Developing a
Stormwater Pollution Prevention
Plan (SWPPP)
Introduction
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Information needed for developing a SWPPP
Step-by-step process for ensuring that pollutants
are not making their way into the stormwater
discharges from your site
Stormwater Locator
http://www.cicacenter.org/swrlnew.cfm
Getting Started
Must We Develop a SWPPP?
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Clean Water Act requires operators of “discharges
associated with industrial activity” obtain a NPDES
Most industrial stormwater discharges are covered
under general permits. In order to submit a SWPPP,
the following must occur in this order…
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Read general permit and determine eligibility for permit
coverage
Develop a SWPPP
Submit Notice of Intent (NOI)
What is Stormwater?
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Water from rain or snowmelt
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Does not immediately infiltrate into the ground
Flows over or through natural or man-made
storage or conveyance systems
Results in increased surface runoff
Picks up industrial pollutants
Discharges into nearby waterbodies or
stormwater sewer systems
Major Sources for Pollutants in
Stormwater
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Loading and Unloading Operations
Exposed Storage (outdoors or open to runoff)
Exposed Process Activities
Dust or Particulate Generating Processes
Illicit Connections and Non-Stormwater
Discharges
Waste Management
How to Implement a Stormwater
Pollution Prevention Plan
(SWPPP)
Elements of a SWPPP

A typical SWPPP includes the following
elements:
1.
2.
3.
4.
5.
6.
Stormwater Pollution Prevention Team
Site Assessment and Planning
Selecting Control Measures
Procedures for Inspections and Monitoring
Completing your SWPPP
Keeping Records of Your Implementation Activities
Element 1
Your Stormwater Pollution Prevention
(P2)Team
Your team should…
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Include those people most familiar with the
facility and its operations
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Define goals for the facility’s stormwater
management program
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Be responsible for implementing general
permit requirements and P2 requirements
Pollution
Prevention
Team
Element 2
The Site Assessment and Planning
Purpose
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The purpose of the site
assessment is to look at
your facility and determine
what materials and activities
are a source of
contamination to the
stormwater running off the
site
The Site Assessment
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Conduct an assessment of activities:
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Detailed walk through to create a site map
Identify locations where industrial materials or
material handling activities take place
Inventory of materials and pollutants
Locate areas with spill or leak potential
Identify non-stormwater discharges
Evaluation of the sampling data for the site
Site evaluation summary
The Site Description - Maps
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Include a general location map and also a site
map that indicates the following:
 Flow directions of runoff
 Storm drains / inlets
and outfalls (i.e.,
locations where
stormwater exits the
property, including
pipes, ditches, swales
and other conveyance
structures)
Site Map - Locations of Other Features
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Footprint of significant structures and impervious
surfaces
Nearby receiving waters (indicate their impairment
status)
Stormwater conveyances, BMPs & monitoring points
Exposed materials, significant spills & other potential
pollutant sources
Industrial activities (fueling stations, loading and
unloading areas, vehicle maintenance areas, waste
handling areas, processing & storage areas)
Sources of run-on from adjacent properties
containing significant quantities of pollutants
Pre-BMP
Site Map
Site Assessment – Material Inventory
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Identify and inventory industrial materials and activities
exposed to stormwater, and their associated potential
pollutants:
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raw materials
intermediate products, by-products, final products & waste
products
material handling equipment or activities
industrial machinery
industrial production and processes
pollutants such as crankcase oil, cleaning solvents, etc.
Provide description of materials management practices:
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treatment practices and structural / nonstructural control
measures
Material Inventory (cont’d)
The Site Assessment – Spills and Leaks
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Document where potential spills and leaks could occur and
the corresponding outfalls
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Document all leaks/ spills containing a hazardous substance
or oil in a reportable quantity for the past 3 years
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An Reportable Quantity (RQ) for oil is the amount of oil that
violates applicable water quality standards or causes a film /
sheen / discoloration of the water surface or shoreline, or
causes a sludge / emulsion beneath the water surface or on
adjoining shorelines
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For other substances RQ levels are expressed as pounds
released over any 24 hour period and are listed at 40 CFR
117.3 and 40 CFR 302.4
Significant Spills and Leaks
The Site Assessment
Non-Stormwater Discharges
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Identify all potential sources of non-stormwater discharges
Examples of allowable non-stormwater discharges:
 Discharges from fire-fighting activities
 Potable water, including water line flushings
 Routine external building washdown that does not use detergents
Examples of unauthorized non-stormwater discharges:
 Surfactant-laden washwater
 Sewage cross connection
Demonstrate & certify unauthorized discharges have been
eliminated
 Describe the evaluation method used and test results
 Indicate the location of the evaluation
 Provide the date of the test or evaluation
Non-Stormwater Discharge
Assessment
Site Assessment - Evaluate Sampling
Data
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Evaluate any stormwater data
sampling available from the past
5 years
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Identify or pinpoint any pollutants of
concern, hotspots, or control
measures that are not functioning
correctly.
Useful for selecting BMPs
The Site Assessment - Site Evaluation
Summary
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Becomes the foundation for the SWPPP.
Identify & locate on-site industrial materials and
activities.
Determine whether the materials and activities
may contaminate stormwater discharges.
Use the information to develop a plan to reduce
or eliminate discharge impacts to protect
receiving water quality.
Summary of Pollutant Sources
Element 3
Selecting Control Measures aka Best
Management Practices (BMPs)
BMP Selection & Plan Design
Provide a narrative description of the BMPs that
you have selected for the site
BMP Selection & Plan Design
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Minimize Exposure
Good Housekeeping
Maintenance
Spill Prevention and Response Procedures
Erosion and Sediment Controls
Management of Runoff
Salt Storage Piles or Piles Containing Salt
Sector-Specific Requirements
Employee Training
Non-Stormwater Discharges
Waste, Garbage, and Floatable Debris
Dust Generation and Vehicle Tracking of Industrial Materials
Numeric Effluent Limitations Based on Effluent Limit Guidelines
Additional Controls to Address Impaired Waters
BMP #1 – Minimize Exposure
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Minimize exposure of
manufacturing, processing,
material storage areas,
unloading areas, dumpsters
and other disposal areas.
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Move industrial materials
and activities inside or
protect them with storm
resistant coverings.
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Try to minimize the creation
of new impervious surfaces
BMP #2 - Good Housekeeping
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Involves maintaining a clean and orderly work
site so that pollutants don’t have a chance to
enter stormwater, such as...
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Improving operations and maintenance of
industrial machinery and processes
Implementing careful material storage practices
Scheduling routine cleanup operations
Maintaining up-to-date inventory control
BMP #3 - Preventive Maintenance
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Develop a program that ensures BMPs and
industrial equipment are kept in good condition to
prevent /minimize releases of pollutants:
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Regularly inspect and maintain equipment; include
schedules
Recommend keeping a maintenance log
Make equipment/BMP repairs before next rain event
Equipment (tanks, drums, hoses) should be checked for
signs of deterioration
BMP #4 - Spill Prevention & Response
Procedures
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Minimize the potential for leaks/spills that
may be exposed to stormwater
Label containers (e.g., “Used Oil”) that could
be susceptible to spillage
Implement barriers between material storage
and traffic areas, secondary containment
provisions, and procedures for material
storage and handling
Have procedures for expeditiously stopping,
containing, and cleaning up leaks/spills
Train employees
BMP #5 - Erosion and Sediment
Controls
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The SWPPP plan should identify activities that
present a potential for significant soil erosion
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Grading
Seeding
Mulching
Sodding
Sediment traps
Silt fences
Sediment ponds
Stabilized entrances
BMP #6 - Management of Runoff
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Management of runoff reduces pollutants that are
discharged from the site
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Employ structures, practices intended to divert, infiltrate,
reuse, or otherwise reduce stormwater runoff
Must be site-specific
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Vegetative swales
Berms
Collection and reuse of stormwater
Inlet controls
Snow management
Inflitration devices
Wet retention measures
BMP #7 - Salt Storage Piles or Piles
Containing Salt
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Cover and
isolate to ensure
pile does not
come into
contact with
stormwater
runoff
BMP #8 – Sector-Specific Requirements
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EPA’s 2008 MSGP
regulates discharges from
29 industrial sectors
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Review your general permit
to determine if there are
sector specific discharge
requirements
BMP #9 - Employee Training
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Training program
should include
topics such as spill
prevention, good
housekeeping,
recordkeeping,
material
management
practices, etc…
BMP #10 – Non-Stormwater
Discharges
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Unauthorized nonstormwater discharges
cannot be discharged from
your facility
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Specifically authorized by
a separate, individual
NPDES permit
BMP #11 - Waste, Garbage, and
Floatable Debris
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Stormwater must not carry
waste, garbage and debris
to receiving waters.
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Identify and implement
control measures to keep
exposed areas free of
such waste.
BMP #12 - Dust Generation and Vehicle
Tracking of Industrial Materials
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Minimize generation of dust and off-site tracking or
raw, final or waste materials
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Sprinklers/irrigation
Vegetative cover
Mulch, tillage, stone
Wind breaks
Spray on chemical soil
treatments
BMP #13 - Numeric Effluent Limitations
Based on Effluent Limit Guidelines
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Federal effluent limits are maximum
concentrations of a specific pollutant allowed
in a discharge
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Exceedance is a permit violation
BMP #13 (cont’d)
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Applies to runoff from:
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Spray down / intentional wetting of logs at wet deck
storage areas
Phosphate fertilizer manufacturing
Asphalt emulsion facilities
Cement manufacturing facilities
Mine dewatering discharges at crushed stone, construction
sand and gravel, or industrial sand mining facilities
Hazardous waste and non-hazardous waste landfills
Coal storage piles at steam electric generating facilities to
runoff from phosphate fertilizer, asphalt emulsion, material
storage piles, mine dewatering discharges, waste landfills,
and coal storage piles
Element 4
Procedures for Inspections and
Monitoring
Visual Inspections
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Regular visual inspections are a means to
ensure that all elements of the plan are in
place and working properly
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Designate qualified, trained plant personnel to
perform inspections
Track results, make changes and maintain
records of results
Records must reflect when, who and what was
found
Visual Inspections (cont’d)
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Perform visual inspections
(observation and recording of
results) quarterly
Must have an inspection schedule in
SWPPP
Annually, must perform visual
inspection when a stormwater
discharge is occurring
Must make necessary changes to
facility control measures as a result
of inspection
Visual Inspections (cont’d)
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Inspection date/time
Names and signatures of facility personnel
performing inspection
Weather conditions
Any previously unidentified discharges
Any control measures needing
maintenance or replacement
Visual Inspections (cont’d)
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Any incidence of non-compliance observed
Any additional control measures needed to comply
with permit
1st 30 minutes of a storm event that involves a
discharge (or as soon as practicable) visually
inspect stormwater sample in clear container at
each discharge point and look for:
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color, odor, clarity, floating solids, settled solids,
suspended solids, foam, oil sheen, other obvious
pollution
Area/Activity
Inspected?
Controls
Adequate
(appropria
te,
effective,
and
operating)
?
Corrective Action Needed and Notes
1
Material loading/unloading and
storage areas
Yes No  N/A
Yes No
Describe Corrective Actions
2
Equipment operations and
maintenance areas
Yes No  N/A
Yes No
Describe Corrective Actions
3
Fueling areas
Yes No  N/A
Yes No
Describe Corrective Actions
4
Outdoor vehicle and equipment
washing areas
Yes No  N/A
Yes No
Describe Corrective Actions
5
Waste handling and disposal
areas
Yes No  N/A
Yes No
Describe Corrective Actions
6
Erodible areas/construction
Yes No  N/A
Yes No
Describe Corrective Actions
7
Non-stormwater/ illicit
connections
Yes No  N/A
Yes No
Describe Corrective Actions
8
Salt storage piles or pile
containing salt
Yes No  N/A
Yes No
Describe Corrective Actions
9
Dust generation and vehicle
tracking
Yes No  N/A
Yes No
Describe Corrective Actions
10
(Other)
Yes No  N/A
Yes No
Describe Corrective Actions
11
(Other)
Yes No  N/A
Yes No
Describe Corrective Actions
12
(Other)
Yes No  N/A
Yes No
Describe Corrective Actions
Monitoring Data
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Controlled Samples sent to a certified laboratory
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Monthly
Quarterly
Annually
Submit reporting data to EPA within 30 days of laboratory results
Annual report to EPA Reporting
Additional reporting to EPA includes:
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spills, leaks,
releases of hazardous substances/oil
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oral report within 24 hours of noncompliance that endangers
health/environment
5 day follow-up report to the 24 hour oral report
any planned changes to your facility
anticipated non-compliance
Transfer of ownership
The need to correct information on the Notice of Intent
Required Monitoring
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Quarterly benchmark – parameters depends on
SIC code
Annual effluent limitations – parameters depends
on regulated activity
State or Tribal requirements – depends on facility
location
Annual impaired waterbody – depends on
impairment (s)
Additional monitoring required by EPA – if notified
by EPA
Reporting
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All monitoring date must be submitted to EPA
within 30 days of lab results
Additional reporting includes:
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Spills, leaks, releases of hazardous substances
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Oral report of non-compliance within 24-hours
5-day follow-up written report
Annual report on SW must be submitted (standard form
may be used)
Element 5
Completing your SWPPP
Completing your SWPPP
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Implement the
selected BMPs
Train all
employees to
carry out the
goals of the
plan
Plan Evaluation
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Annual site compliance evaluation
must include the following:
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Inspect stormwater drainage areas
Evaluate the effectiveness of
BMPs
Ensure proper operation of
structural measures (traps, ponds,
etc.)
Revise the plan, if needed, within
2 weeks
Prepare a report summarizing
inspection results
Sign the report and keep it with the
plan
Plan Evaluation (cont’d)
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Recordkeeping and internal
reporting
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Must maintain records of
spills, leaks, inspections and
maintenance activities
Plan revisions
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Major changes in a facility’s
design and/or operation will
necessitate changes in
SWPP plan
Endangered Species/Historic Places
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You must include
documentation that
supports endangered
species and historic place
requirements as identified
in the MSGP
Certification and Submission of
SWPPP
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Date and sign SWPPP
Include a copy of the Multi Sector General
Permit (MSGP) attached to your SWPPP
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The confirmation letter you receive from the
Notice of Intent (NOI) processing center is not
sufficient
Modification of SWPPP
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Modify SWPPP whenever
necessary to address any
changing or additional
conditions
SWPPP on the Internet
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For first time MSGP applications
(i.e., new dischargers, new
sources, other eligible
dischargers), you must post
your SWPPP on the internet
By posting on internet the
discharge authorization date
granted from EPA could be 30
days instead of 60 days
Element 6
Keeping Records of Your
Implementation Activities
Keeping Records
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Document compliance
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Conduct inspections
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Within requirements of your permit
Keep records of activities
Keep records of corrective actions
Ensure reliable reports kept on-site with
your SWPPP
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Accessible, complete, up-to-date
Additional Documentation
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Permit records
Spill records
Employee training records
Maintenance records
Inspection records
Monitoring records
Corrective action records
Questions?