INDUSTRIAL STORMWATER
FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
U.S. EPA Office of Water
EPA-833-F-06-036
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 food and kindred products facilities as
defined by Standard Industrial Classification (SIC) Major Code 20. This includes facilities manufacturing
or processing foods, beverages, and related products for human consumption and prepared feeds for
animals and fowls. Establishments engaged in manufacturing cigarettes, cigars, and other tobacco
products are also included. Facilities and products in this group fall under the following categories, all
of which require coverage under an industrial stormwater permit:
4 Meat Products (SIC 2011, 2013, and 2015)
4 Dairy Products (SIC 2021, 2022, 2023, 2024, and 2026)
4 Canned, Frozen, and Preserved Fruits, Vegetables, and Food Specialties (SIC 2032, 2033, 2034,
2035, 2037, and 2038)
4 Grain Mill Products (SIC 2041, 2043, 2044, 2045, 2046, 2047, and 2048)
4 Bakery Products (SIC 2051, 2052, and 2053)
4 Sugar and Confectionery Products (SIC 2061, 2062, 2063, 2064, 2066, 2067, and 2068)
4 Fats and Oils (SIC 2074, 2075, 2076, 2077, and 2079)
4 Beverages (SIC 2082, 2083, 2084, 2085, 2086, and 2087)
4- Miscellaneous Food Preparations and Kindred Products (SIC 2091, 2092, 2095, 2096, 2097, 2098,
and 2099)
4 Tobacco Products (SIC 2111, 2121, 2131, and 2141)
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
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
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 indus-
trial 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 storm-
water permit and links to State stormwater permits, go to www.epa.gov/npdes/stormwater and click
on "Industrial Activity."
What pollutants are associated with my facilities activities?
Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of food
and kindred products will vary. There are a number of factors that influence to what extent industrial
activities and significant materials can affect water quality.
4 Geographic location
4 Topography
4 Hydrogeology
4 Extent of impervious surfaces (i.e., 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
Each of these factors interacts to influence the quantity and quality of stormwater runoff. For
example, flour/oil particulate emissions from vents (e.g., from baking operations) may be a significant
source of pollutants at some facilities, while material storage may be a primary source at others.
Similarly, a facility with all stormwater from exposed industrial activity diverted to the sanitary sewer
would have less of an impact than a facility not practicing this control option. In addition, sources of
pollutants other than stormwater, such as illicit connections, spills, and improperly dumped materials,
may increase the pollutant loadings discharged in the receiving stream.
The nature of the business, and the required sanitary conditions, require that raw materials through
final product be protected from stormwater. As such, the contamination of stormwater from these
activities are primarily from the loading and unloading of products and raw materials; spillage and
leaks from tanks and containers stored outdoors; waste management practices; pest control; and
improper connections to the storm sewer.
The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at food and
kindred products facilities.
Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Food and Kindred
Product Facilities
Activity
Raw material unloading/
product loading
Liquid storage containers
(i.e., above ground storage
tanks)
Pollutant Source
Container defects (bags, drums, bottles, crates)
Spills and leaks during unloading/loading (tanks, rail cars)
Failed connections (hoses and couplings)
Washdown of unloading/loading area
Failed piping and connections (couplings, flanges, hoses, and
valves)
External corrosion and structural failure
Spills and overflows due to operator error
Pollutant
Biochemical oxygen
demand (BOD), total
suspended solids (TSS), oil
and grease, pH, nitrogen
(TKN)
BOD, TSS, oil and greases,
PH
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Food and Kindred
Product Facilities (continued)
Activity
Liquid storage containers
(drums, carboys, and gallon
jugs)
Solid storage containers
(soils, holding bins, fiber
drums, etc.)
Air emissions
Solid waste
Spent equipment, scraps,
etc
Wastewater
Pest control
Illicit connections to the
storm sewer
Pollutant Source
Outside containers
Open containers
External corrosion of the containers
Operator handling and transporting
Spills and leaks from damaged containers
Dust and particulates
Operator handling and transporting
Spills and leaks
Oven emissions
Vents
Fine solids handling
Dumpsters and trash cans
BOD, TSS, oil and greases, pH, copper, manganese
Treatment processes (e.g., hydraulic overflow)
Outside piping and connections (couplings, flanges, hoses,
valves, and pumps)
Outside application of pesticides, rodenticides, and insecticides
Process wastewaters
Process floor drains
Sanitary sewers
USTs
Pollutant
BOD, TSS, oil and greases,
PH
BOD, TSS, pH
BOD, TSS, oil and greases,
pH
BOD, TSS, oil and greases,
pH, fecal coliform
Miscellaneous insecticides,
rodenticides, pesticides,
etc., TKN
BOD, TSS, oil and greases,
pH
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 food and kindred products facilities. You will likely need to implement
a combination or suite of BMPs to address stormwater runoff at your facility. Your first consideration
should be for pollution prevention BMPs, which are designed to prevent or minimize pollutants
from entering stormwater runoff and/or reduce the volume of stormwater requiring management.
Prevention BMPs can include regular cleanup, collection and containment of debris in storage areas,
and other housekeeping practices, spill control, and employee training. It may also be necessary to
implement treatment BMPs, which are engineered structures, intended to treat stormwater runoff
and/or mitigate the effects of increased stormwater runoff peak rate, volume, and velocity. Treatment
BMPs are generally more expensive to install and maintain and include oil-water separators, wet
ponds, and proprietary filter devices.
BMPs must be selected and implemented to address the following:
Good Housekeeping Practices
Good housekeeping is a practical, cost-effective way to maintain a clean and orderly facility to
prevent potential pollution sources from coming into contact with stormwater. It includes establishing
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
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
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 food and
kindred 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 food
and kindred 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.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
Table 2. BMPs for Potential Pollutant Sources at Food and Kindred Product Facilities
Pollutant Source
BMPs
Raw material unloading/product
loading
FJ Situate loading/unloading areas indoors or in a covered area.
FJ Confine loading/unloading activities to designated areas outside drainage
pathways and away from surface waters.
FJ Ensure that a facility representative is present during unloading/loading activities.
FJ Close storm drains during loading/unloading activities in surrounding area.
Q Use a dead-end sump where materials could be directed.
Q Use rubber seals in truck loading dock areas to contain spills.
Q Inspect all containers for leaks or damage prior to unloading/loading of any raw or
spent materials.
Q Avoid loading/unloading materials in the rain or provide cover or other protection
for loading docks.
Q Provide diversion berms, dikes or grassed swales around the perimeter of the area
to limit run-on.
FJ Cover loading and unloading areas and perform these activities on an impervious
pad to enable easy collection of spilled materials. Provide overhangs or door skirts
to enclose trailer ends at truck loading/unloading docks.
FJ For rail transfer, a drip pan shall be installed within the rails to collect spillage from
the tank.
Q Where liquid or powdered materials are transferred in bulk to/from truck or rail
cars, ensure hose connection points at storage containers are inside containment
areas, or drip pans are used in areas where spillage may occur which are not in a
containment area.
FJ Drain hoses back into truck, railcar, etc. after loading/unloading materials.
FJ Install high level alarm on tanks to prevent overfilling.
FJ Use dry cleanup methods rather than washing the areas down.
Raw material unloading/product
loading (continued)
Q Regularly sweep area to minimize debris on the ground.
FJ Provide dust control if necessary. When controlling dust, sweep and/or apply water
or materials that will not impact surface or ground water.
FJ Train employees in spill prevention, control, cleanup, and proper materials
management techniques.
FJ Train employees on proper unloading/loading techniques.
FJ Initiate an inventory control for all raw and spent materials.
Liquid storage
FJ Cover and/or enclose storage areas to minimize exposure of tanks and the
collection of stormwater inside the curbed/diked area.
FJ 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.
Q Surround above-ground liquid storage tanks with curbs/dikes to provide secondary
containment storage. The enclosed volume should be the greater of either 10% of
the total tank volume or 110% of the volume contained in the largest tank.
FJ If containment structures have drains, ensure that the drains have valves, and that
valves are maintained in the closed position.
FJ Institute protocols for checking/testing stormwater in containment areas prior to
discharge.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
Table 2. BMPs for Potential Pollutant Sources at Food and Kindred Product Facilities (continued)
Pollutant Source
BMPs
Liquid storage (continued)
FJ Install impervious surface for the floor of the storage area and slope it to a lined
sump for the collection of spills.
FJ Use drip pans when loading and unloading liquid materials and place at locations
where spillage may occur (hose connections, hose reels, filler nozzles, and opened
tanks/drums).
FJ Bulkhead liquid storage tanks indoors (i.e., tank outlets located inside buildings).
Q Inspect the external condition (corrosion, leaks) of the containers.
FJ Inspect the general area around the containers.
FJ Use double-walled tanks.
Q Develop and implement spill plans.
FJ Train employees in spill prevention, control, proper storage, handling and
transportation techniques (e.g., filling and transferring contents).
Liquid storage (drums, carboys,
and gallon jugs)
FJ Store containers indoors when possible.
FJ Store containers, including empty or used containers, in secondary containment
with a roof or cover (including temporary cover such as a tarp that prevents
contact with precipitation).
Q Store containers, including empty or used containers, 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 1 0 percent of the total enclosed tank
volume or 1 1 0 percent of the volume contained in the largest tank).
Q Clearly label containers with its contents.
Ensure that all containers are closed (e.g., valves shut, lids and manways sealed,
caps closed).
FJ
FJ Wash containers indoors before storing empty containers outdoors.
Q If outside or in a covered area, minimize run-on of stormwater into a storage area
by grading area to ensure that stormwater runs "off" and not "on."
Q Maintain an inventory control of all raw and spent materials.
FJ Employ measures to protect against spillage from the overflows (e.g., high level
sensors, alarms).
FJ Train employees in spill prevention and control.
Waste management -
wastewater
Q Develop a leak prevention program for valves, pumps, and piping equipment.
FJ Inspect the outside pipe connections (couplings, valve seals and gaskets, flanges,
etc.) of the treatment system for leaks, corrosion, and poor maintenance upkeep.
FJ Use dry cleanup methods.
Waste management - solid
waste (paper, wood pellets,
scrap metals, refuse, etc.)
Inspect the general area around the solid waste storage (e.g., look for signs of
leaching).
Store waste so that it is physically contained (dumpsters, drums, bags). Store waste
in an enclosed/covered area.
If outside or in a covered area, minimize exposure to stormwater by grading the
area to ensure that stormwater runs "off" and not "on."
Ensure hazardous waste disposal practices are performed in accordance with
federal, state, and local requirements.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
Table 2. BMPs for Potential Pollutant Sources at Food and Kindred Product Facilities (continued)
Pollutant Source
BMPs
Waste management - air
emissions
Clean around vents and stacks to atmosphere from process and storage areas.
Place tubs around vents and stacks for easy collection of settling particles.
Remove fugitive dust accumulations on ledges, walls, floors, and equipment. If
you use compressed air to clean up dust, shut down your machinery and other
potential ignition sources.
Inspect air emission control systems (e.g., baghouses) regularly and repair and
replace as necessary.
Route overflows/condensates from process vents to on-site treatment system or to
the sanitary sewer.
Minimize free-fall height to reduce fugitive-dust losses.
Locate fabric dust-filter collectors outside the facility if possible. If fabric dust-filter
collectors are inside the facility, place them in an area protected by an explosion-
protection system.
Pest control
Q Follow manufacturer's directions for application of pest control materials to site.
FJ Time application for dry weather conditions.
FJ Store partially full containers indoors or undercover.
Q Apply insecticides during breeding months.
Q Protect rat bait houses from stormwater.
Improper connections to the
storm sewer
FJ Perform smoke or dye testing to determine if interconnections exist between the
sanitary and storm sewers.
FJ Plug all floor drains leading to storm sewers.
Q Update facility schematics to accurately reflect all plumbing connections.
Meat products - operation
of meat packaging plants
including animal holding pens
(beef, chicken)
Q Enclose/cover fowl hanging area.
Q Enclose/cover the animal holding pens.
FJ Grade the areas around the animal holding pens to ensure stormwater "runs off"
and not "on" to the holding pen. And regularly inspect area around animal holding
pens for stormwater runoff or run-on.
FJ Store materials from cleanup activities in appropriate containers in an enclosed/
covered area.
FJ Area for trailers holding empty bird cages should have stormwater run-on/runoff
controls in place.
FJ Use mechanical sweepers around site to clean up fugitive feathers, dust, and
manure.
FJ Decrease total lot area when animal numbers are low to decrease total stormwater
runoff.
FJ Direct run-off to storage lagoons and holding ponds until it can be land applied or
evaporated or discharged to a municipal treatment system. If connecting to a sanitary
sewer check with the system operator to ensure that the discharge is acceptable.
FJ Train employees on proper material (i.e., hide, hair, feathers, and animal parts)
cleanup procedures around and within the animal holding pens.
Manure management
FJ Place animal manure in grassy area as far as possible from water courses so
seepage has a chance to be filtered and absorbed by the grass before entering
creek or stream. For land with a slope of greater than one percent, plant a dense,
sod forming grass at least 20 feet wide around the downgradient side of any
manure stockpile.
FJ Use grass filter strips, filter fencing, or straw bales to filter solids and nutrients from
runoff.
FJ Store manure in bermed or covered areas.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products Facilities
Table 2. BMPs for Potential Pollutant Sources at Food and Kindred Product Facilities (continued)
Pollutant Source
BMPs
Dairy products - manufacturing
and storage of packaged dairy
products (including spoiled and
broken product containers)
Store aged/spoiled dairy products in enclosed storage area on an impervious or
contained pad and under a roof or canopy where possible.
Use dry cleanup methods instead of washing the areas down.
Ensure that all aged/spoiled products (e.g., bottles, cartons, plastic containers) are
disposed of in a proper manner (bagged, covered).
Keep foam from going into sewers because it contains milk solids. Common
sources of excessive foaming are open-type separators, splashing when filling
tanks, air sucked in through leaky connections in lines under partial vacuum,
through leaky packing and through faulty rotary seals or pumps.
Inspect storage area for leaks and spills and to monitor housekeeping and runoff
prevention practices.
Train employees on spill prevention, control and proper disposal methods for all
aged/spoiled dairy products.
Canned frozen and preserved
fruits, vegetables, and frozen
specialties - fruit and vegetable
storage and disposal
FJ Store all fruits and vegetables in appropriate containers (e.g., bins, bushels,
baskets, buckets) and in enclosed/covered areas.
Q Minimize fruit and vegetable storage time outdoors.
FJ Store empty fruit and vegetable containers in an enclosed/covered area.
FJ Use particulates emission control systems for all cooking processes to reduce
particulate matter.
Q Inspect all fruit and vegetable storage areas to monitor BMP implementation.
FJ Train employees on proper handling/disposal methods for fresh/rotten fruits and
vegetables.
Grain mills - grain handling,
storage, and mixing
FJ Store all grain in appropriate containers (e.g., silos, hoppers) in an enclosed/
covered area.
FJ Use a vacuum control system in all grain mixing areas to minimize fugitive dust.
Q Inspect the general area around the grain storage to monitor BMP implementation.
FJ Train employees on grain handling procedures.
Bakery products - ingredient
storage and mixing
Store all ingredients (e.g., corn sweeteners, flour, shortening, syrup, vegetable oils)
in appropriate containers (e.g., tanks, drums, bags) in an enclosed/covered area.
Inspect ingredient storage areas for BMP implementation.
Bakery products - baking
process
Remove flour/oil dust accumulation around ventilation exhaust systems.
Install an air emission control system for all baking processes to reduce particulate
matter.
Sugar and confectionery - sugar
handling
FJ Use a vacuum control system in all granular and powdered processing areas.
Fats and oils - storage and
disposal
FJ Store all fats and oils, (e.g., butcher shop materials, hair, hide, tallow, bone meal,
and offal) in enclosed/covered areas.
FJ Ensure all fats and oils are physically contained.
Q Inspect all fats and oils storage areas for BMP implementation.
Beverages - materials storage
and mixing
Q Ensure grain is stored in enclosed/covered area.
FJ Use a particulates emission control system for all grain handling and brewing
processes.
Q Protect reusable beverage containers that are stored outdoors from stormwater
contact.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector U: Food and Kindred Products 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 Multi-Sector General Permits and
from the following sources:
4 Colorado State University Cooperative Extension. 1994. Best Management Practices for Manure
Utilization.
www.ext.colostate.edu/PUBS/crops/XCM174.PDF
4 Environment Canada. 1997. Fraiser River Action Plan - Stormwater Best Management Practices
(BMPs) for Selected Industrial Sectors in the Lower Fraiser Basin.
www.rem.sfu.ca/FRAP/9703.pdf
4 New Jersey Technical Assistance Program for Industrial Pollution Prevention. "Pollution
Prevention Guidebooks-Food and Kindred Products: SIC Code 20".
www.ycees. nj it.ed u/njtap/isr20. htm
4 Pierce County, Washington, Public Works and Utilities. "Stormwater Pollution Prevention
Manual: A Guide to Best Management Practices for Industries, Businesses, and Homeowners"
www.co.pierce.wa.us/pc/services/home/environ/water/wq/bmpmanaul.htm
4 Pollution Prevention Institute, Kansas Small Business Environmental Assistance Program. "Water
Quality Protection Tool-Grain Storage."
www.sbeap.org/waterquality/assessment/?id=6
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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