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Importance of Storm water pollution prevention team in developing a SWPPP

The Storm water pollution prevention plan (SWPPP) is intended to be a “living” document, updated as necessary, such that when industrial activities or storm water control practices are modified or replaced, the SWPPP is similarly revised to reflect these changes.

A typical SWPPP includes the following elements:

• Storm water pollution prevention team;

• Site description;

•Summary of potential pollutant sources;

• Description of control measures;

• Schedules and procedures;

• Documentation to support eligibility considerations under other federal laws; and

•Certification of the SWPPP.

The process of developing a Storm water pollution prevention plan (SWPPP) involves the following four steps:

• Step 1: Formation of a 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 storm water pollution sources;

• Step 3: Selection of appropriate control measures that minimize the discharge of pollutants during storm events for each of these sources; and

• Step 4: Development of procedures for conducting required inspection/monitoring activities, as well as regular maintenance of control measures.

You are required to develop your Storm water pollution prevention plan (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

The first step in developing the Storm water pollution prevention plan is to identify the storm water pollution prevention team. The storm water pollution prevention team is responsible for assisting the facility manager in developing the changes made to the control measures.

Since industrial facilities differ in size and facility’s SWPPP as well as implementing and maintaining storm water control measures, taking corrective action where necessary to address permit violations or to improve the performance of control measures, and modifying the SWPPP to reflect complexity, the number of team members will also vary. The storm water 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 storm water from the facility.

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A key member of the storm water 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 or State inspector visits the facility, this person will be the main point of contact for the Storm water pollution prevention plan (SWPPP). Quest Consultants provides professional engineering services relating to SWPPP. It also provides SWPPP training to its clients so that they can develop and implement effective SWPPP plan. To know more information, visit our www.questepa.com.

Importance of a Spill Prevention, Control and Countermeasures (SPCC) plan

A facility that meets the criteria described above must comply with the SPCC rule by preventing oil spills and developing and implementing an SPCC Plan.

Benefits of implementing an SPCC Plan include:

• The SPCC regulations reduce the likelihood and severity of oil leaks and spills.

• By preparing and implementing a plan, the facility assures it has installed effective spill prevention equipment/secondary containment, established emergency response plans, and provides employee training to prevent and/or respond to oil spills.

• These proactive activities will reduce emergency response and environmental liability costs associated with spills. Likewise, reduced fire risks and worker exposure can be realized.

You can determine whether your facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines by considering the geography and location of your facility relative to nearby navigable waters (such as streams, creeks and other waterways). Additionally, you should determine if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams.

Estimate the volume of oil that could be spilled in an incident and how that oil might drain or flow from your facility and the soil conditions or geographic features that might affect the flow toward waterways. Also you may want to consider whether precipitation runoff could transport oil into navigable waters or adjoining shorelines. You may not take into account manmade features, such as dikes, equipment, or 4 other structures that might prevent, contain, hinder, or restrain the flow of oil. Assume these manmade features are not present when making your determination. If you consider the applicable factors described above and determine a spill can reasonably flow to a waterway, then you must comply with the SPCC rule.

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Owners or operators of regulated facilities must properly instruct their oil handling personnel in the operation and maintenance of equipment to prevent the discharge of oil.  Under the rules adopted by EPA described in 67 FR 47042, SPCC training is not required for employees that do not handle oil. As described in 67 FR 47042, owners or operators must conduct annual spill prevention briefings for their operating personnel to ensure adequate understanding of the SPCC Plan for that facility. The briefings must highlight and describe known discharges, failures, or malfunctioning equipment that occurred within the last year at the facility, and recently developed precautionary measures. To know more insights about Spill Prevention, Control and Countermeasures (SPCC), visit our www.questepa.com.

Stormwater pollution prevention plan (SWPPP) need to be reviewed and updated on a regular basis

Your Storm water pollution prevention plan (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.

Below are some examples of events that, if they result in a change in control measures or procedures, will require prompt revision of the Storm water pollution prevention plan to reflect the new facility conditions.

• A change in the composition of the storm water pollution prevention team or new responsible official.

• An unauthorized release or discharge (e.g., spill, leak, or discharge of non-storm water not authorized by this or another NPDES permit) occurs at your facility.

• A discharge violates a numeric effluent limit.

• You become aware, or EPA determines, that your control measures are not stringent enough for the discharge to meet applicable water quality standards;

• An inspection or evaluation of your facility by an EPA official, or local, State, or Tribal entity, determines that modifications to the control measures are necessary to meet the non-numeric effluent limits in this permit.

• Construction or a change in design, operation, or maintenance at your facility significantly changes the nature of pollutants discharged in storm water 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 a review of control measures and possible SWPPP modification.

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Revisions to the Storm water pollution prevention plan (SWPPP) to document corrective actions 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. In the interim between the annual inspection and completed SWPPP revision, keep a copy of the original Storm water pollution prevention plan (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. Visit our http://www.questepa.comfor more information relating to Storm water pollution prevention plan (SWPPP).

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