mmfarturi^g
TRANSPORTATION INDUSTRIES
Railroads
Oxygen-
Dananding
Nutrients Materials
*
Local and Interurban Passenger Transit X
Trucking and Warehousing
Water Transportation
Transportation by Air
Transportation Services
WATfR ttt) WASTE MANAGBfNT BOJSTRIES
Water Supply
Sewerage Systems
RCRA Subtitle C TSOFs
RCRA Subtitle D Facilities
EtBET DCUnRIES
Stean Electric Power Generation
The specific pollutant will depend up
RET: NsNitrogen
PaPhosphotus
ML-AuBuiia Nitrogen
BGO=Blochanical Oxygen Danand
COD=Cheadcal Oxygen Dsnand
* X
X
X
*
*
* *
* *
X
n the processes used at an in
TCSeffintal T>i'jMi«»lM«>g
miiv. uVvu.vKuii.uuiE>
MBAS-Methylene Blue Active Agents
ObCyanide
TOD-Total Organic Carbon
nted Binhenyls 0+0=011 and <
j^'QUOG
-------
C/IW/Disk 17/Dbc. #30
KJ
BttB 4-11. Savory of Potential Activities Vat Can Result in
v^v^i^ •M*I^* ^"M» • mn~i •• »• t •!!•• mm* •gTinatTi • MJJ_ « in i i ~ n TI~IT^
Loading/Unloading
Category
PRIMARY HBUSIRIES
Livestock Production
Poultry and Eiggs
Mining Industries
Oil and Gas Extraction
Dry Bulk
B
B
L
Liquids
B
M
B
Outdoor Storage
of Raw Material
Waste or Product
B
B
B
Outdoor
Industrial
Activity
B
fl
H
Dust or
Particulate
Generating
Ptouesses
B
B
L
Illicit
Corrections/
Industrial
Practices
L
B
B
Land
Application
B
B
B
Ofb'lVULTICN INDUKDUES
Building/Heavy Construction N
MANUFACnilDC DfUSDOES
Pood and Tobacco Manufacturing
Meat Products H
Dairy Products H
Canned/Preserved Fruits and Vegetables H
Grain Hill Products B
CdMled/Preserved Seafood Processing B
Textile Hill Products B
Later and Hood Products
Logging M
Hood Preserving B
Reconstituted Hood Products B
Furniture and Fixtures
Metal Furniture and Fixtures B
Paper and Allied Products B
Chemical and Allied Products
Industrial Inorganic Chemical."; B
Inorganic Dyes and Pigments B
Plastics and Synthetics B
Drugs B
L
B
B
B
B
B
L
B
M
B
B
B
B
B
B
B
L
B
L
B
L
L
B
B
L
B
B
B
L
L
M
L
fl
L
M
L
B
B
L
L
M
B
B
L
L
B
L
L
N
B
M
L
L
M
B
B
B
L
L
L
L
B
B
B
fl
B
M
L
M
M
B
fl
B
B
H
B
M
L
B
M
fl
L
L
H
M
L
M
L
L
L
L
-------
D/196P/Disk 17/Doc. 130
TIBLR 4-11. Sumy of Potential activities That On Result in Stxn
Outdoor Storage Outdoor
Loading/Unloading of Rav Material Industrial
Category Dry Bulk Liquids Waste or Product Activity
Soap and Detergents
Industrial Organic Chemicals
Gun and Wood Chemicals
Organic Dyes and Pigaents
Fertilizer Chemicals
Pesticide Chemicals
M
-------
'/Disk 17/Dbc. #30
TAEU 4-11. Suny of Potential Activities Vat Can Result In Statm
m w^^ • • •— ^•^^••••^ ^••a «•» ,^» a^pMfcg ^» •••» • WV^B^AA ^A<^MV ^^*^»»fc •>••«•*••• ^
Category
TRANSPlFTAnCN DCUSTRIES
Railroads
Local and Interurban Passenger Transit
Trucking and Warehousing
Uater Transportation
Transportation by Air
Transportation Services
WATER AM) WASTE HANAGETOJT DCUSTRIES
Uater Supply
Sewerage Systens
RORA Subtitle C TSDFs
ROM Subtitle D Facilities
QCBGT DCU5HUES
Steam Electric Power Generation
Outdoor Storage Outdoor
Loading/Unloading of Rav ffaterial Industrial
Dry Bulk Liquids Waste or Product Activity
B
L
B
B
B
B
B
B
B
B
B
B
L
B
B
B
B
N
B
B
B
B
B
L
B
H
B
B
B
B
B
B
B
B
fl
H
B
B
B
B
B
B
B
H
Dust or
Particulate
Generating
*********
N
N
B
B
B
B
L
fl
B
B
B
Illicit
Connections/
Industrial Land
Practices Application
L
L
H
L
L
L
L
L
L
L
L
L
L
L
L
H
L
N
fl
B
B
B
KEY: B-There is a high potential for this industrial activity to contanlnate storn water.
H-There is a moderate potential for this industrial activity to contaminate storn later.
L-There is a lov to no potential for this industrial activity to oontandnate stora later.
-------
4.2 SUMMARY OF TEE MATURE AMD EXTENT OF DISCHARGES FROM SEPARATE
STORM SEWERS FROM INDIVIDUAL FACILITIES
4.2.1 MIMING AND OIL AND GAS PRODUCTION
4.2.1.1 Mining Industries
The mining industries include facilities involved in metal
mining (SIC Code 10), coal mining (SIC Code 12), and mining of
non-metallic minerals (SIC Code 14). As shown in Figure 4-1, the
majority of types of mining facilities are currently covered by
existing national effluent guidelines limitations.
Mining activities generally occur outdoors exposed to
weather conditions. Characteristics affecting pollutants in
storm water discharges include the nature of the host material,
the type of mining operation, and abandonment of mines.
Nature of the Host Material
The earth materials associated with the ore or mineral being
mined are a major source of pollutants in storm water discharges
from mine sites (EPA 1975; EPA 1979; EPA 1981). Regardless of
the mining methods used, earth materials must be disturbed, moved
and handled in the process of accessing the desired ore.
Disturbed materials include overburden (soil layers above the
target formation) and tailings (waste earth materials left over
from mining and ore processing operations). The contents of
these materials depend on the nature of the substance being
mined, as well as the localized nature of the surrounding
geology.
Coal mining in the east, for example, is typically
associated with sulfur-bearing earth materials that, when exposed
to oxygen and water, create sulfuric acid. The acid then causes
metals present in the earth materials to dissolve or leach. This
phenomenon creates acid mine drainage, a widely recognized
environmental problem associated with both active and inactive
mines. Coal mining in the west is generally not associated with
acid runoff, but it can impart sodium or other salts to runoff
due to the highly alkaline nature of the surrounding soils
(Sorensen 1979).
Type of Mining Operation
Mining operations, including surface mining, shaft mining,
and open pit mining, are generally exposed to precipitation. In
addition, ore processing operations located at mine sites add to
the volume and exposure of mining wastes. Depending on the type
of mining operations employed, storm water may be affected by
contact with exposed ore, disturbed overburden, dust or
4-15
-------
particulate, or wastes front mining and ore processing operations.
Surface mining is characterized by the removal of protective
layers of vegetation and soil, exposing large amounts of
unweathered earth materials. These materials contain salts and
soluble toxic pollutants that may end up in surface runoff via
erosion and leaching.
Mine drainage from shaft mines is generated from water that
collects in the mine from ground water seepage, storm water, and
any process water used. This drainage may be acid or alkaline,
depending on the nature of the host material. During mining
activities, mine water is pumped or drained from the mine and, if
required, treated prior to discharge or recycle. The type of
treatment employed depends on the nature of the effluent, as well
as the applicable effluent limitations guidelines (EPA 1975; EPA
1979; EPA 1981). After mining activities are completed, mine
drainage may continue unless appropriate closure steps are taken.
Open pit mining operation, like shaft mining, must contend
with mine water collecting at the bottom of the pit. Dikes and
channels are often constructed to minimize the amount of runoff
entering the pit and to facilitate drainage from the bottom of
the pit without excessive erosion.
Activities at metal and mineral mine operations include
extraction, beneficiation, and processing of ores and minerals.
Extraction is the initial removal of the ore from the earth.
Beneficiation is the inital attempt at liberating and
concentrating mineral from the the extracted ore. Beneficiation
can involve by a variety of milling (crushing, gringing, washing,
filtration), agglomeration (sintering, palletizing, briguetting)
and other (heap, dump, vat and in situ leaching, precipitation,
flotation, magnetic separation, roasting in preparation for
leaching) techniques. Mineral processing operations generally
follow beneficiation and include techniques that often change the
chemical composition of the ore or mineral, such as smelting,
electrolytic refining and acid attack or digestion.
Waste Generation
Mining operations create large amounts of wastes, which are
generally managed in waste piles, ponds, or dumps. Mining waste
is generated from several activities, including but not limited
to, removal of overburden in surface mining and removal of earth
materials from shaft mines and from ore processing operations.
Erosion and leaching of soluble toxic materials caused by runoff
from such waste is a widespread problem.
There is a distinction between wastes from extraction and
beneficiation operations and minineral processing wastes.
4-16
-------
Beneficiation operations often generate high volume solid waste
streams that are essentially earhen in character, including
tailings and leach piles. The waste material is often physically
and chemically similar to the material (ore or mineral) that
entered the operation, except that particle size reduction has
often occurred. Environmental impacts from beneficiated
materials are generally higher than from extracted ore because
increased surface area of the ore allows more mobility of toxics
and reagents, such as cyanide, that are added to the
beneficiation process may be released to the environment.
Mineral processing operations generate waste streams that
generally bear little or no resemblance or no resemblance to the
material that entered the operation. These operations usually
change the physical structure of the mineral. For example,
concentrated ores are heated to produce a product metal, a slag,
dust, and acid plant blowdowh.
wastes from metal, phosphate, asbestos and uranium mines
were studied in the Report to Congress, "Wastes from the
Extraction and Beneficiation of Metallic Ores, Phosphate Rock,
Asbestos, Overburden from Uranium Mining and Oil Shale" (EPA,
December 1985). Mines in the metal, phosphate, and asbestos
segments produce about 1 to 1.3 billion metric tons per year of
waste, with total waste accumulated by all active, inactive and
abandoned mines since 1910 estimated at 50 billion metric tons.
Of the 1.3 billion metric tons of waste produced each year, 61
million metric tons of copper, gold, silver, lead, or zinc wastes
exhibit RCRA hazardous characteristics, with 23 million metric
tons per year of gold and silver wastes potentially hazardous
because they have been leached using cyanide solution. The
quantity of waste generated at a given facility can vary from 10
tons per day to 500,000 tons per day.
In the mining Report to Congress, EPA concluded that wastes
with the highest acid formation potential are in the copper,
gold, and silver industry segments The report indicated that
major causes of damage in the cases studied included periodic
runoff, spills and sudden releases caused by heavy rains as well
as seepage, and that damage to surface waters is often reducible
or reversible by use of modified waste management practices or
physical controls.
Inactive and Abandoned Mining Facilities
Some inactive and abandoned mining units, many of which are
decades old, may pose significant environmental hazardous.
Inactive and abandoned mines have been a major source of
uncontrolled runoff for many years (Barks 1977; EPA 1987).
Sources of pollutants in runoff at abandoned mine sites are
essentially the same as those at active mines, including mine
drainage and runoff from mining and processing waste piles.
4-17
-------
Pollutant concentrations and loadings may be higher than those
associated with active sites because the sites may have been
mined prior to the development of regulatory controls for mines
and appropriate closure procedures were not taken prior to
abandonment of the site. In addition, detention ponds and other
controls may have never been put in place, or may no longer be
functioning correctly. Prior to abandonment, mine owners are
often reluctant to cap or bury tailing piles and to take other
steps that might make future recovery of minerals more difficult.
The runoff from abandoned mines is often uncontrolled and not
monitored. Ownership and responsibility for abandoned mines is
often difficult or impossible to establish.
Pollutant Description
EPA has identified four metals of concern (lead, arsenic,
cadmium, and chromium) that are generally found in wastes from
any type of mine site, regardless of the substance being mined.
These metals are of particular concern because they are common
and thought to have serious human health effects (EPA 1987).
Other mining-associated metals of concern include copper, zinc,
nickel, molybdenum, and magnesium.
The potential pollutants in storm water runoff from mining
sites vary greatly and depend on the segment; the beneficiation
process; and site-specific geologic, hydrologic, and climatic
factors. Some rock is high in metals or radionuclides. Some
beneficiation processes use acids and cyanides. Runoff from
mining wastes and tailings can contain these materials and also
be acidic or alkaline.
During development of effluent guidelines for the coal
mining category, EPA studied runoff from areas associated with
coal mining operations, including coal storage piles, refuse
piles, and other disturbed areas (EPA 1981). Pollutants found in
runoff from these areas included solids, metals, pesticides, and
organic compounds. Table 4-3 summarizes the results of this
study.
4-18
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its
TABU
TSS
Dissolved solids
Total volatile solids
Volatile suspended
solids
Settleable solids
Total solids
Metals
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Iron
Manganese
Pesticides
BBC-beta
BHC-delta
Organic Chemicals
Benzene
Chlorobenzene
Chloroform
Methylene chloride
Bis (2-ethylhexyl)
phthalate
Other Pollutants
PH
COD
TOC
7
3
4
it
2
it
3
4
4
3
7
7
0
2
1
8
9
9
2
1
2
3.30
580
26
22
0.00
180
0.002
0.002
0.002
0.013
0.010
0.006
0.003
0.00002
0.038
0.001
0.027
O.OU
0.019
0.275
0.027
0.00033
0.00010
0.044
0.012
0.045
0.162
0.003
12.675
*.125
67.06
1.960
1,398
10.25
0.00
91/1
, 147
0.013
0.350
0.060
0.025
0.235
0.232
0.271
0.0011
1.771
0.137
0.031
0.014
4.297
1,246
17.436
0.00033
0.00010
0.046
0.012
0.261
0 3
0.007
5. tt
262.044 1
11.508
240.0
3,100
2,900
28
0.00
22,000
0.028
1.340
0.220
0.038
0.980
1.000
1.000
0.0024
10.000
0.450
0.036
0.014
30.000
9,000
80.000
0.00033
0.00010
0.048
0.012
0.476
1.440
0.010
1 •)
• . i.
, 160
19.300
-------
A study of runoff from waste piles at an inactive lead-zinc
mining area showed that elevated levels of several metals had
migrated to a nearby creek (Barks 1977). Table 4-4 shows a
comparison of pollutants measured in waste pile storm water
runoff to those measured upstream of the waste piles.
4-20
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TABLE MO. Omparil-on of Pollutants in Runoff Pro* Lead-Zinc
Nlninf Vast* Piles to Upstrea* Pollutant Concentrations
Pollutant*
Dissolved solids (mg/L)
Bicarbonate (mg/L)
Sulfate (mg/L)
Zinc (ug/L)
Aluminum (ug/L)
Lead (ug/L)
Copper (ug/L)
Cadmium (ug/L)
Nickel (ug/L)
Runoff From
Waste Piles
414
62
230
16,000
600
380
46
26
16
Upstream
Concentrations
134
136
8
20
30
4
0
1
2
'Dissolved fraction only.
Source: Barks 1977.
-------
4.2.1.2 Oil and Gas Extraction
This group (SIC Code 13) includes establishments involved in
the exploration, development, and production of crude oil,
natural gas, and natural gas liquids. Operations performed by
these establishments include well drilling, well logging,
completion, and stimulation, as well as oil/gas/water separation
and treatment.
Drilling activities may include clearing of land,
construction of temporary access roads, installation of drilling
and related equipment, and reserve pit construction. The first
three of these activities are comparable to those conducted at
construction sites.
Reserve pits are primarily used to receive drill cuttings
throughout the well drilling operation, and are sized roughly
according to the estimated total depth of the well. A pit is
typically dug in the open with a backhoe and should be designed
to meet State-required specifications, such as inner side slope
limits, depth of the pit relative to the nearest ground water
aquifer, liner type, and freeboard allowance (i.e., space between
the top of the pit contents and the upper lip of the pit). Some
States require at least 2 feet of freeboard to prevent possible
overflows caused by precipitation or over-filling. In addition
to the erosion that can occur due to the disturbed land at a
drill site, significant contamination of storm water runoff is
possible at sites where reserve pits are poorly constructed,
located, or managed. The common practice of land applying
reserve pit waste is also a potential source of pollutants in
storm water discharges.
Production activities are established once a well has been
successfully completed. The primary function of a production
unit is to separate the oil, water, and gas received from the
well head to the extent that the oil and/or gas is ready for sale
and transfer, either by truck or pipeline. Production units, or
tank batteries, are usually located outside and may serve
numerous wells in a producing field. Separation occurs in a
series of tanks and vessels designed to produce increasing
degrees of water-free oil and/or gas. Oil that will meet
pipeline specifications is then sent to storage tanks known as
stock tanks. The number and size of stock tanks depend upon the
volume of oil produced, method of selling the oil to the
pipeline, and the frequency and rate at which oil is taken by the
pipeline company.
For the most part, production operations function without
exposing the process streams to storm water. However, the major
waste product from separation processes, produced water, is often
4 -22
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handled and disposed of in ways that can come in contact with
storm water. The choice of disposal methods for produced water
depends on various factors, including State regulations, company
policies, economics, geological considerations (i.e., feasibility
of injection well disposal), and regional precipitation patterns.
For example, only States having net evaporation zones allow the
use of produced water evaporation pits. Such open pits are
generally not allowed in areas of net precipitation. Some States
also allow the direct discharge of produced water to surface
waters or to unlined drainage ways. In addition to these
disposal methods, tank batteries can include produced water
holding tanks that are open to the atmosphere.
Wastes from oil and gas extraction activities were studied
in a Report to Congress, "Management of Wastes from the
Exploration, Development and Production of Crude Oil, Natural Gas
and Geothermal Energy" (EPA 1987). This study identified seven
chemical constituents of oil and gas field wastes present at
levels of potential concern, including the hydrocarbons benzene
and phenanthrene, and the inorganic constituents lead, barium,
arsenic, fluoride, and antimony. These seven chemical
constituents were reported on the basis of their frequency of
occurrence in waste samples, and as such, represent only a small
percentage of all chemicals to be found in oil and gas field
wastes. For example, produced water is an aqueous solution
containing many dissolved compounds, including minerals such as
sodium chloride and dissolved hydrocarbons in widely varying
concentrations. When produced water is discharged to surface
waters, the sodium chloride and other dissolved minerals can have
serious effects on the receiving streams. This particular
problem led EPA to set a water-quality limit for chloride
discharged to the waters of Kentucky, citing the major impact
that produced water from stripper wells was having on State
waters (52 FR 9102). In addition, suspended solids may be a
significant constituent of runoff from drill sites where land has
been cleared and disturbed.
EPA reported several waste disposal practices that may
result in significant contamination of storm water discharges.
California permits the discharge of oily wastes to large, unlined
sumps or pits and ephemeral streams. Pollutants from wastes
discharged to ephemeral streams can become resuspended during
storm events and carried to larger receiving waters.
Waste disposal practices on the North Slope of Alaska are
very different from those in other areas of the United States.
Discharges of excess liquid directly onto the tundra and roads
from production reserve pits is allowed under Alaska Department
of Environmental Conservation regulation. ADEC estimates that
100 million gallons of this liquid are pumped onto the tundra and
roadways on the North Slope each year, carrying reserve pit
constituents such as chromium, barium, chlorides, and oil.
4-23
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Illegal disposal of wastes at oil and gas operations is a
pervasive problem that may result in damage to surface waters and
wetlands. Incidents of illegal disposal of oil and gas wastes
are found throughout the United States.
Nothing in the literature indicates that storm water is
routinely collected and treated before discharge from oil and gas
extraction facilities.
4.2.3 MANUFACTURING INDUSTRIES
Manufacturing facilities include operations that produce new
products from various materials and substances. Examples of
manufacturing facilities include food processing facilities,
chemicals manufacturing, metal products manufacturing, and
petroleum refining.
4.2.3.1 Food and Tobacco Manufacturing
The manufacturing operations conducted by facilities in
these groups are related to food (e.g., meat, fish, vegetables,
dairy, grain, bakery, confectionery, beverages) and tobacco
production, processing, packaging, and storage. Examples include
meat, fruit and vegetable canners, grain mills, bakeries, seafood
processors, soft drink bottlers, breweries, and rendering plants.
Primary sources of pollutants in discharges from separate
storm sewers at food and tobacco manufacturing facilities include
the loading and unloading of bulk or liquids, outdoor storage and
processing, outdoor industrial activity, illicit
connections/industrial practices, and land application of wastes.
Examples of these sources include the unloading and care of
animals, the loading of packaged goods at meat processing
facilities, and pneumatic transfer of grain, generating dust or
particulate. Because many of these facilities use large volumes
of water in cooling and other process streams, illicit
connections between these streams and storm water outlets are
common. Land application of wastes onsite is also a common
practice which may impact pollutant concentrations in discharges
from separate storm sewers.
For the majority of facilities, the pollutants that would
most likely be present in discharges from storm sewers from these
industrial sources include oxygen-demanding pollutants such as
biochemical oxygen demand (BOD) and chemical oxygen demand (COD),
and total suspended solids (TSS). Of particular concern within
this group is storm water runoff from animal pens located at meat
processing facilities. Pollutants of concern in storm water from
animal pen areas include oxygen-demanding pollutants, nutrients,
4 - 24
-------
and pathogens.
Some food processing facilities use solvents such as hexane,
methyl ethyl ketone, and methylene chloride for extraction and
leaching operations. Although extraction and leaching operations
are expected to be performed indoors, solvent loading and
unloading areas and solvent storage areas can be expected to be
outdoors.
4.2.3.2 Textile Mill Products
The facilities in this group (SIC Code Group 22) are princi-
pally engaged in receiving and preparing fibers; transforming
these materials into yarn, thread, or webbing; converting the
yarn and web into fabric or related products; and finishing these
materials at various stages of production. Many facilities
produce a final consumer product, such as thread, yarn, bolt
fabric, hosiery, towels, sheets, or carpet, while the rest
produce transitional products. The category for apparel and
other textile products (SIC Code 23) includes industries
primarily involved in manufacturing sewn textile products.
In general, processing is dry and little or no discharge of
waste water results. Process areas and raw materials and product
storage areas are almost always located inside buildings,
protected from rainfall. Spilling of chemicals and dyes used to
treat fabrics during shipment and transfer into the facility, and
from waste treatment plants can add pollutants to storm water
discharges. Illicit connections are also possible due to the age
of many textile mills.
Textile chemical treatment agents include acid, alkali,
starch, polyvinyl alcohol, carbonyl methyl cellulose, polyacrylic
acid, bleach, soap, adhesives, silicones, and various other
organic and inorganic compounds. The dyes used can be either
organic or inorganic and either toxic or nontoxic.
4.2.3.3 LMtn**er and Wood Products
The manufacturing operations conducted by facilities in this
group (SIC Code Group 24) are all related to lumber and wood
products, except wood furniture manufacturing. Examples of
lumber and wood products manufacturing operations include
sawmills and planing mills, mi11work, and mobile and
prefabricated wood buildings.
The activities of these facilities that might contribute to
storm water pollution include loading and unloading, outdoor
storage, and outdoor industrial activity. This is also true for
facilities receiving and storing wood and wood chips for use in
the manufacture of wood veneers, plywood, and reconstituted wood
4-25
-------
products (e.g., hardboard, particleboard, and insulation board
[EPA 1981]). Storm water discharges from these facilities are
expected to contain significant levels of oxygen-demanding
pollutants and TSS.
Wood preserving facilities involve more chemical intensive
processes. Wood preservatives are used to delay deterioration
and decay of wood caused by organisms such as insects, fungi, and
marine borers. A wide variety of chemicals are used to
preserve wood. Three broad categories of wood pesticides include
creosote or oil-borne preservatives, pentachlorophenol (penta)
solutions, and water-soluble inorganic arsenical compound and/or
chromate salts (inorganics). Long-lasting protection of wood
requires penetration of preservatives to a uniform depth. This
deep penetration is usually accomplished by forcing preservative
into the wood under pressure, so that "pressure treated11 is often
used as a synonym for "preserved".
Creosote or mixtures of creosote with petroleum oils or coal
tar is the primary wood preservative used in the United States.
It is the product of distilled coal tar and is composed of
hundreds of polynuclear aromatic hydrocarbons (PAHs) as well as
tar acids and bases. Pentachlorophenol, the second most common
wood preservative, has been used to treat wood since 1947. It is
applied to poles, crossarms, lumber, timbers, fence posts and
other wood products in a 5% solution with petroleum solvents
where a clean paintable surface is not required.
Inorganic arsenical preservatives account for the third
largest category of wood preservatives in the United States.
These preservatives, which were developed in the 1930s, consist
of mixtures of bivalent copper, pentavalent arsenic, hexavalent
chromium or fluorides. The three most widely used compounds for
commercial wood treatment include chromated copper arsenate
(CCA); ammoniacal copper arsenate (ACA); and fluorochrome-
arsenate phenol (FCAP). These preservatives usually color the
wood greenish-brown, and provide clean paintable surfaces.
In 1985, three major product groups accounted for 89 percent
of the total production of preserved wood in the United States: °
(1) lumber and timber, mostly preserved with inorganic
preservatives; (2) railroad cross ties, switch ties and bridge
ties, almost all preserved with creosote; and (3) poles, 60
percent preserved with pentachlorophenol, 23 percent with
creosote, and 17 percent with inorganic preservatives. The
remainder of production consists of fence posts, piling, plywood,
crossarms and other products.
The distribution of preservative use by the wood preserving
industry is summarized in Table 4-9. Seventeen percent of the
plants treat with more than one preservative. Runoff generated
at these plants can be contaminated with constituents of all
4 '•* 26
-------
preservatives used at the plant. The American Wood Preservers
Institute reported 571 plants producing preserved wood in 1985.
About 60 percent of these plants are in the southeast and
southcentral portions of the United States and account for 64
percent of the production of treated wood. Most plants that
treat with creosote and/or pentachlorophenol are more than 25
years old; several operating plants are more than 75 years old.
4-27
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Most surface protection takes place at sawmills, where cut
lumber is dip- or spray-treated to prevent surface discoloration
(sapstain formation) during short-term storage. In 1983,
approximately 3.7 billion board feet of lumber was surface
protected, the majority with about 1.5 million pounds of aqueous
solutions of sodium pentachlorophenate, at sawmills. This
accounted for about 10 percent of the sawmills total production
of lumber. Water solutions of sodium pentachlorophenate are
applied to wood by dipping or spraying. Commercial
chlorophenates have been found to contain polychlorinated
dibenzo-p-dioxins (PCDDs) and dibenzofurans (PCDFs). EPA
estimates that there may be up to 500 sawmills currently surface
protecting wood with chlorophenate formulations and a total of
1,500 sawmills that have protected wood with chlorophenates
within the past ten years.
Pollutants in storm water runoff from treated material
storage yards at wood-preserving facilities were studied by EPA
in 1981 in support of effluent guidelines development, and in
support of a proposed hazardous waste listing in 1988. Table
4-10 presents a summary of the screening sampling program
performed by EPA. Certain metals, including chromium, copper,
and arsenic, were found at high levels in storm water from wood-
preserving facilities. Several organic pollutants were found at
significant concentrations, including pentachlorophenol, fluor-
anthene, benzo(a)anthracene, chrysene, phenanthrene, and pyrene.
EPA proposed to list a number of wood preserving wastes including
preservative drippage (free drippage of preservative from treated
wood and preservative that is washed-off treated wood by
precipitation) as hazardous waste under RCRA, and establish
hazardous waste management unit requirements for drip pads
(December 30, 1988 (53 FR 53287). Sump, catch basin and
drainage ditch sediment data and drippage data for facilities
that use chlorophenolic formulations from the proposed listing
are shown in Table 4-11.
4-29
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F/196P/Oisk 13/Doc §25
TABLE 1"t4. Summary of EPA Screening Sampling of
Storn Water Runoff at Wood Preserving Facilities
Parameters
Range
Number of
Facilities Sampled
Traditional Parameters (mg/1)
BOO (5-day)
COD
Total Solids
Volatile. Solids
Suspended Solids
Dissolved Volatile Solids
Dissolved Solids
Total Phenols
Oil and Grease
Metals (uff/1)
Beryllium
Cadmium
Chromium
Copper
Nickel
Lead
Zinc
Arsenic
Mercury
Acid Compounds (ug/1)
i , 4-Dime thylphenol
2-Ni trophenol
Pen tachlorophenol
Phenol
Base/Neutral Compounds (ug/1)
Acenaph thene
Fluoranthene
Naphthalene
Bis(2-ethylhexyl) Phehalate
Butyl Benzyl Phthalate
Di-n-butyl Phthalate
Diethyl Phthalate
Benzo ( a )an thracmne
Benzo(a)pyr«ne
Benzo(k)fluorai) thene
Chrysene
Acenaph tbyleae
Anthracene
Benzo (ghi )perylene
Fluorene
Phenan threne
Dibenzo(a,h)anthracene
Pyrene
2. A -
54 -
169 -
108 -
23.0 -
<5 -
105 -
0.009 -
<5 -
0.7 -
0.4 -
3.2 -
8.5 •
6.2 -
2.9 -
83 -
19 -
<0.40 -
ND -
ND -
ND -
ND -
ND •
ND -
ND -
ND -
ND -
ND -
ND •
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
48
600
3,800
845
3,330
800
912
1.3
24
40
3.1
1,500
760
310
520
990
2,200
4.9
18
<10
440
32
340
680
71
<10
<10
<10
<10
120
300
230
140
15
1,500
82
110
1,300
14
410
6
6
6
6
6
6
6
5
6
6
6
6
6
6
6
6
6
6
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
ND • Not Detected.
Source: EPA 1981.
-------
4.2.3.4 Furniture and Fixtures
This industry group is composed of facilities which
manufacture household furniture (SIC Code 251), office furniture
(SIC Code 252), public building and related furniture (SIC Code
253), partitions and fixtures (SIC Code 254), and miscellaneous
furniture and fixtures (SIC Code 259). Metal finishing occurs
among industries described by SIC Codes 2514, 2522, 2531, 2542,
2591, and 2599. Other facilities in this industry group are
involved in manufacturing wood furniture and fixtures.
Activities associated with these facilities are conducted largely
indoors, although chemical and waste storage and handling occur
outside and illicit connections or improper dumping of wastes to
separate storm sewers can be a problem.
The nature of discharges from separate storm sewers from
metal finishing facilities is discussed under the heading
Fabricated Metal Products.
4.2.3.5 Paper and Allied Products
This industry group is composed of pulp mills (SIC Code
261), paper mills (SIC Code 262), paperboard mills (SIC Code
263), paperboard containers and boxes (SIC Code 265), and
miscellaneous converted paper products (SIC Code 267). Most
of the activities that can potentially affect storm water at
facilities within this industry group are the same from subgroup
to subgroup. Industries in the printing and publishing group
(SIC Code Group 27) conduct their activities largely indoors.
The major processes in the paper and allied manufacturing
are wood preparation, pulping, bleaching, stock preparation, and
paper-making. In addition to these basic processes, some mills
perform de-inking, which refers to the reclamation of waste
paper. De-inking removes ink, fillers, coating, and other non-
cellulose materials. De-inking mills often store large volumes
of waste paper in uncovered areas.
The potential sources of pollutants in storm water
discharges include: transport, loading, unloading, and storage
of raw materials, including logs, wood chips, waste paper, and
process chemicals; outdoor activities, including waste treatment
and residuals management operations, and wood preparation
processes; and particulate emissions from burning of fossil
fuels.
Wood preparation processes are usually conducted outdoors.
These processes generally involve the use of high water volumes.
Waste water from these operations is considered process waste
water and is treated at waste treatment facilities. During wet
weather, however, the capacity of the collection system may be
4-32
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insufficient to provide treatment for runoff. In addition,
illicit connections are possible due to the age of most paper
mills, and due to the typically close proximity of surface water
such as lakes or streams.
4.2.3.6 Chemicals and Allied Products
This major industry group (SIC Code Group 28) includes
establishments producing basic chemicals and establishments
manufacturing products through the use of chemical processes.
Facilities included in this major group produce: basic chemicals
such as acids, alkalies, salts, and organic chemicals; chemical
products to be used in further manufacture, such as synthetic
fibers, plastics materials, dry colors, and pigments; and
finished chemical products to be used for ultimate consumption or
use, such as drugs, cosmetics, and soaps, or to be used as
materials or supplies in other industries, such as paints,
fertilizers, and explosives.
This group can also be subdivided into facilities that
produce inorganic chemicals and related products, and facilities
that produce organic chemicals and related products. This
distinction is important because each subgroup uses very
different raw materials, processes, and methods of materials
handling. The facilities in both groups store raw materials,
products, and wastes onsite; however, the inorganic chemicals and
products segment of the industry is more likely to store
materials outdoors.
For several types of facilities, effluent guidelines
limiting phosphorus, fluoride and pH, include limitations for
storm water discharges. Effluent guidelines for the fertilizer
manufacturing industry address precipitation runoff that may come
into incidental contact with raw materials, products, or
intermediate products. Regulated pollutants in fertilizer
manufacturing runoff include ammonia, organic nitrogen, nitrate,
phosphorus, BOD, TSS, and pH. Effluent guidelines for the
inorganic chemicals industry require all storm water and plant
site runoff to be collected and routed to the plant treatment
facility if contact is possible with any leakage, spillage, raw
materials, or product. Pollutants limited in the inorganic
chemicals effluent guidelines include cyanide and various metals,
depending on the facility.
Facilities within the chemicals and allied products industry
group can contribute to storm water pollution as a result of
materials storage and handling, as well as outside manufacturing
activities. In general, facilities that produce pharmaceutical
preparations, soaps and detergents, paints and ink formulations,
and pesticides take stronger precautions to prevent storm water
contact with their raw materials and products. Inorganic
chemical and fertilizer manufacturers, on the other hand, may
4 - 33
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store raw materials and products outdoors.
Although organic-chemical-related facilities generally do
not store raw materials and products in the open air, outside
storage facilities, such as tanks, may release pollutants as a
result of floating roof seals, leaking pump seals, and spills.
At many organic chemical facilities, outside process areas are
commonly diked and the storm water is treated along with process
waste water.
Pollutants from the inorganic chemicals industries most
likely to be found in storm water include BOD, TSS, acids or
bases, and inorganic pollutants and metals, depending on the
specific inorganic chemicals manufactured at the facility. In
addition, fertilizer manufacturers can be expected to be a source
of nutrients. Pollutants from the organic chemicals industries
most likely to be found in storm water discharges include BOD,
COD, total organic carbon (TOC), TSS, oil and grease, metals, and
organic chemicals, depending on the facility.
4.2.3.7
This major group consists of two major subgroups: petroleum
refining (SIC Code 2911) and asphalt paving and roofing materials
(SIC Codes 2951 and 2592). Because most of the establishments in
this group are associated with the processes and products of
petroleum refineries, the nature of storm water runoff from
petroleum refineries is presented in the following discussion.
It is important to note, however, that these subgroups differ
with respect to their effects on storm water because petroleum
refining is a more outdoor-oriented industry than the manufacture
of asphalt paving and roofing materials.
Outside storage areas may contain raw materials, products,
or hazardous materials, such as sludge from process or treatment
units. Any storm water that comes in contact with any raw
material, intermediate product, finished product, byproduct, or
waste product located on petroleum refinery property is subject
to effluent guidelines and standards developed for the Petroleum
Refining Point Source Category (40 CFR Part 419).
Because many operational refineries have been in business
for much of this century and process equipment is exposed to the
atmosphere at most refineries, leaks and spills are common
throughout all process areas. The opportunity for illicit
connections to storm sewer systems is significant given the age
of most of these facilities. In addition, storm water discharges
from storage tank farms can contain high levels of pollutants due
to leaks and spills.
The pollutants addressed in the effluent guidelines and
4 - 34
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standards for storm water discharges within the Petroleum
Refining Point Source Category include oil and grease, TOC, BOD,
COD, TSS, phenolic compounds, total and hexavalent chromium, and
pH. Exceedance of oil and grease and TOC limitations triggers
the requirement to comply with limitations for the remaining
pollutant parameters.
4.2.3.8 Rubber and Plastic Products
The facilities in this group (SIC Code Group 30). manufacture
products from manufactured plastic and from natural, synthetic,
or reclaimed rubber. Plastic molding and forming facilities
consist of plants that blend, mold, form, or otherwise process a
wide variety of plastic materials into intermediate or final
plastic products. Rubber products manufacturing can be divided
into miscellaneous molded, extruded, and fabricated products;
reclaimed rubber; and latex products. Regardless of the product
being manufactured, most industrial activities that affect storm
water runoff are similar at all facilities in this group.
A primary source of pollutants occurs when storm water comes
into contact with stored raw materials, products, and process
wastes. In addition, leaks and spills of processing agents and
hydraulic oil could also result in increased pollutant
concentrations in storm water discharges. Reclaimed rubber
facilities in particular may store raw materials (e.g., recycled
rubber) in the open air.
For the plastics industry, plastic pellets (i.e. plastic
material used by processors to make plastic products) are of
growing concern. These pellets are generally 1 to 5 millimeters
in diameter, and if discharged can pose threats to aquatic life.
Individual pellets are not valuable, and many processors have not
set up systems to control or reduce their loss.
For the rubber industry, oil and grease in storm water
discharges is of particular concern. The bulk storage of
recycled rubber can be a source of oil and grease and TSS. An
EPA study (EPA 1974) cited several facilities that were
experiencing substantial oil in storm water discharges. Oil is
used at rubber manufacturing facilities as a fuel, a processing
agent, a lubricant, and a hydraulic fluid in molding and
extruding machinery. In general, the sources of oil were leaks
and spills at bulk storage facilities, and storage and transfer
of waste oils in open areas. At another rubber facility, leaking
hydraulic systems had seriously contaminated the shallow ground
water beneath the facility.
4.2.3.9 Leather and Leather Products
This industry group is composed of facilities engaged in
4-35
-------
leather tanning, curing, or finishing (SIC Code 3111). In
addition, facilities that use finished leather to manufacture
leather products are included in this group (SIC Code 313-319).
With respect to storm water, the leather tanning and finishing
facilities are the most significant segment of this industry, and
are discussed below.
A source of pollutants in storm water discharges from this
group include loading/unloading areas and waste treatment areas.
Loading and unloading areas at leather tanning facilities handle
hides and the various chemicals used in the tanning process
(e.g., sodium sulfide, trivalent chromium, sodium hydroxide, fat
liquor, and pigment and dyes). Waste treatment areas that handle
the wastes generated at these facilities can also result in high
pollutant levels in storm water discharges. In light of the fact
that many tanneries are old and water is used extensively in the
tanning process and for facility cleanup, the potential exists
for illicit discharges to storm water systems.
The pollutants expected to be found in storm water
discharges because of their use or generation during the tanning
and finishing process include chromium, TSS, BOD, and pathogens.
The leather tanning manufacturing process includes three basic
steps: beam house operations, where hides or skins are washed,
soaked, and the attached hair is removed using chemicals such as
sodium sulfate; tanyard process, where tanning agents containing
chromium are used to stabilize the proteinaceous matter in the
hides or skins; and retanning and wet finishing processes, where
further tanning is done with chemical agents, such as sodium
hydroxide and fat liquor. Water is essential to the tanning
process and is used in virtually all manufacturing processes. A
wide range of chemicals are used in the processes, including
solvents, detergents, lime, acids, chromium, organic tanning,
dyes, and lubricants (EPA 1982).
4.2.3.10 Stone* Clay, Glass» and Concrete Products
This group is composed of establishments involved in the
processing and/or manufacturing of stone, clay, and glass
products (SIC Code Group 32). Subgroups include flat glass,
glass and glassware (pressed or blown), products of purchased
glass, hydraulic cement, structural clay products glass, pottery
and related products, concrete, gypsum, and plaster products, and
miscellaneous nonmetallic mineral products.
A number of activities associated with stone, clay, and
glass production can contribute to storm water pollution. These
activities include loading/ unloading; storage of raw materials,
intermediates, products and residuals; and the generation of dust
and particulate. The two subgroups of particular concern in
terms of storm water discharges are hydraulic cement and asbestos
products manufacturing.
4 - 36
-------
In addition to cement, most hydraulic cement plants produce
concrete and cement blocks. The most common product of cement
manufacturing, portland cement, is made from a calcareous
material, such as limestone or chalk, and from alumina and
silica-bearing material, such as clay or shale. The
manufacturing process generally consists of: 1) grinding raw
materials and mixing in specified proportions, 2) burning in a
rotary kiln at a temperature of approximately 1,350'C (2,500'F),
3) cooling and grinding the clinker into a fine powder once the
material enters and partially fuses into balls (clinkers), and 4)
adding gypsum to control the setting speed when the cement is
mixed with water.
Sources of pollutants in storm water associated with cement
industry include transport, loading, and unloading of raw
materials, products, and residuals; storage of raw materials,
products, and residuals; and processing dusts, including kiln
dust. Effluent guidelines and standards have been promulgated
for storm water discharges from material storage pile runoff from
the storage of raw materials intermediate products, finished
products, and waste materials at cement manufacturing facilities,
is regulated (40 CFR Part 411).
The primary pollutant associated with storm water discharges
in cement manufacturing is solids. In addition, due to the use
of calcareous materials, the resulting pH of storm water runoff
from these facilities can also be of concern. Effluent
guidelines for runoff from cement manufacturing specify
limitations for total suspended solids and pH.
The asbestos industry can generally be described in terms of
the products manufactured: asbestos textiles, including
asbestos-bearing yarn, cord, thread, cloth, roofing, lap, wick,
rope, tape, and carded fibers; asbestos friction materials,
including products used in transportation, mining, and heavy
industry; and asbestos gaskets for packing and insulation. The
manufacturing processes include various mechanical operations
that are mostly dry and relate to grading and forming of asbestos
fibers. Major water uses are wet scrubbers and wet mixing of
molding materials for the production of asbestos friction
materials. Asbestos dust from air exhaust systems and material
handling facilities can adversely impact storm water quality.
4.2.3.11 Primary Metals Industries
The facilities in this group (SIC Code Group 33) are engaged
in the primary manufacturing of ferrous metals and metal products
and the primary and secondary smelting and refining of nonferrous
metals. In addition, facilities engaged in the molding, casting,
or forming of ferrous or nonferrous metals are included in this
group. The following discussion regarding potential sources of
4-37
-------
pollutants in storm water discharges applies to all industries
within the group, and examples for specific facilities are
provided.
The primary sources of pollutants in storm water discharges
from these facilities will result from the storage and handling
of raw materials, finished products, and wastes. Open air
storage and handling of raw materials, products, and wastes is a
common practice at many of these facilities. In addition, dust
and particulate-generating processes, particularly at smelting
and refining facilities, are considered potential sources of
pollutants in storm water discharges. Slag quench processes
performed at metal molding and casting facilities has a high
potential to add pollutants to storm water discharges. Also,
based on the high process water usage for operations such as
spray quenching, heat treating, and die cooling, and the old age
of many primary metals industry facilities, there is a reasonable
potential for illicit connections and discharges to storm water
collection systems.
Storm water from the storage of raw material and waste has
the potential to contain leached metals, total dissolved and
suspended solids, adverse pH levels, and possibly other inorganic
pollutants. A particular area of concern in the primary metals
category are coal and coke storage and handling areas. Table 4-
12 presents runoff data from coal and coke storage areas at iron
and steel manufacturing facilities. As shown, elevated
concentrations of TSS, iron, and ammonia are present in storm
water runoff. Storm water from the storage of finished products
also has the potential to contain metals, oil and grease, adverse
pH levels, and TSS.
4-38
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TABLE fiB. SUMMIT of Results
Study of Runoff Proa Coal and Coke Storage Piles at
Iron and Steel Facilities
(continued)
Pollutant Site No. Potential Problem Areas
Average Vet Concentrations
(mg/L)
Aoraonia
Sulfate
1
2
1
2
1
2
1
2
1
2
1
2
Coal storage
Coke storage
Coke and coal handling
Coal storage
Coke storage
Coke and coal handling
36
0.33
2.1
29.3
43
n.a. (c)
n.a. (b)
232
n.a. (b)
129 (d)
312
n.s. (c)
(a) n.d. - none detected.
(b) n.a. - not analyzed.
(c) n.s. - no samples collected.
(d) There vere tvo sampling points near the coke storage area at Site 2.
average concentrations for only one (outfall 013) are shovn.
Source: Bookman 1979
The
-------
Pollutant Sit. No. Potential Proble.
Areas
Average Wet Concentrati
ons
IDS
Total iron
Dissolved
iron
Phenols
Cyanide
(total)
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
Coal storage
Coke storage
Coke and coal handling
Coal storage
Coke storage
Coke and coal handling
Coal storage
Coke storage
Coke and coal handling
Coal storage
Coke storage
Coke and coal handling
Coal storage
Coke storage
Coke and coal handling
Coal storage
Coke storage
Coke and coal handling
4187
853
505
392 (d)
184
n.s. (c)
2239
471
745
959 (d)
2158
n.s. (c)
39.3
18
32.3
12.6 (d)
2.4
n.s.
n.d. (a)
0.2
0.1
1.0 (d)
0.1
n.s. (c)
0.39
0.01
0.06
0.03 (d)
0.37
n.s. (c)
n.d. (a)
n.d. (a)
0.01
0.35 (d)
n.d. (a)
n.s. (c)
-------
Particulate emissions from smelting and refining operations
can also result in high levels of pollutants in storm water
discharges. Metals associated with these particulate emissions
can generally be related to the primary metal being manufactured.
An example of the large potential for pollutants in storm water
involves a secondary lead smelter. Levels as high as 350,000
parts per million of lead were detected in a storm drain adjacent
to the closed smelting facility (Seattle Metro 1987). Sediment
taken from the storm drain had lead concentrations so high that
it was sold to another smelter for reprocessing.
4.2.3.12 Metal Products Industries
This industry category includes facilities involved in the
manufacture of metal and metal-related products. Facilities
within this category are classified according to the following
major SIC Code Groups: fabricated metal products (SIC Code Group
34), industrial machinery and equipment (SIC Code Group 35),
electronic and other electrical equipment (SIC Code Group 36),
transportation equipment (SIC Code Group 37), and instruments and
related products (SIC Code Group 38).
The sources of pollutants to storm water are similar
throughout this industry group. Generally, these sources relate
to storage, waste water treatment, emissions from fume exhaust
systems, and potential illicit connections to storm water
systems.
Metal finishing, electroplating, and coating facilities (SIC
Codes 3471 and 3479) generally conduct all manufacturing
processes indoors, although in warmer climates some plants
operate waste treatment facilities outdoors. Loading/unloading,
storage, and air emissions are the major sources of storm water
pollutant loadings associated with industrial activity.
Most chemicals purchased by this industry (e.g., acids,
caustic, metal salts, cyanide salts, solvents, and paints) are
packaged in drums. Some larger facilities purchase bulk
quantities of chemicals that are unloaded from rail cars or tank
trucks. Most raw material chemicals are stored indoors although,
some storage is outdoors (e.g., bulk storage of caustic or acid).
Waste residuals (e.g,. sludges, spent solutions) are stored
outdoors in drums, rolloffs, or hoppers, which may be exposed to
rainfall.
Some of the chemical processes at metal finishing,
electroplating, and coating plants require fume exhaust systems.
Processes typically included are chromium plating; hard coating
of aluminum; aluminum and copper etching; iron and steel
pickling; aluminum bright dip; lead plating; copper plating;
nickel plating; anodizing; chromating; phosphating; painting; and
4 - 40
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zinc plating. Exhaust systems nay include a wet scrubber system
or mesh pad mist eliminator to remove contaminants from the
exhausted air stream. The treated or untreated discharge air may
contain aerosols contaminated with toxic metals, transient
organics, and cyanide. Significant settling of pollutants may
occur on areas around exhaust pipes (typically roofs). Also,
areas around scrubbers, mist eliminators, and duct work can
potentially be contaminated by leaks and/or spills. The pollu-
tants of concern for metal finishing facilities are toxic metals,
cyanide, and solvents. EPA PCS data for treated storm water
discharges from an electroplating facility showed oil and grease
levels to range from 1.6 mg/L to 239.7 mg/L.
Porcelain enameling facilities (SIC Codes 3431 and 364) are
involved in the application of porcelain enamel coatings to base
metals to provide a decorative and protective finish. The
porcelain enameling process involves the preparation of the
enamel slip (formed from frit, a glassy raw material, clays and
other raw materials); the surface preparation of the base enamel;
drying; and firing to fuse the coating to the metal. Process
chemicals used include frit, clay, gums, bentonites, colloidal
silica, zirconium oxide, electrolytes, solvents, alkaline
cleaners, acids, nickel sulfate, cyanide, and chrornate.
The potential sources of pollutants to storm water from the
porcelain enameling industry are similar to those of the metal
finishing industry. These sources include storage of chemicals
and waste products, and emissions and leaks from air exhaust
systems. In addition, water is used in the porcelain enameling
industry for cooling such equipment as bull mills, air
compressors, and miscellaneous transport and power installations.
The pollutants of concern for the porcelain enameling industry
include toxic metals and solvents.
Battery manufacturing operations (SIC Codes 3691 and 3692)
involve anode and cathode manufacturing processes and various
ancillary operations. Ancillary operations are primarily
associated with battery assembly and chemical production of anode
and cathode active materials. Anodes are usually zero-valent
metals. The active mass for anodes is prepared by directly
cutting and drawing or stamping the pure metal or alloyed metal
sheet. Cathodes often consist of oxidized metals, such as lead
peroxide or nickel hydroxide.
Potential sources of pollutants in storm water include
outdoor storage areas, outdoor waste treatment operations, and
emissions from air exhaust systems. The pollutants of concern
are toxic metals. Waste waters and solid wastes from battery
manufacturing often contain one or more of the following toxic
metals: cadmium, lead, mercury, nickel, or zinc.
The electrical and electronic components industry segment
4-41
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(SIC Code Group 36) manufactures products such as electron tubes,
phosphorescent coatings, capacitors (fixed), capacitors (fluid-
filled) , carbon and graphite products, mica paper, incandescent
lamps, fluorescent lamps, fuel cells, magnetic coatings,
resistors, transformers (dry), transformers (fluid-filled),
insulated devices (plastic and plastic laminated), insulated wire
and cable (nonferrous), ferrite electronic parts, motors,
generators, alternators, resistance heaters, and switch gears
(EPA 1983).
The potential sources pollutants in storm water include
storage of raw materials, products and process residuals, and
waste water treatment systems. The potential storm water
pollutants from this industry include toxic metals and solvents.
4.2.3.13 Miscellaneous Manufacturing Industries
This category includes a variety of facilities that
manufacture miscellaneous products. Facilities within this
category are classified within SIC Code Group 39. Examples of
facilities within this group include jewelers, and musical
instrument, toy, and sporting goods manufacturers. Most of these
facilities employ processes similar to other manufacturing
facilities (e.g., the use of the electroplating process in
jewelry manufacturing).
4.2.4 CONSTRUCTION INDUSTRIES
4.2.4.1 Construction Practices
Typical construction practices include clearing and
grubbing, rough grading, facility construction, pest control, and
the restoration of staging and stockpile areas on completion of
the job.
Clearing and Grubbing;
Clearing and grubbing are typically the initial phases of a
construction activity. These activities create major
disturbances to the land surface, with construction of
transportation (highways) and energy networks (electric
transmission lines, and oil or natural gas pipelines) being some
of the largest construction activities. Unwanted vegetation such
as trees, shrubs, or tall grasses will be cleared from the site
or right of way. In some cases, the surface soil may be stripped
and stockpiled for use during site restoration. Unwanted
buildings or structures may be demolished or moved.
cutting of trees, other woody plants, and grasses can
produce large volumes of timber and wood waste. Some of the
timber can be used for lumber, plywood, or pulpwood. Remnants of
trees such as large branches and stumps can be used for wood
4-42
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chips which are buried in disposal sites or burned. Preparation
of wood chips is the preferred method of disposal of wood wastes,
because they serve as protective mulches on cut and fill slopes,
access roads, and certain staging areas.
Rough grading
Rough grading occurs at essentially all construction
operations, with grading being particularly important to highway
cuts and fills, excavations for dams and pipelines, and housing
and related land development.
Grading exposes extensive areas of soil to erosion from rain
and wind. For example, up to 30 acres of soil may be exposed per
mile of highway constructed. Under heavy rainfall, a road
construction site may produce 3,000 tons of sediment per mile.
Heavy construction equipment such as bulldozers and trucks
become both a direct and indirect source of storm water
pollutants. Diesel fuel, oil and lubricants are direct sources
of pollutants. In addition, construction equipment causes severe
compaction of clayey soils, lowering water infiltration and
making revegetation of graded areas more difficult. Compaction
of soils by heavy machinery reduces permeability and surface
storage and increases hydrologic activity (Novotny and Chesters
1981).
Site grading also establishes the drainage patterns for the
site after construction is completed. A well graded site can
reduce the volume and rate of storm water discharged from a site
after the construction is completed. However, a site which is
graded to remove as much storm water as quickly as possible can
result in high storm water volumes being discharged and erosion
problems.
Facility construction
Facility construction includes core drilling, foundation
grouting and concrete operations during the construction of
transmission structures, highways, buildings, and dams.
Activities associated with facility construction may also include
asphalt operations and the construction of storage areas or
workshops.
Washing equipment from concrete operations on site may
result in improper disposal or spillage of concrete or washwater
into receiving waters or along streambanks. Large volumes of
water are also used in washing of sand and stone aggregates.
Along with sediments, these materials may contain trace elements
such as cobalt, chromium, manganese, and lead.
Facility construction activities generate solid wastes from
4-43
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construction camps, shops and storage areas (including scrap,
trash, and sanitary wastes) which nay be washed into receiving
waters during storm events.
Pest Control and dust control
Pest control can involving spraying sites with insecticides,
herbicides, or rodenticide, to remove harmful insects, herbaceous
and woody plants, or unwanted animals. Pest control activities
are often undertaken at the onset of the construction operation.
Pesticides are also used to protect wooden structures and
structural elements from attack by subterranean termites.
Persistent chlorinated hydrocarbon insecticides, including
chlordane, aldrin, dieldrin, and heptachlor are the insecticides
primarily used for protection against subterranean termites.
These insecticides provide 18 to 20 years protection in most
instances.
Herbicides are sometimes used in construction projects such
as paving parking lots, driveways, secondary or county roads or
in similar situations where a relatively thin layer of concrete,
asphalt, blacktop, or other material is laid down. The
herbicides are applied to the soil surface to prevent sturdy
weeds from growing through the pavement. However, when properly
applied, this type of herbicide use presents little long-term
environmental risk because the method of application prevents
herbicide transport away from the site.
Dust control activities are often conducted after site
grading has been completed and before the site is restored.
Water, used or unused oil, and calcium chloride are commonly used
for dust control on access and haul roads, and on graded areas
subjected to heavy truck traffic.
Site Restoration
Site restoration includes cleanup of the site, final
grading, loosening and tillage of compacted soils, establishment
of permanent vegetation, restoration of damage to trees and
shrubs, removal of temporary stream fording structures or
sediment control structures, removal of temporary construction
facilities such as access and haul roads, reshaping,
stabilization and revegetation of pits and stockpile areas,
removal of office and work areas structures, and other practices
that reestablish a landscape capable of withstanding erosion.
These operations will vary in detail, but those involving
site cleanup, final grading, and establishment of permanent
trees, shrubs, grasses, and groundcover should be carried out in
accordance with erosion and sediment control plans, storm water
management plans, construction contracts and the landscape plans
4 - 44
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developed for the site. Incomplete or inadequate site
restoration nay result in the erosion of excess soil piles.
4.2.4.2 Pollutants in Storm Water from Construction Sites
About 1.6 million acres of land are disturbed annually
throughout the nation. As a rough approximation, construction
sites generate about 50 tons of soil loss per acre on average.
Some mismanaged areas on steep slopes may generate several
hundred tons of soil loss per acre. Nationwide, storm water
discharges from construction activities result in 85 million tons
of sediment being discharged to surface waters.
Where construction activities are intensive, the localized
impacts on water quality may be severe, and that even a small
amount of construction may have a significant negative impact on
water quality in localized areas (EPA 1984). For example, Konrad
(1978) reported that 37 percent of the total suspended solids
load and 48 percent of the total phosphorous load in one
watershed originated from 2.6 percent of the total area of the
watershed that was under development.
The amount of sediment in storm water discharges from
construction sites can depend on a number of factors. Scheduling
clearing operations during dry weather seasons can greatly reduce
sediment in storm water discharges relative to discharges from
poorly planned operations which expose large areas of cleared
surfaces during heavy rain. Staging clearing will also reduce
the amount of sediment from a site, as will grassed bufferstrips,
and retention ponds. Quick revegetation of disturbed soils at
construction sites can also minimize sediment production.
The potential for soil erosion is greatest during clearing
and grubbing, excavation, rough and final grading, and site
restoration/landscaping activities, where stripped topsoils and
exposing bare soils with no protection may exist. Where
construction activities have drastically altered or destroyed
vegetative cover and the soil mantle, sediment derived from these
construction sites may exceed 20,000 to 40,000 times that
obtained from adjacent, undeveloped farm or woodland in an
equivalent period of time (Virginia 1980).
Tables 4-13 and 4-14 presents soil loss data for
construction activities (Sullivan 1977, Oberts 1985, Tahoe 1980).
4-45
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TABLE
Construction Site Soil Los*
Area
Soil loss
(MT/km'/yr)
Maryland residential construction
Washington, DC, residential construction
Maryland residential, commercial
construction
Fairfax Co., Virginia, highvay construction
Georgia highvay construction
Montgomery Co., Maryland,
residential construction
Menomonee Basin, Visconsin,
residential construction
Highvay construction
Small urban construction
354-42,350
16,800
1,000-100,000
12,600
17,500-52,500
8,770-42,000
4,370
12,607
350-35,019
TABLE
Comparison of Pollutant Concentrations in Construction
Site and Residential Town Sediments
Parameter
Urban Residential
Construction Site
(mg/kg total solids)
Residential Lavn
(mg/kg total solids)
COO
TKN
Total Phosphate
Lead
Zinc
25,000
160
19
47
90
103,000
3,000
30
220
154
-------
Some constituents, such as nutrients, will be transferred
from a solid to a soluble form. Reported data (Whipple et al.
1983) indicate that the percentages of dissolved nitrogen (N) and
phosphorus (P) found in construction site runoff were 84.6
percent and 43.3 percent of total N and P, respectively.
Although most pollutants in storm water discharges from
construction sites are associated with soil loss, other sources
of pollutants include (EPA 1984):
o unloading and outdoor storage and processing of con-
struction-related materials. These materials include,
aggregate, sand, block, and dirt.
o Chemicals from fertilizer (phosphorus, nitrogen)
o Pesticides used to control weeds and insects;
o Petroleum products and.construction chemicals, such as
cleaning solvents, paints, concrete, asphalt, acids, and
salts; and
o Solid wastes ranging from employee litter to trees and other
debris.
The amount and type of pollutants in storm water discharges
depend upon the type and timing of construction practices, soil
types, topography, and number of people and machines linked with
the construction site.
The Report of the Ecology and Welfare Subcommittee of the
Relative Risk Reduction Project (SAB, 1990) indicates that sound
environmental planning and management to minimize the ecological
impacts of development should be a part of every approved
construction project.
4.2.5 WASTE MANAGEMENT AND RECYCLING INDUSTRIES
The waste management group includes waste treatment,
storage, and disposal facilities regulated under Subtitles C and
D of the Resource Conservation and Recovery Act (RCRA) and land
used for management of sludge from POTWs. Many of the facilities
within this group can be classified by SIC Code 495.
As discussed above, mining operations, oil and gas operations,
feedlots, and many manufacturing facilities manage their wastes
on-site. Waste management and recycling activities at these
facilities are not addressed in this section, but are considered
under the appropriate facility type.
4.2.5.1 Hazardous Waste TSDFs
4 - 48
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EPA has developed extensive regulations under Subtitle C for
facilities that treat, store, or dispose of hazardous wastes.
Commercial facilities providing treatment and disposal of
hazardous wastes employ physical/chemical/biological treatment
units, incinerators, and landfills. The majority of waste
treatment occurs in tanks or lined impoundments, where the
possibility exists for spillage if sufficient free board is not
maintained. Perhaps more significant are possible releases from
leaks or breaks in piping. Other potential sources of pollutants
are chemical handling areas (e.g., lime used for neutralization
of wastes) and sludge drying areas. In these areas, pollutants
can be added to storm water discharges from chemicals or sludges
being placed, spilled, or blown to the ground.
The transportation, loading, and offloading of hazardous
wastes at these facilities provide some opportunities for spills
and leaks. Soil and debris from transportation equipment can
contribute to pollutants in storm water discharges. Heavy
vehicles, including trucks and earth moving equipment, also have
the potential for contributing particulate emissions if roads
lack proper dust suppression programs.
Stack emissions from incinerators may result in high
pollutant concentrations in storm water discharges.
4.2.5.2 Subtitle D Facilities (Excluding Mining and Oil and Gas
Wastes)
Disposal of "nonhazardous" wastes is regulated under
Subtitle D of RCRA. These wastes include many different types of
waste streams, such as municipal solid waste, industrial waste,
and construction and demolition debris.
The Subtitle D waste stream is very diverse and includes
different types of wastes such as waste tires, infectious waste,
industrial nonhazardous waste, and municipal solid wastes. A
wide range of Subtitle D wastes are produced within each
industrial section. These waste streams may vary in chemical
composition and/or physical form. RCRA does not prohibit the
placement of very-small-quantity generator and household
hazardous waste in these landfills. Some large-quantity
generators may also be illegally disposing of their hazardous
wastes in Subtitle D units.
Municipal Solid Waste Landfills
EPA has summarized case studies documenting surface water
impacts and ground water contamination incidents. Evaluation of
163 case studies revealed surface water impacts at 73 facilities.
Elevated levels of organics, including pesticides, and metals
have been found in ground water and/or surface water at many
4-49
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sites. For most of these landfills, information on the waste
received either was not available or was incomplete, although a
limited number are known to have received hazardous waste before
EPA issued regulation under Subtitle C of RCRA.
Examples of ecological damage were also identified. Impacts
on fish or other aquatic life have been documented. Acute
catastrophic impacts (e.g., major fish kills) are not usually
associated with municipal solid waste landfills. Municipal solid
waste landfills are more likely to discharge pollutants to
surface water that would cause subtle changes to the aquatic
environment. A study conducted at one site indicated that the
diversity of benthic organisms downstream from the landfill was
much less than that found upstream. The few species that
survived downstream were more tolerant of the higher metal
concentrations from the landfill.
Of the 850 sites listed or proposed for listing on the
Superfund National Priorities List (NPL) in May 1986, 184 sites
(22 percent) were identified as municipal solid waste landfills.
Halogenated organics, aromatics, and metals were found at most of
these sites. Releases of hazardous materials to surface waters
were documented at 43 percent of these sites.
EPA estimates that annually, approximately 262 million
metric tons of nonhazardous industrial wastes were being disposed
of in 12,400 landfills, waste piles, and land application units.
Study results indicate only sporadic application of design and
operating controls at industrial landfills, with run-on/runoff
controls employed at fewer than 35 percent of industrial
landfills and 70 percent of industrial land application units.
The study estimated that only 6 percent of active industrial
landfills monitored discharges (storm water runoff or leachate)
to surface water.
On a national basis, EPA has found little difference in the
location, design, and operation of newer municipal solid waste
landfills compared to older landfills. In terms of location
characteristics, EPA found no real reduction in the siting of
municipal solid waste landfills in sensitive hydrologic areas
over the last twenty years, or in a comparison of pre- to post-
1980 facilities.
The use of engineering/design controls at municipal solid
waste landfills has increased only slightly over the last 20
years. EPA has found that about 50 percent of landfills 15 to 20
years old employ some type of surface water run-on/run-off
control system, increasing steadily to about 75 percent for
landfills built in the 1980s. For new municipal solid waste
landfills, EPA found the number of municipal solid waste
landfills that monitor releases to surface water to be about 15
percent, with no increases in percentages for new landfills.
4-50
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State inspection data, case study evidence, and risk
characterization studies, and the current limited use of design
controls indicate that some solid waste landfills have degraded
surface water quality and that this degradation could continue.
Older landfills are of most concern because they may have
received large volumes of hazardous waste and, in general, their
use of design controls was very limited. States reported that
1,100 municipal solid waste landfills monitored discharges to
surface water (12 percent of the total number) and 660 municipal
solid waste landfills were cited for surface water impacts.
4.2.5.3 Recycling Facilities
Facilities in this group are involved in significant
recycling of materials, including metal scrapyards, battery
reclaimers, salvage yards, and automobile junkyards.
Used motor vehicle parts (SIC Code 5015) includes, but is
not limited to, automobile junk yards. Junk yards typically
store damaged and/or old automobiles, trucks, and buses on paved,
gravel, grassy, or nuded lands. Because of the condition of
these vehicles and the activities occurring on the yard,
significant losses of fluids, which are sources of toxic metals,
oil and grease and PAHs, frequently occur. Weathering of plated
and nonplated metal surfaces result in contributions of toxic
metals to storm water.
Scrap and waste materials dealers (SIC Code 5093) have large
loading/unloading areas and may have outdoor storage. Scrap or
waste materials, when stored outdoors, contribute pollutants to
storm water discharges. Examples include ferrous and nonferrous
metals, used paper, batteries, chemicals, and chemical solutions.
Because of the wide range of waste products involved, all
pollutants of concern are considered to be potentially present
for this group.
Closed Facilities
EPA estimates that there are 32,000 closed solid waste
disposal facilities located across the United States. EPA has
noted concern about these facilities which represent potential
threats to human health and the environment because of their
number and because many were poorly designed and managed (see
August 30, 1988 (53 JFR 33314).
4.2.5.4 Application of Sludges from POTWs
Municipal sewage sludges may be applied to agricultural or
forestry lands; used for reclamation of disturbed or marginal
lands; used at turf farms, parks, and recreation areas; or used
in landscaping. Median and mean pollutant concentrations of
4-51
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sewage sludges are presented in Table 4-15,
4-52
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TABU
Sevage Sludge Pollutant Concentrations
Component
Total N
NH *-N
NO."-N
P ' .
K
Component
Cu
Zn
Hi
Pb
Cd
PCBs
Median (Percent)
3.30
0.09
0.01
2.30
0.30
Median (ng/kg*)
850.00
1,740.00
82.00
500.00
16.00
3.90
Mean (Percent)
3.90
0.65
0.05
2.50
0.40
Mean (Bg/kg*)
1,210.00
2,790.00
320.00
1,360.00
110.00
5.15
*0ven-dry solids basis.
-------
Sludge application programs may contribute to high pollutant
loadings in storm water depending on the operation and management
of the site. Associated activities of concern are ponding and
runoff from sites with poor drainage, sludge spills from
transport vehicles and pipelines, the tracking of mud from fields
onto highways, and dust generation from the use of haul vehicles
and equipment.
4.2.6 TRANSPORTATION FACILITIES
Transportation-related facilities including railroad
transportation (SIC Code Group 40), local and interurban
passenger transit (SIC Code Group 41), motor freight transport
and warehousing (SIC Code Group 42), the U.S. Postal Service (SIC
Code Group 43), water transportation (SIC Code Group 44), air
transportation (SIC Code Group 45), and transportation services
(SIC Code Group 47). All facilities within these groups are
expected to have a high potential for high pollutant levels in
storm water discharges. Table 4-16 lists the major groups in
this discussion and summarizes the potential sources of storm
water pollutants from various activities within each group.
4-54
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TABLI
Summary of Potential Storm Water Pollutant Sources
froa Transportation Industries
SIC Code
Industry
Potential Storm Water
Pollutant Sources
40XX Railroad Transportation
41XX Local and Interurban Transit
42XX Motor Freight Transportation
and Warehousing
43XX U.S. Postal Service
44XX Water Transportation (primarily
SIC Code 449X, Services Inci-
dental to Water Transportation,
such as cargo handling and
marina operations)
o Rail yards
o Outdoor maintenance areas
o Parking lots
o Loading/unloading areas
o Outdoor maintenance areas
o Parking lots
o Outdoor maintenance areas
(motor freight industries only)
o Parking lots
o Loading/unloading areas
(warehousing only)
o Outdoor maintenance areas
o Parking lots
o Outdoor maintenance areas (boat
cleaning, painting, and repair)
o Parking lots
o Loading/unlbading areas
-------
Many transportation facilities are involved in vehicle
maintenance and substantial material handling. Depending on the
nature of a given operation, vehicle maintenance and material
handling practices which occur outside may result in high levels
of pollutants in storm water discharges. Perhaps more
importantly, illicit connections, spills and improper dumping
associated with these operations may result. Floor drains in
garages and vehicle maintenance bays are of special concern. In
the past, floor drains where often improperly connected to storm
sewers because of prevailing construction practices,
inappropriate placement of the storm drains so it collects both
storm water runoff and maintenance drainage, and prior to the
construction of adequate POTWs, a desire to direct heavy greases
and solvents which can adversely impact a POTW's performance,
away from the POTW. Extensive building inspections by the Huron
River Pollution Abatement Program in Washtenaw County, Michigan
detected illicit discharges at a rate of 60 percent for
automobile related businesses, including service stations,
automobile dealerships, car washes and body shops. Materials
typically disposed via these illegal connections were oils,
greases, radiator fluids, detergents and solvents.
Activities involved in outdoor maintenance areas include
vehicle and equipment maintenance and cleaning; vehicle
refueling; and storage of oil, fuel, solvents, and wastes.
Loading and unloading areas, particularly in the rail and motor
freight industries, can also contribute pollutants to storm water
discharges. The extent and type of pollutants in storm water
discharges will depend upon the types of materials being handled
at the various facilities. These materials can range from
chemical raw materials or products to food-related materials or
products.
4.2.6.4 Airports
Major sources of pollutants in storm water discharges from
airports result from aircraft and ground vehicle maintenance,
aircraft and ground vehicle cleaning, transport/storage of fuels
and other petroleum products, and deicing of aircraft and
runways.
Aircraft and ground vehicle maintenance is generally
performed in hangers or garages, but some maintenance activities
may be performed outdoors. Maintenance activities may result in
losses of such vehicle fluids as motor oil, lubricants, and
hydraulic fluids used in ground vehicle engines, gear boxes,
brake systems, and aircraft hydraulic systems. Petroleum-based
cleaning solvents are used in vehicle maintenance for cleaning
and degreasing engine parts and other mechanical components (CDM
1987). Pollutants associated with maintenance include toxic
4-56
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metals, PAHs, and volatile organics.
Aircraft and ground vehicle cleaning is typically performed
outdoors, but not in all cases. The products used include soap
or detergent-based cleaning agents. Pollutants associated with
cleaning operations include BOD and TSS.
Various types of fuels and related materials are
transported, loaded, unloaded, and stored at airports. These
include jet fuel, gasoline, lubricating oil, and hydraulic fluid.
Table 4-17 presents data from Stapleton International Airport,
Denver, on the storage volumes of these materials (CDM 1987).
4-57
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Material
Jet Fuel
Above ground
Underground
Piping
Gasoline
Lubricating Oil
Hydraulic Fluid
Quantity Stored (gallons)
14,532,000
882,100
300,000
75,000
5,100
1,300
TABLE WK. Properties of Glycol-Based Fluids
Property
Ethylene
Glycol
Diethylene
Glycol
Propylene
Glycol
Biodegradability (BOD,)
Toxicity LD,0 (human)
LD,0 (rats)
750,000 mg/L 890,000 mg/L 1,000,000 mg/L
1.4 ml/Kg 1.0 ml/Kg 7.0 ml/Kg
5.5-8.5 ml/Kg 14.8-20.9 ml/Kg 32.5 nl/Kg
Source: U.S. Dept. of Transportation, Federal Aviation Administration.
-------
Spills from transport, loading, unloading, and storage are
relatively common at Stapleton. Records from 1977 to 1979 show
an average of 77 fuel spills at Stapleton per year. Pollutants
associated with the transport, loading, unloading, and storage of
these materials include PAHs, toxic metals, and transient
organics.
Aircraft and runway deicing operations are usually performed
with chemical solutions containing up to 50-percent ethylene
glycol. Runway deicing operations are performed by the airport
authority, while most aircraft deicing operations occur on pads
operated by an airlines. The length of the deicing season varies
across the country, with airports in Colorodo typically
performing deicing operations for nine months while airports in
Chicago may only deice for six months out of the year. The
amount of deicing fluids used depend on temperature and the
amount and type of preciptiation (freezing rain may require more
deicing fluids than many snowfalls) as well.
Urea and ammonium nitrate are the primary ingredients of
other deicing compounds used at airports. Both of these
chemicals act as nutrients and are oxygen demanding in water.
When deicing operations are performed, large volumes of ethylene
glycol are sprayed on aircraft and runways. Data from Stapleton
International Airport show that 62,986 gallons of concentrated
ethylene glycol were used during the month of February 1988
(Denver Public Works 1988). Properties of glycol-based fluids
are shown in Table 4-18. Ethylene glycol is toxic and exerts a
high oxygen demand on receiving streams when discharged at
significant concentrations. Data from Stapleton International
Airport indicate that storm water discharges contained levels of
up to 5,050 mg/L ethylene glycol during a monitoring period from
December 1986 to January 1987. The highest ethylene glycol
concentrations resulted in a BOD5 concentration of 2,525 mg/L
(COM 1987).
4-59
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4.2.6.5 Port Facilities
Storm water discharges from port facilities are of concern
due to the extremely large amounts of material transfer
operations, the proximity of facility to receiving water, waste
management practices, and certain washing and material
preparation activities that occur.
4.2.7 ELECTRIC POWER GENERATION
This category includes facilities engaged in the generation
and transmission of electricity, gas, or steam. Facilities
included in this category can be characterized according to SIC
Codes 491 (electric services), 492 (natural gas production and
distribution), and 493 (electric and gas services combined).
The remainder of this subsection discusses the steam electric
category.
Steam electric facilities generate energy through the use of
fossil and nuclear fuels. Types of steam electric facilities
include coal-fired power plants, oil-fired power plants, and
nuclear power plants. Transformers and raw materials such as
coal may be stored onsite at these facilities.
4.2.7.1 Coal Fired Plants
Coal is stored outdoors by coal fired utilities. Utility
stockpiles at the end of August 1980 were at 185,000,000 metric
tons. (Coal Outlook) Coal storage is expected to continue to
grow as coal consumption increases.
The effluent guidelines for the Steam Electric Power
Generating Point Source Category (40 CFR Part 423) address TSS
and pH in storm water runoff from coal piles. In addition, coal
pile runoff has high levels of total dissolved solids (TDS),
sulfate, iron, aluminum, mercury, copper, arsenic, selenium and
manganese. Table 4-19 shows storm water data collected from coal
piles at two electric power plants. In addition, Table 4-20
lists 1988 PCS data for treated storm water discharge reported by
117 electric service facilities nationwide.
4-61
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TABLE
*%tro. Edison
Portland,
"anganese
Acidity
itf°?-23fOOO
500-4,600
200-2,700
200-1,400
70-100
10-40
3»200-2,000
230-3,800
500-7,500
400-6,000
20-400
8-90
0.4-2.5
'-4,600
-------
TABLE MB. Summary of Permit Compliance System Data for
Stora Water Discharges Proa Electric Senrice Facilities
Pollutant
Electric Services (No. of Facilities • 117)*
Long-Tern Average
Concentration No. Observ.
Daily Maximum
Concentration No. Observ.
Oxygen-Demanding Pollutants (all in
Dissolved Oxygen
BOD
COD
Solids (all in mg/L)
TSS
Settleable solids
Metals (all in ug/L)
Arsenic
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Thallium
Nickel
Silver
Vanadium
Zinc
Antimony
Tin
Aluminum
Selenium
Mercury
3.9-8.0
0.6-2,600
•
•
0.0-6,520
0.02-1.00
•
•
0.0-209
<0. 01-0. 01
<0. 0-26.0
<0. 0-23.0
0.00-128
0.00-518
<0. 00-30.0
0.05-1.75
<0. 10-0. 10
0.01-55.0
<0. 00-7. 70
0.04-0.50
<0.01-506
<0. 30-0. 30
0.20-0.60
0.00-414
0.00-10.0
mg/L):
59
0
127
727
37
37
1
35
21
68
57
37
25
1
16
26
3
68
1
0
9
30
41
5.4-8.3
7.5-18.5
0.6-2,600
0.0-12,944
<0. 1-25.0
0.0-209
<0.0-0.01
<0. 0-26.0
<0. 0-23.0
0.00-128
0.00-3,768
0.00-30.0
0.05-18.8
<0. 10-0. 10
<0. 00-80.0
<0. 00-7. 70
0.04-0.50
<0.01-506
<0. 30-0. 30
0.10-1.50
0.30-0.60
0.00-414
0.00-10.0
35
2
137
881
37
60
13
70
41
101
107
70
14
1
48
38
3
100
1
9
9
49
59
'Data for all facilities in SIC Code 4911 reporting to PCS nationwide during
1988.
-------
-
TABU MSB. Siuattry of Penit Compliance Systea Data for
Stora Water Discharges Proa Electric Service Pacilitiea (continued)
Pollutant Electric Services (No. of Facilities » 117)*
Long-Term Average Daily Haxiouo
Concentration No. Observ. Concentration No. Observ.
Organics (most in ug/L):
TOC (mg/L) 4.0-8.0 4 7.0-64.7 8
Cyanide (mg/L) <0.01-20.0 26 <0.01-20.0 26
Toluene 3.50-5.00 2 <5.00-5.00 2
Benzene 3.50-5.00 2 <5.00-5.00 2
Ethylbenzene <3.00-5.00 2 <3.00-5.00 2
Nethylene chloride 1.00-15.0 2 1.00-15.0 2
1,1,1,-trichloro- <5.00-5.00 2 <5.00-5.00 2
ethane
PCBs in H20 <0.05-0.50 19 <0.05-1.00 29
Inorganics (all in mg/L):
Chloride 6.0-163 8 7.0-234 8
Sulfide <0.10-0.10. 3 <0.10-0.10 3
Sulfate 607-2,710 8 863-4,000 8
Chlorine 0.0-0.15 6 0.0-0.17 6
Other Pollutants:
pB 0.0-10.9" 832 0.0-11.9 838
Turbidity (JTU) 1.2-54.5 48 1.2-57.0 48
Total hardness 829-3,697 8 938-5,975 8
(mg/L)
Fecal colifora <2.0-840 2 <2.0-1,600 2
(cts/lOOml)
Hydrocarbons (mg/L) <0.10-7.30 38 <0.10-12.5 40
Oil and grease 0.0-17.8 407 0.0-233 581
'Data for all facilities in SIC Code 4911 reporting to PCS nationvide during
1988.
"pH range reported in this column is daily minimum, not long-term average.
-------
The pollutants in runoff and drainage from coal piles depend
on a number of factors, including: location, size and
configuration of the coal pile; composition of coal; climate; and
control technology used.
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5.0 SUMMARY OF OPTIONS FOR CONTROLLING POLLUTANTS
5.1 Background
Options for controlling pollutants in storm water discharges
associated with industrial activities (other than from
construction activities) will be discussed in terms of two major
pollutant sources: (1) materials discharged to separate storm
sewers via illicit connections, improper dumping, and spills; and
(2) pollutants associated with runoff collected by separate storm
sewers. Options for controlling pollutants in storm water
discharges associated with industrial activities from
construction activities are addressed separately.
a. Non-Storm Water Discharges to Separate Storm Sewers
As discussed earlier, in some cases, a substantial portion
of the pollutant load from separate storm sewers which discharge
storm water associated with industrial activity is associated
with non-storm water discharges. Non-storm water discharges to
separate storm sewers include a wide variety of sources,
including illicit connections, improper dumping, spills, or
leakage from storage tanks and transfer areas. Measures to
control spills and visible leakage can be incorporated into storm
water pollution prevention plans (see below).
In many cases, operators of industrial facilities may be
unaware of illicit discharges or leakage from underground storage
tanks or other non-visible systems. In some cases, illicit
connections to storm sewers were installed before their legal
prohibition, and forgotten about. For example, illicit
connections are often associated with floor drains that are
connected to separate storm sewers. Rinse waters used to clean
or cool objects, and other process wastewaters may be discharged
to the separate storm sewer by an improperly connected floor
drain. These non-storm water discharges to a storm sewer may be
inadvertent with the operator unaware that the floor drain is
connected to the storm sewer. In this case, the key to
controlling these discharges is to identify them.
Methods to Identify Non-Storm Water Discharges to Separate Storm
Sewers
Several methods for identifying the presence of non-storm
water discharges are discussed below1. A comprehensive
evaluation of the storm sewers at a facility may incorporate
several methods.
A more complete discussion of methods to identify illicit
connections can be found in "Draft Manual of Practice:
Identification of Illicit Connections", U.S. EPA, Sept. 1990.
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Schematics - Where they exist, accurate piping schematics
can be inspected as a first step in evaluating the integrity
of the separate storm sewer system. The use of schematics
is limited because schematics usually reflect the design of
the piping system and may not reflect the actual
configuration constructed. Schematics should be updated or
corrected based on additional information found during
inspections.
Evaluation of drainage map and inspections - Drainage maps
should identify the key features of the drainage system:
each of the inlet and discharge structures, the drainage
area of each inlet structure, and units such as storage or
disposal units or material loading areas, which may be the
source of an illicit discharge or improper dumping. In
addition, floor drains and other water disposal inlets that
are thought to be connected to the sanitary sewer can be
identified. A site inspection can be used to augment and
verify map development. These inspections, along with the
use of the drainage map, can be coordinated with other best
management practices discussed below.
End-of-pipe screening - Discharge points or other access
points such as manhole covers can be inspected for the
presence of dry weather discharges and other signs of non-
storm water discharges. Dry weather flows can be screened
by a variety of methods. Inexpensive onsite tests include
measuring pH; observing for oil sheens, scums and
discoloration of pipes and other structures; as well as
color-metric detection tests for chlorine, detergents, metals
and other parameters. In some cases, it may be appropriate
to collect samples for more expensive analysis in a
laboratory for fecal coliform, fecal streptococcus,
conventional pollutants, volatile organic carbon, or other
appropriate parameters.
Water balance - Many sewage treatment plants require that
industrial discharges measure the volume of effluent
discharged to the sanitary sewer system. Similarly, the
volume of water supplied to a facility is generally
measured. A significantly higher volume of water supplied
to the facility relative to that discharged to the sanitary
sewer and other consumptive uses may be an indication of
illicit connections. This method is limited by the accuracy
of the flow meters used.
Dry weather testing - Where storm sewers do not discharge
during dry weather conditions, water can be introduced into
floor drains, toilets and other points where non-storm water
discharges are collected. Storm drain outlets are then
observed for possible discharges.
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o Dye testing - Dry weather discharges from storm sewers can
occur for a number of legitimate reasons including ground
water infiltration or the presence of a continuous discharge
subject to an NPDES permit. Where storm sewers do have a
discharge during dry weather conditions, dye testing for
illicit connections can be used. Dye testing involves
introducing fluorometric or other types of dyes into floor
drains, toilets and other points where non-storm water
discharges are collected. Storm drain outlets are then
observed for possible discharges.
o Manhole and Internal TV Inspection - Physical inspection of
manholes and internal inspection of storm sewers either
physically or by television are used to identify potential
entry point for illicit connections. Dry weather flows,
material deposits, and stains are often indicators of
illicit connections. TV inspections are relatively
expensive and generally should be used only after a storm
sewer has been identified as having illicit connections.
b. Options for Preventing Pollutants in Storm Water
The following five categories describe options for reducing
pollutants in storm water discharges from industrial plants:
i) Providing end-of-pipe treatment;
ii) Implementing Best Management Practices to prevent pollution;
iii) Diverting storm water discharge to municipal sewage
treatment plants (where capacity exists to avoid a combined
sewer overflow);
iv) Using traditional storm water management practices; and
v) Eliminating pollution sources.
A comprehensive storm water management program for a given
plant may include controls from each of these categories.
Development of comprehensive control strategies should be based
on a consideration of plant characteristics.
i. End-of-Pipe Treatment
End-of-pipe treatment requirements are typically imposed
through numeric effluent limitations, which provide the
discharger with flexibility to design the most cost effective
type of treatment for the given facility.
At many types of industrial facilities, it may be
appropriate to collect and treat the runoff from targeted areas
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of the facility. This approach was taken with 10 industrial
categories with national effluent guideline limitations for storm
water discharges. There are several basic similarities among the
national effluent guideline limitations for storm water
discharges:
o to meet the numeric effluent limitation, most, if not all,
facilities must collect and temporarily store onsite runoff
from targeted areas of the plant;
o the effluent guideline limitations do not apply to
discharges whenever rainfall events, either chronic or
catastrophic, cause an overflow of storage devices designed,
constructed, and operated to contain a design storm. The
10-year, 24-hour storm, or the 25-year, 24-hour storm
commonly are used as the design storm in the effluent
guideline limitations; and
o most technology-based treatment standards are based on
relatively simple technologies such as settling of solids,
neutralization, and drum filtration.
Potential ground water impacts should also be considered by
operators when designing storage devices.
ii. Best Management Practices
The term best management practices (BMPs) can describe a
wide range of management procedures, schedules of activities,
prohibitions on practices, and other management practices to
prevent or reduce the pollution of waters of the United States.
BMPs also include operating procedures, treatment requirements
and practices to control plant site runoff, drainage from raw
materials storage, spills or leaks. BMPs can be established in
two ways: BMP plans and site or pollutant-specific BMPs.
BMP Plans
EPA has worked with industry to identify the generic BMPs
which most well-operated facilities use for pollution control,
fire prevention, occupational safety and health, or product loss
prevention. EPA often establishes NPDES permit conditions that
require generic BMPs to be identified and implemented through BMP
plans. Many of the BMPs in a typical BMP plan involve planning,
reporting, training, preventive maintenance, and good
housekeeping.
Many industrial facilities currently employ BMPs as part of
normal plant operation. For example, preventive maintenance and
good housekeeping are routinely used in the chemical and related
industries to reduce equipment downtime and to promote a safe
work environment for employees. Good housekeeping BMPs generally
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are aimed at preventing spills and similar environmental
incidents by stressing the importance of proper management and
employee awareness. Experience has shown that many spills of
hazardous chemicals can be attributed, in one way or another, to
human error. Improper procedures, lack of training, and poor
engineering are among the major causes of spills. Experience has
shown that BMPs can be used appropriately and BMP plans can
effectively reduce pollutant discharges in a cost-effective
manner. BMP plans should reflect requirements for Spill
Prevention Control and Countermeasure (SPCC) plans required under
section 311 of the CWA, and may incorporate any part of the SPCC
plan into the BMP plan by reference. BMP plans should also
ensure that solid and hazardous waste is managed in accordance
with requirements established under the Resource Conservation and
Recovery Act (RCRA). Management practices required under RCRA
should be expressly incorporated into the BMP plan.
In addition, each of the following nine specific
requirements should be addressed in the BMP plan to reduce
pollutants in runoff from the plant:
o Statement of policy
o Spill Control Committee
o Material inventory
o Material compatibility
o Employee training
o Visual Inspections
o Preventive maintenance
o Reporting and notification procedures
o Housekeeping
o Security
Additional technical information on BMPs and the elements of
a BMP plan is contained in the publication entitled "NPDES Best
Management Practices Guidance Document," U.S. EPA, June 1981.
Site or Pollutant-Specific Best Management Practices
In addition to the requirements of BMP plans discussed
above, more advanced site or pollutant-specific BMP requirements
can be developed. The following four categories describe these
site or pollutant-specific BMPs:
o Prevention
o Spill Prevention and Containment
o Mitigation
o Ultimate Disposition
Table 5-1 lists BMPs associated with each category.
Containment requirements
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EPA believes that tank systems for storage of liquid toxic
chemicals and truck and rail transfer facilities for liquid toxic
chemicals can present a significant risk, if basic accepted
engineering practices are not employeed. EPA has concluded on
the basis of studies, information from other governmental
sources, and supporting information on various rulemakings that
many tank systems have leaked and that other are likely to leak
in the future2.
The major causes of releases from tank systems are unrelated
to the characteristics of the material stored in the tanks,
assuming that the stored material is compatible with the material
of construction of the tank system. EPA's "Hazardous Waste Tank
Risk Analysis11, EPA, 1986 indicates that the principal causes of
reported tank failures are external corrosion, installation
problesm, structural failure, spills, and overfills due to
operator errors, and ancillary equipment failure, and that
current practices lead to a substanital prbability of release to
the environment from tank failures due to corrosion, rupture,
improper intallation, gasket failures, and operator errors. The
analysis also indicated that current practices tend to allow
releases to continue undetected until the release becomes
obvious. The analysis estimated that for all tank systems
(including above and below ground), approximately 10 percent or
less of the tank system throughput over a 20 year time period
would be released using current management practices.
The Spill Prevention Control and Countenneasure (SPCC)
database and the Pollution Incident Reporting System (PIRS)
database provided valuable information on the causes of failure
and releases from aboveground storage tanks3. Exclusive of
failures caused by operator error and natural phenomena, failure
by all forms of corrosion was 2.2 percent in the PIRS database
and 6.2 percent in the SPCC database.
The SPCC and PIRS databases indicate that structural failure
accounted for between 6 and 7 percent of the reported failures
for aboveground tanks. An OSWER study indicates that it is not
possilbe to identify specific causes of structural failure.
Structural failures can include fabrication defects, design
defects, mechanical failures, or structural failures.
Failures of ancillary equipment is a significant cause of
releases from above ground systems. The SPCC and PIRS databases
indicate over 2,000 incidents of spills of oil or hazardous
substances reported. If failures due to operator error and
natural phenomena are excluded, between 85 and 90 percent of
2 For example, see July 14, 1986 (51 FR 25427).
3 See July 14, 1986, (51 FR 25429).
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theese release incidents result from filures of piping systems
(inclduing failures of pumps, flanges, couplings, interconnecting
hoses, and valves).
Structural failure problems can be attributed to a large
degree to improper design and installation. Certification by a
qualified professional engineer that the design and installation
is in accordance with sound engineering practices and applicable
standards can be of considerable benefit. The major limitation
of design and installation standards is that once a tank system
is designed, built and installed, improvements in the standards
or even errors in applying the standards cannot be retrofitted in
most cases. Thus, some form of containment system or release
monitoring system is necessary to control these situations.
Most releases associated with ancillary equipment appear to
have resulted from mechanical and thermal stresses common to
daily operation. These stresses are most evident on the
components of the systems that are most susceptible to wear, such
as pipes with flanges or threaded connections, valves, and pumps.
Pumps and valves, for example, are designed with moving parts and
seals that periodically deteriorate with use.
The principal leak prevention measure for ancillary
equipment is its proper design and installation. The design
should match its intended function taking into consideration the
proper material of construction. The material of construction
must match the thermal coefficients of expansion and corrosive
properties of the substances transported. A quality audit of
tank system installation, especially to prevent loose fittings,
poor welding, and maligned gaskets, will prevent many leaks. The
difficulties of addressing the problems of structural failure and
corrosion of ancillary equipment are similar to those of the
tanks themselves. Thus, in addition to prop[er design and
installation of ancillary equipment, some form of release
detection is required to enable an appropriate response in the
event of a release from even a well-designed and installed
system. In addition, various forms of secondary containment are
capable of containing a release in the event of a failure of the
primary containment system.
Operator errors are among the most prevalent causes of tank
system leaks and releases. Proper training and establishment of
standard operating procedures and safety activities can reduce
the occurrence of human errors. Spill control and contingency
plans, training plans and operating procedures are important.
Some operator errors can be averted by installing engineered
safeguards. Overflow protection devices can be installed on tank
systems to provide warning to the operator and or to shutdown
transfer pumps when the tank reaches full capacity. Protective
guards can be installed to prevent vehicular or forklift damage
to tanks. Proper tagging or labeling valves can help alleviate
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human error in operating valves. Tank design standards, such as
specification of a minimum freeboard requirement and a minimum
volume requirement for secondary containment, can also help to
reduce the consequences of human error.
In addition to the direct methods for controlling or
reducing the likelihood of releases from tank systems there are a
number of monitoring methods and backup devices that are capable
of addressing, to varying degree, the problems associated with
releases due to corrosion, poor design, fabrication, and/or
installation of piping and other ancillary 'equipment, and
operator error. These include tank system inspection, leak
detection, and secondary containment.
Physical inspections can be conducted in order to detect
existing leaks and to identify problem areas that can lead to
releases if not repaired. If a release is detected early and
response measures are taken, inspections can reduce risks.
Inspections can commence at the time a tank system is installed
and can be conducted on a periodic basis thereafter. Periodic
inspections can include visual inspections of tanks (foundations,
connections, coating, and tank walls), internal inspections for
tanks which can be entered, and visual inspection of pipes and
ancillary equipment. Inspection equipment includes penetrate
dyes, vacuum boxes , ultrasound instruments, and radiographic
equipment.
While regular visual inspections can reduce risks, they
cannot be relied upon completely. There are many problems that
visual inspection would not reveal and because visual inspection
is an episodic rather than continuous process, detection of
releases may occur after significant quantities of toxic
pollutants have migrated to the environment.
If a leak is detected early and response measures taken,
this approach can reduce risks. There are an umber of leak
detection methods that can be applied to tank systems, including
pneumatic, valve manometer, liquid level bubble, fabricated
float, laser beam, overfill/standpipe, buoyancy sensor, and
capacitance probe tests.
Secondary containment is a method of containing releases to
enable detection of toxic materials leaking from tank systems.
Secondary containment technologies include berms, dikes, liners,
vaults and double-walled tanks. When combined with monitoring,
the overwhelming advance of secondary containment is that it
allows for the detection of releases from the primary containment
vessel while providing a secondary barrier that contains the
released material before it is discharged.
There are other benefits to secondary containment.
Secondary containment can isolate the primary tank from high
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ground water and saturated soils, thereby protecting the tank
from potential corrosion by the combination of water and
corrosion-inducing soils. Another important benefit is that the
secondary containment system can also be designed to provide for
containment and detection of accidental spills and overfills.
The secondary containment system designs incorporating vaults and
berms, spills and overfills can be easily detected by visual
examination and also decontaminated readily. This compensates
for human errors and reduces the reliance upon flawless operator
performance. Secondary containment prevents spills and overfills
whose volume does not exceed the capacity of the secondary
containment from being discharges.
Secondary containment can afford security for other causes
of tank failure. As a secondary barrier, it can eliminate
releases caused by point anode corrosion, collect leakage from
loose fitting and worn seals on valves and pumps, and prevent
releases due to structural failure of the tank system.
Containment requirements can take a number of forms. EPA
has analyzed various models for containment requirements for
chemical handling/storage facilities include requirements for:
Spill Prevention Control and Countermeasure (SPCC) plans for oil
facilities (40 CFR 112); hazardous waste tank requirements for
hazardous waste generators (40 CFR 262); hazardous waste tank
requirements for treatment, storage and disposal facilities (40
CFR 264 and 265); underground storage tank requirements (40 CFR
); Occupational Safety and Health Administration (OSHA) general
safety and health regulations for flammable and combustible
liquids that require suitable drainage or diking for the area
surrounding tanks (29 CFR 1910); the National Fire Protection
Association (NFPA) code 30 (widely adopted by localities);
Department of Transportation (DOT) requirements for oil pipelines
(49 CFR 195); and the Minerals Management Service (MMS) of the
Department of Interior requirements for the containment and
collection of oil discharges from offshore drilling operations
(30 CFR 250).
These requirements have helped establish current engineering
practices for millions of tanks . EPA believes that the majority
of facilities with large amounts of toxic chemical storage
facilities have existing spill prevention and containment
systems. For example, the majority of hazardous waste tanks (63%
of 9,100 hazardous waste tanks in 1986) were found to have some
type of partial or full secondary containment prior to the
development of more stringent containment requirements under RCRA
Subtitle C (see July 14, 1986 (51 FR 25422)). Many facilities,
For example, SPCC requirements apply to 700,000 on-shore
tanks and 190,000 off-shore facilities, and UST requirements apply
to over 1,000,000 tanks.
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especially medium- and large-sized facilities also perform
integrity and leak testing .
Containment requirements: SPCC Model
40 CFR 112 establishes pollution prevention requirements,
including requirements for Spill Prevention Control and store or
handle oil. The requirements associated with 40 CFR 112 are
similar to the requirements in the NPDES draft general permits
for spill prevention and containment measures at SARA Title III,
Section 313 facilities. Costs associated with SPCC plan
requirements under 40 CFR 112 where evaluated from a number of
sources, including "Economic Impact Analysis of Proposed
Revisions to the Oil Pollution Prevention Regulation (40 CFR
112), EPA, draft January 1991, "Supplemental Cost/Benefit
Analysis of the Proposed Revisions to the Oil Pollution
Prevention Regulation", EPA, May 1991; and data provided by the
American Petroleum Institute (API).
The SPCC requirements apply to over 250,000 facilities with
significant amounts of oil. These facilities can be described in
term of four sectors: 1) production (246,000 facilities with
572,620 tanks); 2) marketing (11,305 facilities with 88,529
tanks); refining (207 facilities 88,529 tanks); and
transportation (2,132 facilities with 9,197 tanks). The
transportation sector addresses pipeline facilities (also
regulated under 49 CFR Part 195). In general, facilities in the
transportation sector where not addressed in this analysis, since
the NPDES general permits requirements for SARA Title III,
Section 313 facilities, in general, do not apply to similar types
of faciltiies or practices.
A analysis of the causes of spills that was developed to
support SPCC regulations is included in Appendix A.
Numerous Federal regulations, industry standards, and
recommended practices were reviewed during the data gathering
process for characterizing the regulated community and the causes
of oil spills. This section presents a brief summary of each of
the regulations, standards, and recommendations reviewed during
preparation of this rulemaking. Only a cursory description of
each is provided; the complete regulation, standard, or
recommended practice should be referred to for additional and
more detailed information. Exhibit 1 presents a summary of
Federal regulations and industry standards/recommendations which
were reviewed and found to contain applicable information
pertinent to each of the technical requirements examined in this
5 U.S. EPA, Retaliatory Impact Analysis of Technical Standards
for Underground Storage Tanks. Volume 5, 1988, p. 6-20.
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rulemaking. These regulations and standards apply to aboveground
tanks, pipes, and operations associated with the storage of
petroleum. Exhibit 1 identifies specific sections and/or
chapters from the regulations and standards which impact each
issue.
SUMMARY OF STANDARDS AND RECOMMENDED PRACTICES
API Standard 620 — Recommended Rules for Design and Construction
of Larae. Welded. Low-Pressure Storage Tanks.
Seventh Edition, September 1982, Revision 1,
April 1985.
The American Petroleum Institute (API) rules are intended
to cover the design and construction of large, welded, low
pressure, carbon steel, aboveground tanks. The rules only
cover those tanks which are of such a shape that can be
generated by the rotation of a suitable contour around a
single vertical axis. API Standard 620 covers tanks that
are operated at metal temperatures not exceeding 200°F and
with pressures in their gas or vapor spaces exceeding those
permissible under API Standard 650, but not exceeding 15
pounds per square inch gauge. The basic rules provide for
installations in areas where the lowest recorded one-day
mean atmospheric temperature is as low as -50°F. These
rules may be used for tanks intended either for holding or
storing liquids with gases or vapors above the surface of
the liquid or for holding or storing gases or vapors alone.
These rules do not apply to "lift-type" gas holders.
Although this Standard does not cover horizontal tanks, it
is not intended to preclude the application of appropriate
portions to the design and construction of horizontal tanks.
API Standard 650 — Welded Steel Tanks for Oil Storage. Eighth
Edition, November 1988.
API Standard 650 covers material, design, fabrication,
erection, and testing requirements for vertical,
cylindrical, aboveground, closed- and open-topped, welded
steel storage tanks in various sizes and capacities with
internal pressures approximating atmospheric pressure,
except that a higher internal pressure is permitted when
certain additional requirements are met. This standard only
covers tanks whose entire bottom is uniformly supported and
tanks in non-refrigerated service that have a maximum
operating temperature of 200°F.
API RP 651 — Cathodic Protection of Above-Ground Petroleum
storage Tanks. Final Revision, January 1990.
API Recommended Practice (RP) 651 is a draft document which
provides recommended practices to limit potential corrosion
5-11
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problems common to steel aboveground tanks. It presents a
description of corrosion problems and methods for evaluating
the need for cathodic protection. This publication also
describes the design, installation/ and maintenance of
various types of cathodic protection systems.
API RP 652 — Lining of Above-Ground Petroleum Storage Tanks
Bottoms. Draft 10, May 1990.
API RP 652 presents procedures and recommended practices for
improving corrosion control in aboveground storage tanks by
the addition of linings to tank bottoms. It includes a
description of the various types of corrosion which may
affect tank bottoms, and factors which should be considered
when evaluating the need for and suitability of different
types of linings. It provides general guidance on
application of linings.
API Std 653 — Tank Inspection. Repair. Alteration, and
Reconstruction. First Edition, January 1991.
The recently adopted API Standard 653 is applicable to
carbon and low-alloy steel tanks built to API Standard 650
and its predecessor 12C. It provides minimum standards to
maintain the integrity of aboveground, non-refrigerated,
atmospheric tanks which are already in service. Some of the
topics covered include suitability for service, brittle
fracture, repair and alteration, reconstruction, and
inspection and testing.
API 2008 —— Safe Operation of Inland Bulk Plants. Fourth
Edition, June 1984.
API 2008 is an informational publication and is focused
primarily on worker safety issues. This document addresses
operational standards such as inspection of foundations and
pipe fittings. This publication is not considered an
industry standard.
ASME/ANSI B31.3 — Chemical Plant and Petroleum Refinery Piping.
1987 Edition.
The American Society of Mechanical Engineers (ASME)/American
National Standards Institute (ANSI) B31.3 code is a section
of the ASME/ANSI B31 Code for Pressure Piping. It is
applicable to piping systems handling nearly all types of
fluids, and to nearly all types of service, including oil
and other petroleum products. It includes requirements for
materials, design, fabrication, assembly, erection,
examination, and inspection of piping systems.
ASME/ANSI B96.1 — Welded Aluminum-Allov Storage Tanks; 1986
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Edition/ 1988 Addenda.
ASME/ANSI B96.1 is applicable to field-erected, vertical,
cylindrical, welded, aluminum-alloy tanks. Other
restrictions are included. It addresses the design,
materials, fabrication, erection, inspection, and testing
requirements. It does not contain allowances for corrosion.
NACE RP 0285 — Standard Recommended Practice - Control of
External Corrosion on Metallic Buried,
Partially Buriedf or Submerged Liquid Storage
Systems. March 1985.
The National Association of Corrosion Engineers (NACE) RP
0285 is applicable to buried, partially buried, or submerged
ferrous metal liquid storage systems, It addresses
determination of the need for corrosion control, corrosion
control design considerations, coatings; and criteria for
design, installation, operation, and maintenance of cathodic
protection systems.
NFPA 30 — Flammable and Combustible Liquid Codes. 1987
Edition.
The National Fire Protection Agency (NFPA) has established
The Flammable and Combustible Codes (NFPA 30), which apply
to all flammable and combustible liquids except those that
are solid at 100°F or above. Its provisions are intended to
reduce the hazard to a degree consistent with reasonable
public safety, without undue interference to public
convenience and necessity, for activities which require the
use of flammable and combustible liquids. It includes
requirements for aboveground, underground, and portable
tanks. Requirements concerning design and construction of
buildings which contain tanks are also discussed.
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NFPA 30A — Automotive and Marine Service Station Code. 1987
Edition.
The Automotive and Marine Service Station Code (NFPA 30A)
applies to automotive and marine service stations primarily
with underground but also aboveground storage. Its
provisions are intended to reduce hazards which require the
use of flammable and combustible liquids. This Code does
not apply to those service stations, or portions of service
stations, where liquified petroleum gases or compressed
natural gases are dispensed as automotive fuels.
NFPA 31 — Installation of Oil Burning Equipment. 1987
Edition.
The Installation of Oil Burning Equipment Standard (NFPA 31)
applies to oil-fired stationary equipment, including but not
limited to industrial-, commercial-, and residential-type
steam, hot water, and warm air heating plants; domestic-
type range burners and space heaters; portable oil burning
equipment; and all accessory equipment and control system,
whether electric, thermostatic, or mechanical and electrical
wiring in connection therewith. This standard does not
apply to internal combustion engines, oil lamps, and
portable devices such as blow torches, melting pots, and
weed burners.
NFPA 78 — Lightning Protection Code. 1989 Edition.
NFPA 78 presents lighting protection requirements for
structures containing flammable vapors and gases, as well as
liquids which can give off flammable vapors.
Underwriters Steel Abovearound Tanks for Flammable and
Laboratory Combustible Liquids. Sixth Edition, Revised
(UL) 142 — September 1987.
Underwriters Laboratory (UL) 142 is applicable to
aboveground, horizontal and vertical, welded steel tanks
intended for the outside storage of flammable and
combustible liquids at pressures in the vapor spaces between
atmospheric and 0.5 psig. These types of tanks are intended
for use with only noncorrosive, stable liquids that have a
specific gravity not exceeding that of water. These
requirements do not apply to tanks covered by API 650, API
12D, API 12F, or vertical tanks elevated by legs or
supporting skirts.
SUMMARY OF REGULATIONS
E.O. 11988 — Floodplain Management
5-14
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Executive order (E.O.) 11988 was issued in 1977, to serve as
a guideline for use by federal agencies to provide effective
flood management policies. Its goals are to avoid or
minimize adverse impacts associated with occupancy and
modifications of floodplains and to avoid direct and
indirect support of development on floodplains when there
are practical alternatives. Guidelines for implementing
E.O. 11988 have been promulgated by the Water Resources
Council (1978) and the Interagency Task Force on Floodplain
Management (1983).
FEMA 44 CFR 60 — Criteria for Land management Use
The Federal Emergency Management Agency (FEMA) regulation
contained in 44 CFR 60 constitutes part of a set of
regulations which establish a system for providing insurance
to interested parties in flood-prone areas. Part 60
provides requirements for general structures, including
aboveground petroleum storage tanks, located in flood hazard
areas, which must be met by flood-prone communities applying
for flood insurance eligibility.
OSHA
29 CFR 1910.120 —— Occupational Safety and Health Standards
The Occupational Safety and Health Administration (OSHA)
standards at 29 CFR 1910.120 are applicable to certain
operations which involve employee exposure or the reasonable
possibility for employee exposure to safety or health
hazards during; 1) required and voluntary clean-up
operations at uncontrolled hazardous waste sites; 2)
corrective actions at Resource Conservation and Recovery Act
(RCRA) sites; 3) operations at Treatment, Storage, and
Disposal (TSD) facilities; and 4) emergency response
actions. These regulations address operation of health and
safety plans, site characterization and analysis, site
control, personnel training, medical surveillance,
engineering controls, work practices, and personal
protective equipment. The OSHA Standards also cover such
items as environmental monitoring, handling of containers,
decontamination, and operations conducted at various types
of sites. OSHA has decided that petroleum products are
covered by these regulations; as a result, petroleum
handling facilities must adhere to them.
USCG 33 CFR 154 — Oil Pollution Prevention Regulations for
Marine Oil Transfer Facilities
USCG 33 CFR 154 is applicable to any facility which is
capable of transferring oil in bulk to or from a vessel with
a capacity of 250 or more barrels of oil. The USCG
5-15
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regulations address the operations manual requirements,
equipment requirements, and facility operations.
USCG 33 CFR 156 — Oil and Hazardous Material Transfer
Operations
USCG 33 CFR 156 provides requirements which are designed to
prevent the spillage and leakage during the transfer of oil
and hazardous materials from, to, or within any vessel
(except public vessels) with a capacity of 250 or more
barrels of that material. Subpart A addresses pollution
prevention regulations for oil transfer operations. Special
requirements for the lightering of oil and hazardous
material cargoes are discussed in Subpart B.
Containment requirements? Hazardous waste tanks
The RCRA Subtitle C requirements for hazardous wastes is a
more stingent model of control than the SPCC approach. The RCRA
model requires the use of double-walled tanks, double-walled
pipe, corrosion protection and a lined concrete pad and curbing
beneath (see July 14, 1986, (51 FR 23466)). In addition,
closure, post-closure, and corrective action requirements are
required for treatment, storage and disposal facilities.
5-16
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Exhibit 1
Review of Storage Tank Codei and Standard!
Other Tech.
Requirements
Lightning Protection
Control
Teat ing
Certification of
Tank Inatallation
Plant Security
Flood Protection
Detection of Leak*
Training
Stringency
Retention Ponda,
Settling Ponda, 1
Mudpita
Brittle Fracture
API 620
S.O
s.o
API 650 (8TH Ed.)
' '
2, 5. 6
(.3
5.3, 6
2.0, S.O, 6.0
API RP 651 (Final
Rev.)
API RP 652 (Draft
10)
API 653 (lat Ed.)
i.O, 3.0, 4.0,
10.0
4.10
10.0
Section 3
API PUB. 2001
(4TH Ed.)
'
All
HFPA 30 (1987 Ed.)
Chapter 2-5.6.2
Chapter 5-5.4
NFPA 30A
tf-
'rr
-------
Exhibit 1 (continued)
Review of Storage Tank Codea and standards
Other Tech.
Requirements
Lightning Protection
General Corroalon
Control
Tank Integrity
Testing
Certification of
Tank Installation
Plant Security
Flood Protection
Detection of Leaks
Training
Stringency
Brittle Fracture
Retention ( Settling
Pendi. and Hudplt*
NFPA 31
(1967 Ed.)
Chap. 2-1
NFPA RP2003-10/74
Portiona
NFPA 78
Chapter 6
RACE RP02B9
All
OSHA 29 CFR 1910
1910. IOC
1910.106
Part 1910.120
FEHA 44 CFR
60.3(0
All
-------
Exhibit 1 (Continued)
Review of Storage Tank Codes and standards
q
Lightning protection
General Corroaion Control
Tank Integrity Teating
Certification of Tank
Inatallation
Plant Security
Flood Protection
Detection of Leaki
Training
Stringency
Brittle Fracture
Retention Ponda 1 Settling
?onda, and Hudpita
All
156.170
154.570
156.170
154.700
Section 20
Section 20
Section 20
amended)
Section 6
Section 6
Chapter VI
Chapter VI
-------
ill. Diversion of Discharge to Sewage Treatment Plant
Where storm water discharges contain significant amounts of
pollutants that can be removed by a sewage treatment plant, the
storm water discharge can be discharged to the sanitary sewage
system. Such diversions must be coordinated with the operators
of the sewage treatment plant and the collection system to avoid
worsening problems with either combined sewer overflows (CSOs),
basement flooding or wet weather operation of the treatment
plant. Where CSO discharges, flooding or plant operation
problems can result, onsite storage followed by a controlled
release during dry weather conditions may be considered.
iv. Traditional Storm Water Management Practices
In some situations, traditional storm water management
practices such as grass swales, catch basin design and
maintenance, infiltration devices, unlined retention or detention
basins, water reuse, and oil and grit separators can be applied
to an industrial setting. However, care must be taken to
evaluate the potential of many of these traditional devices for
ground water contamination. In some cases, it is appropriate to
limit traditional storm water management practices to those areas
of the drainage system that generate storm water with relatively
low levels of pollutants (e.g., many rooftops, parking lots,
etc.). At facilities located in northern areas of the country,
snow removal activities may play an important role in a storm
water management program. In addition, other types of controls
such as spill prevention measures can be considered to prevent
catastrophic events that can lead to surface or ground water
contamination.
v. Elimination of Pollution Sources
In some cases, the elimination of a pollution source may be
the most cost-effective way to control pollutants in storm water
discharges associated with industrial activity. Options for
eliminating pollution sources include reducing onsite air
emissions affecting runoff quality, changing chemicals used at
the facility, and modification of material management practices
such as moving storage areas into buildings.
c. Options for Controlling Pollutants in Storm Water Discharges
Associated with Industrial Activity from Construction Activities.
Most controls for construction activities can be broken into
two group: 1) sediment and erosion controls; and 2) storm water
controls. Sediment and erosion controls are generally those
controls which address pollutants in storm water generated from
the site during the time when construction activities are
occurring. Storm water controls are generally those controls
which are installed during the construction process, but
5-18
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primarily result in reductions of pollutants in storm water
discharged from the site after the construction has been
completed.
The National Association of Homebuilders (NAHB) comments on
the storm water rulemaking indicate that requiring Best
Management Practices (BMPs) is the appropriate way to regulate
construction site runoff. NAHB recommended that appropriate BMPs
should address:
- Environmental Site Planning;
- Non-Structural Management Practices, including
Vegetative Controls; and
- Structural Controls.
State Programs: A May 1990 survey by MD DEP indicated:
- 13 States have mandatory sediment and erosion control
or storm water management programs effective State-
wide ;
- 2 States have mandatory programs for portions of the
State;
- An additional 9 States had developed State-wide
guidance for local governments to use; and
7 states indicated they were awaiting EPA regulations
before developing or revising a State program.
Municipal Programs;
- Comprehensive estimates of the number of municipalities
with erosion and sediment controls are unavailable.
- Most of the State programs require or allow for
implementation at the municipal level.
- Over the last ten years, the National Association of
Homebuilders (NAHB) has received requests to review
over 500 local ordinances. They estimate that the
following municipalities have some type of sediment and
erosion/ storm water management program:
- almost all large municipalities
- almost all municipalities on the West Coast
(except Alaska), East Coast and Great Lakes States
have some type of sediment/storm water control
program.
5-19
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- most other municipalities in Regions I, II, III
and IV States (West Virginia is an exception with
few controls).
- About 25% of the municipalities in the Regions VI
and VIII States.
- Few municipalities in Region VII and Alaska.
NAHB believes that sediment and erosion controls have
become standard industry practice even where they are
not required by law.
Sediment and Erosion Controls.
Vegetative controls are often the most important measures
taken to prevent off-site sediment movement, and can provide a
six-fold reduction in discharge suspended sediment levels.
Erosion controls provide the first line of defense in preventing
off-site sediment movement and are designed to prevent erosion by
protecting soils. Sediment controls are designed to remove
sediment from runoff before the runoff is discharged from the
site. Sediment and erosion controls can be further divided into
two major classes of controls: vegetative practices and
structural practices. Major types of sediment and erosion
practices are summarized below. A more complete description of
these practices is described in "Draft - Sediment and Erosion
Control, An Inventory of Current Practices", U.S. EPA, OWEP,
April 20, 1990.
Sediment and Erosion Controls; Vegetative Practices.
Vegetation, as discussed here, refers to covering or
maintaining an existing cover over soils. The cover may be
grass, trees, vines, shrubs, bark, mulch or straw. The
establishment and maintenance of vegetation are one of the most
important factors in minimizing erosion while construction
activities are occurring. A vegetation cover reduces the erosion
potential of a site by: absorbing the kinetic energy of raindrops
which would otherwise impact soil; intercepting water so it can
infiltrate into the ground instead of running off carrying
surface soils; and by slowing the velocity of runoff promoting
deposition of sediment in the runoff. Vegetative controls are
often the most important measures taken to prevent off-site
sediment movement, and can provide a six-fold reduction in
discharge suspended sediment levels6.
"Performance of Current Sediment Control Measures at
Maryland Construction Sites", January 1990, Metropolitan Washington
Council of Governments.
5-20
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Temporary Seeding - Temporary seeding provides for temporary
stabilization by establishing vegetation of areas of the site
which will be disturbed at some time during the construction
operation, and where work (other than the initial disturbance) is
not conducted until some time later in the project. Soils at
these areas may be exposed to precipitation for an extended time
period, even though work is not occurring on these areas. In
most climates, temporary seeding is typically appropriate for
areas exposed by grading or clearing for more than seven to
fourteen days. Temporary seeding practices have been found to be
up to 95% effective in reducing erosion7.
Permanent Seeding - Permanent seeding involves establishing a
sustainable ground cover at a site. Permanent seeding stabilizes
the soil to reduce sediment in runoff from the site. Permanent
seeding is typically required at most sites for aesthetic
reasons.
Mulching
Mulching is typically conducted as part of permanent and
temporary seeding practices. Where temporary and permanent
seeding is not feasible, exposed soils can be stabilized by
applying plant residues or other suitable materials to the soil
surface. Although generally not as effective as seeding
practices, mulching, by itself, does provide some erosion
control. Mulching in conjunction with seeding practices provides
erosion protection prior to the onset of vegetation growth. In
addition, mulching protects seeding practices, providing a higher
likelihood of their success. To maintain optimum effectiveness,
mulches must be anchored to resist wind displacement.
Sod Stabilization
Sod stabilization involves establishing long-term stands of
grass with sod in sediment producing areas. When installed and
maintained properly, sodding can be 99% effective in reducing
erosion8, making it the most effective vegetation practice
available. The higher cost of sod stabilization relative to
other vegetative controls typically limits its use to exposed
soils where a quick vegetative cover is desired and on sites
which can be maintained with ground equipment. In addition, sod
is sensitive to climate and may require intensive watering and
fertilizing.
7 "Guides for Erosion and Sediment Control in California",
USDA - Soil Conservation Service, Davis CA, Revised 1985.
8 "Guides for Erosion and Sediment Control in California",
USDA - Soil Conservation Service, Davis CA, Revised 1985.
5-21
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Vegetative Buffer Strips
Vegetative buffer strips are preserved or planted strips of
vegetation at the top and bottom of a slope, outlining property
boundaries, or adjacent to receiving waters such as streams or
wetlands. Vegetative buffer strips can slow runoff flows at
critical areas, decreasing erosion and allowing sediment
deposition.
Protection of Trees
This practice involves preserving and protecting selected
trees that were on the site prior to development. Mature trees
have extensive canopy and root systems which help to hold soil in
place.. Shade trees also keep soil from drying rapidly and
becoming susceptible to erosion. Measures taken to protect trees
can vary significantly, from simple measures such as installing
tree fencing around the drip line and installing tree armoring,
to more complex measures such as building retaining walls and
tree wells.
Sediment and Erosion Controls; Structural Practices
Structural practices either: divert flow to prevent runoff
across exposed areas; stabilize soils; or remove sediment from
flows. Structural practices which divert flow are preventative,
and reduce pollutants directly proportional to the amount of flow
diverted. Structural practices which stabilize soils, such as
outlet protection or graveled road entrances, can effectively
mitigate extreme erosion problems in localized areas. Structural
practices which remove sediment, such as sediment traps or silt
fences, can remove from 60-80% of sediment in flows.
Structural practices involve the installation of devices to
divert flow, store flow or limit runoff. Structural practices
can have several objectives. First, structural practices can be
designed to prevent water from crossing disturbed areas where
sediment may be removed. This involves diverting runoff from
undisturbed upslopes areas by use of earth dikes, temporary
swales, perimeter dike/swales, or diversions that outlet in
stable areas. A second objective of structural practices can be
to remove sediment from site runoff before the runoff leaves the
site. Several approaches to removing sediment from site runoff
include diverting flows to a trapping or storage device, or
filtering diffuse flow through straw bale dikes, silt fences, or
brush barriers before it leaves the site. All structural
practices require proper maintenance (removal of sediment) to
remain functional.
Earth Dike
5-22
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Earth dikes are temporary berms or ridges of compacted soil
which channel water to a desired location. Earth dikes should be
stabilized with vegetation.
Straw Bale Dike
Straw bales are temporary barriers of straw or similar
material used to intercept sediment in runoff from small drainage
areas of disturbed soil. When installed and maintained properly,
straw bale dikes can remove approximately 67% of the sediment in
runoff. This optimum efficiency can only be achieved through
careful maintenance with special attention to replacing rotted or
broken bales.
Silt Fence
Silt fences are a barrier of geotextile fabric (filter
cloth) used to intercept sediment in diffuse runoff. Care must
be taken in maintaining silt fences with an emphasis on
maintaining the structural stability of the silt fence and
removal of excessive sedimentation.
Brush Barriers
Brush barriers are sediment barriers composed of tree limbs,
weeds, vines, root mat, soil, rock and other cleared materials
placed at the toe of a slope.
Drainage Swales
A drainage swale is a drainage way with a lining of grass,
riprap, asphalt, concrete, or other materials. Drainage swales
are installed to convey runoff without causing erosion.
Check Dams
Check dams are small temporary dams constructed across a
swale or drainage ditch to reduce the velocity of runoff flows,
thereby reducing erosion of the swale or ditch. Check dams
should not be used in a live stream. Check dams reduce the need
for more stringent erosion control practices in the swale due to
the decreased velocity and energy of runoff. Materials which can
be used to install a check dam include rock, logs and covered
straw bales.
Level Spreader
Level spreaders are outlets for dikes and diversions
consisting of an excavated depression constructed at zero grade
across a slope. Level spreaders convert concentrated runoff into
diffuse runoff and release it onto areas stabilized by existing
5-23
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vegetation.
Subsurface Drain
Subsurface drains transport water to an area where can be
managed effectively. Drains can be made of tile, pipe or tubing.
Pipe Slope Drain
A pipe slope drain is a temporary structure placed from the
top of a slope to the bottom of a slope to convey surface runoff
down slopes without causing erosion.
Temporary Storm Drain Diversion
Temporary storm drain diversions are used to re-direct flow
in a storm drain to discharge into a sediment trapping device.
Storm Drain Inlet Protection
Storm drain inlet protection can be provided by a sediment
filter or an excavated impounding area around a storm drain
inlet. These devices prevent sediment from entering storm
drainage systems prior to permanent stabilization of the
disturbed area.
Rock Outlet Protection
Rock protection placed at the outlet end of culverts or
channels can reduce the depth, velocity and energy of water such
that the flow will not erode the receiving downstream reach.
Sediment Traps
Sediment traps can be installed in a drainageway, at a storm
drain inlet, or other points of discharge from a disturbed area.
Other Controls
Other controls include temporary sediment basins, sump pits,
entrance stabilization measures, waterway crossings, and wind
breaks.
Storm Water Management Controls
Storm water controls are generally those controls which are
installed during the construction process, but primarily result
in reductions of pollutants in storm water discharged from the
site after the construction has been completed. Construction
activities often result in a significant change in land use.
These changes in land use typically involve an increase in the
overall imperviousness of the site, which can result in dramatic
5-24
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changes to the runoff patterns of a site. As the amount of
runoff from a site increases, the amount of pollutants carried by
the runoff increases. In addition, activities such as automobile
travel on roads can result in higher pollutant concentrations in
runoff then preconstruction levels. Traditional storm water
management controls do not influence the change in land use
associated with construction. Rather, traditional storm water
management controls attempt to limit the increases in the amount
of runoff and the amount of pollutants discharged from a site
associated with the change in land use.
Major classes of storm water management controls include:
infiltration of runoff onsite; flow attenuation by vegetation or
natural depressions; outfall velocity dissipation devices; storm
water retention structures and artificial wetlands; and storm
water detention structures. For many sites, a combination of
these controls may be appropriate.
Infiltration of Runoff Onsite
A variety of infiltration technologies can be used to reduce
the volume and pollutant loadings of storm water discharges from
a site, including infiltration trenches and infiltration basins.
Infiltration devises tend to mitigate changes to pre-development
hydrologic conditions. Properly designed and installed
infiltration devices can reduce peak discharges, provide
groundwater recharge, augment low flow conditions of receiving
streams, reduce storm water discharge volumes and pollutant
loads, and protect downstream channels from erosion.
Infiltration devices are a feasible option where soils are
permeable and the water table and bedrock are well below the
surface. Infiltration basins can also be used as sediment basins
during construction . Infiltration trenches can be more easily
placed into under utilized areas of a development, and can be
used for small sites and infill developments. However trenches
may require regular maintenance to prevent clogs, particularly
where grass inlets or other pollutant removing inlets are not
used. In some situations, such as low density areas of parking
lots, porous pavement can provide for infiltration.
Flow Attenuation bv Vegetation or Natural Depressions
Flow attenuation provided by vegetation or natural
depressions can provide pollutant removal, infiltration, and
9 "Controlling Urban Runoff: A Practical Manual for Planning
and Designing Urban BMPs", July, 1987, Metropolitan Washington
Council of Governments.
5-25
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lower the erosive potential of flows10. In addition, these
practices can enhance habitat values and the appearance of a
site. Vegetative flow attenuation devises include grass swales
and filter strips as well as trees that are either preserved or
planted during construction.
Typically the costs of vegetative controls are small
relative to other storm water practices. The use of check dams
incorporated into flow paths can provide additional infiltration
and flow attenuation. Given the limited capacity to accept
large volumes of runoff, and potential erosion problems
associated with large concentrated flows, vegetative controls
should typically be used in combination with other storm water
devices.
Grass swales are typically used in low or medium residential
development and highway medians as an alternative to curb and
gutter drainage systems12.
Outfall Velocity Dissipation Devices
Outfall velocity dissipation devises include riprap and
stone or concrete flow spreaders. Outfall velocity dissipation
devices slow the flow of water discharged from a site to lessen
the amount of erosion caused by the discharge.
Storm Water Retention Structures
Properly designed and maintained storm water retention
structures, also referred to as wet ponds, can achieve a high
removal rate of sediment, BOD, organic nutrients and metals.
Retention basins are most cost-effective in larger, more
intensively developed sites. Retention ponds can also create
wildlife habitat, recreation, and landscape amenities, and
corresponding higher property values.
Retention Structures/ Artificial Wetlands
Retention structures include ponds and artificial wetlands
that are designed to maintain a permanent pool of water.
Properly installed and maintained retention structures (also
10 "Urban Targeting and BMP Selection", United States EPA,
Region V, November 1990.
11 "Standards and Specifications for Infiltration Practices",
1984, Maryland Water Resources Administration.
12 "Controlling Urban Runoff: A Practical Manual for Planning
and Designing Urban BMPs", Metropolitan Washington Council of
Governments, July 1987.
5-26
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known as wet ponds) and artificial wetlands1314 can achieve a high
removal rate of sediment, BOD, organic nutrients and metals, and
are most cost-effective when used to control runoff from larger,
intensively developed sites. These devises rely on settling
and biological processes to remove pollutants.
Water Quality Detention Structures
Storm water detention structures include extended detention
ponds, which control the rate at which the pond drains after a
storm event. Extended detention ponds are usually designed to
completely drain in about 24 to 40 hours, and will remain dry at
other times. They can provide pollutant removal efficiencies
that are similar to those of retention ponds16. Extended
detention systems are typically designed to provide both water
quality and water quantity (flood control) benefits17.
d. Coal Pile Runoff Treatment Technology
The primary technology options for treating coal pile runoff
considered in the final "Development Document for Effluent
Limitations Guidelines and Standards and Pretreatment Standards
for the Steam Electric Point Source Category", (EPA-440/182/029),
November 1982, EPA, were: 1) equalization, pH adjustment,
settling; and 2) equalization, chemical precipitation treatment,
settling, pH adjustment.
Metals may be removed from wastewater by raising the pH of
the wastewater to precipitate them out as hydroxides. Typically,
wastewater pH's of 9 to 12 are required to achieve the desired
precipitation levels. Lime is frequently used for pH adjustment.
Wastewaters which have a pH greater than 9 after lime addition
will require acid addition to reduce the pH before final
discharge. Polymer addition may be required to enhance the
settling characteristics of the metal hydroxide precipitate.
13 "Wetland basins for Storm Water Treatment: Discussion and
Background", Maryland Sediment and Stormwater Division, 1987
14 "The Value of Wetlands for Nonpoint Source Control -
Literature Summary", Strecker, E., et.al., 1990.
15 "Controlling Urban Runoff, A Practical Manual for Planning
and Designing Urban BMPs", Metropolitan Washington Council of
Governments, 1987.
16 "Urban Targeting and BMP Selection", United States EPA,
Region V, November 1990.
17 "Urban Surface Water Management", Walesh, S.G., Wiley,
1989.
5-27
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Typical polymer feed concentrations in the wastewater are 1 to 4
ppm. The metal hydroxide precipitate is separated from the
wastewater in a clarifier or a gravity thickener. Unlike
settling ponds, these units continually collect and remove the
sludge formed. Filters are typically used for effluent polishing
and can reduce suspended solids levels below 10 mg/1. Sand or
coal are the most common filter media. Vacuum filtration is a
common technique for dewatering sludge to produce a cake that has
good handling properties and minimum volume.
The major equipment requirements for such a system include a
lime feed system, mix tank polymer feed system, flocculator/
clarifier, deep bed filter, and acid feed system. For
wastewaters which have a pH of less than 6, mixers and mixing
tanks are made of special materials of construction (stainless
steel or lined-carbon steel). For wastewaters with pH's greater
than 6, concrete tanks are typically used. The underflow from the
clarifier may require additional treatment with a gravity
thickener and a vacuum filter to provide sludge which can be
transported economically for landfill disposal.
e. Salt Storage
Salt is readily dissolved by precipitation. The Salt
Institute highly recommends that salt stockpiles, whether large
or small, should never be left exposed to the elements-rain or
snow. A permanent under-roof storage facility is best for
protecting salt. If this is not possible, then outside piles
should be build on impermeable bituminous pads and covered with
one of the many types of temporary covering materials, such as
tarpaulin, polyethylene, poly urethane, polypropylenes or
Hypalon. These materials are also available with reinforcement
for added strength. (see "The Salt Storage Handbook", Salt
Institute, 1987). Storage facilities will result in reductions
of lost product and easier handling of materials (and thus
reduced labor costs) which will offset the cost of the storage.
Options for storing and handling salt are discussed at
length in the following:
o "Manual for Deicing Chemicals: Storage and Handling", EPA,
1974, EPA-670/2-74-033
o "An Economic Analysis of the Environmental Impact of Highway
Deicing", EPA, 1976, EPA-600/2-76-105
o "Manual for deicing Chemicals: Application Practices",
1974, EPA, EPA-670/2-74-045
5-28
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6-1
6.0 SELECTION OF DRAFT PERMIT CONDITIONS
6.1 Summary of permit conditions
Based on a consideration of the appropriate factors for BAT
and BCT requirements, and a consideration of the factors and
options for controlling pollutants in storm water discharges
associated with industrial activity, the draft general permits
proposes two prohibitions, a set of tailored requirements for
developing and implementing storm water pollution prevention
plans, and for selected discharges, two effluent limitations1.
The conditions of these draft permits have been designed to
comply with the technology-based standards of the CWA (BAT/BCT),
as well as to ensure compliance with applicable State water-
quality standards.
Based on a consideration of the appropriate factors for BAT
and BCT requirements, and a consideration of the factors and
options discussed in Chapter 5 for controlling pollutants in
storm water discharges associated with industrial activity, the
draft general permits proposes two prohibitions, a set of
tailored requirements for developing and implementing storm water
pollution prevention plans, and for selected discharges, two
effluent limitations2.
Chapter 5 summarizes the options for controlling pollutants
Part I.e.2 of the draft general permits provide that
facilities with storm water discharges associated with industrial
activity which, based on an evaluation of site specific conditions,
believe that the appropriate conditions of these permits do not
adequately represent BAT and BCT requirements for the facility may
request to be excluded from the coverage of the general permit by
either submitting to the Director an individual application (Form
1 and Form 2F) with a detailed explanation of the reasons
supporting the request, including any supporting documentation
showing that certain permit conditions are not appropriate, or
participating in a group application (see 40 CFR 112.26(c)).
2 Part I.e.2 of the draft general permits provide that
facilities with storm water discharges associated with industrial
activity which, based on an evaluation of site specific conditions,
believe that the appropriate conditions of these permits do not
adequately represent BAT and BCT requirements for the facility may
request to be excluded from the coverage of the general permit by
either submitting to the Director an individual application (Form
1 and Form 2F) with a detailed explanation of the reasons
supporting the request, including any supporting documentation
showing that certain permit conditions are not appropriate, or
participating in a group application (see 40 CFR 112.26(c)).
-------
6-2
in storm water discharges associated with industrial activity.
The draft general permit proposes numeric effluent limitations
for two classes of discharges, coal pile runoff, and runoff that
comes into contact with certain chemical storage or handling
facilities at SARA Title III, Section 313 facilities. For other
discharges covered by the permit, the draft permit conditions
reflect EPA's decision to rely primarily on requiring best
management practices to prevent pollution in storm water
discharges and using traditional storm water management
practices. The draft permit conditions applicable to these
discharges are not numeric effluent limitations, but rather are
flexible requirements for developing and implementing site
specific plans to prevent pollutants in storm water discharges
associated with industrial activity.
In developing these draft permit conditions, EPA considered
a range of control options, including providing end-of-pipe
treatment, best management practices, diverting storm water
discharges to sewage treatment plants, traditional storm water
management practices, and eliminating pollutant sources (see
Chapter 5). EPA's consideration of these options is briefly
summarized below.
At many types of industrial facilities, it may be
appropriate to collect and treat runoff from targeted areas of
the facility. This approach has been taken with the 10
industrial categories with national effluent limitations
guidelines for storm water discharges. As noted above, end-of-
pipe treatment requirements typically are focussed on targeted
areas of an industrial facility. End-of-pipe treatment typically
requires the collection of the storm water to be treated, and
providing for some type of treatment such as settling,
neutralization or precipitation of metals. The Agency currently
does not have sufficient data to develop appropriate discharge
standards needed to require end-of-pipe treatment from all of the
sources of storm water discharges associated with industrial
activity covered by these permits.
The Agency has selected a number of best management
practices and traditional storm water management practices as the
BAT/BCT level of control for the majority of storm water
discharges covered by these permits. Unlike other control
options considered, the Agency believes that the practices
addressed in the draft permit are flexible enough to allow site-
specific application to all of the varied discharges covered. A
complete description of these provisions is provided below.
Diverting storm water discharges to a sewage treatment plant
can be a cost-effective approach to controlling pollutants in
storm water discharges in some situations. This approach would
require the installation of storm water containment for runoff
followed by controlled discharge to the sewage treatment plant in
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a manner that did not exceed the capacity of the treatment plant
collection system or the plant itself. However, this option is
not available to facilities that are not provided service by a
sewage treatment plant. In addition, the Agency does not have
sufficient information to evaluate the existing capacity of sewer
systems to accept storm water discharges.
EPA encourages the elimination of pollutant sources where
feasible to reduce the risk of pollutants in storm water
discharges. As discussed below, the Agency believes that
elimination of pollutant sources such as leaking values and pipes
will assist SARA Title III, Section 313 facilities with water
priority chemicals in meeting the whole effluent toxicity
limitation in the draft permits. However, some industrial
activities, such as operating landfills, may not be readily
amenable to this approach. Thus, the Agency is generally
hesitant to rely on this technology when developing permit
conditions that are generally applicable to all discharges
covered by the permit. Rather, EPA will continue to evaluate the
appropriate role of this technology in Tier II, III and IV
permitting activities.
EPA believes that the draft permit conditions, including the
prohibition on non-storm water discharges and requirements for
BMPs in the storm water pollution prevention plans combine to
meet the BAT/BCT tests specified in 40 CFR 125.3 for permits
issued on a BPJ basis. For BAT requirements, the following
factors were significant to the Agency in making this
determination:
o the age of equipment and facilities involved;
o the process employed;
o the engineering aspects of the application of various types
of control techniques;
o the cost of achieving such effluent reduction; and
o non-water quality environmental impacts.
For BCT requirements, the following factors were significant
to the Agency in making this determination:
o The reasonableness of the relationship between the costs of
attaining a reduction in effluent and the effluent reduction
benefits;
o The age of equipment and facilities involved;
o the process employed;
o the engineering aspects of the application of various types
of control techniques; and
o non-water quality environmental impacts.
The BPJ determination was made by the work group for the
permit which included experienced permit writers from each EPA
Regional office as well as other professionals from various EPA
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offices.
The draft permit conditions require discharges to develop
and implement BMP oriented storm water pollution prevention plans
rather than meet numeric effluent limitations. EPA is authorized
under 40 CFR 122.44(k)(2) to impose BMPs in lieu of numeric
effluent limitations in NPDES permits when they Agency finds
numeric effluent limitations to be infeasible. EPA may also
impose BMPs which are "reasonably necessary ... to carry the
purposes of the Act" under 40 CFR 122.44(k)(3). Both of these
standards for imposing BMPs were recognized in NRDC v. Costle.
568 F.2d at 1380. The conditions in the draft general permits
are proposed under the authority of both of these regulatory
provisions.
EPA believes that it is not feasible at this time to
establish a set of generic numeric effluent limitations that
would be universally appropriate to all of the varied classes of
storm water discharges associated with industrial activity
covered by these permits. As discussed above, a number of varied
pollutant sources can be identified as major potential sources of
pollutants in storm water discharges associated with industrial
activity. Variations in types and concentrations of pollutants
input from many different sources make establishing generic
concentration-based effluent limitations applicable to all
discharges covered by this permit difficult. The Agency also
believes that while the baseline BMPs required in these permits
are generally appropriate for all facilities covered by the
permits, some components of the BMPs plan will be more successful
at preventing pollution at certain types of facilities than at
other types of facilities. Further, EPA has limited quantitative
data on the pollutant removal efficiencies of the BMPs required
in this permit. These factors make the development of either
concentration-based or pollution removal-based numeric effluent
limitations technically infeasible.
EPA recognizes that it could require individual applications
from most facilities in lieu of the permit to collect site
specific information, including data describing pollutants in
storm water discharges. However, this would not necessarily
provide sufficient data regarding the pollutant removal
efficiencies of the BMPs or other control options to support a
numeric effluent limitation. In addition, such an approach would
be inconsistent with the four tiered strategy for issuing permits
outlined above and would result in fundamentally unworkable
administrative burdens. Ultimately, this could intolerably delay
imposition of NPDES storm water controls and the water quality
benefits to be gained, which in turn is inconsistent with the
goals and purposes of the CWA, particularly Section 402(p). EPA
views the draft baseline permits as an important tool for
developing some of the information necessary to establish numeric
controls where appropriate.
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The Court in NRDC v. Costle made clear, that BMPs can serve
as an acceptable substitute for numeric effluent limitations in
appropriate contexts such as storm water permits. EPA notes
that, in the storm water general permit context, EPA has always
planned to rely on BMPs as a primary source of controls. See.
e.g.. 42 FR 6846 (Feb. 4. 1977) (proposing the creation of
general permit programs for storm water oriented towards use of
BMPs).
EPA is not arguing, of course, that it will always be
infeasible to establish numeric effluent limitations for storm
water discharges associated with industrial activity. As
discussed earlies, the Agency has developed ten effluent
limitations guidelines for storm water discharges from specific
industrial categories. In addition, the draft general permits
contain numeric (or toxicity) effluent limitations for two
classes of discharges, coal pile runoff and certain discharges
from SARA Title III, Section 313 facilities. Numeric limitations
can be clearly appropriate for well defined classes of storm
water discharges where sufficient data indicates that the numeric
limitations represent the appropriate BAT/BCT or water quality-
based standard.
Development of industry-specific and watershed-specific
permits under Tiers II and III will be based on collection of
more detailed monitoring, sampling, and qualitative information,
much of which will be collected either through the terms of
today's draft permit or through EPA's group application process.
EPA is indicating only that such numeric effluent limitations are
not possible for all storm water discharges at all facilities in
the Tier I permits (and that issuance of Tier I permits is
authorized by the CWA and EPA regulations).
In addition, EPA believes the requirements in today's permit
are reasonably necessary to carry the purposes of the Act and
hence are authorized pursuant to 40 CFR 122.44(k)(3). For
example, many of the requirements of the BMP oriented storm water
pollution prevention plan are directed towards identifying
sources of pollutants. This information will supplement
monitoring data required under Section 308 of the Act and will
assist facilities in developing cost-effective efforts directed
at reducing pollutants in storm water discharges.
Furthermore, the BMP requirements in these permits operate
as limitations on effluent discharges that reflect the
application of BAT/BCT. This is because certain BMPs mandate the
use of source control technologies which may, in certain
instances, be the best available of the technologies economically
achievable (or the equivalent BCT finding). See, e.g., NRDC v.
EPA. 822 F.2d 104, 122-23 (D.C. Cir. 1987) (EPA has substantial
discretion to impose non-quantitative permit requirements
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pursuant to Section 402(a)(2)).
6.2 Prohibitions
The draft general permits prohibit non-storm water
discharges as a component of discharges authorized by this
permit. These permits are intended to authorize discharges
composed entirely of storm water associated with industrial
activity. The prohibition on non-storm water discharges in these
permits ensures that non-storm water discharges are not
inadvertently authorized by these permits. Where a storm water
discharge is mixed with process wastewaters or other sources of
non-storm water prior to discharge, and the discharge is
currently not authorized by an NPDES permit, the discharger
should submit the appropriate application forms to obtain permit
coverage. The Agency believes that these mixed discharges are
addressed more appropriately through individual NPOES permits or
other general permits as individual or other general permits will
allow development of more tailored and specific permit conditions
appropriate for such discharges.
The draft general permits also prohibit discharges that
contain a hazardous substance in excess of reporting quantities
established at 40 CFR 117.3 or 40 CFR 302.4, and clarifies that
where such a discharge occurs, the permit does not relieve the
permittee of the reporting requirements of 40 CFR 117 and 40 CFR
302. The Agency believes that the vast majority of discharges
that contain a hazardous substance in excess of reporting
quantities will be associated with non-storm water sources (e.g.
chemical spill events). Where a discharge composed entirely of
storm water associated with industrial activity containing a
hazardous substance in excess of reporting quantities occurs or
is expected to occur, the Agency believes that the potential
risks associated with the discharge are such that it is more
appropriate to address the discharge with an individual permit
which contains more specific permit conditions based on industry
specific or site specific factors and a consideration of
receiving water characteristics. Since discharges containing a
hazardous substance in excess of reporting quantities are not
authorized by these permits, such releases are not exempted from
reporting requirements by 40 CFR 117.12(a)(1), and hence the
permits do not relieve the permittee of the reporting
requirements of 40 CFR 117 and 40 CFR 302.
EPA anticipates that storm water discharges that contain oil
in excess of reporting quantities established under 40 CFR 110.6
(e.g. exhibit an oil sheen) will be more common. For example,
many storm water discharges from parking lots or roads, as well
as from industrial facilities, contain an oil sheen. Although
discharges composed entirely of storm water associated with
industrial activity are authorized by these permits where the
discharge complies with the other applicable requirements of the
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permit, it should be noted that where a discharge of oil in
excess of reporting quantities is caused by a nonstorm water
discharge (e.g. a spill of oil into a separate storm sewer), the
spill is not authorized by this permit, and the discharger is not
relieved of their obligation to report the spill under 40 CFR
110.
6.3 Tailored Pollution Prevention Plan Requirements
All facilities covered by the draft general permits must
prepare, retain and implement a storm water pollution prevention
plan. The draft permits address tiered sets of pollution
prevention plan requirements for a number of categories of
industries: construction activities; baseline requirements for
all industries except construction activities; special
requirements for certain facilities subject to SARA Title III,
Section 313; special requirements for storm water discharges
associated with industrial activity to large and medium municipal
separate storm sewer systems; and special requirements for
facilities with outdoor salt storage piles. These tailored
requirements have been developed to address specific features or
activities associated with the identified storm water discharges.
The proposed requirements for developing and implementing
storm water pollution prevention plans are based primarily on
traditional storm water management, pollution prevention and BMP
concepts which have been tailored to prevent pollutants in storm
water discharges associated with industrial activity.
The requirements for storm water pollution prevention plans
in the draft general permits have two major objectives: "(1) to
identify sources of pollution potentially affecting the quality
of storm water discharges associated with industrial activity
from the facility; and (2) describe and ensure that practices are
implemented to reduce pollutants in storm water discharges
associated with industrial activity from the facility and to
ensure compliance with the terms and conditions of this permit.
In developing these tiered requirements, the Agency believes
that it is not appropriate, at this time, to require a single set
of effluent guidelines or a single design or operational standard
for all facilities which discharge storm water associated with
industrial activity. Rather, this permit establishes a framework
for the development and implementation of site-specific storm
water pollution prevention plans. This framework provides the
necessary flexibility to address the variable risk for pollutants
in storm water discharges associated with the different types of
industrial activity that are addressed by these permits, while
ensuring procedures to prevent storm water pollution at a given
facility are appropriate given the processes employed,
engineering aspects, functions, costs of controls, location, and
age of facility. The approach taken allows flexibility to
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establish controls which can appropriately address different
sources of pollutants at different facilities.
Plan Requirements for Construction Activities
The requirements for storm water pollution prevention plans
for operations that discharge storm water associated with
industrial activity from construction activities differ from the
requirements for other types of facilities.
In developing these draft permits, the Agency has reviewed a
significant number of existing State and local requirements for
sediment and erosion controls, and storm water management
controls for construction activities/new development addressing a
wide range of climates and types of construction activities.
Source Identification
Storm water pollution prevention plans must be based on an
accurate understanding of the pollution potential of the site.
The first part of the plan requires an evaluation of the sources
of pollution at a specific construction site. The source
identification components for pollution prevention plans for
construction activities proposed in these permits include, at a
minimum, a description of the following:
o A description of the nature of the construction activity,
including a proposed timetable for major activities;
o Estimates of the total area of the site and the area of the
site that is expected to undergo excavation or grading;
o An estimate of the runoff coefficient of the site and the
increase in impervious area after the construction is
completed, a description of the nature of fill material to
be used, and existing data describing the soil or the
quality of any discharge from the site;
o A site map indicating, at a minimum, drainage patterns and
approximate slopes anticipated after major grading
activities, areas used for the storage of soils or wastes,
the location of major control structures identified in the
plan, the location of impervious structures after
construction is completed, and springs and other surface
waters; and
o The name of the receiving water(s), or if the discharge is
to a municipal separate storm sewer, the name of the
municipal operator of the storm sewer and the ultimate
receiving water(s).
ii. Controls to Reduce Pollutants
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Many municipalities and States have developed sediment and
erosion control requirements. A significant number of
municipalities and States have also developed storm water
management controls. These permits require that facilities which
discharge storm water associated with industrial activity from
construction activities must include in their storm water
pollution prevention plan procedures and requirements specified
in applicable sediment and erosion site plans or storm water
management plans approved by State or local officials. Upon the
applicant's submittal of an NOI to be authorized to discharge
under this permit, applicable requirements specified in sediment
and erosion plans or storm water management plans approved by
State or local officials are incorporated by reference and are
enforceable under this permit even if they are not specifically
included in a storm water pollution prevention plan required
under this permit3.
The controls for construction activities proposed in these
permits have three goals: 1) to divert upslope water around
disturbed areas of the site; 2) to limit the exposure of
disturbed areas to the shortest duration possible; and 3) to
remove sediment from storm water before it leaves the site.
Each construction operation covered by the permits is
required to develop a description of three classes of controls
appropriate for inclusion in the facility's plan, and implement
such controls. The description of controls must address erosion
and sediment controls, storm water management and a specified set
of other controls.
Erosion and sediment controls include both vegetative
practices and structural practices. Vegetative practices are the
first line of defense for preventing erosion. These controls are
based on a consideration of temporary seeding, permanent seeding,
mulching, sod stabilization, vegetative buffer strips, and
protection of trees. Temporary seeding practices are often cited
as the single most important factor in reducing erosion at
construction sites . Since vegetative practices play such a
Facilities with storm water discharges associated with
industrial activity related to construction activities which, based
on an evaluation of site specific conditions, believe that state
and local plans do not adequately represent BAT and BCT
requirements for the facility may request to be excluded from the
coverage of the general permit by submitting to the Director an
individual application with a detailed explanation of the reasons
supporting the request, including any supporting documentation
showing that certain permit conditions are not appropriate.
4 "New York Guidelines for Urban Erosion and Sediment
Control", USDA - Soil Conservation Service, March, 1988.
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important role in preventing erosion, it is critical that they
are rapidly employed in appropriate areas. The draft permits
provide that at a minimum, temporary seeding, permanent seeding,
mulching or sod stabilization procedures, or their equivalent,
must be conducted on all disturbed areas within 7 calendars days
of the last activity at that area.
Structural controls provide a second line of defense by
capturing pollutants before they leave the site. Structural
controls are necessary because vegetative controls cannot be
employed at areas of the site which are continually disturbed and
because a finite time period is required before vegetative
practices are fully effective. The permits require that
structural practices must be based on a consideration of straw
bale dikes, silt fences, earth dikes, brush barriers, drainage
swales, check dams, subsurface drain, pipe slope drain, level
spreaders storm drain inlet protection, rock outlet protection,
sediment traps, and temporary sediment basins. For sites with
more than 10 disturbed acres at one time which are served by a
common drainage location, at a minimum, a detention basin
providing storage for runoff from disturbed areas from a one inch
storm, shall be provided. For drainage locations serving 10 or
less acres, at a minimum, silt fences, straw bale dikes, or
equivalent sediment controls are required for all sideslope and
downslope boundaries of the construction area or a detention
basin providing storage for runoff from disturbed areas from a
one inch storm shall be provided. Although sediment basins are
generally viewed as being more effective than other structural
controls, flexibility has been added to the proposed requirements
for drainage locations serving 10 or less acres since these
smaller sites may have more difficulty finding an appropriate
location for a basin.
Storm water management controls are to include a description
of measures to control pollutants in storm water discharges that
will occur after construction operations have been completed. In
developing structure practices, the operator is to consider the
appropriateness of: infiltration of runoff onsite; flow
attenuation by use of open vegetated swales and natural
depressions; storm water retention structures and storm water
detention structures.
When developing a plan, a combination of practices should be
used. Schueler advocates that a management practice system
combosed of a combination of structural and non-structural
measures must be considered when evaluating the impact of a given
development on a watershed over a long time. Under this system
approach, the components of the system are designed in an
integrated manner to address each of the following:
o Runoff Attention: Site imperviousness is reduced by
reducing the distrubed area and protecting site tree cover
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and disconnecting impervious areas. Stream buffers and
wetlands are also protected.
o Runoff Conveyance: The runoff conveyance can mitigate flows
in a number of ways, including using vegetated swales, and
level spreaders.
Developing land often significantly increases peak discharge
volumes and velocities. These increased discharge velocities can
greatly accelerate erosion near the outlet of on-site structural
controls. To mitigate these effects, the draft permits require
velocity dissipation devices to be placed at the outfall of all
detention or retention structures and along the length of any
outfall channel as necessary to provide a non-erosive velocity
flow from the structure to a water course. A typical standard
for a non-erosive velocity is 4 feet per second calculated based
on a 10 year frequency storm (see MD DNR requirements).
Justification shall be provided by the permittee for
rejecting each practice based on site conditions. These permits
do not establish specific standards for storm water management
(other than requirements in approved State and local storm water
site plans).
Other controls to be addressed in pollution prevention plans
for construction activities require that all wastes composed of
building materials must be removed from the site for disposal in
licensed disposal facilities. No building material wastes or
unused building materials can be buried, dumped, or discharged at
the site, unless the facility is licensed for such disposal.
These provisions will help ensure that State or local waste
disposal requirements are adhered to and that wastes are not
improperly or illegally dumped at the construction site.
Each site is required to have graveled access entrance and
exit drives and graveled or paved parking areas to reduce the
tracking of sediment onto public or private roads. All unpaved
roads on the site carrying more than 25 vehicles per day must
also be graveled. These measures will limit erosion and the
transport of sediment offsite from these areas.
In addition, the plan shall ensure and demonstrate
compliance with applicable State or local sanitary sewer or
septic5 system regulations.
5 In rural and suburban areas that are served by septic
systems, malfunctioning septic systems can contribute pollutants
to storm water discharges. Malfunctioning septic tanks may be a
more significant surface runoff pollution problem than a ground
water problem. This is because a malfunctioning septic system is
less likely to cause ground water contamination where a bacterial
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Erosion and sediment controls can become ineffective if they
are inappropriately disturbed or otherwise damaged. Maintenance
of controls has been identified as a major part of effective
erosion and sediment programs. Plans are required to provide a
description of procedures to maintain in good and effective
condition and promptly repair or restore all grade surfaces,
walls, dams and structures, vegetation, erosion and sediment
control measures and other protective devices identified in the
site plan. At a minimum, procedures in a plan must provide that
all erosion controls on the site are inspected at once every
seven calendar days and within 24 hours after any storm event of
greater than 0.5 inches of rain per 24 hour period. Diligent
inspections are necessary to assure adequate implementation site
sediment and erosion controls, particularly in the later stages
of construction when the volume of runoff is greatest and the
storage capacity of the sediment basins has been reduced.
Plan Requirements for Facilities other than Construction
Activities.
In 1979, EPA completed a technical survey of industry best
management practices (BMPs) which was based on a review of
practices used by industry to control the non-routine discharge
of pollutants from non-continuous sources including runoff,
drainage from raw material storage area, spills, leaks, and
sludge or waste disposal. This review included analysis and
assessment of published articles and reports, technical
bulletins, and discussions with industry representatives through
telephone contacts, written questionnaires and site visits.
The review identified two classes of pollution control
measures. The first class of controls are those management
practices generally considered to be essential to a good BMP
program, are low in cost, and applicable to broad categories of
industry and types of substances. These practices are
independent of the type of industry, ancillary sources, specific
chemicals, group of chemicals, or plant-site locations. The
mat in the soil retards the downward movement of wastewater.
Surface malfunctions are caused by clogged or impermeable soils,
or when stopped up or collapsed pipes forces untreated wastewater
to the surface. Surface malfunctions can vary in degree from
occasional damp patches on the surface to constant pooling or
runoff of wastewater. These discharges have high bacteria, nitrate
and nutrient levels and can contain a variety of household
chemicals. This permit does not establish new criteria for septic
systems, but rather adopts existing State or local criteria.
6 "Performance of Current Sediment Control Measures at
Maryland Construction Sites", January, 1990, Metropolitan
Washington Council of Governments
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survey concluded that these controls were broadly applicable to
all industry types and activities, and should be viewed as
minimum requirements in any effective BMP program. The second
class of controls are those management practices controls which
provide a second line of defense against the release of
pollutants and included prevention measures, containment
measures, mitigation and cleanup measures, and treatment
methods7.
Since that time, EPA has, on a case-by-case basis, imposed
BMP requirements in NPDES permits. The Agency has also continued
to review and evaluate case studies involving the use of BMPs8
and the use of pollution prevention measures associated with
spill prevention and containment measures for oil9. During the
development of NPDES permit application requirements for storm
water discharges associated with industrial activity, the Agency
evaluated appropriate means for identifying and evaluating the
potential risk of pollutants in storm water from industrial
sites. Public comments received during the rulemaking provided
additional insight regarding storm water risk assessment, as well
as appropriate pollution prevention and control measures and
strategies. During this time, the Agency again reviewed 'storm
water control practices and measures. These experiences have
shown the Agency that pollution prevention measures such as BMPs
can be appropriately used and that permits containing BMP
requirements can effectively reduce pollutant discharges in a
cost-effective manner.
i. Source Identification
Storm water pollution prevention plans must be based on an
accurate understanding of the pollution potential of the site.
For a complete description of the BMP survey, see "NPDES
Best Management Practices Guidance Document11, U.S. EPA, December
1979, EPA-600/9-79-045. See also the 1981 document of the same
name, "NPDES Best Management Practices Guidance Document" which
provides a more complete discussion of baseline BMPs.
8 For example, see: "Best Management Practices: Useful Tools
for Cleaning Up", Thron, H., Rogoshewski, P., 1982, Proceedings
of the 1982 Hazardous Material Spills Conference; "The Chemical
Industries Approach to Spill Prevention" Thompson, C., Goodier,
J., 1980, Proceedings of the 1980 National Conference on Control
of Hazardous Material Spills; and a series of EPA memorandum
entitled "Best Management Practices in NPDES Permits - Information
Memorandum", 1983, 1985, 1986, 1987, 1988.
9 See Oil Pollution Prevention requirements, including Spill
Prevention, Control, and Counter-measure Plan requirements, at 40
CFR 112.
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The first part of the plan requires an evaluation of the sources
of pollution at a specific industrial site. The source
identification components proposed in this permit include:
o A drainage site map;
o An estimate of the area of impervious surfaces and the total
area drained by each outfall;
o A narrative description of specified features that may
impact the pollution potential of a discharge;
o A list of significant spills and leaks of toxic or hazardous
pollutants that occurred at the facility after the effective
date of the permit;
o A prediction of the direction of flow, and an estimate of
the types of pollutants that may be present in storm water
discharges associated with industrial activity, prediction
of the direction, rate of flow and total quantity of
pollutants that may be present in storm water discharges
associated with industrial activity; and
o A summary of existing sampling data describing pollutants in
storm water discharges.
ii. Practices and Program Elements to Reduce Pollutants
The second major section of the storm water pollution
prevention plan addresses practices and program elements to
reduce pollutants in areas identified as being potential
pollutant sources for storm water discharges associated with
industrial activity. In developing these requirements, the
Agency has selected those practices identified in studies of BMPs
which are appropriate for all facilities with storm water
discharges associated with industrial activity. In addition, the
Agency has also addressed commonly used, low-cost pollution
prevention measures for storm water discharges (traditional storm
water management and sediment and erosion prevention) and a
requirement for facilities to certify that storm water discharges
have been tested for the presence of non-storm water pollution
sources10.
10 The certification requirement that storm water discharges
associated with industrial activity have been tested for the
presence of non-storm water pollution sources is similar to the
certification requirement in the Form 2F application for storm
water discharges associated with industrial activity (see November
16, 1990 (55 Fg 47990). EPA is including this certification
provision in these general permits since dischargers may obtain
coverage under these permits without the submittal of Form 2F.
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(1). pollution prevention committee;
(2). risk identification and assessment\material inventory;
(3). preventive maintenance;
(4). good housekeeping;
(5). spill prevention and response procedures;
(6). traditional storm water management;
(7). sediment and erosion prevention;
(8). employee training;
(9). visual inspections; and
(10). record keeping and internal reporting procedures; and
(11). certification that storm water discharges have been
tested for the presence of non-storm water pollution
sources.
These permits establish the framework and the basic elements
for storm water pollution prevention measures. However, the plan
requirements provide flexibility to allow the development of
site-specific measures. At a given site, specific measures
incorporated into the pollution prevention plan will reflect the
sources of pollutants that have been identified at the site. For
example, a facility that has identified dust and particulate
generating processes as potential sources of storm water
pollution will incorporate appropriate good housekeeping and
traditional storm water management practices to address these
sources. However, a facility without dust and particulate
generating processes would not have to incorporate measures to
address dust and particulate generating processes into their
plan.
Pollution Prevention Committee
The Storm Water Pollution Prevention Committee identifies
specific individuals within the plant organization who are
responsible for developing the storm water pollution prevention
plan and assisting the plant manager in its implementation,
maintenance, and revision. The activities and responsibilities
of the committee should address all aspects of the facility's
storm water pollution prevention plan. However, it is preferred
that plant management, not the committee, has overall
responsibility and accountability for the quality of the storm
water pollution prevention plan.
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Risk Identification and Assessment\Material Inventory
The storm water pollution prevention plan should assess the
potential of various sources at the plant to contribute
pollutants to storm water discharges associated with industrial
activity. These activities should assist in assessing the
pollution potential of runoff from specific areas of the plant.
The plan should inventory the types of materials handled, the
location of material management activities, and types of material
management activities.
The pollution prevention committee should assess the layout
and activities at the plant identified as high-priority areas
with a significant potential for contributing pollutants to the
drainage system. Factors to consider when evaluating the
pollution potential of runoff from various portions of an
industrial plant include:
o loading and unloading operations;
o outdoor storage activities;
o outdoor manufacturing or processing activities;
o dust or particulate generating processes; and
o waste disposal practices.
other factors to consider are the toxicity of chemicals;
quantity of chemicals used, produced, or discharged; history of
NPDES permit violations; history of significant leaks or spills
of toxic or hazardous pollutants; and nature and uses of the
receiving waters.
Chemicals should be compatible with the materials used in
storage and process equipment, including the piping, valves and
pumps. Incompatibility of materials can cause equipment failure
resulting from corrosion, fire, or explosion. Equipment failure
can be prevented by ensuring that the materials of construction
for containers handling hazardous substances or toxic pollutants
are compatible with the container's contents and surrounding
environment.
Preventive Maintenance
A preventive maintenance program involves inspection and
maintenance of storm water management devices (cleaning oil/water
separators, catch basins) as well as inspecting and testing plant
equipment and systems to uncover conditions that could cause
breakdowns or failures resulting in discharges of pollutants to
surface waters. A good preventive maintenance program includes
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identifying equipment or systems used in the program;
periodically inspecting or testing equipment and systems;
adjusting, repairing, or replacing items; and maintaining
complete records on the equipment and systems.
Good Housekeeping
Good housekeeping requires the maintenance of a clean,
orderly facility. Training of employees in housekeeping
techniques and establishing housekeeping protocols reduces the
possibility of mishandling chemicals or equipment. These
measures also ensure that discharges of wash waters to separate
storm sewers are avoided.
Spill Prevention and Response Procedures
Areas where potential spills can occur, and their
accompanying drainage points should be identified clearly in the
storm water pollution prevention plan. Where appropriate,
specifying material handling procedures and storage requirements
in the plan should be considered. Procedures for cleaning up
spills should be identified in the plan and made available to the
appropriate personnel. The necessary equipment to implement a
clean up should be available to personnel. Spill response
procedures should avoid discharging to separate storm sewers
where safety considerations allow.
Appropriate Storm Water Management
After measures have been taken to minimize pollutant sources
to storm water, traditional storm water management practices
should be considered. For the purposes of these permits,
traditional storm water management practices are measures which
reduce pollutant discharges by reducing the volume of storm water
discharges associated with industrial activity, such as directing
storm water to existing vegetative swales, or preventing storm
water to run onto areas of the site which conduct industrial
activity. Low-cost measures that can be applied to an industrial
setting may include diverting rooftop or other drainage across
available grass swales, cleaning catch basins, and installing and
maintaining oil and grit separators. Other measures that may be
appropriate in some cases include infiltration devices and
unlined retention and detention basins. Traditional storm water
management practices can include water reuse activities, such as
the collection of storm water for later uses such as irrigation
or dust control. Appropriate snow removal activities may be
considered, such as selecting a site for removed snow and
selecting and using deicing chemicals.
However, care must be taken to evaluate whether these
traditional devices cause ground water contamination. In some
cases, it is appropriate to limit traditional storm water
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management practices to those areas of the drainage system that
generate storm water with relatively low levels of pollutants
(e.g., many rooftops, parking lots, etc.).
Sediment and Erosion Prevention
The plan shall identify areas which, due to topography,
activities, or other factors, have a high potential for soil
erosion, and identify and ensure the implementation of measures
to limit erosion.
Employee Training
Employee training programs are necessary to inform personnel
at all levels of responsibility of the components and goals of
the storm water pollution prevention plan. Training should
address topics such as spill response, good housekeeping and
material management practices. A pollution prevention plan
should identify periodic dates for such training.
Visual Inspection and Records
Qualified plant personnel should be identified to inspect
designated equipment and plant areas. Typical inspections should
include examination of pipes, pumps, tanks, supports,
foundations, dikes, and drainage ditches. Material handling
areas should be inspected for evidence of, or the potential for,
pollutants entering the drainage system. A tracking or followup
procedure should be used to ensure that adequate response and
corrective actions have been taken. Records of inspections
should be maintained.
Record Keeping and Reporting Procedures
A record keeping system ensures adequate implementation of
the storm water pollution prevention plan. Incidents such as
spills, leaks and improper dumping, along with other information
describing the quality and quantity of storm water discharges
should be included in the records. Inspections and maintenance
activities such as cleaning oil and grit separators or catch
basins should be documented and recorded.
Non-Storm Discharges
Plans shall include a certification that the discharge has
been tested for the presence of non-storm water discharges. The
certification shall include a description of the results of any
test for the presence of non-storm water discharges, the method
used, the date of any testing, and the on-site drainage points
that were directly observed during the test. Such certification
may not be feasible if the facility operating the storm water
discharge associated with industrial activity does not have
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access to an outfall, manhole, or other point of access to the
ultimate conduit which receives the discharge. In such cases,
the source identification section of the storm water pollution
plan shall indicate why the certification required by this part
was not feasible.
b. Special Requirements for Storm Water Discharges Associated
with Industrial Activity from Facilities Subject to SARA
Title III, Section 313 Requirements
The Superfund Amendments and Reauthorization Act (SARA) of
1986 resulted in the enactment of Title III of SARA, the
Emergency Planning and Community-Right-to-Know Act. Section 313
of Title III of SARA requires operators of certain facilities
that manufacture, import, process, or otherwise use listed toxic
chemicals to report annually their releases of those chemicals to
any environmental media. Listed toxic chemicals include 329
chemicals listed at 40 CFR 372.
Facilities that meet all of the following criteria for a
calendar year are subject to Title III reporting requirements for
that calendar year and must report under 40 CFR 372.30:
o The facility has 10 or more full-time employees;
o The facility is a multi-establishment complex where all
establishments have a primary SIC code of 20 through 39;
o The facility is a multi-establishment complex in which one
of the following is true:
- The sum of the value of products shipped and/or
produced from those establishments that have a primary
SIC code of 20 through 39 is greater than 50 percent of
the total value of all products shipped and/or produced
from all establishments at the facility;
- One establishment has a primary SIC code of 20 through
39 and contributes more in terms of value of products
shipped and/or produced than any other establishment
. within the facility;
o The facility manufactured (including imported), processed,
or otherwise used a toxic chemical in excess of an
applicable threshold quantity of that chemical set forth in
40 CFR 372.25.
After 1989, the threshold quantity of listed chemicals that
the facility must manufacture, import or process in order to be
required to submit a release report is 25,000 pounds per year.
The threshold for a use other than manufacturing, importing or
processing of listed toxic chemicals is 10,000 pounds per year.
EPA estimates that 35,000 facilities nationwide will be subject
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to SARA Title III reporting requirements after 1990. EPA
promulgated a final regulation clarifying these reporting
requirements on February 16, 1988 (53 FR 4500). EPA believes
that the information received through reporting is a "front end"
of the toxics program to which EPA is already committed and
ultimately will assist in better controls for routine toxics
releases and improved industrial practices to prevent and respond
to accidents involving toxics.
Of the 329 toxic chemicals listed at 40 CFR 372 which are
used to define the scope of SARA Title III, Section 313
requirements, the Agency has identified approximately 175
chemicals which it is classifying, for the purposes of these
general permits, as 'Section 313 water priority chemicals'. For
the purposes of these general permits, "Section 313 water
priority chemicals' are defined as chemicals or chemical
categories which also: 1) are listed at 40 CFR 372.65 pursuant to
SARA Title, Section 313; 2) are present at or above threshold
levels at a facility subject to SARA Title III, Section 313
reporting requirements; and 3) that meet at least one of the
following criteria: (i) are listed in Appendix D of 40 CFR 122 on
either Table II (organic priority pollutants), Table III (certain
metals, cyanides, and phenols) or Table V (certain toxic
pollutants and hazardous substances); (ii) are listed as a
hazardous substance pursuant to section 311(b)(2)(A) of the CWA
at 40 CFR 116.4; or (iii) are pollutants for which EPA has
published an acute or a chronic toxicity criteria.
The large amounts of toxic chemicals at facilities with
Section 313 water priority chemicals raises concerns regarding
the potential of material handling and storage operations to add
pollutants to storm water discharges associated with industrial
activity. The material management practices associated with the
storage and use of toxic chemicals is a major potential source of
pollutants in storm water discharges associated with industrial
activity. The Agency believes that the threshold criteria
established in SARA Title III, Section 313, along with the
regulatory definition of storm water discharge associated with
industrial activity, identify potential risks in a manner that is
appropriate for use in developing priorities for establishing the
applicability of specialized monitoring and pollution prevention
measures for facilities which use and manage toxic chemicals.
In evaluating risks and establishing regulatory priorities
for facilities with storm water discharges associated with
industrial activity, the Agency believes that the large amounts
of toxic chemicals found at facilities with Section 313 water
priority chemicals pose sufficient risk to warrant specific
permit conditions establishing: 1) containment-oriented
requirements for areas of the facility used for material
management of these chemicals; and 2) acute whole effluent
toxicity (WET) monitoring requirements and associated limits for
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storm water associated with industrial activity discharged from
the containment areas. (Any untreated overflow from containment
facilities designed, constructed and operated to treat the volume
of runoff associated with a 25 year, 24 hour rainfall event is
not subject to the. WET effluent limitation).
Under the draft general permits, facilities with Section 313
water priority chemical storage facilities which are exposed to
storm water discharges are subject to specialized containment
provisions and the WET effluent limitation.
The draft general permits provide that storm water pollution
prevention plans for facilities with Section 313 water priority
chemicals must, in addition to the requirements associated with
the baseline pollution prevention plans, provide for containment-
oriented controls11. Containment involves the use of physical
structures or collection/drainage equipment used to confine a
release of material after it escapes from its physical location
or containment. Dikes surrounding material storage tanks are the
most common example of containment. The containment-oriented
provision of these general permits are designed to mitigate the
discharge of toxic chemicals to waters of the United States from
both significant spill events and from more routine material
management practices and leaks.
EPA believes that tank systems for storage of liquid toxic
chemicals and truck and rail transfer facilities for liquid toxic
chemicals can present a significant risk, if basic accepted
engineering practices are not employeed. EPA has concluded on
the basis of studies, information from other governmental
sources, and supporting information on various rulemakings that
many tank systems have leaked and that other are likely to leak
in the future12.
The containment-oriented control requirements only apply to
priority areas of facilities with Section 313 water priority
chemicals (e.g. portions of the facility where Section 313 water
priority chemicals are stored or managed and which generate storm
11 The containment oriented provisions of these permits are
based on a review of the 1979 survey of BMPs (see "NPDES Best
Management Practice Guidance Document", U.S. EPA, December 1979,
EPA-600/9-79-045) ; Oil pollution prevention requirements, including
Spill Prevention, Control, and Counter-measure (SPCC) plan
requirements at 40 CFR 122.12; "The Oil Spill Prevention, Control,
and countermeasures Program Task Force Report", EPA, May 1988; and
the draft "Analysis of Implementing Permitting Activities for Storm
Water Discharges Associated With Industrial Activity", EPA, 1991.
12
For example, see July 14, 1986 (51 FR 25427).
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water discharges associated with industrial activity13). In
establishing the containment-oriented provisions of the draft
general permits, the Agency has provided flexibility to allow
facilities to use or modify appropriate existing containment
approaches that facilities currently employ.
The evaluated a number of technical options for addressing
releases of SARA Title III, Section 313 water priority chemicals.
These options are summarized in Table 6-1.
3 It should be noted that many facilities which are subject
to SARA Title III, Section 313 reporting requirements because they
manage Section 313 water priority chemicals do not generate storm
water discharges associated with industrial activity. The
regulatory definition of 'storm water associated with industrial
activity' (40 CFR 122.26(b)(14)(xi)) addresses facilities in all
Standard Industrial Classification (SIC) codes between 20 and 39
(as well as additional classes of facilities). However, facilities
under SIC codes 20, 21, 22, 23, 2424, 25, 265, 267, 27, 283, 285,
30, 31 (except 311), 323, 34 (except 3441), 35, 36, 37 (except
373), 38, 39 which are not otherwise addressed by in the regulatory
definition only generate storm water associated with industrial
activity where material handling equipment or activities, raw
materials, intermediate products, final products, waste materials,
by-products, or industrial machinery are exposed to storm water.
Such facilities which do not generate storm water discharges
associated with industrial activity are not subject to these
permits.
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TABLE 6-1
Summary of Control Techologies
Problem
External corrosion
Internal corrosion
Leaks (Tanks and
ancillary
equipment)
Loss of structural
integrity
Overfill
Operator error
Technology
Cathodic protection
Coatings
Secondary containment
Materials standards
Coatings
Liners
Secondary containment
leak detection
visual inspection
ground water monitoring
secondary containment
with monitoring
design standards
quality audit
installation standards
secondary containment
protective controls
secondary containment
operator procedures and
training
secondary containment
Ability to
contain
release
prior to
Function discharge
slows corrosion rate
slows corrosion rate
barrier against corr-
osive soils and
collects releases
slow corrosion
slow corrosion
protective barrier
collects releases
early warning
early warning
detection
early warning, det-
ection and contain.
proper design
eliminate flaws
proper installation
early warning, detec-
ection and containm.
prevent overfill
early warning and
containment
reduce errors
early warning and
containment
No
No
Maybe
No
No
No
Maybe
No
No
No
Yes
No
NO
NO
Yes
No
Yes
No
Yes
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The draft permit provides permittees the opportunity to
submit to the Director of the NPDES program a proposed
alternative spill contingency and integrity testing plan if the
operator believes that the containment provisions of the permit
are not economically practicable. Where the Director of the
NPDES program approves of an alternative plan, the provisions of
the alternative plan serve in lieu of secondary containment
requirements in the permit.
Proposed alternative spill contingency and integrity testing
plans must provide a detailed description that shows that such
requirements are not economically practicable. At a minimum,
such description of economically impracticability should address
the estimated costs of implementing the containment provisions of
the permit, and any other impacts on the processes of the
facilities associated with implementing the containment
provisions of the permit. In addition, proposed alternative
plans must provide for conducting integrity testing of storage
tanks at least once every five years, conducting integrity and
leak testing of valves and piping a minimum every year, establish
site-specific contingency measures, and a written commitment of
manpower, equipment and materials required to respond
expeditiously to any release.
The storm water pollution prevention plans at facilities
with Section 313 water priority chemicals and with storm water
discharges associated with industrial activity must be reviewed
and certified by a Registered Professional Engineer. With the
certification, the Engineer must attest that: the Engineer has
visited and examined the facility and is familiar with the
provisions of .this part; the plan has been prepared in accordance
with good engineering practice; and the plan is adequate for the
facility. Such certifications will in no way relieve the owner
or operator of a facility covered by the plan of their duty to
prepare and fully implement such a plan.
The containment-oriented provision of these general permits
are designed to mitigate the discharge of toxic chemicals to
waters of the United States from both significant spill events
and from more routine material management practices and leaks.
Storm water collected in containment areas can pick up
significant levels of pollutants where material management
practices result in leaks, spills or other exposure to chemicals.
Rather than attempt to establish specific numeric limits and
multiple monitoring requirements for each pollutant subject to
Section 313, the Agency believes that it is more appropriate and
potentially cost effective to establish a single acute whole
effluent toxicity limit and monitoring requirement for these
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discharges. This approach is consistent with the Agency's policy
of limiting whole-effluent toxicity where generic effluent
toxicity is caused by multiple chemical toxicants intermingled in
an effluent.14 For this reason, the draft general permits would
establish an acute whole-effluent toxicity effluent limit for
storm water discharged from containment structures at these
facilities applied as a technology-based performance standard.
Toxicity monitoring and WET limits have been used in the
NPDES program to address a wide range of discharges, including
intermittent discharges. The workgroup has considerable
experience in writing toxicity limitations. The Agency has
evaluated a number of permits with toxicity limits for
intermittant sources in developing these toxicity limit in the
draft permit15. Applying numeric or toxicity limits on a
technology-basis to intermittent discharges such as storm water
protects against periodic releases of high levels of pollutants.
Establishing limits for intermittent discharges is consistent
with the approach taken in the NPDES program which does not allow
for periodic exceedances of limits by continuous discharges.
Using the chemical specific approach to limiting pollutant
discharges has kept significant amounts of toxic compounds out of
surface waters. However, over time, it has become apprarent that
a chemical-specific approach, by itself, cannot adequately
protect all surface waters because many toxic compounds cannot be
measured by available detection methods. In addition,
toxicological data are unavailable for thousands of toxic
compounds that are routinely discharged to surface waters.
Finally, data on the effects of individual compounds do not
account for the interactions among pollutants that may occur in
complex mixtures of toxicants16.
The Agency anticipates that most rainfall is not toxic prior
to contact with surfaces or structures. (Note that the test EPA
uses to characterize toxicity involves neutralizing the sample
prior to testing, so that the effects of acidity are not
measured). Where storm water discharges exhibit toxicity, it is
anticipated that the toxicity is associated with chemical
toxicants picked up from runoff surfaces. The Agency anticipates
u "Permit Writer's Guide to Water Quality-Based Permitting
for Toxic Pollutants," EPA Office of Water (EPA 440/4-87-005) , July
1987.
15 For example, see TX0074438, TX0091855, LA0000493,
TX0103292, LA0004090, and TX0073954.
16 "Biological testing to control toxic water pollutants",^
Wall, T.M., Hanmer, R.W., Journal WPCF, Volume 59, Number 1, page
7.
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that most storm water discharges from these areas at well-
maintained facilities with good housekeeping practices will not
exhibit acute toxicity. For the majority of storm water
discharges that do exhibit acute toxicity, the toxicity can be
reduced by improving storage or material handling procedures,
practices or equipment17.
Since these discharges are generated from limited-sized,
specific storage and material handling areas, a wide range of
technologies are available to reduce the toxicity of the limited
volume of storm water that is subject to the WET effluent
limitation. Other classes of discharges may require various
types of end-of-pipe treatment or various offsite disposal
options such as discharging to a POTW.
The draft general permits provide that any untreated
overflow from containment facilities designed, constructed and
operated to treat the volume of runoff associated with a 24 hour,
25 year rainfall event is not subject to the WET limitation.
In developing the WET limitation, the Agency has also
evaluated a number of other regulatory standards for discharges
from storage tanks. The Occupational Safety and Health
Administration (OSHA) has implemented general safety and health
regulations for flammable and combustible liquids that require
sutitable drainage or diking for area surrounding tanks. These
regulations are intended to "prevent accidental discharge of
liquid from endangering adjoing property or reaching waterways
(29 ?CFR 1910.106). SPCC plan requirements for oil facilties
establish the standard of preventing the "discharge [of] oil in
harful quantities . . . into or upon the navigable waters of the
United States". The National Fire Protection Association code 30
requires that, "where provision is made for draing water from
diked area, such drains shall be controlled ... so as to
prevent flammable or combustible liquids from entering natural
water courses, public sewers, or public drains, if thier presence
would constitute a hazard".
c. Special Requirements for Storm Water Discharges Associated
with Industrial Activity from Salt Storage facilities
Salt is readily dissolved by precipitation. The Salt
Institute highly recommends that salt stockpiles, whether large
or small, should never be left exposed to the elements-rain or
snow. A permanent under-roof storage facility is best for
protecting salt. If this is not possible, then outside piles
should be build on impermeable bituminous pads and covered with
"Biological testing to control toxic water pollutants",
Wall, T.M., Hanmer, R.W., Journal WPCF, Volume 59, Number 1, page
7.
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one of the many types of temporary covering materials, such as
tarpaulin, polyethylene, poly urethane, polypropylenes or
Hypalon. These materials are also available with reinforcement
for added strength. (see "The Salt Storage Handbook", Salt
Institute, 1987). Storage facilities will result in reductions
of lost product and easier handling of materials (and thus
reduced labor costs) which will offset the cost of the storage.
In 1991, EPA surveyed the Department of Transportation in
NH, SD, ME, MA, and ID regarding the use of salt storage
facilities. In Maine, all DOT salt piles are covered by
buildings, and 25 of 130 mixed salt-sand piles are covered by
buildings, but DOT was in the process of covering the remaining
mixed salt/sand piles. MA DOT indicated that 98% of its salt
piles were covered. The remaining 2 percent of the salt piles
are not covered because they are located on privately-owned land
which is not accessible to the State government for construction.
Idaho DOT uses a mixture of salt and aggregate material, with a
low concentration of salt for snow and ice maintenance activities
and estimated that 15% of these piles of this mixture piles are
covered.
Based on a consideration of current industry practices, the
draft permits provide that storm water pollution prevention plans
for facilities with storage piles of salt used for deicing or
other commercial or industrial purposes must, in addition to the
requirements associated with the baseline pollution prevention
plans, enclose or cover their salt storage to prevent exposure to
precipitation. Proper storage of salt, either under roof or by
covering outside stockpiles, can assist in the protection of the
environment as well protect the salt supply and ease the handling
of salt18. The Agency believes that this requirement is
appropriate as salt storage is an accepted and recommended
practice by industries and municipalities (see "The Salt Storage
Handbook", Salt Institute, 1987).
d. Special Requirements for Contaminated Storm Water Discharges
Associated with Industrial Activity from Oil and Gas
Production or Exploration Facilities
Information from sources such as nonpoint source assessments
developed pursuant to Section 319(a) of the CWA indicate that
significant water quality impacts can be caused by wet-weather
failure of on-site waste disposal systems at oil and gas
exploration and production operations (such as storm induced
overflows of reserve pits used to hold spent drilling muds and
cuttings). These draft general permits contain two provisions to
address these events. First, where an operator of a contaminated
18 See "Salt Storage", and "The Salt Storage Handbook", Salt
Institute, Alexandria, VA, 1987.
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storm water discharge associated with industrial activity from an
oil and gas production or exploration operation selects to obtain
a Professional Engineer (PE) certification instead of conducting
annual sampling, the PE certification must attest that reserve
pits used to hold spent drilling muds or cuttings have been
designed and built to prevent storm induced overflows. Second,
pollution prevention plans for oil and gas exploration or
production operations are to include a schedule for qualified
personnel to inspect any reserve pit used to hold spent drilling
muds and cuttings at least once every thirty calendar days and
within 24 hours after any storm event of greater than 0.5 inches
of rain per 24 hour period to evaluate the potential of storm
enduced overflows.
The draft permits provide that pollution prevention plans
for oil and gas production or exploration operations include a
schedule for qualified personnel to inspect any reserve pit used
to hold spent drilling muds and cuttings at least once every
thirty calendar days and within 24 hours after any storm event of
greater than 0.5 inches of rain per 24 hour period to evaluate
the potential of storm enduced overflows.
e. Special Requirements for Storm Water Discharges Associated
with Industrial Activity through Large and Medium Municipal
Separate Storm Sewer Systems
Facilities covered by these permits must comply with
applicable requirements in municipal storm water management
programs developed under NPDES permits issued for the discharge
of the municipal separate storm sewer system that receives the
facility's discharge, provided the discharger has been notified
of such conditions. Permits for discharges from large and medium
municipal separate storm sewer systems will typically require
municipal permittees to develop storm water management programs
which address storm water associated with industrial activity
which discharges through their system.
f. Special Requirements for Storm Water Discharges Associated
with Industrial Activity composed of Coal Pile Runoff
The draft general permits establish effluent limitations of
50 mg/1 total suspended solids (TSS) and a pH range of 6 to 9 for
storm water discharges associated with industrial activity
composed of coal pile runoff. This effluent limitation is
similar to the effluent guideline limitation for coal pile runoff
from facilities in the steam electric power generating point
source category (see 40 CFR 423.12(b)(9)). EPA believes that,
with the exception of pile size, the operation of coal piles by
the steam electric industry is similar to the operation of coal
piles by other facilities with storm water discharges associated
with industrial activity. The most significant feature
distinguishing coal pile operation is the size of the pile. The
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6 - 29
Agency believes that the technologies for addressing coal pile
runoff, and the costs of implementing those technologies are
similar regardless of the type of industrial facility operating
the pile. For these reasons, the Agency believes that the
effluent limitations for coal pile runoff should be the same for
all facilities covered by the permit and should be equivalent the
effluent guideline limitation for coal pile runoff from
facilities in the steam electric power generating point source
category.
The limitation does not apply to any untreated overflow from
facilities designed, constructed and operated to treat the volume
of coal pile runoff which is associated with a 25 year, 24 hour
rainfall event. The effluent limitations guidelines for coal
pile runoff from facilities in the steam electric power
generating point source category at 40 CFR 423.12(b)(9)
incorporates a 10 year, 24 hour design storm into a best
practicable control technology currently available (BPT) limit.
BCT and BAT effluent limitation guidelines for coal pile runoff
are currently reserved. The Agency believes that the appropriate
design storm for coal pile runoff addressed by these permits is
the more stringent 25 year, 24 hour design storm as these permits
establish BAT/BCT limits (which are typically more stringent than
BPT limits), and the 25 year, 24 hour storm is more commonly used
in effluent guideline limitations based on the BAT or BCT
standards.
Design Storms
Several provisions of the draft general permit incorporate
design storms. These provisions include: sediment pond
requirements for certain construction activities; effluent
limitations for coal pile runoff; and effluent limitations and
containment requirements for SARA Title III, Section 313
facilities. Design storms are used for technology-based
requirements to allow a facility to size any control structures
necessary to meet a specified limitation. In general, the larger
the design storm, the larger the capacity of storage or control
necessary to meet a requirement, thereby raising the costs of
compliance.
Without design storms, the discharger would face uncertainty
in designing the volume of controls, and would have to
arbitrarily select a rare event on which to develop a design. In
some cases, limited historic rainfall data exists, making it
impracticable to estimate extremenly rare storm events such as a
100 year or 200 year storm event, again creating uncertaintly for
control designers, and possibly resulting in the development of
extremely large volume controls where the entire design volume is
never used.
To avoid this uncertainty and provide dischargers with an
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appropriate opportunity to comply with permit conditions, a
number of alternatives for design storms have been evaluated,
including the following storm events:
o
o
24-hour, 100-year storm;
w 24-hour, 25-year storm;
o 24-hour, 10-year storm;
o 24-hour, 2-year storm;
o 1 inch storm; and
o 1/2 inch storm.
The average intesity of storm events can vary significantly
in different parts of the country. A desing storm based on a
return period accounts for this regional variablility. In
general, the design of drainage systems (e.g. water volume
control systems) will vary in different parts of the country to
accomadate the rainfall characteristics of that part of the
country. Use of a design storm based on a return period will
allow the coordination of the development of storm water quality
measures with storm water quantity controls.
Peak discharge control is often required as a flood control
measure for one or more design storm under local regulations for
new development (including residential and commercial
development)19. The most common used design storm used for this
purpose is the 2 year storm storm. In natural watersheds in many
eastern parts of the United States, the two year storm produces a
flood that fills a stream to the top of its banks. The 2 year
storm creates an erosive condition in these channels. Some
jurisdictions also require control of the 10 or 100 year design
storm.
EPA has selected the 24 hour, 25 year storm for use for BAT
controls in these draft general permits. The 24 hour, 25 year
rainfall event is the most commonly used design storm for BAT
national effluent limitations guidelines which address storm
water. The 24 hour, 25 year rainfall event provides a reasonable
margin of safety when sizing secondary containment units20. A
design capacity for a 24 hour, 25 year rainfall is fairly
consistant with other regulatory programs for tank containment.
For example, SPCC requirements require containment structures to
be based on 110% capacity of the largest tank. The SPCC
requirement will be more stringent in cases such as where, the.
containment area for a 30 foot tank is twice the area of the
19 "Controlling Urban Runoff: A practical manual for planning
and designing urban BMPs", July, 1987, Metropolitan Washington
Council of Governments.
20 "NPDES Best Management Practices Guidance Document", EPA,
1979, (EPA-600/9-79-045).
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tank, and the area has a 24 hour, 25 year storm of 10 inches.
EPA has selected the 24 hour, 10 year storm for use as a BCT
control of sediment basins for construction activities which
discharge from an area which disturbs more than 10 acres. The
sediment basins focus primarily on the control of sediment from
construction sites, and hence a BCT control is appropriate. The
control is limited to larger sites (those with a discharge
serving more than 10 acres) because such sites will generally
have more flexiblity in selecting an appropriate location for the
basins.
MONITORING REQUIREMENTS
The Agency considered a number of factors, including those
listed below, in developing monitoring requirements
o Discharge variablility;
o Environmental significance and nature of the pollutant or
pollutant parameter;
o cost of monitoring relative to the discharger's capabilities
and benefit obtained; and
o Support of future permitting activities.
Impacts on Small Businesses
The general permits are not expected to have a significant
economic impact on a substantial number of small businesses. The
baseline general permit requirements provide considerable
flexibility
Although the construction industry involves many small
businesses, the large majority of small businesses represent
trades associated with subcontractors. The general permit
generally does not directly impact such businesses, with most
compliance costs ultimately being paid by developers. Small
developments under 5 acres are excluded from the regulatory
definition of storm water discharge associated with industrial
activity.
The costs of requirements for those construction activities
covered by the permit generally are directly related to size of
construction operation, with larger sites incurring larger costs.
Generally, the most expensive control, sediment basins, is
limited to larger sites (those with a discharge serving more than
10 acres).
-------
7. COST ESTIMATES
a. Pollution prevention plan implementation
Storm water pollution prevention plans for the majority of
facilities will address relatively low cost baseline controls for
the majority of industrial facilities. EPA's analysis of storm
water pollution prevention plans indicates that the cost of
developing and implementing the costs of these plans is variable
and will depend on a number of factors, including: the size of
the facility, number of employees, chemicals stored or used at a
facility, the nature of the plant operations and plant designs
and the housekeeping measures employed. Table 7-1 provides
estimates of the range of costs of preparing and implementing a
storm water pollution prevention plan. It is expected that the
low cost estimates provided in Table 7-1 is appropriate for the
majority of smaller facilities. High cost estimates are also
provided.
b. SARA Title III Facilities
Table 6-2 provides estimates of the range of costs of
preparing and implementing a storm water pollution prevention
plan for facilities which are subject to the special requirements
for facilities subject to SARA Title III Section 313 reporting
requirements for chemicals which are classified as 'Section 313
water priority chemicals1. EPA anticipates that the majority of
facilities are expected to have existing spill prevention and
containment systems that will meet the majority of the
requirements of these permits.
High cost estimates correspond to facilities that are
expected to be required to undertake some actions to upgrade
existing spill prevention and containment systems to meet the
requirements of these permits. Costs associated with meeting the
toxicity limit of these permits are based on an assumption that
the toxicity of discharge can be reduced by: modifying material
handling practices; by modifying existing storage equipment to
eliminate leaks and other sources of chemical exposure; or by
discharging waters collected by a containment system to a POTW.
Costs of treatment where the facility does not have existing
treatment capacity or off site disposal is typically expected to
be higher.
Some facilities are expected to have more than one tanks or
other unit operation which uses SARA Title III, Section 313 water
priority chemicals. In these cases, the costs per unit operation
is expected to be lowered, because some measures, such as
containment units, can be consolidated to address more than one
unit.
7-1
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TABLE 7-1
SUMMARY OF ESTIMATED COSTS FOR COMPLIANCE WITH STORM WATER
POLLUTION PREVENTION PLANS WITH BASELINE REQUIREMENTS
Costs in 1988 dollars
Control Measure Minimum Maximum
fixed annual fixed annual
Plan Preparation 2,000 - 75,000 19,650
(Annualized Costs1)
Plan Revisions 200 - 7,500 1,965
(Annualized Costs )
Material Inventory/ - 90 640
Risk Assessment
Spill prevention/response 90 - 700
Procedures
Employee Training - 100 - 1,115
Visual Inspections - 100 - 1,025
Preventive Maintenance/ - - - 4,160
Housekeeping
Storm Water Management - - 5,000 500
Sediment and Erosion - 100 500 1,000
Prevention
Recordkeeping
Non-storm water
certification
200
50
100
14,000
100
Total Fixed cost3 2,400 102,100
Total Annual Costs 530 30,855
This table identifies estimated minimum and maximum costs to
develop and implement storm water pollution prevention plans.
Minimum costs of implementing program components are zero where
existing programs, procedures or security is assumed adequate.
1 Annual ized cost based upon a 5 year permit and 10% discount
rate.
2 Annualized cost based upon a 5 year permit and 10% discount
rate.
3 Total costs only address situation where storm water
pollution plan needs to be developed and not the lower cost
situation where a plan is existing and needs revision.
7-2
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TABLE 7-2
SUMMARY OF ESTIMATED COST PER UNIT OPERATION FOR COMPLIANCE WITH
STORM WATER POLLUTION PREVENTION PLANS
FOR FACILITIES SUBJECT TO SECTION 313 OF SARA TITLE III
WITH WATER PRIORITY CHEMICALS
Control Measure
Costs in 1988 dollars
Minimum Maximum
fixed annual fixed annual
Liquid Storage
Curbing
(Annualized Costs)
Raw Material Storage
Tarpaulin
(Annualized Costs)
Runon Diversion
Trench
(Annualized-costs)
Collection System
Toxicity Reduction
Evaluation/Remediation
Total Fixed Costs
Total Annual Costs
0
0
0
0
1,120
400
1,100
160
250
15,000 3,000
25,000 500
42,620
3,910
7-3
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In addition to the costs shown, containment may result in
substantial savings over the long-term by reducing clean-up and
corrective action costs.
Verification of Spill Prevention/Containment Costs
The costs of the spill prevention and containment
requirements were compared with several other models for
containment controls to ensure accuracy and reasonableness.
Containment requirements can take a number of forms. Two models
were analyzed, the SPCC model for containment and the RCRA
Subtitle C model for hazardous waste tanks.
Containment requirements; SPCC Model
40 CFR 112 establishes pollution prevention requirements,
including requirements for Spill Prevention Control and
Countenneasure (SPCC) plans for certain facilities which store or
handle c;il. The requirements associated with 40 CFR 112 are
similar to the requirements in the NPDES draft general permits
for spill prevention and containment measures at SARA Title III,
Section 313 facilities. Costs associated with SPCC plan
requirements undergo CFR 112 where evaluated from a number of
sources, including&"Economic Impact Analysis of Proposed
Revisions to the Oil Pollution Prevention Regulation (40 CFR
112), EPA, draft January 1991,^'Supplemental Cost/Benefit
Analysis of the Proposed Revisions to the Oil Pollution
Prevention Regulation", EPA, May 1991; and data provided by the
American Petroleum Institute (API).
The SPCC requirements apply to over 250,000 on-shore
facilities and 187,000 offshore facilities with significant
amounts of oil. On-shore facilities can be described in term of
four sectors: 1) production (246,000 facilities with 572,620
tanks); 2) marketing (11,305 facilities with 88,529 tanks);
refining (207 facilities 88,529 tanks); and transportation (2,132
facilities with 9,197 tanks). The transportation sector
addresses pipeline facilities (also regulated under 49 CFR Part
195). In general, facilities in the transportation sector where
not addressed in this analysis, since, in general, the NPDES
general permits requirements for SARA Title III, Section 313
facilities, in general, do not apply to similar types of
facilities or practices.
Cost data from the "Supplemental Cost/Benefit Analysis of
the Proposed Revisions to the Oil Pollution Prevention
Regulation", EPA, May 1991 and data on the number of tanks per
facility from API data were used to generate the estimated costs
of compliance with spill prevention and containment requirements
found shown in Table 7-3. Estimated compliance costs per
facility or per unit operation is expected to vary based on the
7-4
-------
number and size of the tanks.
These cost estimates were compared to cost proposals
provided by SPCC for the installation of secondary containment
for two tank systems. The first tank system was a 1,000,000
gallon steel tank which was 44 feet high and 66 feet in diameter.
The cost of installing a 6.5 foot berm (which included 6 inches
freeboard) was $74,694. This included costs for gravel
($30,607), pavement ($23,140), a dual drainage system ($6,000),
and engineering ($14,939). The second tank system was a 100,000
gallon steel tank which was 27 feet high and had a diameter of 24
feet. The cost of installing a 5 feet berm (which includes 6
inches freeboard) was $17,495. This included costs for gravel
($7,222), pavement ($3,773), drainage ($3,000) and engineering
($3,500).
7-5
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TABLE 7-3
SUMMARY OF ESTIMATED COST PER UNIT OPERATION FOR COMPLIANCE WITH
SPCC REQUIREMENTS FOR OIL FACILITIES
Costs in 1991 dollars
First Subsequent
Year Year
Control Measure ; Cost Cost
Drainage System for Tank Truck Loading/ $50,000 $100
Unloading areas
Valves for drainage from diked areas $500-$!,000 $40-$70
(per diked area)
Drainage system from undiked areas $2,000-$69,000 small
Secondary containment for Bulk Storage $430-$820 small
Tanks
7-6
-------
Containment requirements; Hazardous waste tanks
The RCRA Subtitle C requirements for hazardous wastes is a
more stringent model of control than the SPCC approach. The RCRA
model requires the use of double-walled tanks, double-walled
pipe, corrosion protection and a lined concrete pad and curbing
beneath. EPA analyzed costs of the RCRA hazardous waste tank
requirements as part of the process of developing regulations for
such units (July 14, 1986, (51 FR 23466), and see "Cost Analysis
of RCRA Regulations for Hazardous Waste Tank Facilities and
Economic Impact Analysis of RCRA Regulations for Hazardous Waste
Tank Facilities", EPA 1986). In that study, EPA estimated the
capital cost of above ground facilities for small businesses to
be $4,795, with a cumulative operation and maintenance cost of
$966 for years 1 through 8 and a cumulative operation and
maintenance cost of $1,200 for years 9 through 10. This amounts
to an annualized costs of $1,661 before taxes, and $1,434 after
taxes. The EPA estimated costs of RCRA requirements for above
ground tanks is shown in Table 3-
7-7
-------
Table 7-4 - Installed before Tax costs for new carbon steel above ground
with full secondary containment
Tank without secondary
secondary
Size containment ($)
(gal)
275
550
3000
10000
125000
10000*
initial O&M Annualiz.
Tank with secondary
containment ($)
initial O&M Annualiz.
690
1480
7000
14000
14000
51000
0
0
0
0
0
0
100
210
1000
1400
16200
7200
1260
2160
10000
20000
151000
74000
250
250
250
250
250
250
430
560
1600
3100
21600
10700
Increm. cost of
conta inment ($)
initial O&M Annualiz.
570 250 330
670 250 350
3000 250 600
6000 250 1700
37000 250 5400
23000 250 3500
consists of 4 tanks in an operation
7-8
-------
Integrity testing and Leak detection
The number of possible compliance alternatives increases the
difficulty of estimating an appropriate cost for integrity
testing.
Buried pipe integrity testing is estimated to cost $155 per
tank4. The estimated cost of a leak detector that is retrofitted
is $465 per tank, based on equipment cost of $155 per tank and
installation costs of $310 per tank to retrofit existing tanks.
Monitoring methods for underground storage tanks systems
include automatic in-tank monitoring, monitoring for petroleum
vapors in soil and groundwater monitoring.
c. Construction Sites. t
The two major costs associated with pollution prevention
plans for construction activities include the costs of sediment
and erosion controls (see Table 7-5), and the costs of storm
water management controls (see Table 7-6). The draft general
permits provide flexibility in developing controls for
construction activities. Typically, most construction sites will
employ several types of sediment and erosion controls and storm
water management controls, but not all of the controls listed in
Tables 7-5 and 7-6. In general, sites which disturb a larger
area will incur higher pollution prevention costs.
For construction sites greater than 10 acres, the most
significant costs are generally expected to be those associated
with plan preparation sediment basins, outlet stabilization,
temporary stabilization, and permanent stabilization. For
smaller sites, the most significant costs are generally expected
to be those associated with outlet stabilization, temporary
stabilization, and permanent stabilization.
Table 7-7 provides estimates of the costs for several model
construction sites. The data in this table indicates that costs
can vary even at similarly sized sites. The data also indicates
that costs can be dramatically reduced by good site planning
(e.g. Sites A and C) where fingerprinting and vegetation
preservation can reduce the total area disturbed and the area
where temporary vegetative practices are necessary. In addition,
good planning can reduce the costs of storm water management
devices. In most cases, some costs, such as the costs of
permanent stabilization typically increases the value of the
site.
U.S. EPA, Regulatory Impact Analysis of Technical Standards
for Underground Storage Tanks. Volume 5, 8/24/88, p. 6-18.
7-9
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TABLE 7-5 Sediment and Erosion Control Costs
Vegetative Practices
temporary seeding
permanent seeding
mulching
sod stabilization
vegetative buffer strips
protection of trees
earth dikes
straw bale dikes
silt fences
brush barriers
drainage swales-grass
drainage swales-sod
drainage swales-riprap
drainage swales-asphalt
drainage swales-concrete
check dams-rock
check dams-covered straw bales
level spreader-earthen
level spreader-concrete
subsurface drain
Pipe slope drain
Temporary storm drain diversion
storm drain inlet protection
rock outlet protection
sediment traps
temporary sediment basins.
sump pit
Entrance stabilization
Entrance wash rack
Temporary waterway crossing
Wind breaks
$1.00 per square yard
$1.00 per square yard
$1.25 per square yard
$4.00 per square yard
$1.00 per square yard
$30.00 to $200 per tree set
$5.50 per linear foot
$5.00 per linear foot
$6.00 per linear foot
$3.00 per square yard
* $4.00 per square yard
$45.00 per square yard
$35.00 per square yard
$65.00 per square yard
$100 per dam
$50 per dam
$4.00 per square yard
$65.00 per square yard
$2.25 per linear foot
$5.00 per linear foot
variable
$300 per inlet
$45 per square yard
$500 to $7,000 per trap
$5,000 to $50,000 per basin
$500 to $7,000
$1,500 to $5,000 per entrance
$2,000 per rack
$500 to $1,500
$2.50 per linear foot
Practices such as sod stabilization and tree protection increase
property values and satisfy consumer aesthetic needs.
7-10
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Table 7-6 - Costs of Storm Water Management for Construction Sites
Cost for Cost for
5 Acre 20 Acre
Developed Developed
Area Area
Wet Ponds $5,770 $16,300
Dry Ponds $12,000 $29,330
Dry Ponds with extended detention $5,950 $15,500
Infiltration Trenches $8,500 $34,100
Estimates based on methodology presented in "Cost of Urban Runoff
Quality Controls", Wiegand, C., Schueler, T., Chittenden, W., and
Jellick, D., Urban Runoff Quality-Impact and Quality Enhancement
Technology, Proceedings of an Engineering Foundation Conference,
ASCE, 1986, edited by B. Urbonas and L.A. Roesner.
7-11
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TABLE 7-7 ESTIMATED COSTS FOR MODEL SITES
Parameters For Model Sites
Pervious
Area area of
Site Disturb. Downgrad. finished
Size 7 days Site Perimeter site
(acres) (acres) Entrances (feet) (acres)
Site A
Site B
Site C
Site D
9
9
20
20
5
9
10
20
1
1
2
2
950
1,250
1,500
1,900
1
4
2
7
Estimated Site Costs in Dollars
Control Site A Site B Site C Site D
temporary seeding
permanent seeding
entrance stabiliz.
entrance wash rack
sediment trap
silt fences
storm water
management devices
tree protection
rock outlet prot.
pipe slope drain
Site Cost
Per Acre Cost
4,840
4,840
3,000
-
-
6,000
6,000
250
2,250
-
27,180
3,020
24,200
19,360
3,000
-
-
6,000
7,000
-
2,250
-
61,810
6,850
14,520
9,680
5,000
2,000
25,000
-
5,000*
400
4,500
500
66,600
3,330
48,400
33,400
5,000
2,000
35,000
-
10,000*
-
5,500
-
139,780
6,989
* Assumes conversion of
pond
sediment basin to storm water management
7-12
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d. Oil and Gas Production or Exploration Operations
Facilities with contaminated storm water discharges
associated with industrial activity, in addition to the baseline
requirements for storm water pollution prevention plans, are
required to conduct inspections of reserve pits used to hold
spent drilling muds or cuttings which is estimated to have an
annual cost of $800. Not all oil and gas exploration or
production facilities are expected to have such structures, and
hence this additional cost is not applicable.
e. Salt Storage Facilities
Salt pile covers or tarpaulins are anticipated to have a
fixed cost of $400 and an annual cost of $160 for medium sized
piles, and a fixed cost of $4,000 and an annual cost of $2,000
for very large piles.
Representatives of the Department of Transportation in
Maine, New Hampshire, South Dakota, and Massachusetts where
surveyed in 1991 regarding the costs of building storage
facilities for salt piles. Estimates from ME, NH, SD were:
o small facilities (less than 1,000 cubic yards): $30,000-
$50,000; $70-80/cubic yard;
o medium facilities (between 1,000 and 2,500 cubic yards),
$70,000, $20-30/cubic yard;
o large facilities (5,000 cubic yards), $100,000, $18/cubic
yard.
The Massachusetts DOT indicated that the cost to complete
construction for a typical pole barn building for salt storage
(40x84 feet) which can store between 1,400 and 1,500 tons of salt
is estimated at $100,000. The cost to complete the typical dome
facility (72 feet in diameter) which can store between 1,400 and
1,500 tons of salt is estimated at $85,000.
Maine DOT indicated that all salt piles operated by Maine
DOT which are composed solely of salt compounds are currently
covered by buildings, and 25 of 130 mixed salt-sand piles are
covered by buildings, however the State is in the process of
covering the remaining mixed salt-sand piles. South Dakota DOT
indicated that all salt piles utilized by that agency are covered
by buildings. MA DOT indicated that 98% of its salt piles are
covered. Idaho DOT estimated that 15 percent of its salt-
aggregate mixture piles are covered.
f. Coal Pile Runoff.
The effluent limitations for coal pile runoff in the draft
7-13
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permits can be achieved by two primary methods: by limiting
exposure to coal by use of covers or tarpaulins; and by
collecting and treating the runoff. In some cases, coal pile
runoff may be in compliance with the effluent limitations without
covering the pile or collecting or treating the runoff. In these
cases, the operator of the discharge would not have a control
cost.
The use of covers or tarpaulins to prevent or minimize
exposure of the coal pile to storm water is generally expected to
be practical only for relatively small piles. Coal pile covers
or tarpaulins are anticipated to have a fixed cost of $400 and
annual cost of $160.
Table 7-5 provides estimates of the cost of treating coal
pile runoff5. These costs are based on a consideration of a
treatment train requiring equalization, pH adjustment and
settling, including the costs for impoundment (for equalization),
a lime feed system and mixing tanks for pH adjustment, and a
clarifier for settling. The costs for the impoundment area
include diking and containment around each coal pile and
associated sumps and pumps and piping from runoff areas to
impoundment area. The costs for land are not included. The lime
feed system employed for pH adjustment includes a storage silo,
shaker, feeder, and lime slurry storage tank, instrumentation,
electrical connections, piping and controls.
Additional costs may be incurred if a polymer system is
needed. In such a case, costs would include impoundment for
equalization, a lime feed system, mixing tank, and polymer feed
system for chemical precipitation, a clarifier for settling and
an acid feeder and mixing tank to readjust the pH within the
range of 6 to 9. The equipment and system design, with the
exception of the polymer feeder, acid feeder and final mixing
tank, is essentially the same as shown in Table 7-5. Two tanks
are required for a treatment train with a polymer system, one for
precipitation and another for final pH adjustment with acid. The
cost of mixing is therefore twice that shown in Table 7-5. The
polymer feed system includes storage hoppers, chemical feeder,
solution tanks, solution pumps, interconnecting piping,
electrical connections and instrumentation. The costs of
clarification is identical to that of Table 7-5. A treatment
It should be noted that the type and degree of treatment
required to meet the effluent limitations of these permits will
vary depending upon factors such as the amount of sulfur in the
coal. This section describes a model treatment scheme for the
purposes estimating costs for compliance with the proposed effluent
limitations. Dischargers may implement other less expensive
treatment approaches to enable them to discharge in accordance with
these limits where appropriate.
7-14
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train with a polymer system requires the use of an acid addition
system to readjust the pH within the range of 6 to 9. The
components of this system include a lined acid storage tank, two
feed pumps, an acid pH control loop, and associated piping,
electrical connections and instrumentation.
Additional information regarding the cost of these
technologies can be found in: "Development Document for Effluent
Limitations Guidelines and Standards and Pretreatment Standards
for the Steam Electric Point Source Category", ((EPA-
440/182/029), November 1982, EPA).
7-15
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TABLE 7-8
SUMMARY OF ESTIMATED COSTS FOR
TREATMENT OF COAL PILE RUNOFF
30,000 cubic
meter coal pile
IMPOUNDMENT
Installed Capital Cost ($)
Operation and Maintenance ($/year)
LIME FEED SYSTEM
6,300
negligible
1,200,000
cubic meter
coal pile
12,600
negligible
Installed Capital Cost ($) 127,700
Operation and Maintenance ($/year) 5,300
Energy Requirements (kwh/yr) 3.6 x 10**4
Land Requirements (ft**2) 5,000
MIXING EQUIPMENT
Installed Capital Cost ($) 60,500
Operation and Maintenance ($/year) 2,100
Energy Requirements (kwh/yr) 1.3 x 10**3
Land Requirements (ft**2) 2,000
CLARIFICATION
Installed Capital Cost ($) 168,000
Operation and Maintenance ($/year) 3,000
Energy Requirements (kwh/yr) 1.3 x 10**3
Land Requirements (ft**2) 3,000
361,200
16,100
3.6 X 10**4
5,000
107,500
2,400
1.3 x 10**3
2,000
260,500
3,800
1.3 x 10**3
- 7,000
Source:"Development Document for Effluent Limitations Guidelines and Standards
and Pretreatment Standards for the Steam Electric Point Source
Category", (EPA-440/182/029), November 1982, EPA). Costs estimates have
been revised to account for inflation.
7-16
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ANALYSIS OF THE CAUSES OF OIL SPILLS
INTRODUCTION
EPA identified several areas requiring further study to
support the Phase Two SPCC proposed rule. Spill notification
reports from the Emergency Response Notification System (ERNS),
Accidental Release Inventory Program (ARIP) questionnaires, and
case studies of past oil spills were reviewed and evaluated to
gather the supporting data.
The Phase Two data collection effort provided the data to
support the following elements of the Phase Two rulemaking:
• Requirements for preparing and approving a facility-specific
response plan. The OPA requires that facility-specific
response plans be prepared and that certain plans be
approved by EPA. EPA has developed criteria for preparing a
response plan, for determining when a facility must submit a
response plan, and for identifying which plans must be
reviewed.
• Definition of a "worst case discharge." Because response
plans are required by the OPA to respond to a worst case
discharge, data were collected to develop a definition of a
worst case discharge.
• Determining "significant and substantial harm." Facilities
whose discharges may cause substantial harm must submit
their response plans to EPA. Of the submitted response
plans, some must be approved by EPA. The Agency has
prepared a framework for determining: 1) which plans must
be submitted (i.e., what constitutes substantial harm); and
2) which plans should be reviewed (i.e., what constitutes
significant and substantial harm).
• Additional technical requirements. Because the Phase Two
rule will implement many of the remaining SPCC Task Force
report1 recommendations, data has been collected to
determine the most effective oil pollution prevention
measures. These proposed technical requirements address
spills caused by human error, equipment failure, and other
documented causes of spills.
*The Oil Spill Prevention, Control, and Countermeasures Program
Task Force Report, (EPA Interim Final Report), May 13, 1988.
10
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METHODOLOGY FOR DATA COLLECTION
Described below are the steps used in collecting and
analyzing the technical data to support each element of this
rulemaking.
Obtain basic information from current EPA databases and from
available reports. The information from this step provided the
basis for the Agency's decisions regarding various technical
issues, "worst case discharge, " "substantial harm, " and
"significant and substantial harm." The ERNS database and the
ARIP database were analyzed to obtain these data.
The ERNS database has been examined for information about
causes of oil spills. Further examination of this database may
also help EPA determine what types of facilities are most likely
to have oil spills.
ARIP is a data collection system used to learn more about
the causes and effects of accidental releases of hazardous
materials from fixed facilities. Although the information
gathered through this program is not necessarily from oil spills,
a comparison of Standard Industrial Classification (SIC) codes
indicates that approximately half of the facilities responding to
questionnaires from this program are likely to be regulated by
the SPCC program. EPA assumes that the causes of spills for
hazardous materials are similar to the causes of oil spills .
Case Study Review. Case studies were gathered from The Oil Spill
Intelligence Reports, Golob' s Oil Pollution Bulletin, ERNS, spill
conference proceedings, and conversations with On-Scene
Coordinators (OSC) to support the rationale for selected
regulatory options. Discussed in Section 5.
Application of "worst case discharge" and "significant and
substantial harm." (may or may not happen) The "worst case
discharge" and "significant and substantial harm" decision
matrices were applied to selected case studies and existing
facilities to validate the matrices. This test involved scoring
a number of case study facilities using the matrices.
Additionally, several facilities from various locations in the
United States were scored. The scores for each facility were
evaluated to determine how well the matrices predicted the need
to review the specific response plan.
FACILITY SIZE VERSUS SPILL SIZE
Prior to gathering supporting data for the SPCC proposed
rule, an effort to determine if facility size and/or tank
capacity size is a reliable predictor of oil spill size was
performed through a statistical analysis of the ERNS database.
The data in the ERNS database provide oil spill information
11
-------
reported from SPCC-regulated facilities between 1988 through the
middle of November 1990.
Formal statistical analysis of possible correlations between
various database parameters is difficult because of inter-
dependencies. There are three parameters of concern: spill
size, tank capacity, and facility size. Clearly tank capacity
can not exceed facility size, and in fact tank capacity is a
component of facility size. Therefore, either tank capacity or
facility size, but not both, should be used in any type of
correlation analysis. Since tank size is a component of facility
size and spills can involve more than one tank facility, size was
chosen.
A linear regression analysis was performed on the data, with
the null hypothesis that spill size is dependent upon, and in
fact, can be predicted by, facility size. Because of the wide
variation between facility sizes and spill sizes the data were
log-transformed. The linear regression model equation is as
follows:
S = Constant + A * X
where
5 = Log Transformed Spill Size
A = Regression Coefficient
X = Log Transformed Facility Size
The graph located below shows spill size plotted against
facility size in log-scale. The calculated linear regression
line is the straight line in the middle; the outer curved lines
are the approximate 95th percentile confidence bound on the
regression line. The plot shows a wide dispersion of data points
around the regression line indicating that the simple linear
regression does not adequately explain spill size. The results
of the regression are given in the tables on the following page.
The t-statistic and the associated probability level for
Log(Facility) indicate that there is significant evidence that
the regression coefficient is not zero, meaning that
Log (Facility) has a significant effect upon Log(Spill) and that
the two parameters are not independent of each other. Since
there is a physical limitation on spill size because a spill can
not exceed the size of the facility, the interpretation of the t-
statistic for the regression coefficient for the constant is
meaningless. From this information, the associated probability
level indicates that facility size is a factor in the size of a
spill.
The adjusted squared multiple r statistic for the regression
is 0.121. The adjusted squared multiple r statistic is a measure
of the proportion of the dependent variable's variation that is
12
-------
Paraneter
Constant
Log (Facility)
Coefficient Standard Error Standard Coefficient T-Statlstlc
2.541
0.313
0.976
0.090
0.000 2.604
0.363 3.489
Prob. Level
0.011
0.001
Source
Regression
Residual
SUB of Squares
62.15
408.49
ANALYSIS
df
1
80
OF VARIANCE
Mean Square P-Ratlo
62.15 12.17
5.11
Prob. Level
0.001
13
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removed after fitting the regression line. The adjusted squared
multiple r statistic has a range of zero to one, where zero
indicates that the regression line explains no portion of the
dependent variable's variation and one indicates that the-
regression line explains all of the dependent variable's
variation. In our case, 0.121 would indicated that only a small
amount of the variation in the spill size data can be explained
by facility size. This analysis suggests that although facility
size is a significant factor in the size of reported spills/
facility size alone is insufficient to predict likely spill
sizes.
-------
Exhibit 2
Frequency and Percentage of Oil Spill Causes from Fixed Facilities in ERNS 1989
Release Cause
Unknown
Ancillary Equipment2 Failure
Other Operator Error
Ancillary Equipment Leak
Overflow: Alarm/Mechanical
Failure
Dumping1
Other*
Tank Leak/Seep/Bottom
Ancillary Equipment Corrosion
Underground Storage Tank Leak
Flooding
Overflow: Operator Error
Fire/Explosion/Liqhtninq
Vandalism
Tank Rupture
Tank Replacement
Transformer
Other Natural Disaster
Pits/Settling Ponds
Electrical/Power Outage
Overflow: Truck Operator Error
Tank Corrosion
Hurricane
Secondary Containment: Failure
Secondary Containment: Overflow
Total
Total Number of Reports
1095
1082
531
441
426
364
200
188
158
157
143
99
85
72
60
46
39
40
32
24
24
22
6
1
1
5,336
Percentage of Total
20.5
20.3
10.0
8.3
7.98
6.8
3.75
3.5
3.0
2.9
2.7
1.9
1.6
1.3
1.1
0.9
0.73
0.7
0.6
0.4
0.4
0.4
0.1
0.02
0.02
100
Source: ERNS Database
Includes piping, valves, pumping, etc.
Dumping refers to the willful, conscious dumping of oil for reasons that
were unspecified.
Includes causes not defined by other fields.
15
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Exhibit 3
Frequency of Oil Spill Causes by Spill Sice in BRKS
Release Cause
Tank Corrosion
Tank Leak/Seep/Bottom
Tank Rupture
Ancillary Equipment Failure
Ancillary Equipnent Corrosion
Ancillary Equipnent Leak
Dumpinq
Electrical/Power Outage
Flre/Bxplosion/Llqhtnlnq
Flooding
Hurricane
Other Natural Dlaaster
Other Operator Error
Overflow/Alarm Mechanical Failure
Overflow: Operator Error
Overflow: Truck Operator Error
Secondary Containment: Failure
Secondary Containment: Overflow
Underqround Storage Tank Leak
Unknown
Vandalism
Other
Pits/Settling Ponds
Trans former
Tank Replacement
Total
Spill Size Frequency
< 10K
21
182
SS
1,049
156
439
363
21
79
143
S
40
522
411
91
24
1
1
153
1.086
69
191
32
39
46
5.226
10-20K
0
1
1
17
0
2
1
1
0
0
0
0
4
4
3
0
0
0
2
5
1
0
0
0
0
42
20-50K
1
3
2
16
0
0
0
1
2
0
0
0
3
6
4
0
0
0
1
4
1
0
0
0
0
44
50-100K
0
1
0
0
1
0
0
0
1
0
0
0
1
3
0
0
0
0
0
0
1
0
0
0
0
8
> 100K
0
1
2
0
1
0
0
1
3
0
1
0
1
2
1
0
0
0
1
0
0
2
0
0
0
16
TOTAL
22
188
60
1,082
158
441
364
24
ts
143
6
40
531
426
99
24
1
1
157
1,095
72
200
32
39
46
5.336
Source: ERNS database
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ARIP
ARIP is a data collection system used to learn more about
the causes and effects of accidental releases of hazardous
materials from fixed facilities. The data gathered by the
program also indicate what actions have been effective in
preventing spills, and what actions could have been implemented
to minimize the impacts of spills that had already occurred.
ARIP is administered by EPA.
For ARIP, EPA developed a questionnaire that specifically
addresses the causes of accidental releases; the questions focus
on the practices facilities use to prevent releases, and on the
methods they may employee to assess hazards. These
questionnaires are sent to facilities that have experienced a
release demonstrating one or more of the following criteria:
• the quantity released is in excess of the Comprehensive
Environmental Response, Compensation and Liability Act
(CERCLA) reportable quantity (RQ) for the substance;
• the release results in deaths or injuries;
• the release indicates a trend of related releases from
the same facility; and
• the release involves extremely hazardous substances as
designated under the Emergency and Community Right-to-
Know Act.
The fields found in the ARIP database track the individual
questions that appear on the aforementioned survey. These
include:
• facility-specific information (facility name, address,
SIC code, etc.);
• the name(s) of the released.substance(s);
• time of day of the release;
• location within the facility where the release
occurred;
• cause of release;
• how the release was discovered;
• the quantity of each chemical into each medium (that
is, the amount of a certain substance released to air,
surface water, or land, etc.);
17
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• any deaths or injuries caused by the release;
• what, if any, hazard assessments were performed; and
• what, if any management activities directly related to
safety and loss prevention were performed.
Other fields are also included within the database, most having
to do with less critical details of the release event and what
activities are planned for the facility's future in terms of
safety and spill prevention.
The ARIP database was used to evaluate the proposed Phase
Two amendments to the Oil Pollution Prevention regulation. No
critical data were deleted, but the questions requiring long
responses were removed to accommodate space limitations. The
database file initially contained 1454 records describing events
from 1988 through 1990. Many of these records had completely
blank fields, and many more were for facilities that are not
subject to the SPCC regulations. The number of facilities found
in the database with SIC codes and non-blank records that are
affected by the proposed Oil Pollution Prevention regulation is
497. Although the ARIP database consists of spill quantity in
pounds, the quantity was converted into gallons to be consistent
throughout. This sample provided the data reported here.
To examine the characteristics of the spills contained in
the ARIP database, the database files were manipulated in several
ways. First, a matrix was developed to correlate release cause
and release locations within a facility. Exhibit 4 presents a
matrix correlating release causes and release locations. In this
manner, specific problem areas in facilities can be highlighted.
For example, if a high percentage of all spills occurring at
valves on a storage vessel were a result of human error, this
would be revealed in the matrix. This example might indicate
that the manual manipulation of storage vessel valves is a
critical area requiring additional attention during personnel
training. A number of additional matrices were also developed to
identify:
• spills occurring during certain hours (to determine the
differences in spill characteristics between daytime
and nighttime releases);
• spills occurring at facilities that did not employ
certain safety-related management activities (to
determine differences in the size of these spills and
the size of all spills);
18
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• spills occurring at facilities that did not perform
certain hazard assessments (to determine differences in
the size of these spills and the size of all spills);
and
• spills occurring during different facility operations
(such as during normal production/storage operation
during maintenance operations, etc.)
Finally, some of the above criteria were examined more
closely. For example, the environmental media that received the
hazardous substances were determined and compared. Also, for all
facilities that did not employ safety-related management
activities for a release, a check was made on whether they did
enact management activities at some later date. If a single
facility experienced a release in the absence of safety-related
activities, and then later experienced a release after certain
activities had been implemented, the size and severity of the
releases were compared. The same procedure was followed for
releases occurring at facilities that did not perform hazard
assessments, and then later experienced releases after such
assessments were initiated.
Exhibit 5 offers a comparison of average spill sizes for
releases occurring at different times of the day, and into
different environmental media. The data show that daytime
(defined as 6:00 AM to 6:00 PM) substance released onto land are
roughly one third the size of those that occur into surface
waters or sewers, and they occur about twice as often. At night,
the quantity and frequency of both types of spills decrease.
This information is contrary to the ERNS database which showed a
larger number of spills affecting water than land. Under section
311 of the CWA, only certain oil discharges must be reported to
ERNS. These are, if the discharge:
- causes a sheen to appear on the surface of the water;
violates applicable water quality standards; or
- causes a sludge or emulsion to be deposited beneath the
surface of the water or upon the adjoining shorelines.
Thus, unless the oil spill is in, or threatens, the waters
of the U.S., it is not required to be reported through ERNS.
19
-------
Exhibit 4
Release Cause and Locations within the Facility
RELEASE
LOCATION
Process vessel
Storage vessel
Valves on
process vessel
Valves on
storage vessel
Piping on
process vessel
Piping on
storage vessel
Pumps
Joints
Unknown
Other
Valve
Piping
RELEASE CAUSE
Equipment
Failure
44
28
23
23
30
24
11
21
0
39
12
15
Operator
Error
22
16
14
10
5
8
3
3
0
21
9
3
Bypass
Condition
1
0
0
0
1
0
0
0
0
3
0
0
Upset
Condition
20
5 .
8
2
. 3
1
1
0
0
9
4
1
Fire
0
0
0
1
0
0
0
0
0
2
0
0
Maintenance
Activity
4
1
2
0
2
4
0
2
0
4
1
1
Unknown
2
0
0
1
0
1
0
0
0
2
0
0
Other
2
3
4
0
3
2
1
0
0
6
1
2
Source: ARIP
20
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Exhibit 5
Average Release Sizes: Daytime vs. Nighttime Spills
Average Spill Size
in gallons
Release Medium
Primary Material
on Land
Secondary
Material on Land
Primary Material
in Surface Hater
Secondary Material
in Surface Hater
Primary Material
in Sewer
Secondary Material
in Sewer
All Facilities;
497 Reports5
6,684
(130 spills)
744
(17 spills)
4,756
(30 spills)
1,337
(5 spills)
4,542
(42 spills)
1,182
(10 spills)
Daytime Spills;
310 Reports
3,297
(86 spills)
1,004
(11 spills)
6,172
(22 spills)
1,750
(3 spill-s)
2,935
(25 spills)
2,349
(5 spills)
Nighttime Spills
174 Reports
2,726
(37 spills)
320
(1 spill)*
960
(5 spills)
1,104
(1 spill)
6,927
(17 spills)
14
(5 spills)
Source: ARIP
*' Note that the total number of spills to land and surface water do not add up to the total
number of respective reports. This is because some spills entered environmental media not listed
on this table.
' Since there was only one nighttime spill of secondary materials, this number is not an
average, but the individual spill size, and therefore not suitable for comparison.
21
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Exhibit 6 shows an analysis of release frequency segregated
by facility or SIC category. The number of releases within a
specific range of SIC numbers indicates the relative threat of
release that each type of industrial category imposes. As shown
in the table, chemicals and allied products manufacturing spills
are the most frequent, accounting for over 60% of all releases
reported in this database. Other types of manufacturing,
including oil refining and food manufacturing, account for 30% of
the remaining releases.
Because such a high percentage of the facilities described
by the ARIP database are involved in manufacturing (nearly 95%),
a comparison was made between manufacturing facilities that do,
and those that do not perform hazard assessments at least once a
year. Examples of hazard assessments that facilities may perform
are:
- cause-consequence analysis;
Dow and Mond Hazard Indices;
- HAZOP/hazard and operability analysis;
- failure modes, effects, and criticality analysis; and
what-if analyses.
Several other hazard assessment techniques are used, through not
as frequently as those listed above. As shown in Exhibit 7,
facilities that perform hazard assessments at least once a year
manufacture comparable materials to facilities that perform
hazard assessments less often that once a year. Of the 472
facilities classified as manufacturing, only 46 (9.7%) perform
hazard assessments at least yearly. The average spill size (into
water or on land) for these facilities is less than half of the
average spill size for the other 426 facilities that do not
perform yearly hazard assessments. While production and storage
volumes vary greatly among facilities, the actual products that
these two sets of facilities produce are very similar. Thus, the
data provided in Exhibit 7 suggest that hazard assessments, when
performed regularly, may play an important role in helping to
reduce spill sizes.
Exhibit 8 shows the frequency and percentage of spill causes
reported to ARIP for facilities with applicable SIC codes.
Equipment failure and operator error account for more than 75% of
all spills. Exhibit 9 presents the frequency of spill causes by
spill size categories. More than 80% of the spills reported in
ARIP involve discharges of less than 10,000 gallons. Equipment
failure and operator error are listed as the spill cause of over
75% of spills under 10,000 gallons. Tabular representation of
spill sizes sorted by spill cause are presented in Exhibit 10.
The primary causes of spills in all size categories are equipment
failure and operator error.
22
-------
Exhibit 6
Release Frequency/Standard Industrial Code Category Analysis
Facility Category
Number
of
Releases
Percent
of Total
Releases
Chemicals and Allied Products Manufacturing
Other Manufacturing
Petroleum Refining and Related Industries
Food and Kindred Products Manufacturing
Primary Metal Industries
Electric Utility Plants
Trucking and Warehousing/Hater Transportation
Oil Production
Stone, Clay, Glass and/or Concrete Manufacturing
Coal Mining/Nonmetallic Minerals Mining
Contract Construction
Source: ARIP
23
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Exhibit 7
Hazard Assessment Utilization Analysis
Number of Facilities
Number of Facilities that are
Classified as Manufacturing
Percentage of Facilities that
are Clasified as Manufacturing
Manufacturing
Category
by Percentage
Food and Kindred Products
Chemicals and Allied
Products
Petroleum Refining and
Related Industries
Stone, Clay, Glass, and
Concrete
Primary .Metal Industries
Other Manufacturing
Facilities that
Perform Hazard
Assessments at
| Least Once per Year
49
46
94%
6.5%
78.3%
4.3%
0.0%
6.5%
4.3%
Facilities that do
not Perform Hazard
Assessments at Least
Once per Year
448
426
95%
6.1%
63.4%
9.9%
0.5%
3.0%
17.1%
Average spill size for manufacturing-facilities that perform hazard assessments
at least once per year:
(into surface water and on land—9 spills total)
3,126 gallons
Average spill size for manufacturing-facilities that do not perform hazard assessments
at least one per year:
(into surface water and on land—136 spills total)
6,947 gallons
Source: ARIP
24
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Exhibit 8
Frequency and Percentage of Spill Causes in ARIP
Release Cause
Equipment Failure
Operator Error
Upset Condition
Other
Maintenance Activities
Unknown
Bypass Condition
Fire
TOTALS
Total Number of Reports
269
114
54
24
21
6
5
3
496
Percentage of Total
54
23
11
5
4
1
1
1
100
Source: ARIP
25
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Exhibit 9
Frequency of Spill Causes by Spill Size in ARIP
Release Cause
Equipment Failure
Operator Error
Bypass Condition
Upset Condition
Fire
Maintenance Activities
Unknown
Other
TOTAL
Spill Size Frequency (in gallons)
< 10K
259
110
4
54
3
21
6
23
480
10-20K
5
1
0
0
0
0
0
0
6
20-50K
2
2
0
0
0
0
0
0
4
50-100K
1
1
0
0
0
0
0
0
2
> 100K
2
0
1
0
0
0
0
1
4
TOTAL
269
114
5
54
3
21
6
24
496
Source: ARIP
26
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Exhibit 10
Distribution of Spill Causes by Spill Size in ARIP
Release Cause
Equipment Failure
Operator Error
Bypass Condition
Upset Condition
Fire
Maintenance Activities
Unknown
Other
TOTAL
Spill Size Frequency (in gallons)
< 10K
54%
23%
1%
11%
1%
4%
1%
5%
100%
10-20K
83%
17%
0%
0%
0%
0%
0%
0%
100%
20-50K
50%
50%
0%
0%
0%
0%
0%
0%
100%
50-100K
50%
50%
0%
0%
0%
0%
0%
0%
100%
> 10 OK
50%
0%
25%
0%
0%
0%
0%
25%
100%
TOTAL
54%
23%
1%
11%
1%
4%
1%
5%
100%
Source: ARIP
27
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DRAFT
Statistical Analysis of the Spill Size Distribution as Reported to ERNS
JUL 2 4
In the options paper for tiered response planning, one of the options was to establish absolute
planning quantities regardless of facility type and size. In the proposed option, an average discharge and
maximum most probable discharge would serve as threshold values corresponding to a small spill and a
medium spill, respectively. This paper supplements the options paper by providing a discussion of the
statistical analysis performed and the resulting calculated values which may be used to define the additional
planning quantities.
Spill size data was extracted from the Emergency Response Notification System (ERNS) database
for the four year period between 1987 and 1990. Spill sizes reported as 0 or unknown amounts were
considered incomplete and eliminated from the analysis. The number of non-zero size reports over the four
year period is 17,654. Reported spill sizes ranged from a minimum of 0.145 gallons (1 Ib.) to a maximum of
5.965 million gallons (41.16 million Ibs.). The distribution of spill sizes is heavily skewed with a large
majority of spills at the smaller end of the range.
Statistical analysis performed on the data indicates a lognormal distribution of spill sizes. The.
estimated mean value and the gallon amounts associated with specific quantiles were calculated in order to
define average discharge and maximum most probable discharge, respectively. The estimated mean value of
1300 gallons could be used to define the average discharge. Therefore a small spill would be defined as any
spill volume up to 1300 gallons, but not to exceed the calculated worst case discharge.
Maximum most probable discharge could be defined by a gallon amount associated with a specific
quantile. A quantile is a point within a distribution which delineates the upper bound of a specified
probability density (i.e., the distribution predicts that 95 percent of future spills will be less than the gallon
amount associated with the 95th quantile). The following table lists the gallon amount associated with a
given quantile.
Parameters
Mean (Average)
25th Quantile
• »
50th Quantile
75th Quantile
90th Quantile
95th Quantile
99th Quantile
99.5th Quantile
99.9th Quantile
Parameter Estimate
(Gallons)
1,296
8
44
253
1^31
3,168
18,653
35,763
136^42
Observed Frequency
(Percent of Total)
627.6
50.7
76.0
89.6
94.2
98.6
99.2
99.8
- Not Subject to BOIA Request
-------
Maximum most probable discharge could be defined by the 99th quaotile of this distribution, (i.e.,
approximately 19,000 gallons). A gallon amount associated with a lesser quantile would hot sufficiently
discriminate between an average discharge and -a maximum most probable discharge. A quantile
representing a larger percentage may be too great a quantity, not unlike a worst case discharge for many
facilities. For example, factory-built tanks are a common tank size, which do not usually exceed 20,000
gallons. Using the 99.5th quantik (Le, approximately 36,000 gallons) would probably be greater than the
calculated worst case discharge for a given facility, and therefore the facility would only have to plan for two
tiers of response. Furthermore, according to a cleanup contractor, different equipment is needed for releases
involving more than 20,000 gallons, so this figure represents a breaking point in the response planning effort.
Given this discussion of the statistical analysis, a revised definition for a small spill and a medium
spill could be stated as follows:
• The estimated mean spill value, which could be used to define average
discharge, is 1300 gallons.
Small spill - Any spill volume up to 1*300 gallons, but not to exceed the
calculated worst case discharge. *
• Maximum most probable discharge could be defined by the 99th quantile,
with an assigned value of 19,000 gallons.
Medium spill - Any spill volume between 1,300 gallons and 19,000 gallons,
but not to exceed the calculated worst case discharge.
In addition to these two planning quantities, facilities are required to plan for a worst case discharge.
This method requires only one or two tier planning when the calculated worst case discharge overlaps with
the lesser planning quantities, thus easing the burden on smaller facilities.
- Not Sriyxt to KMA Rope*
2
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