Special Topics in Environmental Management

15 Tips for Developing and Implementing Your SWPPP

  1. Permit coverage must be obtained by either the facility owner or the operator. These are frequently the same. However, if they are different, the responsibility to obtain coverage falls on the one who has day-to-day operational control at the facility. So if the owner does not have operational control, the operator bears the responsibility to obtain coverage.
  2. Most permits require that the SWPPP be prepared before NPDES permit coverage can be obtained for industrial stormwater discharges. However, in some instances, the permit may provide additional time to complete or update a SWPPP after permit coverage is obtained. Nevertheless, it is recommended that the SWPPP be completed at least in draft form before applying for permit coverage, even in states where additional time is granted.
  3. Submitting an NOI form to the permitting authority indicates your certification that you have met the eligibility requirements for coverage under the general permit and your agreement to abide by its terms and conditions.
  4. The SWPPP is intended to be a living document. The plan must be current with the addition, removal, or modification of control measures. Permittees should not wait until the general permit is renewed to update their plans. EPA or the state agency will expect that all control measures identified in the SWPPP are being implemented at the facility.
  5. The SWPPP team may be one or a number of individuals depending on the size and complexity of the facility. These individuals are not simply caretakers who carry out functions developed and assigned by others. Throughout its stormwater regulations, including provisions for industrial SWPPPs, EPA specifies that only qualified personnel conduct monitoring and inspections. EPA defines “qualified personnel” as “those who possess the knowledge and skills to assess conditions and activities that could impact stormwater quality at your facility, and who can also evaluate the effectiveness of control measures.”
  6. Be certain the SWPPP lists the names and responsibilities of the oil SPCC team. Inspectors expect to deal directly with the individual or individuals who are responsible for developing, implementing, and maintaining the SPCC and taking corrective action where needed. If the person(s) assuming these responsibilities changes, that change should be recorded in the SWPPP. Any indication that there is uncertainty at the facility about who is in charge of stormwater control will raise red flags for an inspector.
  7. The SWPPP may refer to other documents that address control of stormwater. For example, if elements in the facility’s SPCC plan or environmental management plan (EMS) are appropriate for preventing pollution from stormwater at the facility, these elements need not be repeated in the SWPPP. However, copies of the relevant portions of the SPCC, EMS, or other document should be kept with the SWPPP.
  8. A compliance inspector will expect to see both the SWPPP document itself and additional required documentation relating to inspections conducted by facility staff as well as maintenance, monitoring results, and corrective action. Keep these records with the SWPPP; they are a critical part of your complete compliance profile.
  9. A stormwater permit does not cover nonstormwater discharges. However, the facility assessment included in the SWPPP must include a review of all nonstormwater discharges and indicate that these discharges either do not require a permit or are covered by another permit. Authorized nonstormwater discharges, or those that do not require permitting, include discharges from fire-fighting activities and irrigation drainage. All unauthorized discharges must be eliminated before coverage under the stormwater general permit can be obtained.
  10. A compliance inspector walking through a facility will probably spend more time looking at the detailed site map(s) of the facility than any other part of the SWPPP. The three principal elements on the site map are location of significant structures and impervious surfaces; direction of stormwater flow by use of arrows; and locations of all existing structural control measures. If there is more information than can be included in a single map, prepare as many maps as necessary to give an accurate picture of the site. No effort should be spared in making sure the site map clearly includes all elements the inspector wants to see, particularly control measures in relation to stormwater flows.
  11. The best SWPPPs are a balanced combination of best management practices (BMPs) and engineering controls. BMPs prevent pollution and reduce the need for engineered structures to capture pollution. Pollution prevention measures include written instructions for good housekeeping and specific employee training requirements. Records of when and how both housekeeping and training have occurred should accompany the SWPPP.
  12. Stormwater general permits require measures to control runoff of soil or sediment from areas that are prone to erosion. These areas should be clearly marked on the site map along with the measures to control runoff (e.g., slope strengthened with vegetation). If it’s on the site and exposed to stormwater, it must be part of the plan even if it does not meet the definition of “industrial equipment” or “development.”
  13. When selecting control measures, be careful not to violate local building or fire codes and other ordinances. An example would be constructing a shed for storage of chemicals and then finding out from the fire department that you are in violation for locating the shed too close to the main building, not equipping the shed with sprinklers or other fire control device, and not properly labeling containers.
  14. Training is required for all employees who work in areas where industrial activities or material-handling activities are exposed to stormwater, or who are responsible for implementing activities necessary to meet the conditions of this permit.The training session or sessions are expected to cover the contents of the facility SWPPP, control measures implemented to achieve compliance with applicable discharge requirements, spill containment and cleanup procedures, maintenance, monitoring, inspection, planning, reporting, and documentation requirements.EPA recommends that training be conducted for any applicable employees at least annually and whenever a new employee who will be active in regulated areas begins employment.
  15. General permits specify minimum frequency of inspection by facility staff, e.g., once a quarter or once a month. But facility operators should view inspections less as a step to meet the conditions of the permit than as a way to ensure that stormwater pollution is being effectively controlled. For example, inspections may be best conducted in conjunction with precipitation events or when materials are shipped out and delivered.

EPA’s guide includes two templates, one to assist operators in developing an industrial SWPPP under the Agency’s 2008 MSGP and one for meeting the additional documentation required during implementation of the stormwater general permit.