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Prepare-review SWPPP

The Prepare-review SWPPP with Site Map is a task in the Complyrs Commercial Stormwater Compliance Program.

Introduction

A Stormwater Pollution Prevention Plan (SWPPP) documents how a facility could pollute stormwater and documents pollution prevention procedures. SWPPPs for commercial facilities are less formal than ones required for industrial or construction compliance. Some of the components of the SWPPP can be extracted from documents prepared to comply with other environmental programs.

Identify Business Activities

Compile a list of activities conducted at the facility. Some activities are primary; central to the running of the business. (For example, vehicle fueling is the primary activity of a gas station.) Some are secondary; conducted by the business but not as part of essential functions. (For example, landscaping, if present, is a secondary activity at a the same gas station.) Regulators will expect you to take more substantial measures to control primary activities than secondary ones.

Identify Potential Pollution Sources

This could include things such as:

  • Sloped land
  • Stored materials
  • Waste storage containers
  • Roofs and downspouts
  • Parking lots
  • Outdoor equipment
  • Applied materials (fertilizers, herbicides, road tar, road salt, etc.)
  • Outdoor cleaning activities
  • Improper connections to the storm sewer system

Note: the Inventory Submitted to CERS, is a good place to find potential stormwater pollutants.

Identify BMPs

All sources and activities identified that could pollute stormwater runoff will need to controlled by BMPs. CASQA has a collection of free BPM sheets on their Commercial Stormwater BMP Handbook page. Find the BMPs that best apply to your sources and activities. Review them and determine what practices are appropriate and practicable. Make a list of the BMPs to be implemented at the facility for each source and activity.

Prepare a Map of Facility

The map should identify the locations of activities and potential pollution sources and where BMPs will be implemented. This map should include all storm drains that are found onsite and the nearest offsite storm drains that receive runoff from the site.

Note: the Site Map Submitted to CERS or better yet, the Site Map found in a Spill Prevention, Control and Countermeasure (SPCC) plan  are ideal starting points for a SWPPP site map.

Prepare a Work Plan

Now that you have pollution sources and activities identified and the BMPs you will implement to prevent pollution, develop a work plan to ensure the BMPs (if behaviors) are followed. Or, if structural, are maintained. This might include a daily task list of simple things like: ensuring trash enclosures are covered and the facility is kept free of litter. Or, it might be annual maintenance to an on-site storm drain.

Develop a Training Plan

The training plan does not need to be extensive or formal. You have identified sources and activities that can pollute stormwater runoff at the facility. You have also identified BMPs to reduce the risk of stormwater pollution. The training should explain these elements to staff and include task assignments to ensure compliance.

Note: do not forget to implement training annually and record the training event.

Annual Review

A SWPPP should be a living document and should be reviewed annually. The review should include:

  • Have any of the facility activities or processes changed in a way that affects stormwater runoff?
  • Has there been a change in materials stored on site that have a potential to pollute runoff?
  • Has the facility physically changed in a way that affects stormwater runoff?
  • Do any of the above changes warrant changing the SWPPP?
  • Are existing BMPs being implemented correctly?
  • Does training need to be changed to improve BMP implementation?

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