If your facility discharges pollutants directly into waterways, listen up. In a previous post we discussed the NPDES program established by the Clean Water Act; how you can obtain a permit to discharge certain pollutants into receiving waters (and how this is actually responsible for improvements in our water quality); and what a huge responsibility that is. Today, we’re going to map out the first steps to obtaining one of these permits.
It takes more than keeping a dust-covered spill kit tucked in the back corner of your warehouse to convince the state to give your facility an NPDES permit. If you want your facility to be covered under either a general or an individual NPDES permit, chances are you’re going to need a Stormwater Pollution Prevention Plan (SWPPP).
A SWPPP is a written document that identifies activities at a facility that could cause stormwater pollution and lists the practices and procedures that the facility will take to prevent pollution from occurring. This document is going to mostly be made up of Best Management Practices (BMPs), which the Environmental Protection Agency (EPA) defines as “a schedule of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of waters of the United States” [40 CFR 122.2].
In other words, whatever measures you’re going to implement to prevent or reduce water pollution are BMPs– and they can run the gamut from employee training to erecting permanent containment structures like concrete berms.
So how do you know which BMPs will suit your facility and be included in your SWPPP?
The first step in creating a SWPPP is to perform a site assessment. Each facility will likely have site-specific pollutant sources, but pay special attention to some of the most common areas identified by the EPA:
- Loading and unloading operations
- Outdoor storage areas
- Outdoor process areas
- Dust or particulate generating processes
- Illicit connections and non-stormwater discharges
- Waste management practices
A detailed walk-through of your entire facility will help uncover areas of concern, drains, stormwater outflow points, and any control measures that are already in place. As you explore each area, make a list of any chemicals or other materials that could cause pollution, and their quantities and location. It’s also a good idea to review purchasing records and chemical inventories to double-check that your list is complete.
Even though your facility may produce the same end products as another facility – the materials, production processes, and material handling procedures are often very different. This is why your walk-through is so important – the EPA doesn’t outline specific BMPs because they can vary so much from facility to facility, so you have to come up with your own!
For BMPs to work, they should identify the pollutant and spell out a specific method for preventing it from entering a waterway. The method may be as simple as training your employees not to dump the pollutant into the floor drain – or as involved as installing an extensive pretreatment system (or somewhere in between).
Common BMPs include:
- Good housekeeping practices
- Erosion and sediment controls
- Source elimination
- Preventative maintenance programs
- Spill prevention and response plans
- Material storage and handling protocols
- Waste management and segregation procedures
- Water conservation techniques
- Installation of secondary containment devices
Other Elements of A SWPPP
Plans should also include documentation on how and when workers will be trained, and name the individual or individuals responsible for training and maintaining the plan. Most plans also include inspection checklists and schedules. Like most plans, a SWPPP is a living document that needs to be reviewed regularly and updated when changes occur at your facility.
And as always, the EPA has produced a guide, just for you! Developing industrial SWPPPs explains how to perform a site assessment, develop BMPs and create a plan to meet the requirements of most multi-sector general NPDES permits.