Plan de Prevención de la Contaminación de Aguas Pluviales_EPA 833-B-09-002_2009
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Transcript of 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
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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.
Tetra
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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.
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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.
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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.
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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