Ohio EPA has released a guidance document on the elements of salt storage that are relevant to preventing contamination including:
- design, and
The document provides guidance on salt storage practices to prevent the contamination of ground water and surface water. “Salt”, as used here, includes solids such as the popular sodium chloride (NaCl), as well as potassium chloride (KCl), calcium chloride (CaCl2), and magnesium chloride (MgCl2). It also includes mixtures of the same substances with abrasives such as sand, cinder, slag, etc.
Recently, several salt storage operations have been identified by Ohio EPA as the source of high chlorides in public or private ground water supplies. While Ohio has no rules specifically governing the storage of salt, ORC 6111 prohibits unauthorized discharge of pollutants to waters of the state, including runoff from salt storage. Ohio EPA considers brine created from rainfall passing through salt piles to be an industrial wastewater that is subject to permitting requirements. For a new salt storage site, Ohio EPA’s Division of Surface Water (DSW) can require a permit-to-install (PTI) to ensure adequate protection of water quality resources. When complaint investigations or routine audits for existing facilities indicate impacts to water resources due to poor management practices, DSW can take action to address any problems identified. Storm water permitting requirements pursuant to 40 CFR 122.26 and OAC 3745-39 must be met, as well as any local zoning requirements. For salt piles in designated urban areas, best management practices can be required under a Municipal Separate Storm Sewer System Permit (MS4), although there are no specific siting or design criteria. For salt stored at an industrial site, the Industrial Multi-Sector General Storm Water Permit would apply and would require the salt to be properly covered/enclosed. Ohio EPA-DSW can require a National Pollutant Discharge Elimination System (NPDES) permit for any site, regardless of location, if it is aware of pollution. Additionally, characterization and abatement of a release from a salt facility can be required under ORC 6111.04.