INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining U.S. EPA Office of Water EPA-833-F-06-018 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 chemical and allied products manufacturing facilities as described by Standard Industrial Classification (SIC) Major Group 28. Facilities and products in this group fall under the following categories, all of which require coverage under an industrial stormwater permit: 4- Industrial inorganic chemicals (SIC 2812-2819) 4- Plastics, synthetics, and resins (SIC 2821-2824) 4 Medicinal chemicals and botanical products; pharmaceutical preparations in virto and in vivo diagnostic substances; biological products, except diagnostic substances (SIC 2833-2836) 4 Soaps, detergents, cosmetics, and perfumes (SIC 2841-2844) 4 Paints, varnishes, lacquers, enamels, and allied products (SIC 2851) 4- Industrial organic chemicals (SIC 2861-2869) 4 Agricultural chemicals (SIC 2873-2879) 4 Miscellaneous chemical products (SIC 2891-2899) 4 Inks and paints, including china painting enamels, India ink, drawing ink, platinum paints for burnt wood or leather work, paints for china painting, artist's paints, and artist's watercolors (SIC 3952) 4 Petroleum refining (SIC 2911) 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 sub- mittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining 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 my facilities activities? Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of chemical 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 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 chemical and allied products manufacturing facilities. Table 1. Common Activities, Pollutants Sources, and Associated Pollutants at Chemical and Allied Products Manufacturing and Refining Facilities Activity Material Handling and Storage Vehicle Fueling and Maintenance Pollutant Source Equipment storage Storage of materials in tanks, either below or above ground Storage of cylinders used to contain industrial gases Storage of empty or full drums Material handling and warehousing Loading/unl Bagging of materials/products Blending and mixing of chemicals Crushing, milling, shredding, granulation, and grinding of materials Distribution of products Vehicle fueling Vehicle maintenance Pollutant Pollutant dependant upon those at particular facility TSS, IDS, oil and grease, gasoline, diesel, acid, coolant EPA-833-F-06-018 ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining Table 1. Common Activities, Pollutants Sources, and Associated Pollutants at Chemical and Allied Products Manufacturing and Refining Facilities (continued) Activity Waste Treatment, Disposal, and Cleanup Manufacturing Process Components Miscellaneous Activities Pollutant Source Waste dumpster or compactor Hazardous waste temporary storage or operation of RCRA treatment, storage, or disposal facility Landfills or temporary Wastewater treatment Thermal oxidation Steam boile Hot oil system for cooling/heat exchange Use of machinery to process materials Plant yard and areas of past industrial activity Access roads and rail Pollutant Pollutant dependant upon those at particular facility Pollutant dependant upon those at particular facility TSS 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 chemical 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 protocols 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 include 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 materials, 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 EPA-833-F-06-018 ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining 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 chemical and allied 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 chemical 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 Chemical and Allied Products Manufacturing and Refining Facilities Pollutant Source BMPs Material handling Q Cover handling and storage areas with roofs, covers, or other appropriate forms of protection. and storage Q Confine storage to designated and labeled areas outside of drainage pathways and away from surface waters. FJ Divert stormwater around storage areas with vegetated swales, and/or berms. FJ Store materials on concrete pads to allow for cleanup of spills or leaks. FJ Provide secondary containment for storage tanks and drum storage. FJ 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. EPA-833-F-06-018 ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and Refining Facilities (continued) Pollutant Source BMPs Material handling and storage (continued) FJ Use double-walled tanks. FJ Locate storage areas away from high traffic areas and surface waters. FJ Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings, hoses, and valves) for failures or leaks and perform preventive maintenance. Q Maintain an inventory of fluids to identify leakage. Q Provide fluid level indicators. Q Properly dispose of chemicals that are no longer in use. 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 Provide drip pads/pans where chemicals are transferred from one container to another to allow for recycling of spills and leaks. FJ Develop and implement spill plans or spill prevention, containment, and countermeasure (SPCC) plans, if required for your facility. Portable containers/drums FJ Develop and implement spill plans or spill prevention, containment, and countermeasure (SPCC) plans, if required for your facility. Q 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 precipitation). Q Provide secondary containment, such as dikes or portable containers, 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). FJ Clearly label drum with its contents. FJ Train employees in spill prevention and control and proper materials management. FJ Empty containment units with manually operated pumps or ejectors. If facility drainage is not engineered as listed above, equip the final discharge point of all facility sewers to prevent discharge in the event of an uncontrolled spill. Loading/unloading areas FJ Confine loading/unloading activities to designated areas outside drainage pathways and away from surface waters. FJ Inspect containers for leaks or damage prior to loading/unloading. FJ Avoid loading/unloading materials in the rain or provide cover or other protection for loading docks. Q Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit run-on. Q Cover loading and unloading areas and perform these activities on an impervious pad to enable easy collection of spilled materials. FJ Slope the impervious concrete floor or pad to collect spills and leaks and convey them to proper containment and treatment. FJ Provide overhangs or door skirts to enclose trailer ends at truck loading/unloading docks. FJ For rail transfer, a drip pan shall be installed within the rails to collect spillage from the tank. EPA-833-F-06-018 ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and Refining Facilities (continued) Pollutant Source BMPs Loading/unloading areas (continued) FJ Where liquid or powdered materials are transferred in bulk from truck or rail cars: - Hose connection points at storage containers to be inside containment areas. - Drip pans used in areas which are not in containment area where spillage may occur. Q Enclose material handling systems. Q Cover materials entering and leaving areas. Q Regularly sweep area to minimize debris on the ground. Q Provide dust control if necessary. When controlling dust, sweep and/or apply water or materials that will not impact surface or ground water. Q Develop and implement spill prevention, containment, and countermeasure (SPCC) plans. Q Train employees in spill prevention, control, cleanup and proper materials management techniques. Manufacturing Process Components Q Use curbing, dikes and gutters to contain and collect spills. Q Keep spill cleanup materials readily available. Q Clean up spills and leaks immediately. Q Use dry cleanup methods where appropriate. Sweep up absorbents as soon as spilled substances have been absorbed. FJ Develop and implement spill prevention, containment, and countermeasure (SPCC) plans. FJ Train employees in spill prevention, control, and cleanup. Vehicle maintenance Good Housekeeping FJ 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 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. FJ 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 in compliance with RCRA regulations. FJ Store batteries and other significant materials inside. FJ 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. 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 Clean without using liquid cleaners whenever possible. EPA-833-F-06-018 ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and Refining Facilities (continued) Pollutant Source BMPs Vehicle maintenance (continued) Good Housekeeping (continued) Q Do 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 FJ 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. FJ If operations are uncovered, perform them on concrete pad that is impervious and contained. 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, grassed swales, or other diversion measures to ensure that stormwater runoff from other parts of the facility does 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 to ensure BMPs are implemented and maintained. Q Train employees on waste control disposal procedures. Vehicle and equipment 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. Q 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 where making and breaking hose connections. FJ 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. FJ 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. FJ Do not "top off" fuel tanks. FJ Minimize/eliminate run-on into fueling areas with diversion dikes, berms, curbing, surface grading or other equivalent measures. Q Collect stormwater runoff and provide treatment or recycling. Q Provide curbing or posts around fuel pumps to prevent collisions from vehicles. EPA-833-F-06-018 ------- INDUSTRIAL STORMWATER FACT SHEET SERIES Sector C; Chemical and Allied Products Manufacturing and Refining Table 2. BMPS for Potential Pollutant Sources at Chemical and Allied Products Manufacturing and Refining Facilities (continued) Pollutant Source Vehicle and equipment fueling (continued) BMPs FJ Regularly inspect and perform preventive maintenance on potential leaks before they occur. Q Inspect the fueling area for leaks and spills. Q Train personnel on vehicle fueling BM fuel storage tanks to detect 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, Street Transportation Department, Storm Water Management Section. 2004. Prevent Stormwater Contamination Best Management Practices Section C - Chemical and Allied Products Manufacturing. SIC Codes 2812-99, 3952. http://phoenix.gov/STREETS/chemprod.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 EPA-833-F-06-018 ------- |