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Best Practices of Stormwater Pollution Prevention Planning and the SWPPP

Posted on Mon, Nov 25, 2013

The purpose of a Stormwater Pollution Prevention Plan (SWPPP) is to identify potential stormwater pollution sources and guide facilities to reduce the potential for pollutants reaching nearby waterways.  Establishing procedures and controls is necessary to accomplish the following SWPPP objectives:

  1. Identify pollutants that may come in contact with stormwater.
  2. Establish measures to prevent pollutants from interacting with stormwater
  3. Establish controls to reduce or eliminate the potential for contaminated storm water being released to the environment.

The Environmental Protection Agency (EPA) defines control measures as “any Best Management Practice (BMP) or other method used to prevent or reduce the discharge of pollutants.” The SWPPP requires that companies identify and document which BMPs will be installed at the facilities. BMPs may include:

  • Schedules of implementation activities
  • Prohibited practices
  • Other management practices
  • Treatment requirements
  • Operating procedures
  • Practices to control industrial stormwater runoff, spillage or leaks, sludge, waste disposal or drainage from raw material storage.

Facilities are not required to have structural best management practices implemented prior to a permit application for permit coverage.  According to the requirements, a facility has one year from the time of submitting a permit application to implement structural best practices. However, the EPA recommends installing structural best management practices as soon as possible.

There are 3 main categories of BMPs. These include:

  • Non-structural BMPs: examples include, but are not limited to:
    • Optimize maintenance practices
    • Control spills and leaks
    • Manage wastes
    • Employee training programs
    • Optimize procedures and operations
  • Simple structural BMPs: examples include, but are not limited to:
    • Move significant materials and activities under cover
    • Store materials in weatherproof containers, shelters, or dumpsters
    • Use temporary shelters, like tarps, on a short-term basis only until permanent structures can be installed
  • Complex structural BMPs: examples include, but are not limited to:
    • Cover materials or operations with canopy or awning type structures
    • Provide curb or slopes designed to prevent stormwater run-on or runoff
    • Create stormwater ponds, sedimentary or wetland treatment systems

The following questions can assist in the evaluation of potential BMPs and implementation:

  • Are the BMPs appropriate for my facility size/industrial activity/significant material?
  • Are the BMPs the most cost effective to install?
  • Is there another BMP that is simpler/more cost-effective that achieves SWPPP goals?
  • Does the BMP require maintenance and is there adequate staffing for required activities?
  • Can BMPs prevent precipitation from coming in contact with operations and/or significant material?
  • Does the facility meet the criteria for ”No Exposure Exclusion”?

The content of the SWPPP will vary depending on site-specific conditions. According to The State of Washington’s Department of Ecology, the following BMPs common in SWPPPs:

Covered Storage:  Chemicals stored outside should be covered so that rainfall does not become contaminated by contact with the chemical containers. The SWPPP should include this as a standard practice at the facility and a map should identify the covered storage areas.

Equipment Maintenance:  The SWPPP should identify equipment that can spill or leak contaminants, such as petroleum products. Provide an inspection and maintenance schedule for each piece of equipment that is identified.

Employee Training:  The first line of defense will often be an onsite employee. With proper training, facility personnel can properly manage stormwater and protect it from contamination.

Site Maintenance:  Grading the site to provide even infiltration of rain and eliminating site debris will minimize contamination of stormwater.

Infiltration:  Infiltration of all or part of the stormwater is preferred. A grassy swale, infiltration trench, or a constructed wetland may provide adequate infiltration for all or most stormwater events. However, when stormwater has become contaminated with pollutants such as oil and grease, treatment may be required before infiltration.

Detention Pond:  At sites that discharge stormwater to surface water, a detention pond will typically be required to control turbidity. Careful attention to pond dimensions and design is necessary to accommodate major storms and provide adequate settling.

 

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Tags: NPDES, EHS, Regulatory Compliance, Flood Preparedness, Chemical Industry

Proposed Changes to the NPDES General Permitting Requirements

Posted on Mon, Nov 04, 2013

On September 27, 2013, the U.S Environmental Protection Agency (EPA) requested public comments regarding proposed changes in the 2013 National Pollutant Discharge Elimination System (NPDES) general permit for storm water discharges from industrial activity.  Once finalized, the new permit will replace the 2008 document, which was issued for a five-year term on September 29, 2008.

According to the EPA, the NPDES general permit, also referred to as the Multi-Sector General Permit (MSGP), covers multiple facilities with common discharges within a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit. The EPA issues these permits for storm water discharges associated with industrial activity, under the NPDES program (as defined in 40 CFR 122.21 and 40 CFR 122.26).

Four states (Idaho, Massachusetts, New Hampshire and New Mexico), Indian lands, and several territories do not have their own federally approved storm water permitting programs.  Within these areas, entities that are subject to industrial storm water discharge regulations are required to apply to the EPA to obtain coverage under the MSGP. Due to the delay to allow for comments, the 2008 MSGP has been administratively continued in accordance with 40 CFR 122.6, and will remain in effect until the new draft permit is finalized. EPA estimates that the new MSGP will be reissued in the spring of 2014.

The MSGP covers 29 different industrial sectors with specific and varying compliance requirements. As written, the draft MSGP includes several new or modified requirements from the 2008 MSGP. The EPA proposes the following:

  • The EPA will perform Environmental Assessments (EA) for dischargers subject to any New Source Performance Standards (NSPS). The EA will consider the potential environmental impacts from the discharge of pollutants in storm water discharges from new sources associated with industrial facilities, where EPA is the permitting authority, to determine whether to prepare an Environmental Impact Statement (EIS).
  • The EPA will require electronic submission of numerous reporting documents including each notice of intent, notice of termination, discharge monitoring reports, annual reports, and all monitoring data, unless a waiver is granted. Waivers would be granted for a one-time use for single information submittal.
  • The EPA will prohibit the discharge of pavement wash waters directly to any surface water or storm drain inlet, unless the facility has implemented control measures or subjected the wastewater runoff to dry clean-up techniques prior to discharge.
  • The EPA will require that each permit holder make a copy of its Storm water Pollution Prevention Plan (SWPPP) publicly available, either by identifying a URL link on the notice of intent (“NOI”) that is filed with EPA to apply for the permit, and then posting the SWPPP on the internet, or by providing storm water management information in the NOI itself. The information required includes a detailed description of:
    • The onsite industrial activities exposed to storm water, including potential spill and leak areas
    • The pollutants associated with each industrial activity exposed to storm water and/or authorized non-storm water
    • The control measures employed to comply with the non-numeric technology-based effluent limits
    • Additional measures taken to comply with requirements in Part 2.2
    • The good housekeeping, maintenance, and inspections schedules
  • The proposed permit clarifies effluent limits to include a greater level of specificity in order to make the requirements more clearly articulated, transparent, and enforceable. These clarifications include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response procedures, and employee training.
  • The proposed permit modifies specificity of corrective actions, including the necessary actions to be implemented prior to deadlines. The draft permit would require that corrective action steps be taken immediately (i.e., on the same day the condition was found) in order to ensure that pollutant discharges are minimized and that a permanent solution is implemented expeditiously. The draft MSGP also requires that subsequent action must be taken to install a new or modified control and make operational, or complete the repair, before the next storm event if possible, and within 14 calendar days from the discovery of the condition.
  • The EPA will require that all annual reports submitted under the new MSGP include a summary of the routine inspections and assessments conducted at the facility throughout the previous year.
  • The proposed permit clarifies that one is considered a discharger to impaired water if the discharge flows directly to the water, including if the discharge enters a storm water collection system that discharges to impaired water.
  • The EPA proposal clarifies language associated with the conduct of corrective actions. These actions are currently required under a limited set of circumstances.  The proposed permit expands the conditions under which corrective actions will be required and imposes specific deadlines for completing these actions, including immediate actions on the day of discovery to address conditions that require corrective action.

Those subject to the 2008 MSGP should carefully review the proposed requirements, as well as the sector-specific requirements that apply to their industry to ensure comprehension of the changes. Formal comments on the proposed draft will be accepted through November 26, 2013.

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Tags: NPDES, SWPPP, EPA, Regulatory Compliance, Facility Management, Flood Preparedness