Do I Need a Storm Water Pollution Prevention Plan?

The Office of Compliance Fact Sheet Series

Updated March 1998 - Doc. No. 1154

What is a storm water pollution prevention plan?

This guide provides background information on pollution prevention planning requirements for facilities with National Pollutant Discharge Elimination System (NPDES) General Permits. A storm water pollution prevention plan is a documented step-by-step process for ensuring that pollutants from your industrial activities are not making their way into the storm water discharges from your site. Specifically, the pollution prevention plan requires that you select and implement best management practices (BMPs). BMPs include schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution in storm water runoff from your site.

Do I need to develop a storm water pollution prevention plan?

The National Pollutant Discharge Elimination System has a permit program established to control the discharge of storm water and/or industrial discharges that could adversely affect the quality of waters of the United States. Transportation industries that require a General Permit under Phase I of the NPDES program are required to develop and implement a storm water pollution prevention plan (SWPPP).

How Do I develop a storm water pollution prevention plan?

The five major phases of developing a SWPPP are (1) planning and organization; (2) assessment; (3) BMP selection and plan design; (4) implementation; and (5) evaluation and site inspection.

(1) Planning and Organization Phase

Before you start putting your SWPPP together, there are two steps that will facilitate the development of your plan. These steps are designed to help you organize your staff and make preliminary decisions: (A) decide who will be responsible for developing and implementing your SWPPP, and (B) look at other environmental plans at your facility that may overlap with the SWPPP for consistency.

(2) Assessment Phase

After identifying who is responsible for developing and implementing your plan and organizing your planning process, you should proceed to this next step - a pollutant source assessment. This is where you take a look at your facility and determine what materials or practices are (or may be) a source of contaminants to the storm water running off your site. To complete this phase, you will:

• Create a map of the facility site to locate pollutant sources and determine storm water management opportunities

• Conduct a material inventory

• Evaluate past spills and leaks

• Identify non-storm water discharges and illicit connections

• Collect or evaluate storm water quality data

• Summarize the findings of this assessment.

To select the most appropriate and effective control measures, consider that potential pollutant sources include areas where materials are handled or stored, outdoor processing areas, loading and unloading areas, and onsite waste management and disposal areas.

( 3) BMP Selection and Plan Design Phase

Once you have identified and assessed potential and existing sources of storm water contamination at your facility, the next step is to select the proper BMPs that will address these pollutant sources. To satisfy the requirements of this phase, you must provide a narrative description of the BMPs you have selected for your site. At a minimum, your plan must incorporate the following eight "baseline" BMPs:

• Good housekeeping
• Traditional storm water management practices
• Preventive maintenance
• Sediment and erosion prevention
• Visual inspections
• Spill prevention and response
• Employee training, and
• Recordkeeping and reporting.

(4) Implementation Phase

At this point, you have designed your SWPPP and the plan has been approved by facility management. Under the implementation phase, you must (A) implement the selected storm water BMPs, and (B) train all employees to carry out the goals of the plan.

(5) Evaluation and Site Inspection Phase

Now that your SWPPP has been put into action, you must keep it up-to-date by regularly evaluating the information you collected in the Assessment Phase and the controls that you selected in the BMP Selection and Plan Design Phase. Specifically, you must (1) conduct site evaluations, (2) keep records of all inspections and reports, and (3) revise the plan as needed.

Additional Information

Publications:

• Storm Water Management for Industrial Activities: Developing Pollution Prevention Plans and Best Management Practices - Summary Guidance , EPA, Office of Water, EPA 833-R-92-002, October 1992.
• Applying for a Storm Water Permit Under the Phase I Program Fact Sheet
• Phase I NPDES Permit Renewal Fact Sheet
• Do I Need a Storm Water Permit in the Trucking Industry? Fact Sheet

Contacts: Additional information is also available from the following sources:

• General information regarding the EPA - http://www.epa.gov
• Application forms for permits - http://www.epa.gov/earth1r6/6wq/npdes/forms/forms.htm
• EPA's Office of Water Resource Center at (202) 260-7786

EPA's Office of Water PIPES bulletin board (via modem) at 703-749-9216 or http://pipes.ehsg.saic.com/pipes.htm.