Fact Sheet: Information on How to Identify Sources of Storm Water Pollutants and the Management Practices Available to Reduce/Prevent Pollutants from Coming in Contact With Storm Water

Wisconsin Department of Natural Resources
Storm Water Discharge Permit Program

Managing Storm Water Discharges from Industry: Preparing a Pollution Prevention Plan

Purpose of the Plan

The general Storm Water Discharge Permit requires a permittee to develop, implement and manage a Storm Water Pollution Prevention Plan. The purpose of the Pollution Prevention Plan is to identify sources of storm water pollutants at your industrial site and the management practices you can take to reduce and prevent pollutants from coming into contact with storm water.

Non-storm water discharges to storm sewers may also be a problem. The Storm Water Discharge Permit does not authorize the discharge of non-contact cooling water, washdown water, wastewater from illicit sanitary sewer connections or other types of non-storm water discharges to storm sewer systems. The Pollution Prevention Plan must identify these types of discharges to storm sewers on your site. You will need to either obtain the appropriate Wisconsin Pollutant Discharge Elimination System (WPDES) Permit, which authorizes the discharge of wastewater or process water to the storm sewer, or identify the steps to eliminate these discharges.

In your Pollution Prevention Plan you will evaluate and recommend which management practices are appropriate and adequate to meet the pollution prevention needs of your specific industrial site. You will also need to develop a schedule for implementing your recommendations. The actions you have identified in your Pollution Prevention Plan to reduce and control storm water pollutants will be your site's "Best Management Practices;" or BMPs, once your Plan is approved by the Department of Natural Resources. You must amend the Plan if there are changes in your outdoor industrial activities which increase exposure of pollutants to storm water.

Content of the Plan

The Storm Water Discharge Permit requires that your Pollution Prevention Plan identify and discuss the following:

• Employees responsible for implementing your Pollution Prevention Plan
  
• A site map showing the direction of storm water flow across your site, all storm water outfall/drainage, outdoor storage material loading areas and paved/building areas
  
• Existing storm water sampling data (if any)
  
• Potential sources of storm water pollutants from "source areas" such as outdoor storage, equipment or processing, unloading and loading areas, outside manufacturing, or raw materials storage, etc.
  
• Non-storm water discharges from air conditioners, process wastewater, non-contact cooling water, etc.
  
• BMPs to control pollutants from various "source areas"
  
• Facility monitoring plan which identifies specific chemicals present on your site which may contaminate storm water runoff, outfalls you plan to sample, and a site storm water inspection process

Required Best Management Practices

There are two categories of BMPs required by the Storm Water Discharge Permit. "Source Area" Control BMPs are designed to prevent storm water from becoming contaminated at a site. When "Source Area" Control BMPs are not feasible or are clearly insufficient, the Pollution Prevention Plan must prescribe appropriate "Storm Water Treatment" BMPs as needed to reduce the pollutants in storm water prior to discharge to waters of the state.

"Source Area" Control Best Management Practices

The goal of using "Source Area" Control BMPs is to minimize or eliminate contact of storm water with the areas of pollutant sources you have identified in your Pollution Prevention Plan. Many of these practices will be simple, non-technical, low-cost approaches to pollution prevention.

At a minimum, the Pollution Prevention Plan must evaluate and recommend actions your industry intends to take in the following areas:

• Good-housekeeping practices such as sweeping, vacuuming, regular disposal of garbage and waste materials, storing materials properly
  
• Preventive maintenance practices including inspection of outdoor equipment and systems on a regular basis and allowing for timely repair prior to leaks or breakdown
  
• Spill prevention and response program which identifies where spills are likely to occur, identifies handling, storage requirements, and spill clean-up procedures
  
• Employee awareness and training program which explains how employees can permit their job to minimize storm water pollution
  
• Visual inspection program which creates a record of inspections confirming that the Best Management Practices are keeping pollutants from getting into storm water

• Sediment and erosion reduction practices such as diversions or stabilizing vegetation
  
• Salt piles must be covered or enclosed
  
• SARA, Title III, Section 313 Water Priority Chemicals outdoor storage areas have special requirements such as berming, covering, curbing -- see general permit.

• Materials coverage
  
• Diversions which minimize contact of storm water with storage areas
  
• Materials enclosure or containment
  
• Storm water collection and re-use

"Storm Water Treatment" Best Management Practices

The primary emphasis of the general Storm Water Discharge Permit is pollution prevention. However, there are some "Storm Water Treatment" BMPs required when pollution prevention is not adequate in controlling pollutants. The following "Storm Water Treatment" BMPs should be considered in your Pollution Prevention Plan if needed:

• Oil/water separators are required if there are significant discharges of storm water contaminated with petroleum products
  
• Traditional storm water treatment practices are required if source area controls are ineffective or impractical and storm water is contaminated by significant amounts of sediment from eroding areas, including bare earth industrial lots. These practices utilize filtration or sedimentation such as filter fences, grassed swales, retention ponds, vegetated buffers, wet detention basins, etc.

Industrial Permit Questions	John Pfender (608) 267-7620
Construction Site Permit Questions	Michelle Schueller (608) 266-7078
Pollution Prevention Plan Questions	Julia Riley (608) 266-8804
Storm Water General Information	Kim Knutson (608) 264-6262 Jim Helm (608) 266-2779

Information Available through the Environmental Protection Agency

The Environmental Protection Agency (EPA) has developed several Storm Water Program documents. You can obtain a copy of the following documents by calling:

National Technical Information Service (NTIS) (703) 487-4650

• Document #PB 922 359 69. Storm Water Management for Industrial Activities: Developing Pollution Prevention Plans and Best Management Practices. EPA 832-R-92-006 (September 1992).
  
• Document #PB 92-227-669. NPDES Storm Water Sampling Guidance Document, EPA 833-B-92-001 (July 1992). This document can also be obtained by calling the EPA Storm Water hotline: (703) 821-4823.

Information Available through the Department of Natural Resources

A Storm Water Pollution Prevention Plan guidance document developed by the Department of Natural Resources (DNR) will be available to all permittees. The DNR is also developing its own Industrial Storm Water Sampling guidance document.

The Wisconsin Construction Site Best Management Practice Handbook is available through Document Sales, (608) 266-3358.

Storm Water Pollution Prevention Planning

In 1987, Congress amended the Clean Water Act to require, in part, that storm water discharges associated with industrial activities be regulated as point sources. The amendment placed a high priority on developing permits for industrial storm water discharges. The Wisconsin Department of Natural Resources (DNR) is in the process of developing administrative rules that will guide how this storm water management program will be carried out. After these rules are adopted, the DNR will finalize and issue the General Permit that was public noticed in December of 1992.

The DNR anticipates that it will start issuing these permits in 1994. The first requirement of the permit will be for industries to develop Storm Water Pollution Prevention Plans for their facilities. To assist industries in the development of this plan, the department has produced a guidance document entitled "Industrial Storm Water Pollution Prevention Planning."

This guidance outlines the major components to be included in the plan and suggestions on how to obtain the information necessary to draft the plan. Please note this guidance document is a draft version and some parts will probably change as the DNR finalizes its program policies. However, the basic planning process set forth in the final manual is expected to remain fundamentally the same as that set forth in this draft guidance. The final version will be available when the permit is issued.

The cost of the draft guidance will be $3.15/copy (includes sales tax). If you are interested in getting a head start on your plan and would like to obtain a copy of this draft guidance, please do the following:

1. Fill out the form below
   
2. Include a check or money order for $3.15 made payable to the Wisconsin Department of Natural Resources
   
3. Include a self addressed mailing label
   
4. Mail the label, form and payment to:

The full address listed above must be used when you send in this form or the order may not be processed!

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