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Need A Stormwater Pollution Prevention Plan (SWPPP)?

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What is the process of a Stormwater Pollution Prevention Plan (SWPPP)?

Owner/Operator Interview

01

We develop an initial understanding of your site through a telephone interview. We discuss what industrial activities are occurring on-site now, what activities will be occurring in the future, how storm water is currently managed on-site and where storm water runoff is discharged from the site. From the interview and using publicly available mapping data, we develop an initial understanding of your site and sketch a map of industrial activities occurring on-site.

Site
Visit

02

Once we have developed an initial understanding of existing industrial activities, we visit your site to verify information from the interview and collect more detailed information. We assess the flow of surface runoff, where it enters any sewer or collection system, and all the potential storm water discharge locations from the site. We also assess where all the potential pollutant sources are on-site and the existing controls used to reduce the risk of discharging pollutants.

Plan
Development

03

We develop a SWPPP specific for your industrial facility based on the information collected during the interview and site visit. We focus as much as possible on the existing controls and procedures that qualify as BMP’s in order to limit disruption of your existing processes.

Certification & Review

04

The initial SWPPP draft is delivered to you for your review and approval prior to submittal to the Agency. Your review is critical to ensure that the SWPPP reflects current industrial activities at your site and that BMP’s and controls specified are within the capability of your operation or facility. After we receive your approval, the SWPPP will be certified as true and accurate and that your storm water discharges contain storm water runoff only.

Inspections & Reporting

05

Each SWPPP contains requirements for quarterly inspections and annual reporting. Inspections and reporting can be completed in-house by your staff or by our staff. The decision to self-perform or contract inspections and reporting should be made considering conditions specific to your facility, such as whether your staff on-site has existing capacity, the cost of mobilizing outside staff regularly for inspections, and the time and effort required to complete each inspection.

Stormwater Pollution Prevention Plan (SWPPP)

If you're here, you must be researching Storm Water Pollution Prevention Plans (SWPPP), most likely for an industrial facility or construction site your business or employer owns, operates, or manages. I'm assuming you, the reader, are a regular person, not a scientist, engineer or other professional whose job it is to understand these things. I hope when I'm done, you will have a basis for understanding what these plans are, why they are necessary, how to utilize them and how to be a better buyer of storm water consulting services. Let’s start by defining some terms you may be unfamiliar with to help you communicate effectively with your engineers and environmental consultants.

SWPPP - Pronounced "swip", rhymes with "whip". A Stormwater Pollution Prevention Plan (SWPPP) is a document that describes how your facility prevents pollution of. The majority component of NPDES permit compliance requirements.

General Permit – The term “General Permit” could also be called a “common permit” – that is, a permit to do all of the common things that a facility in your industry would do. The permit is "General" as opposed to an “Individual Permit”, which is sometimes required for facilities with “uncommon” activities. We will touch on Individual Permits later, but for now just know that most NPDES permits are General, and Individual Permits are a special case. As you may have guessed, typically Individual Permits require a larger fee, so it is desirable to obtain General Permit coverage if possible.

NPDES – Pronounced “Nip-deez” by all the cool kids, it stands for National Pollutant Discharge Elimination System. The NPDES program was created by the Clean Water Act in 1972 as a means to reduce or control the amount of pollution in storm water runoff. In most jurisdictions, NPDES permits for storm water come in several flavors:

  • Permit to discharge storm water from a construction site
  • Permit to discharge storm water from an industrial facility
  • Permit to discharge storm water from a Municipal Separate Storm Sewer Systems (MS4)

If you are a private business owner/representative, it is most likely you are interested in a permit to discharge from an industrial facility, construction site, or a combination of these two.

NPDES General Permits (in Illinois) - The IEPA has issued three specific General NPDES Permits, listed below. Again, these are General Permits, and were written to cover many common activities taking place within the state’s jurisdiction.

  • ILR00 – is the shorthand code for “General NPDES Permit for Storm Water Discharges from Industrial Activities
  • ILR10 - is the shorthand code for “General NPDES Permit for Storm Water Discharges from Construction Site Activities. Construction sites are mainly interested in preventing erosion from disturbed soil and reducing the chance of sediment being washed downstream.
  • ILR40 – is the shorthand code for “General NPDES Permit for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems

Jurisdiction (US EPA vs. state agency) – NPDES Permits are most often issued by the regulatory agency (IEPA, IDEM, EGLE, etc) of the state you live in. The US EPA is the federal EPA office who can, and does, issue permits. Which has jurisdiction depends on where your facility is located and the water body to which your storm water discharges. In the rare case that your facility (or your neighbors) are located on military installations, national parks, or tribal lands, jurisdiction would belong to US EPA. Otherwise, you will be dealing with the regulatory agency of the state you live in.

Pollutants - You think you already know what pollution is. Let's pressure test that. What comes to mind when we say pollution in stormwater? Plastic? Oil? Industrial chemicals? How about fertilizer from farm fields? Did you think of raw sewage? Or how about the pharmaceuticals passed through humans and through wastewater treatment plants into rivers? Most importantly for SWPPPs, did you think of suspended solids in stormwater as pollution?

Suspended Solids - Suspended solids are small particles of dirt, minerals and rock in water. You would recognize this immediately as "dirty water" or water you wouldn't want to swim in. In short, not only is cloudiness considered pollution on its own, but chemical pollutants can stick to the particles as well.

MS4 - Municipal Separate Storm Sewer Systems (also known as MS4 if you're a storm sewer nerd) (yes, storm sewer nerds are an actual thing) refer to a system of public storm drains that are used for storm water only, with sewage collected in a different sewer system.

Combined Sewer (not separated) systems require a different permit, not discussed here. This is because theoretically, the storm water runoff from such a system would be treated at the municipal wastewater treatment plant. Similar treatment for storm water outfalls is also possible, but again is relatively expensive. Although some NPDES permit requirements can be onerous, addressing a risk of pollution using good housekeeping, regular maintenance, and administrative controls is typically far less expensive than construction of such “end of pipe” treatment.

SWMP - Storm Water Management Program refers to a comprehensive program to manage the quality of storm water discharged from the municipal separate storm sewer system. Often

SWPPP vs. SWMP – In Illinois, a SWPPP is a requirement for ILR00 and ILR10 permits and SWMP is a requirement for ILR40 permits. A SWMP is more extensive than a SWPPP because it is dealing with the drainage of an entire town or city, rather than a single facility or site. SWMPs need to address multiple uses of public property, whereas activities at an industrial facility or construction site requiring a SWPPP are predictable and much more narrow in scope.

Frequently Asked Questions

What is a SWPPP?

The purpose of a Storm Water Pollution Prevention Plan (SWPPP) is to minimize the risk of storm water runoff becoming contaminated and discharging downstream.

The SWPPP could be thought of as a manual for management of storm water on-site. It would describe which activities pose a risk of storm water contamination, where those activities occur, what are the passive and active means for reducing the risk of storm water contamination, and where preventive maintenance needs to occur regularly.

Why does my Industrial Facility need a Storm Water Pollution Prevention Plan?

Storm water runoff has the potential to become contaminated by dissolved, suspended, and floatable pollutants after contacting surfaces, equipment, or materials at certain facilities. Contaminants range from those known in everyday life like diesel and gasoline to emerging persistent chemicals like PFAS. Even native soil and sediment is considered a pollutant regardless of whether that soil is certified as uncontaminated itself.

What are Best Management Practices?

Best Management Practices (BMP)’s typically refer to administrative controls that minimize the risk of discharging polluted runoff. BMP’s include regularly scheduled inspections and maintenance, documentation of proper maintenance procedures, on-site restrictions on where certain activities can and cannot occur, or standard operating procedures for conducting industrial activities.

Often, procedures that qualify as storm water BMP’s are already in place at a facility. In this case, we simply document your current processes for inclusion in the SWPPP. For some facilities, the SWPPP can be implemented without major construction or simply carrying on with standard operating procedures that qualify as BMP’s.

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