We know that your facility would never (purposely) discharge nasty pollutants into a waterway. And you don’t have any cows or horses or other kind of animal feeding operations in your workplace, so you don’t have to worry about compliance with stormwater regulations concerning secondary containment. Right? Well — actually, you do. Just because your facility doesn’t have animals, it doesn’t mean you’re off the hook.
The Environmental Protection Agency (EPA) says that facilities that discharge pollutants are considered “point sources.” That means if your facility releases anything other than pure, fresh water that is at the ambient temperature of the receiving waters, you’re going to need a National Pollutant Discharge Elimination System (NPDES) permit.
In order to get that permit, you’ll need a Stormwater Pollution Prevention Plan (SWPPP) that outlines the processes, procedures and defenses that your employees will use to prevent water pollution. Those processes, procedures and defenses are known as best management practices (BMPs). In short, a BMP is something a facility does (or in some cases does not do) to avoid polluting receiving waters. The official definition is:
“Schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of ‘waters of the United States’. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.”
(Repeat after me: The EPA wants me to have an NPDES, but first I have to have a SWPPP that lists my BMP.)
Great, you’re thinking. Now I have to get even more equipment to satisfy the SWPPP. But there is good news! The EPA does not mandate what BMPs a facility must use to build a compliant plan. It is up to the facility to evaluate their processes, storage and handling procedures, spill response equipment and capabilities and determine what will work best for the site.
You’ve already worked really hard to be compliant with secondary containment regulations. And you’ve done the math and figured out how much secondary containment you need. You know that your secondary containment system will prevent leaks, spills and drainage from leaving your facility. So guess what? That makes secondary containment a BMP. It fulfills just what the EPA requires for a SWPPP: containment, maintenance and operating procedures. So, with your secondary containment system, you’re way ahead of the game when it comes to stormwater regulations.
You tell us: What do you use for secondary containment to be in compliance with Stormwater regulations?