EPA 833-B-09-002
Developing Your Stormwater
Pollution Prevention Plan
A Guide for Industrial Operators
February 2009
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Contents
Section 1: Introduction i
l.A Why Should You Use This Guide? 1
l.B What Is Stormwater Runoff and What Are Its Impacts? 1
Section 2: Getting Started 3
2.A Am I Required to Develop a SWPPP? 3
2.B What Are the Basic Elements Required in a SWPPP? 4
2.C Stormwater Pollution Prevention Team (Step 1) 5
2.D What Do I Need to Do to Complete My SWPPP? 6
Section 3: Site Assessment and Planning (Step 2) 7
3.A Conduct an Assessment of the Activities Performed at Your Facility 7
3.B Evaluate Sampling Data 10
3.C Develop General Location and Site Maps 11
Section 4: Selecting Control Measures (Step 3) 14
4.A Minimize Exposure 15
4.B Good Housekeeping 17
4.C Maintenance 18
4.D Spill Prevention and Response Procedures 18
4.E Erosion and Sediment Controls 19
4.F Management of Runoff 20
4.G Salt Storage Piles or Piles Containing Salt 20
4.H Sector-Specific Requirements 21
4.1 Employee Training 22
4.J Non-Stormwater Discharges 23
4.K Waste, Garbage, and Floatable Debris 23
4.L Dust Generation and Vehicle Tracking of Industrial Materials 24
4.M Numeric Effluent Limitations Based on Effluent Limit Guidelines 24
4.N Additional Controls to Address Impaired Waters 25
Section 5: Procedures for Inspections and Monitoring (Step 4) 26
5.A Routine Facility Inspections 26
5.B Visual Assessments 29
5.C Annual Comprehensive Site Inspections 31
5.D Documentation of Monitoring Procedures 33
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 6: Completing Your SWPPP 34
6.A Finish your SWPPP 34
6.B Obtain NPDES Permit Coverage 34
6.C Updating Your SWPPP 35
Section 7: Keeping Records of Your Implementation Activities 36
Section 8: Common Compliance Problems at Industrial Facilities 37
Resources 39
Appendices
Appendix A: MSGP SWPPP Template 40
Appendix B: Additional MSGP Documentation Template 41
Appendix C: Example Site Map 42
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 1: Introduction
This guide includes suggestions on how to develop a stormwater pollution prevention
plan (SWPPP). This guide does not impose any new legally binding requirements on
EPA, States, or the regulated community, and does not confer legal rights or impose
legal obligations upon any member of the public. In the event of a conflict between
the discussion in this document and any statute, regulation, or permit, this document
would not be controlling.
Interested parties are free to raise questions and objections about the substance of
this guide and the appropriateness of the application of this guide to a particular situ-
ation. EPA and other decision makers retain the discretion to adopt approaches on a
case-by-case basis that differ from those described in this guide where appropriate.
l.A Why Should You Use This Guide?
You should use this guide if you are an operator of an industrial facility required
to develop a stormwater pollution prevention plan (SWPPP) that complies with a
National Pollutant Discharge Elimination System (NPDES) industrial stormwater
permit issued by your State or the U.S. Environmental Protection Agency (EPA). You
may also find this guide to be useful if you are a State or EPA inspector who reviews
SWPPPs, or you operate a commercial facility that is not required to obtain an NPDES
permit but you are nevertheless interested in ways to minimize stormwater-related
pollution at your facility.
Because each State permit can be slightly different, this guide is written more geneti-
cally in an attempt to make it applicable to as many industrial general permits as
possible. Owners and operators of industrial facilities should carefully read their
respective industrial stormwater general permit to understand
where using this guide may conflict with a State SWPPP require-
ment, and make adjustments to their SWPPPs as needed. EPA
includes additional text describing how to address SWPPP
requirements that are specifically included in the Agency's own
2008 Multi-Sector General Permit (MSGP), the "2008 MSGP".
SWPPP Tip!
In addition to helping you develop a SWPPP, this guide also
includes sections that will assist you in keeping your implemen-
tation records and in avoiding common compliance problems,
after you are authorized under the EPA 2008 MSGP or your
State's general permit. See Section 7 for a discussion of how to
keep implementation records. See Section 8 for a discussion of
common compliance problems.
Owners and operators of industrial facilities,
which are subject to a State or EPA industrial
stormwater general permit typically must
develop a SWPPP as a basic requirement. If
your facility is subject to such a requirement,
failing to develop a SWPPP can result in
enforcement action against your facility by
EPA or a State! For example, EPA has targeted
enforcement actions against some industrial
sectors for failing to have developed SWPPPs
for their facilities.
l.B What Is Stormwater Runoff and What Are Its Impacts?
Stormwater runoff is water from rain or snowmelt that does not immediately infiltrate
into the ground and flows over or through natural or man-made storage or convey-
ance systems. When undeveloped areas are converted to land uses with impervious
surfaces such as buildings, parking lots, and roads, the natural hydrology of the
land is altered and can result in increased surface runoff rates, volumes, and pollut-
ant loads. Stormwater runoff picks up industrial pollutants and typically discharges
them directly into nearby waterbodies or indirectly via storm sewer systems. Runoff
from areas where industrial activities occur can contain toxic pollutants (e.g., heavy
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Figure 1. Stormwater runoff can carry pollutants from Impervious surfaces to
receiving waters.
metals and organic chemicals) and other
pollutants such as trash, debris, and oil and
grease, when facility practices allow exposure
of industrial materials to Stormwater. This
increased flow and pollutant load can impair
waterbodies, degrade biological habitats, pol-
lute drinking water sources, and cause flood-
ing and hydrologic changes to the receiving
water, such as channel erosion.
Industrial facilities typically perform a
portion of their activities in outdoor areas
exposed to the elements. This may include
activities such as material storage and han-
dling, vehicle fueling and maintenance, ship-
ping and receiving, and salt storage, all of
which can result in pollutants being exposed
to precipitation and capable of being carried
off in Stormwater runoff. Also, facilities may
have performed industrial activities outdoors
in the past and materials from those activities
still remain exposed to precipitation. In addi-
tion, accidental spills and leaks, improper
waste disposal, and illicit connections to
storm sewers may also lead to exposure of
pollutants to Stormwater.
EPA has identified six types of activities at
industrial facilities that have the potential to
be major sources of pollutants in Stormwater:
Loading and Unloading Operations
Loading and unloading operations can
include pumping of liquids or gases from
tankers to storage facilities, pneumatic
transfer of dry chemicals, transfer by
mechanical conveyor systems, or transfer
of bags, boxes, drums or other contain-
ers by forklift or other material handling
equipment. Material spills or losses in these
areas can accumulate and be washed away
during a storm.
Outdoor Storage
Outdoor storage activities include stor-
age of fuels, raw materials, by-products,
intermediate products, final products, and
process residuals. Materials may be stored
in containers, on platforms or pads, in bins,
boxes or silos, or as piles. Storage areas
that are exposed to rainfall and/or runoff
can contribute pollutants to Stormwater
when solid materials wash off or materials
dissolve into solution.
Outdoor Process Activities
Although many manufacturing activities
are performed indoors, some activities,
such as timber processing, rock crush-
ing, and concrete mixing, occur outdoors.
Outdoor processing activities can result in
liquid spillage and losses of material solids,
which makes associated pollutants avail-
able for discharge in runoff.
Dust or Paniculate Generating Processes
Dust or particulate generating processes
include industrial activities with stack
emissions or process dusts that settle on
surfaces. Some industries, such as mines,
cement manufacturing, and refractories,
also generate significant levels of dust that
can be mobilized in Stormwater runoff.
Illicit Connections and Non-Stormwater
Discharges
Illicit connections of process wastes or
other pollutants to Stormwater collection
systems, instead of to sanitary sewers, can
be a significant source of Stormwater pol-
lution. Non-stormwater discharges include
any discharge from the facility that is not
generated by rainfall runoff (for example,
wash water from industrial processes).
With few exceptions, these non-stormwater
discharges are prohibited. Refer to your
permit for a list of authorized non-storm-
water discharges.
Waste Management
Waste management practices include
everything from landfills to waste piles to
trash containment. All industrial facilities
conduct some type of waste management
at their site, much of it outdoors, which
must be controlled to prevent pollutant
discharges in Stormwater.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 2: Getting Started
2.A Am I Required to Develop a SWPPP?
The Clean Water Act (Section 402 (p)) requires that operators of "discharges associated
with industrial activity" obtain a National Pollutant Discharge Elimination System
(NPDES) permit. EPA regulations (40 CFR 122.26) define the categories of industrial
activity required to obtain NPDES permits, and specify the application requirements
for these permits. To regulate stormwater discharges from these industrial activities,
EPA and authorized States issue NPDES general permits.
Most industrial stormwater discharges are covered under general permits, as opposed
to individual permits, although States and EPA can and do issue individual permits
to some facilities based on site-specific or industry-specific concerns. General permits
are used primarily because they avoid the need to issue multiple permits, and instead
only require a single permit to cover a large number of industrial facilities performing
similar types of activities. To be covered under a general permit, an eligible operator
of an industry must read the general permit, typically develop a SWPPP, comply with
any special eligibility provisions, and submit a notice of intent (NOI) or permit appli-
cation to the permitting authority.
Federal regulations require NPDES permit coverage for stormwater discharges from
the following categories of industrial activity:
Category One (i): Facilities subject to federal stormwater effluent discharge stan-
dards in 40 CFR Parts 405-471
Category Two (ii): Heavy manufacturing (for example, paper mills, chemical
plants, petroleum refineries, and steel mills and foundries)
Category Three (iii): Coal and mineral mining and oil and gas exploration and
processing
Category Four (iv): Hazardous waste treatment, storage, or disposal facilities
Category Five (v): Landfills, land application sites, and open dumps with industrial
wastes
Category Six (vi): Metal scrapyards, salvage yards, automobile
junkyards, and battery reclaimers
Category Seven (vii): Steam electric power generating plants
Category Eight (viii): Transportation facilities that have
vehicle maintenance, equipment cleaning, or airport deicing
operations
Category Nine (ix): Treatment works treating domestic sewage
with a design flow of 1 million gallons a day or more
Category Eleven (xi): Light manufacturing (For example, food
processing, printing and publishing, electronic and other elec-
trical equipment manufacturing, and public warehousing and
storage).
SWPPP Tip!
EPA's 2008 Multi-Sector General Permit (2008
MSGP) Applies to a Limited Geographic Area -
The 2008 MSGP applies in five States (Alaska,
Idaho, New Mexico, Massachusetts, and
New Hampshire), Indian Country lands, most
territories, and some federal facilities. Alaska
will be taking over administration of stormwater
permits beginning in 2009. Information on
where the 2008 MSGP is available is included
as Appendix C of the 2008 MSGP, which can be
found at www.epa.gov/npdes/stormwater/msgp.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Where Do I Get a Copy of the Industrial
Stormwater General Permit in My State?
To determine who issues the industrial
stormwater permit in your State, you can visit
EPA's stormwater website at www.epa.gov/
npdes/stormwater/authorizationstatus or
the Industrial Stormwater Resource Locator at
www.envcap.org/iswrl.
Who Is an Operator?
EPA defines the operator of an industrial facil-
ity as:
The entity that has operational control over
industrial activities, including the ability to
modify those activities, or
The entity that has day-to-day operational
control of activities at a facility neces-
sary to ensure compliance with the permit
(e.g., the entity that is authorized to direct
workers at a facility to carry out activities
required by the permit). See definition in
Appendix A of the 2008 MSGP.
In many cases, the owner and operator are
one in the same person. In a few instances,
there may be more than one operator at a site
(with the owner being an operator based on
the definition provided above). Where there is
both an owner (without operational control)
and an operator, it is the operator's responsi-
bility to obtain permit coverage and comply
with the permit provisions.
SWPPP Tip!
What is a SWPPP?
A SWPPP is a site-specific, written document
that:
Identifies potential sources of stormwater
pollution at the industrial facility;
Describes stormwater control measures that
are used to reduce or eliminate pollutants
in stormwater discharges from the industrial
facility; and
Identifies procedures the operator will use
to comply with the terms and conditions of
the 2008 MSGP or a State general industrial
stormwater permit.
You are required to develop your SWPPP to
address the specific conditions at your site and
keep it up-to-date to reflect changes at your
site both for your use and for review by the
regulatory agencies responsible for overseeing
your permit compliance.
2.B What Are the Basic Elements
Required in a SWPPP?
A SWPPP is a written document that identi-
fies the industrial activities conducted at the
site, including any structural control prac-
tices, which the industrial facility operator
will implement to prevent pollutants from
making their way into stormwater runoff.
The SWPPP also must include descriptions of
other relevant information, such as the physi-
cal features of the facility, and procedures for
spill prevention, conducting inspections, and
training of employees. The SWPPP is intended
to be a "living" document, updated as neces-
sary, such that when industrial activities or
stormwater control practices are modified or
replaced, the SWPPP is similarly revised to
reflect these changes.
The process of developing a SWPPP involves
the following four steps:
Step 1: Formation of a pollution preven-
tion team of qualified personnel who will
be responsible for preparing the plan and
assisting the plant manager in implement-
ing practices to comply with the permit;
Step 2: Assessment of potential stormwater
pollution sources;
Step 3: Selection of appropriate control
measures that minimize the discharge of
pollutants during storm events for each of
these sources; and
Step 4: Development of procedures for
conducting required inspection/monitoring
activities, as well as regular maintenance
of control measures.
This guide will assist you with these four
steps. The selection of a pollution preven-
tion team is discussed in the next section
(Section 2.C). Site assessment is addressed in
Section 3, the selection of control measures is
discussed in Section 4, and inspection/moni-
toring procedures are addressed in Section 5.
The remaining sections of the guide address
implementation of practices to comply with
the permit and periodic evaluation of your
SWPPP.
SWPPP Tip!
Prepare your SWPPP before submitting an NOI
or permit application for coverage!
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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A typical SWPPP includes the following
elements:
Stormwater pollution prevention team;
Site description;
Summary of potential pollutant sources;
Description of control measures;
Schedules and procedures;
Documentation to support eligibility con-
siderations under other federal laws; and
Certification of the SWPPP.
EPA has developed a model Industrial SWPPP
Template, which can be found in Appendix A,
and on EPA's website at www.epa.gov/npdes/
stormwater/msgp. This template, developed
for permit holders subject to the 2008 MSGP,
is available in Microsoft Word and can be
customized to address SWPPP requirements
in different State NPDES permits.
Where your facility has other written pro-
cedures in place, such as a Spill Prevention,
Control and Countermeasure (SPCC) Plan or
an Environmental Management System (EMS)
developed for a National Environmental
Performance Track facility, your SWPPP can
reference the portions of those documents in
lieu of duplicating that information in your
SWPPP. In these instances, you should keep
copies of the relevant portions of those docu-
ments with your SWPPP.
SWPPP Tip!
EPA's 2008 MSGP includes the requirements
for a SWPPP in Part 5 of the permit.
Additional SWPPP Documentation
After you become authorized under the
permit, you will need to keep records on any
implementation activities required under your
permit, including records related to inspec-
tions, maintenance, monitoring results, and
corrective actions. This additional documen-
tation, although separate from the actual
SWPPP, should be kept with the SWPPP so
that all of your NPDES stormwater records are
filed in one central location (see Section 7).
To assist permittees in their recordkeeping,
EPA has developed an Additional MSGP
Documentation template, which is available at
www.epa.gov/npdes/stormwater/msgp. This
template, developed for permit holders subject
to the 2008 MSGP, is available in Microsoft
Word and can be modified as necessary to
address State-specific permit requirements.
2.C Stormwater Pollution Prevention
Team (Step 1)
The first step in developing the SWPPP is to
identify the stormwater pollution prevention
team. The stormwater pollution prevention
team is responsible for assisting the facility
manager in developing the facility's SWPPP
as well as implementing and maintaining
stormwater control measures, taking correc-
tive action where necessary to address permit
violations or to improve the performance of
control measures, and modifying the SWPPP
to reflect changes made to the control mea-
sures. Since industrial facilities differ in size
and complexity, the number of team members
will also vary. The stormwater pollution pre-
vention team should consist of those people
on-site who are most familiar with the facility
and its operations and responsible for ensur-
ing that necessary controls are in place to
eliminate or minimize the impacts of storm-
water from the facility.
A key member of the stormwater pollution
prevention team (for some facilities, this
may be the only member) is the person with
primary responsibility for developing and
overseeing facility activities necessary to com-
ply with the permit. This should be someone
who will be on-site on a daily basis and who
is familiar with the facility and its operations.
This person will also likely have primary
responsibility for ensuring that inspections
and monitoring activities are conducted. If an
EPA or State inspector visits the facility, this
person will be the main point of contact for
the SWPPP.
What to Include in Your SWPPP
In your SWPPP, identify the staff members
(by name or title) that comprise the facility's
stormwater pollution prevention team as well as
their individual responsibilities. Make sure you
keep this information up-to-date as staff members
change.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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SWPPP Tip!
Consider adding a stormwater management
component to employee job descriptions and
annual reviews, as appropriate to specific
jobs. Often these requirements compliment
existing tasks such as maintaining a clean work
area; promptly cleaning up spills and leaks;
performing regularly scheduled equipment
maintenance; and properly storing all chemicals,
oils, and other liquid pollutants.
Each member of the stormwater pollution
prevention team should have ready access to
either an electronic or paper copy of appli-
cable portions of the industrial stormwater
general permit and the SWPPP.
2.D What Do I Need to Do to Complete My
SWPPP?
After identifying your pollution prevention
team, you are ready to complete the next three
steps in the development of your SWPPP:
Step 2: Assessing your site and activities
(Sections);
Step 3: Selecting control measures
(Section 4); and
Step 4: Developing procedures for inspec-
tions and monitoring (Section 5).
Section 6 describes final steps necessary to
complete your SWPPP and to obtain permit
coverage. Section 7 suggests how records
relating to permit compliance should be kept.
SWPPP Tip!
Qualified Personnel - Members of your
stormwater pollution prevention team and those
conducting inspections and monitoring activities
should be "qualified personnel." EPA defines
qualified personnel as "those who posses the
knowledge and skills to assess conditions and
activities that could impact stormwater quality
at your facility, and who can also evaluate the
effectiveness of control measures."
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 3: Site Assessment and
Planning (Step 2)
This section describes how to collect the information needed for your SWPPP. This
information includes:
An assessment of the activities performed at your facility - this assessment will help
identify potential pollutant sources.
An evaluation of existing sampling data - a review of sampling data will show
where past problems have occurred.
Preparing maps of your facility - site maps will identify the location of industrial
activities, pollutant sources, control measures, and the direction of stormwater flow.
3.A Conduct an Assessment of the Activities Performed at Your Facility
The first step in developing a SWPPP is to gain a thorough understanding of
the activities conducted and equipment located at your facility to be able to
identify potential pollutant discharge concerns. To complete this step, you will YOUT SWPPP
need to conduct a detailed walk-through of your facility to identify industrial
materials or material handling activities exposed to stormwater (see text box Develop a list of industrial
below), any stormwater controls already in place at your facility, the direc-
tion of stormwater flow through and from your facility, and the location of all
stormwater outfalls. If possible, you should conduct your walk-through dur-
ing a rain event so that you can observe the flow of stormwater on your site.
In addition to your walk-through, you should communicate with fellow site
employees who may be more familiar with daily operations than you so that you can
thoroughly identify any activities that may contribute stormwater pollutants, but that
may not be readily visible during a routine walk-through (e.g., to identify activities
that are not performed on a routine basis).
How Does EPA Define Industrial Materials and Material Handling
Activities?
Industrial materials or activities include, but are not limited to: material handling
equipment or activities; industrial machinery; raw materials; industrial production and
processes; and intermediate products, by-products, final products, and waste products.
Material handling activities include, but are not limited to: the storage, loading and
unloading, transportation, disposal, or conveyance of any raw material, intermediate
product, final product or waste product. See 40 CFR 122.26(g).
ite
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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The facility assessment will reveal locations
where industrial materials or material han-
dling activities may be contributing stormwa-
ter contaminants, and help you identify the
most important pollutant sources. The follow-
ing approach is suggested for completing your
facility assessment:
Identification of Activities Exposed to
Stormwater. As you conduct your facility
assessment, make a list of the industrial
activities exposed to stormwater (e.g., mate-
rial storage; equipment fueling, maintenance,
and cleaning; cutting steel beams). Note their
location so they can be identified on the site
map.
Inventory of Materials and Pollutants. Make
a list of the materials and pollutants (e.g.,
crankcase oil, zinc, sulfuric acid, and clean-
ing solvents) associated with each identified
activity, including pollutants associated with
these materials, based on how they are stored,
handled, disposed, etc. Note whether these
materials are exposed to stormwater, or have
the potential to be exposed to stormwater. How
materials are stored and handled has a bearing
on the potential for stormwater pollution.
What to Include in Your SWPPP
For each of the activities identified above, create
an inventory of the materials associated with
each activity (this may be easiest to do in a
table). Identify whether these materials are or
have the potential to be exposed to stormwater.
Also, identify any pollutants associated with these
materials based on how they are stored, handled,
disposed, etc.
Areas with Spill or Leak Potential. Document
where potential spills and leaks may occur,
and specify the outfall(s) that could be
affected by such spills and leaks. Document
all significant spills and leaks that actually
occurred at exposed areas, or that drained to
a stormwater conveyance, in the three years
prior to the date you prepare or amend your
SWPPP. You should consider spillage and
leakage of all types of materials when prepar-
ing for and documenting such releases.
What to Include in Your SWPPP
Identify locations of potential spills and leaks
that could contribute pollutants to stormwater
discharges, and the corresponding outfalls that
would be affected. Review past records of all
significant 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 of such records in
your SWPPP.
Presence of Non-Stormwater Discharges. A non-
stormwater discharge is any discharge from
your facility this is not composed entirely of
rainfall or snowmelt runoff. Non-stormwater
discharges often come from potable water
sources or process wastewater discharges.
With few exceptions, the discharge of non-
stormwater as runoff from your facility is pro-
hibited unless it is specifically allowed under
an NPDES permit.
You must evaluate for the presence of non-
stormwater discharges and be able to demon-
strate that all unauthorized non-stormwater
discharges have been eliminated prior to
obtaining coverage under a stormwater permit
(or that any other discharges are otherwise
covered under a different NPDES permit).
Conduct your evaluation during a period of
dry weather (no rain for at least the previous
three days). Walk your site and evaluate each
outfall to identify any locations with flowing
or stagnant water or discharging liquid; the
presence of such water or liquid that would be
indicative of a non-stormwater discharge. You
should try to identify the source of the water
or liquid, and determine if it is one of the
allowable non-stormwater discharges identi-
fied below or otherwise in need of further
action to eliminate the source. You should
also identify any indicators of past or inter-
mittent non-stormwater discharges (such as
evidence of stains at the outfall).
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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SWPPP Tip!
Allowable Non-Stormwater Discharges
Most industrial stormwater general permits include a list of non-stormwater discharges that are
"allowable" and do not need to be eliminated. As used in EPA's 2008 MSGP, "allowable non-stormwater
discharges" are those that while not stormwater discharges, are covered under the terms and conditions
of the stormwater permit. These are often discharges that if not covered under a stormwater permit would
require coverage under some other NPDES permit. The list of allowable non-stormwater discharges from
the 2008 MSGP (Part 1.1.3) includes:
Discharges from fire-fighting activities;
Fire hydrant flushings;
Potable water, including water line flushings;
Uncontaminated condensate from air conditioners, coolers, and other compressors and from the
outside storage of refrigerated gases or liquids;
Irrigation drainage;
Landscape watering provided all pesticides, herbicides, and fertilizer have been applied in accordance
with the approved labeling;
Pavement wash waters where no detergents are used and no spills or leaks of toxic or hazardous
materials have occurred (unless all spilled material has been removed);
Routine external building washdown that does not use detergents;
Uncontaminated ground water or spring water;
Foundation or footing drains where flows are not contaminated with process materials; and
Incidental windblown mist from cooling towers that collects on rooftops or adjacent portions of your
facility, but not intentional discharges from the cooling tower (e.g., "piped" cooling tower blowdown or
drains).
If any non-stormwater discharges are identi-
fied during the evaluation, you should take
steps to eliminate any that are prohibited
under your permit. For example, plug a floor
drain, re-route a sink drain to the sanitary
sewer, or submit an NPDES permit application
for an unauthorized cooling water discharge.
What to Include in Your SWPPP
Documentation of your evaluation for non-
stormwater discharges. Typically, this
documentation should include:
The date of any evaluation;
A description of the evaluation criteria used;
A list of the outfalls or onsite drainage points
that were directly observed during the
evaluation;
The different types of non-stormwater
discharge(s) and source locations; and
The action(s) taken, such as a list of control
measures used to eliminate unauthorized
discharge(s), if any were identified.
Location of Salt Storage. Document the loca-
tion of any storage piles containing salt used
for deicing or that are used for other commer-
cial or industrial purposes. Salt and deicing
materials should be stored inside and not
exposed to stormwater runoff, if possible.
What to Include in Your SWPPP
If your facility has storage piles containing salt,
document the type of material, amount, and its
location.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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3.B Evaluate Sampling Data
You should evaluate any stormwater sampling
data you, or others, collected, from the pre-
vious permit term or any time in the past 5
years, which are associated with stormwater
discharges from the facility. This includes any
analytic sampling data, such as benchmark
monitoring or effluent limitation guideline
data. The purpose of evaluating your past sam-
pling data is to identify or pinpoint any pollut-
ants of concern, hotspots, or control measures
that are not functioning correctly. This infor-
mation will be useful as you identify and select
control measures (described in Section 4).
What to Include in Your SWPPP
A summary of all stormwater discharge sampling
data collected at your facility during the previous
permit term. You should summarize the data
by pollutant, and indicate whether the pollutant
parameter exceeded any applicable benchmark or
effluent limit.
Include in your SWPPP your evaluation of the
data, particularly where pollutants exceeded the
2008 MSGP benchmark values (see SWPPP Tip
below). Attempt to identify why that pollutant
existed in elevated concentrations, what are the
potential sources of that pollutant at your facility,
and what potential measures you could use to
reduce that pollutant.
M
SWPPP Tip! ^^^^^^^HH
Compare your sampling results to EPA's 2008
MSGP Benchmark values below.
f Pollutant 2008 MSGP
Benchmark
Ammonia*
Biochemical Oxygen
Demand (5 day)
Chemical Oxygen Demand
Total Suspended Solids
Turbidity
Nitrate + Nitrite Nitrogen
Total Phosphorus
Aluminum (T) (pH 6.5 - 9)
Antimony (T)
Arsenic (T)
Beryllium (T)
Cadmium (T)t
Copper (T)*t
Cyanide
Iron (T)
Lead (T)*t
Magnesium (T)
Mercury (T)
Nickel (T)t
Selenium (T)*
Silver (T)*t
Zinc (T)t
2.14 mg/L
30 mg/L
120 mg/L
100 mg/L
50NTU
0.68 mg/L
2.0 mg/L
6.0-9.0S.U.
0.75 mg/L
0.64 mg/L
0.15 mg/L
0.13 mg/L
0.0021 mg/L
0.014 mg/L
0.022 mg/L
1.0 mg/L
0.082 mg/L
0.064 mg/L
0.0014 mg/L
0.47 mg/L
0.005 mg/L
0.0038 mg/L
0.12 mg/L
(T) Total recoverable
* New criteria are currently under development, but
values are based on existing criteria.
t These pollutants are dependent on water
hardness. The benchmark value listed is based
on a hardness of 100 mg/L. The 2008 MSGP
requires industrial facility to analyze receiving
water samples for hardness, and use the hardness
tables provided in the 2008 MSGP to determine
the applicable benchmark value for that facility.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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3.C Develop General Location and Site
Maps
The final step in the site assessment process
is to document the results of your site assess-
ment on a detailed site map. If you have
already developed a site map for an earlier
permit, you should modify the map as neces-
sary to reflect changes at your facility, includ-
ing changes to any of your control measures
or industrial activities.
Your SWPPP must include both a general loca-
tion map and a detailed site map. The follow-
ing is a discussion of what is required for each
type.
Figure 2. Example general location map.
General Location Map
A general location map is helpful to identify
nearby, but not necessarily adjacent, water-
bodies around your facility. Include in your
SWPPP a general location map (e.g., U.S.
Geological Survey (USGS) quadrangle map,
or other large scale area map) with enough
detail to identify the location of your facil-
ity and all nearby receiving waters that may
receive your stormwater discharges. Create a
USGS map for your area by using the USGS
National Map Viewer (http://nmviewogc.
cr.usgs.gov/viewer.htm). Maps can be printed
or saved as PDF documents and inserted into
your SWPPP.
Figure 3. Example general location map.
One free web-based mapping service is
EPA's Water Locator Tool, which is avail-
able at www.epa.gov/npdes/stormwater/
msgp. To use the tool, enter your facility
address in Step 1, then click on "Window to
My Environment" in Step 2 (make sure your
pop-up blocker is turned off). You will be
able to zoom and reposition the map. When
you get the map to the appropriate scale and
location, you can copy and paste it into your
SWPPP. Use a graphics program or a pen to
mark the location of your facility on the map.
An example general location map is included
in Figure 3.
What to Include in Your SWPPP
Develop a general location map of your facility
that shows:
the location of your facility
receiving waters to which your facility
discharges
It may also be helpful to include roads or political
boundaries to better locate your facility.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
11
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Site Map
Develop a map of your site that includes,
among other things, the footprint of all build-
ings, structures, paved areas, and parking
lots. The site map is intended to show the
direction of stormwater flow throughout your
facility and the potential pollutant sources
that may come into contact with your storm-
water runoff.
EPA recommends that you develop a first draft
of the site map based on the information col-
lected during your assessment. After you select
appropriate control measures (Section 4) and
monitoring locations (Section 5), you should
revise your site map to reflect this information
and any additional changes identified as you
develop your SWPPP. If you are unable to fit
all the information on one map, use multiple
maps to provide a full characterization of the
information described above. Also, if activities
and conditions change at your site during the
term of the NPDES permit, you should update
the map as described in Section 6.C of this
guide. An example of a site map is included
(see Figure 4) and in Appendix C.
Map Notes:
- All interior floor drains, including the vehicle washarea and fuel island, discharge to the municipal
sanitary sewer system.
- All SDs are part of the MS4. Contact the City of Anywhere Public Works Department, Stormwater
Management Division at (111) 999-0001 concerning significant inspection findings associated with
these storm drains.
IN
Not to Scale
Acme Scrap Metal Recycling Yard Site Map
110 Willowbrook Road, Anywhere, USA 00011
SWPPP Contact: John Doe (111) 999-0000
Symbols:
- Speed Bump
Concrete Curbing Approximate Facility Operation
^^ Area Boundry
Storm Sewer
- > Sanitary Sewer
* Flow Path
Acronym List
SD Storm Drain
Dl Drop Inlet
SWC Solid Waste Can (General Location)
WOT Waste Oil Tank
ETS Empty Tank Storage
AST Above Ground Storage Tank
MS4 Municipal Separate Storm Sewer System
Authorized Non-Stormwater Discharges:
HPR Hot Water Heater Pressure Relief Pipe (potable
water)
AC Air Conditioning Condcnsate
FS Fire Suppression System Test Discharge (potable
water)
Spills:
Minor fuel spill on fuel island - July 20,2007
Potential Pollutant
Source:
Vehicle and
Equipment
Maintenance Garage
WOT: Waste Oil Tank
Aboveground 500-gallon waste oil
tank
ETS: Empty Tank
Storage
SWC: Solid Waste
Can
AST: Above Ground
Storage Tank
Covered Aluminum
Recycling Bay
Covered Plastic
Recycling Bay
Ferrous metal storage
Pile
Non-Ferrous metal
storage bins
Truck Parking
Potential Pollutants:
Fuel, oil, antifreeze, grease, hydraulic
Fluid, brake Fluid, solvents,
transmission fluid, parts washer, and
paint
Residual oil, lubricants, hydraulic
fluid
Two 1000 gallon ASTs, Diesel and
Gasoline
Hydraulic fluid, grease, aluminum,
plastic
Hyoraulic fluid, oil, grease, fuel
Non-Ferric metals
Oi I, grease, fuel
Impervious Surface Estimate
(% of total facility area): 90%
Total Facility Size (acres): 6.5
Figure 4. Example site map.
12
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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What to Include in Your SWPPP
Include a site map of your facility which includes the items below:
The size of the property in acres;
The location and extent of significant structures and impervious surfaces;
Directions of stormwater flow (use arrows);
Locations of all existing structural control measures;
Locations of all receiving waters in the immediate vicinity of your facility, indicating if any of the waters are
impaired and, if so, whether the waters have TMDLs established for them;
Locations of all stormwater conveyances including ditches, pipes, and swales;
Locations of potential pollutant sources identified (see Section 3.B);
Locations where significant spills or leaks have occurred;
Locations of all stormwater monitoring points;
Locations of stormwater inlets and outfalls, with a unique identification code for each outfall (e.g., Outfall
No. 1, No. 2, etc), indicating if you are treating one or more outfalls as "substantially identical", and an
approximate outline of the areas draining to each outfall;
Municipal separate storm sewer systems, where your stormwater discharges to them;
Locations and descriptions of all non-stormwater discharges;
Locations of the following activities where such activities are exposed to precipitation:
- Fueling stations;
- Vehicle and equipment maintenance and/or cleaning areas;
- Loading/unloading areas;
- Locations used for the treatment, storage, or disposal of wastes;
- Liquid storage tanks;
- Processing and storage areas;
- Immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured
products, waste material, or by-products used or created by the facility;
Transfer areas for substances in bulk; and
- Machinery; and
Locations and sources of run-on to your site from adjacent property that contains significant quantities of
pollutants.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 13
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Section 4: Selecting Control
Measures (Step 3)
SWPPP Tip!
Control measures are the best management practices (BMPs) or other structural or
non-structural practices that are used to prevent or reduce the discharge of pollutants
in stormwater. Structural control measures, as the name implies, focus on installation
of hard structures to control discharges. Structural controls include practices such
as vegetative swales, collection and reuse of stormwater,
inlet controls, snow management, infiltration devices, and
wet retention measures. Non-structural control measures
are intended to prevent or reduce the generation of pol-
lutants in stormwater and/or the volume of stormwater
runoff using practices that focus on facility operations and
procedures. Examples of non-structural control measures
include procedural practices such as employee trainings
and the posting of signs that raise staff awareness to
the BMPs and procedures in place to control stormwater
pollutants.
A combination of preventive and active treatment control measures usually results
in the most effective stormwater management for minimizing the offsite discharge of
pollutants in stormwater runoff. Most control measures require regular maintenance
to function as intended. Some control measures have simple main-
tenance requirements, while others may require more extensive
upkeep in order to maximize their performance. Note that identify-
ing weaknesses in current facility practices will help permittees
determine appropriate control measures for use at the site.
Effluent 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 permit's effluent limits.
General Stormwater Management Principles
In most industrial stormwater permits, including the 2008 MSGP,
the site operator is given the flexibility to select the type of control
measures, including specific technologies, which he/she believes are
best suited to the facility and that will meet the permit's require-
ments. This flexibility is necessary given the variability of each
industrial operation, the differences in the topography from site to
site, and the dissimilarities in the activities and materials exposed to
stormwater. However, there are certain general principles of storm-
water management that are common to all sites, and that can be
used by operators in their selection and design of control measures.
These general principles, listed below, should be considered as a way
to maximize the performance of control measures at your site.
Pollution prevention - The best way to prevent stormwater pollution is to mini-
mize the use of water contaminants in your industrial activities. When selecting
control measures for the facility, you should focus on controls that are geared
toward reducing pollutants at the source to prevent stormwater pollution. Source
control practices include maintaining equipment, picking up trash and debris,
training site staff on appropriate spill procedures, and proper materials manage-
ment and storage.
What does "minimize"
mean?
The technology-based limits
included in EPA's 2008 MSGP
require that you minimize (i.e.,
defined as reduce and/or eliminate)
stormwater exposure to pollutants
using control measures that are
technologically available, economi-
cally practicable, and achievable in
light of best industry practice.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Minimizing exposure - Another effective
way to minimize stormwater pollution is to
eliminate opportunities for stormwater to
come into contact with industrial activi-
ties and polluting materials. You should
look for opportunities to relocate industrial
activities/materials to covered or contained
areas and to properly store and transport
any accumulated scrap or waste material.
Combining controls - Combined control
measures are often more effective than
control measures in isolation. For example,
good housekeeping will often go a long way
to minimize stormwater pollution but is
more effective when combined with mini-
mizing the exposure of significant materi-
als or activities and a structural control,
such as inlet protection.
Examining your site's pollutant sources -
Understand the type and quantity of pol-
lutants that could contaminate stormwater
leaving your facility. Use your knowledge
of the potential pollutants to drive your
selection and design of effective control
measures.
Maximizing infiltration - Onsite infiltra-
tion reduces overland runoff, improves
groundwater recharge, and augments base
flow in local streams. You should look for
opportunities to minimize impervious area
and increase areas where stormwater can
infiltrate on-site. Keep in mind, however,
that the use of onsite infiltration typically
must be combined with other control mea-
sures to avoid ground water contamination.
Using existing vegetated areas - Open
vegetated swales and natural depressions
can be used to dissipate energy in overland
flow and reduce erosion. Vegetated swales
and natural depressions can increase infil-
tration and, in some cases, promote uptake
of metals and nutrients by plants.
Buffering on-site or adjacent waterbodies
or drainage systems - Maintain or restore
vegetated buffer zones between your facili-
ty's impervious areas and adjacent surface
waters.
Using structural practices (as applicable) -
When non-structural control measures
are not effective in preventing stormwater
contamination, structural control measures
(e.g., swirl separators, sand filters, retention
basins, etc.) may be needed to treat storm-
water before it leaves your facility.
EPA's Technology-Based Discharge
Requirements
The following sections describe the 12 catego-
ries of discharge requirements (or "effluent
limits") required by the 2008 MSGP. Although
the wording of these requirements may be
unique to the EPA permit, many State permits
include requirements that are similar to the
2008 MSGP.
4.A Minimize Exposure
The first step in an effective stormwater con-
trol program is minimizing exposure of man-
ufacturing, processing, material storage areas,
loading and unloading areas, dumpsters and
other disposal areas, maintenance activities,
and fueling operations to rain, snow, snow-
melt, and runoff by both locating industrial
materials and activities inside or protecting
them with storm resistant coverings.
SWPPP Tip!
No Exposure Exemption
EPA's regulations recognize the effectiveness of
minimizing exposure by allowing facilities to opt
out of the permit by submitting a "No Exposure
Certification" when all industrial activities are
protected from contact with stormwater. The "No
Exposure Certification" is included as Appendix K
of the 2008 MSGP. Note that industrial materials
do not need to be enclosed or covered if
stormwater runoff from affected areas will not be
discharged to receiving waters or if discharges
are authorized under another NPDES permit.
Check your State permit for specific requirements
for incorporating minimizing exposure into your
SWPPP.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
-------
Figure 5. Minimize exposure by providing cover for potential contaminants.
What to Include in Your SWPPP
Describe all structural controls or practices used to minimize the exposure of industrial activities to rain, snow,
snowmelt, and runoff. The SWPPP must describe where the controls or practices are being implemented at
your site. The location must also be identified on the SWPPP site map. Examples of exposure-minimizing
control measures that could be used at your facility and described in the SWPPP include:
The location and extent of grading, berms, or curbs used to contain contaminated stormwater or divert
stormwater around areas of industrial activity;
A description of the types of materials and equipment that are stored within secondary containment and
the location of contained storage areas;
The location of spill cleanup kits and a description and schedule for employee spill abatement and cleanup
training;
Proper procedures for leaky vehicles and equipment, such as drip pans; parking in a contained area, or
parking indoors;
The use and location of spill/overflow protection equipment;
Procedures for long-term storage or disposal of equipment and vehicles, such as draining all fluids;
The location of covered and/or contained equipment cleaning areas; and
The disposal method for all wash water, such as an on-site sump (if a sump is used, specify the pumping
frequency) or sanitary sewer.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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4.B Good Housekeeping
Good housekeeping practices offer a practical
and cost-effective way to maintain a clean and
orderly facility to prevent potential pollution
sources from coming into contact with storm-
water. Good housekeeping practices also help
to enhance safety and improve the overall
work environment. To effectively document
in your SWPPP that you are including good
housekeeping procedures at your site, you
should establish protocols to reduce the pos-
sibility of mishandling materials or equipment
and train employees in good housekeeping
techniques. An effective good housekeeping
program not only benefits stormwater quality
but makes the facility a clean, safe place for
employees and clients.
SWPPP Tip!
Labeling Storm Drains - A good stormwater
awareness practice is to label all storm drains
on your industrial facility with a "No Dumping-
Drains to Stream" or similar message. If select
drains at your facility discharge to the sanitary
sewer system or to a sump (for example, at
a wash rack), you should label those with a
"Drains to Sanitary Sewer" or similar message.
Common areas where good housekeeping
practices should be followed include areas
where trash containers are kept and adjacent
areas, material storage areas, vehicle and
equipment maintenance areas, and loading
docks. Involving employees in routine moni-
toring of housekeeping practices has proven to
be an effective means of ensuring the contin-
ued implementation of this control measure.
Figure 6. Two photos showing an industrial facility before and after it
followed good housekeeping practices.
What to Include in Your SWPPP
Describe any practices you are implementing to
keep exposed areas of your site clean. Describe
where each practice is being implemented at your
site. Include here your schedule or approach for:
Regular pickup and disposal of waste materials
and scrap equipment;
Maintenance of clean work spaces;
Routine inspections for leaks and of the
condition of drums, tanks, and containers;
Routine inspections to make sure that industrial
materials are properly stored and labeled;
A schedule for sweeping paved areas and
floors, including who will perform the
sweeping (employee or contractor);
The individual or position responsible for
emptying drip pans placed beneath leaking
equipment, valves, and fill lines.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
17
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4.C Maintenance
A good maintenance program requires regu-
lar inspections, testing, and the preventive
maintenance and repair of industrial equip-
ment (stationary and mobile) and industrial
systems. Maintenance programs are intended
to ensure that structural control measures
and industrial equipment are kept in good
operating condition and to prevent or mini-
mize leaks and other releases of pollutants
(see Section 4.D for more specific informa-
tion). If you notice a deficiency or otherwise
find that your control measures or industrial
equipment need to be replaced or repaired to
ensure proper functioning, and to avoid leaks
or other releases, you must make the neces-
sary repairs or modifications, typically prior
to the next wet weather event and as expedi-
tiously as practicable.
Facilities with good maintenance programs
will keep a maintenance log that tracks the
regular maintenance of industrial equipment
and stormwater control measures. The log
provides a maintenance history for each piece
of equipment and demonstrates to regulatory
authorities that you have implemented the
maintenance program outlined in your SWPPP.
Figure 7. Equipment should receive routine
preventative maintenance to prevent drips and
leaks.
What to Include in Your SWPPP
Describe procedures to:
Maintain industrial equipment so that leaks
and other releases are avoided, and
Maintain any of your site's control measures in
effective operating condition.
Include the schedule you will follow for such
maintenance activities. Describe where each
applicable procedure is being implemented at the
site.
4.D Spill Prevention and Response
Procedures
Spills and leaks, together, are the largest
source of industrial stormwater pollution.
For this reason, your SWPPP must identify
control measures that are used at your site to
minimize the potential for spills, leaks, and
other releases that may come into contact
with stormwater. Among the practices that
should be in place at your site are plans for
effective response to spills if or when they
occur. If your facility has more than 1,320
gallons of oil storage capacity in aboveground
tanks you may also be required to develop a
Spill Prevention, Control and Countermeasure
(SPCC) plan consistent with 40 CFR 112.1.
Figure 8. Spill kits should be maintained in
areas with spill potential, such as fueling
stations.
SWPPP Tip!
Employees must be aware of notification
procedures in the event of a spill or leak,
including when to contact appropriate facility
personnel, emergency response agencies, and
regulatory agencies. State or local requirements
may necessitate reporting of spills or other
prohibited discharges to local emergency
response, public health, or drinking water supply
agencies. Contact information must be posted
in locations that are readily accessible and
available to employees. Where a leak, spill, or
other release containing a hazardous substance
or oil in an amount equal to or in excess of a
reportable quantity established under either
40 CFR Part 110, 40 CFR Part 117, or 40 CFR
Part 302, occurs during a 24-hour period, you
must notify the National Response Center (NRC)
at (800) 424-8802 or, in the Washington,
DC, metropolitan area, call (202) 267-2675 in
accordance with the requirements of 40 CFR
Part 110, 40 CFR Part 117, and 40 CFR Part
302 as soon as you have knowledge of the
discharge.
18
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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What to Include in Your SWPPP
Describe any structural controls or procedures you are putting in place to minimize the potential for leaks, spills, and other
releases. At a minimum, your SWPPP should include:
The location(s) of spill response plans for significant materials;
A schedule for training employees in spill response procedures;
Procedures for plainly labeling containers (e.g., "Used Oil," "Spent Solvents," "Fertilizers and Pesticides," etc.) that could be
susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills or leaks occur;
Preventative measures such as barriers between material storage and traffic areas, secondary containment provisions, and
procedures for material storage and handling;
The individual or position responsible for making sure the spill kits are complete and ready for use;
Procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases; and
Procedures for notification of appropriate facility personnel, emergency response agencies, and regulatory agencies.
Describe where each control is to be located or where applicable procedures will be implemented.
4.E Erosion and Sediment Controls
Permits typically require control measures to
be selected and implemented to limit erosion
on areas of the site that, due to topography,
land disturbing activities, soils, cover, materi-
als, or other factors, are likely to experience
erosion. In general, erosion control measures,
which prevent soil or sediment from becoming
mobilized, should be used as the primary line
of defense, while sediment control measures,
which trap, infiltrate, or settle out mobilized
sediments, should be used to back-up the ero-
sion control measures. For instance, erosion
control measures, include grading, seeding,
mulching, and sodding, that prevent soil from
becoming dislodged, should be considered
first. Where sediment may be dislodged and
potentially mobilized in stormwater runoff,
sediment control measures that trap eroded
sediment include silt fences, sediment ponds,
and stabilized entrances should be considered.
When selecting, designing, installing, and
implementing appropriate erosion and sedi-
ment control measures, you should consult
with your Tribal, State, and local authorities to
SWPPP Tip!
Projects that disturb 1 acre or more of land
generally require coverage under an NPDES
construction general permit (CGP). Information
on EPA's 2008 CGP requirements, including
links to construction SWPPP resources, is
available at www.epa.gov/npdes/stormwater/cgp.
Figure 9. Slope drains to protect a hillside from
erosion.
ensure that you consider the appropriate con-
trol measures. EPA's internet-based resources
relating to controlling erosion and sedimen-
tation include the sector-specific Industrial
Storrmvater Fact Sheet Series, (www.epa.gov/
npdes/stormwater/msgp), National Menu
of Stormwater BMPs (www.epa.gov/npdes/
stormwater/menuofbmps), and National
Management Measures to Control Nonpoint
Source Pollution from Urban Areas
(www.epa.gov/owow/nps/urbanmm/
index.html).
What to Include in Your SWPPP
Include the following:
A narrative description of areas of your site that
are susceptible to erosion (note: the site map
will also identify these areas);
A description of erosion and sediment control
measures used at your site to stabilize exposed
areas and contain runoff to minimize onsite
erosion and potential offsite discharges of
sediment.
Note-. Permits often require flow velocity
dissipation devices at discharge locations and
within outfall channels where necessary to reduce
erosion and/or settle out pollutants. Describe
in your SWPPP the location of each control
implemented at your site.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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4.F Management of Runoff
Similar to erosion and sediment controls, the
management of stormwater runoff that flows
through your site is an effective way to reduce
the pollutants that are discharged from your
site. Where you employ structures or practices
that are intended to divert, infiltrate, reuse,
or otherwise reduce stormwater runoff so as
to reduce the discharge of pollutants, your
SWPPP must include a description of those
controls. Appropriate measures are highly
site-specific, but may include vegetative
swales, berms, collection and reuse of storm-
water, inlet controls, snow management, infil-
tration devices, and wet retention measures.
Figure 10. Vegetated berm used to prevent facility
inundation when the river is at flood stage.
As mentioned previously, a combination of pre-
ventive and treatment control measures usually
results in the most effective approach to storm-
water management for minimizing the offsite
discharge of pollutants in stormwater runoff.
SWPPP Tip!
When selecting control measures, be careful not
to violate local building or fire codes and other
ordinances. An example would be constructing
a shed for storage of chemicals and then finding
out from the fire department that you are in
violation for locating the shed too close to the
main building, not equipping the shed with
sprinklers or other fire control device, and not
properly labeling containers.
What to Include in Your SWPPP
Include the following:
A description of controls used at your site to
divert, infiltrate, reuse, contain, or otherwise
reduce stormwater runoff.
A description of locations at your site where
each control will be implemented.
4.G Salt Storage Piles or Piles Containing
Salt
Salt is commonly used for deicing and other
commercial or industrial purposes, including
maintenance of paved surfaces. Salt piles or
piles that are predominantly composed of other
materials that contain some salt typically must
be covered or enclosed and otherwise isolated
from coming into contact with stormwater
(e.g., good housekeeping, diversions, contain-
ment). Piles do not need to be enclosed or
covered if stormwater runoff from the piles is
not discharged or if discharges from the piles
are authorized under another NPDES permit.
To effectively document in your SWPPP that
you are minimizing exposure of these piles
to stormwater, you should consider creating a
checklist to verify that salt loading and offload-
ing operations occur within contained areas
with appropriate measures in place to prevent
the track out of salt from the contained areas.
Figure 11. Salt pile covered with a tarp.
20
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
-------
What to Include in Your SWPPP
Include the following:
The identification of salt storage piles or piles containing salt, and a description of structures at your site
covering or enclosing such piles, or that prevent the discharge of stormwater from such piles.
If tarps are used to cover piles, the SWPPP should describe procedures for when tarps will be placed over
the piles.
A description of any controls or procedures used to minimize exposure resulting from adding to or removing
materials from the pile.
The locations at your site where each control and/or procedure are implemented. Note that these locations
must be identified on the SWPPP site map as well.
4.H Sector-Specific Requirements
Most industrial stormwater general permits
regulate discharges of stormwater from a
number of different industrial sectors. For
instance, EPA's 2008 MSGP regulates dis-
charges from 29 different industrial sectors.
These "sectors" consist of similar facilities
categorized by the nature of their industrial
activity, type of materials handled, and mate-
rial management practices employed. The
sectors are structured to a large extent on the
definition of "stormwater discharge associ-
ated with industrial activity" found at 40 CFR
122.26 (b)(14)(i)-(ix), (xi), under which many
sectors are identified based on their standard
industrial classification (SIC) code.
Review your industrial stormwater general
permit to determine if there are additional
sector-specific discharge requirements (or
"effluent limits") for which your type of
industrial activity are subject. If so, you will
need to specifically document how you will
comply with those requirements in your
SWPPP. Not all sectors will necessarily have
additional sector-specific discharge require-
ments. For example, Sector N of EPA's 2008
MSGP includes specific requirements for
scrap recycling and waste recycling facili-
ties as defined by SIC Major Group Code 50
(5093). One of the specific Sector N discharge
requirements is to "minimize surface runoff
from coming in contact with scrap processing
equipment." Alternatively, the Chemical and
Allied Products Manufacturing, and Refining
sector (Sector C) does not have any sector-
specific discharge requirements in the 2008
MSGP.
Note that, if covered by the 2008 MSGP, you
are responsible for complying with sector-
specific requirements associated with your
primary industrial activity and all co-located
industrial activities. Co-located industrial
activities are industrial activities, exclud-
ing your primary industrial activity, located
on-site that are also required to be covered
by the 2008 MSGP or a State general permit.
Statewide general permits may have different
requirements for specific industrial sectors.
SWPPP Tip!
Sector-specific requirements for the 2008
MSGP - All sector-specific requirements can be
found in Part 8 of the 2008 MSGP.
Sector-specific fact sheets - EPA has developed
fact sheets specific to the industrial activities,
pollutants and control measures used at each
of the 29 sectors covered by the 2008 MSGP.
These sector fact sheets can be found at
http://cfpub.epa.gov/npdes/stormwater/
swsectors.cfm.
What to Include in Your SWPPP
Include the following:
The industrial sector, or sectors, applicable to
the permitted site.
A discussion of the control measures
implemented to address sector-specific
requirements, if applicable, consistent with
Part 8 of the 2008 MSGP.
The location of each control and/or procedure
used to comply with the sector-specific
requirements.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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4.1 Employee Training
Stormwater training is required for all
employees who work in areas where indus-
trial activities or material handling activities
are exposed to stormwater, or who are respon-
sible for implementing activities necessary
to meet the conditions of this permit. These
employees include inspectors, maintenance
personnel, and all members of your Pollution
Prevention Team. The training session or
sessions are expected to cover the contents of
the facility SWPPP, control measures imple-
mented to achieve compliance with applicable
discharge requirements, spill containment
and cleanup procedures, maintenance, moni-
toring, inspection, planning, reporting, and
documentation requirements.
EPA recommends that training be conducted
for any applicable employees at least annu-
ally and whenever a new employee starts who
meets the description above. You should have
a sign-in/sign-out sheet at each training class
to document that employees have partici-
pated. Keep the sign-in/sign-out sheet with
your SWPPP.
What to Include in Your SWPPP
Include the following:
Person(s) responsible for conducting the
training (a member of the Pollution Prevention
Team, contractor, or other?)
The employees or positions that will receive
stormwater training.
The frequency of stormwater training
sessions (annually, upon hire, or other).
EPA recommends at least once per year.
For example, the SWPPP might state that
stormwater training will be conducted annually
in September so employees are ready for the
upcoming wet weather season.
The stormwater topics covered during the
training session or sessions.
The sign-in/sign-out sheets from the training
session.
SWPPP Tip!
Customize the employee training to the issues
at your facility, and ensure that employees
are trained on the control measures they are
expected to implement. Among the topics you
cover in your training should be some of the
basic principles of stormwater management. For
example, you should convey that;
Stormwater pollution occurs when rainfall
runoff picks up pollutants from the ground or
areas exposed to rainfall.
Polluted stormwater can cause significant
water quality problems, such as fish
kills and drinking water contamination.
Stormwater runoff is typically discharged
directly to receiving waters, and is not
treated somewhere else, like at a wastewater
treatment plant.
Potential stormwater pollutants should
be kept inside or under cover whenever
possible.
The best way to prevent stormwater
problems is through general good
housekeeping practices. A clean and
organized facility will usually have very few
stormwater problems.
If anyone sees any potential stormwater
problems, they should report it to the facility
operator or a member of the stormwater
pollution prevention team.
Figure 12. In addition to employee training, labeling storm
drains is a good measure to educate employees.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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4.J Non-Stormwater Discharges
In Section 3.A, this guide discussed the
assessment of allowable and prohibited non-
stormwater discharges at your site. As stated
in that section, unauthorized non-stormwater
discharges cannot be discharged from your
facility unless specifically authorized by a
separate, individual NPDES permit. Your
SWPPP should describe the assessment
you conducted under Section 3.A, how you
eliminated any unauthorized non-stormwater
discharges, and your plans to prevent unau-
thorized non-stormwater discharges at your
facility.
Figure 13. Unauthorized non-stormwater discharge from
an industrial facility.
What to Include in Your SWPPP
Include the following:
A list of allowable non-stormwater discharges
that occur at your facility.
A description of unauthorized non-stormwater
discharges found at your site and how they
were eliminated.
Steps taken to ensure that other unauthorized
non-stormwater discharges do not occur in the
future.
Note: If this section is already addressed by your
documentation of non-stormwater discharges
(see Section 3.A), you can simply include a cross-
reference to that section of your SWPPP.
4.K Waste, Garbage, and Floatable
Debris
You are responsible for making sure that
stormwater runoff does not carry waste, gar-
bage, and floatable debris to receiving waters.
To verify compliance with this requirement,
you should identify and implement control
measures (e.g., good housekeeping, sweep-
ing, keeping lids closed on dumpsters) to
keep exposed areas free of such materials.
Alternatively, your SWPPP should identify
how you will intercept and properly dispose of
these materials before they leave your facility.
What to Include in Your SWPPP
Include the following:
A description of controls and procedures that
will be used to minimize discharges of waste,
garbage, and floatable debris.
Descriptions of the location of these control
measures and procedures at your site.
Figure 14. Poor management of waste and garbage at a
facility.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
23
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4.L Dust Generation and Vehicle Tracking
of Industrial Materials
As an operator, you are responsible for
minimizing generation of dust and off-site
tracking of raw, final or waste materials. Dust
control practices can reduce the activities and
air movement that cause dust to be gener-
ated from disturbed soil surfaces. Airborne
particles pose a dual threat to the environ-
ment and human health. Dust can be car-
ried offsite, thereby increasing soil loss from
disturbed areas and increasing the likelihood
of sedimentation and water pollution. Control
measures to minimize the generation of dust
include:
Sprinkling/Irrigation. Moistening the
ground surface with water is an effective
dust control method for haul roads and
other traffic routes.
Vegetative Cover. By establishing a vegeta-
tive cover on areas that will not see vehicle
traffic, exposed soil is stabilized and wind
velocity at ground level can be reduced,
thus reducing the potential for dust to
become airborne.
Mulch. Mulch is a quick and effective, but
not permanent, means of dust control for
newly disturbed areas.
Wind Breaks. Wind breaks can be trees or
shrubs left in place during site clearing or
constructed barriers such as a wind fence,
snow fence, tarp curtain, hay bale, crate
wall or sediment wall. The break reduces
wind velocity, minimizing airborne trans-
fer of soil off site.
Tillage. Deep tillage in large open areas
brings soil clods to the surface where they
rest on top of dust, preventing it from
becoming airborne.
Stone. Stone can be an effective dust deter-
rent for construction roads and entrances
or as a mulch in areas where vegetation
cannot be established.
Spray-on Chemical Soil Treatments
(Palliatives). Examples of chemical adhe-
sives include anionic asphalt emulsion,
latex emulsion, resin-water emulsions
and calcium chloride. Chemical pallia-
tives should be used only on mineral soils.
When considering chemical application
to suppress dust, determine whether the
chemical is biodegradable or water-soluble
and what effect its application could have
on the surrounding environment, including
waterbodies and wildlife.
To reduce vehicle tracking of materials and
sediment, the operator should keep stored or
spilled materials away from all roads within
the site. Specific measures such as setting up
a wash site or separate pad to clean vehicles
prior to their leaving the site may be effective
as well.
What to Include in Your SWPPP
Include the following:
A description of controls and procedures used
at your site to minimize the generation of dust.
Descriptions of procedures and controls used
to minimize off-site tracking of raw, final, or
waste materials.
Describe the location where each control and/
or procedure will be implemented and include
on the SWPPP site map.
4.M Numeric Effluent Limitations Based
on Effluent Limit Guidelines
Some industrial activities identified in indus-
trial stormwater permits also have Federal
numeric effluent limits (called effluent limita-
tion guidelines) that must be achieved in
stormwater discharges. The effluent limits are
maximum concentrations or levels of specific
pollutants that can be discharged in facility
stormwater. If your facility includes one of the
industrial categories listed below, refer to your
industrial stormwater general permit (Parts
6.2.2.1 and 2.1.3 of EPA's 2008 MSGP) regard-
ing numeric effluent limits and monitoring
requirements to which you are subject:
Discharges resulting from spray down or
intentional wetting of logs at wet deck
storage areas
Runoff from phosphate fertilizer manu-
facturing facilities that comes into contact
with any raw materials, finished product,
by-products or waste products
Runoff from asphalt emulsion facilities
Runoff from material storage piles at
cement manufacturing facilities
Mine dewatering discharges at crushed
stone, construction sand and gravel, or
industrial sand mining facilities
Runoff from hazardous waste landfills
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Runoff from non-hazardous waste landfills
Runoff from coal storage piles at steam
electric generating facilities
An example of a numeric effluent limit is the
requirement for facilities that discharge storm-
water from asphalt emulsion facilities to meet
specific, numeric concentration limits for TSS,
pH, and oil and grease (i.e., based on the lim-
its in 40 CFR Part 443, Subpart A).
If your facility is subject to numeric effluent
limits, you must document the location and
type of control measures installed at your site
to meet those limits.
What to Include in Your SWPPP
Include the following:
All numeric effluent limits the facility is
required to meet based on effluent limit
guidelines.
A description of the control measures used to
meet the numeric effluent limits.
The location of each control measure at your
site.
4.N Additional Controls to Address
Impaired Waters
Many general permits have additional require-
ments for discharges to impaired waters.
"Impaired waters" have been identified by
a Tribe, State, or EPA as not meeting appli-
cable State water quality standards pursuant
to Section 303 (d) of the Clean Water Act.
This may include both waters with approved
or established Total Maximum Daily Loads
(TMDLs), and those for which a TMDL has
not yet been approved or established.
SWPPP Tip!
Impaired waters are streams, rivers, and lakes
that do not currently meet designated uses
and water quality standards. States, territories,
and authorized tribes are required under the
Clean Water Act to compile lists of known
impaired waters, called 303(d) lists. Stormwater
discharges to impaired waters may trigger
additional control measures and monitoring
requirements. For facilities subject to EPA's
2008 MSGP, see Part 2.2 for a more detailed
discussion of water quality-based effluent
limitations and conditions for discharging to
impaired waters.
A TMDL determines the greatest amount of
a given pollutant, such as sediment, that a
water body can receive without violating
water quality standards and designated uses.
The TMDL then establishes pollution reduc-
tion goals to bring the water body into compli-
ance with water quality standards. Facilities
that are subject to NPDES permits (i.e., "point
sources"), such as facilities subject to EPA's
2008 MSGP, which discharge the pollutant
causing the water body impairment, receive
"waste load allocations" or "WLAs". The WLA
estimates the daily amount of the impairment
pollutant that can be discharged from par-
ticular sources or categories of sources so that
the waterbody can be restored to meeting its
applicable water quality standards.
Should your facility discharge Stormwater to
a water body subject to a TMDL, EPA or a
State permit authority may require additional
effluent limits, monitoring requirements, or
other restrictions consistent with an appli-
cable WLA, or you may be required to apply
for an individual NPDES permit. Where you
have been informed either in the permit or
directly by EPA or a State permit authority
that you are subject to any "water quality-
based" discharge requirement consistent with
an applicable WLA, you are required to docu-
ment in your SWPPP the control measures
used to meet that requirement and to describe
the location of such control measures.
SWPPP Tip!
Find impaired waters near your facility - Use
EPA's Water Locator Tool (available at
www.epa.gov/npdes/stormwater/msgp) or other
tool to map impaired waters within 10 miles
of your facility. Enter your facility address in
Step 1, then click on "Retrieve List of Impaired
Waterbodies" under step 3 to see the list.
What to Include in Your SWPPP
Include the following:
A description of the control measures used to
meet the water quality-based effluent limits.
The location of each control measure at your
site.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 5: Procedures for
Inspections and Monitoring (Step 4)
The next step in developing your SWPPP is to set out the procedures you will follow
for inspecting your site and monitoring your stormwater discharge. The procedures
you develop in your SWPPP for inspection and monitoring will help you understand
whether your control measures are working and, if not, provide you with ways you
may improve your stormwater control.
Industrial stormwater permits typically
require three types of inspections:
1. Routine facility inspections
(see Section 5.A)
2. Visual assessments (see Section 5.B)
3. Annual comprehensive site inspec-
tions (see Section 5.C)
Some States also require you to take
samples of your stormwater discharge for
laboratory analysis. Check the applicable
section of your industrial stormwater
permit to determine if you are required to
collect water quality monitoring samples.
See Section 5.D for guidance on how to
address your monitoring procedures in
the SWPPP.
The following sections describe the type
of information you should document in
your SWPPP and the associated decisions
you will have to make when planning for
and conducting each of the three types of
inspections.
5.A Routine Facility Inspections
Your industrial stormwater permit will likely specify a minimum frequency for con-
ducting routine facility inspections. The minimum frequency typically ranges from
once per month to once per quarter; however, EPA recommends that you develop
a routine inspection schedule customized for your facility and specific site condi-
tions, which in many instances will require that you inspect more frequently than
the minimum requirement. EPA also suggests conducting routine inspections when
measurable precipitation falls during normal business hours. Observing site condi-
tions during storms provides you with real-time feedback on control measures that
are working and those that are not working effectively.
EPA's 2008 MSGP requires three types of
facility inspections.
1. Routine facility inspections (2008 MSGP, Part 4.1)
2. Quarterly visual assessment of stormwater discharges
(2008 MSGP, Part 4.2)
3. Comprehensive site inspections (2008 MSGP, Part 4.3)
The 2008 MSGP also includes the requirements
for the following types of monitoring:
1. Benchmark monitoring (2008 MSGP, Part 6.2.1)
2. Effluent guidelines limitation monitoring
(2008 MSGP, Part 6.2.2)
3. State or Tribal monitoring (2008 MSGP, Part 6.2.3)
4. Impaired waters monitoring (2008 MSGP, Part 6.2.4)
Monitoring procedures are described in Part 6.1 of the 2008
MSGP.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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EPA's 2008 MSGP requires quarterly routine
facility inspections of all areas where industrial
materials or activities are exposed to stormwater,
and of all stormwater control measures used
to comply with the effluent limits contained
in the permit. Inspections must be conducted
by qualified personnel, including at least one
member of your pollution prevention team,
during regular business hours. You must specify
the relevant inspection schedules in your
SWPPP document as required in Part 5.1.5.
The 2008 MSGP requires that at least one of the
four quarterly inspections each year be conducted
when a stormwater discharge is occurring.
SWPPP Tip!
You should check your industrial stormwater
general permit to determine if it establishes
exceptions to the inspection requirements for
certain types of sites. For example, 2008 MSGP
Part 4.1.3 identifies exceptions to routine visual
inspections for inactive or unstaffed sites.
Recommended Routine Facility Inspection
Sequence
Although you are given the discretion to
determine how best to conduct your inspec-
tion, EPA recommends that your inspection
follow a sequence that corresponds to how
raw materials arrive at your site and are
stored or processed in areas exposed to storm-
water, and to how intermediate or finished
products are stored, processed, or transported
from your facility. Accordingly, the following
recommended inspection sequence will help
ensure that you conduct a thorough routine
inspection at your facility. Whichever process
you determine is appropriate for your facility,
you are required to describe that approach in
your SWPPP.
SWPPP Tip!
Invest in an inexpensive digital camera to
photo-document your inspections. Maintaining
a photo history of inspections and control
measures can help you to recognize if
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.
1. Plan your inspection: Develop a consis-
tent process to ensure that you inspect
all areas. One method to ensure that your
inspections are consistent and thorough is
to create a checklist (or make notes on a
copy of your SWPPP) of areas to inspect.
Use as a resource your updated site map
identifying the locations of industrial
activities exposed to stormwater, storm-
water conveyances and discharge points,
and any BMPs.
2. Evaluate the area where raw materials are
delivered. Are these areas contained or
is there potential for stormwater to carry
spills or pollutants away from the drop
area? If so, can these pollutants leave your
site to an adjoining facility, storm drain,
or surface water? If so, additional control
measures should be implemented.
3. Are raw materials stored in a contained
area with overhead cover, berms, or other
secondary containment? If not, do the raw
materials have the potential to contribute
to stormwater pollution?
Note: Single-wall chemical containers
need to be located within secondary
containment structures, behind berms,
or covered to prevent stormwater con-
tamination from an accidental release of
containerized chemicals. Similarly, solid
materials with the potential to contain
pollutants (i.e., scrap material or wrecked
vehicles) should include secondary
containment.
4. Is equipment maintenance and fueling
conducted in appropriately contained
areas? Are spill kits present and full
in areas where a liquid spill could be
expected?
5. Do the industrial processes occur in cov-
ered and contained areas?
6. Where do you store waste material?
Note: If the waste material has the poten-
tial to contaminate stormwater it must be
stored in a contained area or otherwise
controlled. Be sure to evaluate the facil-
ity "bone-yard" and scrap all equipment
that is out-of-date and not intended to be
reused.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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7. Is the finished product appropriately con-
tained for potential pollutant sources?
8. Following the internal evaluation, walk the
perimeter of your site and look for evidence
of stormwater dischargesparticularly
stains from oil and grease or chemicals.
Should you observe these, look at the dis-
charge area and consider additional control
measures. You should specifically observe
all stormwater outfalls where stormwater
leaves your facility.
9. Following each inspection, you will need
to make note of control measures that
require maintenance, or that need to be
replaced, and make sure that the SWPPP
and site map are current regarding indus-
trial activities and potential pollutants.
10. Finally, where appropriate, repair or
replace worn or ineffective control mea-
sures as soon as possible but certainly
before the next forecasted precipitation
event.
SWPPP Tip!
Figure 15. Example of a sheen indicating the presence of oil or other hydro
carbons.
As you conduct your routine facility inspections,
keep in mind these visual indicators of poor
control measures or missing control measures:
1. Rainbow colored sheen on the surface of
stormwater indicates the presence of oil or
other hydrocarbons;
2. Brown or other dark colored streaks in
flowing stormwater indicates soil erosion or
uncontained sediment;
3. Stormwater flowing through straw waddles or
other stormwater containment barriers;
4. Foam;
5. Trash and other debris being carried off-site
by stormwater; and
6. Overflowing storm drains or detention ponds
could be indicative of a clog or poor inlet
design.
Routine Facility Inspection Reports
Your routine facility inspections will need
to be recorded and documented. Generally,
a standard inspection report is taken into
the field and completed for each inspection.
You should include in your SWPPP a copy
of the standard inspection form you will
use. An example routine facility inspection
form can be found in the "Additional MSGP
Documentation Template" on EPA's website at
www.epa.gov/npdes/pubs/
msgp2008_recordkeepingtemplate.doc.
SWPPP Tip!
Remember to update your SWPPP if you add,
remove, or modify control measures following
a routine visual, or other, inspection. Should
you get inspected, EPA or the State agency will
expect that all control measures identified in
your SWPPP to be current and to be effectively
implemented at your facility.
28
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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What to Include in Your SWPPP
Your SWPPP should describe the routine facility inspection process in enough detail that a member of your staff could complete an
inspection by following the description in the SWPPP. The SWPPP description should include:
1. Person(s) or positions of person(s) responsible for conducting the routine facility inspections
At least one member of your stormwater pollution prevention team should be involved in the routine facility inspections. Consider
involving employees who regularly work in areas where stormwater may come into contact with industrial activity or materials.
2. Schedules for conducting the routine facility inspections
Identify the minimum inspection frequency (e.g., monthly, quarterly) in your SWPPP. Consider scheduling the inspections for a
set day every month or quarter, yet allow sufficient flexibility to be able to take advantage of a storm event, since many permits
require that at least one inspection be conducted during a rain event.
3. Routine facility inspection procedures
Describe how the routine facility inspection will be conducted, including which control measures or areas will be inspected
and what the inspector will be looking for. Examples of things the inspector should be looking for include the condition of
stormwater outfalls (trash accumulation, staining, evidence of unauthorized non-stormwater discharges, etc.); overall good
housekeeping; and the condition of installed control measures (do any need to be maintained or replaced?).
Among other procedures to describe, provide a description of the sequence you will follow during each inspection. One option is
to use the recommended inspection sequence above or customize it to better suit your facility's layout.
4. Reporting procedures
Describe your reporting procedures and include a blank copy of the inspection form that will be used during the routine
inspections. Most industrial stormwater general permits require that inspection reports include the following:
The inspection date and time.
The name(s), title(s), and signature(s) of the inspector(s).
Weather information for the day of the inspection and, if appropriate, days or weeks prior to the inspection.
A description of any discharges observed.
A description of the visual quality of discharges (sheen, turbid, etc.).
Control measures in need of maintenance or repairs.
Control measures that need to be replaced.
Any incidents of noncompliance observed.
Additional control measures needed to comply with the permit requirements.
Inspection reports also need to be signed by the inspector. Your inspection form should include a signature line for this.
5.B Visual Assessments
The second component of an effective storm-
water inspection program is periodic visual
assessments of the stormwater discharging
from your facility. Visual assessments are con-
ducted on samples taken during a storm event,
and require that you make observations of the
stormwater sample in order to qualitatively
assess the nature of your discharge based on
several visual parameters. This requires that
you collect a stormwater sample in a clean,
clear jar and look at the sample in a well lit
area. Generally, a sample must be collected
from each stormwater discharge location asso-
ciated with industrial activity. The purpose
of conducting visual assessments is to make
sure that stormwater discharges are free from
objectionable characteristics (i.e., pollutants
you can see). Should you observe objection-
able characteristics, you should backtrack
upstream from the sample collection location
to identify potential sources of the pollutants.
Some pollutants may be present in stormwater
but cannot be seen; for this reason EPA or your
State may require benchmark or effluent limit
monitoring depending on the facility SIC code
or industrial sector. See Section 5.D for more
information on monitoring.
Most industrial stormwater permits do not
require visual assessment samples to be col-
lected consistent with 40 CFR Part 136 pro-
cedures (the Clean Water Act guidelines for
SWPPP Tip!
Check your industrial stormwater permit to
determine if you are required to submit your
visual assessment samples to a laboratory for
analysis. The 2008 MSGP does not require
samples to be submitted to a laboratory.
However, if your permit does require you to
submit samples for laboratory analysis, the
samples must be collected and documented in
accordance with 40 CFR Part 136 guidelines.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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establishing test procedures for the analysis
of pollutants); however, visual assessment
samples should be collected in such a man-
ner that the samples are representative of the
stormwater discharge.
EPA's 2008 MSGP includes specific require-
ments for when and how to collect the visual
assessment sample. You should look in your
permit to determine what requirements apply
to your facility's visual assessments. However,
EPA believes its permit's requirements offer
a clear and consistent way to conduct these
assessments. They are summarized as
follows:
Collect stormwater samples within the first
30 minutes of an actual discharge from a
storm event. If it is not possible to collect
the sample within the first 30 minutes of
discharge, collect the sample as soon as
possible after the first 30 minutes. In this
case, be sure to document in your records
(kept with your SWPPP) why it was not
possible to take samples within the first
30 minutes. In the case of snowmelt,
samples must only be taken during a period
with a measurable discharge from your site.
Collect the sample in a clean, clear glass, or
plastic container.
Examine the sample in a well-lit area
or, if necessary, illuminate with a strong
flashlight.
Collect the samples from discharges that
happen at least 72 hours (3 days) from the
previous discharge event.
What to Include in Your SWPPP
Include in your SWPPP a description of your visual assessment process:
1. Person(s) or positions of person(s) responsible for visual assessments.
Note: The visual assessment should be conducted by a member of your stormwater pollution prevention team.
2. Schedules for conducting the visual assessments.
Note: Identify the minimum inspection frequency (typically quarterly) in your SWPPP. You should also describe procedures
for determining when to conduct the visual assessments (e.g., within 30 minutes of an actual discharge, at least 3 days from
previous discharge, etc.).
3. Specific items to be covered by the assessment (e.g., the 2008 MSGP requires permittees to visually inspect the sample in a
well-lit area to assess the following water quality characteristics:
Color Suspended solids
Odor Foam
Clarity Oil sheen
Floating solids Other obvious indicators of stormwater pollution)
Settled solids
4. The number and locations of outfalls scheduled for visual assessments. List the outfalls where visual assessments will take
place, and make sure these locations are identified on your site map.
5. A description of safety considerations, requirements, and equipment for collecting samples during wet weather events.
Note: Sample must be collected in a clean, clear glass (required for oil and grease samples) or plastic container. Describe any
other equipment necessary to collect the samples (such as sampling poles for hard to reach outfalls, rain gear, etc.). Describe
any necessary safety considerations for staff while collecting the samples (for example, if they are sampling at an outfall
discharging into receiving water with high flows, or sampling in a manhole).
6. Reporting procedures: Describe your reporting procedures and include a blank copy of the assessment form that will be used
during the visual assessments. Most industrial stormwater general permits require that visual assessment reports include the
following:
Sample location(s)
Sample collection date and time, and visual assessment date and time for each sample
The names of individuals, and titles or job positions, collecting the sample and performing visual assessment, and their
signatures
Nature of the discharge (i.e., runoff or snowmelt)
Results of observations of the stormwater discharge
Probable sources of any observed stormwater contamination
If applicable, why it was not possible to collect samples within the first 30 minutes of discharge.
The SWPPP should also contain a checklist or list of the water quality parameters that must be observed and documented.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Visual Assessment Documentation
Similar to the inspection reports for the
routine facility inspections, you must docu-
ment the results of your visual assessments in
a written report. You should include a blank
copy of your visual assessment report form
that you will use in your SWPPP. An example
of a visual assessment report can be found
in the "Additional MSGP Documentation
Template" on EPA's website at
www.epa.gov/npdes/pubs/msgp2008_
recordkeepingtemplate.doc.
Digital photos of the samples are recom-
mended, but not required, to document the
condition of the sample and future reference.
5.C Annual Comprehensive Site
Inspections
Most industrial stormwater general permits
require an annual comprehensive site inspec-
tion. The annual comprehensive site inspec-
tion is a more in-depth version of the routine
facility inspection. The annual comprehensive
site inspection evaluates the condition of
control measures, taking into account trends
observed in analytic and visual stormwater
samples taken during the year, and found dur-
ing routine inspections.
Check your general permit to determine if the
comprehensive site inspection needs to be
conducted at a certain time (e.g., by the end
of the fiscal year). Some permits require you
to submit your comprehensive site inspection
findings to the State permit authority as part of
your annual report, typically due shortly after
the end of the fiscal year. EPA's 2008 MSGP
requires that the annual report be submitted
and postmarked within 45 days of completing
the annual comprehensive site inspection.
The comprehensive site inspection must cover
all areas of the facility affected by the require-
ments of your industrial stormwater general
permit, including all potential stormwater pol-
lutant sources identified in the SWPPP, areas
where control measures are used to comply
with applicable effluent limits, and areas where
spills and leaks have been documented in the
three years prior to the annual comprehensive
site inspection. In addition, the annual inspec-
tion must, as appropriate, include a review of
visual stormwater monitoring data collected
each quarter of the previous year and the
results of the routine site inspections.
SWPPP Tip!
EPA's 2008 MSGP requires you to conduct annual comprehensive
site inspections once during each of the following inspection periods:
Year 1: September 29, 2008 - September 29, 2009
Year 2: September 29, 2009 - September 29, 2010
Year 3: September 29, 2010 - September 29, 2011
Year 4: September 29, 2011 - September 29, 2012
Year 5: September 29, 2012 - September 29, 2013
Comprehensive site inspections must be
conducted by qualified personnel with at least
one member of your stormwater pollution
prevention team participating in the compre-
hensive site inspections.
The annual inspection should be preceded
by evaluation of the year's visual stormwater
sample observations, analytic monitoring data,
and your routine site inspection findings. The
overall review of the previous year's visual and
analytic monitoring results will provide you
with areas of focus for the annual inspection;
however, the annual inspection must include
all control measures included in the SWPPP,
regardless of the results from the past visual
assessments and site inspections. Inspecting
all stormwater control measures is meant to
ensure that they are functioning correctly, and,
if not, to correct any deficiency or malfunction.
Accordingly, at the end of the annual compre-
hensive inspection you, and your stormwater
pollution prevention team, should be able to
answer the following questions.
Are the control measures in place, main-
tained, and operating effectively?
Is the routine site inspection protocol
effective and conducted at the appropriate
frequency?
If your previous visual samples been were
indicated the presence of pollutants in your
stormwater, and your analytic samples
been found to have high levels of any
benchmark pollutants or other pollutants of
concern, do you suspect that any particular
areas of your site are contributing to these
monitoring results? Do you suspect that the
improper functioning of any stormwater
control measures is contributing to these
monitoring results?
Is the SWPPP up-to-date regarding all of
the stated control measures and monitoring
schedules?
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Based on the answers to these questions, you
may need to modify your stormwater man-
agement program and to update your SWPPP
to address problems found during your
inspection.
Comprehensive Site Inspection Documentation
The results, and documentation, of your
annual site inspection must be maintained
on-site and, depending on the requirements
in your stormwater permit, submitted with
your annual report. An example of a compre-
hensive site inspection report can be found
in the "Additional MSGP Documentation
Template" on EPA's website at
www.epa.gov/npdes/pubs/msgp2008_
recordkeepingtemplate.doc.
What to Include in Your SWPPP
Include in your SWPPP a description of the annual comprehensive site inspection process:
1. Person(s) or positions of person(s) responsible for inspection
Note-. Include at least one member of the stormwater pollution prevention team.
2. Schedules for conducting the inspections
Note-. Describe when during the year the annual inspection will take place.
3. Describe the list of documents to be reviewed prior to the annual site inspection. This list will typically include:
The current SWPPP
All routine inspection reports for the past year
All visual assessment reports for the past year
Other documentation that may relate to how your facility complies with stormwater permit requirements, such as
maintenance records, spill records, etc. for the past year.
4. A copy of the current SWPPP site map
Note-. A current copy of the site map can be used during the comprehensive site inspection to make sure the inspector is
covering all required areas.
5. Procedures for 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 for. Specific items to be
covered by the inspection include:
Industrial materials, residue, or trash that may have or could come into contact with stormwater;
Leaks or spills from industrial equipment, drums, tanks, and other containers;
Offsite tracking of industrial or waste materials, or sediment where vehicles enter or exit the site;
Tracking or blowing of raw, final, or waste materials from areas of no exposure to exposed areas; and
Control measures needing replacement, maintenance, or repair.
6. A copy of the annual site inspection form you will use.
Note-. EPA's 2008 MSGP has a comprehensive site inspection form in Appendix I of EPA's 2008 MSGP. Your annual site
inspection form should contain:
The date of the inspection;
The name(s) and title(s) of the personnel making the inspection;
Findings from the areas of your facility that were examined;
All observations relating to the implementation of your control measures including:
- Previously unidentified discharges from the site,
- Previously unidentified pollutants in existing discharges,
- Evidence of, or the potential for, pollutants entering the drainage system;
- Evidence of pollutants discharging to receiving waters at all facility outfall(s), and the condition of and around the
outfall, including flow dissipation measures to prevent scouring, and
- Additional control measures needed to address any conditions requiring corrective action identified during the
inspection.
Any required revisions to the SWPPP resulting from the inspection;
Any incidents of noncompliance observed or a certification stating the facility is in compliance with this permit (if there is no
noncompliance); and
A statement, signed and certified in accordance with Appendix B, Subsection 11 of EPA's 2008 MSGP.
7. A schedule for completing and submitting (if required) the annual site inspection form/report in a timely manner.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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5.D Documentation of Monitoring
Procedures
Your industrial stormwater general permit may
include requirements to conduct stormwater
discharge monitoring. The type of monitor-
ing you are required to conduct will likely be
based on your type of industrial activity. Not
all types of industrial activity will be required
to collect stormwater discharge samples,
however, if your facility is required to conduct
monitoring (such as benchmark monitoring or
effluent limitation guideline monitoring), you
must describe the procedures you will use to
carry out this monitoring in your SWPPP.
EPA has prepared an Industrial Stormwater
Monitoring and Sampling Guide (available
at www.epa.gov/npdes/stormwater/msgp)
that will support this guide. The Industrial
Stormwater Monitoring and Sampling Guide
provides a more detailed description of moni-
toring approaches and procedures that are
recommended than is included in this guide.
As a general matter, your stormwater discharge
samples will be taken at your facility's storm-
water outfall locations, not at locations within
your facility. Some stormwater general permits
allow you to sample at only one outfall when
multiple outfalls at your facility have similar
industrial activities, control measures, exposed
materials, and runoff coefficients. Outfalls that
have these similar characteristics are called
"substantially identical outfalls" or "represen-
tative outfalls." See your industrial stormwater
general permit for more information.
What to Include in Your SWPPP
Include in your SWPPP, a description of the following monitoring requirements:
1. What you need to monitor
Make sure your SWPPP clearly identifies the parameters you need to monitor, and any applicable benchmark concentrations or
effluent limits associated with each parameter.
2. Where you need to monitor
Your site map should identify the outfalls at your facility. In your SWPPP, identify at which outfalls you will be required to
monitor. If you are allowed to sample one of the outfalls that are "substantially identical", and you plan on using a representative
outfall, include the following documentation in your SWPPP:
Location of each substantially identical outfall;
Description of the general industrial activities conducted in the drainage area of each substantially identical outfall;
Description of the control measures implemented in the drainage area of each substantially identical outfall;
Description of the exposed materials located in the drainage area of each substantially identical outfall that are likely to be
significant contributors of pollutants to stormwater discharges;
An estimate of the runoff coefficient of the drainage areas (low = under 40%; medium = 40 to 65%; high = above 65%);
and
Why the outfalls are expected to discharge substantially identical effluents.
3. When you need to monitor
If you are required to monitor, your industrial stormwater general permit will specify a monitoring frequency (typically quarterly
or annually). For each of the parameters you identified above, include in your SWPPP the monitoring frequency. Some permits
also specify exemptions or alternative monitoring periods, which should also be addressed in your SWPPP.
Your SWPPP should also describe the type of storm event that should be monitored. In the 2008 MSGP, EPA requires
monitoring during a storm event those results in an actual discharge from your site ("measurable storm event") that follows the
preceding measurable storm event by at least 72 hours (3 days).
4. How you will conduct the monitoring
Describe in your SWPPP how you will conduct the monitoring, including who will collect the samples. Typically, monitoring is
conducted by taking one grab sample from a discharge resulting from a measurable storm event and collected within the first
30 minutes of a measurable storm event, during normal business hours, when stormwater is discharging from your facility.
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 before being analyzed.
5. Where you will send the sample for analysis
Finally, in your SWPPP, include information about the laboratory where you will send the samples for analysis. Include information
such as lab name and address, any sampling procedures required by the lab, and who will take the samples to the lab.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 6: Completing Your SWPPP
Now that you have conducted a site assessment of your facility, developed maps,
selected control measures, and developed procedures for inspections and monitoring.
You are almost done with your SWPPP! The last step is to make sure all this informa-
tion is organized into a single document (your SWPPP) and to obtain NPDES permit
coverage.
6.A Finish your SWPPP
The information you put together as part of Sections 3 through 5 make up the con-
tents of your SWPPP. There are only two more steps for you to finish before your
SWPPP is complete:
Conduct a final review of your SWPPP; and
Sign and certify your SWPPP
Review Your Draft SWPPP
You should review the SWPPP requirements in your industrial stormwater general
permit to ensure that your SWPPP includes all required elements. For example, in the
2008 MSGP, the SWPPP requirements are in Part 5. Check off all the SWPPP permit
requirements as you verify that they have been met. Also, develop a final copy of your
site map and make sure that all required elements are addressed.
EPA recommends that you have both your stormwater pollution prevention team, and
someone who was not involved in developing the SWPPP, review your draft SWPPP.
Sign and Certify Your SWPPP
The last step in completing your SWPPP is to have a facility executive or duly autho-
rized representative of that executive sign and certify that the SWPPP meets all the
requirements in the general permit. This signature demonstrates that the SWPPP was
reviewed by someone who has operational control over the facility (i.e., can commit
resources to implementing the SWPPP and ensuring compliance with the permit).
You should check your general permit to determine which person is required to sign
and certify the SWPPP. Note that the signatory requirements for the 2008 MSGP are
found in Appendix B, Subsection 11 of EPA's 2008 MSGP.
6.B Obtain NPDES Permit Coverage
Important! Before obtaining permit coverage, you should read the appropriate industrial
stormwater permit and develop your SWPPP.
Most permits require that you develop your SWPPP before you can obtain NPDES per-
mit coverage for your industrial stormwater discharges. However, in some instances,
the permit may provide you with additional time to complete or update a SWPPP after
permit coverage is obtained. Nevertheless, it is recommended that your SWPPP be
completed at least in draft form prior to applying for permit coverage, even in those
States 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 fill out and submit an application form, often called a Notice of Intent or
34 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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NOI. Submitting an NOI form to the permit-
ting authority indicates your certification that
you have met the eligibility requirements for
coverage under the permit, and your agree-
ment to abide by the terms and conditions of
the 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 State
has notified you accordingly. EPA's 2008 MSGP
(see Part 1.3.1) uses a 30 to 60-day waiting
period following the receipt of a facility's com-
plete NOI. The waiting period expires when
the permit's status changes from "waiting" to
"active" on the Agency's eNOI website.
Read the application requirements in your
general permit for information on the proce-
dures and the specific form you will need to
complete before becoming authorized. Some
States charge an administrative fee to apply for
permit coverage. Before submitting your appli-
cation, you must also make sure that you meet
all eligibility requirements in the permit. For
example, if your facility discharges to one of
several highly protected waters (e.g., a Tier 3
or "Outstanding Natural Resource Water"),
you may not be eligible for coverage under a
general permit and instead may have to file an
application for individual permit coverage.
SWPPP Tip!
Documentation to Support Eligibility
Considerations 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 of the permit). State
industrial stormwater permits may have other
documentation requirements.
6.C Updating Your SWPPP
Your SWPPP is a document that will need to
be reviewed and updated on a regular basis.
Whenever you find the need to change a pro-
cedure that is described in your SWPPP or to
modify a control measure described therein,
you must update the SWPPP to reflect those
changes as quickly as practicable. Should the
SWPPP require modification to document cor-
rective actions, a new certification statement
must be signed and dated upon completion of
the revision.
Below are some examples of events that, if
they result in a change in control measures or
procedures, will require prompt revision of the
SWPPP to reflect the new facility conditions.
A change in the composition of the storm-
water pollution prevention team or new
responsible official.
An unauthorized release or discharge (e.g.,
spill, leak, or discharge of non-stormwater
not authorized by this or another NPDES
permit) occurs at your facility.
A discharge violates a numeric effluent
limit.
You become aware, or EPA determines, that
your control measures are not stringent
enough for the discharge to meet applicable
water quality standards;
An inspection or evaluation of your facility
by an EPA official, or local, State, or Tribal
entity, determines that modifications to the
control measures are necessary to meet the
non-numeric effluent limits in this permit.
Construction or a change in design, opera-
tion, or maintenance at your facility sig-
nificantly changes the nature of pollutants
discharged in stormwater from your facil-
ity, or significantly increases the quantity
of pollutants discharged.
The average of four quarterly sampling
results exceeds an applicable benchmark.
If less than four benchmark samples have
been taken, but the results are such that
an exceedance of the 4 quarter average is
mathematically certain (i.e., if the sum of
quarterly sample results to date is more
than 4 times the benchmark level) this is
considered a benchmark exceedance, trig-
gering a review of control measures and
possible SWPPP modification.
Remember, revisions to the SWPPP to docu-
ment corrective actions requires a new signed
and dated certification statement by the respon-
sible official. All other changes must be signed
and dated by the person preparing the change.
SWPPP Tip!
In the interim between the annual inspection and completed SWPPP
revision, keep a copy of the original SWPPP with your handwritten
notes for SWPPP modifications at the facility. Should you be
inspected before the revised SWPPP is complete, the copy with your
notes can be used to demonstrate the changes that will be in the
revised document.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section T. Keeping Records of Your
Implementation Activities
Completing your SWPPP and obtaining NPDES permit coverage is an important step
towards complying with your State or EPA Clean Water Act requirements. Having
completed these steps, you are now ready to begin documenting your compliance
with the requirements of your permit. EPA's 2008 MSGP and many State permits
require you to keep records of any activities at your site that are related to your com-
pliance, such as conducting inspections, visual assessments, stormwater discharge
monitoring, and corrective actions.
As you conduct inspections, monitoring, corrective actions, and other permit imple-
mentation activities, you will generate additional records, such as inspection reports
and 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 full compliance with the conditions of your permit.
Some examples of this additional documentation include:
Permit records - copies of the NOI or permit application submitted, any letters
received from the permitting authority, and a copy of your general permit.
Spill records - dates of any incidences of significant spills, leaks, or other releases
that resulted in a discharge of pollutants, the circumstances leading to the release,
actions taken in response to the release, and measures taken to prevent the recur-
rence of a release.
Employee training records - keep copies of all employee training records, including
dates, who was trained, and the training topics.
Maintenance records - retain copies of all maintenance and repairs of control mea-
sures, including dates of regular maintenance, dates when maintenance needs were
discovered, and dates when control measures were returned to full function.
Inspection records - keep copies of all routine facility
inspection reports, quarterly visual assessment reports,
and annual comprehensive site inspection reports.
Monitoring records - retain records of all sampling
results including data collection forms, lab results, and
discharge monitoring reports (DMRs).
Corrective action records - keep records of any cor-
rective actions and follow-up activities conducted to
demonstrate compliance with the permit.
SWPPP Tip!
For 2008 MSGP permit holders, the list of
additional documentation requirements can be
found in Part 5.4 of the permit. Also, EPA has
developed an "Additional MSGP Documentation
Template" with sample forms that you can
download from www.epa.gov/npdes/stormwater/
msgp to help you organize this information.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Section 8: Common Compliance
Problems at Industrial Facilities
The following are common problems found during inspections of industrial sites
conducted by EPA. These are provided to assist you in developing and maintaining
an effective SWPPP. As a general matter, it is not enough to simply have a completed
SWPPP at your site. To establish compliance with your permit's limits and condi-
tions, you must also implement the procedures, and install and maintain the control
measures, described in your SWPPP, and make modifications as necessary to improve
your performance.
You should review these common compliance problems and consider how your
SWPPP, or how your implementation of the procedures described in your SWPPP, can
be modified to ensure you are not making the same mistakes.
1. No SWPPP developed. Some facilities do not realize that they
need to develop a SWPPP, or they may copy a generic SWPPP or
a SWPPP for another facility. A SWPPP is a site-specific plan and
should address only your facility.
2. Control measures described in SWPPP not used. The SWPPP
identifies stormwater control measures that are not actually being
used at the site. The stormwater regulations hold you responsible
for effectively implementing all control measures identified in your
SWPPP. If your SWPPP has identified control measures not being
used at your site, you need to edit your SWPPP accordingly to
accurately reflect those measures you are in fact using.
3. No SWPPP on-site. A copy of the SWPPP is not available on-site
for review when a permitting authority or other regulatory agency
inspects your site. You are responsible for maintaining a copy
on-site at all times. If your SWPPP is being updated off-site, keep
a marked-up copy on-site or an electronic copy until the revised
SWPPP arrives.
Figure 16. Good housekeeping is probably the
most common BMP in SWPPPs. Poor sweeping
practices can contribute significant pollutants in
stormwater runoff.
4. SWPPP not signed. The responsible facility representative did not sign and
authorize the current version of the SWPPP.
5. Stormwater pollution prevention team not up-to-date. The stormwater pollution
prevention team identified in the SWPPP is not current. This is particularly
a problem at facilities with high turnover. Remember, you can identify team
members by title rather than by name if high turnover makes it difficult to keep a
current list of names.
6. On-site staff not familiar with SWPPP. Upon arrival of an inspector, no one
familiar with the stormwater program is available. A common permit requirement
is that at least one employee per shift is familiar with the stormwater program and
has access to the relevant files.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Figure 17. Leaking dumpsters can introduce
pollutants into stormwater runoff.
SWPPP Tip!
SWPPP Availability - Keep a copy of the
current, signed and certified SWPPP at your
facility, and make it available to EPA, State,
local agency or other regulatory agency staff
at the time of an onsite inspection or upon
request. The SWPPP should also be made easily
available to facility staff, and should be readily
referred to during regular facility operations to
ensure that all activities are implemented as
described in the SWPPP.
7. Improper collection of visual assessment
samples. Visual stormwater samples are
collected from pooled areas on site. Pooled
areas tend to concentrate pollutants and
are not representative, unless the contents
of the pooled areas flow off of the facility
(this is to your disadvantage).
8. Uncovered dumpsters. Dumpsters that
receive metal waste are not covered or
contained. Dumpsters from contract waste
collection agencies are often not appro-
priately sealed and can leak oils or other
contaminants.
9. Poor employee/contract staff training.
Employees or contract staff are not famil-
iar with your stormwater management
program. You are responsible for educat-
ing employees and contractors because if
they release pollutants at your facility, you
are responsible. If you use contractors,
they should be referred to in your SWPPP
and required to be trained as a part of the
contract.
10. Inspection or monitoring records are not
kept with the SWPPP. Records of routine
site inspections, visual assessments, or
monitoring results are not available with
the SWPPP for review. All records on
implementation of practices required in
the permit must be kept with the SWPPP
(see Section 6.C for more information).
38
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Resources
EPA, 2008 Multi-Sector General Permit, issued September 29, 2008
(available at www.epa.gov/npdes/stormwater/msgp).
EPA's Stormwater Website - www.epa.gov/npdes/stormwater
Industrial Stormwater Resource Locator - www.envcap.org/iswrl/
EPA's Industrial Stormwater Website - www.epa.gov/npdes/stormwater/indust
EPA's 2008 MSGP Website - www.epa.gov/npdes/stormwater/msgp
The Industrial Stormwater and MSGP Websites have a number of resources and tools to aid MSGP
permittees, which include:
Annual Reporting Form - Permittees can use this form to report their annual comprehensive
site inspection and corrective actions to EPA.
Conditional "No Exposure" Exclusion - Industrial facilities can use this form to certify 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 of the 2008 MSGP.
Electronic Notice of Intent (eNOI) System - Allows permittees to quickly apply for permit
coverage under EPA's 2008 MSGP.
Industrial Stormwater Monitoring and Sampling Guide - Provides guidance on how to meet the
monitoring and sampling requirements in the 2008 MSGP.
Industrial Sector Fact Sheets - These fact sheets summarize the types of facilities included that
sector, the pollutants associated with this sector, and the types of Stormwater control measures
generally used.
List of Tier 2 and Tier 3 Waters - Lists of waters currently designated by states as Tier 2 or Tier
3 for antidegradation purposes to help you complete your NOI.
MSGP Discharge Monitoring Report (MDMR) - Permittees can use this paper copy form to
submit monitoring data to EPA.
Reporting MSGP Monitoring Data - Allows permittees to electronically file all benchmark,
effluent limitation guidelines, and impaired waters monitoring data through the eNOI system.
Sample MSGP SWPPP Template - Industrial facilities can use the "Industrial SWPPP Template"
to create their own SWPPPs.
Sample Recordkeeping Templates - Use the sample templates and forms to keep records of your
monitoring, inspection, maintenance, visual evaluation, and corrective action activities.
Search, Sort, and View Industrial NOIs - Searchable database of Stormwater notices of intent
(NOIs) for industrial facilities seeking coverage under EPA's MSGP.
Water Locator Tool - Helps industrial facilities pinpoint their site's latitude and longitude,
receiving water, and impairment status of the water, applicable total maximum daily loads
(TMDLs), and potential pollutants of concern.
EPA's NPDES Authorization Status Website - www.epa.gov/npdes/stormwater/authorizationstatus
EPA's Menu of National Stormwater BMPs - www.epa.gov/npdes/stormwater/menuofbmps
Industrial Stormwater Permit Guide - www.pneac.org/stormwater/
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators 39
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Appendix A: MSGP SWPPP Template
EPA has created a template to assist operators in developing an industrial SWPPP that
addresses the requirements in the 2008 MSGP. The template includes instructions and
space to help operators document activities specific to their facility, such as:
Facility Description and Contact Information
Potential Pollutant Sources
Stormwater Control Measures
Schedules and Procedures for Monitoring
Inspections
Documentation to Support Eligibility Considerations under Other Federal Laws
SWPPP Certification
SWPPP Modifications
SWPPP Attachments
A customizable Microsoft Word version of the MSGP SWPPP Template is available for
download from www.epa.gov/npdes/stormwater/msgp.
40 Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Appendix B: Additional MSGP
Documentation Template
EPA has created a template to assist 2008 MSGP permit holders in collecting the addi-
tional documentation required during implementation of the permit. The Additional
MSGP Documentation Template includes example forms and tables to help permittees
document activities related to:
Significant spills, leaks or other releases
Employee training
Maintenance
Routine Facility Inspection Reports
Quarterly Visual Assessment Reports
Comprehensive Site Inspection Reports
Monitoring results
Deviations from assessment or monitoring schedule
Benchmark Exceedances
Impaired Waters Monitoring: Documentation of Natural Background Sources or
Non-Presence of Impairment Pollutant
Active/Inactive status change
SWPPP Amendment Log
The Additional MSGP Documentation template can be downloaded in Microsoft Word
format at www.epa.gov/npdes/stormwater/msgp.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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