Industrial Stormwater Fact Sheet Series Sector B: Paper and Allied Products Manufacturing Facilities


INDUSTRIAL  STORMWATER
FACT  SHEET SERIES
                                            Sector B: Paper and Allied Products
                                                        Manufacturing Facilities
            U.S. EPA Office of Water
            EPA-833-F-06-017
            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 paper and allied products
  manufacturing facilities as defined by Standard Industrial Classification (SIC) Major Group Code 26.
  Facilities and products in this group fall under the following categories, all of which require coverage
  under an industrial stormwater permit:
    4 Pulp mills (SIC 2611)
    4 Paper mills (SIC 2621)
    4 Paperboard mills (SIC 2631)
    4 Paperboard containers and boxes (SIC 2652-2657)
    4 Converted paper and paperboard products, except containers and boxes (SIC 2671-2679)

  Products manufactured by these facilities include newsprint, printing and writing papers, bleached
  and unbleached  packaging paper, glassine, tissue papers, vegetable parchment, greaseproof papers,
  bleached and unbleached paperboard, special industrial papers, and pulp.


  What does an industrial stormwater 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
  submittal 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 measures
  that will be implemented at your facility to minimize the discharge of these pollutants in runoff
  from the site. These 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 industrial 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

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector B: Paper and Allied Products Manufacturing Facilities
  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 my facility's activities?
  Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of
  paper and allied 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 Hydrogeology
     4 Topography
     4 Extent of impervious surfaces (e.g., concrete or asphalt)
     4 Type of ground  cover (e.g., vegetation, crushed stone, or dirt)
     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 paper and
  allied products manufacturing facilities.

  Table 1.  Common Activities, Pollutant Sources, and Associated Pollutants at Paper and Allied
  Products Manufacturing Facilities
Activity
Raw material
preparation
Pulping
Bleaching
Papermaking
Materials loading
and unloading,
storage, and waste
management and
disposal
Equipment/vehicle
maintenance,
repair, and storage
Vehicle fueling
Pollutant Source
Exposure of the generated wood
chips, sawdust, and other wood debris
Storage of materials used for
reclamation of useful pulp
Storage of chemicals used for
bleaching of pulp
Storage of coatings, when exposed to
stormwater
Spills and leaks of materials
Spills and leaks of materials
Parts clean
Waste disposal of oily rags, oil and gas
filters, batteries, coolants, degreasers
Fluid replacement including hydraulic
fluid, oil, transmission fluid, radiator
fluids, and grea
Diesel fuel
Pollutant
Total suspended solids (TSS) and biochemical oxygen
demand (BOD5)
Detergents, solvents, TSS, and BOD
Hydrosulfite, hypochlorite, chlorine, oxygen, and peroxides
Some mixture of starches, latices, polyvinylacetate,
recoverable solvents, TSS, and BOD
Solvents, glues, fuels, oils, lubricants, alcohol, starch,
wooden pallets, paper rollstock, waxes, air emissions from
solvent recovery processes, baled waste paper, dyes, inks,
ammonia, biocides, miscellaneous materials removed
during pulping, final products, adhesives, paper wastes,
dust and particulates from cyclones used in paper trim
activities, resins/polymers, clay slurries
Solvents, glues, fuels, oils, lubricants, alcohol, starch,
wooden pallets, paper rollstock, waxes, air emissions from
solvent recovery processes, baled waste paper, dyes, inks,
ammonia, biocides, miscellaneous materials removed
during pulping, final products, adhesives, paper wastes,
dust and particulates from cyclones used in paper trim
activities, resins/polymers, clay slurries
Solvents, oil, heavy metals, acid/alkaline wastes
Oil, heavy metals, solvents, acids
Oil and grease, arsenic, lead, cadmium, chromium,
chemical oxygen demand (COD), and benzene
Diesel, gasoline, oil
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector B: Paper and Allied Products Manufacturing Facilities
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 paper and allied product manufacturing 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.

BMPs must be selected and implemented to address the following:

Good Housekeeping Practices
Good housekeeping is a practical, cost-effective way to maintain a clean and orderly facility to prevent
potential pollution sources from coming into contact with stormwater. It includes establishing proto-
cols to reduce the possibility of mishandling materials or equipment and training employees in good
housekeeping techniques. Common areas where good housekeeping practices should be followed in-
clude trash containers and adjacent areas, material storage areas, vehicle and equipment maintenance
areas, and loading docks. Good housekeeping practices 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 materi-
als, and debris. Involving employees in routine monitoring of housekeeping practices has proven to
be an effective means of ensuring the continued implementation of these measures.

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 consid-
ered 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.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector B: Paper and Allied Products Manufacturing Facilities
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 paper and allied
product 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 paper and allied product 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.
Table 2. BMPs for Potential Pollutant Sources at Paper and Allied Products Manufacturing Facilities
Pollutant Source
BMPs
Loading and
unloading areas
Confine storage to designated and labeled areas outside of drainage pathways.
Cover storage areas with a roof or tarp.
Divert stormwater around storage areas with vegetated swales, and/or berms.
Provide secondary containment for storage tanks and drum storage.
Cover dumpsters used for waste paper and other materials.
Store materials on concrete pads to allow for cleanup of spills or leaks.
Expedite recycling process for exposed scrap paper.
Develop and implement spill plans.
Provide for dust and debris collection where cyclones are utilized.
Train employees in spill prevention and control
Storing logs, lumber,
and other timber
products
FJ Divert stormwater around storage areas with vegetated swales, and/or berms.
FJ Locate storage areas on stable, well-drained soils with slopes of 2-5 percent to prevent
ponding. 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.
FJ 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.
FJ Use sedimentation measures such as silt fence to control sediment from leaving storage area.
Q Cover piles to prevent contact with stormwater (use roofs, canopies, soils, sheds, etc.).
Q For solid wastes use covered containers such as dumpsters or garbage cans that are durable,
corrosion resistant, non-absorbent, and/or non-leaking.
Q For log storage piles, develop a leachate collection system to capture and treat discharges (do
not allow leachate to discharge to the storm drain system)
Q Sweep the log storage yard on a regular basis.
FJ Train employees in good housekeeping measures.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector B: Paper and Allied Products Manufacturing Facilities
Table 2. BMPs for Potential Pollutant Sources at Paper and Allied Products Manufacturing Facilities
(continued)
Pollutant Source
BMPs
Storing logs, lumber,
and other timber
products (continued)
Provide secondary containment for 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.
Storing chemicals
Q Properly dispose of chemicals that are no longer in use by taking them to a Hazardous Waste
Recycling Center or contracting with a qualified disposal company.
Q Clearly identify accumulation dates on the outside of waste chemical storage units.
FJ Maintain an inventory of fluid levels to identify leakage.
Q Locate storage areas away from high traffic areas and surface waters.
FJ Develop and implement spill prevention, containment, and countermeasure (SPCC) plans, if
required for your facility.
FJ Provide drip pads/pans where chemicals are transferred from one container to another 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.
Storing liquid fuels
Q If area is uncovered, connect sump outlet to sanitary sewer (if possible) or to 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.
Above ground tanks
FJ Use secondary containment, such as dikes, with a height sufficient to contain a spill (the
greater of 10 percent of the total enclosed tank volume or 110 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.
FJ Use double-walled tanks with overflow protection.
Q Keep liquid transfer nozzles/hoses in secondary containment area.
Portable containers/drums
FJ Store drums indoors when possible.
Q 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.
Vehicle fueling
FJ Conduct fueling operations (including the transfer of fuel from tank trucks) on an impervious
or contained pad and under a roof or canopy where possible. Covering should extend beyond
spill containment pad to prevent rain from entering.
FJ When fueling in an uncovered area, conduct fueling operations on a concrete pad (asphalt is
not chemically resistant to the fuels being handled).
Q Use drip pans where leaks or spills of fuel can occur and when making and breaking hose
connections.
Q Use fueling hoses with check valves to prevent hose drainage after filling.
FJ Keep spill cleanup materials readily available.
FJ Clean up spills and leaks immediately.
Q Use spill and overflow protection devices.
FJ Use curbs or berms to minimize stormwater run-on to fueling areas.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector B: Paper and Allied Products Manufacturing Facilities
Table 2. BMPs for Potential Pollutant Sources at Paper and Allied Products Manufacturing Facilities
(continued)
Pollutant Source
BMPs
Vehicle fueling
(continued)
Use dry cleanup methods for fuel area rather than hosing down the fuel area. Sweep up
absorbents as soon as spilled substances have been absorbed.
Perform inspections and preventive maintenance on fuel storage tanks to detect potential leaks
before they occur.
Inspect the fueling area for leaks or spills.
Train personnel on vehicle fueling BMPs.
Provide curbing or posts around fuel pumps to prevent collisions from vehicles.
Discourage "topping off" of fuel tanks.
Equipment/vehicle
maintenance
Good Housekeeping
Q Eliminate floor drains 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.
FJ Use drip pans, drain boards, and drying racks to direct drips back into a fluid holding tank for
reuse.
FJ 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.
FJ Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers by
taking them to a disposal site (check your Phone Book under Hazardous Materials and Waste
Services).
FJ Store batteries and other significant material inside.
Q Label and track the recycling of waste material (e.g., used oil, spent solvents, batteries).
FJ Maintain an organized inventory of materials.
FJ Eliminate or reduce the number and amount of hazardous materials and waste by substituting
nonhazardous or less hazardous materials.
Q Clean up leaks, drips, and other spills without using large amounts of water or liquid cleaners.
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.
FJ 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.
FJ 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 concrete pad that is impervious and contained.
FJ Park vehicles and equipment indoors or under a roof whenever possible and maintain proper
control of oil leaks/spills.
FJ Check vehicles closely for leaks and use pans to collect fluid when leaks occur.
EPA-833-F-06-017

Q Use berms, curbs, or other diversion measures to ensure that stormwater runoff from other
parts of the facility does not flow over the maintenance area.

FJ 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

FJ Inspect the maintenance area regularly to ensure above BMPs are implemented.

Q Train employees on 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 current Multi-Sector
General Permits and from the following sources:

4 City of Phoenix, Arizona, Street Transportation Department, Stormwater Management Section.
2004. Prevent Stormwater Contamination Best Management Practices Section B - Paper and
Allied Products Manufacturing. SIC Codes 2610-2679.
http://phoenix.gov/STREETS/papprod.pdf

4 U.S. EPA 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 U.S. EPA, Office of Wastewater Management. NPDES Stormwater Multi-Sector General Permit
for Industrial Activities (MSGP).
www.epa.gov/npdes/stormwater/msgp
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