Industrial Stormwater Fact Sheet Series Sector V: Textile Mills, Apparel, and Other Fabric Product Manufacturing Facilities


INDUSTRIAL   STORMWATER
FACT  SHEET  SERIES
            U.S. EPA Office of Water
            EPA-833-F-06-037
            December 2006
 Sector V: Textile Mills, Apparel, and
Other Fabric Product Manufacturing
                            Facilities
  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 textile facilities as described by
  Standard Industrial Classification (SIC) Major Groups 22, 23, and 31 which includes all facilities that
  produce textiles. Facilities and products in this group fall under the following categories, all of which
  require coverage under an industrial stormwater permit:
    4 Textile mill product facilities (SIC 2211-2299), which typically receive and prepare fibers,
      transform these materials into fabric or related products, and finish the materials before
      packaging.
    4 Apparel facilities (SIC 2311-2399), which typically receive woven or knitted fabric for cutting,
      sewing, and packaging.
    4- Leather and leather products (SIC 3131-3199), except leather tanning and finishing (SIC 3111).


  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 V: Textile Mills, Apparel, and Other
Fabric Product Manufacturing Facilities
  What pollutants are associated with my facilities activities?
  Pollutants conveyed in stormwater discharges from textile facilities will vary. There are a number of
  factors that influence to what extent industrial activities and significant materials can affect water
  quality.

     4  Geographic location
     4  Topography
     4  Hydrogeology
     4  Extent of impervious surfaces (e.g.,, concrete or asphalt)
     4  Type of ground cover (e.g., vegetation, crushed stone, or dirt)
     4  Outdoor activities (e.g., material storage, loading/unloading, vehicle maintenance)
     4  Size of the operation
     4  Type, duration, and intensity of precipitation events

  The activities, pollutant sources, and pollutants detailed in Table 1 are commonly found at textile
  facilities.

  Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Textile Facilities
Activity
Outdoor material loading/
unloading
Raw material storage and
handling
Storage and handling of
materials for dyeing
Storage and handling of
materials for scouring and
cleaning
Storage and handling of
materials for bleaching,
printing, finishing, and other
activities
Vehicle and equipment
fueling
Pollutant Source
Wooden pallets, spills/leaks from material
handling equipment, raw materials, finished
products, solvents, dyes
Wool, cotton, synthetics, rayon, other fibers,
coal/wood piles, fuels, oil, and/or lubricants
Dyes, dye preservatives, and/or pigments
Wool, scouring agents, and/or detergents
Dyes, bleaches, detergents, finishing agents,
and/or printing products
Spills and leaks during fuel transfer, spills due
to "topping off" tanks, runoff from fueling
areas, washdown of fueling areas, leaking
storage tanks, spills of oils, brake fluids,
transmission fluids, engine coolants
Pollutant
Total suspended solids (TSS), pH, oil and
grease, chemical oxygen demand (COD),
biochemical oxygen demand (BOD5),
heavy metals
BOD5, COD, TSS, , pH, oil and grease,
lead, chromium, and/or benzene
Copper, phenols, lead, chromium, zinc,
aluminum, and/or acids
BOD5, COD, TSS, oil and grease, sulfides,
phenols, pH, and/or chromium
BOD5, COD, TSS, oil and grease, sulfides,
phenols, pH, chromium, chromium
peroxide, and/or acids
Gas/diesel fuel, fuel additives, oil,
lubricants, 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 textile 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
  EPA-833-F-06-037

-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector V: Textile Mills, Apparel, and Other
Fabric Product Manufacturing Facilities


  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 textile mills, apparel, and other fabric product
  manufacturing facilities include:
     4 Plainly labeling and storing all containerized materials (e.g., fuels, petroleum products,
        solvents, dyes, etc.)  in a protected area, away from drains
     4 Using containment areas or enclosures for materials stored outdoors
     4 Use an inventory control plan to prevent excessive purchasing of potentially hazardous
        substances
     4 For storing empty chemical drums/containers, ensuring the drums/containers are clean  (e.g.,
        triple-rinsing) and there is no contact of residuals with precipitation/runoff. Collecting  and
        disposing of washwater from these cleanings properly.
     4 Regularly cleaning above ground storage tank areas
     4 Using dry cleanup methods in above ground storage tank areas and fueling areas
     4 Addressing the replacement or repair of leaking connections, valves, transfer lines, and pipes
        that may carry  chemicals, dyes, or wastewater where applicable

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

  Specific exposure minimization practices for textile mills, apparel, and other fabric product
  manufacturing facilities include covering fueling areas and covering or enclosing areas where transfer
  of materials may occur. Since, many processes are typically conducted indoors at textile mills, apparel,
  and other fabric product manufacturing facilities, then changes in the manufacturing process, such as
  a switch to less toxic chemicals, can lessen the amount of contamination in stormwater discharges.
  EPA-833-F-06-037

-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector V: Textile Mills, Apparel, and Other
Fabric Product Manufacturing Facilities

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.

Specific runoff management practices for textile mills, apparel, and other fabric product
manufacturing facilities include:
4 Minimizing runoff of stormwater from areas adjacent to above ground storage tank and
fueling areas
4 Inserting filters in catch basins adjacent to above ground storage tank areas
4 Treating and/or recycling stormwater runoff collected from fueling areas

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 textile 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 textile 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.

Table 2. BMPs for Potential Pollutant Sources at Textile Facilities
Pollutant Source
BMPs
Outdoor material
loading and unloading
Confine loading/unloading activities to a designated area outside drainage pathways and
away from surface waters.

Load/unload indoors or in a covered area.

Cover loading/unloading area with permanent cover (e.g., roofs) or temporary cover (e.g.,
tarps).

Close storm drains during loading/unloading activities in surrounding areas.

Avoid loading/unloading materials in the rain.

Slope the impervious concrete floor or pad to collect spills and leaks and convey them to
proper containment and treatment.
EPA-833-F-06-037

-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector V: Textile Mills, Apparel, and Other
Fabric Product Manufacturing Facilities
Table 2. BMPs for Potential Pollutant Sources at Textile Facilities (continued)
Pollutant Source
BMPs
Outdoor material
loading and unloading
(continued)
FJ 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.

Q Install an oil/water separator in catch basins.

FJ Inspect all containers prior to loading/unloading of any raw or spent materials.

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

FJ Dead-end sump where spilled materials could be directed.

FJ Use dry cleanup methods instead of washing the areas down.

Q Train employees on proper loading/unloading techniques and spill prevention and response.
Chemical storage
FJ Store materials indoors when possible.

FJ Store permanent tanks in a paved area surrounded by a dike system which provides
sufficient containment for the larger of either 10 percent of the volume of all containers or
110 percent of the volume of the largest tank.

FJ 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.

FJ Plainly label and store all containerized materials (e.g., fuels, petroleum products, solvents,
dyes, etc.) in a protected area, away from drains.

Q Implement an inventory control plan to prevent excessive purchasing of potentially
hazardous substances.

Q Ensure that empty drums/containers that are being stored are clean and there is no contact
of residuals with precipitation/runoff. Collect and dispose of washwater from these
cleanings properly.

Q Store reactive, ignitable, or flammable liquids in compliance with the local fire code, and the
National Electric Code.

FJ Regularly clean chemical storage areas.

FJ Restrict access to the chemical storage areas.

Q Insert filters in adjacent catch basins.

FJ Permanently seal drains within critical areas that may discharge to a storm drain.

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

Q Train employees in spill prevention and control and proper materials management.
Coal pile management
Confine storage to areas outside of drainage pathways and away from surface waters.

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

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

Use properly designed basins for collection, containment, and recycling of pile spraying
materials.
Use control measures such as berms, silt fences or waddles to control sediment from leaving
storage area.
FJ

FJ Train employees in good housekeeping measures.
EPA-833-F-06-037

-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector V: Textile Mills, Apparel, and Other
Fabric Product Manufacturing Facilities
Table 2. BMPs for Potential Pollutant Sources at Textile Facilities (continued)
Pollutant Source
BMPs
Material handling: bulk
liquid fuel storage
FJ Cover/enclose areas where the transfer of material may occur.
FJ Store permanent tanks in a paved area surrounded by a dike system that provides
containment for the larger of either 10 percent of the volume of all containers or 100
percent of the volume of the largest tank.
Q Tanks should be placed in gravel or concrete paved areas, away from natural drainage paths
to waterways (such as parking lot drains).
FJ 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.
FJ Use double-walled tanks with overflow protection.
FJ Keep liquid transfer nozzles/hoses in secondary containment area.
FJ Inspect storage tanks to detect potential leaks and perform preventive maintenance.
FJ Inspect piping systems (pipes, pumps, flanges, couplings, hoses, valves) for failures or leaks.
Develop and implement spill plans.
Q Train employees on proper filling and transfer procedures, spill prevention and control.
Material handling:
containerized material
storage
Store drums indoors when possible.
Store drums, including empty or used drums, in secondary containment with a roof or cover
(including temporary cover such as a tarp that prevents contact with precipitation).
Provide secondary containment, such as dikes or portable containers, with a height
sufficient to contain a spill (the greater of 10 percent of the total enclosed tank volume or
110 percent of the volume contained in the largest tank).
If storing empty chemical drums, triple-rinse containers and collect discharge waters from
washings.
Clearly label drum with its contents.
Educate personnel for proper storage, use, cleanup, and disposal of materials.
Material handling:
designated material
mixing areas
FJ Cover and enclose areas where the transfer of materials may occur.
FJ Mix solvents in designated areas away from drains, ditches, and surface waters.
FJ Never wash drums in the mix kitchen or dispose of obsolete dyes and chemicals down the
drain.
FJ When a new drum is opened, the old drum should be emptied or drained thoroughly into
the new drum.
Waste management
Store waste in enclosed and/or covered areas.
Store wastes in covered, leak proof containers (e.g., dumpsters, drums).
Cover the dumpsters or move them indoors.
Use linked dumpsters that do not leak.
Provide a lining for the dumpsters.
Direct runoff to on-site retention pond.
Ensure hazardous and solid waste disposal practices are performed in accordance with
applicable federal, state, and local requirements.
Ship all wastes to offsite licensed landfills or treatment facilities.
EPA-833-F-06-037

Q When fueling in uncovered area, use concrete pad (not asphalt).

Q 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 Minimize/eliminate run-on onto fueling areas with diversion dikes, berms, curbing, surface
grading or other equivalent measures.

FJ Collect stormwater runoff and provide treatment or recycling.

FJ Use dry cleanup methods for fuel area rather than hosing the fuel area down. Clean up
spills and leaks immediately.

FJ Discourage topping off of fuel tanks.

FJ Regularly inspect and perform preventive maintenance on storage tanks to detect potential
leaks before they occur.

Q Inspect the fueling area for leaks and spills.

Q Train personnel on fueling BMPs.

Q Provide curbing or posts around fuel pumps to prevent collisions during vehicle ingress and
egress.
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.
EPA-833-F-06-037

-------
INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector V: Textile Mills, Apparel, and Other
Fabric Product Manufacturing Facilities


  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, Arizona, Street Transportation Department, Storm Water Management Section.
      2004. Prevent Stormwater Contamination Best Management Practices for: Section V - Textile
      Mills, Apparel, Leather and Other Fabric Facilities. SIC Codes: 2200-2399 & 3131-3199.
      http://phoenix.gov/STREETS/textfab.pdf

    4 New Jersey Technical Assistance Program for Industrial Pollution Prevention. "Pollution
      Prevention Guidebooks. Textile Industry: SIC Code 22."
      www.ycees.njit.edu/njtap/isr22.htm

    4 U.S. EPA, Office of Research and Development. 1996. Best Management Practices for Pollution
      Prevention in the Textile Industry. EPA/625/R-96/004.
      www.p2pays.org/ref/02/01099.htm

    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
  EPA-833-F-06-037

-------