Stormwater Pollution Prevention Plans (SWPPPs): Keeping Your Plan Compliant
If your facility performs industrial activities outside or has outdoor storage, there is a good possibility that you are applicable to general industrial stormwater permitting. Whether you are familiar with the requirements of your industrial stormwater permit or are looking to apply for permit coverage for the first time, all general industrial stormwater permittees are required to develop a stormwater pollution prevention plan, or SWPPP as it is commonly known. This plan outlines important details about your facility and how your facility intends to comply with your stormwater permitting requirements.
Your SWPPP and its supporting documents are some of the first things that inspectors will look at when assessing your facility for compliance. It is crucial to make sure that your SWPPP meets all regulatory requirements and stays up to date. Whether you are developing your first SWPPP or reviewing your current one, below are some items you don’t want to miss including.
Common SWPPP Requirements
Pollution Prevention Team
First and foremost, your SWPPP needs to identify who at your facility will be responsible for both developing the SWPPP and carrying out the requirements of your stormwater permit. Their responsibilities include, but are not limited to, completing inspections and sampling, conducting corrective actions when permit non-compliance occurs and updating the SWPPP when changes occur onsite.
Assessment of Onsite Storage and Activities
All SWPPPs need to identify what industrial activities at your facility have the potential to impact stormwater. The EPA defines industrial materials or activities that need to be considered under 40 CFR 122.26(g). These include activities such as:
- Material handling equipment or activities (including the storage, loading and unloading, transportation, disposal, or conveyance of any raw material, intermediate product, final product, or waste product);
- Industrial machinery;
- Storage and handling of raw materials;
- Industrial production and processes; and
- Intermediate products, by-products, final products, and waste products.
Make sure that you are considering all of your outdoor activities and storage when making this list. Everything from occasional equipment maintenance to exhaust stacks from processing areas, and something as simple as uncovered dumpsters to loading and unloading practices should be listed in your SWPPP.
Once you have identified your industrial activities and materials that take place in outdoor areas exposed to stormwater runoff, you will also need to identify what potential pollutants are associated with each. For example, a fueling station onsite would have the potential to pollute stormwater with oil and grease. Similarly, a scrap metal dumpster has the potential to pollute stormwater with various metals. Even mostly finished goods could have residual oils and chemicals on them, which have the potential to pollute stormwater.
Control Measures for Potential Pollutants
Once your industrial activities and their potential to pollute are identified, you will need to identify control measures, or best management practices (BMPs), to prevent or reduce the discharge of pollutants in stormwater. The SWPPP provides a place to outline what site-specific control measures are implemented at your facility. Below are some examples of control measures that should be addressed in your SWPPP.
- Minimize Exposure – Anything done onsite that helps minimize the exposure of your materials to stormwater should be documented in your SWPPP. This could be finding space indoors or offsite for material previously stored outside, or covering materials with awnings or tarps to minimize exposure to runoff.
- Good Housekeeping – The frequency and description of good housekeeping practices implemented at your facility should be covered in your SWPPP. This can be as simple as noting the frequency of trash pickups to prevent overflow or committing to keeping outdoor storage areas debris-free. Finally, include employee training on the importance of cleaning up any mishandled materials immediately to prevent them from being washed offsite during the next rain event.
- Maintenance – Make sure maintenance programs for any outdoor industrial equipment and/or systems are referenced or outlined in your SWPPP. Most permits also require a preventative maintenance log to note when this maintenance takes place.
- Spill Prevention and Response Procedures – Identify measures implemented onsite to minimize the potential for spills, leaks, and any other releases from material stored outdoors, or even near doorways in your building. If you have other spill plans at your facility, be sure to reference them in your SWPPP.
Consult your permit for all mandatory control measures that should be addressed in your SWPPP.
As you’re identifying your materials and activities stored outside, you will want to note their location for your site map. All SWPPPs include a site map that outlines where industrial materials and activities are located throughout the property. It identifies stormwater runoff features, such as the direction of flow, storm drains, and final outfalls where stormwater leaves your property. The map should be used as your road map during facility inspections. Your permit will typically list in detail what items are required for your site map. Be sure to check that list thoroughly to make sure an inspector doesn’t catch something you missed.
Not all industries will have the same industrial activities and potential pollutants onsite. The federal general stormwater permit and many state permits list additional permit requirements for different sectors of industry listed in the permit. These sectors will outline stormwater sampling specific to your industry, additional common industrial materials or activities that need to be added to your SWPPP and site map, and even additional inspection or reporting requirements. Do not forget to add these requirements to your SWPPP and follow them throughout the term of your permit.
One of the most important parts of your SWPPP is outlining the procedures you have in place to comply with your permit requirements. This typically includes, but is not limited to:
- routine facility inspections,
- quarterly visual assessments,
- analytical sampling, and
- corrective action reports.
These tools help you determine if your control measures are working to minimize pollutants, give you an opportunity to review your SWPPP, and make sure that all other areas are in compliance with your permit. Most permits require at least three years of these records to be kept onsite and will definitely be reviewed should your facility be inspected.
Updating Your SWPPP
It is important to remember that your SWPPP is a living document. It should reflect any changes in personnel, outdoor storage, best management practices, and stormwater discharge from your facility throughout the term of your permit. If your SWPPP is not up to date, it could result in corrective actions or even a violation. Below are common triggers for updating your SWPPP.
Changes to Storage
If there are any major changes to outdoor storage or the industrial activities taking place at your facility, these need to be added to your SWPPP. The addition of new material needs to not only include a description of the material, but also a consideration of how that material or activity could potentially pollute stormwater and what BMPs should be implemented to minimize those pollutants.
Certain problems discovered during visual or routine site inspections, or the exceedance of your benchmark limits after an analytical sample, can trigger corrective actions. Sometimes this includes extra inspections that must be conducted and filed in your SWPPP, or even submitted to your permitting authority. If, as a result of corrective actions, you make updates to your best management practices or onsite storage, you will want to be sure to update your SWPPP with those changes.
Changes to personnel
It is important that your pollution prevention team and spill emergency contacts are up to date. If your main SWPPP contact changes, there is also a good possibility that an official change form will need to be submitted to your permitting authority. You don’t want to miss reporting reminders, inspection requests, or any other items sent by the permitting authority to an out-of-date site contact. This can lead to surprise inspections or missed violations if communications from your permitting authority are not reaching your pollution prevention team members.
And finally, while most permit renewals do not require a complete rewrite of your facility’s SWPPP, you will certainly be responsible for reviewing the new permit and updating your SWPPP with any new requirements. Below are general permits expiring in 2021 alone:
- North Carolina
- South Carolina
- Utah (Group 4)
If you need help putting together your SWPPP or any of its components, contact U.S. Compliance. Our team assists hundreds of facilities with health, safety, and environmental compliance and can help you put together an effective plan.