INDUSTRIAL  STORMWATER
FACT  SHEET SERIES
                                Sector AC: Electronic and Electrical Equipment and
                                    Components, Photographic, and Optical Goods

            U.S. EPA Office of Water
            EPA-833-F-06-044
            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 electronic and electrical equipment
  and components, photographic, and optical goods manufacturing facilities as defined by Standard
  Industrial Classification (SIC) Major Groups 36 and 38 and (SIC 357). Facilities and products in
  this group fall under the following categories, all of which require coverage under an industrial
  stormwater permit.
    4- Computer and Office Equipment (SIC 3571-3579)
    4 Electronic and Electrical Equipment and Components, Except Computer Equipment (SIC 3612-
      3699)
    4 Measuring, Analyzing, and Controlling  Instruments; Photographic and Optical Goods, Watches
      and Clocks (SIC 3812-3873)


  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 AC: Electronic and Electrical Equipment and Components,
Photographic, and Optical Goods Manufacturing Facilities
  What pollutants are associated with my facilities activities?
  Pollutants conveyed in stormwater discharges from facilities involved with the manufacturing of
  electronic and electrical  equipment and components, photographic, and optical goods 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 activity at the types of facilities discussed here are
  normally done indoors and will not be exposed to stormwater. The types of activities where exposure
  to stormwater may occur consist primarily of loading/ unloading activities, and the storage and
  handling of raw materials, by-products, final products or waste products. A  wide variety of materials
  are used at these facilities  including metals,  acids used for chemical etching, alkaline solutions,
  solvents, various oils and fuels and miscellaneous chemicals. Tanks or drums of these materials may
  be exposed to stormwater during loading/un-loading operations, or through outdoor storage or
  handling at some facilities.

  Liquid wastes which may be exposed at least temporarily include spent solvents and acids,
  miscellaneous chemicals and oily wastes. These wastes may be contaminated with a variety of heavy
  metals and chlorinated hydrocarbons.  Used equipment, scrap metal and wire, soiled rags and sanding
  materials may also be exposed to stormwater and constitute a potential source of pollutants. In
  addition, some facilities  may have dumpsters containing nonhazardous wastes or manufacturing
  debris which may be exposed to stormwater.

  The activities, pollutant  sources, and pollutants detailed in Table 1 are commonly found at electronic
  and electrical equipment and components, photographic, and optical goods manufacturing facilities.

  Table 1. Common Activities, Pollutant Sources, and Associated Pollutants at Electronic and Electrical
  Equipment and Components, Photographic, and Optical Goods Manufacturing Facilities
Activity
Outdoor material loading/
unloading
Outdoor material and
equipment storage
Pollutant Source
Wooden pallets, spills/leaks from material
handling equipment, raw materials, finished
products, solvents
Sulfuric acid, alkaline solutions, solvents
miscellaneous chemicals, oily wastes, lead ,
silver, copper, zinc, spent solvents and acids,
scrap metal and wire, oily rags
Pollutant
Total suspended solids (TSS), oil and
grease, organics
Organics, oil and grease, acids,
alkalinity, 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 electronic and electrical equipment and components, photographic, and
  optical goods manufacturing 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
  EPA 833-F-06-044

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector AC: Electronic and Electrical Equipment and Components,
Photographic, and Optical Goods Manufacturing Facilities


  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 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
  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.
  EPA 833-F-06-044

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector AC: Electronic and Electrical Equipment and Components,
Photographic, and Optical Goods Manufacturing Facilities


  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 electronic and
  electrical equipment and components, photographic, and optical goods 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 electronic and electrical
  equipment and components, photographic, and optical goods 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 Electronic and Electrical Equipment and
  Components, Photographic, and Optical Goods Manufacturing Facilities
   Pollutant Source
BMPs
   Outdoor material loading
   and unloading
Q  Confine loading/unloading activities to a designated area outside drainage pathways
   and away from surface waters.

FJ  Perform loading/unloading activities indoors or in a covered area.

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

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

FJ  Avoid loading/unloading materials in the rain.

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

Q  Provide overhangs or door skirts to enclose trailer ends at truck loading/unloading
   docks.

Q  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  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.

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

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

Q  Train employees on proper loading/unloading techniques and spill prevention and
   response.
   Outdoor material storage
   Cover storage areas with roofs or tarps.

   Confine storage of raw materials, parts, and equipment to designated areas away
   from high traffic, outside drainage pathways and away from surface waters.

   Provide secondary containment around chemical storage areas.
  EPA 833-F-06-044

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector AC: Electronic and Electrical Equipment and Components,
Photographic, and Optical Goods Manufacturing Facilities
  Table 2.  BMPs for Potential Pollutant Sources at Electronic and Electrical Equipment and
  Components, Photographic, and Optical Goods Manufacturing Facilities (continued)
   Pollutant Source
BMPs
   Outdoor material storage
   (continued)
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.
Q  Provide diversion berms, dikes or grassed swales around the perimeter of the area to
   limit run-on.
Q  Direct stomrwater runoff to an on-site retention pond.
FJ  Ensure that all containers are properly sealed and valves closed.
FJ  Conduct container integrity testing and provide leak detection.
FJ  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.
FJ  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.
FJ  Train employees on proper waste control and disposal.
   Waste management
FJ  Store waste in enclosed and/or covered areas.
FJ  Store wastes in covered, leak proof containers (e.g., dumpsters, drums).
FJ  Cover the dumpsters or move them indoors.
FJ  Use linked dumpsters that do not leak.
FJ  Provide a lining for the dumpsters.
FJ  Direct runoff to on-site retention pond.
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.
   Particulate emission
   management
FJ  Clean around vents and stacks.
FJ  Place tubs around vents and stacks to collect particulates.
FJ  Inspect air emission control systems (e.g., baghouses) regularly and repair or replace
   when necessary.
  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.
  EPA 833-F-06-044

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INDUSTRIAL STORMWATER  FACT SHEET SERIES
Sector AC: Electronic and Electrical Equipment and Components,
Photographic, and Optical Goods Manufacturing Facilities


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

  A list of names and telephone numbers for each EPA Region or state NPDES permitting authority can
  also be found at this link. Click on "contacts" to find the appropriate contact information.

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

     4  City of Phoenix, Arizona, Street Transportation Department. 2004. Best Management Practices
        for Section AC—Electronic & Electrical Equipment or Components, Photographic & Optical
        Goods Manufacturers.
        http://phoenix.gov/STREETS/eleltrnic.pdf

     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  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 Region 9. 1999. Oil/Water Separators: Best Environmental Practices for Auto Repair
        and Fleet Maintenance.  EPA-909-E-99-001.
        www.epa.gov/reg ion09/cross_pr/p2/autofleet/separator.pdf

     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-06-044

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