Environmental Consulting
Stormwater Pollution Prevention Plan (SWPPP)
Trinity is the leading industry regulatory expert in SWPPP stormwater runoff from industrial facilities and construction sites that can contaminate rivers, lakes, and coastal waters.
Since the early 2000s, Trinity has developed SWPPPs for numerous facilities across the nation and assists facilities with program updates and assessments.
The criteria for needing a SWPPP and stormwater permit coverage are based on the facility’s SIC code or industrial activity codes for industrial activities and the area of disturbed land for construction activities.
In general, the following industrial activities are subject to stormwater permitting:
- Facilities subject to federal stormwater effluent discharge standards in 40 CFR 405-471
- Heavy manufacturing (for example, paper mills, chemical plants, petroleum refineries, steel mills and foundries)
- Coal and mineral mining and oil and gas exploration and processing
- Hazardous waste treatment, storage, or disposal facilities
- Landfills, land application sites, and open dumps with industrial wastes
- Metal scrapyards, salvage yards, automobile junkyards, and battery reclaimers
- Steam electric power generating plants
- Transportation facilities that have vehicle maintenance, equipment cleaning, or airport deicing operations
- Treatment works treating domestic sewage with a design flow of 1 million gpd or more
- Light manufacturing (e.g., food processing, printing and publishing, electronic and other electrical equipment manufacturing, and public warehousing and storage)
Facilities in these industrial sectors that have no exposed industrial activities may file a certification statement to be exempt from stormwater permitting and planning requirements.
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SWPPP Overview
What is Stormwater Pollution Prevention Plan (SWPPP)?
Trinity has the expertise to develop strategies to minimize stormwater runoff pollution, including erosion control, sedimentation prevention, and chemical management, ensuring compliance with environmental regulations.
Stormwater runoff from industrial facilities and construction sites can contaminate rivers, lakes, and coastal waters. Under the National Pollutant Discharge Elimination System (NPDES) regulations, stormwater that comes into contact with industrial facilities in 10 major categories and construction projects disturbing one or more acres of land must prepare a Stormwater Pollution Prevention Plan (SWPPP) and obtain stormwater permit coverage.
The stormwater permit will specify required SWPPP contents. Most permits require SWPPPs to include the following elements:
- Identification of pollution prevention team
- Description of the industrial activities at the facility
- Description of pollutant sources
- Management Controls including:
- Housekeeping/Preventative Maintenance/Spill Prevention
- Monitoring requirements
- Visual inspection plan (and records of inspections)
- Employee training program
- Sediment and erosion control
- Runoff management
- Recordkeeping and internal reporting
- Annual Comprehensive site evaluation
Industrial Stormwater Permit Coverage and Permitting Process
Individual Permit
Individual permit coverage for stormwater is more typical for facilities that also have a direct discharge for process wastewaters. The process for obtaining and complying with an individual stormwater permit is generally the same as other direct discharge permits.
General Permit
EPA and state agencies with stormwater permitting jurisdiction develop general permits for stormwater discharges. The EPA version is called the Multi-Sector General Permit (MSGP). Some states develop several different types of general stormwater permits applicable to specific types of facilities (e.g., Colorado has separate general stormwater permits for different types of mining activities and for non-extractive industries).
To obtain coverage under a general permit, the basic steps typically include the following:
- Develop a SWPPP (also referred to as a SWP3, SPPP, PPP, PPC, SWMP depending on the state)
- Specific SWPPP requirements will be listed in the applicable general permit
- Complete the Notice of Intent (NOI)
- Submit prior to initial discharge
- May require a certification that activity will not impact endangered/threatened species
- Submit a Notice of Termination (NOT) after the discharge is eliminated or when the owner or operator changes
Coverage under a general permit will typically require a facility to reapply for coverage (file a new NOI) when the general permit is reissued. General permits are reissued at least every five years.
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