Industrial Stormwater Fact Sheet Series Sector Y: Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries


INDUSTRIAL  STORMWATER
FACT SHEET  SERIES
           U.S. EPA Office of Water
           EPA-833-F-06-040
           December 2006
    Sector Y: Rubber, Miscellaneous
Plastic Products, and Miscellaneous
          Manufacturing Industries
 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 rubber, miscellaneous plastic
 products, and manufacturing facilities as described by Standard Industrial Classification (SIC) Major
 Group 30. Facilities and products in this group fall under the following categories, all of which require
 coverage under an industrial stormwater permit:
    4- Tires and inner tubes (SIC 3011)
    4- Rubber and plastic footwear (SIC 3021)
    4 Rubber and plastic hose and belting (SIC 3052)
    4 Gaskets, packaging, and sealing devices (SIC 3053)
    4 Fabricated rubber products, not elsewhere classified (SIC 3061 and 3069)
    4- Miscellaneous plastic products (SIC 3081 and 3089)
    4 Miscellaneous manufacturing industries (SIC 3991-3999)
 Also discussed are stormwater discharges from miscellaneous manufacturing industries (except
 jewelry, silverware, and plateware) commonly identified by SIC Major Group 39 (except for 391).
 Miscellaneous manufacturing industries specifically include manufacturers of:
    4 Musical instruments (SIC 3931)
    4 Games, toys, and athletic goods (SIC 3942-3949)
    4 Pens, pencils, and artists' supplies (SIC 3951-3955, except 3952)
    4 Buttons, pins, and needles (SIC 3961 and 3965)

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector Y: Rubber, Miscellaneous Plastic Products,
and Miscellaneous Manufacturing Industries


  What does an industrial storm water 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 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 activities at my facility?
  Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of
  rubber, miscellaneous plastic, and other 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 (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

  Most of the actual manufacturing and processing activities associated  with this industry normally
  occur indoors. However, there is a wide variety of materials used at these facilities which may include:
     4  Solvents
     4  Acids and caustic
     4  Carbon black
     4  Plasticizers
     4-  Paint
     4  Processing oils
     4  Resins
     4  Rubber compounds and solutions
     4  Scrap plastic and rubber
     4  Fuels such as diesel or gasoline
     4  Adhesives
     4  Zinc
     4  Miscellaneous chemicals

  Tanks,  drums, or bags of these materials (including  raw materials, by-products, final products, or
  waste products) may  be exposed to stormwater during loading/unloading  operations or through out-
  door storage or handling at some facilities. Other items which may be exposed to stormwater include
  surplus processing machinery, scrap metal, PVC pipe, and rags.

  The  activities, pollutant sources, and pollutants detailed in Table 1  are commonly found at Rubber,
  miscellaneous plastic product, and miscellaneous manufacturing facilities.

  EPA-833-F-06-040                                                                           2

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector Y: Rubber, Miscellaneous Plastic Products,
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  Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Rubber, Miscellaneous
  Plastic Products, and Miscellaneous Manufacturing Facilities
Activity
Outdoor material
loading/unloading
Outdoor material
and equipment
storage
Pollutant Source
Wooden pallets, spills/leaks from material handling equipment,
solvents, resins
Solvents, acids and caustic, plasticizers, paint, lubricating oils,
processing oils, resins, rubber compounds, mineral spirits, zinc, scrap
metal, scrap plastic and rubber, plastic pellets, PVC pipe, and rags
Pollutant
Total suspended solids (TSS),
oil and grease, organics
Organics, zinc, hydrocarbons,
oil and grease, acids,
alkalinity
  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 rubber, miscellaneous plastic products, and miscellaneous manufactur-
  ing 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 de-
  signed 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 in-
  tended 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 proto-
  cols 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 in-
  clude 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 materi-
  als, 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


  EPA-833-F-06-040                                                                           3

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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector Y: Rubber, Miscellaneous Plastic Products,
and Miscellaneous Manufacturing Industries

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.

Additionally, identifying weaknesses in current facility practices will aid the permittee in determining
appropriate BMPs that will achieve a reduction in pollutant loadings.

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 rubber,
miscellaneous plastic products and miscellaneous manufacturing 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 rubber, miscellaneous plastic products and
miscellaneous manufacturing 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 Rubber, Miscellaneous Plastic Products, and
Miscellaneous Manufacturing Facilities
Pollutant Sources
BMPs
Outdoor material
unloading/loading
FJ Confine loading/unloading activities to designated areas outside drainage pathways and
away from surface waters.

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

FJ Use a dead-end sump where materials could be directed.

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

FJ 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.

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

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

FJ Provide overhangs or door skirts to enclose trailer ends at truck loading/unloading docks.
EPA-833-F-06-040

FJ Inspect pallets for protruding nails or broken boards.
Outdoor material
storage
FJ Cover storage areas with roofs or tarps.
Q Confine storage of raw materials, parts, and equipment to designated areas away from high
traffic, outside drainage pathways and away from surface waters.
Q Provide secondary containment around chemical storage areas.
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 Provide diversion berms, dikes or grassed swales around the perimeter of the area to limit
run-on.
Q Direct stormwater runoff to an on-site retention pond.
FJ Ensure that all containers are properly sealed and valves closed.
Q Conduct container integrity testing and provide leak detection.
Q Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings, hoses, and
valves) for failures or leaks and perform preventive maintenance.
FJ Plainly label all containers.
Q Maintain an inventory of fluids to identify leakage.
FJ Wash and rinse containers indoors before storing them outdoors.
FJ Train employees on proper spill prevention and response techniques.
Q Train employees on proper waste control and disposal.
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.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector Y: Rubber, Miscellaneous Plastic Products,
and Miscellaneous Manufacturing Industries
Table 2. BMPs for Potential Pollutant Sources at Rubber, Miscellaneous Plastic Products, and
Miscellaneous Manufacturing Facilities (continued)
Pollutant Sources
Waste management
(continued)
Particulate emission
management
BMPs
FJ Dispose or recycle packaging properly.
FJ Ensure hazardous and solid waste disposal practices are performed in accordance with
applicable federal, state, and local requirements.
Q Ship all wastes to offsite licensed landfills or treatment facilities.
Q Clean around vents and stacks.
FJ Place tubs around vents and stacks to collect particulates.
Q Inspect air emission control systems regularly and repair or replace when necessary.
Rubber Manufacturers - Zinc material management
Material storage
Dumpsters
Dust collectors or
baghouses
Grinding operations
from which zinc dust
may be released
Zinc stearate coating
operations
Q Store zinc bags indoors.
Q Use of special large volume sacks (2,500 pound sacks rather than 50- to 100-pound sacs)
with less potential for releases of zinc.
FJ Store materials in use in sealable container.
Q Provide an airspace between the container and the cover to minimize "puffing" losses when
the container is opened.
Q Use automatic dispensing and weighing equipment.
FJ Use pre-weighed bags that can be thrown directly into the mixer to reduce spillage.
Q Clean up spills without washing zinc into storm drains.
FJ Train employees on proper handling and emptying of zinc bags.
FJ Cover the dumpsters or move them indoors.
Q Use linked dumpsters that do not leak.
FJ Provide a lining for the dumpsters.
FJ Repair or replace improperly operating baghouses.
FJ Provide regular maintenance.
FJ Use dust collection system or reduce the amount of dust generated.
Q Develop a spill prevention/response plan.
FJ Use dry cleanup methods for spills.
Q Use alternate compounds to zinc stearate.
Plastics Manufacturers - Plastic Pellet Management
Management
Education and training
FJ Conduct regularly scheduled self evaluations to identify problem areas.
Q Encourage information sharing between companies.
FJ Develop educational materials for employees, including those involved in transporting
Dellets.
FJ Educate key officials and company managers regarding the fate and effects and the
economic disadvantages of pellet loss.
Q Educate company employees regarding environmental hazards of pellet loss and employee
responsibility for corrective actions.
Q Train pellet handlers to operate equipment, particularly fork lifts, in a manner that minimizes
the potential for pellet loss.
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector Y: Rubber, Miscellaneous Plastic Products,
and Miscellaneous Manufacturing Industries
Table 2. BMPs for Potential Pollutant Sources at Rubber, Miscellaneous Plastic Products, and
Miscellaneous Manufacturing Facilities (continued)
Pollutant Sources
BMPs
Equipment and
facilities
FJ Install a containment system to capture stormwater runoff.
FJ Implement dry cleanup procedures.
Q Install connecting hoses equipped with valves that will close automatically when the
connection is broken.
Q Direct the water flow from rail hopper cars and bulk trucks through a screen to capture the
pellets rather than spilling them onto the ground.
FJ Seal expansion joints in concrete floors with a flexible material to facilitate cleanup.
Q Install alarms in the pellet conveying system.
Q Pave all pellet handling areas, including loading docks and rail sidings.
FJ Place screening in storm drains.
Q Place control devices where they can be serviced without losing pellets.
FJ Equip bag-handling stations with vacuum hoses to facilitate spill cleanup.
Q Use tarps or containment devices to collect pellets as they are spilled.
FJ Install grating at doorways for wiping feet.
Q Modify loading systems so that transfer lines can be completely emptied, with any residual
resin being contained when loading ceases.
FJ Ensure equipment is secured and stored properly.
Operations
FJ Place portable screens underneath connection points when making and breaking all
connections.
FJ Secure outlet caps and seals before moving full or empty rail hopper cars and trucks.
FJ Implement handling procedures that minimize punctures and pellet spillage.
FJ Inspect pellet packaging before offloading.
FJ Repair punctured bags immediately.
Good housekeeping
FJ Implement daily and routine housekeeping and spill response procedures.
FJ Develop standard operating procedures for containing and cleaning up spills.
FJ Conduct routine inspections for the presence of loose pellets on the facility grounds,
including parking lots, drainage areas, driveways, etc.
Packaging
FJ Use reinforced bags and containers lined with puncture-resistant material.
FJ Minimize the use of valved bags or seal valved bags immediately after filling.
FJ Use sealed containers instead of break bulk packaging.
Shipping
FJ Use containers for cargo shipping rather than individual pallets.
FJ Identify the person responsible for sealing the ports on rail hopper cars and bulk trucks, and
document sealing.
FJ Close and secure the rail hopper car valve with strong wire or aircraft cable in addition to the
normal sealing mechanism.
Q Visually confirm that each compartment and tube of shipping vehicles is empty.
Q Inspect interiors of trailers and sea containers for defects that may puncture pellet packaging.
Consider vandalism exposure when selecting leased track sites.
EPA-833-F-06-040

FJ Seal empty rail hopper cars and bulk trucks before returning them to shipper.
Recycling and waste
FJ Store waste pellets in properly labeled containers.
disposal
FJ Recycle or resell waste pellets.
FJ Check broken and discarded packaging for residual pellets.

FJ Inspect handling and storage procedures.

FJ If an outside vendor is used for waste removal, train in material handling, spill prevention and
control.
What if activities and materials at my facility are not exposed to
precipitation?
The industrial stormwater program requires permit coverage for a number of specified types of
industrial activities. However, when a facility is able to prevent the exposure of ALL relevant activities
and materials to precipitation, it may be eligible to claim no exposure and qualify for a waiver from
permit coverage.

If you are regulated under the industrial permitting program, you must either obtain permit coverage
or submit a no exposure certification form, if available. Check with your permitting authority for
additional information as not every permitting authority program provides no exposure exemptions.

Where do I get more information?
For additional information on the industrial stormwater program see
www.epa.gov/npdes/stormwater/msgp.

A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
be found at www.epa.gov/npdes/stormwatercontacts.

References
Information contained in this Fact Sheet was compiled from EPA's past and current Multi-Sector
General Permits and from the following sources:

4 City of Phoenix, Arizona, Street Transportation Department, Stormwater Management Section.
2004. Prevent Storm Water Contamination Best Management Practices for Section Y - Rubber,
Plastic Products & Miscellaneous Manufacturing. Major Groups 30 and 39 (Except 3910-19).
http://phoenix.gov/STREETS/rubplas.pdf

4 U.S. EPA, Office of Air and Water Programs - Effluent Guidelines Division.1974. Development
Document for Effluent Limitations Guidelines and New Source Performance Standards for the
Tire and Synthetic Segment of the Rubber Processing Point Source Category. EPA-820-B-80-100.

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/
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INDUSTRIAL STORMWATER FACT SHEET SERIES
Sector Y: Rubber, Miscellaneous Plastic Products,
and Miscellaneous Manufacturing Industries


    4 U.S. EPA, Office of Water. 1992. Plastic Pellets in the Aquatic Environment: Sources and
      Recommendations. EPA 842/B-92/010.

    4 U.S. EPA, Office of Wastewater Management. NPDES Stormwater Multi-Sector General Permit for
      Industrial Activities (MSGP).
      www. epa .go v/n pd es/sto rm wate r/msg p
  EPA-833-F-06-040

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