SWP3 Requirements - the Oklahoma Department of Environmental

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Stormwater Pollution Prevention
Plan (SWP3) Requirements
Joe Willingham, P.E.
Professional Engineer III
Industrial Wastewater Enforcement Section
Water Quality Division
Department of Environmental Quality
Outline
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General issues
Who needs to sign them
When do they need to be submitted to DEQ
What needs to be in them
How often do they need to be updated
General Issues
 Requirements listed in Part 4 of OKR10
 Must be prepared prior to submission of NOI
 Should be prepared in accordance with good
engineering practices
 Licensed PE only required for those parts of SWP3
involving the practice of engineering
General Issues
 Address requirements for support activities
 Listed in Addendum G of OKR10
 Include information on listed or endangered species
found in proximity to site
General Issues
 For sites discharging to receiving waters impaired for
sediment
 Document best management practices (BMPs) used to
control pollutants of concern
 For sites discharging to receiving water with approved
Total Maximum Daily Load (TMDL) or watershed plan
 Document how SWP3 is consistent with it
Making SWP3s Available
 Should be retained on-site or
available upon request
 Post sign with:
 OPDES permit number or copy of NOI
 Name and phone number of contact
person
 Brief description of project
 Location of SWP3 if site is inactive or
lacks on-site location
Signatory Requirements
 Listed in Part 6.7
 NOIs or NOTs
 Signed by responsible corporate official, general partner
or proprietor, principal executive officer or ranking
elected officer
 Reports or other information requested by DEQ
 Signed by officials above or duly authorized
representative
Signatory Requirements
 Authorized representative
 Must be made in writing and signed by responsible
official
 Can be named individual or any individual occupying a
named position
 Certification statement in Part 6.7.4 must be included
on any signed documents.
Certification Statement
Submitting SWP3s to DEQ
 Only submit SWP3 to DEQ if the project is located:
 Within Outstanding Resource Waters
 Within a Federal and State Aquatic Resource of Concern
(ARC)
 Within a larger site which is disturbing land of 40 or
more acres
 Will be returned unreviewed if not in one of the
above areas
Where to Send NOI & SWP3
Department of Environmental Quality
Environmental Complaints and Local Services
Storm Water Unit
707 North Robinson, P.O. Box 1677
Oklahoma City, OK 73101-1677
FAX (405) 702-6226
Plan Contents
 Stormwater Team
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Responsible for SWP3 and permit compliance
Must be identified by name or position
Must include individual responsibilities
Must have access to permit, SWP3, and other
documentation
 Keep a copy of OKR10 and signed NOI with SWP3
Plan Contents
 Construction Activity Description
 Include size of property, total area to be disturbed,
support activities, and maximum area to be disturbed at
any one time
 Identify all other operators and their areas of control
 Describe intended construction sequence, including
 Installation of control measures
 Schedule of earth-disturbing activities
 Dates for stabilization of exposed soil
Plan Contents
 Site Map
 Must be legible
 Must include:
 Boundaries of property and locations of construction
activities
 Locations of waters of the state within 1 mile of site
 Boundary lines of any natural buffers
 Site topography, existing vegetative cover, and drainage
patterns
Plan Contents
 Site Map (cont’d)
 Must include:
 Stormwater and allowable non-stormwater discharge
locations
 Locations of potential pollutant-generating activities
 Locations of stormwater control measures
 Sampling locations for asphalt batch plants, if applicable
Plan Contents
 Construction Site Pollutants
 Identify pollutants expected at site
 Examples: sediment, paint, solvents, fuels, trash, etc.
 Describe activities generating listed pollutants
 Examples: paving operations, concrete washout,
paint/stucco washout, solid waste disposal, dewatering
 Account for areas where spills or leaks could occur
 Document changes from manufacturer’s specifications
for fertilizer applications
Plan Contents
 Endangered Species/Historic Preservation/Water
Quality Impaired Waters
 Document any effect stormwater discharges or
stormwater discharge-related activities may have
 Describe and implement measures to protect
endangered species or threatened habitat or meet
TMDL/watershed plan requirements
 Describe how BMPs would reduce and avoid pollutant
of concern into any impaired waters
Plan Contents
 Controls to Reduce Pollutants
 Includes structural and non-structural
 Structural examples: silt fence, sediment traps, check
dams, etc
 Non-structural examples: good housekeeping practices,
training, etc.
 Describe control measures and timing for each major
activity
Plan Contents
 Stormwater Control Measures
 Potential resource: National Stormwater BMP Menu
 http://cfpub.epa.gov/npdes/stormwater/menuofbmps
 Minimum requirements:
 Straw or hay bales as BMPs are NOT allowed
 Designed to retain sediment on site
 Must be properly selected, installed, and maintained
 Follow manufacturer’s specifications and good engineering
practices
 If it is installed, maintain it or remove it
Stormwater Control Measures
 Minimum requirements:
 Remove off-site accumulations of sediment
to minimize offsite impact
 Remove sediment from sediment traps or
ponds when design capacity has been
reduced by 50%
 Prevent litter, construction debris, and
chemicals from becoming a pollutant source
 Address offsite material storage areas used
solely by permitted project
Stormwater Control Measures
 Stabilization practices
 Describe vegetative/non-vegetative stabilization
practices used for temporary or final stabilization
 Temporary stabilization - provided during establishment
and growth of vegetation and/or when earth-disturbing
activities will occur again in future
 Final stabilization - provides permanent cover and meets
termination requirements
 Soil disturbing activities are complete AND
 70% of native background cover established OR
 Equivalent permanent stabilization measures installed
Stabilization Practices
Stormwater Control Measures
 Structural Practices
 Include description
 Sediment basin requirements
 Required in areas where ≥10 disturbed acres drain to a
common location
 Must store runoff from a 2 year, 24 hour storm from each
disturbed acre OR
 Must provide 3,600 ft3 of storage per acre drained
 Use velocity dissipation devices at discharge locations and
along outfall channel
Velocity Dissipation
Plan Contents
 Pollution Prevention
 Spill prevention and response
 Include procedures to prevent and
respond to spills and leaks
 Identify name/position of employee
responsible for spill or leak detection
and response
 List contact information for facility
personnel, emergency response
agencies, and regulatory agencies OR
reference SPCC plan for site
Plan Contents
 Pollution Prevention
 Waste management
 Include procedures on handling and disposal of wastes
including:
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Sediment
Construction waste
Hazardous waste
Demolition/clearing debris
Sanitary waste
Plan Contents
 Monitoring
 For discharges subject to numeric limitations (i.e.
asphalt batch plants)
 Identify
 Locations where samples will be collected
 Linear projects – can identify substantially identical outfalls
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Responsible personnel
Normal working hours for project
Equipment to be used
Sample collection procedures
Plan Contents
 Maintenance
 BMPs identified in SWP3 must be maintained
 Conduct maintenance before next anticipated storm
event or as necessary to maintain effectiveness
 Adding or modifying BMPs must be completed prior to
next storm event
 If impracticable, document situation in SWP3, AND
 Complete as soon as possible after event
Maintenance
Plan Contents
 Inspections
 Identify “qualified person”
 Identify frequency
 Minimum = once every 14 days and within 24 hours of 0.5
inch rain event or discharge from snowmelt
 Include inspection form in SWP3
 Complete reports within 24 hours of inspection
 Keep completed reports onsite with SWP3
 Must be signed
Note Certification Statement
Plan Contents
 Training Requirements
 Ensure personnel understand permit requirements prior
to beginning work
 Minimum topics to cover:
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Location of stormwater controls
Maintenance procedures for stormwater controls
Pollution prevention requirements
Inspection and documentation procedures
 Only required for personnel responsible for inspections
Training Log
 Example from EPA’s
SWP3 template
 Can create your own
 Must be kept with
SWP3
Plan Contents
 Corrective Actions
 Involve repair, modification, or replacement of stormwater
controls
 Include clean up and disposal of materials from spills or
releases
 May remedy a permit violation
 Deadlines for completion – 7 days from time of discovery
 Document and modify SWP3 as appropriate
Plan Contents
 Non-Stormwater Discharges
 Identify those that are combined with stormwater
discharges
 Identify pollution prevention measures
 Identify location(s) on site map
 Ensure measures are implemented to reduce and/or
eliminate such discharges
Allowable Non-Stormwater
Discharges
Source: EPA’s SWP3 Template
Plan Contents
 Contractor Certifications
 Used at discretion of permittee
 Not required
 Places the responsibility for complying with permit
requirements and your SWP3 with the contractor
 Requires contractors to abide by your NOI, SWP3, and
BMPs
 Include this information in SWP3
Examples
From EPA’s SWP3 Template
From Addendum D of OKR10
Keeping SWP3s Current
 Living document
 Make changes
 As conditions at the site change
 When site inspections indicate BMP is ineffective
Source: http://www.epa.gov/npdes/pubs/exampleswppp_residential.pdf
Resources
 EPA’s SWP3 Templates and Examples
 http://cfpub.epa.gov/npdes/stormwater/swppp.cfm
#report
 http://www.epa.gov/npdes/pubs/sw_swppp_guide.
pdf
 SWP3 Webcasts
 http://cfpub.epa.gov/npdes/courseinfo.cfm?progra
m_id=0&outreach_id=308&schedule_id=962
Questions, Comments, Discussion
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