Best Management Practices for Stormwater Compliance

Stormwater compliance must be addressed in your company’s overall environmental strategy. Failing to do so can expose your company to fines and other risks. However, managing stormwater runoff can be a difficult task.

In order to help, we have outlined Best Management Practices (BMPs) for stormwater compliance. These EPA-recommended measures will protect water quality and improve compliance with relevant stormwater regulations.

What Is Stormwater Compliance?

Stormwater compliance requires taking specific action to minimize runoff from melted snow or rainwater. This runoff can reach storm sewer systems or nearby communities or navigable waters. The runoff may contain contaminants. If it does, it can increase your environmental impact.

All stormwater compliance plans must address runoff in several ways. This is because no one solution will completely solve the issue. By using more than one tactic, you can better protect natural resources. In turn, this will reduce your company’s liability.

In the environmental sector, stormwater pollution prevention measures break down into two types of best management practices: structural measures that are tangible and non-structural measures that cannot be touched but are often just as effective to reduce stormwater pollution.

• Structural BMPs: examples include oil-water separators, nutrient separating baffle boxes, velocity dissipation devices, silt fences, riprap, rock dams, or sediment ponds.
• Non-structural BMPs: examples include performing actions such as training personnel, trash/litter pickup, and routine sweeping.

When seeking ways to reduce stormwater runoff in a commercial or industrial setting, you should consider implementing best practices, as outlined by the EPA in their Pollution Prevention Measures and Controls guidelines.

Best Practices for Commercial Stormwater Compliance

1. Which Best Management Practices Fit Your Company?

We recommend establishing BMPs at your company that will effectively reduce the discharge and potential discharge of pollutants in stormwater. Consider these pollution prevention measures:

• Close drain valves when oil is present.
• Store materials and equipment off the ground.
• Inspect the contents of storage containers to prevent overfills during the transfer of the materials.
• Follow proper labeling of all drums, tanks, and other containers.
• Perform materials and equipment handling activities in existing containment systems.
• Conduct manufacturing operations inside where the exposure to stormwater is reduced.
• Train employees in proper material handling protocol.
• Store working fluids and hydraulics in original containers until use.
• Ensure that adequate clean-up material is on-site and readily available to personnel to support spill prevention and response measures.
• Inspect for spills/leaks periodically.
• Contain, clean up, and report spills and leaks immediately.
• Ensure that above-ground storage tanks are housed in roofed concrete containment areas or in secondary containment areas.

2. Establish Good Housekeeping Practices

Good housekeeping practices are designed to maintain a clean and orderly work environment. This will reduce the potential for significant materials to come in contact with stormwater. We recommend the following good housekeeping BMP activities:

• Take preventative measures to ensure that loose refuse and waste are not discharged into nearby receiving waters.
• Cover roll-off dumpsters and/or store them under roofing structures.
• Regularly pick up garbage.
• Have forklift operators inspect their units for oil leaks on a daily basis.
• Keep wooden pallets and raw materials storage areas organized.
• Use drip pans where appropriate.
• Sweep pavement and traffic areas regularly.
• Ensure that significant materials (e.g. drums and containers) are properly stored and kept away from traffic areas.
• Designate storage areas for tools, equipment, chemicals, and supplies.
• Inspect work areas to identify leaks or conditions that could lead to materials discharge.
• Take immediate action if a spill is detected.
• Use the appropriate clean-up material when cleaning up a spill.
• Sweep up and dispose of spent and contaminated absorbents.
• Properly label all containers to show the name and type of the material or substance.

3. Follow Proper Structural Controls

Commercial and industrial companies should implement structural controls to manage runoff at their site. Management of runoff through structural controls, such as vegetated swales or storm drainage systems, ensures controlled flows, management of pollutants, and the preservation of the natural physical characteristics of the receiving waters.

• Ensure that site drainage is over paved, landscape, and vegetated areas.
• Take measures to ensure that the majority of industrial activities occur in indoor areas.
• Set up systems for all stormwater runoff to leave drainage areas via natural sloping or storm drains conveyance systems.
• Route the stormwater runoff to be discharged into drainage swales that are vegetated and equipped with riprap at the base.
• Use structural controls at the swales to prevent erosion and filter out sediment and particulates.
• Contain any leaks and spills of oil, wastes, and other liquid substances through secondary containment measures, including in the form of spill pallets, the building itself, and spill response materials.
• Use the covering for roll-off dumpsters as a structural control to prevent any rainfall from entering the dumpsters.
• Prepare to close the drain at your storm drain system in the event of a spill or leak from trucks or forklifts and during loading and unloading activities.

4. Document Your Preventative Maintenance Measures

Preventative maintenance practices are designed to identify potential problems with equipment and secondary containment measures. This effort helps reduce the failures of each system and the effects that such failures could have on stormwater runoff.

We recommend performing inspection of on-site controls during periodic inspections, as required based on facility operations. Members of your pollution prevention team and/or maintenance team can perform inspections.

Your facility should keep documentation of all maintenance activities that occur on-site. Documentation should include the following:

• Mark the date(s) of inspection and regular maintenance.
• Record the date(s) of discovery of areas in need of repair/replacement.
• Capture the date(s) that the repaired equipment was returned to full service.
• Document the justification for an extended maintenance/repair schedule.

5. Verify Erosion Control Measures

Erosion controls are designed to reduce the movement of sediment from your facility.

All stormwater runoff that leaves the drainage areas of your facility via natural sloping or storm drains conveyance system should be discharged into the drainage swales, which should be equipped with riprap at the base. This will help prevent erosion from the runoff and allow sediment and particulates to settle before exiting your facility.

6. Take Spill Prevention and Response Measures

Companies should focus on high-risk areas where spills could contribute pollutants to stormwater discharges. Employees should focus on spill prevention in all operations. By reducing or eliminating spills of chemicals and/or waste, your team can help minimize the potential for stormwater pollution.

Consider implementing the following spill prevention and response measures and providing personnel with training on these elements:

• Inspect for spills/leaks daily.
• Verify the availability of spill control materials in the storage areas on a periodic basis.
• Contain, clean up, and report spills and leaks immediately;
• Ensure proper use of secondary containment and spill control materials.
• Perform regular inspections of storage container content to prevent overfills during the transfer of materials.
• Properly label all drums, tanks, and other containers that hold chemicals or waste.
• Keep containers away from equipment traffic routes that could damage the container.
• Place containers holding chemicals or waste at least 25 feet away from storm drains.
• Minimize storage areas for chemicals or waste to the extent possible.
• Mark (or post) chemical and waste storage areas.
• Label areas near storm sewers, swales, ditches, down-spouts, or other stormwater collection devices that should not be used for the storage of chemicals or waste.
• Clearly mark containers holding hazardous wastes that require special handling, storage, use, and disposal.
• Provide secondary containment if the on-site storage of a chemical or waste liquid exceeds 55 gallons in any single container.
• Ensure that any pumping/transferring processes involving a chemical or waste liquid are manned at all times to monitor the system for leaks, pump status, and system integrity.
• Focus on how to prevent spills or leaks during loading and unloading operations.

How RSB Environmental Can Help

The best practices outlined above can improve your company’s stormwater compliance plan. However, implementing these tactics may still require some expert guidance. Fortunately, RSB Environmental is here to help.

As top environmental consultants, our firm can create a stormwater compliance plan for your company and help you follow Best Management Practices. Or, if you already have a plan in place, we can assist you in modifying and improving your existing plan to align with BMPs.

Our team is expertly trained in the NPDES (National Pollutant Discharge Elimination System) Stormwater Program managed by the EPA to help you implement the appropriate processes in your new or revised plan.

We invite you to contact us today to schedule a consultation with our team of experts. We look forward to assisting you with stormwater compliance to ensure compliance and avoidance of costly fines and/or penalties.