Stormwater Pollution Prevention Plan (SWP3)

Requirements

Joe Willingham, P.E.Professional Engineer III

Industrial Wastewater Enforcement SectionWater Quality Division

Department of Environmental Quality

General issues Who needs to sign them When do they need to be submitted to DEQ What needs to be in them How often do they need to be updated

Outline

Requirements listed in Part 4 of OKR10 Must be prepared prior to submission of NOI Should be prepared in accordance with good

engineering practices Licensed PE only required for those parts of

SWP3 involving the practice of engineering

General Issues

Address requirements for support activities Listed in Addendum G of OKR10

Include information on listed or endangered species found in proximity to site

General Issues

For sites discharging to receiving waters impaired for sediment

Document best management practices (BMPs) used to control pollutants of concern

For sites discharging to receiving water with approved Total Maximum Daily Load (TMDL) or watershed plan

Document how SWP3 is consistent with it

General Issues

Should be retained on-site or available upon request Post sign with:

OPDES permit number or copy of NOI

Name and phone number of contact person

Brief description of project Location of SWP3 if site is inactive

or lacks on-site location

Making SWP3s Available

Listed in Part 6.7 NOIs or NOTs

Signed by responsible corporate official, general partner or proprietor, principal executive officer or ranking elected officer

Reports or other information requested by DEQ Signed by officials above or duly authorized

representative

Signatory Requirements

Authorized representative Must be made in writing and signed by

responsible official Can be named individual or any individual

occupying a named position

Certification statement in Part 6.7.4 must be included on any signed documents.

Signatory Requirements

Certification Statement

Only submit SWP3 to DEQ if the project is located: Within Outstanding Resource Waters Within a Federal and State Aquatic Resource of

Concern (ARC) Within a larger site which is disturbing land of

40 or more acres Will be returned unreviewed if not in one of

the above areas

Submitting SWP3s to DEQ

Department of Environmental QualityEnvironmental Complaints and Local Services

Storm Water Unit 707 North Robinson, P.O. Box 1677

Oklahoma City, OK 73101-1677 FAX (405) 702-6226

Where to Send NOI & SWP3

Stormwater Team Responsible for SWP3 and permit compliance Must be identified by name or position Must include individual responsibilities Must have access to permit, SWP3, and other

documentation

Keep a copy of OKR10 and signed NOI with SWP3

Plan Contents

Construction Activity Description Include size of property, total area to be disturbed,

support activities, and maximum area to be disturbed at any one time

Identify all other operators and their areas of control

Describe intended construction sequence, including Installation of control measures Schedule of earth-disturbing activities Dates for stabilization of exposed soil

Plan Contents

Site Map Must be legible Must include:

Boundaries of property and locations of construction activities

Locations of waters of the state within 1 mile of site

Boundary lines of any natural buffers Site topography, existing vegetative cover, and

drainage patterns

Plan Contents

Site Map (cont’d) Must include:

Stormwater and allowable non-stormwater discharge locations

Locations of potential pollutant-generating activities

Locations of stormwater control measures Sampling locations for asphalt batch plants, if

applicable

Plan Contents

Construction Site Pollutants Identify pollutants expected at site

Examples: sediment, paint, solvents, fuels, trash, etc. Describe activities generating listed pollutants

Examples: paving operations, concrete washout, paint/stucco washout, solid waste disposal, dewatering

Account for areas where spills or leaks could occur Document changes from manufacturer’s

specifications for fertilizer applications

Plan Contents

Endangered Species/Historic Preservation/Water Quality Impaired Waters Document any effect stormwater discharges or

stormwater discharge-related activities may have

Describe and implement measures to protect endangered species or threatened habitat or meet TMDL/watershed plan requirements

Describe how BMPs would reduce and avoid pollutant of concern into any impaired waters

Plan Contents

Controls to Reduce Pollutants Includes structural and non-structural

Structural examples: silt fence, sediment traps, check dams, etc

Non-structural examples: good housekeeping practices, training, etc.

Describe control measures and timing for each major activity

Plan Contents

Stormwater Control Measures Potential resource: National Stormwater BMP Menu

http://cfpub.epa.gov/npdes/stormwater/menuofbmps Minimum requirements:

Straw or hay bales as BMPs are NOT allowed Designed to retain sediment on site Must be properly selected, installed, and maintained

Follow manufacturer’s specifications and good engineering practices

If it is installed, maintain it or remove it

Plan Contents

Minimum requirements: Remove off-site accumulations of

sediment to minimize offsite impact Remove sediment from sediment

traps or ponds when design capacity has been reduced by 50%

Prevent litter, construction debris, and chemicals from becoming a pollutant source

Address offsite material storage areas used solely by permitted project

Stormwater Control Measures

Stabilization practices Describe vegetative/non-vegetative stabilization

practices used for temporary or final stabilization Temporary stabilization - provided during establishment

and growth of vegetation and/or when earth-disturbing activities will occur again in future

Final stabilization - provides permanent cover and meets termination requirements Soil disturbing activities are complete AND

70% of native background cover established OR Equivalent permanent stabilization measures installed

Stormwater Control Measures

Stabilization Practices

Structural Practices Include description Sediment basin requirements

Required in areas where ≥10 disturbed acres drain to a common location

Must store runoff from a 2 year, 24 hour storm from each disturbed acre OR

Must provide 3,600 ft3 of storage per acre drained Use velocity dissipation devices at discharge

locations and along outfall channel

Stormwater Control Measures

Velocity Dissipation

Pollution Prevention Spill prevention and response

Include procedures to prevent and respond to spills and leaks Identify name/position of

employee responsible for spill or leak detection and response

List contact information for facility personnel, emergency response agencies, and regulatory agencies OR reference SPCC plan for site

Plan Contents

Pollution Prevention Waste management

Include procedures on handling and disposal of wastes including: Sediment Construction waste Hazardous waste Demolition/clearing debris Sanitary waste

Plan Contents

Monitoring For discharges subject to numeric limitations (i.e.

asphalt batch plants) Identify

Locations where samples will be collected Linear projects – can identify substantially identical outfalls

Responsible personnel Normal working hours for project Equipment to be used Sample collection procedures

Plan Contents

Plan Contents

Maintenance BMPs identified in SWP3 must be maintained Conduct maintenance before next anticipated

storm event or as necessary to maintain effectiveness

Adding or modifying BMPs must be completed prior to next storm event If impracticable, document situation in SWP3, AND Complete as soon as possible after event

Maintenance

Inspections Identify “qualified person” Identify frequency

Minimum = once every 14 days and within 24 hours of 0.5 inch rain event or discharge from snowmelt

Include inspection form in SWP3 Complete reports within 24 hours of inspection Keep completed reports onsite with SWP3 Must be signed

Plan Contents

Note Certification Statement

Training Requirements Ensure personnel understand permit

requirements prior to beginning work Minimum topics to cover:

Location of stormwater controls Maintenance procedures for stormwater controls Pollution prevention requirements Inspection and documentation procedures

Only required for personnel responsible for inspections

Plan Contents

Training Log

Example from EPA’s SWP3 template

Can create your own

Must be kept with SWP3

Corrective Actions Involve repair, modification, or replacement of

stormwater controls Include clean up and disposal of materials from

spills or releases May remedy a permit violation Deadlines for completion – 7 days from time of

discovery Document and modify SWP3 as appropriate

Plan Contents

Non-Stormwater Discharges Identify those that are combined with

stormwater discharges Identify pollution prevention measures Identify location(s) on site map Ensure measures are implemented to reduce

and/or eliminate such discharges

Plan Contents

Allowable Non-Stormwater Discharges

Source: EPA’s SWP3 Template

Contractor Certifications Used at discretion of permittee Not required Places the responsibility for complying with

permit requirements and your SWP3 with the contractor

Requires contractors to abide by your NOI, SWP3, and BMPs

Include this information in SWP3

Plan Contents

ExamplesFrom EPA’s SWP3 Template From Addendum D of OKR10

Living document Make changes

As conditions at the site change When site inspections indicate BMP is ineffective

Keeping SWP3s Current

Source: http://www.epa.gov/npdes/pubs/exampleswppp_residential.pdf

EPA’s SWP3 Templates and Examples http://cfpub.epa.gov/npdes/stormwater/

swppp.cfm#report http://www.epa.gov/npdes/pubs/

sw_swppp_guide.pdf SWP3 Webcasts

http://cfpub.epa.gov/npdes/courseinfo.cfm?program_id=0&outreach_id=308&schedule_id=962

Resources

Questions, Comments, Discussion