Industrial Stormwater Pollution Prevention Plan Guide

 Industrial view from Great Salt Lake

Regulatory Background & Requirements

When it rains or snows, water flows over impervious and disturbed soil surfaces on industrial sites, creating stormwater runoff. This runoff picks up loose soils, debris, hazardous wastes, oils, and other pollutants and transports them to nearby waterbodies or storm sewer systems. Proper stormwater controls are critical for stopping these pollutants from entering communities, waterways, and the surrounding environment to protect Utah's water quality.

Stormwater runoff and wastewater discharges from industrial sources can contain high levels of pollutants that negatively impact the waterways the discharge enters. The National Pollutant Discharge Elimination System (NPDES) permitting program places limits and regulations on the discharge from each industrial facility and/or activity. Industrial facilities are typically required to obtain permits for stormwater discharges associated with industrial activities. These permits require the creation of a Stormwater Pollution Prevention Plan (SWPPP) for each facility covered under the permit. The SWPPP identifies potential sources of pollution that may impact stormwater quality. It also establishes a plan for the implementation of practices to reduce pollution impacts and compliance with the requirements of the permit.

The 11 categories of regulated industrial activities are (from “Developing Your SWPPP,” 2021):

  1. Facilities subject to federal stormwater effluent discharge standards (40 CFR Parts 405-471)
  2. Heavy manufacturing (e.g., paper mills, chemical plants, petroleum refineries, steel mills and foundries).
  3. Coal and mineral mining and oil and gas exploration and processing.
  4. Hazardous waste treatment, storage, and disposal facilities.
  5. Landfills, land application sites, and open dumps with industrial wastes.
  6. Metal scrap yards, salvage yards, automobile junkyards, and battery reclaimers.
  7. Steam electric power generating plants.
  8. Transportation facilities that have vehicle maintenance, equipment cleaning, or airport deicing operations.
  9. Treatment works treating domestic sewage with a design flow of 1 million gallons a day or more.
  10. Construction sites that disturb 5 acres or more (permitted separately).
  11. Light manufacturing (e.g., food processing, printing and publishing, electronic and other electrical equipment manufacturing, public warehousing and storage).

The Clean Water Act mandates that operators engaged in "discharges associated with industrial activity" must secure a NPDES permit under Section 402(p). The EPA regulations outlined in 40 CFR 122.26 identify the types of industrial activities necessitating NPDES permits and outline the application requirements. In cases where the EPA is not the designated permitting authority for stormwater from industrial facilities, it has delegated this responsibility to states or territories, empowering them to regulate stormwater discharges from such industrial activities (“Developing Your SWPPP,” 2021).

The EPA has developed a series of fact sheets for the 29 industrial sectors regulated by the Multi-Sector General Permit (MSGP). These fact sheets help identify typical pollutants from each sector and SCMs that can be used to minimize pollutant discharges.

Stormwater Permits

Stormwater permits aim to protect water quality by managing runoff from industrial activities, promoting sustainable practices, and minimizing the environmental impact of such operations. The Multi-Sector General Permit (MSGP) regulate stormwater discharges from various industrial activities.

Multi-Sector General Permit

Multi-Sector General Permits are broader in scope than the CGP and the CPP, addressing stormwater discharges associated with various industrial activities across multiple sectors. These permits outline specific requirements, monitoring procedures, and pollution prevention measures to control pollutants such as sediments, chemicals, and heavy metals. Permitted industrial activities include, but are not limited to:

  • Manufacturing Facilities - Operations involved in the production of goods, including facilities engaged in metal fabrication, chemical manufacturing, textiles, and other manufacturing processes.
  • Construction and Development - Certain construction activities, especially those with significant land disturbance, may fall under the MSGP requirements.
  • Transportation and Warehousing - Facilities involved in transportation, including trucking terminals, airports, and rail yards, may be covered by the MSGP.
  • Mining and Extractive Industries - Activities related to mining, quarrying, and the extraction of natural resources are often subject to stormwater permitting.
  • Fuel Storage and Distribution - Facilities storing or distributing fuels, such as gas stations and fuel storage depots, may fall under the permit requirements.
  • Food and Beverage Processing - Facilities involved in food processing and beverage production are often included in the industrial sectors covered by the MSGP.
  • Landfills and Waste Management - Operations related to waste management, including landfills and transfer stations, may need to obtain an MSGP.
  • Utilities - Facilities associated with utilities, such as power generation plants and water treatment facilities, may be subject to stormwater permitting.

Stormwater Pollution Prevention Plan

A Stormwater Pollution Prevention Plan (SWPPP) is a comprehensive document designed to identify potential sources of pollution at a site and outline measures to prevent or minimize the discharge of pollutants in stormwater runoff. A typical SWPPP includes the following elements:

  • Site Description
  • Regulatory Requirements
  • Site Map
  • Potential Pollutant Sources
  • Best Management Practices (BMPs)
  • Sediment and Erosion Control
  • Spill Prevention and Response
  • Emergency Response
  • Good Housekeeping Practices
  • Inspection and Monitoring
  • Employee Training
  • Recordkeeping
  • Documentation of Compliance

Site Description

A site description provides a concise overview of the industrial facility, offering essential details for effective stormwater management in the SWPPP. It serves as a reference to assess potential environmental impacts and implement BMPs, minimizing pollutant discharges. Included elements are project information, SWPPP operator details, historical information, site boundaries, adjacent land uses, sensitive areas, topography, hydrology, access points, utilities, vegetation, and cultural features.

Regulatory Requirements

Regulatory requirements are outlined in a SWPPP, specifying the applicable program (e.g., Clean Water Act, NPDES) and permit information (e.g., Multi-Sector General Permit). The SWPPP ensures compliance with federal, state, and local stormwater regulations, setting pollutant discharge limits and reporting obligations. It details inspection, monitoring, and corrective action procedures, emphasizing recordkeeping and employee training. Emergency response plans, notice of intent for permit coverage, and public notification requirements are also included.

Site Map

Site maps within a Stormwater Pollution Prevention Plan (SWPPP) offer visual representations of the industrial facility. These maps provide a clear layout, indicating the location of potential pollutant sources, stormwater control measures, and drainage patterns. A vital component of the SWPPP, site maps aid in effective stormwater management by enhancing the understanding of the site's spatial characteristics. They serve as valuable tools for assessing and implementing Best Management Practices (BMPs) to minimize pollutant discharges during industrial activities.

Potential Pollutant Sources

Areas within an industrial facility that could contribute to water pollution through stormwater runoff must be identified in a SWPPP. These sources encompass activities and materials that may generate pollutants, such as sediment, chemicals, or debris. In the SWPPP, a clear delineation of these potential sources is provided, allowing for targeted implementation of Best Management Practices (BMPs) to prevent or minimize pollutant discharges. By addressing and mitigating these sources, the SWPPP aims to protect water quality and ensure compliance with stormwater regulations during industrial operations.

Best Management Practices (BMPs)

Non-Structural Control Measures

Stormwater control measures (SCMs) are structural or non-structural practices used to prevent and/or reduce pollutant discharges in stormwater. Non-structural SCMs are practices that specifically focus on facility operations and procedures. Examples include employee trainings and signage to increase staff knowledge of BMPs. Appropriate non-structural control measures can be determined by identifying weaknesses on site that may allow stormwater contamination.

The following general stormwater management principles can help operators select and design the control measures that will be most effective for their site (EPA, 2021).

  • Pollution prevention - Focus on selecting controls that reduce pollutants at the source such as maintaining equipment, picking up and disposing of trash and debris, training staff and requiring appropriate spill procedures, and proper storage of materials.
  • Minimizing exposure - Prevent circumstances in which industrial materials and activities come in contact with stormwater. This can be done by storing materials in contained and/or covered areas, moving materials and activities to areas away from water, and transporting waste properly.
  • Know your site’s pollutant sources - Determine the type and quantity of pollutants. Use this information to select and design the best control measures to prevent contamination of stormwater.
  • Maximize infiltration - Find opportunities to decrease impervious surfaces. This will increase on-site infiltration, which reduces runoff flows, recharges groundwater, and improves base flow in nearby streams.
  • Combine control measures - Many control efforts are more effective when used in combination.
  • Use structural practices - If non-structural control measures are not preventing stormwater pollution, use structural practices such as swirl separators, sand filters, retention basins, etc.
Structural Controls

Structural SCMs generally include installing designed and structured BMPs to control stormwater and sediment discharges. Industrial permits usually require control measures for areas on site that may experience erosion. Both erosion (primary defense) and sediment (secondary defense) controls can be used for the most effective means of preventing stormwater pollution. Examples include sediment traps, vegetated buffers, mulching, grading, sediment ponds, and many more.

  • Use existing vegetated areas - These areas can be used to reduce stormwater flow velocity, reduce erosion, increase infiltration, and – with the appropriate plants – increase uptake of metals and nutrients.
  • Establish vegetated buffers - If vegetated areas do not exist, establish and maintain vegetated buffer zones between waterbodies and drainage systems on site or nearby.
How to do this at your site:

Spill Prevention and Response

According to the EPA (“Developing Your SWPP,” 2021), spills and leaks combine to create the largest source of stormwater pollution from industrial activities. Due to this, control measures are required at industrial sites.

Common spill prevention and response practices include:

  • Keep spill kits onsite where spills may occur for a rapid response.
  • Post contact information where all employees can access it.
  • Notify appropriate personnel when a leak or spill occurs.
  • Use dry methods, such as absorbents, to clean up spills.
  • Use drip pans and absorbents where leaky equipment is stored.
  • Label containers that may spill or leak with proper handling and spill response information.
  • Train all employees on proper procedures.
How to do this at your site:
Notification and response procedures should have been identified in your SWPPP. Make sure to follow these procedures. All employees must be aware of notification procedures to ensure that appropriate actions are taken including contacting emergency response and regulatory agencies if necessary.

Emergency Response

Emergency response procedures in a SWPPP address potential spills or emergency situations during industrial activities. The SWPPP outlines detailed plans for responding to incidents that could impact stormwater quality, including emergency contact information, specifying the steps to be taken in the event of a spill, and identifying the responsible parties for managing emergency response actions.

Good Housekeeping Practices

These practices focus on maintaining a clean and organized facility. This helps prevent potential pollution sources as well as increases safety on site. Good housekeeping practices include:

  • Vacuum or sweep regularly.
  • Wash areas as needed. Collect, treat, and/or dispose of water properly.
  • Store materials properly.
  • Collect and contain waste and garbage correctly. Keep container lids closed.
How to do this at your site:
The best way to practice good housekeeping is to minimize the potential for waste and debris to end up in stormwater discharge. This can be achieved through methods that capture materials before they can be taken away by runoff. Common areas to consider implementing these practices include waste containers, storage areas, maintenance areas, and loading docks.

Inspection and Monitoring

Inspection and monitoring play a crucial role in ensuring compliance with stormwater regulations. The SWPPP outlines a schedule for regular inspections of the construction site or industrial facility, evaluating the effectiveness of implemented Best Management Practices (BMPs) and identifying any potential issues. Additionally, monitoring procedures are detailed, specifying the frequency and methods for assessing stormwater quality and quantity. These measures enable quick detection of any departures from permit requirements, facilitating responsive actions to correct the issue.

Employee Training

Employee training is required as a part of a SWPPP to ensure that personnel associated with industrial activities understand the stormwater management practices being used on the site. The SWPPP delineates training programs to educate employees on the importance of pollution prevention, BMPs, and relevant regulatory requirements. This training equips personnel with the knowledge and skills necessary to implement measures that minimize the impact of stormwater runoff on water quality.

Recordkeeping

The SWPPP outlines specific recordkeeping requirements, detailing the types of records to be maintained and their retention periods. These records serve as a historical reference, providing evidence of compliance with regulatory obligations. By systematically documenting inspections, corrective actions, and other pertinent information, the SWPPP details a comprehensive and organized record-keeping system which demonstrates compliance during inspections and facilitates ongoing assessment and improvement of stormwater management practices within the industrial facility.

Documentation of Compliance

Systematic recording and retention of evidence to demonstrate adherence to regulatory requirements is required in a SWPPP, and specific measures are detailed for documenting compliance, including the maintenance of records related to inspections, monitoring results, corrective actions, employee training, and any other relevant activities. Comprehensive and organized documentation within a SWPPP ensures transparency and accountability in demonstrating the site’s compliance with stormwater regulations. This documentation is required for inspections at the site.

Additional Resources

References

EPA. (2021, March). Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operators. https://www.epa.gov/sites/default/files/2021-03/documents/swppp_guide_industrial_2021_030121.pdf

Authors

Lauren Houskeeper, Water Quality Programs Assistant
Erin Rivers, Water Quality Extension Specialist

 

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