Special Topics in Environmental Management

Putting Together a Good Stormwater Pollution Prevention Team

This team is responsible for assisting the facility manager in developing the facility’s SWPPP as well as implementing and maintaining stormwater control measures. The team will be taking corrective action where necessary to address permit violations or to improve the performance of control measures, and modifying the SWPPP to reflect changes made to the control measures. This is a big job and that’s why it’s important to choose your team members wisely.

For starters, the stormwater pollution prevention team should consist of those people on-site who are most familiar with your facility and its operations. They are going to be the people responsible for ensuring that necessary controls are in place to eliminate or minimize the impacts of stormwater from the facility.

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Members of your stormwater pollution prevention team and those conducting inspections and monitoring activities should be "qualified personnel." EPA defines qualified personnel as "those who posses 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."

A key member of the stormwater pollution prevention team (for some facilities, this may be the only member) is the person with primary responsibility for developing and overseeing facility activities necessary to comply with the permit. This should be someone who will be on-site on a daily basis and who is familiar with the facility and its operations. This person will also likely have primary responsibility for ensuring that inspections and monitoring activities are conducted. If an EPA or state inspector visits the facility, this person will be the main point of contact for the SWPPP.

Since most industrial facilities differ in size and complexity, the number of team members will also vary.

You need to make sure each member of the stormwater pollution prevention team has ready access to either an electronic or paper copy of applicable portions of the industrial stormwater general permit and the SWPPP.

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Consider adding a stormwater management component to employee job descriptions and annual reviews, as appropriate to specific jobs. Often these requirements compliment existing tasks such as maintaining a clean work area; promptly cleaning up spills and leaks; performing regularly scheduled equipment maintenance; and properly storing all chemicals, oils, and other liquid pollutants.

Make sure to call out the stormwater pollution prevention team members by name or title as well as their individual responsibilities in your SWPPP. You’ll have to update this information every time staff members change. But that’s not the only time you’ll have to update your SWPPP. In tomorrow’s issue of the Advisor we talk about all of the other events that require a SWPPP update.