INDUSTRIAL STORMWATER
FACT SHEET SERIES
Sector L: Landfills and Land
Application Sites
U.S. EPA Office of Water
EPA-833-F-06-027
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 landfills and land application sites.
Facilities and products in this group fall under the following categories, all of which require coverage
under an industrial stormwater permit:
4 Landfills
4 Land application sites
4 Open dumps that receive or have received industrial waste
These include sites subject to regulation under Subtitle D of the Resource Conservation and Recovery
Act (RCRA) including municipal solid waste landfills (MSWLFs), industrial solid nonhazardous waste
landfills, and industrial waste land application sites.
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."
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
What pollutants are associated with activities at my facility?
Pollutants conveyed in stormwater discharges from landfills and land application sites 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
Factors such as these will interact to influence the quantity and quality of stormwater runoff. At
landfill and land application sites, runoff carrying suspended sediments and the commingling of
runoff with uncontrolled leachate are the two primary sources of pollutants in stormwater. In
addition, sources of pollutants other than stormwater, such as illicit connections, spills, and other
improperly dumped materials, may increase the pollutant loading discharged into receiving waters.
Other potential sources of pollutants at landfills and land application sites include those from
ancillary areas and areas which are not directly associated with landfill or land application activities
(e.g., vehicle maintenance, truck washing). These activities may be subject to permit requirements
separate from those required of landfills and land application sites.
Municipal Solid Waste Landfills (MSWLFs). The wastes disposed of in MSWLFs are variable and
may include household waste (including household hazardous waste which is excluded from RCRA
hazardous waste regulation), nonhazardous incinerator ashes, commercial wastes, yard wastes, tires,
white goods, construction wastes, municipal and industrial sludges, asbestos, and other industrial
wastes. Industrial process wastes represent a small percent of the total wastestream (although
most MSWLFs currently or have previously accepted industrial wastes and are therefore subject to
stormwater permitting requirements). MSWLFs that operated prior to the implementation of RCRA
hazardous waste management requirements in 1980 may have received wastes that would have been
classified as hazardous wastes under current RCRA requirements.
Industrial landfills, most of which are privately owned, only receive wastes from industrial facilities
such as factories, processing plants, and manufacturing sites. These facilities may also receive
hazardous wastes from very small quantity hazardous waste generators. Included in these waste
streams are some PCB contaminated wastes. The Toxic Substances Control Act PCB disposal regulations
allow limited categories of PCB materials to be disposed of in RCRA Subtitle D landfills. Because
wastes generated by industrial facilities vary considerably, both between and within industries,
the wastes disposed of at industrial landfills can be highly variable. For example, the industrial
nonhazardous waste category includes wastes from the pulp and paper industry, the organic chemical
industry, the textile manufacturing industry, and a variety of other industries. Consequently, these
waste streams may vary in chemical composition and/or physical form.
Land application sites receive wastes (primarily wastewaters and sludges) from facilities in virtually ev-
ery major industrial category. Similar to landfills, the variability in types of waste that are land applied
precludes any general characterization of the materials that may be exposed to stormwater. Typically,
individual land applications will only dispose of wastes with specific characteristics. However, the crite-
ria for selection are site-specific depending on type of process used and the soil characteristics. Waste
application techniques are dependent on waste characteristics, cover crop and soil characteristics.
Stormwater discharges from landfills and land application sites often contain high TSS levels because
of the extensive land disturbance activities associated with landfill operations. Suspended solids can
adversely affect fisheries by covering the bottom of a stream or lake with a blanket of material that
EPA-833-F-06-027 2
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
may destroy spawning grounds or the bottom fauna upon which fish feed. In addition, while they
remain in suspension, suspended solids can increase turbidity, reduce light penetration, and impair
the photosynthetic activity of aquatic plants.
The activities, pollutant sources, and associated pollutants detailed in Table 1A and 1B are commonly
found at landfills and land application sites. It is important to note that the occurrence and levels of
pollutants other than TSS in stormwater discharges are dependent on the types of wastes deposited/ap-
plied and facility design and operation (including use of stormwater management/treatment practices).
Table 1A. Common Activities, Pollutant Sources, and Associated Pollutants at Landfills
Activity
Cover crop management
Outdoor chemical storage
Waste transportation
Leachate collection
Landfill operations
Exposed soil from excavating
cells/trenches
Exposed stockpiles of cover
material
Inactive cells with final cover but
not finally stabilized
Daily or intermediate cover
placed on cells or trenches
Haul roads (including vehicle
tracking of sedimentation)
Vehicle/equipment maintenance
Pollutant Source
Applied chemicals
Exposure of chemical material storage
areas to precipitation
Waste tracking on-site and haul road,
solids transport on wheels and exterior of
trucks or other equipment
Uncontrolled leachate (commingling of
leachate with runoff or run-on)
Exposure of waste at open face
Erosion
Fueling activities
Parts cleaning
Waste disposal of oily rags, oil and gas
filters, batteries, coolants, degreasers
Fluid replacement including hydraulic
fluid, oil, transmission fluid, radiator
fluids, and grease
Pollutant
Fertilizers, pesticides, and herbicides
Various chemicals stored
TSS, total dissolved solids (IDS), turbidity,
floatable
Iron, TSS, biochemical oxygen demand
(BOD), ammonia, alpha terpineol, benzole
acid, p-Cresol, phenol, zinc, pH
BOD, TSS, TDS, turbidity
TSS, TDS, turbidity
Diesel fuel, gasoline, oil
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
Table IB. Common Activities, Pollutant Sources, and Associated Pollutants at Land Application Sites
Activity
Cover crop management
Outdoor chemical storage
Waste transportation
Pollutant Source
Applied chemicals
Exposure of chemical material storage
areas to precipitation
Waste tracking on-site and haul road,
solids transport on wheels and exterior of
trucks or other equipment
Pollutant
Fertilizers, pesticides, and herbicides
Various chemicals stored
TSS, total dissolved solids (TDS), turbidity,
floatable
EPA-833-F-06-027
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
Table 1B. Common Activities, Pollutant Sources, and Associated Pollutants at Land Application Sites
(continued)
Activity
Vehicle/equipment maintenance
Pollutant Source
Fueling activities
Parts cleaning
Waste disposal of oily rags, oil and gas
filters, batteries, coolants, degreasers
Fluid replacement including hydraulic
fluid, oil, transmission fluid, radiator
fluids, and grease
Pollutant
Diesel fuel, gasoline, oil
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
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 landfills and land application sites. 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. Preven-
tion BMPs can include regular cleanup, collection and containment of debris in storage areas, and
other housekeeping practices, spill control, diversions, 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, sedimen-
tation 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. Good housekeeping practices must include a schedule for regular
pickup and disposal of waste materials such as oils and fluids 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 landfills and land application sites include providing
protected storage areas for pesticides, herbicides, fertilizers, and other significant materials, vehicle
maintenance areas, and recycled materials areas if present. Additionally, a preventative maintenance
program should be developed that addresses:
4 The maintenance of containers used for outdoor chemical/significant materials/recyclables
storage to prevent leaking
4 All elements of leachate collection and treatment systems to prevent exposure of leachate to
stormwater
4 The integrity and effectiveness of any intermediate or final cover
EPA-833-F-06-027
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
Minimizing Exposure
Where feasible, minimizing exposure of potential pollutant sources to precipitation is an important
control option. For landfills and land application sites, this measure is again most applicable to areas
other than the active disposal/application sited although minimizing disturbance in these areas is
important as well. 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).
Erosion and Sediment Control
BMPs must be selected and implemented to limit erosion on areas of your site that are likely to
experience erosion, such as access roads, application areas, and active and recently reclaimed landfill
areas. Erosion control BMPs such as seeding and mulching prevent soil from becoming dislodged and
should be considered first along with diverting uncontaminated surface flows away from disturbed
areas. 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.
Landfill construction creates constant changes in the contours of the facility resulting in changing
patterns of stormwater run-on and runoff. Controlling erosion of landfill slopes is among the
primary concerns of the landfill operator. Practices generally include a combination of temporary
controls (straw bales, silt fences, etc.) in active disposal areas and permanent controls (recontouring,
revegetation, etc.) in areas where waste disposal has been completed.
Specific sediment and erosion practices for landfills and land application sites include providing
temporary stabilization and placing geotextiles on the inactive portions of stockpiles. This should be
done for:
4 Materials stockpiled daily for immediate and final cover
4 Inactive areas of the landfill or open dump
4 Any landfill or open dump area with final covers but where vegetation has yet to establish
itself
4 Where waste application has been completed at land application sites but final vegetation has
not yet been established
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.
EPA-833-F-06-027
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
Implement BMPs, such as those listed below in Table 2 for the control of pollutants at landfills and
land application sites, 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 landfills and
land application sites; 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 2A. BMPs for Potential Pollutant Sources at Landfills and Land Application Sites
Pollutant Source
BMPs
Application of
fertilizers, pesticides,
and herbicides
FJ Observe 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.
Q Inspect and maintain all containers used to prevent leaking.
Q Implement employee training program for proper application and spill prevention.
Q Store drums and containers indoors when possible.
Chemical material
storage areas
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 Locate material 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.
FJ Clearly label drums with their contents.
FJ Maintain an inventory of fluids to identify leakage.
FJ Properly dispose of chemicals that are no longer in use.
FJ 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.
Q Have materials such as absorbent pads easily accessible to clean up spills.
Q Develop and implement spill plans or spill prevention, containment, and countermeasure
(SPCC) plans, if required for your facility.
FJ Train employees in spill prevention and control and proper materials management.
Exposure of waste at
open face (Landfills
only)
Minimize the area of exposed open face as much as is practicable.
Divert flows around open face using structural measures such as dikes, berms, swales, or
pipe slope drains.
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).
FJ
FJ
FJ Regularly inspect erosion and sediment controls.
EPA-833-F-06-027
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
Table 2A. BMPs for Potential Pollutant Sources at Landfills and Land Application Sites (continued)
Pollutant Source
BMPs
Waste tracking and
solids transport on
wheels and exterior
of trucks or other
equipment from
on-site/offsite or haul
roads.
FJ Clean wheels and exterior of trucks or other equipment as necessary to minimize waste
tracking (but contain any wash waters).
Q Establish procedures such as rumble strips and gravel apron to minimize offsite tracking
Uncontrolled leachate
Divert flows around site using structural measures such as dikes, berms, or swales.
Frequently inspect leachate collection system and landfill for leachate leaks.
Maintain landfill cover and vegetation.
Maintain leachate collection system.
Maintain all elements of leachate collection and treatment systems to prevent commingling
of leachate with stormwater.
Erosion from:
Excavating cells/
trenches
Stockpiles of cover
material
Inactive cells with final
cover but not finally
stabilized
Daily or intermediate
cover placed on cells
or trenches
Haul roads
Q Implement structural controls such as dikes, swales, silt fences, filter berms, sediment traps
and ponds, outlet protection, pipe slope drains, check dams, and terraces to convey runoff,
to divert stormwater flows away from areas susceptible to erosion, and to prevent sediments
from entering water bodies.
FJ Confine stockpiling to areas outside of drainage pathways and away from surface waters
FJ Stabilize soils with temporary seeding, mulching, and placing geotextiles on the inactive
portions of stockpiles
Q Leave vegetative filter strips along streams.
Q Keep as much vegetation as possible when building roads and seed as necessary and
appropriate.
Q Construct vegetated swales along road.
Q Stabilize haul roads and entrances to landfill with gravel or stone.
Q Clean wheels and body of trucks or other equipment as necessary to minimize sediment
tracking (but contain any wash waters).
FJ Frequently inspect all stabilization and structural erosion control measures and perform all
necessary maintenance and repairs.
Vehicle/equipment
fueling
Stationary fueling areas
Q 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 a 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.
FJ Keep spill cleanup materials readily available. Clean up spills and leaks immediately.
FJ Minimize/eliminate run-on onto fueling areas with diversion dikes, berms, curbing, surface
grading or other equivalent measures.
Q Collect stormwater runoff and provide treatment or recycling.
EPA-833-F-06-027
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
Table 2A. BMPs for Potential Pollutant Sources at Landfills and Land Application Sites (continued)
Pollutant Source
BMPs
Vehicle/equipment
fueling (continued)
Stationary fueling areas (continued)
Q Use dry cleanup methods for fuel area rather than hosing the fuel area down. Follow
procedures for sweeping up absorbents as soon as spilled substances have been absorbed.
FJ Regularly inspect and perform preventive maintenance on storage tanks to detect potential
leaks before they occur.
FJ Inspect the fueling area for leaks and spills.
FJ Provide curbing or posts around fuel pumps to prevent collisions during vehicle ingress and
egress.
FJ Discourage "topping off" of fuel tanks.
Mobile fueling areas
Q Use drip pan under the transfer hose.
Q Use fueling hoses with check valves to prevent hose drainage after filling.
Q Ensure the fueling vehicle is equipped with a manual shutoff valve.
Q Do not allow topping off of the fuel in the receiving equipment.
Q Train personnel on fueling BMPs.
Vehicle/equipment
maintenance
Good Housekeeping
Q Eliminate floor drains that are connected to the storm or sanitary sewer; if necessary, install
a sump that is pumped regularly. Collected wastes should be properly treated or disposed of
by a licensed waste hauler.
FJ Use drip plans, 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 Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers properly.
FJ Store batteries and other significant materials inside.
Q Label and track the recycling of waste material (e.g., used oil, spent solvents, batteries).
Q Maintain an organized inventory of materials.
Q Eliminate or reduce the number of hazardous materials used and amount of waste by
substituting nonhazardous or less hazardous materials.
Q Clean up leaks, drips, and other spills without using large amounts of water.
Q Prohibit the practice of hosing down an area where the practice would result in the exposure
of pollutants to stormwater.
Q Clean without using liquid cleaners whenever possible.
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 down 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.
EPA-833-F-06-027
-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector L: Landfills and Land Application Sites
Table 2A. BMPs for Potential Pollutant Sources at Landfills and Land Application Sites (continued)
Pollutant Source
BMPs
Vehicle/equipment
maintenance
(continued)
Minimizing Exposure (continued)
Q If operations are uncovered, perform them on a concrete pad that is impervious and
contained.
Q Park vehicles and equipment indoors or under a roof whenever possible where proper
control of oil leaks/spills is maintained and exposure to stormwater is prevented.
Q Watch vehicles closely for leaks and use pans to collect fluid when leaks occur.
Management of Runoff
Q Use berms, curbs, or other diversion measures to ensure that stormwater runoff from other
parts of the facility does not flow over the maintenance area.
Q Collect the stormwater runoff from the cleaning area and provide treatment or recycle the
runoff. 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 for proper implementation of control measures.
FJ Train employees on proper waste control and disposal procedures.
What if activities and materials at my facility are not exposed to
precipitation?
The industrial stormwater program requires permit coverage for a number of specified types of
industrial activities. However, when a facility is able to prevent the exposure of ALL relevant activities
and materials to precipitation, it may be eligible to claim no exposure and qualify for a waiver from
permit coverage.
If you are regulated under the industrial permitting program, you must either obtain permit coverage
or submit a no exposure certification form, if available. Check with your permitting authority for
additional information as not every permitting authority program provides no exposure exemptions.
Where do I get more information?
For additional information on the industrial stormwater program see
www.epa.gov/npdes/stormwater/msgp.
A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
be found at www.epa.gov/npdes/stormwatercontacts.
References
Information contained in this Fact Sheet was compiled from EPA's past and current Multi-Sector
General Permits and from the following sources:
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-06-027
------- |