EPA releases guidance on Storm Water Act compliance

Nonwovens Industry, Feb, 1994 by Peter Mayberry

Late last year, the Environment Protection Agency (EPA) published a lengthy notice in the Federal Register outlining notice in the Federal Register outlining pollution control guidance that may be useful to nonwovens manufacturers in complying with the agency's storm water discharge permit requirements. The notice indicates how the EPA thinks paper and allied product makers should prevent contamination of storm water runoff at their facilities.

While not legally binding on our industry, the notice will assist nonwovens manufacturers in preparing and updating pollution prevention plans required under their facility-specific storm water discharge permits.

INDA, Association of the Nonwoven Fabrics Industry, has circulated a summary of the recent EPA guidelines, as well as a Storm Water Pollution Prevention Plan Guidance Manual (prepared by INDA's legal counsel, Keller & Heckman), to its members to assist them in their efforts to comply with the Storm Water Act provisions.

Storm Water Discharge Permits

Since 1987, federal law has required that industrial facilities, including those operated by nonwovens manufacturers, obtain permits authorizing them to discharge the storm water that runs off of their property.

The EPA is the federal agency responsible for implementing the law and has issued a series of rules that allow facilities to choose one of three different methods of complying: 1) by applying for an individual permit, 2) by participating in a group permit application or 3) by complying with general permit conditions.

State governments also go involved because water pollution control agencies of most states are responsible for implementing the EPA's storm water discharge permit program.

There was no group application for the nonwovens industry, which means that most, if not all, nonwovens manufacturers have either filed an individual permit application or notified the EPA (or a state agency) of their intent to comply with general permit conditions.

The most significant general permit condition is the requirement that facilities prepare a pollution prevention plan. Many states have required facilities that submitted individual applications to prepare pollution prevention plans as well and many INDA members' facilities were required to have prepared storm water pollution prevention plans as early as April 1, 1993. Facilities must update their plans on a regular basis.

The first step in preparing a pollution prevention plan is to identify potential sources of storm water contamination. The plan must then identify best management practices, which the facility will use to avoid such contamination. Those best management practices include preventative maintenance, good housekeeping, spill prevention and response procedures and storm water management controls.

Recent EPA Guidance

Last November, the EPA published a draft "Multi-Sector Storm Water General Permit," which identifies measures that the agency considers to be best management practices for storm water control and for the "Paper & Allied Products Manufacturing" industrial sector. It also contains potential pollution sources and inventories of exposed materials that are common at nonwovens manufacturers' sites.

In the notice, the EPA identifies the following industrial activities common to paper and allied product manufacturing, which nonwoven plants should address in their pollution prevention plans: bactericide use, baghouse, cyclone and dust coating collectors, corrugate, creasing, cutting, equipment storage, vehicle fueling, gluing, rail and truck loading, material handling, printing, access railroads, scoring, stitching, storage areas and taping.

In addition, the notice contains a list of significant materials found on-site at paper and allied products manufacturing plants that could contaminate storm water if improperly handled or accidentally released outdoors. Included in this list are solvents, glues, oils, lubricants, alcohol, starch, wooden pallets, paper roll stock, waxes, air emissions from solvent recovery processes, baled waste paper, dyes, inks, ammonia, biocides, final products, adhesives, paper wastes, resins/polymers, clay slurries and dust particulars from cyclones used in paper trim activities.

The notice contains suggested best management practices for outdoor loading and unloading activities and raw and/or material storage areas where the EPA believes there is the greatest possibility of storm water contamination at paper and allied products manufacturing plants. Specifically, in regard to outdoor loading and unloading, the EPA recommends that steps be taken to: 1) confine loading/unloading activities to a designated response and control area; 2) avoid loading/unloading materials in the rain; 3) cover loading/unloading areas or conduct these activities indoors; 4) develop and implement spill plans; 5) use berms or dikes around loading/unloading areas; 6) inspect containers for leaks or damage prior to loading; 7) use catch buckets, drop cloths and other spill prevention measures; and 8) provide paved areas to enable easy collection of spills.