INDUSTRIAL STORMWATER
FACT SHEET SERIES
Sector K: Hazardous Waste Treatment,
Storage, or Disposal Facilities
U.S. EPA Office of Water
EPA-833-F-06-026
December 2006
What is the NPDES stormwater 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 hazardous waste treatment, storage,
or disposal facilities (TSDF), including those that are operating under interim status or a permit under
Subtitle C of the Resource Conservation and Recovery Act (RCRA). Some industrial facilities that
generate hazardous waste have on-site capacity to store, treat, and even dispose of their waste. Many
hazardous waste generators, however, send their waste offsite to a TSDF.
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
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 storage, treatment
and disposal of hazardous waste will vary given the diversity and quantity of hazardous waste
handled at TSDFs. There are a number of factors that influence to what extent industrial activities and
significant materials can affect water quality. TSDFs regulated under RCRA Subtitle C, however, are
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
required to control much of their stormwater runoff through secondary containment (e.g., secondary
containment for tank systems). When a spill of a listed hazardous waste occurs, for example, the
spilled material and any stormwater that comes into contact with the material is a hazardous waste
under RCRA and must be cleaned up and managed in accordance with all applicable regulations.
In addition to the types of hazardous materials handled and the procedures for controlling runoff at
a particular TSDF, 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 Extent of impervious surfaces (i.e., concrete or asphalt)
4 Type of ground cover (e.g., vegetation, crushed stone, or dirt)
4 Outdoor activities (e.g., only storage, or storage plus treatment and disposal)
4 Size of the operation (e.g., volume of wastes handled)
4 Type, duration, and intensity of precipitation events
The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at hazardous
waste treatment, storage, or disposal facilities.
Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Hazardous Waste
Treatment, Storage, or Disposal Facilities
Activity
Bulk Liquid/Solid
Transfer
Hazardous Material
Storage
Waste Handling &
Disposal
Vehicle and
equipment fueling
and maintenance
Building and Grounds
Maintenance
Illicit discharges
Pollutant Source
Spills during transfer of chemicals between above
ground storage tank and drums or other containers.
Spills or leaks of hazardous materials used for
operations
Outdoor storage or handling of chemicals
Unloading of chemicals and other hazardous materials
Leaks and spills of acids or solvents from drums or
tanks
Spills c
Residual hazardous material due to poor
Chemical mixing
Vehicle fueling and maintenance activities, outdoor
storage tanks, and drums of gas, diesel, kerosene,
lubricants, solvents
Storage of pesticides and other chemicals
Application of chemicals
Improper connection of floor, sink, or process
wastewater drains to storm sewers
Pollutant
Acids, solvents, ammonia, hydroxides,
Total suspended solids (TSS), chemical
oxygen demand (COD) pH, biological-
oxygen demand (BOD)
Organic and inorganic compounds.
Organic and inorganic compounds
Mixed waste which can limit recyclables
Oil and grease (O&G), diesel, gasoline,
TSS, antifreeze
Pesticides, oxygen-demanding
substances, sediments, nutrients,
organics, and toxicants
Dependent on source
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 hazardous waste treatment, storage, or disposal facilities. You will likely
need to implement a combination or suite of BMPs to address stormwater runoff at your facility.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
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.
Facilities in this industrial sector must already be in compliance with the standards for operating a
hazardous waste treatment, storage, or disposal facility as established under RCRA. Due to previously
imposed requirements on hazardous waste treatment, storage, or disposal facilities, stormwater BMPs
are already employed at most TSDFs. These BMPs include:
4 Roofs or other forms of permanent cover for storage areas.
4 Secondary containment, capable of preventing stormwater run-on from entering the system or
with the capacity to contain the volume of the tank plus precipitation from a 25-year, 24-hour
rainfall event, for tank systems.
4 Detention/retention ponds and filtering devices.
4 Daily and weekly inspections of tank systems and containers, respectively. These inspections,
which should already take place, will be incorporated into facility stormwater pollution
prevention plans.
4 Employee training already should be occurring, will need to be expanded as necessary to
include issues concerning stormwater management.
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
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
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
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 hazardous
waste treatment, storage, or disposal 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 hazardous waste treatment, storage, or disposal 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.
One activity that is not included in the RCRA requirements is loading and unloading operations and
the potential for spills during this process. Table 2A identifies examples of effective BMPs for the
control of pollutants associated with unloading and loading activities.
Table 2: BMPs for Potential Pollutant Sources at Hazardous Waste Treatment, Storage, or Disposal
Facilities
Pollutant Source
BMPs
Hazardous Material
Storage
Confine storage of hazardous materials to designated areas.
Storage of hazardous materials should be indoors or in a covered area.
Store hazardous materials according to the manufacturer by installing concrete or non-
absorbing berms around each specific hazardous material to avoid mixing wastes.
Ensure sufficient aisle space to ease inspections and handling.
Store hazardous materials away from high-traffic areas.
Implement inspection schedule for storage areas to detect problems before they occur.
Inspect all containers prior to placing in hazardous materials storage areas.
Store drums of hazardous material on spill pallets.
ASTs of hazardous materials should be stored within secondary containment equipped with self
bailers, shutoff valve, and sumps.
Use dry cleanup methods instead of washing the areas down.
Train employees on proper storage techniques.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
Table 2: BMPs for Potential Pollutant Sources at Hazardous Waste Treatment, Storage, or Disposal
Facilities (continued)
Pollutant Source
BMPs
Bulk liquid/solid
transfer areas
FJ Confine transferring activities to a designated area.
FJ Performing transfer activities indoors or in a covered area.
FJ Install an impervious or concrete pad under area for bulk transfer activities with area sloped
toward sump or detention pond.
Q During transfer activities of hazardous materials always close drains using drain seals, drain
guards, drain plugs, or a shutoff valve.
Q After drum use, washout should drain directly into a clarifier.
Q Place track pans or popup pool containers under tankers before transfer activities occur to
prevent uncontained spills.
FJ Avoid transferring bulks materials in the rain.
FJ Inspect the transfer areas to detect problems before they occur.
FJ Inspect all containers prior to transferring activities of hazardous materials.
FJ Use dry cleanup methods instead of washing the areas down.
FJ Train employees on proper bulk transfer techniques.
Bulk storage areas
FJ Confine bulk storage to a designated area.
FJ Store hazardous bulk materials indoors or in a covered area.
FJ Cover bulk materials with permanent cover (e.g., roofs) or temporary cover (e.g., tarps).
FJ Implement schedule to conduct inspections of the bulk storage areas to detect problems before
they occur.
FJ Inspect all containers prior to storage of outside bulk materials.
FJ Store outside bulk materials within secondary containment either using concrete berms or
other non absorbing materials.
Q Berm, curb or dike outside bulk storage areas.
Q Use dry cleanup methods instead of washing the areas down.
Q Train employees on proper outside bulk storage of hazardous material techniques.
Vehicle and
equipment fueling
FJ 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 extend beyond
spill containment pad to prevent rain from entering.
Q When fueling in uncovered area, use concrete pad (asphalt is not chemically resistant to the
fuels being handled).
FJ 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 Use spill and overflow protection devices including gutter guards, basin guard, and curb
guards.
FJ Keep spill cleanup material readily available. Clean up spills and leaks immediately.
FJ Minimize/eliminate run-on into fueling area with diversion dikes, berms, curbing, surface
grading or other equivalent measures.
Q Direct stormwater from fueling area into detention pond or filtering system.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
Table 2: BMPs for Potential Pollutant Sources at Hazardous Waste Treatment, Storage, or Disposal
Facilities (continued)
Pollutant Source
BMPs
Vehicle and
equipment fueling
(continued)
FJ Use dry cleanup methods for fuel area rather than hosing down the fuel area. Implement
procedures for sweeping up absorbents as soon as spilled substance have been absorbed.
Q Fuel pumps should be protected from collisions by installing curbing or posts.
Q Discourage "topping off" of fuel tanks.
Q Implement inspection schedule of preventive maintenance on fuel storage tanks to detect
potential leaks before they occur.
Q Train employees as well as any outside contractor, the proper fueling techniques.
Vehicle maintenance
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 Implement preventive measures to avoid spills and drips.
FJ Conduct all cleaning at a centralized station so the solvents stay in one area.
FJ 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.
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 Clean up leaks, drips, and other spills without using large amounts of water. Use absorbents
for dry cleanup whenever possible.
Q Use dry cleanup methods instead of washing the areas down.
Q Prohibit the practice of hosing down an area where the practice would result in the discharge
of pollutants to a stormwater system.
FJ Do not pour liquid waste into floor drains, sinks, outdoor storm drain inlets, or other storm
drains or sewer connections.
FJ Maintain inventory of materials.
Q Eliminate or reduce quantity of hazardous materials and waste by substituting non- hazardous
or less hazardous materials.
Q Label and track the recycling of waste material (e.g., used oil, spent solvents, batteries).
FJ Store batteries and other significant materials inside or if stored outdoors, cover with tarps and
stored on spill pallets.
FJ Dispose of oily rags, oil filters, air filters, batteries, spent coolant, and degreasers in compliance
with RCRA regulations.
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.
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.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
Table 2: BMPs for Potential Pollutant Sources at Hazardous Waste Treatment, Storage, or Disposal
Facilities (continued)
Pollutant Source
BMPs
Vehicle maintenance
(continued)
Management of Runoff
Q Use berms, curbs, grassed swales or other diversion measures to ensure that stormwater runoff
from other parts of the facility do 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 BMPs are implemented.
Q Train employees on waste control and disposal procedures.
Vehicle and
equipment storage
and parking
Store vehicles and equipment indoors.
Install berms and dikes in storage areas.
Use absorbents and dry cleanup methods.
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.
Table 2A: BMPs for Potential Pollutant Sources Associated with Unloading and Loading at
Hazardous Waste Treatment, Storage, or Disposal Facilities
Pollutant Source
BMPs
Outdoor unloading
and loading
FJ Confine loading/unloading activities to a designated area.
FJ Performing loading/unloading activities indoors or in a covered area.
FJ Cover loading/unloading area with permanent cover (e.g., roofs) or temporary cover (e.g.
tarps).
Q Close storm drains during loading/unloading activities in surrounding areas.
Q Avoid loading/unloading materials in the rain.
Q Inspect the unloading/loading areas to detect problems before they occur.
Q Inspect all containers prior to loading/unloading of any raw or spent materials.
Q Berm, curb or dike loading/unloading areas.
Q Use dry cleanup methods instead of washing the areas down.
Q Train employees on proper loading/unloading techniques.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector K: Hazardous Waste Treatment, Storage, or Disposal Facilities
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 for: Section K - Hazardous Waste
Facilities (Typically RCRA subtitled) SIC Code - NA/NAICS Code - 562211. SIC Codes: 3210-3299."
http://phoenix.gov/STREETS/hzwst504.pdf
4 Naval Facilities Engineering Service Center. "Storm Water Best Management Practices (BMP)
Decision Support Tool: Storm Water Pollution Prevention Options by Category. Category:
Hazardous Waste Storage, Treatment, and Recycling."
http://205.153.241.230/stormwaterbmp/cgi-bin/P2Cat.cfm?Cat=Hazardous%20Waste%20Storage,
%20Treatment%20and%20Recycling
4 Orange County, California; Watershed & Coastal Resources Division.
www.ocwatersheds.com/StormWater/documents_bmp_existing_development.asp#ind
4 U.S. EPA, September 1992. Stormwater Management for Industrial Activities: Developing Pollution
Prevention Plans and Best Management Practices. EPA 832-R-92-006.
www.epa.gov/npdes/stormwater
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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