INDUSTRIAL  STORMWATER
FACT SHEET  SERIES
                                       Sector A: Timber Products Facilities
           U.S. EPA Office of Water
           EPA-833-F-06-016
           December 2006
 What is the NPDES stormwater permitting program for industrial
 activity?
 Activities, such as material handling and storage, equipment maintenance and cleaning, industrial
 processing or other operations that occur at industrial facilities are often exposed to stormwater. The
 runoff from these areas may discharge pollutants directly into nearby waterbodies or indirectly via
 storm sewer systems, thereby degrading water quality.

 In 1990, the U.S. Environmental Protection Agency (EPA) developed permitting regulations under the
 National Pollutant Discharge Elimination System (NPDES) to control stormwater discharges associated
 with eleven categories of industrial activity. As a result, NPDES permitting authorities, which may be
 either EPA or a state environmental agency, issue stormwater permits to control runoff from these
 industrial facilities.


 What types of industrial facilities are required to obtain permit
 coverage?
 This fact sheet specifically discusses stormwater discharges from timber products facilities as described
 by Standard Industrial Classification (SIC) Major Group 24 - identified in EPA's Multi-Sector General
 Permit as Sector A, Timber Products Facilities. This includes all facilities that produce lumber and wood
 products, except furniture. Facilities and products in this group fall under the following categories, all
 of which require coverage under an industrial stormwater permit:

    4 Log storage and handling (wet deck storage areas only authorized if no chemical additives are
      used in the spray water or applied to the logs) (SIC 2411)
    4 General sawmills and planing mills (SIC 2421)
    4 Hardwood dimension and flooring mills (SIC 2426)
    4 Special product sawmills not elsewhere classified (SIC 2429)
    4 Millwork, veneer, plywood,  and structural wood (SIC 2431-2439
      * Not included are wood kitchen cabinet manufacturers (SIC 2434) which are instead
        addressed in the Fact Sheet for wood and metal furniture and fixture manufacturing.

    4 Wood containers (SIC 2441-2449)
    4 Wood buildings and mobile homes (SIC 2451 and 2452)
    4 Wood preserving (SIC 2491)
    4- Reconstituted wood products (SIC 2493)
    4 Wood products, not elsewhere classified (SIC 2499)

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector A: Timber Products Facilities
  What does an industrial storm water permit require?
  Common requirements for coverage under an industrial stormwater permit include development of a
  written stormwater pollution prevention plan (SWPPP), implementation of control measures, and sub-
  mittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP
  is a written assessment of potential sources of pollutants in stormwater runoff and control measures
  that will be implemented at your facility to minimize the discharge of these pollutants in runoff from
  the site. These control measures include site-specific best management practices (BMPs), maintenance
  plans, inspections, employee training, and reporting. The procedures detailed in the SWPPP must be
  implemented by the facility and updated as necessary, with a copy of the SWPPP kept on-site. The in-
  dustrial stormwater permit also requires collection of visual, analytical, and/or compliance monitoring
  data to determine the effectiveness of implemented  BMPs. For more information on  EPA's industrial
  stormwater permit and links to State stormwater permits, go to www.epa.gov/npdes/stormwater
  and click on "Industrial Activity."


  What pollutants are associated with activities at my facility?
  Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of
  timber products will vary. There are a number of factors that influence to what extent industrial
  activities and significant materials can affect water quality.
     4 Geographic location
     4 Topography
     4 Hydrogeology
     4 Extent of impervious surfaces (e.g., concrete or asphalt)
     4 Type of ground cover (e.g., vegetation, crushed stone, or dirt)
     4 Outdoor activities (e.g., material storage, loading/unloading, vehicle maintenance)
     4 Size of the operation
     4 Type, duration, and intensity of precipitation events

  The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at timber
  products manufacturing facilities.
  Table 1. Common Activities, Pollutants Sources, and Associated Pollutants at Timber Products
  Facilities
   Activity
Pollutant Source
Pollutant
   Log storage and handling
Exposure of lumber to precipitation
Bark and wood debris, total suspended solids
(TSS), and leachates (which can contain high
levels of TSS and biochemical oxygen demand
(BOD))
   Untreated lumber and residue
   generation activities and
   untreated wood materials
   storage
Exposure of lumber and residues to
precipitation
Bark and wood debris, TSS, and leachates
(which can contain high levels of TSS and
BOD)
   Wood surface protection
   activities and chemicals and
   surface protected materials
   storage
Spills from surface protection areas
and storage and mixing tank areas;
treated wood drippage, transport, and
storage; and fugitive emissions from
spraying
Chemicals (used for surface protection), BOD,
chemical oxygen demand (COD), and TSS
   Wood preservation activities and
   chemicals and preserved wood
   material storage
Drippage after pressurized treatment;
washing after preservation: spills and
leaks from process equipment and
preservative tanks; fugitive emissions;
and kick-back
Chemicals (specific toxics dependant on the
preserving formulations used), BOD, TSS, oil,
and grease
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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector A: Timber Products Facilities
  Table 1. Common Activities,
  Facilities (continued)
Pollutants Sources, and Associated Pollutants at Timber Products
Activity
Wood assembly/fabrication
activities and final fabricated
wood product storage
Equipment/vehicle maintenance,
repair, and storage

Pollutant Source
Exposure of lumber, residues, and
vehicles/equipment to precipitation
Parts cleaning
Waste disposal of oily rags, oil and gas
filters, batteries, coolants, degreasers
Fluid replacement including hydraulic
fluid, oil, transmission fluid, radiator
fluids, and grease

Pollutant
BOD, TSS, oil, and grease
Solvents, oil, heavy metals, acid/alkaline
wastes
Oil, heavy metals, solvents, acids
Oil and grease, arsenic, lead, cadmium,
chromium, COD, and benzene

  What BMPs can be used to minimize contact between stormwater
  and potential pollutants at my facility?
  A variety of BMP options may be applicable to eliminate or minimize the presence of pollutants
  in stormwater discharges from timber products facilities. You will likely need to implement a
  combination or suite of BMPs to address stormwater runoff at your facility. Your first consideration
  should be for pollution prevention BMPs, which are designed to prevent or minimize pollutants
  from entering stormwater runoff and/or reduce the volume of stormwater requiring management.
  Prevention BMPs can include regular cleanup, collection and containment of debris in storage areas,
  and other housekeeping practices, spill control, and employee training. It may also be necessary to
  implement treatment BMPs, which are engineered structures, intended to treat stormwater runoff
  and/or mitigate the effects of increased stormwater runoff peak rate, volume, and velocity. Treatment
  BMPs are generally more expensive to install and maintain and include oil-water separators, wet
  ponds, and proprietary filter devices.

  EPA requires that all timber products facilities implement BMPs in the following areas of the site:
     4  Log, lumber, and other wood product storage areas
     4  Residue storage areas
     4  Loading, and unloading areas
     4  Material handling areas
     4  Chemical and liquid fuel storage areas
     4  Equipment/vehicle maintenance, storage, and repair areas

  Facilities that surface protect and/or preserve wood products are also required to address specific
  BMPs for wood surface protection and preserving activities.

  BMPs must be selected and implemented to address the following:

  Good Housekeeping  Practices
  Good housekeeping is the practical, cost-effective way to maintain a clean and orderly facility and
  keep contaminants out of stormwater discharges. It includes establishing protocols to reduce the
  possibility of mishandling materials or equipment and training employees in good housekeeping
  techniques. Common problem areas at a facility include areas around trash containers, storage areas,
  and loading docks. Good housekeeping measures must include a schedule for regular pickup and
  disposal of garbage and waste materials and routine inspections of drums, tanks, and containers
  for leaks and  structural conditions. Practices also include containing and covering garbage, waste
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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector A: Timber Products Facilities
  materials, and debris. Involving employees in routine monitoring of housekeeping practices has
  proven to be an effective means of ensuring their continued implementation.

  Additional good housekeeping practices for timber products facilities in storage, loading/unloading
  and material handling areas include:
     4  Limiting the discharge of wood debris by confining to restricted locations, and by keeping it
        cleaned up in  non-designated areas
     4  Cleaning up air-borne dusts that have settled in other areas
     4  Chemical management

  Minimizing Exposure
  Where feasible, minimizing exposure of potential pollutant sources to precipitation is an important
  control option. Minimizing exposure prevents pollutants, including debris, from coming into contact
  with precipitation and can reduce the need for BMPs to treat contaminated stormwater runoff. It can
  also prevent debris from being picked up by stormwater and carried into drains and surface waters.
  Examples of BMPs for exposure minimization include covering materials or activities with temporary
  structures (e.g., tarps) when wet weather is expected or moving materials or activities to existing
  or new permanent structures (e.g., buildings, silos, sheds). Even the simple practice of keeping a
  dumpster lid closed can be a very effective pollution prevention measure.

  Erosion and Sediment Control
  BMPs must be selected and implemented to limit erosion on areas of your site that, due to
  topography, activities, soils, cover, materials, or other factors are likely to experience erosion. Erosion
  control BMPs such as seeding, mulching, and sodding prevent soil from becoming dislodged and
  should be considered first. Sediment control BMPs such as silt fences, sediment ponds, and stabilized
  entrances trap sediment after it has eroded. Sediment control BMPs should be used to back-up
  erosion control BMPs.

  Management of Runoff
  Your SWPPP must contain a narrative evaluation of the appropriateness of stormwater management
  practices that divert,  infiltrate, reuse, or otherwise manage  stormwater runoff so as to reduce the
  discharge of pollutants. Appropriate measures are highly site-specific, but may include, among others,
  vegetative swales, collection and  reuse of stormwater, inlet controls, snow management, infiltration
  devices, and wet retention measures.

  A combination of preventive and treatment BMPs will yield the most effective stormwater
  management for minimizing the offsite discharge of pollutants via stormwater runoff. Though not
  specifically outlined in this fact sheet, BMPs must also address preventive maintenance records or
  logbooks, regular facility inspections, spill prevention and response, and employee training.

  All BMPs require regular maintenance to  function as intended. Some management measures  have
  simple maintenance requirements, others are quite involved. You must regularly inspect all BMPs to
  ensure they are operating properly, including during runoff events. As soon as a problem is found,
  action to resolve it should be initiated immediately.

  Implement BMPs, such as those listed below in Table 2 for the control of pollutants at timber
  products manufacturing facilities, to minimize and prevent the discharge of pollutants in stormwater.
  Identifying weaknesses in current facility  practices will aid the permittee in determining appropriate
  BMPs that will achieve a reduction in pollutant loadings.  BMPs listed in Table 2 are broadly applicable
  to timber products manufacturing facilities; however, this is not a complete list and you  are
  recommended to consult with regulatory agencies or a stormwater engineer/consultant to identify
  appropriate BMPs for your facility.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector A: Timber Products Facilities
  Table 2.  BMPs for Potential Pollutant Sources at Timber Products Facilities
   Pollutant Source
BMPs
   Log, lumber and
   wood product
   storage areas
FJ  Divert stormwater around storage areas with vegetated swales, and/or berms. A properly
   designed vegetated swale can also provide infiltration benefits.
Q  Locate storage areas on stable, well-drained soils with slopes of 2-5 percent to prevent
   ponding and to convey stormwater leachate to treatment. Sloping should be limited to
   prevent erosion. Slopes should be stabilized.
FJ  Line storage areas with crushed rock or gravel  or porous pavement to promote infiltration,
   minimize discharge, and provide sediment and erosion control.
Q  Practice good housekeeping measures such as frequent removal of debris, bark, and wood
   waste. Cleanup methods may include mobile sweepers, scrapers, brow logs, or scoops.
FJ  Use properly designed basins for collection, containment, and  recycling of log spraying
   materials.
   Use sedimentation measures such as silt fence  to control sediment from leaving storage area.
   Cover piles to prevent contact with stormwater (use roofs, canopies, soils, sheds, etc.).
   For solid wastes use covered containers such as dumpsters or garbage cans that are durable,
   corrosion resistant, non-absorbent, and/or non-leaking.
   Residual storage
   areas
Q  Locate stored residues away from drainage pathways and surface waters.
Q  Avoid contamination of residues with oil, solvents, chemically treated wood, trash, etc.
FJ  Limit storage time of residues to prevent degradation and generation of leachates.
Q  Divert stormwater around residue storage areas with vegetated swales, and/or berms.
Q  Consolidate piles to minimize surface areas exposed to precipitation.
FJ  Spray surfaces with water to reduce windblown dust and residue particles.
FJ  Place materials on raised pads of compacted earth, clay, shale, or stone and collect and
   properly treat contaminated runoff and leachate.
Q  Cover and/or enclose stored residues to prevent contact with precipitation using silos, van
   trailers, shed, roofs, buildings, or tarps.
FJ  Limit slopes of storage areas to  minimize velocities of runoff which may transport residues.
   Keep slopes stabilized.
Q  Use check dams in drainage ways.
FJ  Use steel or plastic drums that are rigid and durable, corrosion resistant, non-absorbent,
   watertight, and equipped with a close fitting cover.
Q  Train employees in proper residuals management.
   Loading and
   unloading areas;
   material handling
   areas
    Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
    run-on.
    Slope the impervious concrete floor or pad to collect spills and leaks and convey them to
    proper containment and treatment.
    Cover loading and unloading areas and perform these activities on an impervious pad at a
    dock with a door skirt.
    Enclose material handling systems for wood wastes.
    Cover materials entering and leaving areas.
    Provide good housekeeping measures to limit debris.
    Provide dust control. When controlling dust, sweep and/or apply water or materials which
    will not impact surface or ground water.
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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector A: Timber Products Facilities
  Table 2.  BMPs for Potential Pollutant Sources at Timber Products Facilities (continued)
   Pollutant Source
BMPs
   Loading and
   unloading areas;
   material handling
   areas (continued)
FJ  Provide paving in spill-prone areas to enable easy collection of spilled materials.

FJ  For rail transfer, use a drip pan installed within the rails to collect spillage from the tank.

FJ  Train employees in  spill prevention and control.
   Chemical storage
   areas
FJ  Provide secondary containment around chemical storage areas. If containment structures
    have drains, ensure that the drains have valves, and that valves are maintained in the closed
    position. Institute protocols for checking/testing stormwater in containment areas prior to
    discharge.

Q  Properly dispose of chemicals that are no longer in use.

Q  Provide fluid level indicators.

Q  Inventory fluids to identify leakage.

Q  Locate storage areas away from high traffic areas and surface waters.

Q  Develop and implement spill prevention, containment, and countermeasure (SPCC) plans.

Q  Cover and/or enclose chemical storage areas.

Q  Provide drip pads/pans to allow for recycling of spills and leaks.

Q  Store and handle reactive, ignitable, or flammable liquids in compliance with applicable local
    fire codes, local zoning  codes, and the National Electric Code.

Q  Train employees in spill  prevention and control.
   Liquid fuel storage
   areas
Q  If area is uncovered, connect sump outlet to sanitary sewer (if possible) or an oil/water
    separator, catch basin filter, etc. If connecting to a sanitary sewer check with the system
    operator to ensure that the discharge is acceptable. If implementing separator or filter
    technologies ensure that regular inspections and maintenance procedures are in place.

Above ground tanks

FJ  Use secondary containment, such as dikes, with a height sufficient to contain a spill (the
    greater of 1 0 percent of the total enclosed tank volume or 1 1 0 percent of the volume
    contained in the largest tank).  If containment structures have drains, ensure that the drains
    have valves, and that valves are maintained in the closed position. Institute protocols for
    checking/testing stormwater in containment areas prior to discharge.

Q  Use double-walled tanks.

FJ  Keep liquid transfer nozzles/hoses in secondary containment area.

Q  Include overflow protection.

FJ  Store drums indoors when possible.
                           Store drums, including empty or used drums, in secondary containment with a roof or cover
                           (including temporary cover such as a tarp that prevents contact with stormwater).
                        FJ  Clearly label drum with its contents.
   Wood surface
   protection and
   preserving activities
FJ  Extend drip time in process areas before moving to storage areas.

FJ  Pave and berm areas used by equipment that has come in contact with treatment chemicals.

FJ  Dedicate equipment that is used for treatment activities to that specific purpose to prevent the
    tracking of treatment chemicals to other areas on the site.

FJ  Locate treatment chemical loading and unloading areas away from high traffic areas where
    tracking of the chemical may occur.

FJ  Provide drip  pads under conveyance equipment from treatment process areas.
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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector A: Timber Products Facilities
  Table 2.  BMPs for Potential Pollutant Sources at Timber Products Facilities (continued)
   Pollutant Source
BMPs
   Wood surface
   protection and
   preserving activities
   (continued)
FJ  Provide frequent visual inspections of treatment chemical loading and unloading areas during
   and after activities occur to identify any spills or leaks needing cleanup.
FJ  Cover and/or enclose treatment areas or apply log treating chemicals on impervious
   containment pad.
Q  Provide containment in treated wood storage areas.
Q  Cover storage areas to prevent contact of treated wood products with precipitation.
Q  Elevate stored, treated wood products to prevent contact with run-on/runoff.
Q  Store freshly treated  logs on impervious containment pad, in a building or under a roof.
Q  Do not vent volatile or mist-laden exhaust containing log treating chemicals to the outside
   without proper collection or filtration.
Q  Inspect processing areas, transport areas, and treated wood storage areas monthly to assess
   usefulness of practices to minimize the deposit of treatment chemicals on unprotected soils
   and in areas that will come in contact with stormwater discharges.
   Vehicle and
   equipment
   maintenance,
   storage, and repair
   areas
Good Housekeeping
Q Eliminate floor drains that are connected to the storm or sanitary sewer; if necessary, install
   a sump that is pumped regularly. Collected wastes should be properly treated or disposed
   of by a licensed waste hauler.
Q Prevent and contain spills and drips.
Q Use drip pans, drain boards, and drying  racks to direct drips back into a fluid holding tank
   for reuse.
Q Drain all parts of fluids prior to disposal. Oil filters can be crushed and recycled.
Q Promptly transfer used fluids to the proper container; do not leave full drip pans or other
   open containers around the shop.  Empty and clean drip pans and containers.
Q Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers
   properly.
Q Store batteries and other significant materials inside.
Q Label and track the recycling of waste material  (e.g., used oil, spent solvents, batteries).
Q Maintain an organized inventory of materials.
Q Eliminate or reduce the number and amount of hazardous materials and waste by
   substituting non-hazardous or less hazardous materials.
Q Clean up leaks, drips, and other spills without using large amounts of water. Use
   absorbents for dry cleanup whenever possible.
Q Prohibit the practice of hosing down an area where the practice would result in the
   discharge of pollutants to a stormwater system.
Q Clean without using liquid cleaners whenever possible.
Q Conduct all  cleaning at a centralized station so the solvents stay in one area.
Q If parts are dipped in liquid, remove them slowly to avoid spills.
Q Do not pour liquid waste into floor drains, sinks, outdoor storm drain inlets, or other storm
   drains or sewer connections.
Minimizing Exposure
Q Perform all cleaning operations indoors or  under covering when possible. Conduct the
   cleaning operations in an area with a concrete  floor with no floor drainage other than to
   sanitary sewers or treatment facilities.
Q If operations are uncovered, perform them on a concrete pad that is impervious and
   contained.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector A: Timber Products Facilities
  Table 2.  BMPs for Potential Pollutant Sources at Timber Products Facilities (continued)
   Pollutant Source
BMPs
   Vehicle and
   equipment
   maintenance,
   storage, and repair
   areas (continued)
Minimizing Exposure
Q  Park vehicles and equipment indoors or under a roof whenever possible and maintain
   proper control of oil leaks/spills.
Q  Check vehicles closely for leaks and use pans to collect fluid when leaks occur.
Management of Runoff
Q  Use berms, curbs, or other diversion measures to ensure that stormwater runoff from other
   parts of the facility do not flow over the maintenance area.
Q  Collect the stormwater runoff from the cleaning area and provide treatment or recycling.
   Discharge vehicle wash or rinse water to the sanitary sewer (if allowed by sewer authority),
   wastewater treatment, a land application site, or recycle on-site. DO NOT discharge
   washwater to a storm drain or to surface water.
Inspections and Training
Q  Inspect the maintenance area regularly for proper implementation of control measures.
Q  Train employees on proper waste control and disposal procedures.
  What if activities and materials at my facility are not exposed to
  precipitation ?
  The industrial stormwater program requires permit coverage for a number of specified types of
  industrial activities. However, when a facility is able to prevent the exposure of ALL relevant activities
  and materials to precipitation, it may be eligible to claim no exposure and qualify for a waiver from
  permit coverage.
  If you are regulated under the industrial permitting program, you must either obtain permit coverage
  or submit a no exposure certification form, if available. Check with your permitting authority for
  additional information as not every permitting authority program provides no exposure exemptions.

  Where do I get more information?
  For additional information on the industrial stormwater program see
  www.epa.gov/npdes/stormwater/msgp.
  A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
  be found at www.epa.gov/npdes/stormwatercontacts.

  References
  Information contained in this Fact Sheet was compiled from EPA's past and present Multi-Sector
  General Permits and from the following sources:
     4 USEPA, Office of Wastewater Management. NPDES Stormwater Multi-Sector General Permit for
        Industrial Activities (MSGP).
        www.epa.gov/npdes/stormwater/msgp
     4 USEPA, Office of Science and Technology. 1999. Preliminary Data Summary of Urban
        Stormwater Best Management Practices. EPA-821 -R-99-012
        www.epa.gov/OST/stormwater
     4- USEPA, Office of Water. 1999. Storm Water Management Fact SheetóDust Control.
        EPA 832-F-99-003.
        www.epa.gov/owm/mtb/dustctr.pdf

  EPA833-F-06-016                                                                             8

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