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Importance of Storm water pollution prevention team in developing a SWPPP

The Storm water pollution prevention plan (SWPPP) is intended to be a “living” document, updated as necessary, such that when industrial activities or storm water control practices are modified or replaced, the SWPPP is similarly revised to reflect these changes.

A typical SWPPP includes the following elements:

• Storm water pollution prevention team;
• Site description;
• Summary of potential pollutant sources;
• Description of control measures;
• Schedules and procedures;
• Documentation to support eligibility considerations under other federal laws; and
• Certification of the SWPPP.

The process of developing a Storm water pollution prevention plan (SWPPP) involves the following four steps:

• Step 1: Formation of a pollution prevention team of qualified personnel who will be responsible for preparing the plan and assisting the plant manager in implementing practices to comply with the permit;
• Step 2: Assessment of potential storm water pollution sources;
• Step 3: Selection of appropriate control measures that minimize the discharge of pollutants during storm events for each of these sources; and
• Step 4: Development of procedures for conducting required inspection/monitoring activities, as well as regular maintenance of control measures.

You are required to develop your Storm water pollution prevention plan (SWPPP) to address the specific conditions at your site and keep it up-to-date to reflect changes at your site both for your use and for review by the regulatory agencies responsible for overseeing your permit compliance

The first step in developing the Storm water pollution prevention plan is to identify the storm water pollution prevention team. The storm water pollution prevention team is responsible for assisting the facility manager in developing the changes made to the control measures.

Since industrial facilities differ in size and facility’s SWPPP as well as implementing and maintaining storm water control measures, taking corrective action where necessary to address permit violations or to improve the performance of control measures, and modifying the SWPPP to reflect complexity, the number of team members will also vary. The storm water pollution prevention team should consist of those people on-site who are most familiar with the facility and its operations and responsible for ensuring that necessary controls are in place to eliminate or minimize the impacts of storm water from the facility.

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A key member of the storm water 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 Storm water pollution prevention plan (SWPPP). Quest Consultants provides professional engineering services relating to SWPPP. It also provides SWPPP training to its clients so that they can develop and implement effective SWPPP plan. To know more information, visit our http://www.questepa.com.

Importance of a Spill Prevention, Control and Countermeasures (SPCC) plan

A facility that meets the criteria described above must comply with the SPCC rule by preventing oil spills and developing and implementing an SPCC Plan.

Benefits of implementing an SPCC Plan include:

• The SPCC regulations reduce the likelihood and severity of oil leaks and spills.
• By preparing and implementing a plan, the facility assures it has installed effective spill prevention equipment/secondary containment, established emergency response plans, and provides employee training to prevent and/or respond to oil spills.
• These proactive activities will reduce emergency response and environmental liability costs associated with spills. Likewise, reduced fire risks and worker exposure can be realized.

You can determine whether your facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines by considering the geography and location of your facility relative to nearby navigable waters (such as streams, creeks and other waterways). Additionally, you should determine if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams.

Estimate the volume of oil that could be spilled in an incident and how that oil might drain or flow from your facility and the soil conditions or geographic features that might affect the flow toward waterways. Also you may want to consider whether precipitation runoff could transport oil into navigable waters or adjoining shorelines. You may not take into account manmade features, such as dikes, equipment, or 4 other structures that might prevent, contain, hinder, or restrain the flow of oil. Assume these manmade features are not present when making your determination. If you consider the applicable factors described above and determine a spill can reasonably flow to a waterway, then you must comply with the SPCC rule.

Author – Bio

Owners or operators of regulated facilities must properly instruct their oil handling personnel in the operation and maintenance of equipment to prevent the discharge of oil. Under the rules adopted by EPA described in 67 FR 47042, SPCC training is not required for employees that do not handle oil. As described in 67 FR 47042, owners or operators must conduct annual spill prevention briefings for their operating personnel to ensure adequate understanding of the SPCC Plan for that facility. The briefings must highlight and describe known discharges, failures, or malfunctioning equipment that occurred within the last year at the facility, and recently developed precautionary measures. To know more insights about Spill Prevention, Control and Countermeasures (SPCC), visit our http://www.questepa.com.

Stormwater pollution prevention plan (SWPPP) need to be reviewed and updated on a regular basis

Your Storm water pollution prevention plan (SWPPP) is a document that will need to 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 therein, you must update the SWPPP to reflect those changes as quickly as practicable.

Below are some examples of events that, if they result in a change in control measures or procedures, will require prompt revision of the Storm water pollution prevention plan to reflect the new facility conditions.

• A change in the composition of the storm water pollution prevention team or new responsible official.
• An unauthorized release or discharge (e.g., spill, leak, or discharge of non-storm water 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.
• Construction or a change in design, operation, or maintenance at your facility significantly changes the nature of pollutants discharged in storm water 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.

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Revisions to the Storm water pollution prevention plan (SWPPP) to document corrective actions requires 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. In the interim between the annual inspection and completed SWPPP revision, keep a copy of the original Storm water pollution prevention plan (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. Visit our http://www.questepa.comfor more information relating to Storm water pollution prevention plan (SWPPP).

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Steps that a facility owner/ operator can take to prevent oil spills include

You can determine whether your facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines by considering the geography and location of your facility relative to nearby navigable waters (such as streams, creeks and other waterways). Additionally, you should determine if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams.

Estimate the volume of oil that could be spilled in an incident and how that oil might drain or flow from your facility and the soil conditions or geographic features that might affect the flow toward waterways. Also you may want to consider whether precipitation runoff could transport oil into navigable waters or adjoining shorelines. You may not take into account manmade features, such as dikes, equipment, or other structures that might prevent, contain, hinder, or restrain the flow of oil. Assume these manmade features are not present when making your determination. If you consider the applicable factors described above and determine a spill can reasonably flow to a waterway, then you must comply with the SPCC rule.

A facility that meets the criteria described above must comply with the SPCC rule by preventing oil spills and developing and implementing an SPCC Plan.

Steps that a facility owner/ operator can take to prevent oil spills include:

• Using containers suitable for the oil stored. For example, use a container designed for flammable liquids to store gasoline;
• Providing overfill prevention for your oil storage containers. You could use a high-level alarm or audible vent;
• Providing sized secondary containment for bulk storage containers, such as a dike or a remote impoundment. The containment needs to hold the full capacity of the container plus possible rainfall. The dike may be constructed of earth or concrete. A double-walled tank may also suffice;
• Providing general secondary containment to catch the most likely oil spill where you transfer oil to and from containers and for mobile refuelers and tanker trucks. For example, you may use sorbent materials, drip pans or curbing for these areas; and
• Periodically inspecting and testing pipes and containers. You need to visually inspect aboveground pipes and oil containers according to industry standards; buried pipes need to be leak tested when they are installed or repaired. Include a written record of inspections in the Plan.

Author – Bio

By preparing and implementing a plan, the facility assures it has installed effective spill prevention equipment/secondary containment, established emergency response plans, and provides employee training to prevent and/or respond to oil spills. These proactive activities will reduce emergency response and environmental liability costs associated with spills. Likewise, reduced fire risks and worker exposure can be realized. Visit our http://www.questepa.comto know more insights.

Need to develop SWPPP plan for industrial facilities

Common requirements for coverage under an industrial storm water permit include development of a written storm water pollution prevention plan, implementation of control measures, and submittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP is a written assessment of potential sources of pollutants in storm water runoff and control measures that will be implemented at your facility to minimize the discharge of these pollutants in runoff from the site. These control measures include site-specific best management practices (BMPs), maintenance plans, inspections, employee training, and reporting. The procedures detailed in the SWPPP must be implemented by the facility and updated as necessary, with a copy of the SWPPP kept on-site. The industrial storm water permit also requires collection of visual, analytical, and/or compliance monitoring data to determine the effectiveness of implemented BMPs.

Your SWPPP must contain a narrative evaluation of the appropriateness of storm water management practices that divert, infiltrate, reuse, or otherwise manage storm water runoff so as to reduce the discharge of pollutants. Appropriate measures are highly site-specific, but may include, among others, vegetative swales, collection and reuse of storm water, inlet controls, snow management, infiltration devices, and wet retention measures.

A combination of preventive and treatment BMPs will yield the most effective storm water management for minimizing the offsite discharge of pollutants via storm water runoff. All BMPs require regular maintenance to function as intended. Some management measures have simple maintenance requirements, others are quite involved. You must regularly inspect all BMPs to ensure they are operating properly, including during runoff events. As soon as a problem is found, action to resolve it should be initiated immediately.

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Many industrial facilities may have already incorporated storm water management practices into day-to-day operation as a part of an environmental management plan required by other regulations. It is the responsibility of the pollution prevention team to evaluate these other plans to determine which, if any, provisions may be incorporated into the SWPPP. To know more insights about storm water pollution prevention plan, visit our http://www.questepa.com.

Important factors to be considered for better implementation of SWPPP Plan

Several pieces of information should be collected before a Storm Water Pollution Prevention Plan can be prepared. This information will provide the technical basis for selection of erosion and sedimentation control BMPs and post construction BMPs. A significant amount of this data must be included in the SWPPP, as specified by the UPDES permit. It is suggested that the following items be collected.

Existing Conditions Map – Obtain a topographic site map of the proposed construction area. The map should indicate the existing land use of the site as well as the location of surface waters on or near the site boundaries.

Soils Information – Collect soil information about the site. This information can generally be obtained from the National Resources Conservation Service (NRCS). In some cases, soil sampling may need to be conducted. This information will typically identify soil constraints, design criteria, and slope stability.

Runoff Water Quality – Where possible, obtain storm water quality data from runoff collected at or near the proposed construction site.

Name of Receiving Water – Identify the receiving water(s) which ultimately collect runoff from your site.

Rainfall Data – Determine the amount of rainfall you anticipate in your design of storm water management measures.

Important Points to notice for better implementation of SWPPP Plan

Employee Training

• Train all employees about the importance of pollution prevention
• Train all maintenance employees about their responsibilities to implement the Storm water Pollution Prevention Plan
• Train employees in applicable BMPs and the proper use of site specific equipment and resources
• Conduct annual employee training

Discuss the Storm water Pollution Plan at staff meetings

• Changes in BMPs
• Deficiencies found during inspections and corrective measures

Maintain Records

• Keep copies of training attendance rosters
• Keep maintenance records for storm water structural controls and onsite treatment systems
• Copies of inspection reports

Measure Success Through:

• Successful inspections through tracking findings and following up on corrective actions
• Knowledgeable and responsible employees
• Permit compliance
• Cleaner facility and environment

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If sediment and erosion controls and good housekeeping practices are not followed, construction activity can result in the discharge of significant amounts of sediment and other pollutants. Any change in a facility design, construction, or maintenance plan will necessitate changes in the SWPPP. It is important to keep your SWPPP plan updated. For more information on SWPPP, please visit our http://www.questepa.com.

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