Operators of industrial facilities must prepare and manage stormwater plans to comply with the conditions for holding a National Pollutant Discharge Elimination System (NPDES) stormwater permit.

The Four Steps to Preparing Stormwater Plans

NPDES permits are issued under the framework of the Federal Clean Water Act by a state government or by the EPA and are a regulatory necessity for many industrial operations. NPDES stormwater permits differ slightly in their requirements from state to state; however, the four key steps to preparing a compliant stormwater pollution prevention plan (SWPPP) are always likely to be as follows:

Step 1: Form a Pollution Prevention Team

Stormwater plans must include the names of a designated team of personnel, qualified to prepare the SWPPP and to implement practices for permit compliance. The team members must be identified by name or professional title and will be actively involved in putting stormwater plans together and maintaining pollution controls at the industrial facility.

Step 2: Assess Potential Sources of Pollution                                                                                                 

The next step is to identify, assess and evaluate potential sources of stormwater pollution at the site(s) to be covered by the NPDES permit. More specifically, the necessary activities include:

  • Identification and assessment of activities conducted at the facility
  • Review and evaluation of any existing sampling data for the facility
  • Drafting a site map identifying:
    • Where each industrial activity is performed
    • The sources of pollution
    • Control measures
    • The direction of stormwater flow

Step 3: Document All Stormwater Pollution Control Measures

Stormwater plans must include detailed descriptions of all physical controls, implemented best practices, and procedures for minimizing exposure of industrial activities to stormwater runoff.

Step 4: Describe Monitoring and Inspection Procedures

A stormwater permit will typically require the following three forms of monitoring and inspection to be documented and performed:

  1. Routine inspections of the facility (perhaps monthly or quarterly)
  2. Visual inspection of stormwater samples (during or immediately following discharge events) and as permitted, collection and analysis of stormwater samples for reporting parameters
  3. An annual comprehensive site inspection and performance evaluation

Each of these inspection types must be documented in the SWPPP in detail, with full descriptions of who will complete the tasks, planned inspection schedules, and detailed procedures for each inspection.

Drafting, Reviewing, and Updating Stormwater Plans

Once the four steps described above are complete, all the information must be compiled into one document, which constitutes the SWPPP. Going forward, plans must be reviewed on a regular basis and updated as changes occur in team membership, procedures, schedules, or anything else relevant to the plans and permit compliance.  Plans should be updated at least annually.

While this blog post has broken down the preparation of stormwater plans into four basic steps, the reality is that SWPPP preparation is no small task to complete. That’s why ATC is here to help your company prepare and manage compliant stormwater plans.

Contact us to find out more about how we can assist with your facility compliance needs.