Developing a Stormwater Pollution Prevention Plan (SWPPP)

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Developing a Stormwater Pollution Prevention
Plan (SWPPP)
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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 http//www.cicacenter.org/swrln
  ew.cfm

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Getting Started
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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)

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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

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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

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How to Implement a Stormwater Pollution
Prevention Plan (SWPPP)
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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

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Element 1Your Stormwater Pollution Prevention
(P2)Team
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Your team should

• Include those people most familiar with the
  facility and its operations
• Define goals for the facilitys stormwater
  management program
• Be responsible for implementing general permit
  requirements and P2 requirements

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Pollution Prevention Team
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Element 2The Site Assessment and Planning
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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

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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

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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)

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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

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Pre-BMP Site Map
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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

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Material Inventory (contd)
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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 117.3 and 40 CFR 302.4

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Significant Spills and Leaks
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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

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Non-Stormwater Discharge Assessment
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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

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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.

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Summary of Pollutant Sources
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Element 3Selecting Control Measures aka Best
Management Practices (BMPs)
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BMP Selection Plan Design

• Provide a narrative description of the BMPs that
  you have selected for the site

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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

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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

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BMP 2 - Good Housekeeping

• Involves maintaining a clean and orderly work
  site so that pollutants dont 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

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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

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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

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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

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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

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BMP 7 - Salt Storage Piles or Piles Containing
Salt

• Cover and isolate to ensure pile does not come
  into contact with stormwater runoff

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BMP 8 Sector-Specific Requirements

• EPAs 2008 MSGP regulates discharges from 29
  industrial sectors
• Review your general permit to determine if there
  are sector specific discharge requirements

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BMP 9 - Employee Training

• Training program should include topics such as
  spill prevention, good housekeeping,
  recordkeeping, material management practices, etc

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BMP 10 Non-Stormwater Discharges

• Unauthorized non-stormwater discharges cannot be
  discharged from your facility
• Specifically authorized by a separate, individual
  NPDES permit

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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.

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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

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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

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BMP 13 (contd)

• 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

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Element 4Procedures for Inspections and
Monitoring
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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

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Visual Inspections (contd)

• 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

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Visual Inspections (contd)

• Inspection date/time
• Names and signatures of facility personnel
  performing inspection
• Weather conditions
• Any previously unidentified discharges
• Any control measures needing maintenance or
  replacement

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Visual Inspections (contd)

• 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

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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

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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

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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)

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Element 5Completing your SWPPP
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Completing your SWPPP

• Implement the selected BMPs
• Train all employees to carry out the goals of the
  plan

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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

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Plan Evaluation (contd)

• Recordkeeping and internal reporting
• Must maintain records of spills, leaks,
  inspections and maintenance activities
• Plan revisions
• Major changes in a facilitys design and/or
  operation will necessitate changes in SWPP plan

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Endangered Species/Historic Places

• You must include documentation that supports
  endangered species and historic place
  requirements as identified in the MSGP

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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

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Modification of SWPPP

• Modify SWPPP whenever necessary to address any
  changing or additional conditions

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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

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Element 6Keeping Records of Your Implementation
Activities
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Keeping Records

• Document compliance
• 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

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Additional Documentation

• Permit records
• Spill records
• Employee training records
• Maintenance records
• Inspection records
• Monitoring records
• Corrective action records

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Questions?