STORMWATER POLLUTION PREVENTION PLANS(SWPPP)
When construction companies begin a project, they need to promise to reveal potential sources of stormwater pollution on the site by signing a document known as stormwater pollution prevention plan.
This document is necessary especially if the construction company seeks to obtain a National Pollutant Discharge Elimination System (NPDES) permit. In this article, we will highlight the contents and use of a stormwater pollution prevention plan.
What is SWPPP?
A Stormwater Pollution Prevention Plan (SWPPP) is a written document signed by a construction company executive for a particular construction site, identifying every activity, condition and source that could lead to stormwater pollution and outlining the steps called Best Management Practices (BMPs) the company would take to prevent any pollution from water discharged from the site.
Who Needs a SWPPP?
Any construction site or facility that seeks to obtain a National Pollutant Discharge Elimination System (NPDES) permit must first sign a stormwater pollution prevention plan before the permit can be given.
Also, every facility or site whose pollutants are directly discharged into a Water of the United States (WOTUS) must obtain a NPDES. It is prohibited by the Clean Water Act of 1972 to discharge pollutants into any navigable waterways in the absence of an NPDES permit.
The National Pollutant Discharge Elimination System (NPDES) permit has strict specifications on the type of pollutants that can be discharged into the waterways, how to keep track of pollutants discharged, how to report discharges, and how to preserve the water quality from being contaminated by the discharges.
How To Obtain a SWPPP
To get a NPDES permit, a facility first submits a Notice of Intent (NOI). In this NOI will contain the exact type of pollutants the facility or site will discharge in the course of construction and also the specific names of waters that will be receiving the discharges.
After this notice is given, facilities then proceed to submit a SWPPP. This is to help in the regulation and preservation of waterways by the Environmental Protection Agency (EPA) by monitoring facilities that discharge polluted water.
Where a SWPPP is not needed
Where a facility discharges pollutants that enter a local sewer system, no NPDES permit and consequently no SWPPP is required. However, this does not imply that the facility can just go ahead to discharge polluted water into a local or municipal sewer system without properly obtaining permission from the local water authority.
This is because most municipalities and local water authorities have pre-treatment regulations and volume limits. Some authorities could regulate the type of pollutants discharged, while some require permits like stormwater permits or plans before discharges can be made.
Why is a SWPPP necessary?
It is necessary to sign a Stormwater pollution prevention plan so as to specifically note what constitutes a pollutant and what is prohibited, so as not to break any EPA regulations. Where any of such regulations are broken, the costs that would be incurred by the facilities in lawsuits could leave the company bankrupt.
What should a SWPPP contain?
The main aim of the SWPPP is preventive in nature: to avoid water pollution from facilities and their discharges. However, the plan doesn't just contain preventive measures but also actions that can be taken in the case where a pollution does occur.
The following must be contained in any SWPPP:
Site description
Best management practices
Pollution prevention team
Pollution stimulants
Spill prevention measures
Spill control plans
Inspection and monitoring procedures
Employee training provisions
SITE DESCRIPTION
The first thing contained in a SWPPP is the facility's name and address. The activities performed in the site should be described properly as well. To further aid the description of the site, a site map is required to show the geographical placement of the facility as well as its physical size.
Some features of a typical site map include:
Monitoring points for stormwater outflow previous spill areas potential stormwater pollution areas location of secondary containment structures
The direction of the stormwater away from the facility
The location of all receiving waters
Locations of all pipes, swales, drains, ditches, inlets, outfalls or other stormwater conveyances
Fueling stations, offloading areas, tanks, transfer areas, equipment storage and outdoor maintenace.
Sources of run-on from adjoining properties that could lead to pollution
BEST MANAGEMENT PRACTICES
All the applicable best management practices (BMPs) should be documented as well as timelines for all control and prevention measures that will be observed at the construction site or facility.
These practices include structural controls to divert or limit stormwater flows, permanent stormwater management controls and temporary stabilization measures such as mulching and seeding.
NAMES AND FUNCTIONS OF TEAM MEMBERS
There should be a team set up to monitor and track pollution on site. This is the pollution prevention team and their main task is to render assistance to the facility manager to develop and revise the SWPPP.
They are also responsible, in most cases, for seeing that the best management practices (BMPs) outlined in the SWPPP are duly followed. In the case of spills or actual pollution, they are responsible for taking corrective measures.
The names and functions or positons of each member of the team should be specified in the plan as well. Each member should be able to assess the SWPPP, and where necessary, the NPDES permit.
POLLUTION STIMULANTS
The SWPPP must track and identify all activities that could potentially result in spills, leaks or other pollution. Areas housing materials that have suffered much exposure to rain and snow melting should also be identified.
Any spill or pollution that has occured previously within the last three years should be listed.
SPILL PREVENTION MEASURES
A control measure should be outlined for every area or activity that could lead to pollution. These control measures should be clearly stated and explained. How excess pollutants will be stopped from being discharged should also be documented.
There are limits regulating the amount of stormwater pollutants that can be discharged. These limits are either technology- or water quality-based. Other control measures require basic routines such as promptly stopping small leaks and spills, prompt waste removal, keeping materials covered up.
SPILL CONTROL PLANS
Where all the prevention measures fail, it is necessary to have damage control plans. These should be properly detailed in the SWPPP. Copies of these control plans should be retained and made accessible to facility workers.
INSPECTION AND MONITORING PROCEDURES
Different types of pollutants require different levels of monitoring depending on the effluent limitations placed on such pollutants. Some need constant, continuous monitoring, while others need to be checked just one or two times a year.
Apart from the required monitoring checks, facility managers need to conduct inspections on the facility to ensure the control measures are being properly followed.
EMPLOYEE TRAINING PROCEDURES
Every worker on the facility/site should be trained on how to follow the measures to prevent stormwater pollution.
Updating a SWPPP
At any point in the process changes are made in plans and measures, they should be reflected in the SWPPP. Some of the updates that are likely to occur include changes in members of the pollution prevention team, changes in procedures or materials, movement of materials and tools.
Even where no change is made to the SWPPP, it should be properly reviewed whenever the NPDES is to due for renewal.