Stormwater Pollution Prevention Plans
What is a SWPPP (Stormwater Pollution Prevention Plan)?
A Stormwater Pollution Prevention Plan (SWPPP) is a site-specific report that identifies all of the practices, procedures, and materials at a facility that could degrade stormwater quality. The SWPPP itemizes the actions the facility must take to comply with stormwater regulations and prevent unauthorized discharges of contaminated stormwater from flowing offsite.
How does a facility determine if it needs a SWPPP?
Any facility that discharges polluted stormwater into a waterway, such as a ditch, stream, or river, must obtain a National Pollutant Discharge Elimination System (NPDES) permit. To obtain a permit, a Notice of Intent (NOI) must be submitted to the regulating authority characterizing the types of contaminants, and specifying the name of the waterway receiving the discharge. The facility is then required to develop a SWPPP.
The SWPPP is developed with the cooperation of the facility environmental manager, the regulator, and, often, a stormwater consultant to establish limits and parameters for a wide variety of pollutants, such as grease and oil, metals, pH, temperature, biological oxygen demand, and turbidity. SWPPPs are not required for discharges into a sanitary sewer or Publicly Owned Treatment Works (POTW). However, a POTW may have certain limits or restrictions on volume of discharge or what types of contaminants can be discharged into that system without pre-treatment. Some POTWs may also require special plans or permits for discharges into their system.
What is included in a SWPPP?
A SWPPP primarily focuses on establishing preventative measures for minimizing discharge of pollutants into waterways. However, since spills can and do happen even at well-managed sites, a SWPPP must include a plan for addressing stormwater best management practices with regard to spill response. Specifically, the SWPPP must include: 1) A map and description of the facility; 2) Names and titles of the spill response team; 3) A list of the possible pollution-causing practices performed at the facility; 4) A list of spill and pollution control measures, 5) A detailed spill response plan; 6) A facility inspection/monitoring schedule; and 7) An employee training schedule.
SWPPP Components in Detail:
1) Site Description:
In addition to the name and address of the business operating at the facility, the site description includes a detailed diagram clearly depicting the location of stormwater outfalls and potential pollutant discharge points. These details include stormwater flow pathways across the site; the location of stormwater catch basins, drains, or ditches; location of stored chemicals or other potential contaminants; previous spill locations; discharge monitoring locations; areas of particularly high risk for contaminant spills, such as fueling islands, vehicle or equipment washing areas, or loading docks; and locations of possible offsite discharges onto the property.
2) Pollution Prevention Team:
The team helps the site manager develop, review, and revise the SWPPP. The team is also tasked with insuring that Best Management Practices, or BMPs are in place and being adhered to. Finally, the names and positions of the team are maintained in the SWPPP and NPDES permit.
3) Conditions and Actions that Can Cause Pollution:
The SWPPP must describe each outdoor area or activity that represents a pollution risk, such as uncovered, outdoor storage of raw materials, waste material, or industrial by-products. A three-year record of past spills must also be maintained.
Stockpiled soil, sand, road salt, or other materials, stored on hard surfaces and subject to rain or snowmelt, are one of the major causes of pollution entering storm drains. Vehicular fluids, stored equipment, and vehicle wash areas are also a significant source of water pollution. Leaks and spills during fueling and maintenance are another common way for oils, petroleum, and solvents to enter stormwater systems.
4) Pollution Countermeasures and Controls:
Each potentially harmful process or area at a facility must be controlled with at least one countermeasure, as described in the SWPPP. The NPDES permit lists each potential pollutant at the facility, along with its effluent limit, or maximum allowed concentration as measured at a data collection point. However, the NPDES permit does not include a discussion of the applied countermeasures, which are detailed in the SWPPP.
Countermeasures can incorporate simple, basic stormwater BMPs, such as keeping vehicles, soil, sand, salt, or stockpiled chemicals in an indoor or covered area, or can include more technologically involved stormwater BMPs such as stormwater catch basin filters, oil-water separators, settling tanks, or vegetated swales. Other stormwater BMPs can include periodic inspections of vehicles and equipment for fluid leaks, regular sweeping of parking and equipment storage areas, and the placement of filtration pads around vulnerable ditches or catch basins.
5) Required Monitoring and Inspection Procedures:
The NPDES permit specifies the stormwater monitoring schedule, the types of pollutants to be analyzed along with their respective allowances, and often, the specific location and procedure for collecting stormwater samples for analysis. The Oregon Department of Environmental Quality (ODEQ), which regulates stormwater pollution in Oregon, requires quarterly Discharge Monitoring Reports (DMRs), and all facilities are required to report any non-compliance events.
Facilities are also required to conduct routine inspections to verify that the selected controls and countermeasures are in fact working. By keeping a record of inspections, a facility can prove during a compliance audit that BMPs are in place and being followed.
6) Spill Response Procedures:
Despite best intentions and diligent planning, spills of pollutants can and do occur even at the most well-managed facilities. Therefore each site much establish a Spill Response Plan (SRP). The SRP should be kept with the SWPPP to document spill response principles and procedures. Often the spill response plan for other regulatory requirements, such as fuel storage and product loading/unloading can qualify as the SWPPP SRP.
7) Worker Training Program:
A facility is required to keep written records of its worker training program with regard to BMPs, SRPs, and the SWPPP. The training should be conducted in concert with other environmental training requirements, such as Hazardous Waste Operations and Emergency Response (HAZWOPER) training, which is required under the Occupational Safety and Health Administration (OSHA) standard 29 CFR Part 1910.120 for facilities that handle hazardous substances.
8) Periodic SWPPP Review and Revision:
When a facility makes changes to the way it stores or handles potential stormwater contaminants, it is required to revise its SWPPP accordingly. Such changes can include moving a process or storage area to another location, streamlining a process to reduce contaminant use or exposure to stormwater, turnover of relevant personnel, or adding a new process or potential pollutant to the facility. The SWPPP should also be reviewed when the NPDES permit is being renewed. Plans must be signed and dated by the relevant corporate officer, and kept on site to document compliance. Ideally, the SWPPP should be part of the overall standard operating procedures (SOPs) at a facility, to insure that environmental protection and compliance are understood by all employees and integrated into day-to-day operations.
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