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Executive Summary: It's not always the first thing that comes to mind when thinking of facility maintenance, but achieving and sustaining clean stormwater discharge is incredibly important. Not only is it an environmental danger to let harmful pollutants flow down drains, it’s an ever-present risk for EPA violations and the headaches, fines and lawsuits that come with them.
New Pig Corporation, the world’s leading provider of products to control leaks, drips and spills, knows how serious it is to keep drains pollutant-free. The experts there recently conducted a survey of industrial professionals to learn how well businesses understand the problems presented by contaminated stormwater discharge and the strategies used to mitigate the issue.
The survey found that many companies have a serious lack of stormwater management, especially if they don’t have a trained stormwater expert in the workplace. In another notable takeaway, numerous businesses aren’t taking a full-time approach to protecting drains and other areas subject to stormwater runoff – perhaps to their detriment.
This report features an in-depth look at the survey's key findings.
Professionals from industrial and manufacturing sectors made up just over half (52%) of the March 2019 survey’s 335 respondents. Other businesses represented include those in government, repair, automotive, transportation and construction industries.
Of the participants, 27% were primarily focused on water or stormwater management as part of their duties, and another 27% said someone else at their workplace was focused on the job. Among the respondents who were not chiefly assigned to stormwater management, 62% were still involved in the matter and the selection and purchase of stormwater products.
Since the Clean Water Act was passed in 1977, the EPA, states and local communities have put pressure on industries to ensure clean stormwater discharge with regulations, including the requirements that facilities create Stormwater Pollution Prevention Plans (SWPPP) before they can receive National Pollutant Discharge Elimination System (NPDES) permits.
In extreme cases, knowing violations of the law can lead to criminal convictions and fines in the millions. On top of that, many municipalities have separate rules that govern stormwater discharge.
Still, only 54% of participants said they have a dedicated water or stormwater management employee, with 52% answering that they have an active SWPPP. Of those without a plan, it’s possible some are simply not discharging into a waterway, but polluted stormwater can be a safety issue at any facility.
Additionally, in facilities where no employees are primarily focused on water or stormwater management, only 4% considered their organization’s level of knowledge as “expert,” while 53% said it was “novice.” Businesses like the latter might need more outside help to maintain clean discharge, and even then, they are at greater risk of being out of compliance.
Survey respondents identified numerous areas presenting a potential risk for stormwater pollution, and they also said they believe the easiest place to treat or remove pollution is at both the storm drain and the source of the pollution (57%). These high-risk areas are often where hazards are most visible, making the problems and solutions simple to identify.
A closer look at the approach implemented among those who use stormwater pollution prevention products, however, shows 57% are using them at high-risk drains only, with just 26% using them on all drains and 17% on most drains. But when it comes to the battle against stormwater pollutants, if there’s a drain, there’s a problem.
"But when it comes to the battle against stormwater pollutants, if there's a drain, there's a problem."
High-risk drains, such as those within parking lots or in fuel transfer areas, are central to a protection strategy, but all drains are susceptible to pollution and can take a facility out of compliance if they don’t receive the proper attention. A low-risk drain is still a risk.
Ideally, a facility will have a comprehensive system of stormwater solutions, removing impurities at every source to keep water discharge well within limits. Called a “treatment train,” it’s a customized product system that works in harmony to contain, confine, stop and filter industrial pollutants from entering protected spaces and waters.
For example, at a waste collection area, a heavy metal filter sock can be used around a corroded dumpster, with filter socks and drain filters placed at all nearby drains. When the treatment train works in concert, contaminated water is far less likely.
For more information, New Pig has written an e-book listing the seven critical areas where businesses need to protect storm drains and how to get a start in solving stormwater problems.
Visit a parking lot anywhere, not only at an industrial facility, and it likely won’t take long to find an oily sheen or gasoline rainbows on the pavement. These visible and viscous contaminants are certainly on the minds of the survey respondents, with 83% identifying oils, fuels and grease as the stormwater pollutants they are most concerned about capturing. Trash and debris (39%) and sediments (35%) were distant runners-up.
Unsurprisingly, with 90% of participants saying their sites have parking lots, vehicles were declared the greatest source of stormwater pollution at their sites (62%). They’re right to feel this way, as vehicles generally are the single largest producer of stormwater pollutants at facilities, with the potential for gas and oil to drip from an undercarriage, wheels to track in sediments, copper dust to fall from brake pads and zinc to leech out of wearing tires. Therefore, facilities should be protecting all drains in the path of vehicles, such as those found in driveways, near loading docks and throughout a parking lot – no matter the size of the area.
A majority of respondents said they only maintain, replace or check their stormwater products “whenever there is a problem” (36%), but issues develop slowly, so more frequent maintenance proactively reduces the risk of something happening. Less than half of participants do check their products monthly (26%) or after every storm (10%), which are the recommended intervals.
Part of a holistic approach to stormwater management is around-the-clock drain protection and routine maintenance, but depending on the product being used, that means different things.
If it’s a durable filtration product meant to stand up to all weather conditions and continued use, employees should be able to set it and forget it – for a while, at least. These types of products still need to be checked with regularity, as they will collect pollutants and become oversaturated over time, requiring the product to be cleaned or replaced.
On the other hand, if it’s a drain blocker, it will likely only be used during high-risk events or emergencies because drains still need to let out water, after all. It’s important to use blockers every time in these instances, such as when vehicles are fueling, bulk material is being transferred or waste is being collected.
A large number of people identified that they have dumpsters on-site (77%), but far fewer listed them as a potential source of pollutants (45%). This could be a big oversight, as the experts at New Pig can attest that disgusting “dumpster juice” (a mix of trash, debris, oil, grease, food waste and more) is a credible threat to storm drains.
As the gross concoction of contaminants bakes in the sun and is drenched by rain, it can seep out of even the hardiest dumpster, carrying the pollutants and clogging trash to drains. The containers themselves break down over time, adding dangerous metals to the mix. Bottom line: a big metal box isn’t a full-proof solution.
Among other industrial facility areas with possible pollution sources are loading docks (61% say they are on-site), bulk transfer sites (33%), and stockpiles or outdoor raw materials storage (33%). Depending on the activities taking place in these areas, they deserve just as much attention as those with vehicles or dumpsters. For example, spills are common at loading docks and bulk transfer sites, and some uncovered raw materials may shed pollutants during rainfall.
Judging from New Pig’s survey, many businesses and other entities with outdoor facilities are, on the whole, aware of the risks that stormwater pollutants pose to the environment and their bottom line. But the findings indicate many workplaces can be doing more to protect their drains.
A universal, 24/7 approach is best to ensure clean stormwater discharge, which means protecting all drains, all the time with products. Businesses should look beyond the drain at their facilities, too. Stormwater protection doesn’t necessarily have to be limited to the source and the drain. There are many areas in between where pollutants can be filtered or stopped, making a treatment train comprised of multiple products in different areas the best strategy.
"Stormwater protection doesn’t necessarily have to be limited to the source and the drain.”
Accomplishing the goal of clean stormwater and EPA compliance might take a concerted effort at the outset, but with the right products and strategy, the job is manageable for novices and experts alike – and certainly worth the time.
If a facility is going to release anything but pure, fresh water into receiving waters, it will need a National Pollutant Discharge Elimination System permit. To get that, the facility needs to develop a Stormwater Pollution Prevention Plan (SWPPP).
It's a written document signed by a company executive identifying to the EPA potential activities at the facility that may cause pollution and outlining the practices the facility will use to prevent unpermitted pollution.
As facilities change, so may the SWPPP, so it should be reviewed regularly and amended as needed. At minimum, this should happen each time the NPDES is up for renewal.
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