Plan de Prevención de la Contaminación de Aguas Pluviales_EPA 833-B-09-002_2009

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    ii Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Section 6: Completing Your SWPPP 346A Finish your SWPPP 34

    6B Obtain NPDES Permit Coverage 34

    6C Updating Your SWPPP 35

    Section 7: Keeping Records o Your Implementation Activities 36

    Section 8: Common Compliance Problems at Industrial Facilities 37

    Resources 39

    AppendicesAppendix A: MSGP SWPPP Template 40

    Appendix B: Additional MSGP Documentation Template 41Appendix C: Example Site Map 42

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    2 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    metals and organic chemicals) and otherpollutants such as trash, debris, and oil and

    grease, when acility practices allow exposureo industrial materials to stormwater Thisincreased fow and pollutant load can impairwaterbodies, degrade biological habitats, pol-lute drinking water sources, and cause food-ing and hydrologic changes to the receivingwater, such as channel erosion

    Industrial acilities typically perorm aportion o their activities in outdoor areasexposed to the elements This may includeactivities such as material storage and han-dling, vehicle ueling and maintenance, ship-

    ping and receiving, and salt storage, all owhich can result in pollutants being exposedto precipitation and capable o being carriedo in stormwater runo Also, acilities mayhave perormed industrial activities outdoorsin the past and materials rom those activitiesstill remain exposed to precipitation In addi-tion, accidental spills and leaks, improperwaste disposal, and illicit connections tostorm sewers may also lead to exposure opollutants to stormwater

    EPA has identied six types o activities at

    industrial acilities that have the potential tobe major sources o pollutants in stormwater:

    LoadingandUnloadingOperations

    Loading and unloading operations caninclude pumping o liquids or gases romtankers to storage acilities, pneumatictranser o dry chemicals, transer bymechanical conveyor systems, or transero bags, boxes, drums or other contain-ers by orklit or other material handling

    equipment Material spills or losses in theseareas can accumulate and be washed awayduring a storm

    OutdoorStorage

    Outdoor storage activities include stor-age o uels, raw materials, by-products,intermediate products, nal products, and

    process residuals Materials may be storedin containers, on platorms or pads, in bins,boxes or silos, or as piles Storage areasthat are exposed to rainall and/or runocan contribute pollutants to stormwaterwhen solid materials wash o or materialsdissolve into solution

    OutdoorProcessActivities

    Although many manuacturing activitiesare perormed indoors, some activities,such as timber processing, rock crush-ing, and concrete mixing, occur outdoors

    Outdoor processing activities can result inliquid spillage and losses o material solids,which makes associated pollutants avail-able or discharge in runo

    DustorParticulateGeneratingProcesses

    Dust or particulate generating processesinclude industrial activities with stackemissions or process dusts that settle onsuraces Some industries, such as mines,cement manuacturing, and reractories,also generate signicant levels o dust thatcan be mobilized in stormwater runo

    IllicitConnectionsandNon-Stormwater

    Discharges

    Illicit connections o process wastes orother pollutants to stormwater collectionsystems, instead o to sanitary sewers, canbe a signicant source o stormwater pol-lution Non-stormwater discharges includeany discharge rom the acility that is notgenerated by rainall runo (or example,wash water rom industrial processes)With ew exceptions, these non-stormwaterdischarges are prohibited Reer to your

    permit or a list o authorized non-storm-water discharges

    WasteManagement

    Waste management practices includeeverything rom landlls to waste piles totrash containment All industrial acilitiesconduct some type o waste managementat their site, much o it outdoors, whichmust be controlled to prevent pollutantdischarges in stormwater

    Figure 1. Stormwater runo can carry pollutants rom impervious suraces to

    receiving waters.

    Tetra

    Tech

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    4 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Where Do I Get a Copy of the IndustrialStormwater General Permit in My State?

    To determine who issues the industrialstormwater permit in your State, you can visitEPAs stormwater website at www.epa.gov/npdes/stormwater/authorizationstatus orthe Industrial Stormwater Resource Locator at

    www.envcap.org/iswrl

    Who Is an Operator?

    EPA denes the operator o an industrial acil-ity as:

    Theentitythathasoperationalcontroloverindustrial activities, including the ability tomodiy those activities, or

    Theentitythathasday-to-dayoperationalcontrol o activities at a acility neces-sary to ensure compliance with the permit(eg, the entity that is authorized to directworkers at a acility to carry out activitiesrequired by the permit) See denition inAppendix A o the 2008 MSGP

    In many cases, the owner and operator areone in the same person In a ew instances,there may be more than one operator at a site(with the owner being an operator based onthe denition provided above) Where there isboth an owner (without operational control)and an operator, it is the operators responsi-bility to obtain permit coverage and complywith the permit provisions

    2.B What Are the Basic ElementsRequired in a SWPPP?

    A SWPPP is a written document that identi-es the industrial activities conducted at thesite, including any structural control prac-tices, which the industrial acility operatorwill implement to prevent pollutants rom

    making their way into stormwater runoThe SWPPP also must include descriptions oother relevant inormation, such as the physi-cal eatures o the acility, and procedures orspill prevention, conducting inspections, andtraining o employees The SWPPP is intendedto be a living document, updated as neces-sary, such that when industrial activities orstormwater control practices are modied orreplaced, the SWPPP is similarly revised torefect these changes

    The process o developing a SWPPP involves

    the ollowing our steps:

    Step 1: Formation o a pollution preven-tion team o qualied personnel who willbe responsible or preparing the plan andassisting the plant manager in implement-ing practices to comply with the permit;

    Step 2: Assessment o potential stormwaterpollution sources;

    Step 3: Selection o appropriate controlmeasures that minimize the discharge opollutants during storm events or each othese sources; and

    Step 4: Development o procedures orconducting required inspection/monitoringactivities, as well as regular maintenanceo control measures

    This guide will assist you with these oursteps The selection o a pollution preven-tion team is discussed in the next section(Section 2C) Site assessment is addressed inSection 3, the selection o control measures isdiscussed in Sect ion 4, and inspection/moni-toring procedures are addressed in Section 5

    The remaining sections o the guide addressimplementation o practices to comply withthe permit and periodic evaluation o yourSWPPP

    Prepare your SWPPP beore submitting an NOI

    or permit application or coverage!

    What is a SWPPP?

    A SWPPP is a site-specic, written document

    that:

    Identies potential sources o stormwater

    pollution at the industrial acility;

    Describes stormwater control measures that

    are used to reduce or eliminate pollutants

    in stormwater discharges rom the industrial

    acility; and

    Identies procedures the operator will use

    to comply with the terms and conditions o

    the 2008 MSGP or a State general industrial

    stormwater permit.

    You are required to develop your SWPPP to

    address the specic conditions at your site and

    keep it up-to-date to refect changes at your

    site both or your use and or review by the

    regulatory agencies responsible or overseeing

    your permit compliance.

    http://www.epa.gov/npdes/stormwater/authorizationstatushttp://www.epa.gov/npdes/stormwater/authorizationstatushttp://www.envcap.org/iswrlhttp://www.envcap.org/iswrlhttp://www.epa.gov/npdes/stormwater/authorizationstatushttp://www.epa.gov/npdes/stormwater/authorizationstatus
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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 5

    To assist permittees in their recordkeeping,EPA has developed an Additional MSGPDocumentation template, which is available atwww.epa.gov/npdes/stormwater/msgp Thistemplate, developed or permit holders subjectto the 2008 MSGP, is available in MicrosotWord and can be modied as necessary toaddress State-specic permit requirements

    2.C Stormwater Pollution PreventionTeam (Step 1)

    The rst step in developing the SWPPP is toidentiy the stormwater pollution preventionteam The stormwater pollution preventionteam is responsible or assisting the acilitymanager in developing the acilitys SWPPPas well as implementing and maintainingstormwater control measures, taking correc-tive action where necessary to address permitviolations or to improve the perormance o

    control measures, and modiying the SWPPPto refect changes made to the control mea-sures Since industrial acilities dier in sizeand complexity, the number o team memberswill also vary The stormwater pollution pre-vention team should consist o those peopleon-site who are most amiliar with the acilityand its operations and responsible or ensur-ing that necessary controls are in place toeliminate or minimize the impacts o storm-water rom the acility

    A key member o the stormwater pollution

    prevention team (or some acilities, thismay be the only member) is the person withprimary responsibility or developing andoverseeing acility activities necessary to com-ply with the permit This should be someonewho will be on-site on a daily basis and whois amiliar with the acility and its operationsThis person will also likely have primaryresponsibility or ensuring that inspectionsand monitoring activities are conducted I anEPA or State inspector visits the acility, thisperson will be the main point o contact orthe SWPPP

    A typical SWPPP includes the ollowingelements:

    Stormwaterpollutionpreventionteam;

    Sitedescription;

    Summaryofpotentialpollutantsources;

    Descriptionofcontrolmeasures;

    Schedulesandprocedures;

    Documentationtosupporteligibilitycon-siderations under other ederal laws; and

    CerticationoftheSWPPP.

    EPA has developed a model Industrial SWPPPTemplate, which can be ound in Appendix A,and on EPAs website at www.epa.gov/npdes/stormwater/msgp This template, developedor permit holders subject to the 2008 MSGP,is available in Microsot Word and can becustomized to address SWPPP requirements

    in dierent State NPDES permits

    Where your acility has other written pro-cedures in place, such as a Spill Prevention,Control and Countermeasure (SPCC) Plan oran Environmental Management System (EMS)developed or a National EnvironmentalPerormance Track acility, your SWPPP canreerence the portions o those documents inlieu o duplicating that inormation in yourSWPPP In these instances, you should keepcopies o the relevant portions o those docu-ments with your SWPPP

    Additional SWPPP Documentation

    Ater you become authorized under thepermit, you will need to keep records on anyimplementation activities required under yourpermit, including records related to inspec-tions, maintenance, monitoring results, andcorrective actions This additional documen-tation, although separate rom the actualSWPPP, should be kept with the SWPPP sothat all o your NPDES stormwater records areled in one central location (see Section 7)

    EPAs 2008 MSGP includes the requirements

    or a SWPPP in Part 5 o the permit.

    In your SWPPP, identiy the sta members

    (by name or title) that comprise the acilitys

    stormwater pollution prevention team as well as

    their individual responsibilities. Make sure you

    keep this inormation up-to-date as sta members

    change.

    What to Include in Your SWPPP

    http://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgp
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    6 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Each member o the stormwater pollutionprevention team should have ready access toeither an electronic or paper copy o appli-cable portions o the industrial stormwatergeneral permit and the SWPPP

    2.D What Do I Need to Do to Complete MySWPPP?

    Ater identiying your pollution preventionteam, you are ready to complete the next threesteps in the development o your SWPPP:

    Step 2: Assessing your site and activities(Section 3);

    Step3: Selecting control measures(Section 4); and

    Step 4: Developing procedures or inspec-tions and monitoring (Section 5)

    Section 6 describes nal steps necessary tocomplete your SWPPP and to obtain permitcoverage Section 7 suggests how recordsrelating to permit compliance should be kept

    Qualifed Personnel Members o your

    stormwater pollution prevention team and those

    conducting inspections and monitoring activities

    should be qualied personnel. EPA denes

    qualied personnel as those who posses the

    knowledge and skills to assess conditions and

    activities that could impact stormwater quality

    at your acility, and who can also evaluate the

    eectiveness o control measures.

    Consider adding a stormwater management

    component to employee job descriptions and

    annual reviews, as appropriate to specic

    jobs. Oten these requirements compliment

    existing tasks such as maintaining a clean work

    area; promptly cleaning up spills and leaks;

    perorming regularly scheduled equipmentmaintenance; and properly storing all chemicals,

    oils, and other liquid pollutants.

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 7

    This section describes how to collect the inormation needed or your SWPPP Thisinormation includes:

    An assessment o the activities perormed at your acility this assessment will helpidentiy potential pollutant sources

    An evaluation o existing sampling data a review o sampling data will showwhere past problems have occurred

    Preparing maps o your acility site maps will identiy the location o industrialactivities, pollutant sources, control measures, and the direction o stormwater fow

    3.A Conduct an Assessment o the Activities Perormed at Your FacilityThe rst step in developing a SWPPP is to gain a thorough understanding othe activities conducted and equipment located at your acility to be able toidentiy potential pollutant discharge concerns To complete this step, you willneed to conduct a detailed walk-through o your acility to identiy industrialmaterials or material handling activities exposed to stormwater (see text boxbelow), any stormwater controls already in place at your acility, the direc-tion o stormwater fow through and rom your acility, and the location o allstormwater outalls I possible, you should conduct your walk-through dur-ing a rain event so that you can observe the fow o stormwater on your siteIn addition to your walk-through, you should communicate with ellow siteemployees who may be more amiliar with daily operations than you so that you can

    thoroughly identiy any activities that may contribute stormwater pollutants, but thatmay not be readily visible during a routine walk-through (eg, to identiy activitiesthat are not perormed on a routine basis)

    Section 3: Site Assessment and

    Planning (Step 2)

    How Does EPA Defne Industrial Materials and Material Handling

    Activities?

    Industrial materials or activities include, but are not limited to: material handlingequipment or activities; industrial machinery; raw materials; industrial production and

    processes; and intermediate products, byproducts, nal products, and waste products.

    Material handling activities include, but are not limited to: the storage, loading and

    unloading, transportation, disposal, or conveyance o any raw material, intermediate

    product, nal product or waste product. See 40 CFR 122.26(g).

    Develop a list o industrial

    activities at your site exposed

    to stormwater. Identiy these

    activities on your site map.

    What to Include in

    Your SWPPP

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    8 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    The acility assessment will reveal locationswhere industrial materials or material han-dling activities may be contributing stormwa-ter contaminants, and help you identiy themost important pollutant sources The ollow-ing approach is suggested or completing youracility assessment:

    Identifcation o Activities Exposed toStormwater As you conduct your acilityassessment, make a list o the industrialactivities exposed to stormwater (eg, mate-rial storage; equipment ueling, maintenance,and cleaning; cutting steel beams) Note theirlocation so they can be identied on the sitemap

    Inventory o Materials and Pollutants Makea list o the materials and pollutants (eg,crankcase oil, zinc, suluric acid, and clean-ing solvents) associated with each identied

    activity, including pollutants associated withthese materials, based on how they are stored,handled, disposed, etc Note whether thesematerials are exposed to stormwater, or havethe potential to be exposed to stormwater Howmaterials are stored and handled has a bearingon the potential or stormwater pollution

    Areas with Spill or Leak Potential Documentwhere potential spills and leaks may occur,and speciy the outall(s) that could beaected by such spills and leaks Documentall signicant spills and leaks that actuallyoccurred at exposed areas, or that drained to

    a stormwater conveyance, in the three yearsprior to the date you prepare or amend yourSWPPP You should consider spillage andleakage o all types o materials when prepar-ing or and documenting such releases

    Presence o Non-Stormwater Discharges A non-stormwater discharge is any discharge romyour acility this is not composed entirely orainall or snowmelt runo Non-stormwaterdischarges oten come rom potable watersources or process wastewater dischargesWith ew exceptions, the discharge o non-stormwater as runo rom your acility is pro-

    hibited unless it is specically allowed underan NPDES permit

    You must evaluate or the presence o non-stormwater discharges and be able to demon-strate that all unauthorized non-stormwaterdischarges have been eliminated prior toobtaining coverage under a stormwater permit(or that any other discharges are otherwisecovered under a dierent NPDES permit)Conduct your evaluation during a period odry weather (no rain or at least the previousthree days) Walk your site and evaluate eachoutall to identiy any locations with fowingor stagnant water or discharging liquid; thepresence o such water or liquid that would beindicative o a non-stormwater discharge Youshould try to identiy the source o the wateror liquid, and determine i it is one o theallowable non-stormwater discharges identi-ed below or otherwise in need o urtheraction to eliminate the source You shouldalso identiy any indicators o past or inter-mittent non-stormwater discharges (such asevidence o stains at the outall)

    Identiy locations o potential spills and leaks

    that could contribute pollutants to stormwater

    discharges, and the corresponding outalls that

    would be aected. Review past records o all

    signicant spills and leaks that occurred in

    areas exposed to stormwater or that drained to a

    stormwater conveyance over the past three years,

    and provide a summary or copy o such records in

    your SWPPP.

    What to Include in Your SWPPP

    For each o the activities identied above, create

    an inventory o the materials associated with

    each activity (this may be easiest to do in a

    table). Identiy whether these materials are orhave the potential to be exposed to stormwater.

    Also, identiy any pollutants associated with these

    materials based on how they are stored, handled,

    disposed, etc.

    What to Include in Your SWPPP

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 11

    One ree web-based mapping service isEPAs Water Locator Tool, which is avail-able at www.epa.gov/npdes/stormwater/msgp To use the tool, enter your acilityaddress in Step 1, then click on Window toMy Environment in Step 2 (make sure yourpop-up blocker is turned o) You will beable to zoom and reposition the map Whenyou get the map to the appropriate scale andlocation, you can copy and paste it into yourSWPPP Use a graphics program or a pen tomark the location o your acility on the mapAn example general location map is included

    in Figure 3

    3.C Develop General Location and SiteMaps

    The nal step in the site assessment processis to document the results o your site assess-ment on a detailed site map I you havealready developed a site map or an earlierpermit, you should modiy the map as neces-

    sary to refect changes at your acility, includ-ing changes to any o your control measuresor industrial activities

    Your SWPPP must include both a general loca-tion map and a detailed site map The ollow-ing is a discussion o what is required or eachtype

    General Location Map

    A general location map is helpul to identiynearby, but not necessarily adjacent, water-bodies around your acility Include in yourSWPPP a general location map (eg, USGeological Survey (USGS) quadrangle map,or other large scale area map) with enoughdetail to identiy the location o your acil-ity and al l nearby receiving waters that mayreceive your stormwater discharges Create aUSGS map or your area by using the USGSNational Map Viewer (http://nmviewogc.cr.usgs.gov/viewer.htm) Maps can be printed

    or saved as PDF documents and inserted intoyour SWPPP

    Develop a general location map o your acility

    that shows:

    thelocationofyourfacility

    receivingwaterstowhichyourfacility

    discharges

    It may also be helpul to include roads or political

    boundaries to better locate your acility.

    What to Include in Your SWPPP

    Figure 2. Example general location map.

    Figure 3. Example general location map.

    http://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://nmviewogc.cr.usgs.gov/viewer.htmhttp://nmviewogc.cr.usgs.gov/viewer.htmhttp://nmviewogc.cr.usgs.gov/viewer.htmhttp://nmviewogc.cr.usgs.gov/viewer.htmhttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgp
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    12 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    appropriate control measures (Section 4) andmonitoring locations (Section 5), you shouldrevise your site map to refect this inormationand any additional changes identied as youdevelop your SWPPP I you are unable to tall the inormation on one map, use multiplemaps to provide a ull characterization o theinormation described above Also, i activities

    and conditions change at your site during theterm o the NPDES permit, you should updatethe map as described in Section 6C o thisguide An example o a site map is included(see Figure 4) and in Appendix C

    Site Map

    Develop a map o your site that includes,among other things, the ootprint o all build-ings, structures, paved areas, and parkinglots The site map is intended to show thedirection o stormwater fow throughout youracility and the potential pollutant sources

    that may come into contact with your storm-water runo

    EPA recommends that you develop a rst drato the site map based on the inormation col-lected during your assessment Ater you select

    Figure 4. Example site map.

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    14 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Control measures are the best management practices (BMPs) or other structural ornon-structural practices that are used to prevent or reduce the discharge o pollutantsin stormwater Structural control measures, as the name implies, ocus on installationo hard structures to control discharges Structural controls include practices suchas vegetative swales, collection and reuse o stormwater,inlet controls, snow management, inltration devices, andwet retention measures Non-structural control measuresare intended to prevent or reduce the generation o pol-lutants in stormwater and/or the volume o stormwaterruno using practices that ocus on acility operations and

    procedures Examples o non-structural control measuresinclude procedural practices such as employee trainingsand the posting o signs that raise sta awareness tothe BMPs and procedures in place to control stormwaterpollutants

    A combination o preventive and active treatment control measures usually resultsin the most eective stormwater management or minimizing the osite discharge opollutants in stormwater runo Most control measures require regular maintenanceto unction as intended Some control measures have simple main-tenance requirements, while others may require more extensiveupkeep in order to maximize their perormance Note that identiy-ing weaknesses in current acility practices will help permitteesdetermine appropriate control measures or use at the site

    General Stormwater Management Principles

    In most industrial stormwater permits, including the 2008 MSGP,the site operator is given the fexibility to select the type o controlmeasures, including specic technologies, which he/she believes arebest suited to the acility and that will meet the permits require-ments This fexibility is necessary given the variability o eachindustrial operation, the dierences in the topography rom site tosite, and the dissimilarities in the activities and materials exposed tostormwater However, there are certain general principles o storm-water management that are common to all sites, and that can beused by operators in their selection and design o control measures

    These general principles, listed below, should be considered as a wayto maximize the perormance o control measures at your site

    Pollution prevention The best way to prevent stormwater pollution is to mini-mize the use o water contaminants in your industrial activities When selectingcontrol measures or the acility, you should ocus on controls that are gearedtoward reducing pollutants at the source to prevent stormwater pollution Sourcecontrol practices include maintaining equipment, picking up trash and debris,training site sta on appropriate spill procedures, and proper materials manage-ment and storage

    Section 4: Selecting Control

    Measures (Step 3)

    Efuent limits = stormwater control

    requirements. In the 2008 MSGP, as with

    most state industrial stormwater general

    permits, stormwater control measures are those

    structural or non-structural practices that are

    used to achieve the permits efuent limits.

    What does minimize

    mean?

    The technologybased limitsincluded in EPAs 2008 MSGP

    require that you minimize (i.e.,

    dened as reduce and/or eliminate)

    stormwater exposure to pollutants

    using control measures that are

    technologically available, economi

    cally practicable, and achievable in

    light o best industry practice.

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 15

    Minimizing exposure Another eectiveway to minimize stormwater pollution is toeliminate opportunities or stormwater tocome into contact with industrial activi-ties and polluting materials You shouldlook or opportunities to relocate industrialactivities/materials to covered or containedareas and to properly store and transport

    any accumulated scrap or waste material

    Combining controls Combined controlmeasures are oten more eective thancontrol measures in isolation For example,good housekeeping will oten go a long wayto minimize stormwater pollution but ismore eective when combined with mini-mizing the exposure o signicant materi-als or activities and a structural control,such as inlet protection

    Examining your sites pollutant sources Understand the type and quantity o pol-

    lutants that could contaminate stormwaterleaving your acility Use your knowledgeo the potential pollutants to drive yourselection and design o eective controlmeasures

    Maximizing infltration Onsite inltra-tion reduces overland runo, improvesgroundwater recharge, and augments basefow in local streams You should look oropportunities to minimize impervious areaand increase areas where stormwater caninltrate on-site Keep in mind, however,

    that the use o onsite inltration typicallymust be combined with other control mea-sures to avoid ground water contamination

    Using existing vegetated areas Openvegetated swales and natural depressionscan be used to dissipate energy in overlandfow and reduce erosion Vegetated swalesand natural depressions can increase inl-tration and, in some cases, promote uptakeo metals and nutrients by plants

    Buering on-site or adjacent waterbodiesor drainage systems Maintain or restore

    vegetated buer zones between your acili-tys impervious areas and adjacent suracewaters

    Using structural practices (as applicable) When non-structural control measuresare not eective in preventing stormwatercontamination, structural control measures(eg, swirl separators, sand lters, retentionbasins, etc) may be needed to treat storm-water beore it leaves your acility

    EPAs Technology-Based DischargeRequirements

    The ollowing sections describe the 12 catego-ries o discharge requirements (or efuentlimits) required by the 2008 MSGP Althoughthe wording o these requirements may beunique to the EPA permit, many State permitsinclude requirements that are similar to the2008 MSGP

    4.A Minimize Exposure

    The rst step in an eective stormwater con-trol program is minimizing exposure o man-uacturing, processing, material storage areas,loading and unloading areas, dumpsters andother disposal areas, maintenance activities,and ueling operations to rain, snow, snow-melt, and runo by both locating industrialmaterials and activities inside or protectingthem with storm resistant coverings

    No Exposure Exemption

    EPAsregulationsrecognizetheeffectivenessof

    minimizingexposurebyallowingfacilitiestoopt

    out o the permit by submitting a No Exposure

    Certication when all industrial activities are

    protected rom contact with stormwater. The No

    Exposure Certication is included as Appendix K

    o the 2008 MSGP. Note that industrial materials

    do not need to be enclosed or covered i

    stormwater runo rom aected areas will not be

    discharged to receiving waters or i discharges

    areauthorizedunderanotherNPDESpermit.

    Check your State permit or specic requirements

    forincorporatingminimizingexposureintoyourSWPPP.

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    16 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Figure 5. Minimize exposure by providing cover or potential contaminants.

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    Describe all structural controls or practices used to minimize the exposure o industrial activities to rain, snow,

    snowmelt, and runo. The SWPPP must describe where the controls or practices are being implemented at

    your site. The location must also be identied on the SWPPP site map. Examples o exposure-minimizing

    control measures that could be used at your acility and described in the SWPPP include:

    Thelocationandextentofgrading,berms,orcurbsusedtocontaincontaminatedstormwaterordivert

    stormwateraroundareasofindustrialactivity;

    Adescriptionofthetypesofmaterialsandequipmentthatarestoredwithinsecondarycontainmentand

    thelocationofcontainedstorageareas;

    Thelocationofspillcleanupkitsandadescriptionandscheduleforemployeespillabatementandcleanup

    training;

    Properproceduresforleakyvehiclesandequipment,suchasdrippans;parkinginacontainedarea,or

    parkingindoors;

    Theuseandlocationofspill/overflowprotectionequipment;

    Proceduresforlong-termstorageordisposalofequipmentandvehicles,suchasdrainingallfluids;

    Thelocationofcoveredand/orcontainedequipmentcleaningareas;and

    Thedisposalmethodforallwashwater,suchasanon-sitesump(ifasumpisused,specifythepumping

    frequency)orsanitarysewer.

    What to Include in Your SWPPP

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 17

    4.B Good HousekeepingGood housekeeping practices oer a practicaland cost-eective way to maintain a clean andorderly acility to prevent potential pollutionsources rom coming into contact with storm-water Good housekeeping practices also helpto enhance saety and improve the overall

    work environment To eectively documentin your SWPPP that you are including goodhousekeeping procedures at your site, youshould establish protocols to reduce the pos-sibility o mishandling materials or equipmentand train employees in good housekeepingtechniques An eective good housekeepingprogram not only benets stormwater qualitybut makes the acility a clean, sae place oremployees and clients

    Common areas where good housekeeping

    practices should be ollowed include areaswhere trash containers are kept and adjacentareas, material storage areas, vehicle andequipment maintenance areas, and loadingdocks Involving employees in routine moni-toring o housekeeping practices has proven tobe an eective means o ensuring the contin-ued implementation o this control measure

    Labeling Storm Drains A good stormwater

    awareness practice is to label all storm drains

    on your industrial acility with a No Dumping

    Drains to Stream or similar message. I select

    drains at your acility discharge to the sanitary

    sewer system or to a sump (or example, at

    a wash rack), you should label those with a

    Drains to Sanitary Sewer or similar message.

    Figure 6. Two photos showing an industrial acility beore and ater it

    ollowed good housekeeping practices.

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    Describe any practices you are implementing to

    keep exposed areas o your site clean. Describe

    where each practice is being implemented at your

    site. Include here your schedule or approach or:

    Regularpickupanddisposalofwastematerials

    andscrapequipment;

    Maintenanceofcleanworkspaces;

    Routineinspectionsforleaksandofthe

    conditionofdrums,tanks,andcontainers;

    Routineinspectionstomakesurethatindustrial

    materialsareproperlystoredandlabeled;

    Ascheduleforsweepingpavedareasand

    loors, including who will perorm the

    sweeping(employeeorcontractor);

    Theindividualorpositionresponsiblefor

    emptying drip pans placed beneath leaking

    equipment,valves,andfilllines.

    What to Include in Your SWPPP

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    18 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    4.C MaintenanceA good maintenance program requires regu-lar inspections, testing, and the preventivemaintenance and repair o industrial equip-ment (stationary and mobile) and industrialsystems Maintenance programs are intendedto ensure that structural control measures

    and industrial equipment are kept in goodoperating condition and to prevent or mini-mize leaks and other releases o pollutants(see Section 4D or more specic inorma-tion) I you notice a deciency or otherwisend that your control measures or industrialequipment need to be replaced or repaired toensure proper unctioning, and to avoid leaksor other releases, you must make the neces-sary repairs or modications, typically priorto the next wet weather event and as expedi-tiously as practicable

    Facilities with good maintenance programswill keep a maintenance log that tracks theregular maintenance o industrial equipmentand stormwater control measures The logprovides a maintenance history or each pieceo equipment and demonstrates to regulatoryauthorities that you have implemented themaintenance program outlined in your SWPPP

    4.D Spill Prevention and ResponseProcedures

    Spills and leaks, together, are the largestsource o industrial stormwater pollutionFor this reason, your SWPPP must identiycontrol measures that are used at your site tominimize the potential or spills, leaks, and

    other releases that may come into contactwith stormwater Among the practices thatshould be in place at your site are plans oreective response to spills i or when theyoccur I your acility has more than 1,320gallons o oil storage capacity in abovegroundtanks you may also be required to develop aSpill Prevention, Control and Countermeasure(SPCC) plan consistent with 40 CFR 1121

    Employees must be aware o notication

    procedures in the event o a spill or leak,

    including when to contact appropriate acility

    personnel, emergency response agencies, and

    regulatory agencies. State or local requirements

    may necessitate reporting o spills or other

    prohibited discharges to local emergency

    response, public health, or drinking water supply

    agencies. Contact inormation must be posted

    in locations that are readily accessible and

    available to employees. Where a leak, spill, or

    otherreleasecontainingahazardoussubstance

    or oil in an amount equal to or in excess o a

    reportable quantity established under either

    40CFRPart110,40CFRPart117,or40CFR

    Part 302, occurs during a 24-hour period, you

    mustnotifytheNationalResponseCenter(NRC)

    at (800) 424-8802 or, in the Washington,

    DC, metropolitan area, call (202) 267-2675 in

    accordancewiththerequirementsof40CFR

    Part110,40CFRPart117,and40CFRPart

    302 as soon as you have knowledge o the

    discharge.

    Figure 8. Spill kits should be maintained in

    areas with spill potential, such as ueling

    stations.

    Describe procedures to:

    Maintainindustrialequipmentsothatleaks

    and other releases are avoided, and

    Maintainanyofyoursitescontrolmeasuresin

    eective operating condition.

    Include the schedule you will ollow or such

    maintenance activities. Describe where each

    applicable procedure is being implemented at the

    site.

    What to Include in Your SWPPP

    Figure 7. Equipment should receive routine

    preventative maintenance to prevent drips and

    leaks.

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    20 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    4.F Management o RunoSimilar to erosion and sediment controls, themanagement o stormwater runo that fowsthrough your site is an eective way to reducethe pollutants that are discharged rom yoursite Where you employ structures or practicesthat are intended to divert, inltrate, reuse,

    or otherwise reduce stormwater runo so asto reduce the discharge o pollutants, yourSWPPP must include a description o thosecontrols Appropriate measures are highlysite-specic, but may include vegetativeswales, berms, collection and reuse o storm-water, inlet controls, snow management, inl-tration devices, and wet retention measures

    As mentioned previously, a combination o pre-

    ventive and treatment control measures usuallyresults in the most eective approach to storm-water management or minimizing the ositedischarge o pollutants in stormwater runo

    4.G Salt Storage Piles or Piles ContainingSalt

    Salt is commonly used or deicing and othercommercial or industrial purposes, includingmaintenance o paved suraces Salt piles orpiles that are predominantly composed o othermaterials that contain some salt typically mustbe covered or enclosed and otherwise isolatedrom coming into contact with stormwater(eg, good housekeeping, diversions, contain-

    ment) Piles do not need to be enclosed orcovered i stormwater runo rom the piles isnot discharged or i discharges rom the pilesare authorized under another NPDES permit

    To eectively document in your SWPPP thatyou are minimizing exposure o these pilesto stormwater, you should consider creating achecklist to veriy that salt loading and ofoad-ing operations occur within contained areaswith appropriate measures in place to preventthe track out o salt rom the contained areas

    When selecting control measures, be careul not

    to violate local building or re codes and other

    ordinances. An example would be constructing

    a shed or storage o chemicals and then nding

    out rom the re department that you are in

    violation or locating the shed too close to themain building, not equipping the shed with

    sprinklers or other re control device, and not

    properly labeling containers.

    Figure 10. Vegetated berm used to prevent acility

    inundation when the river is at ood stage.

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    Figure 11. Salt pile covered with a tarp.

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    Include the ollowing:

    Adescriptionofcontrolsusedatyoursitetodivert, iniltrate, reuse, contain, or otherwisereduce stormwater runo.

    Adescriptionoflocationsatyoursitewhereeach control will be implemented.

    What to Include in Your SWPPP

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 23

    4.J NonStormwater DischargesIn Section 3A, this guide discussed theassessment o allowable and prohibited non-stormwater discharges at your site As statedin that section, unauthorized non-stormwaterdischarges cannot be discharged rom youracility unless specically authorized by a

    separate, individual NPDES permit YourSWPPP should describe the assessmentyou conducted under Section 3A, how youeliminated any unauthorized non-stormwaterdischarges, and your plans to prevent unau-thorized non-stormwater discharges at youracility

    4.K Waste, Garbage, and FloatableDebris

    You are responsible or making sure thatstormwater runo does not carry waste, gar-bage, and foatable debris to receiving watersTo veriy compliance with this requirement,you should identiy and implement control

    measures (eg, good housekeeping, sweep-ing, keeping lids closed on dumpsters) tokeep exposed areas ree o such materialsAlternatively, your SWPPP should identiyhow you will intercept and properly dispose othese materials beore they leave your acility

    Figure 13. Unauthorized non-stormwater discharge rom

    an industrial acility.

    Figure 14. Poor management o waste and garbage at a

    acility.

    Include the ollowing:

    Alistofallowablenon-stormwaterdischarges

    that occur at your acility.

    Adescriptionofunauthorizednon-stormwater

    discharges ound at your site and how they

    were eliminated.

    Stepstakentoensurethatotherunauthorized

    non-stormwater discharges do not occur in the

    uture.

    Note: I this section is already addressed by your

    documentation o non-stormwater discharges

    (seeSection3.A),youcansimplyincludeacross-

    reerence to that section o your SWPPP.

    What to Include in Your SWPPP

    Include the ollowing:

    Adescriptionofcontrolsandproceduresthat

    will be used to minimize discharges o waste,

    garbage, and loatable debris.

    Descriptionsofthelocationofthesecontrol

    measures and procedures at your site.

    What to Include in Your SWPPP

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    24 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    4.L Dust Generation and Vehicle Trackingo Industrial Materials

    As an operator, you are responsible orminimizing generation o dust and o-sitetracking o raw, nal or waste materials Dustcontrol practices can reduce the activities andair movement that cause dust to be gener-

    ated rom disturbed soil suraces Airborneparticles pose a dual threat to the environ-ment and human health Dust can be car-ried osite, thereby increasing soil loss romdisturbed areas and increasing the likelihoodo sedimentation and water pollution Controlmeasures to minimize the generation o dustinclude:

    Sprinkling/Irrigation Moistening theground surace with water is an eectivedust control method or haul roads andother trac routes

    Vegetative Cover By establishing a vegeta-tive cover on areas that will not see vehicletrac, exposed soil is stabilized and windvelocity at ground level can be reduced,thus reducing the potential or dust tobecome airborne

    Mulch Mulch is a quick and eective, butnot permanent, means o dust control ornewly disturbed areas

    Wind Breaks Wind breaks can be trees orshrubs let in place during site clearing orconstructed barriers such as a wind ence,

    snow ence, tarp curtain, hay bale, cratewall or sediment wall The break reduceswind velocity, minimizing airborne trans-er o soil o site

    Tillage Deep tillage in large open areasbrings soil clods to the surace where theyrest on top o dust, preventing it rombecoming airborne

    Stone Stone can be an eective dust deter-rent or construction roads and entrancesor as a mulch in areas where vegetationcannot be established

    Spray-on Chemical Soil Treatments(Palliatives) Examples o chemical adhe-sives include anionic asphalt emulsion,latex emulsion, resin-water emulsionsand calcium chloride Chemical pallia-tives should be used only on mineral soilsWhen considering chemical applicationto suppress dust, determine whether thechemical is biodegradable or water-solubleand what eect its application could have

    on the surrounding environment, includingwaterbodies and wildlie

    To reduce vehicle tracking o materials andsediment, the operator should keep stored orspilled materials away rom all roads withinthe site Specic measures such as setting upa wash site or separate pad to clean vehicles

    prior to their leaving the site may be eectiveas well

    4.M Numeric Efuent Limitations Basedon Efuent Limit Guidelines

    Some industrial activities identied in indus-trial stormwater permits also have Federalnumeric efuent limits (called efuent limita-tion guidelines) that must be achieved instormwater discharges The efuent limits aremaximum concentrations or levels o specic

    pollutants that can be discharged in acilitystormwater I your acility includes one o theindustrial categories listed below, reer to yourindustrial stormwater general permit (Parts6221 and 213 o EPAs 2008 MSGP) regard-ing numeric efuent limits and monitoringrequirements to which you are subject:

    Dischargesresultingfromspraydownorintentional wetting o logs at wet deckstorage areas

    Runofffromphosphatefertilizermanu-acturing acilities that comes into contact

    with any raw materials, nished product,by-products or waste products

    Runofffromasphaltemulsionfacilities

    Runofffrommaterialstoragepilesatcement manuacturing acilities

    Minedewateringdischargesatcrushedstone, construction sand and gravel, orindustrial sand mining acilities

    Runofffromhazardouswastelandlls

    Include the ollowing:

    Adescriptionofcontrolsandproceduresused

    at your site to minimize the generation o dust.

    Descriptionsofproceduresandcontrolsused

    to minimize o-site tracking o raw, inal, or

    waste materials.

    Describethelocationwhereeachcontroland/

    or procedure will be implemented and include

    on the SWPPP site map.

    What to Include in Your SWPPP

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 27

    Recommended Routine Facility InspectionSequence

    Although you are given the discretion todetermine how best to conduct your inspec-tion, EPA recommends that your inspectionollow a sequence that corresponds to howraw materials arrive at your site and are

    stored or processed in areas exposed to storm-water, and to how intermediate or nishedproducts are stored, processed, or transportedrom your acility Accordingly, the ollowingrecommended inspection sequence wil l helpensure that you conduct a thorough routineinspection at your acility Whichever processyou determine is appropriate or your acility,you are required to describe that approach inyour SWPPP

    1 Plan your inspection: Develop a consis-tent process to ensure that you inspectall areas One method to ensure that yourinspections are consistent and thorough isto create a checklist (or make notes on acopy o your SWPPP) o areas to inspectUse as a resource your updated site mapidentiying the locations o industrial

    activities exposed to stormwater, storm-water conveyances and discharge points,and any BMPs

    2 Evaluate the area where raw materials aredelivered Are these areas contained oris there potential or stormwater to carryspills or pollutants away rom the droparea? I so, can these pollutants leave yoursite to an adjoining acility, storm drain,or surace water? I so, additional controlmeasures should be implemented

    3 Are raw materials stored in a contained

    area with overhead cover, berms, or othersecondary containment? I not, do the rawmaterials have the potential to contributeto stormwater pollution?

    Note: Single-wall chemical containersneed to be located within secondarycontainment structures, behind berms,or covered to prevent stormwater con-tamination rom an accidental release ocontainerized chemicals Similarly, solidmaterials with the potential to containpollutants (ie, scrap material or wrecked

    vehicles) should include secondarycontainment

    4 Is equipment maintenance and uelingconducted in appropriately containedareas? Are spill kits present and ullin areas where a liquid spill could beexpected?

    5 Do the industrial processes occur in cov-ered and contained areas?

    6 Where do you store waste material?

    Note: I the waste material has the poten-

    tial to contaminate stormwater it must bestored in a contained area or otherwisecontrolled Be sure to evaluate the acil-ity bone-yard and scrap all equipmentthat is out-o-date and not intended to bereused

    EPAs 2008 MSGP requires quarterly routine

    acility inspections o all areas where industrial

    materials or activities are exposed to stormwater,

    and o all stormwater control measures used

    to comply with the euent limits contained

    in the permit. Inspections must be conducted

    by qualifed personnel, including at least one

    member o your pollution prevention team,during regular business hours. You must speciy

    the relevant inspection schedules in your

    SWPPP document as required in Part 5.1.5.

    The 2008 MSGP requires that at least one o the

    our quarterly inspections each year be conducted

    when a stormwater discharge is occurring.

    You should check your industrial stormwater

    general permit to determine i it establishes

    exceptions to the inspection requirements orcertain types o sites. For example, 2008 MSGP

    Part 4.1.3 identies exceptions to routine visual

    inspections or inactive or unstaed sites.

    Invest in an inexpensive digital camera to

    photo-document your inspections. Maintaining

    a photo history o inspections and control

    measurescanhelpyoutorecognizeif

    conditions changed or your control measures are

    degrading. Photographs can also help provide

    documentation to EPA or state inspectors that

    control measures are being maintained and

    replaced as needed.

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    28 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    7 Is the nished product appropriately con-tained or potential pollutant sources?

    8 Following the internal evaluation, walk theperimeter o your site and look or evidenceo stormwater dischargesparticularlystains rom oil and grease or chemicalsShould you observe these, look at the dis-charge area and consider additional controlmeasures You should specically observeall stormwater outalls where stormwaterleaves your acility

    9 Following each inspection, you will needto make note o control measures thatrequire maintenance, or that need to bereplaced, and make sure that the SWPPPand site map are current regarding indus-trial activities and potential pollutants

    10 Finally, where appropriate, repair orreplace worn or ineective control mea-

    sures as soon as possible but certainlybeore the next orecasted precipitationevent Routine Facility Inspection Reports

    Your routine acility inspections will needto be recorded and documented Generally,a standard inspection report is taken intothe eld and completed or each inspectionYou should include in your SWPPP a copyo the standard inspection orm you willuse An example routine acility inspectionorm can be ound in the Additional MSGPDocumentation Template on EPAs website atwww.epa.gov/npdes/pubs/

    msgp2008_recordkeepingtemplate.doc

    RemembertoupdateyourSWPPPifyouadd,

    remove, or modiy control measures ollowing

    a routine visual, or other, inspection. Should

    you get inspected, EPA or the State agency will

    expect that all control measures identied in

    your SWPPP to be current and to be eectively

    implemented at your acility.

    Figure 15. Example o a sheen indicating the presence o oil or other hydro

    carbons.

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    As you conduct your routine acility inspections,

    keep in mind these visual indicators o poor

    control measures or missing control measures:

    1.Rainbowcoloredsheenonthesurfaceof

    stormwater indicates the presence o oil or

    other hydrocarbons;2. Brown or other dark colored streaks in

    fowing stormwater indicates soil erosion or

    uncontained sediment;

    3. Stormwater fowing through straw waddles or

    other stormwater containment barriers;

    4. Foam;

    5. Trash and other debris being carried o-site

    by stormwater; and

    6. Overfowing storm drains or detention ponds

    could be indicative o a clog or poor inlet

    design.

    http://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.dochttp://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.dochttp://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.dochttp://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.doc
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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 29

    5.B Visual AssessmentsThe second component o an eective storm-water inspection program is periodic visualassessments o the stormwater dischargingrom your acility Visual assessments are con-ducted on samples taken during a storm event,and require that you make observations o thestormwater sample in order to qualitativelyassess the nature o your discharge based onseveral visual parameters This requires thatyou collect a stormwater sample in a clean,

    clear jar and look at the sample in a well litarea Generally, a sample must be collectedrom each stormwater discharge location asso-ciated with industrial activity The purposeo conducting visual assessments is to makesure that stormwater discharges are ree romobjectionable characteristics (ie, pollutantsyou can see) Should you observe objection-able characteristics, you should backtrackupstream rom the sample collection locationto identiy potential sources o the pollutants

    Some pollutants may be present in stormwaterbut cannot be seen; or this reason EPA or yourState may require benchmark or efuent limitmonitoring depending on the acility SIC codeor industrial sector See Section 5D or moreinormation on monitoring

    Most industrial stormwater permits do notrequire visual assessment samples to be col-lected consistent with 40 CFR Part 136 pro-cedures (the Clean Water Act guidelines or

    Your SWPPP should describe the routine acility inspection process in enough detail that a member o your sta could complete an

    inspection by ollowing the description in the SWPPP. The SWPPP description should include:

    1. Person(s) or positions o person(s) responsible or conducting the routine acility inspections

    At least one member o your stormwater pollution prevention team should be involved in the routine acility inspections. Consider

    involving employees who regularly work in areas where stormwater may come into contact with industrial activity or materials.

    2. Schedules or conducting the routine acility inspections

    Identifytheminimuminspectionfrequency(e.g.,monthly,quarterly)inyourSWPPP.Considerschedulingtheinspectionsfora

    setdayeverymonthorquarter,yetallowsufficientflexibilitytobeabletotakeadvantageofastormevent,sincemanypermits

    requirethatatleastoneinspectionbeconductedduringarainevent.

    3. Routine acility inspection procedures

    Describe how the routine acility inspection will be conducted, including which control measures or areas will be inspected

    and what the inspector will be looking or. Examples o things the inspector should be looking or include the condition o

    stormwateroutfalls(trashaccumulation,staining,evidenceofunauthorizednon-stormwaterdischarges,etc.);overallgood

    housekeeping;andtheconditionofinstalledcontrolmeasures(doanyneedtobemaintainedorreplaced?).

    Amongotherprocedurestodescribe,provideadescriptionofthesequenceyouwillfollowduringeachinspection.Oneoptionis

    tousetherecommendedinspectionsequenceaboveorcustomizeittobettersuityourfacilityslayout.

    4. Reporting procedures

    Describe your reporting procedures and include a blank copy o the inspection orm that will be used during the routine

    inspections.Mostindustrialstormwatergeneralpermitsrequirethatinspectionreportsincludethefollowing: Theinspectiondateandtime.

    Thename(s),title(s),andsignature(s)oftheinspector(s).

    Weatherinformationforthedayoftheinspectionand,ifappropriate,daysorweekspriortotheinspection.

    Adescriptionofanydischargesobserved.

    Adescriptionofthevisualqualityofdischarges(sheen,turbid,etc.).

    Controlmeasuresinneedofmaintenanceorrepairs.

    Controlmeasuresthatneedtobereplaced.

    Anyincidentsofnoncomplianceobserved.

    Additionalcontrolmeasuresneededtocomplywiththepermitrequirements.

    Inspection reports also need to be signed by the inspector. Your inspection orm should include a signature line or this.

    What to Include in Your SWPPP

    Check your industrial stormwater permit to

    determine i you are required to submit your

    visual assessment samples to a laboratory or

    analysis. The 2008 MSGP does not require

    samples to be submitted to a laboratory.

    However, i your permit does require you to

    submit samples or laboratory analysis, the

    samples must be collected and documented in

    accordancewith40CFRPart136guidelines.

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    30 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    establishing test procedures or the analysiso pollutants); however, visual assessmentsamples should be collected in such a man-ner that the samples are representative o thestormwater discharge

    EPAs 2008 MSGP includes specic require-ments or when and how to collect the visual

    assessment sample You should look in yourpermit to determine what requirements applyto your acilitys visual assessments However,EPA believes its permits requirements oera clear and consistent way to conduct theseassessments They are summarized asollows:

    Collectstormwatersampleswithintherst30 minutes o an actual discharge rom astorm event I it is not possible to collect

    the sample within the rst 30 minutes odischarge, collect the sample as soon aspossible ater the rst 30 minutes In thiscase, be sure to document in your records(kept with your SWPPP) why it was notpossible to take samples within the rst30 minutes In the case o snowmelt,samples must only be taken during a period

    with a measurable discharge rom your site

    Collectthesampleinaclean,clearglass,orplastic container

    Examinethesampleinawell-litareaor, i necessary, illuminate with a strongfashlight

    Collectthesamplesfromdischargesthathappen at least 72 hours (3 days) rom theprevious discharge event

    Include in your SWPPP a description o your visual assessment process:

    1. Person(s) or positions o person(s) responsible or visual assessments.

    Note: The visual assessment should be conducted by a member o your stormwater pollution prevention team.

    2. Schedules or conducting the visual assessments.

    Note:Identifytheminimuminspectionfrequency(typicallyquarterly)inyourSWPPP.Youshouldalsodescribeprocedures

    fordeterminingwhentoconductthevisualassessments(e.g.,within30minutesofanactualdischarge,atleast3daysfrom

    previous discharge, etc.).

    3. Speciic items to be covered by the assessment(e.g.,the2008MSGPrequirespermitteestovisuallyinspectthesampleina

    well-litareatoassessthefollowingwaterqualitycharacteristics:

    Color

    Odor

    Clarity

    Floatingsolids

    Settledsolids

    4. The number and locations o outalls scheduled or visual assessments. Listtheoutfallswherevisualassessmentswilltake

    place, and make sure these locations are identiied on your site map.

    5. A description o saety considerations, requirements, and equipment or collecting samples during wet weather events.

    Note:Samplemustbecollectedinaclean,clearglass(requiredforoilandgreasesamples)orplasticcontainer.Describeany

    otherequipmentnecessarytocollectthesamples(suchassamplingpolesforhardtoreachoutfalls,raingear,etc.).Describe

    any necessary saety considerations or sta while collecting the samples (or example, i they are sampling at an outall

    discharging into receiving water with high lows, or sampling in a manhole).

    6. Reporting procedures: Describe your reporting procedures and include a blank copy o the assessment orm that will be used

    duringthevisualassessments.Mostindustrialstormwatergeneralpermitsrequirethatvisualassessmentreportsincludethe

    ollowing: Samplelocation(s)

    Samplecollectiondateandtime,andvisualassessmentdateandtimeforeachsample

    Thenamesofindividuals,andtitlesorjobpositions,collectingthesampleandperformingvisualassessment,andtheir

    signatures

    Natureofthedischarge(i.e.,runofforsnowmelt)

    Resultsofobservationsofthestormwaterdischarge

    Probablesourcesofanyobservedstormwatercontamination

    Ifapplicable,whyitwasnotpossibletocollectsampleswithinthefirst30minutesofdischarge.

    TheSWPPPshouldalsocontainachecklistorlistofthewaterqualityparametersthatmustbeobservedanddocumented.

    What to Include in Your SWPPP

    Suspendedsolids

    Foam

    Oilsheen

    Otherobviousindicatorsofstormwaterpollution)

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    32 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Based on the answers to these questions, youmay need to modiy your stormwater man-agement program and to update your SWPPPto address problems ound during yourinspection

    Comprehensive Site Inspection Documentation

    The results, and documentation, o yourannual site inspection must be maintained

    on-site and, depending on the requirementsin your stormwater permit, submitted withyour annual report An example o a compre-hensive site inspection report can be oundin the Additional MSGP DocumentationTemplate on EPAs website atwww.epa.gov/npdes/pubs/msgp2008_

    recordkeepingtemplate.doc

    Include in your SWPPP a description o the annual comprehensive site inspection process:

    1. Person(s) or positions o person(s) responsible or inspection

    Note: Include at least one member o the stormwater pollution prevention team.

    2. Schedules or conducting the inspections

    Note: Describe when during the year the annual inspection will take place.

    3. Describe the list o documents to be reviewed prior to the annual site inspection. This list will typically include:

    ThecurrentSWPPP

    Allroutineinspectionreportsforthepastyear Allvisualassessmentreportsforthepastyear

    Otherdocumentationthatmayrelatetohowyourfacilitycomplieswithstormwaterpermitrequirements,suchas

    maintenance records, spill records, etc. or the past year.

    4. A copy o the current SWPPP site map

    Note: A current copy o the site map can be used during the comprehensive site inspection to make sure the inspector is

    coveringallrequiredareas.

    5. Procedures or how the annual inspection will be conducted. Describe how the annual inspection will be conducted,

    including which control measures or areas will be inspected and what the inspector will be looking or. Speciic items to be

    covered by the inspection include:

    Industrialmaterials,residue,ortrashthatmayhaveorcouldcomeintocontactwithstormwater;

    Leaksorspillsfromindustrialequipment,drums,tanks,andothercontainers;

    Offsitetrackingofindustrialorwastematerials,orsedimentwherevehiclesenterorexitthesite;

    Trackingorblowingofraw,final,orwastematerialsfromareasofnoexposuretoexposedareas;and

    Controlmeasuresneedingreplacement,maintenance,orrepair.

    6. A copy o the annual site inspection orm you will use.

    Note: EPAs 2008 MSGP has a comprehensive site inspection orm in Appendix I o EPAs 2008 MSGP. Your annual site

    inspection orm should contain:

    Thedateoftheinspection;

    Thename(s)andtitle(s)ofthepersonnelmakingtheinspection;

    Findingsfromtheareasofyourfacilitythatwereexamined;

    Allobservationsrelatingtotheimplementationofyourcontrolmeasuresincluding:

    Previously unidentiied discharges rom the site,

    Previously unidentiied pollutants in existing discharges,

    Evidenceof,orthepotentialfor,pollutantsenteringthedrainagesystem; Evidence o pollutants discharging to receiving waters at all acility outall(s), and the condition o and around the

    outall, including low dissipation measures to prevent scouring, and

    Additionalcontrolmeasuresneededtoaddressanyconditionsrequiringcorrectiveactionidentifiedduringthe

    inspection.

    AnyrequiredrevisionstotheSWPPPresultingfromtheinspection;

    Anyincidentsofnoncomplianceobservedoracertificationstatingthefacilityisincompliancewiththispermit(ifthereisno

    noncompliance);and

    Astatement,signedandcertifiedinaccordancewithAppendixB,Subsection11ofEPAs2008MSGP.

    7. A schedule or completing and submitting (i required) the annual site inspection orm/report in a timely manner.

    What to Include in Your SWPPP

    http://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.dochttp://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.dochttp://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.dochttp://www.epa.gov/npdes/pubs/msgp2008_recordkeepingtemplate.doc
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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 33

    5.D Documentation o MonitoringProcedures

    Your industrial stormwater general permit mayinclude requirements to conduct stormwaterdischarge monitoring The type o monitor-ing you are required to conduct will likely bebased on your type o industrial activity Not

    all types o industrial activity will be requiredto collect stormwater discharge samples,however, i your acility is required to conductmonitoring (such as benchmark monitoring orefuent limitation guideline monitoring), youmust describe the procedures you will use tocarry out this monitoring in your SWPPP

    EPA has prepared anIndustrial StormwaterMonitoring and Sampling Guide (availableat www.epa.gov/npdes/stormwater/msgp )

    that will support this guide TheIndustrialStormwater Monitoring and Sampling Guideprovides a more detailed description o moni-toring approaches and procedures that arerecommended than is included in this guide

    As a general matter, your stormwater dischargesamples will be taken at your acilitys storm-

    water outall locations, not at locations withinyour acility Some stormwater general permitsallow you to sample at only one outall whenmultiple outalls at your acility have similarindustrial activities, control measures, exposedmaterials, and runo coecients Outalls thathave these similar characteristics are calledsubstantially identical outalls or represen-tative outalls See your industrial stormwatergeneral permit or more inormation

    IncludeinyourSWPPP,adescriptionofthefollowingmonitoringrequirements:

    1. What you need to monitor

    Make sure your SWPPP clearly identiies the parameters you need to monitor, and any applicable benchmark concentrations or

    eluent limits associated with each parameter.

    2. Where you need to monitor

    Yoursitemapshouldidentifytheoutfallsatyourfacility.InyourSWPPP,identifyatwhichoutfallsyouwillberequiredto

    monitor. I you are allowed to sample one o the out alls that are substantially identical, and you plan on using a representative

    outall, include the ollowing documentation in your SWPPP:

    Locationofeachsubstantiallyidenticaloutfall;

    Descriptionofthegeneralindustrialactivitiesconductedinthedrainageareaofeachsubstantiallyidenticaloutfall;

    Descriptionofthecontrolmeasuresimplementedinthedrainageareaofeachsubstantiallyidenticaloutfall;

    Descriptionoftheexposedmaterialslocatedinthedrainageareaofeachsubstantiallyidenticaloutfallthatarelikelytobe

    significantcontributorsofpollutantstostormwaterdischarges;

    Anestimateoftherunof fcoefficientofthedrainageareas(low=under40%;medium=40to65%;high=above65%);

    and

    Whytheoutfallsareexpectedtodischargesubstantiallyidenticaleffluents.

    3. When you need to monitor

    Ifyouarerequiredtomonitor,yourindustrialstormwatergeneralpermitwillspecifyamonitoringfrequency(typicallyquarterly

    orannually).Foreachoftheparametersyouidentifiedabove,includeinyourSWPPPthemonitoringfrequency.Somepermits

    also speciy exemptions or alternative monitoring periods, which should also be addressed in your SWPPP.

    YourSWPPPshouldalsodescribethetypeofstormeventthatshouldbemonitored.Inthe2008MSGP,EPArequires

    monitoring during a storm event those results in an actual discharge rom your site (measurable storm event) that ollows the

    precedingmeasurablestormeventbyatleast72hours(3days).

    4. How you will conduct the monitoringDescribe in your SWPPP how you will conduct the monitoring, including who will collect the samples. Typically, monitoring is

    conducted by taking one grab sample rom a discharge resulting rom a measurable storm event and collected within the irst

    30minutesofameasurablestormevent,duringnormalbusinesshours,whenstormwaterisdischargingfromyourfacility.

    Also describe any sample documentation and preservation procedures you plan to use. Some samples may need to be analyzed

    within a short time, or may need to be preserved with blue ice beore being analyzed.

    5. Where you will send the sample or analysis

    Finally, in your SWPPP, include inormation about the laboratory where you will send the samples or analysis. Include inormation

    suchaslabnameandaddress,anysamplingproceduresrequiredbythelab,andwhowilltakethesamplestothelab.

    What to Include in Your SWPPP

    http://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgp
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    34 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Section 6: Completing Your SWPPP

    Now that you have conducted a site assessment o your acility, developed maps,

    selected control measures, and developed procedures or inspections and monitoringYou are almost done with your SWPPP! The last step is to make sure all this inorma-tion is organized into a single document (your SWPPP) and to obtain NPDES permitcoverage

    6.A Finish your SWPPPThe inormation you put together as part o Sections 3 through 5 make up the con-tents o your SWPPP There are only two more steps or you to nish beore yourSWPPP is complete:

    ConductanalreviewofyourSWPPP;and

    SignandcertifyyourSWPPP

    Review Your Draft SWPPP

    You should review the SWPPP requirements in your industrial stormwater generalpermit to ensure that your SWPPP includes all required elements For example, in the2008 MSGP, the SWPPP requirements are in Part 5 Check o all the SWPPP permitrequirements as you veriy that they have been met Also, develop a nal copy o yoursite map and make sure that all required elements are addressed

    EPA recommends that you have both your stormwater pollution prevention team, andsomeone who was not involved in developing the SWPPP, review your drat SWPPP

    Sign and Certify Your SWPPP

    The last step in completing your SWPPP is to have a acility executive or duly autho-rized representative o that executive sign and certiy that the SWPPP meets all therequirements in the general permit This signature demonstrates that the SWPPP wasreviewed by someone who has operational control over the acility (ie, can commitresources to implementing the SWPPP and ensuring compliance with the permit)You should check your general permit to determine which person is required to signand certiy the SWPPP Note that the signatory requirements or the 2008 MSGP areound in Appendix B, Subsection 11 o EPAs 2008 MSGP

    6.B Obtain NPDES Permit CoverageImportant! Beore obtaining permit coverage, you should read the appropriate industrial

    stormwater permit and develop your SWPPP.

    Most permits require that you develop your SWPPP beore you can obtain NPDES per-mit coverage or your industrial stormwater discharges However, in some instances,the permit may provide you with additional time to complete or update a SWPPP aterpermit coverage is obtained Nevertheless, it is recommended that your SWPPP becompleted at least in drat orm prior to applying or permit coverage, even in thoseStates where additional time is granted

    Obtaining Coverage Under a General Permit

    To obtain coverage under a State industrial stormwater general permit, you will typi-cally need to ll out and submit an application orm, oten called a Notice o Intent or

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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 35

    NOI Submitting an NOI orm to the permit-ting authority indicates your certication thatyou have met the eligibility requirements orcoverage under the permit, and your agree-ment to abide by the terms and conditions othe general permit Depending on the permit,you may be authorized to discharge immedi-ately or at some later time In some cases, you

    are not authorized to discharge until the Statehas notied you accordingly EPAs 2008 MSGP(see Part 131) uses a 30 to 60-day waitingperiod ollowing the receipt o a acilitys com-plete NOI The waiting period expires whenthe permits status changes rom waiting toactive on the Agencys eNOI website

    Read the application requirements in yourgeneral permit or inormation on the proce-dures and the specic orm you will need tocomplete beore becoming authorized SomeStates charge an administrative ee to apply or

    permit coverage Beore submitting your appli-cation, you must also make sure that you meetall eligibility requirements in the permit Forexample, i your acility discharges to one oseveral highly protected waters (eg, a Tier 3or Outstanding Natural Resource Water),you may not be eligible or coverage under ageneral permit and instead may have to le anapplication or individual permit coverage

    6.C Updating Your SWPPP

    Your SWPPP is a document that will need tobe reviewed and updated on a regular basisWhenever you nd the need to change a pro-cedure that is described in your SWPPP or tomodiy a control measure described therein,you must update the SWPPP to refect thosechanges as quickly as practicable Should theSWPPP require modication to document cor-rective actions, a new certication statementmust be signed and dated upon completion othe revision

    Below are some examples o events that, ithey result in a change in control measures orprocedures, will require prompt revision o theSWPPP to refect the new acility conditions

    Achangeinthecompositionofthestorm-water pollution prevention team or newresponsible ocial

    Anunauthorizedreleaseordischarge(e.g.,spill, leak, or discharge o non-stormwaternot authorized by this or another NPDESpermit) occurs at your acility

    Adischargeviolatesanumericefuentlimit

    Youbecomeaware,orEPAdetermines,thatyour control measures are not stringentenough or the discharge to meet applicablewater quality standards;

    Aninspectionorevaluationofyourfacilityby an EPA ocial, or local, State, or Tribalentity, determines that modications to thecontrol measures are necessary to meet thenon-numeric efuent limits in this permit

    Constructionorachangeindesign,opera-tion, or maintenance at your acility sig-nicantly changes the nature o pollutantsdischarged in stormwater rom your acil-ity, or signicantly increases the quantityo pollutants discharged

    Theaverageoffourquarterlysamplingresults exceeds an applicable benchmarkI less than our benchmark samples havebeen taken, but the results are such thatan exceedance o the 4 quarter average ismathematically certain (ie, i the sum oquarterly sample results to date is morethan 4 t imes the benchmark level) this isconsidered a benchmark exceedance, trig-gering a review o control measures andpossible SWPPP modication

    Remember, revisions to the SWPPP to docu-ment corrective actions requires a new signedand dated certication statement by the respon-sible ocial All other changes must be signedand dated by the person preparing the change

    In the interim between the annual inspection and completed SWPPP

    revision, keep a copy o the original SWPPP with your handwritten

    notes or SWPPP modications at the acility. Should you be

    inspected beore the revised SWPPP is complete, the copy with your

    notes can be used to demonstrate the changes that will be in the

    revised document.

    Documentation to Support EligibilityConsiderations Under Other Federal Laws

    The 2008 MSGP requires that you keep with

    your SWPPP the documentation supporting

    your eligibility pertaining to endangered species

    requirements, historic properties requirements,

    and NEPA review requirements described in

    the permit (see Part 5.1.6 o the permit). State

    industrial stormwater permits may have other

    documentation requirements.

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    36 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Completing your SWPPP and obtaining NPDES permit coverage is an important steptowards complying with your State or EPA Clean Water Act requirements Havingcompleted these steps, you are now ready to begin documenting your compliancewith the requirements o your permit EPAs 2008 MSGP and many State permitsrequire you to keep records o any activities at your site that are related to your com-pliance, such as conducting inspections, visual assessments, stormwater dischargemonitoring, and corrective actions

    As you conduct inspections, monitoring, corrective actions, and other permit imple-mentation activities, you will generate additional records, such as inspection reportsand monitoring results Keep this additional documentation on-site with your SWPPP,

    and ensure these records are accessible, complete, and up-to-date so that they demon-strate your ull compliance with the conditions o your permit

    Some examples o this additional documentation include:

    Permit records copies o the NOI or permit application submitted, any lettersreceived rom the permitting authority, and a copy o your general permit

    Spill records dates o any incidences o signicant spills, leaks, or other releasesthat resulted in a discharge o pollutants, the circumstances leading to the release,actions taken in response to the release, and measures taken to prevent the recur-rence o a release

    Employee training records keep copies o all employee training records, includingdates, who was trained, and the training topics

    Maintenance records retain copies o all maintenance and repairs o control mea-sures, including dates o regular maintenance, dates when maintenance needs werediscovered, and dates when control measures were returned to ull unction

    Inspection records keep copies o all routine acilityinspection reports, quarterly visual assessment reports,and annual comprehensive site inspection reports

    Monitoring records retain records o all samplingresults including data collection orms, lab results, anddischarge monitoring reports (DMRs)

    Corrective action records keep records o any cor-rective actions and ollow-up activities conducted todemonstrate compliance with the permit

    Section 7: Keeping Records o Your

    Implementation Activities

    For 2008 MSGP permit holders, the list o

    additional documentation requirements can be

    ound in Part 5.4 o the permit. Also, EPA has

    developed an Additional MSGP Documentation

    Template with sample orms that you can

    download rom www.epa.gov/npdes/stormwater/

    msgptohelpyouorganizethisinformation.

    http://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgphttp://www.epa.gov/npdes/stormwater/msgp
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    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 39

    Resources

    EPA, 2008 Multi-Sector General Permit, issued September 29, 2008(available at www.epa.gov/npdes/stormwater/msgp )

    EPAs Stormwater Website www.epa.gov/npdes/stormwater

    Industrial Stormwater Resource Locator www.envcap.org/iswrl/

    EPAs Industrial Stormwater Website www.epa.gov/npdes/stormwater/indust

    EPAs 2008 MSGP Website www.epa.gov/npdes/stormwater/msgp

    The Industrial Stormwater and MSGP Websites have a number o resources and tools to aid MSGPpermittees, which include:

    Annual Reporting Form Permittees can use this orm to report their annual comprehensivesite inspection and corrective actions to EPA

    Conditional No Exposure Exclusion Industrial acilities can use this orm to certiy that their

    industrial materials and operations are not exposed to stormwater Developing your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    Provides guidance on how to develop a SWPPP that meets the requirements o the 2008 MSGP

    Electronic Notice of Intent (eNOI) System Allows permittees to quickly apply or permitcoverage under EPAs 2008 MSGP

    Industrial Stormwater Monitoring and Sampling Guide Provides guidance on how to meet themonitoring and sampling requirements in the 2008 MSGP

    Industrial Sector Fact Sheets These act sheets summarize the types o acilities included thatsector, the pollutants associated with this sector, and the types o stormwater control measuresgenerally used

    List of Tier 2 and Tier 3 Waters Lists o waters currently designated by states as Tier 2 or Tier

    3 or antidegradation purposes to help you complete your NOI

    MSGP Discharge Monitoring Report (MDMR) Permittees can use this paper copy orm tosubmit monitoring data to EPA

    Reporting MSGP Monitoring Data Allows permittees to electronically le all benchmark,efuent limitation guidelines, and impaired waters monitoring data through the eNOI system

    Sample MSGP SWPPP Template Industrial acilities can use the Industrial SWPPP Templateto create their own SWPPPs

    Sample Recordkeeping Templa