Special Topics in Environmental Management

When to Update Your SWPPP

Like many other EHS plans, the SWPPP is a living document that should be reviewed and updated on a regular basis. Whenever you find the need to change a procedure that is described in your SWPPP or to modify a control measure described in the plan, you must update the SWPPP to reflect those changes. What’s the timeline? EPA wants it done as quickly as practicable.

In the interim between the annual inspection and completed SWPPP revision, keep a copy of the original SWPPP with your handwritten notes for SWPPP modifications at the facility. Should you be inspected before the revised SWPPP is complete, the copy with your notes can be used to demonstrate the changes that will be in the revised document.

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If the SWPPP requires modification to document corrective actions, remember that you have to provide a new certification statement signed and dated upon completion of the revision.

Here are some examples of events that, if they result in a change in control measures or procedures, will require prompt revision of the SWPPP to reflect the new facility conditions.

  • A change in the composition of the stormwater pollution prevention team or new responsible official.
  • An unauthorized release or discharge (e.g., spill, leak, or discharge of non-stormwater not authorized by this or another NPDES permit) occurs at your facility.
  • A discharge violates a numeric effluent limit.
  • You become aware, or EPA determines, that your control measures are not stringent enough for the discharge to meet applicable water quality standards;
  • An inspection or evaluation of your facility by an EPA official, or local, State, or Tribal entity, determines that modifications to the control measures are necessary to meet the non-numeric effluent limits in this permit.

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  • Construction or a change in design, operation, or maintenance at your facility significantly changes the nature of pollutants discharged in stormwater from your facility, or significantly increases the quantity of pollutants discharged.
  • The average of four quarterly sampling results exceeds an applicable benchmark. If less than four benchmark samples have been taken, but the results are such that an exceedance of the 4 quarter average is mathematically certain (i.e., if the sum of quarterly sample results to date is more than 4 times the benchmark level) this is considered a benchmark exceedance, triggering a review of control measures and possible SWPPP modification.

Remember, every time you add new revisions to the SWPPP to document corrective actions you are required to add a new signed and dated certification statement by the responsible official. All other changes must be signed and dated by the person preparing the change.