Pollution Prevention Project Report #1
Title: Preparation and Implementation of Storm Water Pollution Prevention Plan
(SWPP) plan
P2 Intern: Jeffrey Luby
Box 72
Mirror Lake N.H.
03853
work (603) 755-4200 x2016
home (603) 569-2669
Facility: Textron Automotive Interiors
Rt. 11
Farmington N.H.
03835
Facility Contact: Dave Labbe
work (603) 755 - 4200 x2524
Facility Advisor: Richard Sherman work (603) 755 - 4200 x2530
Executive Summary:
A Storm Water Pollution Prevention Plan (SWPP) is the integral component of a Federal
Permit required by manufacturing facilities associated with industrial activity as part of
the National Pollution Discharge Elimination System (NPDES). Unless authorized by a
NPDES permit, discharges of storm water associated with industrial activity to waters of
the United States are unlawful. Textron Automotive Interiors (TAI), Farmington, N.H.
required such a SWPP plan to complete the requirements of a federal permit application
to the U.S. Environmental Protection Agency, Office of Wastewater Enforcement and
Compliance. My project as a Pollution Prevention Intern at TAI, was to compile the
necessary information required for the SWPP plan as outlined in federal regulation 40
CFR 122,123 &124. The plan requires a manufacturing facility such as TAI to identify
and address potential sources of storm water pollution on the site and develop Best
Management Practices (BMPs) that reduce or eliminate the risk of pollutants entering any
storm water conveyance which may discharge. Prevention planning for accidental spills
of hazardous materials is much more effective in reducing the risk of storm water
contamination and is far less expensive than responding to an accidental spill or release.
Furthermore, environmental degradation is an obvious outcome in the event of a spill.
The result is anger and a lack of trust in a companies commitment to the environment and
community.
Background:
In the past, the focus of water quality management was directed towards reducing
pollutants in discharges of industrial process water and municipal sewage. Studies have
shown that storm water runoff from urban and industrial areas typically contain
significant quantities of the same general types of pollutants, including heavy metals,
pesticides, herbicides and organic compounds. Efforts to improve water quality under the
National Pollution Discharge Elimination System has broadened the scope of the program
to include industrial and urban runoff plus runoff from landfills, mining and construction
operations as well as transportation facilities such as airports.
Under conditions of the NPDES permit specified in 40 CFR 122, 123 & 124, a facility
associated with industrial activity must obtain a permit to legally discharge storm water
into any surrounding watershed (U.S. waters). Conditions of the permit legally obligate a
designated facility to create and implement a Storm Water Pollution Prevention Plan
(SWPP). The plan must be prepared in accordance with proper engineering practices and
is intended to ensure that a industrial facility like TAI identify and address potential
sources of storm water pollution which may reasonably effect the quality of the effluent
discharge entering the surrounding watershed. TAI’s storm water effluent drains into the
Cocheco River watershed.
Part X of the Federal Register; Non Construction Permit Language, identifies facilities
that require storm water permits by listing Standard Industrial Classifications (SICs) and
activities associated with such classifications. TAI falls under category (xi) which differs
from the other categories listed in that it only addresses storm water discharges where
material handling equipment or activities, raw materials, intermediate products, final
products, waste materials, by-products, or industrial machinery are exposed to storm
water. In addition, the category is intended to include on site outside storage tanks.
My job was to locate and identify the aforementioned activities, form a narrative
description of such activities and develop Best Management Practices (BMPs) with a
pollution prevention approach using guidelines specified in the Federal Register (see
Appendix A for outline), Federal Regulation 40 CFR and a summary guidance provided
to me from the Environmental Protection Agency (EPA); Storm Water Management For
Industrial Activities.
Objectives:
- Locate and identify all potential sources of storm water pollution at TAI Farmington
facility.
- Develop a comprehensive SWPP plan which will include concise pollution prevention
methods and training.
- Ensure SWPP plan complies with the requirements of the federal permit.
- Provide BMPs and control measures to eliminate or minimize storm water pollution.
- Implement BMPs
Approach:
- Obtain and read federal regulations pertaining to storm water and any other suppotrting
information
- Locate problem areas and activities
- Identify hazardous materials
- Develop narrative description of areas or activities
- Trace migration in the event of a spill
- Compile information for site map as specified in Federal Register (see Appendix A)
- Provide Cad operator with site map information so an adequate site map could be
generated
- Obtain any and all resources to ensure compliance with federal regulations.
- Develop a strategy for each problem area in the event of a spill.
Work Accomplished:
I was able to compile all the necessary information into written form. The SWPP plan has
not been implemented. Currently TAI is content to have a written plan. New Federal
Regulation pertaining to storm water are due out any time. TAI is waiting for the new
regulation to be published before fully implementing the SWPP plan in the event
sweeping changes are written into the new regulation. The document is a living document
and will be updated responding to any changes made in any activities pertaining to the
plan.
Pollution Prevention Benefits:
Pollution prevention starts at the point source. The SWPP plan starts at the point source.
The SWPP plan requires that all areas and activities which have the potential to effect
storm water quality be identified and addressed so to assess the risk of a pollutant
entering U.S. waters via a storm water conveyance. The plan provides for the
development and implementation of BMPs coupled with pollution prevention training
utilizing a pollution prevention approach to further reduce the risk, and in some cases
eliminate the possibility of environmental degradation due to an accidental spill or
release.