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Industrial Facilities: Stormwater Pollution
Tuesday, Apr 23rd, 2019
Stormwater pollution is a major concern for many industrial facilities. Fines can be levied against companies that violate stormwater pollution laws. These fines, as well as damage to the local water supply, can be prevented by creating and following a National Pollutant Discharge Elimination System, or NPDES, permit and a Stormwater Pollution Prevention Plan, or SWPPP.
NPDES Permits and SWPPP
Both the NPDES and SWPPP were part of the Federal Water Pollution Control Administration Amendments, which were enacted in 1972, two years after the formation of the Environmental Protection Agency, or EPA. These amendments were created in response to not only the infamous Cuyahoga River fire of 1969, but other similar events. The NPDES permit program helps to address water pollution by regulating the point sources that discharge pollutants into U.S. waters. Essentially, NPDES permits control what pollutants, as well as how much of them, your company can discharge.
Along with the NPDES permit, companies are required to maintain an SWPPP. Unlike the NPDES, which can apply to multiple companies depending on the permit, the SWPPP applies only to a single facility. SWPPPs are a critical part of stormwater pollution management at a facility. The plan covers the following:
- Facility layout
- Inventory of materials that could be exposed to stormwater
- Likely source(s) of pollutants
- History of spills and leaks within the past three years
- Measures and controls that will be implemented to prevent and/or minimize the pollution of stormwater
Following the SWPPP is one of the most critical components of preventing stormwater pollution, and both the company and employees all must participate for it to be successful.
What Causes Stormwater Pollution?
At industrial facilities, there are six types of activities that the EPA has identified as potentially major sources of pollutants to stormwater. Facilities perform some or all these activities, which include:
- Loading and unloading operations
- Outdoor storage
- Outdoor process activities
- Dust or particulate generating processes
- Illicit connections and non-stormwater discharges
- Waste management
Any of these activities that are performed at a facility must be included in the SWPPP, along with the procedures associated with them to reduce or eliminate their pollutant discharges into the stormwater.
If left untouched, stormwater pollution will affect the water we swim and fish in. Some of the consequences of unchecked pollution include damage to aquatic plants, loss of habitat due to trash, and reduction of oxygen in the water. If a facility is discharging into U.S. waters, it should already have both an NPDES permit and SWPPP in place. An SWPPP will include both baseline and advanced best management practices, or BMPs. A baseline BMP is something that can be done quickly and easily, often for free or limited cost. An example would be always replacing and tightening the lids when finished using a chemical. Advanced BMPs require planning and typically a larger budget. For example, an advanced BMP might be building a berm to keep rainwater from flowing into a work area. Facilities will have a mix of baseline and advanced BMPs, and both types are important to preventing stormwater pollution.
Simple Steps to Prevent Pollution
Even if employees don’t play a significant role in the SWPPP, there are still tasks that they can perform to support the plan. Many baseline BMPs could apply to any facility and can be performed on a regular basis by any employee. Some examples include:
- Picking up trash and other debris
- Putting trash and recyclables in the correct collection place
- Keeping lids of outside dumpsters
- Checking storm drains and culverts after a rain event and remove any trash
- Keeping any materials that could wash away, like sand or gravel, covered
Most of these tasks should be performed daily by all employees, particularly making sure to put trash in the right receptacle. Even small efforts like this can make a huge difference in preventing trash from entering nearby water.
In addition to employees participating in waste management, they can also assist with preventing leaks, spills, and the improper use and disposal of chemicals. From fuels and cleaning solvents, to pesticides and fertilizers, it is likely that at some point, every employee will handle a chemical that shouldn’t be entering the stormwater. To help employees decrease their risk of polluting the stormwater, the correct containers should be supplied, and employees should be encouraged to use the smallest size available for the task. In addition, employees should always re-cover any product once they’ve completed a transfer or task. Prevention is always better than trying to contain a spill that has already occurred.
Employers already have a significant number of responsibilities when it comes to preventing stormwater pollution or illegal discharges. One of the most important is performing frequent inspections, at least once per month. This ensures that issues are quickly found and corrected, as well as any BMPs that are not currently sufficient.
Without proper planning, stormwater pollution could easily become a financial catastrophe for an unprepared facility. By planning and ensuring compliance with your NPDES permit and SWPPP, you can prevent a small leak from becoming a big headache.