For a Rainy Day
Pointers on how to successfully implement your company's stormwater pollution prevention plan
So you've completed your stormwater pollution prevention plan (SWP3) and filed your notice of intent (NOI). You're finished, right? Did you forget about the little part on the NOI that says you have developed and implemented your SWP3 prior to submitting the NOI? You still have to implement those Best Management Practices (BMPs) and other required elements of your permit. After all, lack of SWP3 implementation and good recordkeeping may result in a notice of violation (NOV), which in turn may lead an inspector to take a closer look at your facility. This is like inviting the inspector to view the skeletons in your closet. Don't give them an excuse to keep coming back.
Some common SWP3 implementation items often fall through the cracks: training, routine sampling, and inspections. The SWP3 itself is a dynamic document that must be updated as operations change and as local, state, or federal regulations change. Here are a few practical solutions to maintaining compliance with your stormwater permit.
If employees don't know what a BMP is, how can the stormwater pollution prevention BMPs be implemented? Training is a required element in all SWP3s and is key to maintaining compliance. In our experience, educating employees on the "why's" as well as the "how's" is instrumental in implementing the plan. Many people have the misunderstanding that stormwater is treated before entering the streams or lakes. A simple explanation that stormwater, and everything it picks up along the way, flows directly into our recreation areas may instill a sense of responsibility, both at work and at home.
Employees responsible for implementing or maintaining aspects of the SWP3 must be trained on job-specific BMPs. Most companies perform this training, but overlook the requirement that all employees must be informed of the basic goal of the SWP3 and how to contact members of the pollution prevention team if the need arises. Also, SWP3 training must be performed and documented annually. Here are a few tips that may work for your company:
- Basic awareness training does not require instructor-led classroom training. A short, written statement with a few key points sent to each employee can be sufficient. Adding stormwater tips to the company newsletter or sending an eye-catching postcard are other alternatives.
- Many companies have databases to track employee training and alert them when training is required. Integration of the SWP3 training into the training database can prevent missed training.
- Use an e-learning module.
Routine Sampling and Visual Monitoring
How many of us want to go out in the rain and collect stormwater samples, much less keep track of what is a qualifying rain event and how long it has been since it started raining? Not many, but there are some -- probably the ones who jumped in puddles as children and have made a business of sampling stormwater. Using a reliable sampling company can keep the routine stormwater sampling on track.
More than likely, you will be the one conducting quarterly visual monitoring activities. Luckily, that's the easy part. So rummage around the office and find an empty, clean glass jar or container and keep an eye on the skies. Better yet, get a jar from that reliable sampling company you're using. Keep the jar handy so it's ready to go when the sky lets loose. When the rain comes, fill up that jar at each outfall and complete your quarterly visual monitoring form.
Another key element to successful implementation of your SWP3 is routine inspections of your BMPs. Inspections are typically performed monthly, quarterly or annually, but may also be required after a storm event. It's easy to get distracted by day-to-day issues that somehow arise along with the many other obligations of your job. No wonder it's so easy to let several months slip by without performing the inspections. However, if you miss the little issues during the periodic inspections, they may result in larger issues, and more headaches, down the road.
Scheduled inspections on your BMPs can be flagged using preventive maintenance tracking systems or a simple calendar. Many companies have software systems designed to track facility preventive maintenance (PM) activities. Inclusion of the SWP3 inspections and associated corrective actions into this system can facilitate completion of the tasks. However, in the absence of a PM system, today's electronic age allows you to note inspection events on your electronic calendar and set a reminder or alarm to notify you when the inspection is due.
Inspections should be performed by qualified personnel familiar with the industrial activities and associated BMPs performed at your facility. That individual should document the inspections and retain them with your SWP3. Don't forget; corrective actions and implementation dates should also be documented.
Inspections may also identify operational changes that can significantly impact your SWP3. How many times have plant personnel added a new process, purchased new materials, or moved things around without telling you? These activities can significantly impact stormwater if stormwater is not considered during the planning process. Sometimes these activities are only temporary, but must be addressed in your SWP3.
A comprehensive annual inspection is required in all SWP3s. This is a time for the team to evaluate the BMPs and their effectiveness. Now is a good time for the entire team to inspect the operations and make any necessary changes to the plan.
Communication -- Communication -- Communication.
Nobody needs another meeting on their schedule. However, a good SWP3 team meeting can actually improve the effectiveness of your plan and reduce the amount of time you spend on resolving problems. Routine team meetings help maintain an open line of communication, keep the awareness level up, and allow for timely resolution of items identified during inspections. Meeting frequency will depend on the complexity of your operations, but should be quarterly at a minimum. However, we recommend monthly meetings to maintain project visibility and focus. Meeting topics should include:
- Inspection results and corrective actions,
- Planned facility changes, and
- Communication and training -- the more visible the program, the more effective the plan. Keep the information fun and don't forget to include tips for employees to practice at home.
The Dynamic Document
The stormwater pollution prevention plan is meant to be a dynamic document. In many cases, changes can be incorporated by crossing out the old information and hand-writing in the new. For example, if a person on the team moves to a new position and is replaced, it is acceptable to cross out the old name and write in the name of the new member. Or if a raw material storage area is moved, it can be crossed out on the plan figure and hand-drawn in the new location. Keep in mind that adjustments to the BMPs, such as moving the silt fences or drainage controls, may also be necessary depending on the changes at your facility and in your document.
The SWP3 is not meant to be a dust collector. Pull it out of the drawer, dust it off, and make it an effective program. This is one program that can have a bottom line impact on the environment. Protecting our streams, lakes and oceans is everyone's responsibility and by implementing a few key elements of the Plan, we not only maintain compliance, but make an impact.
This article originally appeared in the July/August 2006 issue of Water & Wastewater Products, Vol. 6, No. 4.
This article originally appeared in the 07/01/2006 issue of Environmental Protection.
Heather Woodward works for W&M Environmental Group in Plano, Texas. She is a registered environmental manager with more than 15 years of experience in Environmental, Health, and Safety corporate compliance. Project experience includes general regulatory compliance and reporting, RCRA hazardous waste management, waste minimization/pollution prevention (P2), stormwater pollution prevention, asbestos management, litigation support, CERCLA/Superfund steering committees, Phase I and II Environmental Site Assessments and corporate wellness programs. She can be contacted at (972) 516-0300.
Lori Pfeil works for W&M Environmental Group in Plano, Texas. She has 10 years experience in environmental consulting, performing compliance audits, and developing compliance documents, including stormwater pollution prevention plans (SWP3), spill prevention control and countermeasures (SPCC) plans, best management practices (BMPs), Tier II reports, and Toxic Release Inventories (TRI). Lori is also experienced in Phase I and II Environmental Site Assessments (ESAs) and risk-based closure of impacted properties. She can be contactedat (972) 516-0300.