Developing a Stormwater Pollution Prevention Plan (SWPPP)

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 http://www.cicacenter.org/swrlnew.cfm

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)

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

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 1Your 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

12. Pollution Prevention Team

13. Element 2The 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

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

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)

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

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

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 117.3 and 40 CFR 302.4

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

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 3Selecting 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

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

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

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.