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Industrial Storm Water Pollution Prevention Plan (SWP3) Fact Sheet

The Clean Water Act prohibits the discharge of “pollutants” through a “point source” into a “water of the United States” unless a National Pollution Discharge Elimination System (NPDES) permit is obtained. The permit contains limits on what can be discharged, monitoring and reporting requirements, and other provisions to ensure that the discharge does not negatively impact water quality or human health. In effect, the permit translates requirements of the Clean Water Act into specific provisions tailored to the operations of each industry discharging pollutants.

The (NPDES) general permit for storm water discharges associated with industrial activity requires that each industrial facility covered by the general permit submit a Notice of Intent (NOI) for coverage and develop and implement a SWP3. NPDES individual permits also require the submittal of a NPDES permit application and development and implementation of a SWP3. This fact sheet provides a quick reference for the requirements of a Storm Water Pollution Plan (SWP3).

Storm Water Pollution Prevention Plan (SWP3)

As the name implies, the overall intent of the SWP3s is to prevent storm water contamination. SWP3s must be prepared in accordance with good engineering practices and in accordance with specific requirements outlined in the individual or general industrial storm water permit. Each state’s website and the U.S. EPA website provides guidance on obtaining permit coverage, creating effective and compliant SWP3s, and procedures and protocols necessary to successfully implement a SWP3 at your facility.

Key components of a SWP3 include the following:

  1. Pollution Prevention Team – Identify specific individual(s) responsible for development of the SWP3 and for assisting management in the SWP3 implementation, maintenance, and revision.
  2. Description of Potential Pollutant Sources – Describe potential pollutant sources and activities that may contribute pollutants to storm water discharges. This section should include: site drawings, an inventory of materials exposed to precipitation, spills and leaks, storm water monitoring, risk identification, and summary of potential pollutant sources.
  3. Measures and Controls – Develop, describe, and implement appropriate storm water management controls and best management practices to preclude pollutants from contaminating storm water. These controls should include: good housekeeping, structural controls, preventive maintenance, spill prevention and response procedures, employee training, reporting to agencies, and record keeping.
  4. Inspections – Qualified personnel must inspect the facility at the frequency dictated in the permit. Included in the evaluation are inspections of potential sources of pollution identified in the SWP3, structural control measures, and outfall inspection. An inspection report must be retained as part of the SWP3.

Depending on the state, other information may be required to be included in the SWP3.

EQM Experience

EQM personnel have developed and updated SWP3s for a wide range of industrial clients. In addition to SWP3 development, our storm water experience includes determination of regulatory applicability, site evaluations, certification of non-storm water discharges, development of site-specific sampling protocol, storm water sampling, preparation of NPDES permit applications, and preparation of NOI forms.  This proven storm water experience combined with our experience in developing other closely related environmental plans (Spill Prevention, Control, and Countermeasure Plans, Groundwater Protection Plans, Facility Response Plans, etc.) enables EQM to prepare a high quality, compliant, and user friendly SWP3 for your facility.

 

JIll Binzer Project ManagerJill Binzer, Senior Project Manager/Scientist

Jill Binzer has 20 years of technical and project management experience in the environmental field.  As a Project Manager, she has an extensive work background with private industry and local and state regulatory agencies.  She has worked with a wide variety of clients and businesses and her areas of experience include regulatory compliance with CWA, RCRA, and CERCLA; environmental permitting (NPDES and PTIs); environmental compliance audits; on-site multi-media environmental compliance assistance; environmental health and safety support; and storm water, wastewater, groundwater monitoring and air monitoring.

 

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