1. Developing a Stormwater Pollution Prevention Plan (SWPPP)

2. Introduction Information needed for developing a SWPPP
Step-by-step process for ensuring that pollutants are not making their way into the stormwater discharges from your site
Stormwater Locator 2

3. Getting Started

4. Must We Develop a SWPPP?
Clean Water Act requires operators of “discharges associated with industrial activity” obtain a NPDES
Most industrial stormwater discharges are covered under general permits. In order to submit a SWPPP, the following must occur in this order…
Read general permit and determine eligibility for permit coverage
Develop a SWPPP
Submit Notice of Intent (NOI) 4

5. What is Stormwater? Water from rain or snowmelt
Does not immediately infiltrate into the ground
Flows over or through natural or man-made storage or conveyance systems
Results in increased surface runoff
Picks up industrial pollutants
Discharges into nearby waterbodies or stormwater sewer systems 5

6. Major Sources for Pollutants in Stormwater
Loading and Unloading Operations
Exposed Storage (outdoors or open to runoff)
Exposed Process Activities
Dust or Particulate Generating Processes
Illicit Connections and Non-Stormwater Discharges
Waste Management

7. How to Implement a Stormwater Pollution Prevention Plan (SWPPP)

8. Elements of a SWPPP A typical SWPPP includes the following elements:
Stormwater Pollution Prevention Team
Site Assessment and Planning
Selecting Control Measures
Procedures for Inspections and Monitoring
Completing your SWPPP
Keeping Records of Your Implementation Activities

10. Element 1 Your Stormwater Pollution Prevention (P2)Team

11. Your team should…
Include those people most familiar with the facility and its operations
Define goals for the facility’s stormwater management program
Be responsible for implementing general permit requirements and P2 requirements 11

12. Pollution Prevention Team

13. Element 2 The Site Assessment and Planning

14. Purpose
The purpose of the site assessment is to look at your facility and determine what materials and activities are a source of contamination to the stormwater running off the site 14

15. The Site Assessment Conduct an assessment of activities:
Detailed walk through to create a site map
Identify locations where industrial materials or material handling activities take place
Inventory of materials and pollutants
Locate areas with spill or leak potential
Identify non-stormwater discharges
Evaluation of the sampling data for the site
Site evaluation summary 15

16. The Site Description - Maps
Include a general location map and also a site map that indicates the following:
Flow directions of runoff
Storm drains / inlets and outfalls (i.e., locations where stormwater exits the property, including pipes, ditches, swales and other conveyance structures) 16

18. Site Map - Locations of Other Features
Footprint of significant structures and impervious surfaces
Nearby receiving waters (indicate their impairment status)
Stormwater conveyances, BMPs & monitoring points
Exposed materials, significant spills & other potential pollutant sources
Industrial activities (fueling stations, loading and unloading areas, vehicle maintenance areas, waste handling areas, processing & storage areas)
Sources of run-on from adjacent properties containing significant quantities of pollutants

20. Pre-BMP Site Map 20

22. Site Assessment – Material Inventory
Identify and inventory industrial materials and activities exposed to stormwater, and their associated potential pollutants:
raw materials
intermediate products, by‑products, final products & waste products
material handling equipment or activities
industrial machinery
industrial production and processes
pollutants such as crankcase oil, cleaning solvents, etc.
Provide description of materials management practices:
treatment practices and structural / nonstructural control
measures 22

25. Material Inventory (cont’d)

26. The Site Assessment – Spills and Leaks
Document where potential spills and leaks could occur and the corresponding outfalls
Document all leaks/ spills containing a hazardous substance or oil in a reportable quantity for the past 3 years
An Reportable Quantity (RQ) for oil is the amount of oil that violates applicable water quality standards or causes a film / sheen / discoloration of the water surface or shoreline, or causes a sludge / emulsion beneath the water surface or on adjoining shorelines
For other substances RQ levels are expressed as pounds released over any 24 hour period and are listed at 40 CFR and 40 CFR 302.4 26

27. Significant Spills and Leaks

29. The Site Assessment Non-Stormwater Discharges
Identify all potential sources of non-stormwater discharges
Examples of allowable non-stormwater discharges:
Discharges from fire-fighting activities
Potable water, including water line flushings
Routine external building washdown that does not use detergents
Examples of unauthorized non-stormwater discharges:
Surfactant-laden washwater
Sewage cross connection
Demonstrate & certify unauthorized discharges have been eliminated
Describe the evaluation method used and test results
Indicate the location of the evaluation
Provide the date of the test or evaluation

30. Non-Stormwater Discharge Assessment

31. Site Assessment - Evaluate Sampling Data
Evaluate any stormwater data sampling available from the past 5 years
Identify or pinpoint any pollutants of concern, hotspots, or control measures that are not functioning correctly.
Useful for selecting BMPs 31

32. The Site Assessment - Site Evaluation Summary
Becomes the foundation for the SWPPP.
Identify & locate on-site industrial materials and activities.
Determine whether the materials and activities may contaminate stormwater discharges.
Use the information to develop a plan to reduce or eliminate discharge impacts to protect receiving water quality.

33. Summary of Pollutant Sources

34. Element 3 Selecting Control Measures aka Best Management Practices (BMPs)

35. BMP Selection & Plan Design
Provide a narrative description of the BMPs that you have selected for the site 35

36. BMP Selection & Plan Design
Minimize Exposure
Good Housekeeping
Maintenance
Spill Prevention and Response Procedures
Erosion and Sediment Controls
Management of Runoff
Salt Storage Piles or Piles Containing Salt
Sector-Specific Requirements
Employee Training
Non-Stormwater Discharges
Waste, Garbage, and Floatable Debris
Dust Generation and Vehicle Tracking of Industrial Materials
Numeric Effluent Limitations Based on Effluent Limit Guidelines
Additional Controls to Address Impaired Waters

37. BMP #1 – Minimize Exposure
Minimize exposure of manufacturing, processing, material storage areas, unloading areas, dumpsters and other disposal areas.
Move industrial materials and activities inside or protect them with storm resistant coverings.
Try to minimize the creation of new impervious surfaces 37

38. BMP #2 - Good Housekeeping
Involves maintaining a clean and orderly work site so that pollutants don’t have a chance to enter stormwater, such as...
Improving operations and maintenance of industrial machinery and processes
Implementing careful material storage practices
Scheduling routine cleanup operations
Maintaining up-to-date inventory control 38

39. BMP #3 - Preventive Maintenance
Develop a program that ensures BMPs and industrial equipment are kept in good condition to prevent /minimize releases of pollutants:
Regularly inspect and maintain equipment; include schedules
Recommend keeping a maintenance log
Make equipment/BMP repairs before next rain event
Equipment (tanks, drums, hoses) should be checked for signs of deterioration

41. BMP #4 - Spill Prevention & Response Procedures
Minimize the potential for leaks/spills that may be exposed to stormwater
Label containers (e.g., “Used Oil”) that could be susceptible to spillage
Implement barriers between material storage and traffic areas, secondary containment provisions, and procedures for material storage and handling
Have procedures for expeditiously stopping, containing, and cleaning up leaks/spills
Train employees

42. BMP #5 - Erosion and Sediment Controls
The SWPPP plan should identify activities that present a potential for significant soil erosion
Grading
Seeding
Mulching
Sodding
Sediment traps
Silt fences
Sediment ponds
Stabilized entrances

43. BMP #6 - Management of Runoff
Management of runoff reduces pollutants that are discharged from the site
Employ structures, practices intended to divert, infiltrate, reuse, or otherwise reduce stormwater runoff
Must be site-specific
Vegetative swales
Berms
Collection and reuse of stormwater
Inlet controls
Snow management
Inflitration devices
Wet retention measures

46. BMP #7 - Salt Storage Piles or Piles Containing Salt
Cover and isolate to ensure pile does not come into contact with stormwater runoff

47. BMP #8 – Sector-Specific Requirements
EPA’s 2008 MSGP regulates discharges from 29 industrial sectors
Review your general permit to determine if there are sector specific discharge requirements

48. BMP #9 - Employee Training
Training program should include topics such as spill prevention, good housekeeping, recordkeeping, material management practices, etc…

49. BMP #10 – Non-Stormwater Discharges
Unauthorized non-stormwater discharges cannot be discharged from your facility
Specifically authorized by a separate, individual NPDES permit

50. BMP #11 - Waste, Garbage, and Floatable Debris
Stormwater must not carry waste, garbage and debris to receiving waters.
Identify and implement control measures to keep exposed areas free of such waste.

51. BMP #12 - Dust Generation and Vehicle Tracking of Industrial Materials
Minimize generation of dust and off-site tracking or raw, final or waste materials
Sprinklers/irrigation
Vegetative cover
Mulch, tillage, stone
Wind breaks
Spray on chemical soil
treatments

52. BMP #13 - Numeric Effluent Limitations Based on Effluent Limit Guidelines
Federal effluent limits are maximum concentrations of a specific pollutant allowed in a discharge
Exceedance is a permit violation

53. BMP #13 (cont’d) Applies to runoff from:
Spray down / intentional wetting of logs at wet deck storage areas
Phosphate fertilizer manufacturing
Asphalt emulsion facilities
Cement manufacturing facilities
Mine dewatering discharges at crushed stone, construction sand and gravel, or industrial sand mining facilities
Hazardous waste and non-hazardous waste landfills
Coal storage piles at steam electric generating facilities to runoff from phosphate fertilizer, asphalt emulsion, material storage piles, mine dewatering discharges, waste landfills, and coal storage piles

54. Element 4 Procedures for Inspections and Monitoring

55. Visual Inspections
Regular visual inspections are a means to ensure that all elements of the plan are in place and working properly
Designate qualified, trained plant personnel to perform inspections
Track results, make changes and maintain records of results
Records must reflect when, who and what was found

56. Visual Inspections (cont’d)
Perform visual inspections (observation and recording of results) quarterly
Must have an inspection schedule in SWPPP
Annually, must perform visual inspection when a stormwater discharge is occurring
Must make necessary changes to facility control measures as a result of inspection 56

58. Visual Inspections (cont’d)
Inspection date/time
Names and signatures of facility personnel performing inspection
Weather conditions
Any previously unidentified discharges
Any control measures needing maintenance or replacement 58

59. Visual Inspections (cont’d)
Any incidence of non-compliance observed
Any additional control measures needed to comply with permit
1st 30 minutes of a storm event that involves a discharge (or as soon as practicable) visually inspect stormwater sample in clear container at each discharge point and look for:
color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, other obvious pollution

61. 61 Describe Corrective Actions Area/Activity
Inspected?
Controls Adequate (appropriate, effective, and operating)?
Corrective Action Needed and Notes 1
Material loading/unloading and storage areas
Yes No  N/A
Yes No
Describe Corrective Actions 2
Equipment operations and maintenance areas 3
Fueling areas 4
Outdoor vehicle and equipment washing areas 5
Waste handling and disposal areas 6
Erodible areas/construction 7
Non-stormwater/ illicit connections 8
Salt storage piles or pile containing salt 9
Dust generation and vehicle tracking 10
(Other) 11 12 61

62. Monitoring Data Controlled Samples sent to a certified laboratory
Monthly
Quarterly
Annually
Submit reporting data to EPA within 30 days of laboratory results
Annual report to EPA Reporting
Additional reporting to EPA includes:
spills, leaks,
releases of hazardous substances/oil
oral report within 24 hours of noncompliance that endangers health/environment
5 day follow-up report to the 24 hour oral report
any planned changes to your facility
anticipated non-compliance
Transfer of ownership
The need to correct information on the Notice of Intent 62

64. Required Monitoring
Quarterly benchmark – parameters depends on SIC code
Annual effluent limitations – parameters depends on regulated activity
State or Tribal requirements – depends on facility location
Annual impaired waterbody – depends on impairment (s)
Additional monitoring required by EPA – if notified by EPA 64

66. Reporting
All monitoring date must be submitted to EPA within 30 days of lab results
Additional reporting includes:
Spills, leaks, releases of hazardous substances
Oral report of non-compliance within 24-hours
5-day follow-up written report
Annual report on SW must be submitted (standard form may be used)

67. Element 5 Completing your SWPPP

68. Completing your SWPPP Implement the selected BMPs
Train all employees to carry out the goals of the plan

69. Plan Evaluation
Annual site compliance evaluation must include the following:
Inspect stormwater drainage areas
Evaluate the effectiveness of BMPs
Ensure proper operation of structural measures (traps, ponds, etc.)
Revise the plan, if needed, within 2 weeks
Prepare a report summarizing inspection results
Sign the report and keep it with the plan

70. Plan Evaluation (cont’d)
Recordkeeping and internal reporting
Must maintain records of spills, leaks, inspections and maintenance activities
Plan revisions
Major changes in a facility’s design and/or operation will necessitate changes in SWPP plan

71. Endangered Species/Historic Places
You must include documentation that supports endangered species and historic place requirements as identified in the MSGP

72. Certification and Submission of SWPPP
Date and sign SWPPP
Include a copy of the Multi Sector General Permit (MSGP) attached to your SWPPP
The confirmation letter you receive from the Notice of Intent (NOI) processing center is not sufficient

73. Modification of SWPPP
Modify SWPPP whenever necessary to address any changing or additional conditions 73

74. SWPPP on the Internet
For first time MSGP applications (i.e., new dischargers, new sources, other eligible dischargers), you must post your SWPPP on the internet
By posting on internet the discharge authorization date granted from EPA could be 30 days instead of 60 days

75. Element 6 Keeping Records of Your Implementation Activities

76. Keeping Records Document compliance Conduct inspections
Within requirements of your permit
Conduct inspections
Keep records of activities
Keep records of corrective actions
Ensure reliable reports kept on-site with your SWPPP
Accessible, complete, up-to-date

77. Additional Documentation
Permit records
Spill records
Employee training records
Maintenance records
Inspection records
Monitoring records
Corrective action records 77

78. Questions?