Industrial Facilities

An empty warehouse featuring bare concrete floors and a high ceiling, creating a spacious and industrial atmosphere.

Industrial facilities manage, conduct and control manufacturing, sanitation and development operations in San Antonio. Industrial facility operators work with the City of San Antonio, the San Antonio Water System (SAWS), and other entities to monitor and regulate industrial activities. All facilities retain a responsibility to prevent pollutants from contaminating stormwater runoff.

Implementation of Best Management Practices (BMPs) in facility operations, procedures and employee training helps protect stormwater runoff from industrial chemical pollutants. San Antonio's Phase I Municipal Separate Storm Sewer System (MS4) stormwater discharge permit regulates and prohibits pollutant discharges that contaminate rivers, creeks and channels as a result of industrial activities.

Operational Priorities for Industrial Facilities

River-friendly industrial facility operations focus on the following priorities:

  • Prevent runoff from contacting work areas, including shipping, loading, cargo areas, equipment storage and operations.
  • Prevent rainfall from reaching work areas by using roofs, structures or indoor operations.
  • Avoid practices where used water or wastewater enter storm drains from outdoor washing.
  • Keep industrial pollutants and byproducts from coming into contact with water.
  • Identify facility areas where stormwater, wash water or cooling water may discharge into storm drains.
  • Contain and clean all minor leaks and spills.
  • Evaluate operating procedures and equipment to identify pollutant exposure risks, and revise procedures to reduce or eliminate them.
  • Manage necessary pollutant contact with stormwater by using measures to remove or reduce pollutants before discharge.

BMPs for Industrial Facilities

By adopting BMPs, industrial facilities can help reduce or eliminate stormwater runoff pollutants from reaching San Antonio's rivers, creeks and waterways.

Review BMPs recommended for industrial facilities, along with information and resources on the Municipal Separate Storm Sewer System (MS4) permit and stormwater regulations, in the following sections:

Building Maintenance & Grounds Upkeep

  • Seek to utilize building and grounds maintenance methods which require minimal amounts of water, utilize dry sweeping and remove illicit debris from the ground.
  • If pressure washing outdoor areas at your facility, water discharges may not enter the storm drains. Block storm drain inlets prior to washing and capture recovered wash water for proper discharge into the sanitary sewer.
  • Position rooftop drains and downspouts so that rainfall does not drain directly onto paved surfaces - these can either be connected directly to the storm drain inlet or allowed to flow onto a grassy surface large enough to accept the roof's entire runoff volume.
  • Storm drain inlets and catch basins around your facility should be periodically cleaned and cleared of debris. Storm drain inlet/catch basin cleaning and inspection should occur following any large storm, flooding, or other inclement weather condition.

Employee Training & Education

  • Incorporate stormwater management practices into Standard Operating Procedures (SOPs) and train employees.
  • Include routine inspections of industrial activities and equipment exposed to stormwater runoff as part of training.
  • Use trained, experienced staff to train new hires and conduct facility-wide SOP reviews at least annually.
  • Pair stormwater training with safety training on hazardous waste management, storage and proper disposal.
  • Periodically assess work practices and correct stormwater BMPs that are not being implemented properly.
  • Post BMP reminder signage (e.g., proper wash practices, keep dumpster lids closed, never discharge to street or storm drain).

Fleet & Vehicle Maintenance

  • All equipment maintenance should be performed in an indoor garage facility and not in an outdoor parking area. If outdoor maintenance is necessary, vehicles and equipment should be serviced within a designated area for vehicle repair.
  • Regularly clean maintenance tools; avoid allowing buildup of grease and oil which can be washed away with runoff if maintenance tools are exposed to rainfall.
  • Utilize drip pans or catch containers for placement under vehicles where automotive repairs are being performed in order to prevent spread of accidental fluid leaks or spills during repair.
  • Periodically inspect facility parking and storage yards where equipment is housed for fluid leaks as evidenced by ground staining. Keep equipment yards clear of debris and dry sweep areas while avoiding water hosing.

Fleet Vehicle & Equipment Fueling

  • Design and operate fueling areas to minimize spills and prevent leaked fluids from contacting stormwater runoff.
  • Use a paved area or concrete slab for fueling - do not fuel on open ground; concrete is preferred to asphalt, which can deteriorate with exposure to leaks.
  • Clean accidental gasoline overflows and fuel spills with absorbent, dry-sweeping methods; never wash spills away with hose water.
  • Post signs instructing pump operators, fleet drivers and equipment operators to avoid topping off tanks. Inspect fueling areas daily for gasoline, motor oil, or other fluid leaks and clean as prescribed.

Outdoor Equipment Operations & Maintenance

  • Identify all equipment at your facility that may be exposed to stormwater runoff or could discharge pollutants that contact runoff. Train employees on the chemical pollutants associated with each piece of equipment.
  • Assign employees to regularly monitor and inspect each piece of equipment to maintain clean, proper operation. Equipment should be inspected for leaks and discharges - procedures should direct employees to report spills immediately, initiate proper cleanup and ensure repairs are completed to prevent future leaks.
  • Station outdoor equipment on an impermeable surface or place drip pans beneath potential leak points. Consider roof covers over equipment and install berms to prevent both run-on and runoff. Equipment involved in wet processes where wash water or process liquids are released should be on a paved surface with a connection to the sanitary sewer.
  • Connect air compressors and other equipment that produce blow-down water to the sanitary sewer, or use drip pans to prevent leakage onto unpaved surfaces or into runoff.

Outdoor Materials Storage & Handling

  • When handling bulk solid materials outdoors, keep materials properly covered and held in appropriate containment which will protect them from storm water and inclement weather exposure. Proper storage of outdoor solid materials should include raw materials, manufactured products, by-products and construction materials, especially gravel, sand, lumber, topsoil, compost, concrete, packing materials and metal products.
  • Preferred method for storage of outdoor materials is on a paved surface with a roof or top covering in order to prevent exposure to direct rainfall, along with appropriate berms or mounding to prevent storm water run-off. For temporary storage, place material on a paved surface and cover with durable tarps or plastic sheeting secured with weights or ropes. Temporary storage areas should be located on a mounded or bermed area that will prevent storm water run-off and contact with material.
  • Sweep parking lots and other surfaces near bulk materials storage areas periodically and avoid tracking materials off-site.
  • Liquid storage containers should be kept in a designated area on a paved impermeable surface and within a berm or secondary containment. Containers should be regularly inspected for leaks or structural damage, and any leaks or spills detected should be resolved immediately through proper spill cleanup methods and leak repair.

Preventing Illicit Discharges to Storm Drains

  • Recognize two types of unauthorized discharges:
    • Illicit connections - improper plumbing or connections that route wastewater to storm drains.
    • Illegal dumping - discharging wastewater or materials (e.g., wash water, chemicals, process water) to storm drains, catch basins or streets.
  • Establish and enforce proper collection and disposal procedures for waste/wash waters and other waste materials; identify locations where they occur and pose risks to storm drains.
  • Label storm drain inlets and nearby catch basins with deterrent markers reminding staff that runoff drains to rivers and waterways.
  • Inspect on-site storm drain inlets regularly and remove debris from nearby catch basins to prevent wash-in.
  • Consider on-site inlet insert filters designed to capture pollutants typical of your facility's operations.

Spill Prevention, Containment & Cleanup

  • Prepare and have ready a clear, defined set of contingency procedures for responding to chemical, material or by product spills at your facility; ensure that your employees are well-trained on cleanup procedures.
  • All spills should be cleaned up promptly and not allowed to evaporate or allow pollutants to soak into pavement where trace amounts can be washed into the storm drain or seep into soil as a groundwater pollutant. If pollutants do enter soil, determine if the soil itself requires removal in order to prevent future pollutant exposure to runoff.
  • Minor spill cleanups such as leaks and drips should employ dry cleaning methods as much as possible (application of absorbent materials such as cat litter, sawdust and dry sweeping) - hosed water should not be used to clean up a spilled area, as wash water only removes the liquid while spreading the pollutant out to a larger area.
  • Small spills which are mopped up with a shop rag or similar material should not be placed wet into a dumpster with regular trash, nor should disposable paper towels be used. Spill rags should be stored in a covered bin for dry-out and reuse; rags should never be used to mop up gasoline, solvents or other volatile chemical liquids.
  • For mid-size spills on regular facility floor surfaces, employ absorbent dry sweeping as with small spills. Spilled material can also be wet-dry vacuum cleaned to collect liquid for proper disposal with liquid or hazardous wastes. Vacuums should not be used to clean up gasoline, solvents or volatile chemicals as they may pose an explosion hazard to the vacuum itself.
  • Large spills requiring containment should seek to clean up spilled liquid with minimal amount of wash water used. In the event of a large spill, place temporary barriers, plugs or covers over nearby storm drain inlets until spill has been completely cleaned.
  • Hazardous product or waste spills should be addressed immediately through established emergency procedures and notification of the San Antonio Fire Department for emergency hazmat response.

Trucking & Shipping/Receiving

  • Load and unload raw materials and industrial-use products only at designated loading areas to isolate and effectively control any accidental spill or leakage.
  • For facilities that must use an outdoor loading dock instead of an indoor bay, cover the dock area with a roof overhang or top cover and use a door skirt that fits between the building and truck cargo doors.
  • Install curbs or berms around the loading area to help prevent storm water run-on and runoff in the event of spilled materials.
  • Assign the delivery driver or facility receiver accepting the shipment to inspect the delivery vehicle for leaked motor fluids, spilled materials or foreign debris while on-site at your facility.
  • Have facility maintenance teams on standby in the event of an accidental spill during cargo delivery.
  • Deliver and handle liquids and hazardous waste materials in accordance with all facility guidelines and in compliance with city, state and federal requirements.
  • When parking heavy trucks or equipment, periodically inspect parking and loading lots for signs of automotive fluid leaks. If leaks are detected, immediately activate proper cleanup procedures and expedite repair of the leak source.
  • Designate assigned parking spots for individual vehicles so detected leak spills can be effectively traced to a specific vehicle.

Waste Handling & Disposal

  • Place general shop trash in a dumpster with the lid closed. Position dumpsters on paved areas - not on unpaved soil or grassy areas. Regularly clean areas around dumpsters, but do not hose dumpsters with water. Because most dumpsters leak, keep lids closed or place a roof cover over dumpsters to keep rainfall out.
  • Keep scrap metals and materials under a roof, cover or indoors so rainfall runoff does not contact metals and pick up trace amounts of pollutants such as mechanical oil or fluids.
  • Properly dispose of hazardous waste through an approved hazardous-waste drop-off/collection facility in accordance with city, state and federal requirements. Until transported off-site, keep hazardous wastes indoors or under sufficient cover in secured areas and in properly labeled, sealable containers (e.g., empty oil cans, paint buckets, aerosol cans), as well as hazardous waste materials from vehicle maintenance.

Resources

Local
State
Federal

United States Environmental Protection Agency (EPA)

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