Industrial Stormwater Fact Sheet Series Sector F: Primary Metals Facilities


INDUSTRIAL  STORMWATER
FACT  SHEET SERIES
                                              Sector F: Primary Metals Facilities
           U.S. EPA Office of Water
           EPA-833-F-06-021
           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 primary metals facilities as described
 by Standard Industrial Classification (SIC) Major Group 33. Facilities and products in this group fall
 under the following categories, all of which require coverage under an industrial stormwater permit:
    4 Steel works, blast furnaces, and rolling and finishing mills, including: steel wiredrawing and
      steel nails and spikes; cold-rolled steel sheet, strip, and bars; and steel pipes and tubes (SIC
      3312-3317)
    4 Iron and steel foundries including: gray and ductile iron, malleable iron, steel investment, and
      steel foundries, not elsewhere classified (SIC 3321-3325)
    4 Primary smelting and refining of nonferrous metals including: primary smelting and refining of
      copper and primary production of aluminum (SIC 3331-3339)
    4 Secondary smelting and refining of nonferrous metals (SIC 3341)
    4 Rolling, drawing, and extruding of nonferrous metals including: rolling, drawing, and
      extruding of copper;  aluminum extruded products; rolling, drawing, and extruding of
      nonferrous metals, except copper and aluminum; and drawing and insulating of nonferrous
      wire (SIC 3351-3357)
    4 Nonferrous foundries (castings) including: aluminum die-castings, nonferrous die-castings,
      except aluminum, aluminum foundries, copper foundries, and nonferrous foundries, except
      copper and aluminum (SIC 3363-3369)
    4 Miscellaneous primary metal products, not elsewhere classified, including metal heat treating
      (SIC 3398 and 3399)

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals 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
  primary metals facilities 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

  Although operations at primary metals facilities may vary considerably, the elements with potential
  impact on stormwater discharges are fairly uniform and consistent. Facilities may include considerable
  areas of raw and waste material storage such as coal, coke, metal, ores, sand, scale, scrap, and slag.
  Processes generally involve furnaces for heating and melting metals or for producing coke, any  of
  which may result in significant particulate emissions. Due to the nature of their operations, some
  facilities will have large areas of exposed soil  and heavy vehicle traffic which can lead to erosion.

  Several major activities and materials present at primary metals facilities that can contribute to
  pollutants  including:
     4  Raw material storage and handling activities

     4  Process activities related to furnace operations, casting rolling, and extruding

     4  Waste material storage, handling, and disposal

     4  Erosion and sediment loss from  unstabilized plant areas

  The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at primary
  metals facilities.
  EPA-833-F-06-021

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
  Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Primary Metals Facilities
Activity
Material storage and
handling
Vehicle and
equipment fueling
and maintenance
Waste materials
(handling, storage,
and disposal)
Furnace operations
and pollution control
equipment
Rolling, casting, and
finishing operations
Plant yards
Illicit discharges
Pollutant Source
Metal product stored outside such as foundry
returns, scrap metal, turnings, fines, ingots, bars,
pigs, wire including materials coated with oil
to prevent corrosion or residual chemicals from
cleaning or treating
Outdoor storage or handling of fluxes
Storage of poles, bins, or material handling of coke
or coal
Storage or handling of casting sand or refractory
(from piles, hoppers, or bins)
Leaks and spills of acids or solvents from drums or
tanks
Vehicle fueling and maintenance or outdoor
storage tanks and drums of gas, diesel, kerosene,
lubricants, solvents
Slag or dross stored or disposed of outside in poles
or drums
Fly ash, particulate emissions, dust collector sludges
and solids, baghouse waste
Storage and disposal of waste sand or refractory
rubble in poles outside
Machining waste - fines, turnings, oil, borings,
gates, sprues, scale
Obsolete equipment stored outside
Landfilling or open pit disposal of wastes on-site
Losses during charging of coke ovens or sintering
plants and from particulate emissions
Fugitive emissions from poorly maintained or
malfunctioning baghouses, scrubbers, electrostatic
precipitators, cyclones
Wastewater treatment operations exposed to
precipitation
Particulate emissions from blast furnaces, electric
arc furnaces, induction furnaces
Exposure of wastewater used for cooling or
descaling related to rolling
Storage of products outside after painting, pickling,
or cleaning operations
Casting cooling or shakeout
Losses of particulate matter from machining
operations (grinding, drilling, boring, cutting)
Areas of the facility with unstabilized soils subject
to erosion and sediment loss
Improper connection of floor, sink, or process
wastewater drains to storm sewers
Pollutant
Residual or protective oil and grease, metals,
total suspended solids (TSS), chemical
oxygen demand
pH (limestone)
(COD)
TSS, pH, metals, phenolic compounds
TSS, pH, toxicity depending on material
Oil and grease, diesel, gasoline, TSS,
antifreeze
Metals, pH
TSS
TSS, metals, misc. "wet" sand additives
TSS, metals, Oil and grease
Oil and grease, metals
Metals, cyanide, cadmium, arsenic,
hexavalent chromium, or halogenated or
chlorinated solvents
TSS, particulates, metals, volatiles, pH
TSS, metals
TSS, metals
TSS, Oil and grease, ammonia-N, cyanide,
phenolic compounds, dissolved iron, toxic
organic pollutants, metals (depending on
operation)
Oil and grease, pH, TSS, metals, COD
pH, solvents, metals
TSS, metals
Metals, TSS, Oil and grease
TSS
Dependent on source
  EPA-833-F-06-021

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals 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 primary metal 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.

  There are six main areas of concern related to primary metals facilities including:
     4  Material storage and handling
     4 Waste material storage, handling, and disposal
     4  Furnace, oven, and related pollution control activities
     4  Rolling, extruding, casting, and finishing operations
     4  Plant yards
     4  Illicit connections

  As there are significant variations site to site in regard to activities and significant materials found at
  primary metals facilities, a variety of options may be applicable to eliminate or minimize the presence
  of pollutants in stormwater discharges from these facilities.

  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.

  Specific good housekeeping practices for primary metals facilities include:
     4  Developing a cleaning/maintenance program for all impervious areas of the facility where
        particulate matter, dust, or debris may accumulate (especially in loading/unloading, storage,
        handling and processing areas)

     4  Paving areas where vehicle traffic or material storage occur but where vegetative or other
        stabilization methods are not practicable.  Paving these areas allow good housekeeping
        measures to be practiced and make spills easier to clean up.
  EPA-833-F-06-021

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
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.

Specific exposure minimization practices for primary metals facilities include:
4 Moving materials inside under roof or cover
4 Establishing scheduled removal of wastes to minimize storage on-site

Due to the large size of many primary metals facilities, source controls may not be practical. In some
cases, it may not be feasible to cover or otherwise protect large areas of material storage or exposed
plant yards. Deposition of particulates from furnace or other process emissions may be relatively
diffuse over a large area of the facility and very difficult to control. In these cases management
practices such as settling basins, retention or detention ponds, or recycle ponds can provide effective
treatment of runoff. For smaller areas, filter fabric, or other types of filters may be appropriate. In
areas where oil and grease is a concern, end-of-pipe treatment may be appropriate and should be
considered.

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 primary metals
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 primary metals
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.

EPA-833-F-06-021 5

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
Table 2: BMPs for Potential Pollutant Sources at Primary Metals Facilities
Pollutant Source
BMP
Metal product storage
(outside) such as
foundry returns, scrap
metal, turnings, fines,
ingots, bars, pigs,
wire
Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters.

Provide temporary cover (e.g., tarps) for the storage area.

Minimize material storage through effective inventory and shipping controls.

Minimize run-on from adjacent properties with diversion dikes, berms, curbing, surface
grading or other equivalent measures.

Stabilize areas with exposed soil with diversion dikes, berms, curbing, concrete pads, etc.
Storage or handling
of fluxes
Store fluxes in covered hoppers, silos, or indoors and protect from wind-blown losses.

Stabilize areas surrounding storage and material handling areas.

Establish schedule for sweeping on a regular basis.
Storage piles, bins, or
material handling of
coke and coal
Q Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters

Q Where possible store coke and coal under cover or indoors and protect from wind-blown
losses.

FJ Practice good stockpiling practices such as: storing materials on concrete or asphalt pads;
surrounding stockpiles with diversion dikes or curbs to limit run-on and to slow runoff.

FJ Trap particulates originating in coke or coal storage or handling areas with filter fabric fences,
gravel outlet protection, sediment traps, vegetated swales, buffer strips of vegetation, catch-
basin filters, retention/detention basins or equivalent.

Q Minimize quantities of coke or coal stored on-site through implementation of effective
inventory control.

Q Practice good housekeeping measures such as frequent removal of dust and debris. Cleanup
methods may include mobile sweepers, scrapers, or scoops.

FJ Train employees in good housekeeping measures.
Storage or handling
of casting sand
Q Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters

FJ Store raw sand in silos, covered hoppers, or indoor whenever possible.

FJ Cover storage pile with tarp or awning.

FJ Practice good stockpiling practices such as: storing materials on concrete or asphalt pads;
surrounding stockpiles with diversion dikes or curbs to limit run-on and to slow runoff.

FJ Install sediment basins, silt fence, vegetated filter strips, or other sediment removal measures
downstream/downslope.

Q Minimize quantities of sand stored onsite through implementation of effective inventory
control.
Vehicle and
equipment fueling
Conduct fueling operations (including the transfer of fuel from tank trucks) on an impervious
or contained pad or under a roof or canopy where possible. Covering should cover extend
beyond spill containment pad to prevent rain from entering.

When fueling in uncovered area, use concrete pad (asphalt is not chemically resistant to the
fuels being handled).

Use drip pans where leaks or spills of fuel can occur and where making and breaking hose
connections.

Use fueling hoses with check valves to prevent hose drainage after filling.

Keep spill cleanup material readily available. Clean up spills and leaks immediately.
EPA-833-F-06-021

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
Table 2: BMPs for Potential Pollutant Sources at Primary Metals Facilities (continued)
Pollutant Source
BMP
Vehicle and
equipment fueling
(continued)
Minimize/eliminate run-on into fueling areas with diversion dikes, berms, curbing, surface
grading or other equivalent measures.
Collect stormwater runoff and provide treatment or recycling.
Use dry cleanup methods for fuel area rather than hosing down the fuel area. Follow
procedures for sweeping up absorbent as soon as spilled substance have been absorbed.
Provide curbing or posts around fuel pumps to prevent collisions from vehicles.
Discourage topping off of fuel tanks.
Regularly inspect and perform preventive maintenance on fuel storage tanks to detect
potential leaks before they occur.
Inspect the fueling area for leaks and spills.
Train personnel on vehicle fueling BMPs.
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 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 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.
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 Clean up leaks, drips, and other spills without using large amounts of water. Use absorbents
for dry cleanup whenever possible.
FJ Prohibit the practice of hosing down an area where the practice would result in the discharge
of pollutants to a stormwater system.
Q Do not pour liquid waste into floor drains, sinks, outdoor storm drain inlets, or other storm
drains or sewer connections.
Q Maintain an organized inventory of materials.
Q Eliminate or reduce the number and amount of hazardous materials and waste by
substituting nonhazardous or less hazardous materials.
FJ Label and track the recycling of waste material (e.g., used oil, spent solvents, batteries).
FJ Store batteries and other significant materials inside.
FJ Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers in
compliance with RCRA regulations.
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.
Q If operations are uncovered, perform them on a concrete pad that is impervious and
contained.
EPA-833-F-06-021

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
Table 2: BMPs for Potential Pollutant Sources at Primary Metals Facilities (continued)
Pollutant Source
BMP
Vehicle maintenance
(continued)
Minimizing Exposure (continued)
Q 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.
Management of Runoff
FJ 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.
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
Q Inspect the maintenance area regularly to ensure BMPs are implemented.
Q Train employees on waste control and disposal procedures.
Vehicle and
equipment storage
and parking
Store vehicles and equipment inside.
Install berms and dikes in storage areas.
Use absorbents and dry cleanup.
Clean pavement surface to remove oil and grease.
Use drip pans under all vehicles and equipment waiting for maintenance.
Cover the storage area with a roof.
Inspect the storage yard for filling drip pans and other problems regularly.
Train employees on procedures for storage and inspection items.
Storage tanks or
drums of gas, diesel,
kerosene, lubricants,
solvents
Store tanks and drums inside 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 precipitation).
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).
Clearly label drum with its contents.
Establish regular inspection of all tanks and drums for leaks, spills, corrosion, damage, etc.
Use dry cleanup methods when possible
Utilize effective inventory control to reduce the volume of chemicals stored on-site.
Prepare and train employees in dealing with spills and leaks properly.
Slag or dross stored or
disposed of in piles or
drums
Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters
Collect waste waters used for granulation of slag and direct to a treatment facility. (These are
not allowed under this section.)
Store slag and dross indoors, under cover, or in sealed containers.
Establish regular disposal of slag or dross to minimize quantities stored and handled on-site.
EPA-833-F-06-021

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
Table 2: BMPs for Potential Pollutant Sources at Primary Metals Facilities (continued)
Pollutant Source
BMP
Slag or dross stored or
disposed of in piles or
drums (continued)
FJ Minimize run-on to slag storage areas with diversion dikes, berms, curbing, or vegetated
swales.

Q Trap particulates originating in slag storage areas with silt fences, gravel outlet protection,
sediment traps, vegetated swales, buffer strips of vegetation, catch-basin filters, and/or
retention/detention basins or equivalent.
Fly ash, particulate
emissions, dust
collector sludges and
solids, baghouse dust
Q Store all dusts and sludges indoors to prevent contact with precipitation or losses due to
wind.

FJ Establish regular disposal schedule to minimize quantities stored and handled on-site.

FJ Inspect all residue hauling vehicles for proper covering over the load, adequate gate sealing,
and overall integrity of the body or container.
Storage and disposal
of waste sand or
refractory rubble in
piles
FJ Move piles under cover or tarps whenever possible.

FJ Establish regular disposal schedule to minimize quantities stored on-site.

FJ Stabilize areas of waste product storage and perform regular sweeping of area.
Scrap processing
activities (shredding
etc.)
Good Housekeeping

FJ Schedule frequent cleaning of accumulated fluids and particulate residue around all scrap
processing equipment.

Q Conduct routine preventive maintenance of equipment per original manufacturer's
equipment (OME) recommendations. Replace worn or malfunctioning parts.

Q Conduct periodic maintenance and clean out of all sumps, oil/water separators, media filters.
Dispose of residual waste materials properly, e.g., according to RCRA.

FJ Provide alarm, pump shutoff, or sufficient containment for hydraulic reservoirs in the event of
a line break.

FJ Provide site gages or overfill protection devices for all liquid and fuel storage reservoirs and
tanks.

FJ Provide containment bins or equivalent for shredded material, especially lightweight materials
such as fluff (preferably at the discharge of these materials from the air classification system).

Minimizing Exposure

Q Where practicable, locate process equipment (e.g., balers, briquetters, small compactors)
under cover.

Q Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
run-on.

FJ Provide cover for hydraulic equipment and combustion engines.

Erosion and Sediment Control

FJ Stabilize high traffic areas around processing equipment (e.g., concrete pads, gravel, and
pavement) where practicable.

Management of Runoff

FJ Site process equipment on elevated concrete pads or provide runoff diversion structures,
berms, containment trenches or surface grading around process equipment. Discharge runoff
from within bermed areas to a sump, oil/water separator, media filter or discharge to sanitary
sewer.

Q Provide dry cleanup materials (e.g., dry-absorbents, drip pans, etc.) to prevent contact of
hydraulic fluids, oils, fuels, etc., with stormwater runoff.
EPA-833-F-06-021

Q Provide training to equipment operators on how to minimize run-on to scrap processing
areas.

FJ Schedule frequent inspections of equipment for signs of spills, leakage of contents, oil, fuel,
hydraulic fluids.

FJ Establish and implement spill prevention and response procedures, including employee
training.
Storage of machining
waste-fines,
turnings, oil, borings,
gates, sprues, scale
FJ Store all wastes indoors or in sealed drums, covered dumpsters, etc.

FJ Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters.

Q Stabilize areas of waste product storage and perform regular sweeping and cleaning of any
residues.

Q Use sand filters or other end-of-pipe treatment as back-up measures for outfalls draining
areas where oil is potentially present.

Q Minimize run-on from adjacent properties and stabilized areas with diversion dikes, berms,
curbing, concrete pads, etc.
Storage of obsolete
equipment
Q Where possible, dispose of unused equipment properly, or move indoors.

Q Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters

FJ Cover obsolete equipment with a tarp, awning or roof.

FJ Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
run-on.

FJ Place equipment on a concrete pad.

FJ Use sand filters or other end-of-pipe treatment as back-up measures for outfalls draining
areas where oil is potentially present.
Material handling
equipment such as
conveyors, trucks,
pallets, hoppers, etc.
FJ Schedule frequent inspections of equipment for signs of spills or leakage.

FJ Inspect for accumulation of particulate matter on and around equipment and clean. Where
possible cover these areas to prevent losses to wind and precipitation.

Q Store pallets, hoppers, etc. which have residual materials on them under cover, with tarps, or
inside.
Charging of coke
ovens or sintering
plants.
Cover any exposed areas related to furnace charging/material handling activities.

Stabilize areas around all material handling areas and establish regular sweeping.

Route runoff from particulate generating operations to sediment traps, vegetated swales,
buffer strips of vegetation, catch-basin filters, retention/detention basins or equivalent.
Blast furnaces,
electric arc furnaces,
induction furnaces
and emissions control
equipment including
baghouses, scrubbers,
electrostatic
precipitators, cyclones
Q Use dust collection systems (e.g., bag houses) to collect airborne particles generated as a
result of handling operations.

FJ Promptly dispose of waste materials from dust collection systems and other operations.

FJ Remove spilled material and settled dust from paved portions of the facility by shoveling and
sweeping on a regular basis

FJ Periodically clean material handling equipment and vehicles to remove accumulated dust and
residue.

FJ Route runoff from particulate generating operations to sediment traps, vegetated swales,
buffer strips of vegetation, catch-basin filters, retention/detention basins or equivalent.
EPA-833-F-06-021
10

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
Table 2: BMPs for Potential Pollutant Sources at Primary Metals Facilities (continued)
Pollutant Source
Blastfurnaces,
electric arc furnaces,
induction furnaces
and emissions control
equipment including
baghouses, scrubbers,
electrostatic
precipitators, cyclones
(continued)
Storage of products
outside after
machining, painting,
pickling, or cleaning
operations
Casting cooling or
shakeout operations
exposed to
precipitation or wind
Landfilling or open
pit disposal of wastes
on-site
BMP
FJ Establish schedule for inspection and maintenance of all pollution control equipment — check
for any particulate deposition from leaks, spills, or improper operation of equipment.
Q Train employees in good housekeeping, inspection and maintenance of emission control
equipment, spill prevention and control.
FJ Confine storage to designated and labeled areas outside of drainage pathways and away
from surface waters
FJ Store all materials inside or under cover whenever possible.
FJ Prevent run-on to product storage areas through curbs, berms, dikes, etc.
FJ Use sand filters or other end-of-pipe treatment as back-up measures for outfalls draining
areas where oil is potentially present.
Q Remove residual chemicals from intermediate or finished products before storage or transport
outside.
Q Stabilize storage areas and establish sweeping schedule.
Q Perform all pouring, cooling, and shakeout operations indoors in areas with roof vents to trap
fugitive particulate emissions.
Q Recycle into process as much casting sand as possible.
Application of fertilizers, herbicides, pesticides
Q Conform to all applicable Federal, State, and local regulations when using these products.
Q Strictly follow recommended application rates and methods (i.e., do not apply in excess of
vegetative requirements).
Q Have materials such as absorbent pads easily accessible to clean up spills.
FJ Provide protected storage areas for pesticides, herbicides, fertilizer, and other significant
materials.
FJ Inspect and maintain all containers used for outdoor chemical materials storage to prevent leaking.
FJ Train employees in proper application procedures and spill response.
Exposure of waste at open face
FJ Minimize the area of exposed open face as much as is practicable.
FJ Divert flows around open face using structural measures such as dikes, berms, swales, and
pipe slope drains.
Q Inspect erosion and sedimentation controls every 7 days.
Q Maintain the integrity and effectiveness of any intermediate or final cover (including repairing
the cover as necessary to minimize the effects of settlement, sinking and erosion).
Uncontrolled leachate
Q Frequently inspect leachate collection system and landfill for leachate leaks.
Q Maintain landfill cover and vegetation.
Q Maintain leachate collection system.
Q Maintain all elements of leachate collection and treatment systems to prevent commingling
of leachate with stormwater.

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
Table 2: BMPs for Potential Pollutant Sources at Primary Metals Facilities (continued)
Pollutant Source
Landfilling or open pit
disposal of wastes
on-site (continued)
Areas of the facility
with unstabilized soils
subject to erosion
Illicit connections to
storm sewers
BMP
Waste tracking
Q Clean wheels and exterior of trucks or other equipment as necessary to minimize waste
tracking (but contain any wash waters [process wastewaters]).
Q Minimize run-on from adjacent properties and stabilized areas to areas with exposed soil with
diversion dikes, berms, vegetated swales, etc.
FJ Stabilize all high traffic areas including all vehicle entrances, exits, loading, unloading, and
vehicle storage areas.
FJ Conduct periodic sweeping of all traffic areas.
FJ Trap sediment originating in unstabilized areas using silt fences, gravel outlet protection,
sediment traps, vegetated swales, buffer strips of vegetation, catch-basin filters, retention/
detention basins or equivalent.
Q Inspect and maintain all BMPs on a regular basis.
Q Provide employee training on proper installation and maintenance of sediment and erosion
controls.
Q Inspect and test all floor, sink, and process wastewater drains for proper connection to
treatment facilities and remove any improper connections to storm sewer or receiving waters.
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 Prevention and Remediation Programs Division. "Pollution Prevention and Best Management
Practices for Metal Finishing Facilities."
www.broward.org/envi ronment/pub_bmp_6.pdf

4 City of Phoenix, Street Transportation Department, Storm Water Management Section. 2004.
Prevent Stormwater Contamination Best Management Practices for: Section E - Glass, Clay, Cement,
Concrete, and Gypsum Product Manufacturers. SIC Codes: 3210-3299.
http://phoenix.gov/STREETS/primet.pdf
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector F: Primary Metals Facilities
U.S. EPA Office of Compliance and Office of Enforcement and Compliance Assurance. 1995.
EPA Office of Compliance Sector Notebook Project: Profile of the Iron and Steel Industry.
EPA-310-R-9-005.
www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/iron.html

U.S. EPA Office of Compliance and Office of Enforcement and Compliance Assurance. 1995. EPA
Office of Compliance Sector Notebook Project: Profile of the Nonferrous Metals Industry.
EPA-310-R-95-010.
www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/nonferrous.html

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/

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

World Bank Group. "Pollution Prevention and Abatement Handbook: Iron and Steel
Manufacturing."
http://ifcln1.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_ironsteel_WB/$FILE/ironsteel_PPAH.pdf

World Bank Group. "Pollution Prevention and Abatement Handbook: Iron and Coke
Manufacturing."
http://ifcln1.ifc.org/ifcext/envi ro.nsf/AttachmentsByTitle/gui_coke_WB/$FILE/coke_PPAH.pdf

World Bank Group. "Pollution Prevention and Abatement Handbook: Iron and Copper Smelting."
http://ifcln1. ifc.org/ifcext/envi ro.nsf/AttachmentsByTitle/gui_copper_WB/$FILE/copper_PPAH.pdf

World Bank Group. "Pollution Prevention and Abatement Handbook: Lead and Zinc Smelting."
http://ifcln1. ifc.org/ifcext/envi ro.nsf/AttachmentsByTitle/gui_leadzinc_WB/$FILE/leadzinc_PPAH.pdf

World Bank Group. "Pollution Prevention and Abatement Handbook: Nickel Smelting and Refining."
http://ifcln1.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_nickel_WB/$FILE/nickel_PPAH.pdf
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