EPA 833-B-09-002
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Developing Your Stormwater
Pollution Prevention Plan
A Guide for Industrial Operators
March 2021
CONTENTS
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3. Granulated Oil Absorbent
4. Yellow Hazardous Material Bag
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators March 2021
Contents
Section 1: Introduction 1
l.A Why Should You Use This Guide? 1
1.B What Is Stormwater Discharge and What Are Its Impacts? 2
Section 2: Getting Started 4
2.A Am I Required to Develop a SWPPP? 4
2.B What Are the Basic Elements Required in a SWPPP? 5
2.C Stormwater Pollution Prevention Team (Step 1) 7
2.D What Do I Need to Do to Complete My SWPPP? 8
Section 3: Site Assessment and Planning (Step 2) 9
3.A Conduct an Assessment of the Activities Performed at Your Facility 9
3.B Evaluate Sampling Data 12
3.C Develop General Location and Site Maps 13
Section 4: Selecting Stormwater Control Measures (Step 3) 16
4.A Minimize Exposure 18
4.B Good Housekeeping 19
4.C Maintenance 20
4.D Spill Prevention and Response 20
4.E Erosion and Sediment Controls 22
4.F Management of Stormwater 23
4.G Salt Storage Piles or Piles Containing Salt 23
4.H Employee Training 24
4.1 Non-Stormwater Discharges 25
4.J Dust Generation and Vehicle Tracking of Industrial Materials 25
4.K Numeric Effluent Limitations Based on Effluent Limitations Guidelines 26
4.L Additional Controls to Address Impaired Waters 27
Section 5: Schedules and Procedures for Inspections and Monitoring (Step 4) 30
5.A Routine Facility Inspections 30
5.B Quarterly Visual Assessments of Stormwater Discharges 34
5.C Monitoring Procedures 36
Section 6: Completing Your SWPPP 38
6.A Finish your SWPPP 38
Contents
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
6.B Obtain NPDES Permit Coverage 39
6.C Updating Your SWPPP 40
Section 7: Keeping Records of Your Implementation Activities 41
Section 8: Common Compliance Problems at Industrial Facilities 42
Section 9: Resources 44
Appendices
Appendix A: MSGP SWPPP Template
Appendix B: Additional MSGP Documentation Template
Appendix C: Example Site Map
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
List of Figures
Figure 1. Stormwater can carry pollutants from impervious surfaces to receiving waters 2
Figure 2. Example general location map 13
Figure 3. Example general location map 13
Figure 4. Example site map 14
Figure 5. Minimize exposure by providing cover for potential contaminants 18
Figure 6. Two photos showing an industrial facility before and after it followed good
housekeeping practices 19
Figure 7. Poor management of waste and garbage at a facility 19
Figure 8. Equipment should receive routine preventative maintenance to prevent drips and leaks ...20
Figure 9. Spill kits should be maintained in areas with spill potential, such as fueling stations... 20
Figure 10. Slope drains to protect a hillside from erosion 22
Figure 11. Vegetated berm used to prevent facility inundation when the river is at flood
stage 23
Figure 12. Salt pile covered with a tarp 24
Figure 13. In addition to employee training, labeling storm drains is a good measure to
educate employees 24
Figure 14. Unauthorized non-stormwater discharge from an industrial facility 25
Figure 15. Example of a sheen indicating the presence of oil or other hydrocarbons 32
Figure 16. Good housekeeping is a common practice identified in SWPPPs. Poor sweeping
practices can contribute significant pollutants in stormwater discharge 42
Figure 17. Leaking dumpsters can introduce pollutants into stormwater 43
List of Figures
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Section 1: Introduction
This guide includes suggestions on how to develop a stormwater pollution prevention plan
(SWPPP) for industrial stormwater discharges. This guide does not impose any new legally
binding requirements on EPA, states, territories, 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 situation. 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.
1 .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,
territory or the United States Environmental Protection Agency (EPA). You may also find this
guide to be useful if you are a state, territory, 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 or territory permit can be slightly different, this guide is written more
generically in an attempt to make it applicable to as many industrial general permits as possible.
Operators of industrial facilities should carefully read their respective industrial stormwater
general permit to understand where using this guide may conflict with a state or territory
SWPPP requirement, 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 2021 Multi-
Sector General Permit (MSGP), the "2021 MSGP".
In addition to helping you develop a SWPPP, this guide
includes sections that will assist you in keeping your
implementation records and in avoiding common
compliance problems, after you are authorized under the
EPA 2021 MSGP or your state's or territory'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.
SWPPP Tip!
Operators of industrial facilities subject to a
state, territory, 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, a state, or a
territory!
Section 1: Introduction
1
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
1 .B What Is Stormwater Discharge and What Are Its Impacts?
Stormwater discharge 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 conveyance 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 pollutant loads. Stormwater picks up industrial pollutants and
typically discharges them directly into nearby waterbodies or indirectly via storm sewer systems.
Stormwater discharge from areas where industrial activities occur can contain toxic pollutants
(e.g., heavy 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, pollute
drinking water sources, and cause flooding 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 handling, vehicle fueling and
maintenance, shipping and receiving,
and salt storage, all of which can result in
pollutants being exposed to precipitation
and capable of being carried off in
stormwater. Also, facilities may have
performed industrial activities outdoors
in the past and materials from those
activities 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 containers 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 storage of fuels, raw materials, by-products, intermediate
products, final products, or 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 stormwater discharges can contribute pollutants to stormwater when solid
materials wash off or materials dissolve into solution.
Figure 1. Stormwater can carry pollutants from impervious
surfaces to receiving waters.
Section 1: Introduction
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Outdoor Process Activities
Although many manufacturing activities are performed indoors, some activities, such as
timber processing, rock crushing, and concrete mixing, occur outdoors. Outdoor processing
activities can result in liquid spillage and losses of material solids, which makes associated
pollutants available for discharge in runoff.
Dust or Particulate 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.
Illicit Connections and Non-Stortnwater Discharges
Illicit connections of process wastes or other pollutants to stormwater collection systems,
instead of to sanitary sewers, can be a significant source of stormwater pollution. Non-
stormwater discharges are those discharges that do not originate from storm events (for
example, discharges of process water, air conditioner condensate, non-contact cooling
water, pavement wash water, external building washdown, irrigation water, or
uncontaminated ground water or spring water). With few exceptions, these non-stormwater
discharges are prohibited. Refer to your permit for a list of authorized non-stormwater
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.
Section 1: Introduction
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
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. Where EPA is not
the permitting authority for stormwater from industrial facilities, it has delegated the states or
territories to regulate stormwater discharges from
these industrial activities.
Most industrial stormwater discharges are covered
under NPDES general permits, as opposed to
individual permits, although states, territories, 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 the
applicable eligibility provisions, and submit a notice of
intent (NOI) to the permitting authority.
Federal regulations at 40 CFR 122.26(b)(14) require
NPDES permit coverage for stormwater discharges
from the following categories of industrial activity:
Category One (i): Facilities subject to federal
stormwater effluent limitation guidelines in 40 CFR Subchapter N (Parts 405-471)
Category Two (ii): Heavy manufacturing (e.g., paper mills, chemical plants, petroleum
refineries, steel mills and foundries)
Category Three (iii): Coal and mineral mining and oil and gas exploration and processing
Category Tour (iv): Hazardous waste treatment, storage, or disposal facilities
Category Tive (v): Landfills, land application sites, and open dumps with industrial wastes
Category Six (zri): Metal scrapyards, salvage yards, automobile junkyards, and battery
reclaimers
Category Seven (vii): Steam electric power generating plants
4
SWPPP Tip!
EPA's 2021 Multi-Sector General Permit
(2021 MSGP) Applies to a Limited
Geographic Area
The 2021 MSGP applies in four states (Idaho
[until July 2021], New Mexico, Massachusetts
and New Hampshire), the District of Columbia,
Indian Country lands, Puerto Rico, most
territories and applicable federal facilities in
some states. The 2021 MSGP Appendix C
provides a list of where the 2021 MSGP
applies, and can be found at
www.epa.gov/npdes/stormwater-discharges-
industrial-activities-epas-2021-msgp.
Note: On July 1, 2021, NPDES permitting
authority for industrial stormwater will
transfer to Idaho; for more information about
Idaho's NPDES authorization visit Idaho NPDES
Program Authorization at
https://www.epa.gov/npdes-permits/idaho-
npdes-program-authorization
Section 2: Getting Started
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Category Eight (viii): Transportation facilities that have vehicle maintenance shops,
equipment cleaning operations, or airport deicing operations
Category Nine (ix): Treatment works treating domestic sewage with a design flow of 1
million gallons a day or more
Category Ten (x): Construction sites that disturb 5 acres or more (mostly permitted
separately under a construction stormwater permit)
Category Eleven (xi): Light manufacturing (e.g., food processing, printing and publishing,
electronic and other electrical equipment manufacturing, and public warehousing and
storage).
Where Do I Get a Copy of the Industrial Stormwater General Permit in My
State?
To determine who issues the industrial stormwater permit in your state or territory, you can
visit EPA's stormwater contact us website at https://www.epa.gov/npdes/contact-us-
stormwater#state or the Industrial Stormwater State Resource Locator at
https://www.envcap.org/srl/resourcelocator.php?id=8.
Who Is an Operator?
EPA defines the operator of an industrial facility 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 necessary 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 2021MSGP.
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
responsibility to obtain permit coverage and comply with
the permit provisions.
SWPPP Tip!
What is a SWPPP?
A SWPPP is a site-specific, written document
that:
Identifies potential sources of stormwater
pollution at the industrial facility;
Describes stormwater control measures
that are used to reduce or eliminate
pollutants in stormwater discharges from
the industrial facility; and
Identifies procedures the operator will use
to comply with the terms and conditions of
the 2021 MSGP or a state or territory
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 identifies the industrial activities conducted at the site,
including any structural control practices, which the industrial facility operator will implement to
prevent pollutants from making their way into stormwater discharges.
Section 2: Getting Started
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
The SWPPP also must include descriptions of other relevant information, such as the physical
features of the facility, and procedures for spill prevention, conducting inspections and
monitoring, and training of employees. The SWPPP is intended to be a "living" document,
modified and updated, as necessary, in response to
corrective actions and deadlines.
The process of developing or updating an existing
SWPPP involves the following four steps:
J
r SWPPP Tip!1
r
You must prepare your SWPPP before
submitting an NOI for coverage!
Step 1: Formation of a stormwater pollution prevention team of qualified personnel who
will be responsible for preparing the plan and assisting the plant manager in implementing
practices to comply with the permit;
Step 2: Assessment of potential pollution sources;
Step 3: Selection of appropriate stormwater control measures that minimize the discharge
of pollutants during storm events for each of these sources; and
Step 4: Development of procedures for conducting required inspection and monitoring
activities, as well as regular maintenance of control measures.
This guide will assist you with these four steps. The selection of a stormwater pollution
prevention team is discussed in the next section (Section 2.C). Site assessment and planning is
addressed in Section 3, the selection of control measures is discussed in Section 4, and
schedules and procedures for inspection and monitoring 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.
The required content of the MSGP SWPPP includes the following elements:
Stormwater pollution prevention team;
Site description;
Summary of potential pollutant sources;
Description of stormwater control measures (SCM);
Schedules and procedures;
Documentation to support eligibility pertaining to other federal laws; and
Signature requirements.
EPA has developed a model Industrial SWPPP Template, which can be found on EPA's website at
www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-2021-msgp. This
template, developed for operators under the 2021 MSGP, is available in Microsoft Word and can
be customized to address SWPPP requirements in different state or territory NPDES permits.
Where your facility has other written procedures in place, such as a Spill Prevention, Control and
Countermeasure (SPCC) Plan or an Environmental Management System (EMS), your SWPPP can
reference the portions of those documents in lieu of duplicating that information in your
Section 2: Getting Started
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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J
r SWPPP Tip!1
r
EPA's 2021 MSGP includes the requirements
for a SWPPP in Part 6 of the permit.
SWPPP. In these instances, copies of the relevant
portions of those documents must be kept with your
SWPPP.
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 inspections
and assessments, monitoring, documentation to support eligibility under other federal laws, and
corrective actions and/or additional implementation
measures (AIM). This additional documentation, 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).
What to Include in Your SWPPP
In your SWPPP, identify the staff members (by
name or title) that comprise the facility's
stormwater pollution prevention team as well
as their individual responsibilities. Make sure
you keep this information up-to-date as staff
members change.
To assist permittees in their recordkeeping, EPA has
developed an Additional MSGP Documentation template,
which is available at www.epa.gov/npdes/stormwater-
discharges-industrial-activities-epas-2021-msgp. This
template, developed for permit holders subject to the 2021 MSGP, is available in Microsoft
Word and can be modified as necessary to address state or territory-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 overseeing development of the
facility's SWPPP, any modifications to it, and for implementing and maintaining control
measures and taking corrective action and/or AIM responses when required to address permit
violations or to improve the performance of control measures, and modifying the SWPPP to
reflect changes made to the control measures. Since industrial facilities differ in size and
complexity, the number of team members will also vary. The stormwater pollution prevention
team should consist of those people on-site who are most familiar with the facility and its
operations and responsible for ensuring that necessary controls are in place to eliminate or
minimize the impacts of stormwater from the facility.
SWPPP Tip!
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 comply 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, state, or territory
inspector visits the facility, this person will be the main point of contact for the SWPPP.
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.
Section 2: Getting Started
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Each member of the stormwater pollution prevention team
must have ready access to either an electronic or paper
copy of applicable portions of the 2021 MSGP, the most
updated copy of the SWPPP, and other relevant documents
or information that must be kept with the SWPPP.
2.D What Do I Need to Do to Complete My
SWPPP?
After identifying your pollution prevention team, you are
ready to complete the next three steps in the development
of your SWPPP:
Step 2: Assessing your site and activities (Section 3);
Step 3: Selecting stormwater control measures (Section
4); and
Step 4: Developing schedules and procedures for inspections 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 in the 2021 MSGP as "those who are
knowledgeable in the principles and practices
of industrial stormwater controls and pollution
prevention, and who possess the education and
ability to assess conditions at the industrial
facility that could impact stormwater quality,
and the education and ability to assess the
effectiveness of stormwater controls selected
and installed to meet the requirements of the
permit."
Section 2: Getting Started
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Section 3: Site Assessment and
Planning (Step 2)
This section describes how to collect the information needed for your SWPPP. This information
includes:
An assessment of the activities performed at your facility - this assessment will help identify
potential pollutant sources.
An evaluation of existing sampling data - a review of sampling data will show where past
problems have occurred.
Preparing maps of your facility - site maps will identify the location of industrial activities,
pollutant sources, control measures, and the direction of stormwater flow.
3.A Conduct an Assessment of the Activities Performed at Your
Facility
The first step in developing a SWPPP is to gain a thorough understanding of the activities
conducted and equipment located at your facility to be able to identify potential pollutant
discharge concerns. To complete this step, you will need to
conduct a detailed walk-through of your facility to identify
industrial materials or material handling activities exposed
to stormwater (see text box below), any stormwater
controls already in place at your facility, the direction of
stormwater flow through and from your facility, and the
location of all stormwater discharge points. 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 to help you thoroughly
identify any activities that may contribute stormwater pollutants, but that may not be readily
visible during a routine walk-through
What to Include in Your SWPPP
Develop a list of industrial activities at your site
exposed to stormwater. Identify these activities
on your site map.
(e.g., to identify activities that are not
performed on a routine basis).
The facility assessment will reveal
locations where industrial materials or
material handling activities may be
contributing stormwater contaminants,
and help you identify pollutant sources.
The following approach is suggested for
completing your facility assessment:
How Does EPA Define Industrial Materials
and Material Handling Activities?
Industrial materials or activities include, but are not limited to,
material handling equipment or activities, industrial machinery, raw
materials, intermediate products, by-products, final products, or
waste products. Material handling activities include the storage,
loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product or waste product. See
40 CFR 122.26(g).
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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Identification of Activities Exposed to Stormwater. As you conduct your facility assessment,
make a list of the industrial activities exposed to stormwater (e.g., material storage; equipment
fueling, maintenance, and cleaning; cutting steel beams). Note their location so they can be
identified on the site map.
Inventory of Materials and Pollutants. Make a list of
pollutants or pollutant constituents (e.g., crankcase oil,
zinc, sulfuric acid, and cleaning solvents) associated with
each identified activity, including pollutants associated
with these pollutants or pollutant constituents, based on
how they are stored, handled, disposed, etc. Note
whether they are exposed to stormwater, or have the
potential to be exposed to stormwater. How pollutants
or pollutant constituents 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 could occur, and
specify the discharge point(s) that would be affected by such spills and leaks. Document all
significant spills and leaks of oil or toxic or hazardous substances 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 preparing for and documenting such releases.
Presence ofNon-Stormwater Discharges. A non-stormwater discharge is a discharge that does
not originate from storm events. Non-stormwater discharges often come from potable water
sources or process wastewater discharges. With few exceptions, the non-stormwater discharge
from your facility is prohibited unless it is specifically allowed under an NPDES permit.
You must evaluate for the presence of non-stormwater discharges and be able to demonstrate
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).
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.
Conduct your evaluation during a period of dry weather
(no rain for at least the previous three days). Walk your
site and evaluate each discharge point to identify any
locations with flowing or stagnant water or discharging
liquid; the presence of such water or liquid 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 authorized non-stormwater
discharges identified below or otherwise in need of further action to eliminate the source. You
should also identify any indicators of past or intermittent non-stormwater discharges (such as
evidence of stains at the discharge point).
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
If any non-stormwater discharges are identified
during the evaluation, you should take steps to
eliminate any that are prohibited under your
permit. For example, seal a floor 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 location
of any storage piles containing salt used for
deicing or that are used for other commercial or
industrial purposes. Salt and deicing materials
should be stored inside and not exposed to
stormwater, if possible.
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 discharge points or onsite
drainage points that were directly
observed during the evaluation;
The different types of non-stormwater
discharge(s) and source locations; and
The action(s) taken, such as a list of
control measures used to eliminate
unauthorized discharge(s), if any were
identified.
What to Include in Your SWPPP
If your facility has storage piles containing salt,
document the type of material, amount, and its
location.
Authorized Non-Stormwater Discharges in the 2021 MSGP
Most industrial stormwater general permits include a list of non-stormwater
discharges that are authorized and do not need to be eliminated. As used in
EPA's 2021 MSGP, "authorized 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 authorized non-stormwater discharges from
the 2021 MSGP (Part 1.2.2.1) includes:
Discharges from emergency/unplanned fire-fighting activities;
Fire hydrant flushings;
Potable water, including uncontaminated water line flushings;
Uncontaminated condensate from air conditioners, coolers/chillers, and
other compressors and from the outside storage of refrigerated gases or
liquids;
Irrigation/landscape drainage, provided all pesticides, herbicides, and
fertilizers have been applied in accordance with the approved labeling;
Pavement wash waters, provided that detergents or hazardous cleaning
products are not used (e.g., bleach, hydrofluoric acid, muriatic acid,
sodium hydroxide, nonylphenols), and the wash waters do not come into
contact with oil and grease deposits, sources of pollutants associated
with industrial activities (see Part 6.2.3 of the MSGP), or any other toxic
or hazardous materials, unless residues are first cleaned up using dry
clean-up methods (e.g., applying absorbent materials and sweeping,
using hydrophobic mops/rags) and you have implemented appropriate
control measures to minimize discharges of mobilized solids and other
pollutants (e.g., filtration, detention, settlement);
External building/structure washdown / power wash water that does not
use detergents or hazardous cleaning products (e.g., those containing
bleach, hydrofluoric acid, muriatic acid, sodium hydroxide, nonylphenols)
and you have implemented appropriate control measures to minimize
discharges of mobilized solids and other pollutants (e.g., filtration,
detention, settlement);
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 (e.g., "piped" cooling tower blowdown; drains);
Any authorized non-stormwater discharge listed in Part 1.2.2 of the 2021
MSGP or any stormwater discharge listed in Part 1.2.1 of the 2021 MSGP
mixed with a discharge authorized by a different NPDES permit and/or a
discharge that does not require NPDES permit authorization; and
Section 1.2.2.2 of the 2021 MSGP lists additional authorized non-
stormwater discharges for Sector A and Section 1.2.2.3 of the 2021 MSGP
lists additional authorized non-stormwater discharges for earth-
disturbing activities conducted prior to active mining activities for Sectors
G, H and J facilities.
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
3.B Evaluate Sampling Data
You should evaluate any stormwater discharge sampling data you, or others, collected, from the
previous permit term or any time in the past five 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 sampling
data is to identify or pinpoint any pollutants of concern,
hotspots, or control measures that are not functioning
correctly. This information 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 2021
MSGP benchmark values (see SWPPP Tip below).
Attempt to identify why that pollutant existed in
elevated concentrations, what the potential sources
of that pollutant are at your facility, and what
potential measures you could use to reduce that
pollutant.
SWPPP Tip!
Aluminum and Copper Benchmark
Exceedances
The 2021 MSGP allows operators whose
stormwater discharges exceed the benchmark
thresholds for aluminum and copper to
demonstrate to EPA that their discharges do not
result in an exceedance of a facility-specific value
calculated using the national recommended
water quality criteria multi-variable models in-
lieu of the applicable MSGP benchmark
threshold. See Part 5.2.6.4 of the 2021 MSGP
SWPPP Tip!
New Selenium Benchmark Threshold for
Discharges into Freshwater
The 2021 MSGP includes the benchmark
threshold of 1.5 (ig/L for stormwater discharges
to still/standing (lentic) waters and 3.1 ng/L for
stormwater discharges to flowing (lotic) waters.
Operators required to conduct benchmark
monitoring for selenium are required to identify
on the NOI whether the receiving waterbody is
still/standing or flowing for each discharge point.
SWPPP Tip!
Compare your sampling results to EPA's
2021 MSGP Benchmark values below.
Pollutant
2021 MSGP
Benchmark
(freshwater)
Ammonia
2.14 mg/L
Biochemical Oxygen
Demand (5 day)
30 mg/L
Chemical Oxygen Demand
120 mg/L
Total Suspended Solids
100 mg/L
Turbidity
50 NTU
Nitrate and Nitrite Nitrogen
0.68 mg/L
Total Phosphorus
2.0 mg/L
PH
6.0 9.0 s.u.
Aluminum (T)
1,100 fig/L
Antimony (T)
640 pg/L
Arsenic (T)
150 ng/L
Beryllium (T)
130 fig/L
Cadmium (T)+
18 ng/L
Copper (T)
5.19 jig/L
Cyanide
22 flg/L
Lead (T) t
82 jig/L
Mercury (T)
1.4 pig/L
Nickel (T)t
470 flg/L
Selenium (T)(lentic waters)
1.5 fig/L
Selenium (T) (lotic waters)
3.1 flg/L
Silver (T) t
32 ng/L
Zinc (T)t
120 ng/L
(T) Total recoverable
+ These pollutants are dependent on freshwater
hardness. The benchmark value listed is based on
a hardness of 100 mg/L. The 2021 MSGP requires
industrial facility to analyze receiving freshwater
samples for hardness, and use the hardness
tables provided in the 2021 MSGP to determine
the applicable benchmark value for that facility.
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
3.C Develop General Location and Site Maps
The final step in the site assessment process is to
document the results of your site assessment on a
detailed site map. if you have already developed a site
map for an earlier permit, you should modify the map
as necessary to reflect changes at your facility,
including changes to any of your control measures or
industrial activities.
Your SWPPP must include both a general location map
and a detailed site map. The following is a discussion
of what is required for each type.
General Location Map
A general location map is helpful to identify nearby,
but not necessarily adjacent, waterbodies around your facility. Include in your SWPPP a general
location map (e.g., U.S.Geological Survey (USGS) quadrangle map) with enough detail to identify
the location of your facility and all receiving waters for your stormwater discharges. Create a
USGS map for your area by using the USGS National Map Viewer
(https://apps.nationalmap.gov/viewer). Maps can be printed or saved as PDF documents and
inserted into your SWPPP.
One free web-based mapping service is EPA's Stormwater Discharge Mapping Tool which is
available at https://www.epa.gov/npdes/epas-stormwater-discharge-mapping-tools To use the
tool, enter the address or latitude/longitude of your facility into the "Find address or place" box.
Click the "enter" key or the magnifying glass icon to zoom the map to that location. On the map,
zoom in to your facility location. Click the Draw Fixed Polygon or Draw Freehand Polygon button
above the map, and draw an outline of your facility. Click "Execute Query" below the map. Right
click on the map with your mouse, and select "Print" to print the map as a PDF.
Figure 2. Example general location map
What to Include in Your SWPPP
aiiteiAife/ir''
Develop a general location map of your facility
that shows:
the location of your facility
receiving waters to which your facility
discharges
It may also be helpful to include roads or political
boundaries to better iocate your facility.
Figure 3. Example general location map.
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Site Map
Develop a map of your site that includes, among other things, the footprint of all buildings,
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 stormwater runoff.
EPA recommends that you develop a first draft of the site map based on the information
collected 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.
Detention Basin 2
/Ferrous metal storage v
r i
Covered Aluminum
Recycling Bay
GO
Truck Parking
y.-SioiuiySeww T
Acme Scrap Metal Recycling Yard Site Map
110 Willowbfook Road, Anywhere, USA 00011
SWPPP Contact: John Doe (111) 999-0000
In
Not to Scale
Map Notes:
- All interior Poor 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.
Symbols:
- Speed Bump
Concrete Curbing Approximate Facility Operation
Area Boundry
Storm Sewer
- > Sanitary Sewer
~ Flow Path
Acronym List:
SD Storm Drain
Dl Drop Inlet
SWC Solid Waste Can (General Location)
WOT Waste Oil Tank
ETS Empty Tank Storage
AST Above Ground Storage Tank
MS4 Municipal Separate Storm Sewer System
Authorized Non-Stormwater Discharges:
HPR Hot Water Heater Pressure Relief Pipe (potable
water)
AC Air Conditioning Condensate
FS Fire Suppression System Test Discharge (potable
water)
Spills:
Minor fuel spill on fuel Island - July 20,2007
Potential Pollutant
Potential Pollutants:
Source:
Vehicle and
Fuel, oil, antifreeze, grease, hydraulic
Equipment
Fluid, brake Fluid, solvents,
Maintenance Garage
transmission fluid, parts washer, and
paint
WOT: Waste Oil Tank
Aboveground 500-gallon waste oil
tank
ETS: Empty Tank
Residual oil, lubricants, hydraulic
Storage
fluid
SWC: Solid Waste
Can
AST: Above Ground
Two 1000 gallon ASTs, Diesel and
Storage Tank
Gasoline
Covered Aluminum
Aluminum
Recycling Bay
Covered Plastic
Plastic
Recycling Bay
Baler
Hydraulic fluid, grease, aluminum.
plastic
Crane
Hydraulic fluid, oil, grease, fuel
Ferrous metal storage
Ferric metals
pile
Non-Ferrous metal
Non-Ferric metals
storage bins
Truck Parking
Oil, grease, fuel
Impervious Surface Estimate
(% of total facility area):
90%
Total Facility Size (acres): 65
Figure 4. Example site map.
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
What to Include in Your SWPPP
Include a site map of your facility which includes the items below:
Boundaries of the property and the size of the property in acres;
The location and extent of significant structures and impervious surfaces;
Directions of stormwater flow (use arrows), including flows with a significant potential to cause soil erosion;
Locations of all stormwater control measures;
Locations of all receiving waters, including wetlands, in the immediate vicinity of your facility, indicating which
waterbodies are listed as impaired and which are identified by your state, territory, tribe, or EPA as Tier2, Tier 2.5,
or Tier 3 waters;
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 discharge points, with a unique identification code for each discharge point
(e.g., 001, 002.), indicating if you are treating one or more discharge points as "substantially identical", and an
approximate outline of the areas draining to each discharge point;
If applicable, municipal separate storm sewer systems (MS4s) and where your stormwater discharges to them;
Areas of Endangered Species Act-designated critical habitat for endangered or threatened species, if applicable;
and
Locations of the following activities where such activities are exposed to precipitation:
o fueling stations;
o vehicle and equipment maintenance and/or cleaning areas;
o loading/unloading areas;
o locations used for the treatment, storage, or disposal of wastes;
o liquid storage tanks;
o processing and storage areas;
o 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;
o transfer areas for substances in bulk;
o machinery; and
o locations and sources of run-on to your site from adjacent property that contains significant quantities of
pollutants.
Section 3: Site Assessment and Planning (Step 2)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Section 4: Selecting Stormwater
Control Measures (Step 3)
Stormwater Control Measures (SCMs) are the stormwater management method that incorporates
structural or non-structural practices to prevent or reduce the discharge of pollutants in
stormwater. Structural SCMs, may include the
installation of hard structures to control discharges.
SCMs include practices such as vegetative swales,
collection and reuse of stormwater, inlet controls,
snow management, infiltration devices, and wet
retention measures. Non-structural SCMs are intended
to prevent or reduce the generation of pollutants in
stormwater and/or the volume of stormwater
discharge using practices that focus on facility
operations and procedures. Examples of non-structural
SCMs include procedural practices such as employee trainings and the posting of signs that raise
staff awareness to the best management practices (BMPs) and procedures in place to control
stormwater pollutants.
A combination of preventive and active treatment control measures usually results in the most
effective stormwater management for minimizing the offsite discharge of pollutants in stormwater.
Most control measures require regular maintenance to function as intended. Some SCMs have
simple maintenance requirements, while others may require more extensive upkeep in order to
maximize their performance. Note that identifying weaknesses in current facility practices will help
permittees determine appropriate control measures for use at the site.
General Stormwater Management Principles
In most industrial stormwater permits, including the
2021 MSGP, site operators are given the flexibility to
select the type of SCMs, including specific
technologies, which they believe 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
management that are common to all sites, and that can be used by operators in their selection and
design of control measures. These general principles, listed below, should be considered as a way
to maximize the performance of control measures at your site.
Pollution prevention - The best way to prevent stormwater pollution is to minimize the use of
water contaminants in your industrial activities. When selecting control measures for the
SWPPP Tip!
Effluent limits = stormwater control
requirements. In the 2021 MSGP, as with
most state or territory industrial stormwater
general permits, stormwater control measures
are those structural or non-structural practices
that are used to achieve the permit's effluent
limits.
What does "minimize" mean?
The technology-based limits included in EPA's
2021 MSGP require that you minimize (i.e.,
defined as reduce and/or eliminate) stormwater
exposure to pollutants using control measures
that are technologically available, economically
practicable, and achievable in light of best
industry practice.
Section 4: Selecting Stormwater Control Measures (Step 3)
16
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
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 management and storage.
Minimizing exposure - Another effective way to minimize stormwater pollution is to eliminate
opportunities for stormwater to come into contact with industrial activities 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 single control
measures used in isolation. For example, good housekeeping will often go a long way to
minimize stormwater pollution but is more effective when combined with minimizing the
exposure of significant materials or activities and a structural control, such as inlet protection.
Examining your site's pollutant sources - Understand the type and quantity of pollutants that
could contaminate stormwater leaving your facility. Use your knowledge of the potential
pollutants to drive your selection and design of effective control measures.
Maximizing infiltration - Onsite infiltration 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 when
appropriate. Keep in mind that the use of onsite infiltration typically must be combined with
other control measures 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 infiltration 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 facility's impervious areas and adjacent surface waters.
Using structural practices (as applicable) -When non-structural control measures are not
effective in preventing stormwater contamination, structural control measures (e.g., swirl
separators, sand filters, retention basins, etc.) may be needed to treat stormwater before it
leaves your facility.
E PA's Tech no logy-Based Discharge Requirements
The following sections describe the 10 categories of non-numeric effluent limits required by the
2021 MSGP. Although the wording of these requirements may be unique to the EPA permit, many
state and territory permits include requirements that are similar to the 2021 MSGP.
Section 4: Selecting Stormwater Control Measures (Step 3)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
4.A Minimize Exposure
The first step in an effective stormwater control program is minimizing exposure of manufacturing,
processing, and material storage areas (including loading and unloading, storage, disposal, cleaning,
maintenance, and fueling operations) to rain, snow, snowmelt, and stormwater by either locating
industrial materials and activities inside or protecting them with storm resistant coverings.
SWPPP Tip!
No Exposure Certification (NEC)
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" form is included as
Appendix K of the 2021MSGP. The NEC operates
under a five (5) year permit coverage cycle that is
separate to the MSGP permit coverage and cannot
be administratively continued. Note that
industrial materials do not need to be enclosed
or covered if stormwater from affected areas
will not be discharged to receiving waters or if
discharges are authorized under another
NPDES permit.
Figure 4. Minimize exposure by providing cover
for potential contaminants.
What to Include in Your SWPPP
Describe any structural controls or practices used to minimize the exposure of manufacturing, processing, and
material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling
operations) activities to rain, snow, snowmelt, and stormwater. 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:
Use grading, berming or curbing to prevent discharges of contaminated flows and divert run-on away from these
areas;
Locate materials, equipment, and activities so that potential leaks and spills are contained or able to be contained
or diverted before discharge;
Store leaky vehicles and equipment indoors;
Perform all vehicle and/or equipment cleaning operations indoors, under cover, or in bermed areas that prevent
discharges and run-on and also that capture any overspray; and
Drain fluids from equipment and vehicles that will be decommissioned, and,for any equipment and vehicles that
will remain unused for extended periods of time, inspect at least monthly for leaks.
Section 4: Selecting Stormwater Control Measures (Step 3)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
4.B Good Housekeeping
Good housekeeping practices offer a practical arid cost-
effective way to maintain a clean and orderly facility to
prevent potential pollution sources from coming into
contact with stormwater. Good housekeeping practices
also help to enhance safety and improve the overall work
environment. Good housekeeping measures include
sweeping or vacuuming at regular intervals, washing
down areas and collecting and/or treating and properly
disposing of washdown water, storing materials in
appropriate containers, keeping dumpster lids closed
when not in use or ensuring controls (e.g., secondary
containment, treatment) for dumpsters without lids,
minimizing potential for waste, garbage, and floatable
debris to be discharged by
keeping exposed areas free of
such materials or by
intercepting them before they
are discharged. Facilities that
handle pre-production plastic
(including plastic resin pellets,
powders, flakes, additives,
regrind, scrap, waste and
recycling) must implement
control measures to eliminate
discharges of plastic in
stormwater. To effectively
document in your SWPPP that you are including good
housekeeping procedures at your site, you should establish
protocols to reduce the possibility of mishandling materials
or equipment and train employees in good housekeeping
techniques. An effective good housekeeping program not
only benefits stormwater
quality but makes the facility
a clean, safe place for
employees and clients.
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.
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
convention used for:
Determining when pickup and disposal of
waste materials occurs; and
Routine inspections for ieaks and conditions
of drums, tanks, and containers;
Note: There are specific requirements for
facilities that handle pre-production plastic.
Figure 6. Poor management of waste and
garbage at a facility.
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 monitoring of housekeeping practices has proven to be an
effective means of ensuring the continued implementation of this
control measure
sglllJIIIIllMr
MAINTi:\A\:'[
Figure 5. Two photos showing an industrial
facility before and after it followed good
housekeeping practices.
Section 4: Selecting Stormwater Control Measures (Step 3)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
4.C Maintenance
March 2021
A good maintenance program requires regular inspections, testing, and the preventive
maintenance and repair of industrial equipment (stationary and mobile) and systems. Maintenance
programs are intended to ensure that structural control
measures and industrial equipment are kept in good
operating condition and to prevent or minimize leaks and
other releases of pollutants (see Section 4.D for more
specific information). If you find that your control measures
need routine maintenance, you must conduct the
necessary maintenance immediately in order to minimize
pollutant discharges. If you find that your control measures
need to be repaired or replaced, you must immediately
take all reasonable steps to prevent or minimize the
discharge of pollutants until the final repair or replacement
is implemented. Final repairs/replacement of stormwater
control should be completed as soon as feasible but no
later than the timeframe established in the 2021 MSGP
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.
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 leaks, spills, and other releases that may be exposed
to stormwater. Among the practices that should be in place at
your facility are plans for effective response to spills if or when
they occur. Notification procedures for reporting any leaks, spills,
or other releases should also be developed and followed. 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 7. Equipment should receive routine
preventative maintenance to prevent
drias and leaks.
Figure 8. Spill kits should be
maintained in areas with spill
potential, such as fueling stations.
Section 4: Selecting Stormwater Control Measures (Step 3)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
What to Include in Your SWPPP
Employees must be aware of notification procedures in the event of a
spill or leak, including when to contact appropriate facility personnel,
emergency response agencies, and regulatory agencies. State or local
requirements may necessitate reporting of spills or other prohibited
discharges to local emergency response, public health, or drinking
water supply agencies. Contact information must be posted in
locations that are readily accessible and available to employees.
Where a leak, spill, or other release containing a hazardous
substance or oil in an amount equal to or in excess of a reportable
quantity established under either 40 CFR Part 110, 40 CFR Part 117,
or 40 CFR Part 302, occurs during a 24-hour period, you must notify
the National Response Center (NRC) at (800) 424-8802 or, in the
Washington, DC, metropolitan area, call (202) 267-2675 in
accordance with the requirements of 40 CFR Part 110, 40 CFR Part
117, and 40 CFR Part 302 as soon as you have knowledge of the
discharge.
Describe procedures to:
Maintain all of your site's control measures
in effective operating condition; and
Maintain industrial equipment and systems
in order to minimize pollutant discharges.
Include the schedule you will follow for such
maintenance activities. Describe where each
applicable procedure is being implemented at
the site.
What to Include in Your SWPPP
Describe any structural controls or procedures used to minimize the potential for leaks, spills, and other
releases that may be exposed to stormwater. You must conduct spill prevention and response measures,
including but not limited to the following:
Clean up spills and leaks promptly using dry methods (e.g., absorbents) to prevent the discharge of
pollutants;
Use drip pans and absorbents if leaky vehicles and/or equipment are stored outdoors;
Use spill/overflow protection equipment;
Plainly label containers (e.g., "Used Oil," "Spent Solvents," "Fertilizers and Pesticides") that could be
susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills
or leaks occur;*
Implement procedures for material storage and handling, including the use of secondary
containment and barriers between material storage and traffic areas, or a similarly effective means
designed to prevent the discharge of pollutants from these areas;
Develop training on procedures for expeditiously stopping, containing, and cleaning up leaks, spills,
and other releases. As appropriate, execute such procedures as soon as possible;
Keep spill kits onsite, located near areas where spills may occur or where a rapid response can be
made; and
Notify appropriate facility personnel when a leak, spill or other release occurs.
Describe where each control is to be located or where applicable procedures will be implemented.
Section 4: Selecting Stormwater Control Measures (Step 3)
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
4.E Erosion and Sediment Controls
M
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, materials, 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 erosion control measures. For
instance, erosion control measures, including 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, sediment control measures that trap eroded sediment include silt fences, sediment
ponds, and stabilized entrances should be considered.
Projects that disturb 1 acre or more of land
generally require coverage under an NPDES
construction general permit (CGP). Information
on EPA's 2017 CGP requirements, including links
to construction SWPPP resources, is available at
https://www.epa.gov/npdes/stormwater-
discharges-construction-activities
When selecting, designing, installing, and implementing
appropriate erosion and sediment control measures, you
should consult with your tribal, state, territorial, and local
authorities to ensure that you consider the appropriate
control measures. EPA's internet-based resources relating
to controlling
erosion and
sedimentation
include the sector-
specific Industrial
Figure 9. Slope drains to protect a Stormwater Fact
hillside from erosion. Sheet Series,
(https://www.epa.gov/npdes/industrial-stormwater-fact-
sheet-series), National Menu of Best Management Practices
(BMPs) for Stormwater
(https://www.epa.gov/npdes/national-menu-best-
management-practices-bmps-stormwater), and National
Management Measures to Control Nonpoint Source
Pollution from Urban Areas
(https://www.epa.gov/sites/production/files/2015-
09/documents/urban_guidance_0.pdf).
What to Include in Your SWPPP
Include the following;
A description of activities and processes for
stabilizing exposed soils to minimize
erosion; and
A description of flow velocity dissipation
devices placed at all discharge locations and
all structural and non-structural control
measures to prevent the discharge of
sediment.
If applicable, include a description of the type
and purpose of any polymers and/or chemical
treatments used to control erosion and the
location at your site where each control is
implemented.
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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4.F Management of Stormwater
Similar to erosion and sediment controls, the management of
stormwater 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, contain, or otherwise reduce
jc stormwater so as to
(J
£ 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 stormwater, inlet controls,
snow management, infiltration devices, and wet retention
measures.
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.
A description of locations at your site
where each control will be implemented.
Figure 10. Vegetated berm used to prevent
facility inundation when the river is at
flood stage.
As mentioned previously, a combination of preventive and
treatment control measures usually results in the most
effective approach to stormwater management for
minimizing the offsite discharge of pollutants in stormwater.
4.G Salt Storage Piles or Piles Containing Salt
Salt is commonly used for deicing and other commercial or industrial purposes. 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, containment). Piles do not need to be enclosed or covered if stormwater
from the piles is not discharged or if discharges from the piles are authorized under another NPDES
permit.
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.
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 offloading operations occur within contained
areas with appropriate measures in place to prevent the
track out of salt from the contained areas.
Section 4: Selecting Stormwater Control Measures (Step 3)
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Wluit to Include in Your SWPPP
Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
March 2021
Include the following:
A description of structures at your site that either cover or enclose
salt storage piles or piles containing salt, and any controls that
minimize, or prevent the discharge of stormwater from such 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.
Figure 11. Salt pile covered with a tarp.
4.H Employee Training
Stormwater training is required for all employees who work in areas where industrial activities or
material handling activities are exposed to stormwater, or who are responsible for implementing
activities necessary to meet the conditions the 2021 MSGP. These employees include inspectors,
maintenance personnel, and all members of your pollution prevention team. The training session
or sessions are expected to cover what is in the SWPPP;
spill response procedures, good housekeeping,
maintenance requirements, and material management
practices; the location of all the controls required by the
2021 MSGP and how they are to be maintained; the
proper procedures to follow with respect to pollution
prevention requirements; and when and how to conduct
inspections, record applicable findings, and take
corrective actions; and the facility's emergency
procedures, if applicable...
Figure 12. In addition to employee training,
labeling storm drains is a good measure to
educate employees.
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 stormwater
picks up pollutants from the ground or areas
exposed to precipitation.
Polluted stormwater can cause significant
water quality problems, such as fish kills and
drinking water contamination. Stormwater 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.
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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EPA recommends that training be conducted for any
applicable employees at least annually 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 participated. Keep the sign-
in/sign-out sheet with your SWPPP.
4.1 Non-Stormwater Discharges
In Section 3.A, this guide discussed the assessment of
authorized 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 unauthorized non-stormwater
discharges at your facility.
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 August, so employees are ready
for the upcoming wet weather season.
The stormwater topics covered during the
training session or sessions.
The sign-in/sign-out sheets from the training
session.
What to Include in Your SWPPP
Include the following:
A list of authorized non-stormwater
discharges that occur at your facility.
A description of unauthorized non-
stormwater discharges found at your site
and how they were eliminated.
Steps taken to ensure that other
unauthorized non-stormwater discharges do
not occur in the future.
Note: If this section is already addressed by your
documentation of non-stormwater discharges
(see Section 3.A), you can simply include a cross-
reference to that section of your SWPPP,
Figure 13. Unauthorized non-stormwater
discharge from an industrial facility.
4.J 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 generated from disturbed soil surfaces. Airborne particles pose a dual threat to
the environment and human health. Dust can be carried offsite, thereby increasing soil loss from
disturbed areas and increasing the likelihood of sedimentation and water pollution. Control
measures to minimize the generation of dust include:
Sprinkling/Irrigation. Moistening the ground surface with water is an effective dust control
method for haul roads and other traffic routes.
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Vegetative Cover. By establishing a vegetative 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 transfer 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 deterrent 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 adhesives include anionic asphalt
emulsion, latex emulsion, resin-water emulsions and
calcium chloride. Chemical palliatives 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 include on the SWPPP site map.
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.
4.K Numeric Effluent Limitations Based on Effluent Limitations
Guidelines
Some industrial activities identified in industrial stormwater permits also have Federal numeric
effluent limits (called effluent limitation 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 2.1.3 and 4.2.3.1 of EPA's 2021
MSGP) regarding 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 manufacturing 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
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
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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
Runoff from coal storage piles at steam electric generating facilities
Runoff containing urea from airfield pavement deicing at existing and new primary airports
with 1,000 or more annual non-propeller aircraft
departures
What to Include in Your SWPPP
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.
Include the following:
All numeric effluent limits the facility is
required to meet based on effluent limitations
guidelines.
A description of the control measures used to
meet the numeric effluent limits.
The location of each control measure at your
site.
4.L Additional Controls to Address Impaired Waters
Many general permits have additional requirements for discharges to impaired waters. "Impaired
waters" have been identified by a tribe, state, territory, or EPA as not meeting applicable state or
territory water quality standards pursuant to Section 303(d) of the Clean Water Act. This may
include both waters with approved or established Total Maximum Daily Loads (TMDLs), and those
for which a TMDL has not yet been approved or established.
Find impaired waters near your facility
Use EPA's Stormwater Discharge Mapping Tool
(available at https://www.epa.gov/npdes/epas-
stormwater-discharge-mapping-tools) 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 address. Second,
draw the facility or discharge points on the map
and "execute query" to determine your discharge
information, including surface waters to which
you discharge.
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 reduction goals
to bring the water body into compliance with water quality
standards. Facilities that are subject to NPDES permits
(i.e., "point sources"), such as facilities subject to EPA's
2021 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
particular 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 or
territory permit authority may require additional effluent limits, monitoring, or other restrictions
consistent with an applicable WLA, or you may be required to apply for an individual NPDES permit.
Should your facility discharge stormwater to an impaired water body without an EPA-approved or
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established TMDL, EPA or a state or territory permit authority may require additional monitoring
(for the 2021 MSGP, consistent with Section 4.2.5.1). Where you have been informed either in the
permit or directly by EPA or a state or territory permit authority that you are subject to any "water
quality-based" discharge requirement consistent with an applicable WLA, you are required to
document in your SWPPP the control measures used to meet that requirement and to describe the
location of such control measures.
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 2021 MSGP, see Part
2.2 for a more detailed discussion of water
quality-based effluent limitations and conditions
for discharging to impaired waters.
What to Include in Your SWPPP
Include the following:
A description of the control measures used
to meet the water quality-based effluent
limits.
The location of each control measure at your
site.
Sector-Specific Requirements
Most industrial stormwater general permits regulate
discharges of stormwater from a number of different
industrial sectors. For instance, EPA's 2021 MSGP
regulates discharges from 29 different industrial
sectors. These "sectors" consist of similar facilities
categorized by the nature of their industrial activity,
type of materials handled, and material management
practices employed. The sectors are structured to a
large extent on the definition of "stormwater
discharge associated 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.
What to Include in Your SWPPP
Include the following:
The industrial sector, or sectors, applicable
to the permitted site.
A description of the controls or procedures
that will be used to comply with applicable
sector-specific requirements, consistent with
Part 8 of the 2021 MSGP.
The location where each control and/or
procedure used to comply with the sector-
specific requirements will be implemented.
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
requirements. For example, Sector N of EPA's 2021 MSGP includes specific requirements for scrap
recycling and waste recycling facilities 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
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Refining sector (Sector C) does not have any sector-
specific discharge requirements in the 2021 MSGP.
Note that, if covered by the 2021 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, excluding your
primary industrial activity, located on-site that are also
required to be covered by the 2021 MSGP or a state or
territory general permit. Statewide general permits may
have different requirements for specific industrial sectors.
SWPPP Tip!
Sector-specific requirements for the 2021
MSGP- All sector-specific requirements can be
found in Part 8 of the 2021 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 2021 MSGP.
These sector fact sheets can be found at
https://www.epa.gov/npdes/industrial-
stormwater-fact-sheet-series.
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Section 5: Schedules and Procedures
for Inspections and Monitoring (Step
4)
The next step in developing your SWPPP is
to set out the schedules and 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)
EPA's 2021MSGP requires two types of
facility inspections.
1. Routine facility inspections (2021 MSGP, Part 3.1)
2. Quarterly visual assessment of stormwater
discharges (2021 MSGP, Part 3.2)
The 2021 MSGP also includes the requirements
for the following types of monitoring:
1. Indicator monitoring (2021 MSGP, Part 4.2.1)
2. Benchmark monitoring (2021MSGP, Part 4.2.2)
3. Annual effluent limitations guidelines monitoring
(2021 MSGP, Part 4.2.3)
4. State- territorial-, or tribal-specific monitoring
(2021 MSGP, Part 4.2.4)
5. Impaired waters monitoring (2021 MSGP, Part
4.2.5)
6. Other monitoring as required by EPA (2021 MSGP,
Part 4.2.6)
Monitoring procedures are described in Part 4.1 of the
2021 MSGP.
Some states and territories 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 inspections.
5.A Routine Facility Inspections
Your industrial stormwater permit will likely specify a
minimum frequency for conducting 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
conditions, which in many instances will require that
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, 2021 MSGP Part
3.1.5 identifies exceptions to routine visual
inspections for inactive or unstaffed sites.
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you inspect more frequently than the minimum
requirement. EPA also suggests conducting routine
inspections when measurable precipitation falls during
normal business hours. Observing site conditions during
storms provides you with real-time feedback on control
measures that are working and those that are not
working effectively.
Recommended Routine Facility Inspection
Sequence
What to Include in Your SWPPP
EPA's 2021 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 normal facility operating hours. You must
specify the relevant inspection schedules in your
SWPPP document as required in Part 6.2.5.2.
Although you are given the discretion to determine how
best to conduct your inspection, 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 stormwater, 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.
The 2021 MSGP requires that at least one of the
four quarterly inspections each year be
conducted when a stormwater discharge is
occurring.
1. Plan your inspection. Develop a consistent process tc
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, stormwater 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 contamination from an
accidental release of containerized chemicals. Similarly, solid materials with the potential to
contain pollutants (i.e., scrap material or wrecked vehicles) should include secondary
containment.
D
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 or
territory inspectors that control measures are being
maintained and replaced as needed.
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5.
Is equipment maintenance and fueling conducted
in appropriately contained areas? Are spill kits
present and full in areas where a liquid spill could
be expected?
Do the industrial processes occur in covered and
contained areas?
SWPPP Tip!
6. Where do you store waste material?
Note: If the waste material has the potential to
contaminate stormwater it must be stored in a
contained area or otherwise controlled. Be sure to
evaluate the facility "bone-yard" and scrap all
equipment that is out-of-date and not intended to
be reused.
7.
Is the finished product appropriately contained for
potential pollutant sources?
As you conduct your routine facility inspections,
keep in mind these visual indicators of poor control
measures or missing control measures:
1. Rainbow colored sheen on the surface of
stormwater indicates the presence of oil or
other hydrocarbons;
2. Brown or other dark colored streaks in flowing
stormwater indicates soil erosion or
uncontained sediment;
3. Stormwater flowing through straw waddles or
other stormwater containment barriers;
4. Foam;
5. Trash and other debris being carried off-site by
stormwater; and
6. Overflowing storm drains or detention ponds
could be indicative of a clog or poor inlet design.
9.
Following the internal evaluation, walk the
perimeter of your site and look for evidence of stormwater dischargesparticularly stains
from oil and grease or chemicals. Should you observe these, look at the discharge area and
consider additional control measures. You should specifically observe all stormwater
discharge points 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 industrial activities and potential pollutants.
10. Finally, where appropriate, repair or replace worn or ineffective control measures as soon
as possible but certainly before the next forecasted precipitation event.
Routine Facility Inspection Reports
Your routine facility inspections will need to be
recorded and documented. Generally, a
standard inspection report is taken into the
field and completed for each inspection. You
should include in your SWPPP a copy of the
standard inspection form you will use. An
example routine facility inspection form can be
found in the "Additional MSGP Documentation
Template" on EPA's website at
www.epa.gov/npdes/stormwater-discharges-
industrial-activities-epas-2021-msgp.
Figure 14. Example of a sheen indicating the
presence of oil or other hydrocarbons.
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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
all control measures identified in your SWPPP to
be current and to be effectively implemented at
your facility.
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 discharge points (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) and signature(s) of the inspector(s);
Weather information;
A description of any stormwater discharges occurring at the time of the inspection;
Any previously unidentified stormwater discharges from and/or pollutants at the facility;
Any evidence of, or the potential for, pollutants entering the stormwater drainage system;
Observations regarding the physical condition of and around all stormwater discharge points, including any flow
dissipation devices and evidence of pollutants in discharges and/or the receiving water;
Any stormwater control measures needing maintenance, repairs or replacement;
Any additional control measures needed to comply with the permit requirements; and
Any incidents of noncompliance.
Inspection reports also need to be signed by the inspector. Your inspection form should include a signature line for this.
Section 5: Schedules and Procedures for Inspections and Monitoring (Step 4)
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5.B Quarterly Visual Assessments of Stormwater Discharges
The second component of an effective stormwater inspection program is periodic visual
assessments of the stormwater discharging from your facility. Visual assessments are conducted
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
parameters. This requires that you collect a
stormwater sample in a clean, colorless jar and look at samples. EPA has developed an Industrial
the sample in a well-lit area. Generally, a sample must
be collected from each stormwater discharge point
associated 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 objectionable 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 or territory may require benchmark, effluent limit, or impaired water
monitoring depending on the facility SIC code or industrial sector. See Section 5.C for more
information on monitoring.
Stormwater Monitoring and Sampling Guide that
describes how to prepare for, conduct and
evaluate monitoring results. Individual states and
territories may also have their own guidance on
industrial stormwater monitoring.
Most industrial stormwater permits do not require visual assessment samples to be collected
consistent with 40 CFR Part 136 procedures (the Clean Water Act guidelines for establishing test
procedures for the analysis of pollutants); however, visual assessment samples should be
collected in such a manner that the samples are representative of the stormwater discharge.
EPA's 2021 MSGP includes specific requirements 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, colorless glass, or plastic container.
Examine the sample in a well-lit area or, if necessary, illuminate with a strong flashlight.
Collect the samples from discharges that happen at least 72 hours (three days) from the
previous discharge event.
Visual Assessment Documentation
Similar to the inspection reports for the routine facility inspections, you must document 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
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assessment report can be found in the "Additional MSGP Documentation Template" on EPA's
website at www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-2021-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 2021 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
Settled solids pollution)
4. The number and locations of discharge points scheduled for visual assessments. List the discharge
points 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, colorless 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 discharge points, rain gear, etc.). Describe any
necessary safety considerations for staff while collecting the samples (for example, if they are
sampling at a discharge point with high flows, or sampling in a manhole).
6. Reporting procedures: Describe your reporting procedures and include a blank copy of the
assessment form that will be used during the visual assessments. Most industrial stormwater
general permits require that visual assessment reports include the following:
Sample location(s);
Sample collection date and time, and visual assessment date and time for each sample;
The names of individuals, and titles or job positions, collecting the sample and conducting
visual assessment, and their signatures;
Nature of the discharge (i.e., stormwater from rain or snow);
Results of observations of the stormwater discharge;
Probable sources of any observed stormwater contamination; and
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.
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Digital photos of the samples are recommended, but not required, to document the condition of
the sample and future reference. Check your state or territory permit to see if photos are
required for documentation.
5.C Monitoring Procedures
Your industrial stormwater general permit may include requirements to conduct stormwater
discharge monitoring. The type of monitoring 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 indicator monitoring, benchmark monitoring, effluent limitation guideline monitoring, or
impaired water 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
https://www.epa.gov/npdes/industrial-stormwater-guidance) that will support this guide. The
Industrial Stormwater Monitoring and Sampling Guide provides a more detailed description of
monitoring 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
stormwater discharge points, not at locations within your facility. Some stormwater general
permits allow you to sample at only one discharge point when multiple discharge points at your
facility have similar industrial activities, control measures, exposed materials, and runoff
coefficients. Discharge points that have these similar characteristics are called "substantially
identical discharge points" (SIDP). See your industrial stormwater general permit for more
information.
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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 discharge points at your facility. In your SWPPP, identify at which
discharge points you will be required to monitor. If you are allowed to sample one of the discharge
points that are "substantially identical", and you plan on using a representative discharge point,
include the following documentation in your SWPPP:
Location of each substantially identical discharge point (SIDP);
Description of the general industrial activities conducted in the drainage area of each SIDP;
Description of the control measures implemented in the drainage area of each SIDP;
Description of the exposed materials located in the drainage area of each SIDP that are likely
to be significant contributors of pollutants via stormwater discharges;
An estimate of the runoff coefficient of the drainage areas (low = under 40%; medium = 40
to 65%; high = above 65%); and
Why the discharge points 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 2021
MSGP, EPA requires monitoring during a storm event that results in an actual discharge from your
site ("measurable storm event") that follows the preceding measurable storm event by at least 72
hours (three 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 discharge associated
with a measurable storm event. For indicator and benchmark monitoring composite samples may
be taken instead of grab samples.
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.
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Section 6: Completing Your SWPPP
Now that you have conducted a site assessment of your facility, developed maps, selected
control measures, and developed procedures for inspections and monitoring. You are almost
done with your SWPPP! The last step is to make sure all this information is organized into a
single document (your SWPPP) and to obtain NPDES permit coverage.
6.A Finish your SWPPP
The information you put together as part of Sections 3 through 5 make up the contents 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;
Sign and certify your SWPPP; and
Make your SWPPP publicly available.
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 2021 MSGP, the
SWPPP requirements are in Part 6. 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 authorized
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 2021 MSGP are found in Appendix B, Subsection 11 of EPA's 2021 MSGP.
Make Your SWPPP Publicly Available
Your current SWPPP (with the exception of any confidential business or restricted
information) must be made available to the public. You have three options to comply with
the public availability requirements for the SWPPP in the 2021 MSGP: attaching your SWPPP
to your NOI; providing a URL of your SWPPP in your NOI; or providing the following SWPPP
information in your NOI:
Onsite industrial activities exposed to stormwater, including potential spill and leak areas;
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Pollutants or pollutant constituents associated with each industrial activity exposed to
stormwater that could be discharged in stormwater and/or any authorized non-stormwater
discharges;
Stormwater control measures you employ to comply with the non-numeric technology-
based effluent limits and any other measures taken to comply with the water quality based
effluent limits; and
Schedule for good housekeeping and maintenance and schedule for all inspections.
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 permit
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 or territories where additional time is
granted.
Obtaining Coverage Under a General Permit
To obtain coverage under a state or territory industrial stormwater general permit, you will
typically need to fill out and submit a Notice of Intent or NOI. Submitting an NOI form to the
permitting authority indicates your certification that you have met the eligibility requirements
for coverage 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 or territory
has notified you accordingly. EPA's 2021 MSGP (see Part 1.3.3) uses a 30-day waiting period
following the receipt of a facility's complete NOI in EPA's NPDES eReporting Tool for the MSGP
(NeT-MSGP).
Read the application requirements in your general
permit for information on the procedures and the
specific form you will need to complete before
becoming authorized. Some states or territories
charge an administrative fee to apply for permit
coverage. Before submitting your application, 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 2021 MSGP requires that you keep with
your SWPPP the documentation supporting
your eligibility pertaining to Endangered
Species Act (ESA) Listed Species and Critical
Habitat Protection and National Historic
Preservation Act (NHPA) Protected Properties
described in the permit (see Part 6.2.6 of the
permit). State industrial stormwater permits
may have other documentation requirements.
Section 6: Completing Your SWPPP
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Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators
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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 procedure 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
corrective actions and/or additional implementation measures (AIM) responses, 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 stormwater pollution prevention team or new
responsible official.
An unauthorized release or discharge (e.g., spill, leak, or discharge of non-stormwater not
authorized by this or another NPDES permit) occurs at your facility.
A discharge violates a numeric effluent limit.
You become aware, or EPA determines, that your control measures are not stringent
enough for the discharge to meet applicable water quality standards;
An inspection or evaluation of your facility by an EPA official, or local, state, territorial, 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, operation, or maintenance at your facility significantly
changes the nature of pollutants discharged in stormwater from your facility, 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, triggering AIM and possible SWPPP modification.
Remember, revisions to the SWPPP to document corrective actions and or AIM responses
requires a new signed and dated certification statement by the responsible 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.
Section 6: Completing Your SWPPP
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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, territory, 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 2021 MSGP and many state or territory permits require you to keep records
of any activities at your site that are related to your compliance, such as conducting inspections,
visual assessments, stormwater discharge monitoring, corrective actions and AIM responses.
As you conduct inspections, assessments, monitoring, corrective actions and/or AIM responses ,
and other permit implementation 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
demonstrate your full compliance with the conditions of your permit.
Some examples of this additional documentation include:
Permit records - copies of the NOI 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 recurrence 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 measures,
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 facili
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 and/or AIM response records -
keep records of any corrective actions and/or AIM
responses and follow-up activities conducted to
demonstrate compliance with the permit.
ty
SWPPP Tip!
For 2021 MSGP permit holders, the list of
additional documentation requirements can be
found in Part 6.5 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-discharges-
industrial-activities-epas-2021-msgp to help
you organize this information.
Section 7: Keeping Records of Your Implementation Activities
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Section 8: Common Compliance
Problems at Industrial Facilities
The following are common problems found during inspections of industrial sites conducted by
EPA. These are provided to assist you in developing and maintaining an effective SWPPP. As a
general matter, it is not enough to simply have a completed SWPPP at your site. To establish
compliance with your permit's limits and conditions, 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.
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
Figure 15. Good housekeeping is a common
practice identified in SWPPPs. Poor sweeping
practices can contribute significant pollutants
in stormwater discharge.
Section 8: Common Compliance Problems at Industrial Facilities
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employee per shift is familiar with the stormwater
program and has access to the relevant files.
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 appropriately sealed and can leak oils
or other contaminants.
9. Poor employee/contract staff training. Employees
or contract staff are not familiar with your
stormwater management program. You are
responsible for educating 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 are required to be
trained as a part of the contract.
10. Inspection or monitoring records are not kept with
the SWPPP. Records of routine site inspections,
visual assessments, or monitoring results are not
available with the SWPPP for review. All records on
implementation of practices required in the permit
must be kept with the SWPPP (see Section 6.C for
more information).
Figure 16. Leaking dumpsters can introduce
pollutants into stormwater.
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 be 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. Additionally, you must
make your SWPPP publicly available by either
attaching it to your NOI, including a URL in your
NOI, or providing additional information from
your SWPPP on your NOi.
Section 8: Common Compliance Problems at Industrial Facilities
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Section 9: Resources
EPA's 2021 Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with
Industrial Activity, issued January 15, 2021 (available at
https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-2021-msgp)
EPA's 2021 MSGP Website - https://www.epa.gov/npdes/stormwater-discharges-industrial-
activities-epas-2021-msgp
EPA's Industrial Stormwater Fact Sheet Series - https://www.epa.gov/npdes/industrial-
stormwater-fact-sheet-series
EPA's National Management Measures to Control Nonpoint Source Pollution from Urban Areas -
https://www.epa.gov/sites/production/files/2015-09/documents/urban_guidance_0.pdf
EPA's National Menu of Best Management Practices (BMPs) for Stormwater -
https://www.epa.gov/npdes/national-menu-best-management-practices-bmps-stormwater
EPA's NPDES Stormwater Program Website - https://www.epa.gov/npdes/npdes-stormwater-
program
EPA's Stormwater Contact Us Website - https://www.epa.gov/npdes/contact-us-
stormwater#state
EPA's Stormwater Discharges from Industrial Activities Website -
https://www.epa.gov/npdes/stormwater-discharges-industrial-activities
EPA's Stormwater Discharge Mapping Tool - https://www.epa.gov/npdes/epas-stormwater-
discharge-mapping-tools
Industrial Stormwater State Resource Locator-
https://www.envcap.org/srl/resourcelocator.php?id=8
USGS'sThe National Map - https://apps.nationalmap.gov/viewer
Section 9: Resources
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EPA's 2021 MSGP Website and Stormwater Discharges from Industrial Activities Website have a
number of resources and tools to aid MSGP permittees, which include:
EPA's NPDES eReporting Tool for the MSGP (NeT-MSGP) - Allows permittees to submit new
Notices of Intent (NOIs) for coverage under the 2021 MSGP, make changes to existing NOIs,
submit annual reports, notices of termination (NOTs) and No Exposure Certifications (NECs).
EPA's Network Discharge Monitoring Report (NetDMR) - Allows permittees to electronically
prepare and submit DMRs.
Annual Report Form - Permittees that have been given a waiver by the EPA regional Office
to use a paper annual report in lieu of NeT-MSGP can use this form to report summaries of
their site inspections and corrective actions to EPA.
No Exposure Certification (NEC) Form - Permittees that have been given a waiver by the EPA
Regional Office to use a paper NEC form in lieu of NeT-MSGP can use this form to certify
that their industrial materials and operations are not exposed to stormwater.
List of Tier 3, Tier 2 and Tier 2.5 Waters - Lists waters currently designated by states or
tribes as Tier 3, Tier 2 or Tier 2.5 for antidegradation purposes under 40 CFR 131.12(a)to
help permittees complete their NOIs.
Discharge Monitoring Report (DMR) Form - Permittees that have been given a waiver by the
EPA Regional Office to use a paper DMR form in lieu of NetDMR can use this form to submit
monitoring data to EPA.
Industrial Stormwater Fact Sheet Series - These fact sheets summarize the types of facilities
included in each sector, the pollutants associated with the sector, and the types of
stormwater control measures generally used.
Developing your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators -
Provides guidance on how to develop a SWPPP that meets the requirements of EPA's 2021
MSGP.
Industrial SWPPP Template - Permittees can use this template to develop a SWPPP that is
consistent with the2021 MSGP.
Additional MSGP Documentation Template - Permittees can use this template to ensure
inspection, monitoring, and certification records, and corrective action and additional
implementation measures documentation are maintained with the SWPPP, as required in
the 2021 MSGP.
Industrial Stormwater Monitoring and Sampling Guide - This document provides guidance
on how to meet the monitoring and sampling requirements in EPA' 2021MSGP.
Approved or Established TMDLs - This page provides links to sources and program contacts
related to approved or established TMDLs for waterbodies located in jurisdictions covered
under the2021 MSGP.
NOI Search - These are searchable databases of NOIs for industrial facilities intending to
seek coverage under EPA's 2008 through 2021 MSGPs.
Section 9: Resources
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Appendix A: MSGP SWPPP Template
EPA has created a template to assist operators in developing an industrial SWPPP that addresses
the requirements in the 2021 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 https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-2021-msgp.
Appendix C: Example Site Map
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Appendix B: Additional MSGP
Documentation Template
EPA has created a template to assist 2021 MSGP permit holders in collecting the additional
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
Visual Assessment Documentation
Monitoring results
Deviations from visual assessment or monitoring schedule
Corrective action documentation
Benchmark threshold exceedances
Additional Implementation Measures (AIM) triggering events
AIM responses
SWPPP/Stormwater Control Measure changes unnecessary documentation
AIM exception documentation
Impaired waters monitoring: documentation of natural background sources or non-presence
of impairment pollutant after three years
Active/inactive status change
SWPPP Amendment Log
The Additional MSGP Documentation template can be downloaded in Microsoft Word format at
https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-2021-msgp.
Appendix B: Additional MSGP Documentation Template
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Appendix C: Example Site Map
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