Stormwater Pollution Prevention Plan (SWP3) Requirements Joe Willingham, P.E. Professional Engineer III Industrial Wastewater Enforcement Section Water Quality Division Department of Environmental Quality

Outline General issues Who needs to sign them When do they need to be submitted to DEQ What needs to be in them How often do they need to be updated

General Issues Requirements listed in Part 4 of OKR10 Must be prepared prior to submission of NOI Should be prepared in accordance with good engineering practices Licensed PE only required for those parts of SWP3 involving the practice of engineering

General Issues Address requirements for support activities Listed in Addendum G of OKR10 Include information on listed or endangered species found in proximity to site

General Issues For sites discharging to receiving waters impaired for sediment Document best management practices (BMPs) used to control pollutants of concern For sites discharging to receiving water with approved Total Maximum Daily Load (TMDL) or watershed plan Document how SWP3 is consistent with it

Making SWP3s Available Should be retained on-site or available upon request Post sign with: OPDES permit number or copy of NOI Name and phone number of contact person Brief description of project Location of SWP3 if site is inactive or lacks on-site location

Signatory Requirements Listed in Part 6.7 NOIs or NOTs Signed by responsible corporate official, general partner or proprietor, principal executive officer or ranking elected officer Reports or other information requested by DEQ Signed by officials above or duly authorized representative

Signatory Requirements Authorized representative Must be made in writing and signed by responsible official Can be named individual or any individual occupying a named position Certification statement in Part 6.7.4 must be included on any signed documents.

Certification Statement

Submitting SWP3s to DEQ Only submit SWP3 to DEQ if the project is located: Within Outstanding Resource Waters Within a Federal and State Aquatic Resource of Concern (ARC) Within a larger site which is disturbing land of 40 or more acres Will be returned unreviewed if not in one of the above areas

Where to Send NOI & SWP3 Department of Environmental Quality Environmental Complaints and Local Services Storm Water Unit 707 North Robinson, P.O. Box 1677 Oklahoma City, OK 73101-1677 FAX (405) 702-6226

Plan Contents Stormwater Team Responsible for SWP3 and permit compliance Must be identified by name or position Must include individual responsibilities Must have access to permit, SWP3, and other documentation Keep a copy of OKR10 and signed NOI with SWP3

Plan Contents Construction Activity Description Include size of property, total area to be disturbed, support activities, and maximum area to be disturbed at any one time Identify all other operators and their areas of control Describe intended construction sequence, including Installation of control measures Schedule of earth-disturbing activities Dates for stabilization of exposed soil

Plan Contents Site Map Must be legible Must include: Boundaries of property and locations of construction activities Locations of waters of the state within 1 mile of site Boundary lines of any natural buffers Site topography, existing vegetative cover, and drainage patterns

Plan Contents Site Map (cont’d) Must include: Stormwater and allowable non-stormwater discharge locations Locations of potential pollutant-generating activities Locations of stormwater control measures Sampling locations for asphalt batch plants, if applicable

Plan Contents Construction Site Pollutants Identify pollutants expected at site Examples: sediment, paint, solvents, fuels, trash, etc. Describe activities generating listed pollutants Examples: paving operations, concrete washout, paint/stucco washout, solid waste disposal, dewatering Account for areas where spills or leaks could occur Document changes from manufacturer’s specifications for fertilizer applications

Plan Contents Endangered Species/Historic Preservation/Water Quality Impaired Waters Document any effect stormwater discharges or stormwater discharge-related activities may have Describe and implement measures to protect endangered species or threatened habitat or meet TMDL/watershed plan requirements Describe how BMPs would reduce and avoid pollutant of concern into any impaired waters

Plan Contents Controls to Reduce Pollutants Includes structural and non-structural Structural examples: silt fence, sediment traps, check dams, etc Non-structural examples: good housekeeping practices, training, etc. Describe control measures and timing for each major activity

Plan Contents Stormwater Control Measures Potential resource: National Stormwater BMP Menu http://cfpub.epa.gov/npdes/stormwater/menuofbmps Minimum requirements: Straw or hay bales as BMPs are NOT allowed Designed to retain sediment on site Must be properly selected, installed, and maintained Follow manufacturer’s specifications and good engineering practices If it is installed, maintain it or remove it

Stormwater Control Measures Minimum requirements: Remove off-site accumulations of sediment to minimize offsite impact Remove sediment from sediment traps or ponds when design capacity has been reduced by 50% Prevent litter, construction debris, and chemicals from becoming a pollutant source Address offsite material storage areas used solely by permitted project

Stormwater Control Measures Stabilization practices Describe vegetative/non-vegetative stabilization practices used for temporary or final stabilization Temporary stabilization - provided during establishment and growth of vegetation and/or when earth-disturbing activities will occur again in future Final stabilization - provides permanent cover and meets termination requirements Soil disturbing activities are complete AND 70% of native background cover established OR Equivalent permanent stabilization measures installed

Stabilization Practices

Stormwater Control Measures Structural Practices Include description Sediment basin requirements Required in areas where ≥10 disturbed acres drain to a common location Must store runoff from a 2 year, 24 hour storm from each disturbed acre OR Must provide 3,600 ft3 of storage per acre drained Use velocity dissipation devices at discharge locations and along outfall channel

Velocity Dissipation

Plan Contents Pollution Prevention Spill prevention and response Include procedures to prevent and respond to spills and leaks Identify name/position of employee responsible for spill or leak detection and response List contact information for facility personnel, emergency response agencies, and regulatory agencies OR reference SPCC plan for site

Plan Contents Pollution Prevention Waste management Include procedures on handling and disposal of wastes including: Sediment Construction waste Hazardous waste Demolition/clearing debris Sanitary waste

Plan Contents Monitoring For discharges subject to numeric limitations (i.e. asphalt batch plants) Identify Locations where samples will be collected Linear projects – can identify substantially identical outfalls Responsible personnel Normal working hours for project Equipment to be used Sample collection procedures

Plan Contents Maintenance BMPs identified in SWP3 must be maintained Conduct maintenance before next anticipated storm event or as necessary to maintain effectiveness Adding or modifying BMPs must be completed prior to next storm event If impracticable, document situation in SWP3, AND Complete as soon as possible after event

Maintenance

Plan Contents Inspections Identify “qualified person” Identify frequency Minimum = once every 14 days and within 24 hours of 0.5 inch rain event or discharge from snowmelt Include inspection form in SWP3 Complete reports within 24 hours of inspection Keep completed reports onsite with SWP3 Must be signed

Note Certification Statement

Plan Contents Training Requirements Ensure personnel understand permit requirements prior to beginning work Minimum topics to cover: Location of stormwater controls Maintenance procedures for stormwater controls Pollution prevention requirements Inspection and documentation procedures Only required for personnel responsible for inspections

Training Log Example from EPA’s SWP3 template Can create your own Must be kept with SWP3

Plan Contents Corrective Actions Involve repair, modification, or replacement of stormwater controls Include clean up and disposal of materials from spills or releases May remedy a permit violation Deadlines for completion – 7 days from time of discovery Document and modify SWP3 as appropriate

Plan Contents Non-Stormwater Discharges Identify those that are combined with stormwater discharges Identify pollution prevention measures Identify location(s) on site map Ensure measures are implemented to reduce and/or eliminate such discharges

Allowable Non-Stormwater Discharges Source: EPA’s SWP3 Template

Plan Contents Contractor Certifications Used at discretion of permittee Not required Places the responsibility for complying with permit requirements and your SWP3 with the contractor Requires contractors to abide by your NOI, SWP3, and BMPs Include this information in SWP3

Examples From EPA’s SWP3 Template From Addendum D of OKR10

Source: http://www.epa.gov/npdes/pubs/exampleswppp_residential.pdf Keeping SWP3s Current Living document Make changes As conditions at the site change When site inspections indicate BMP is ineffective Source: http://www.epa.gov/npdes/pubs/exampleswppp_residential.pdf

Resources EPA’s SWP3 Templates and Examples SWP3 Webcasts http://cfpub.epa.gov/npdes/stormwater/swppp.cfm#report http://www.epa.gov/npdes/pubs/sw_swppp_guide.pdf SWP3 Webcasts http://cfpub.epa.gov/npdes/courseinfo.cfm?program_id=0&outreach_id=308&schedule_id=962

Questions, Comments, Discussion