EPA 833-B-09-002
Developing Your Stormwater
Pollution Prevention Plan
A Guide for Industrial Operators
June 2015
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Section 1: Introduction	
l.A  Why Should You Use This Guide?	
l.B  What Is Stormwater Runoff and What Are Its Impacts?	

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

Section5: Procedures for Inspections and Monitoring (Step 4)	26
5.A  Routine Facility Inspections	26
5.B  Visual Assessments	29
5.C  Documentation of Monitoring Procedures	31
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

Section 6: Completing Your SWPPP	32
6.A  Finish your SWPPP	32
6.B  Obtain NPDES Permit Coverage	32
6.C  Updating Your SWPPP	33

Section 7: Keeping Records of Your Implementation Activities	34

Section 8: Common Compliance Problems at Industrial Facilities	35

Resources	37

Appendix A: MSGP SWPPP Template	38
Appendix B: Additional MSGP Documentation Template	39
Appendix C: Example Site Map	40
                                          Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

Section  L    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
2015 Multi-Sector General Permit (MSGP),  the "2015 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 2015 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
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

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 activi-
                ties still  remain exposed to precipitation. In
                addition, 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
  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-stormwa-
  ter 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

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
• Category Four (iv): Hazardous waste treatment, storage, or disposal facilities
• Category Five  (v): Landfills, land application sites, and open dumps with industrial
  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
  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
  SWPPP Tip!
EPA's 2015 Multi-Sector General Permit (2015
MSGP) Applies to a Limited Geographic Area -
The 2015 MSGP applies in four States (Idaho,
New Mexico, Massachusetts and New Hamp-
shire), Indian Country lands, most territories and
some federal facilities. Information on where the
2015 MSGP is available is included as Appendix
C of the 2015 MSGP, which can be found at
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

Where Do I Get a Copy of the Industrial
Stormwater General Permit in My State?
To determine who issues the industrial storm-
water permit in your State, you can visit EPA's
stormwater website at http://water.epa.gov/
State-Contacts.cfm  or the Industrial
Stormwater Resource Locator at

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 2015 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
  •  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 2015 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:  Assess potential stormwater
   pollution sources;

•  Step 3:  Select appropriate control measures
   that minimize the discharge of pollutants
   during storm events for each of these
   sources; and
•  Step 4:  Develop procedures for conducting
   required inspection/monitoring activities,
   as well as regular maintenance of control

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 Tip!
  Prepare your SWPPP before submitting an NOI
  or permit application for coverage!
                                    Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

A typical SWPPP includes the following
•  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 2015 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 2015 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 2015 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
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

    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
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
•  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

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    Whsf fn Inrllldfl in
activities conducted and equipment located at your facility to be able to identify
potential pollutant discharge concerns. To complete this  step, you will need to      YOUT SWPPP
conduct a detailed walk-through of your facility to identify industrial materials
or material handling activities exposed to stormwater (see text box below), any     Develop a list of industrial
stormwater controls already in place at your facility, the  direction of stormwater    activities at your site exposed
flow through and  from your facility,  and the location of all stormwater outfalls.     to stormwater- ldentifVthese
If possible, you should conduct your walk-through during 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 vis-
ible 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
     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).
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

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

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

     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 2015 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 2015 MSGP  (Part 1.1.3) includes:
  •  Discharges from emergency/unplanned fire-fighting activities;
  •  Fire hydrant flushings;
  •  Potable water, including water line flushings;
  •  Uncontaminated condensate from air conditioners, coolers/chillers, and other compressors and from
     the outside storage of refrigerated gases or liquids;
  •  Irrigation drainage;
  •  Landscape watering provided all pesticides, herbicides, and fertilizers have  been applied in accordance
     with the approved labeling;
  •  Pavement wash waters where no detergents or hazardous cleaning products are used and the wash
     waters do not come into contact with oil and grease deposits,  sources of pollutants associated with
     industrial activities, or any other toxic or hazardous  materials,  unless residues are first cleaned up using
     dry clean-up methods and appropriate control measures are implemented to minimize discharges of
     mobilized solids and other pollutants;
  •  Routine external building washdown/power wash water that does not use detergents or hazardous
     cleaning products;
  •  Uncontaminated ground water or spring water;
  •  Foundation  or footing drains where flows are not contaminated with process materials;
  •  Incidental windblown mist from cooling towers that collects on rooftops or adjacent portions of your
     facility, but  not intentional discharges from the cooling tower;  and
  •  Discharges from the spray down of lumber and wood product  storage yards where no chemical addi-
     tives are used in the spray-down waters and no chemicals are applied to the wood during storage.
  •  The 2015 MSGP, Section lists additional allowable non-stormwater  discharges for Sectors G, H
     and J  Mining-related Construction Activities Occurring during the Exploration and Construction Phases
     of Mine Development.
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

  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
  •  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.
drain, re-route a sink drain to the sanitary
sewer, or submit an NPDES permit application
for an unauthorized cooling water discharge.

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

                  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
                   2015 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.
                      SWPPP  Tip!
                    New saltwater benchmarks for
                    discharges into saline waters.
                    If you discharge into saline waters, EPA has
                    added non-hardness dependent metals bench-
                    marks. See the 2015 MSGP for the benchmark
                    value for these metal parameters.
               Compare your sampling results to EPA's 2015
               MSGP Benchmark values below.
2015 MSGP
Biochemical Oxygen
Demand (5 day)
Chemical Oxygen Demand
Total Suspended Solids
Nitrate + Nitrite Nitrogen
Total Phosphorus
Aluminum (T) (pH 6.5 - 9)
Antimony (T)
Arsenic (T)
Beryllium (T)
Cadmium (T)t
Copper (T)*t
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
0.68 mg/L
2.0 mg/L
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 freshwater
                 hardness. The benchmark value listed is based
                 on a hardness of 100 mg/L. The 2015 MSGP
                 requires industrial facility to analyze receiving
                 feshwater samples for hardness, and use the
                 hardness tables provided in the 2015 MSGP to
                 determine the applicable benchmark value for that
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

3.C  Develop General Location and Site
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
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://viewer.
nationalmap.gov/viewer/). 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 available
at http://water.epa.gov/polwaste/npdes/
stormwater/discharge.cfm. 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 appropri-
ate  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
  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

                     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.
Not to Scale
                                                                                               Acme Scrap Metal Recycling Yard Site Map
                                                                                               110 Willowbrook Road, Anywhere, USA 00011
                                                                                               SWPPP Contact: John Doe (111) 999-0000
                                                                                               — -   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
                                                                                                 AC    Air Conditioning Condensate
                                                                                                 FS    Fire Suppression System Test Discharge (potable
                                                                                               Minor fuel spill on fuel island - July 20,2007
                                                                                                Potential Pollutant
                                                                                               Vehicle and
                                                                                               Maintenance Garage
                                                                                                             Aboveground 500-gallon waste oil
                                                                                                ETS: Empty Tank
                                                                                               SWC: Solid Waste
                                                                                               AST: Above Ground
                                                                                               Covered Aluminum
                                                                                               Recycling Bay
                                                                                               Covered Plastic
                                                                                               Recycling Bay
                                                                                                Ferrous metal storage
                                                                                               Non-Ferrous metal
                                                                                               storage bins
                                                                                                              Potential Pollutants:
                                                                                                     Fuel, oil, antifreeze, grease, hydraulic
                                                                                                     Fluid, brake Fluid, solvents,
                                                                                                     transmission fluid, parts washer, and
                                                                                                     Residual oil, lubricants, hydraulic
                                                                                                              Two 1000 gallon ASTs, Diesel and
                                                                                                              Hydraulic fluid, grease, aluminum
                                                                                                              Hydraulic fluid, oil, grease, fuel
                                                                                                              Non-Ferric metals
Truck Parking

Impervious Surface Estimate
(% of total facility area):  90%
Total Facility Size (acres):  6.5
Figure 4. Example site map.
                                                          Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

  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
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators                                                          13

      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

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 2015 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 2015 MSGP, the
      site operator is given the flexibility to select the type of control mea-
      sures, including specific technologies, which he/she believes are best
      suited to the facility and that will meet the permit's requirements.
      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 stormwater manage-
      ment that are common to all sites, and that can be used by opera-
      tors 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
 The technology-based limits
 included in EPA's 2015 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

• 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
• 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 facil-
  ity's impervious areas and adjacent surface
•  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
The following sections describe the 12 catego-
ries of non-numeric effluent limits required by
the 2015 MSGP. Although the wording of these
requirements may be unique to the EPA per-
mit, many State permits include requirements
that are similar to the 2015 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 2015 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
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
                    •  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

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 benefi s 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

                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 oper-
                ating condition and to prevent or minimize
                leaks and other releases of pollutants (see
                Section 4.D for more specific information). 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 necessary
                repairs or modifications, typically prior to the
                next wet weather event and as expeditiously
                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
                  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
            4.D  Spill Prevention and Response
            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
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

  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 2012 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
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
Stormwater Fact Sheet Series, (www.epa.gov/
npdes/stormwater/msgp), National Menu
of Stormwater BMPs  (http://water.epa.gov/
polwaste/npdes/swbmp/), and National
Management Measures to Control Nonpoint
Source Pollution from Urban Areas

  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
  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

                 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 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.
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 2015 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 2015
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  2015
Note that, if covered by the 2015 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 2015 MSGP or a State general permit.
Statewide general permits may have different
requirements for specific industrial sectors.
    SWPPP  Tip!
  Sector-specific requirements for the 2015
  MSGP - All sector-specific requirements can be
  found in Part 8 of the 2015 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 2015 MSGP.
  These sector fact sheets can be found at
  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 2015 MSGP.
  •  The location of each control and/or procedure
     used to comply with the sector-specific
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

4.1   Employee Training
Stormwater training is required for all employ-
ees who work in areas where industrial
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 ses-
sions are expected to cover the contents of the
facility SWPPP, control measures implemented
to achieve compliance with applicable dis-
charge requirements, spill containment and
cleanup procedures, maintenance,  monitor-
ing, 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
                                                                       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

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

                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
                •  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
  and 2.1.3 of EPA's 2015 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
           •  Runoff from non-hazardous waste landfills
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

•  Runoff from coal storage piles at steam
   electric generating facilities
•  Runoff containing urea from airfield pave-
   ment deicing at existing and new primary
   airports with 1,000 or more annual non-
   propeller aircraft departures

An example of a numeric effluent limit is
the requirement for facilities that discharge
stormwater from asphalt emulsion facilities to
meet specific, numeric concentration limits for
TSS, pH, and oil and grease (i.e., based on the
limits 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
  • A description of the control measures used to
    meet the numeric effluent limits.
  • The location of each control  measure at your
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
    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
  2015 MSGP, see Part 2.2 for a more detailed
  discussion of water quality-based effluent
  limitations and conditions for discharging to
  impaired waters.
(TMDLs), and those for which a TMDL has
not yet been approved or established.

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
2015 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
  stormwater/discharge.cfm) or other tool to
  determine whether or not the waters that a
  facility discharges to are impaired or have a
  TMDL. First, enter the facility location. Second,
  draw the facility or discharge locations on the
  map and "execute query" to determine your
  discharge information, including surface waters
  to which you discharge.
  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
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

      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 two types of inspections:
      1 .  Routine facility inspections
         (see Section 5.A)
      2 .  Quarterly visual assessments
         (see Section 5.B)

      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.C 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
EPA's 2025 MSGP requires two types of facility
 1.  Routine facility inspections (2015 MSGP, Part 3.1)
 2.  Quarterly visual assessment of stormwater discharges
    (2015 MSGP, Part 3.2)

The 2015 MSGP also includes the requirements
for the following types of monitoring:
 1.  Benchmark monitoring (2015 MSGP, Part 6.2.1)
 2.  Effluent guidelines limitation  monitoring
    (2015 MSGP, Part 6.2.2)
 3.  State or Tribal monitoring (2015 MSGP, Part 6.2.3)
 4.  Impaired waters monitoring (2015 MSGP, Part 6.2.4)

 Monitoring procedures are described in Part 6.1  of the 2015

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

  EPA's 2015 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
  The 2015 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, 2015 MSGP
  Part 3.1.1 identifies exceptions to routine visual
  inspections for inactive or unstaffed sites.
Recommended Routine Facility Inspection
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

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

 Is the finished product appropriately con-
 tained for potential pollutant sources?
 Following the internal evaluation, walk the
 perimeter of your site and look for evidence
 of stormwater discharges—particularly
 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.
 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.
. Finally, where appropriate, repair or
 replace worn or ineffective control mea-
 sures as soon as possible but certainly
 before  the next forecasted precipitation
                                                                      SWPPP  Tip!
Figure 15. Example of a sheen indicating the presence of oil or other
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
                                                                  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
                                                                      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.
                                  Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

  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.C 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
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.
    SWPPP Tip!
  Make sure your staff is trained on how to take
  samples. EPA has developed an Industrial
  Stormwater Monitoring and Sampling Guide
  (March 2009) that describes how to prepare
  for, conduct and evaluate monitoring results.
  Individual states may also have their own
  guidance on industrial stormwater monitoring.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

                 EPA's 2015 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
            •  Collect the samples from discharges that
               happen at least 72 hours (3 days) from the
               previous discharge event.

            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
  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 2015 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
        •  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
        •  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

Documentation Template" on EPA's website at
www.epa.gov/npdes/storm water/msgp.

Digital photos of the samples  are recom-
mended, but not required, to document the
condition of the sample and future reference.

5.C  Documentation of Monitoring
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%);
       •  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 2015 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

      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

      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
      2015 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 2015 MSGP are found
      in Appendix B,  Subsection 11  of EPAs 2015 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

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

NOI. Submitting an NOI form to the permitting
authority indicates your certification that you
have met the eligibility requirements for cover-
age under the permit, and your agreement
to abide by the terms and conditions of the
general permit.  Depending on the permit, you
may be authorized to discharge immediately
or at some later time. In some cases, you are
not authorized to discharge until the State has
notified you accordingly. EPA's 2015 MSGP (see
Part 1.2.1) uses  a 30-day waiting period fol-
lowing the receipt of a facility's complete 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 2015 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 5.2.6 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
• 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 quarterly 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

      Section  7:    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 2015 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 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 2015 MSGP permit holders, the list of
             additional documentation requirements can be
             found in Part 5.5 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

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

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

EPA, 2015 Multi-Sector General Permit, issued June 4, 2015
(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 - http://water.epa.gov/polwaste/npdes/stormwater/

EPA's 2015 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 summaries of their site
  inspections 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 2015 MSGP.
• Electronic Notice of Intent (eNOI) System - Allows permittees to quickly apply for permit
  coverage under EPA's 2015  MSGP.
• Industrial Stormwater Monitoring and Sampling Guide - Provides guidance on how to meet the
  monitoring and sampling requirements in the 2015 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 eNOI MSGP NOI Home Page - http://water.epa.gov/polwaste/npdes/stormwater/

EPA's Menu of National Stormwater BMPs - http://water.epa.gov/polwaste/npdes/swbmp/

Industrial Stormwater Permit Guide - www.pneac.org/stormwater/
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators                                                37

     Appendix A:   MSGP  SWPPP Template
     EPA has created a template to assist operators in developing an industrial SWPPP that
     addresses the requirements in the 2015 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.
38                                          Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators

Appendix B:   Additional MSGP
Documentation Template
EPA has created a template to assist 2015 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
• Monitoring results
• Deviations from assessment or monitoring schedule
• Corrective Action Documentation
• 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                                         39

    Appendix C:  Example Site Map
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Recycling Bi

Covered Plastic
Recycling Bay


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Ferrous metal storage

Non-Ferrou? metal
storage bins

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Truck Parking
Impervious Surface Estir
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Total Facility Size (acres)

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