Industrial Stormwater Fact Sheet Series Sector O: Steam Electric Power Generating Facilities, Including Coal Handling Areas


INDUSTRIAL  STORMWATER
FACT SHEET  SERIES
           U.S. EPA Office of Water
           EPA-833-F-06-030
           December 2006
     Sector O: Steam Electric Power
Generating Faculties, Including Coal
                     Handling Areas
 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 steam electric power generating
 facilities including:
    4 Steam electric power generation using coal, natural gas, oil, nuclear energy, etc. to produce a
      stream source, including coal handling areas
    4 Coal pile runoff
    4 Dual fuel co-generation facilities


 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."

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector O: Steam Electric Power Generating Facilities,
Including Coal Handling Areas


  What pollutants are associated with activities at my facility?
  Pollutants conveyed in stormwater discharges from steam electric generating facilities, including
  coal handling areas, 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

  Pollutants may be present in stormwater as a result of outdoor activities associated with steam electric
  power generating facilities such as: material handling and transport operations; waste disposal; and
  deposition of airborne particulate matter. In addition, sources of pollutants other than stormwater,
  such as illicit connections, spills, and other improperly dumped materials, may increase the pollutant
  loadings discharged receiving waters.

  Although there are many activities that occur at a facility, this fact sheet only discusses those activities
  that occur outdoors and where activities or materials may be exposed to precipitation. The primary
  and largest potential source of stormwater  pollutants from fossil-fueled steam electric generating
  facilities is ash refuse piles. Vanadium, sodium, sulfur, and nickel are all common elements found in oil
  ash. Silica, alumina, ferric oxide, calcium oxide, magnesium oxide, and sodium and potassium oxides
  are all common.

  The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at steam
  electric generating facilities, including coal  handling areas.
  Table 1.  Common Activities, Pollutant Sources, and Associated Pollutants at Steam Electric
  Generating Facilities, including Coal Handling Areas
Activity
Above ground liquid
storage tanks
Vehicle and
equipment
maintenance
Pollutant Source
External corrosion and structural failure
Installation problems
Spills due to operator error
Failure of piping systems
Leaks or spills during pumping of liquids from barges,
trucks, rail cars to a storage facility
Parts cleaning
Spills of oil, degreasers, hydraulic fluids, transmission
fluid, radiator fluids
Fluids replacement
Pollutant
Fuel, oil and grease (O&G), heavy
metals, ammonia, chloride, sodium
hydroxide, and other materials being
stored
Oil and grease (O&G), heavy metals,
chlorinated solvents, acid/alkaline
wastes, ethylene glycol
Oil and grease (O&G), arsenic, heavy
metals, organics, chlorinated solvents,
ethylene glycol
Oil and grease (O&G), arsenic, heavy
metals, organics, fuel
  EPA-833-F-06-030

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector O: Steam Electric Power Generating Facilities,
Including Coal Handling Areas
  Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Steam Electric
  Generating Facilities, including Coal Handling Areas (continued)
Activity
Fueling operations
Coal handling areas
Ash handling areas,
ash landfills
Scrapyards, refuse
sites
Pollutant Source
Spills and leaks during fuel delivery
Spills caused by "topping off" fuel tanks
Leaking storage tanks
Allowing rainfall on the fuel area or stormwater to run
onto the fuel area
Coal storage
Fugitive dust emissions from coal handing
Spills during delivery
Offsite tracking of coal dust
Spills during transfer of ash to landfills
Offsite tracking of ash
Discarded material
Pollutant
Fuel, oil and grease (O&G), heavy
metals
Suspended solids, copper, iron,
aluminum, nickel, and trace metals
Suspended solids, chromium, copper,
iron, zinc, oil and grease, aluminum
Fuel, oil and grease (O&G), heavy
metals
  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 steam electric generating facilities, including coal handling areas. You will
  likely need to implement a combination or suite of BMPs to address stormwater runoff at your facility.
  Your first consideration should be for pollution prevention BMPs, which are designed to prevent
  or minimize pollutants from entering stormwater runoff and/or reduce the volume of stormwater
  requiring management. Prevention BMPs can include regular cleanup, collection and containment of
  debris in storage areas, and other housekeeping practices, spill control, and employee training. It may
  also be necessary to implement treatment BMPs, which are engineered structures intended to treat
  stormwater runoff and/or mitigate the effects of increased stormwater runoff peak rate, volume, and
  velocity. Treatment BMPs are generally more expensive to install and maintain and include oil-water
  separators, wet ponds, and  proprietary filter devices.

  BMPs must be selected and  implemented to address the following:

  Good Housekeeping Practices
  Good housekeeping  is a practical, cost-effective way to maintain a clean and orderly facility to
  prevent potential pollution sources from coming into contact with stormwater. It includes establishing
  protocols to reduce the possibility of mishandling materials or equipment and training employees
  in good housekeeping techniques. Common areas where good housekeeping practices should be
  followed include trash containers and adjacent areas, material storage areas, vehicle and equipment
  maintenance areas, and loading docks. Good housekeeping practices must include a schedule for
  regular pickup and disposal of garbage and waste materials and routine inspections of drums, tanks,
  and containers for leaks and structural conditions. Practices also include containing and covering
  garbage, waste materials, and debris. Involving employees in  routine monitoring of housekeeping
  practices has proven  to be an  effective means of ensuring the continued implementation of these
  measures.

  Specific good housekeeping practices for steam electric power generating facilities include:
     4 Spill and overflow protection under chemical connectors to contain spillage at liquid storage
       tanks
  EPA-833-F-06-030

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector O: Steam Electric Power Generating Facilities,
Including Coal Handling Areas

4 Dry cleanup methods at liquid storage tank areas
4 Coal pile management
4 Load covers on residue hauling vehicles and ensure gates on trucks are sealed and the truck
body is in good condition
4 Containment curbs around loading/unloading areas or tanks
4 Techniques to reduce ash residue which may be tracked on to access roads traveled by residue
trucks or residue handling vehicles.
4 Techniques to reduce ash residue on exit roads leading into and out of residue handling areas

Minimizing Exposure
Where feasible, minimizing exposure of potential pollutant sources to precipitation is an important
control option. Minimizing exposure prevents pollutants, including debris, from coming into contact
with precipitation and can reduce the need for BMPs to treat contaminated stormwater runoff. It can
also prevent debris from being picked up by stormwater and carried into drains and surface waters.
Examples of BMPs for exposure minimization include covering materials or activities with temporary
structures (e.g., tarps) when wet weather is expected or moving materials or activities to existing
or new permanent structures (e.g., buildings, silos, sheds). Even the simple practice of keeping a
dumpster lid closed can be a very effective pollution prevention measure.

Erosion and Sediment Control
BMPs must be selected and implemented to limit erosion on areas of your site that, due to
topography, activities, soils, cover, materials, or other factors are likely to experience erosion. Erosion
control BMPs such as seeding, mulching, and sodding prevent soil from becoming dislodged and
should be 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 team electric
generating facilities, including coal handling areas, 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 team electric generating facilities, including coal handling areas;
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-06-030

FJ Divert stormwater around storage areas with vegetated swales, and/or berms.

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

Q Use properly designed basins for collection, containment, and recycling of pile spraying
materials.

Q Use control measures such as berms, silt fences or waddles to control sediment from leaving
storage area.

FJ Train employees in good housekeeping measures
Fugitive dust
emissions
Establish procedures to minimize offsite tracking of coal dust.

Use specially designed tires.

Wash vehicles before they leave the site in a designated area where wash water can be
controlled.
Delivery vehicles
FJ Develop procedure for the inspection of all vehicles arriving on the plant site and ensure overall
integrity of the body or container.

FJ Control leakage or spillage from vehicles or containers and ensure that proper protective
measuresent.
Fuel oil unloading
areas
FJ Confine loading/unloading activities to designated areas outside drainage pathways and away
from surface waters.

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

Q Use containment curbs in unloading areas.

Q Use spill and overflow protection (drip pans, drip diapers, etc.) beneath fuel oil connectors.

Q For rail transfer, a drip pan shall be installed within the rails to collect spillage from the tank.

Q Develop and implement spill prevention, containment, and countermeasure (SPCC) plans.

Q Train employees in spill prevention, control and cleanup.

Q Personnel familiar with spill prevention and response procedures should be present during
unloading to ensure that any leaks or spills are immediately contained and cleaned up.
Chemical loading/
unloading areas
Q Cover chemical loading/unloading areas and store chemicals indoors, when possible.

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

FJ Use containment curbs at chemical loading/unloading areas.

Q Develop and implement spill prevention, containment, and countermeasure (SPCC) plans.

Q Train employees in spill prevention, control and cleanup.

FJ Personnel familiar with spill prevention and response procedures should be present during
unloading to ensure that any leaks or spills are immediately contained and cleaned up.
Miscellaneous
loading/unloading
Confine loading/unloading activities to designated areas outside drainage pathways and away
from surface waters.

Inspect containers for leaks or damage prior to loading/unloading.

Avoid loading/unloading materials in the rain or provide cover or other protection for loading
docks.
EPA-833-F-06-030

Cover loading and unloading areas and perform these activities on an impervious pad to enable
easy collection of spilled materials.

Slope the impervious concrete floor or pad to collect spills and leaks and convey them to proper
containment and treatment.

Regularly sweep area to minimize debris on the ground.
Liquid storage tanks
Cover and/or enclose chemical storage areas (including temporary cover such as a tarp that
prevents contact with precipitation). Provide secondary containment around chemical storage
areas.

If containment structures have drains, ensure that the drains have valves, and that valves
are maintained in the closed position. Institute protocols for checking/testing stormwater in
containment areas prior to discharge.

Use double-walled tanks with overflow protection.

Locate storage areas away from high traffic areas and surface waters.

Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings, hoses, and valves)
for failures or leaks and perform preventive maintenance.

Maintain an inventory of fluids to identify leakage.

Provide fluid level indicators.

Properly dispose of chemicals that are no longer in use.

Store and handle reactive, ignitable, or flammable liquids in compliance with applicable local
fire codes, local zoning codes, and the National Electric Code.

Provide drip pads/pans where chemicals are transferred from one container to another to allow
for recycling of spills and leaks.

Use dry cleanup methods.

Develop and implement spill plans or spill prevention, containment, and countermeasure
(SPCC) plans, if required for your facility.

Train employees in spill prevention and control and proper materials management.
Large bulk fuel
storage
If area is uncovered, connect sump outlet to sanitary sewer (if possible) or an oil/water
separator, catch basin filter, etc. If connecting to a sanitary sewer check with the system
operator to ensure that the discharge is acceptable. If implementing separator or filter
technologies ensure that regular inspections and maintenance procedures are in place.
Above ground tanks
Provide secondary containment, such as dikes, with a height sufficient to contain a spill
(the greater of 10 percent of the total enclosed tank volume or 110 percent of the volume
contained in the largest tank).

Use double-walled tanks with overflow protection.

Keep liquid transfer nozzles/hoses in secondary containment area.

Develop and implement spill plans or spill prevention, containment, and countermeasure
(SPCC) plans, if required for your facility.

Train employees in spill prevention and control.
EPA-833-F-06-030

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector O: Steam Electric Power Generating Facilities,
Including Coal Handling Areas
Table 2. BMPs for Potential Pollutant Sources at Steam Electric Generating Facilities, including Coal
Handling Areas (continued)
Pollutant Source
BMPs
Oil bearing
equipment
switchyards
FJ Construct level grades and gravel surfaces to retard flows and limit the spread of spills.
FJ Collect stormwater runoff in perimeter ditches.
Residue hauling
vehicles
FJ Inspect all residue hauling vehicles for proper covering over the load, adequate gate sealing,
and overall integrity of the body or container.
FJ Repair vehicles lacking in the above qualities.
Ash loading areas
FJ Clear the ash building floor and immediately adjacent roadways of spillage, debris, and excess
water before each loaded vehicle departs
Vehicle and
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.
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.
Q 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.
FJ 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.
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.
EPA-833-F-06-030

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector O: Steam Electric Power Generating Facilities,
Including Coal Handling Areas
Table 2. BMPs for Potential Pollutant Sources at Steam Electric Generating Facilities, including Coal
Handling Areas (continued)
Pollutant Source
BMPs
Vehicle and
equipment
maintenance
(continued)
Management of Runoff
Q Use berms, curbs, or grassed swales 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.
FJ 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.
FJ Train employees on waste control and disposal procedures.
Material storage
areas
FJ Store materials indoors.
FJ Cover material with a temporary covering made of polyethylene, polyurethane, polypropylene,
or hypalon.
Q Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
run-on.
Q Construct an enclosure or build a berm around the area.
Q Regularly sweep area to minimize debris on the ground.
Q Train employees in spill prevention, control, cleanup and proper materials management
techniques.
Fueling operations
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.
FJ When fueling in uncovered area, use a concrete pad (not asphalt, which 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.
Q Use fueling hoses with check valves to prevent hose drainage after filling.
Q Keep spill cleanup materials readily available.
Q Clean up spills and leaks immediately.
Q 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.
Q Provide curbing or posts around fuel pumps to prevent collisions from vehicles.
Q Use dry cleanup methods for fuel area rather than hosing the fuel area down.
Q Perform preventive maintenance on storage tanks to detect potential leaks before they occur.
Q Inspect the fueling area to detect problems before they occur.
Q Discourage "topping off" of fuel tanks.
Q Train personnel on vehicle fueling BMPs.
EPA-833-F-06-030

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector O: Steam Electric Power Generating Facilities,
Including Coal Handling Areas

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 Idaho Department of Lands. 1992. Best Management Practices for Mining in Idaho.
www.idl.idaho.gov/Bureau/Minerals/bmp_manual1992/bmp_index.htm

4 Pierce County, Washington, Public Works and Utilities. "Best Management Practices for
Commercial and Industrial Activities."
www.piercecountywa.org/pc/services/home/environ/water/wq/bmpmanaul.htm

4 Naval Facilities Engineering Service Center. "Storm Water Best Management Practices (BMP)
Decision Support Tool: Storm Water Pollution Prevention Operations by Category. Category:
Steam Electric Power Generating Facilities."
http://205.153.241.230/stormwaterbmp/cgi-bin/P2Cat.cfm?Cat=Steam%20Electric%20Power%
20Generating%20Facilities

4 U.S. EPA, 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, 2001. Coal Remining - Best Management Practices Guidance Manual.
EPA-821-B-01-010.
www.epa.gov/waterscience/guide/coal/bmp/

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-06-030

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