Storm water runoff is rain water (or melted snow) that “runs off” the land and into national waterways such as streams, rivers, lakes or the ocean. When storm water runs through industrial sites, it can pick up pollutants, carrying them into the nation’s waters and potentially affecting the safety and navigability of our waters. To help manage storm water runoff pollution, the Environmental Protection Agency (EPA) developed a program under the Clean Water Act, the National Pollution Discharge Elimination System (NPDES), which requires industries to register for a permit and develop a plan for storm water management.
The Arizona PDES Multi-sector General Permit (MSGP) 2010 stipulates various requirements for business operators, including Storm Water Pollution Prevention Plan (SWPPP) development; routine facility inspections and associated corrective actions as needed; employee training; and frequently, analytical monitoring of storm water discharges. The ADEQ requires comprehensive storm water management – and the burden of proof regarding such requirements is solely the facilities responsibility. That said, the importance of adhering to the “four-square” storm water approach cannot be overemphasized. The “four-square” approach consists of – you guessed it – four steps.
Step One – Plan Development
Step one consists of SWPPP development, a requirement familiar to most facilities covered under the former storm water permit. SWPPP development is, simply, developing your plan for rainwater or melted snow running off of your property. At a minimum, your plan must state your structural (for example, building a berm) or non-structural (e.g. conducting employee training) controls and your practices – called “best management practices” or BMP’s – for preventing potentially polluted storm water from merging with protected waters.
Step Two – Implement You must conduct regular storm water inspections. Developing a SWPPP but failing to conduct inspections constitutes a violation. and can expose your company to sizeable fines and penalties. Step two regards the actual evaluation of plan and practices. This includes routine inspections, both during storm and non-storm events.
As any employer recognizes, however, implementing the plan relies not only on the business operator, but also the employees ..bringing us to
Step Three – Training
Step three is to conduct comprehensive employee training.
Finally, if your facility’s sector, such as Sector E, M, N, etc, requires storm water monitoring (as stipulated by Part 8 of the permit), step four regulates off site discharge by way of analytical monitoring of storm water discharge samples.
The SWPPP Bottom Line
By following the “four-square” approach, you can rest assured that your facility will achieve and maintain compliance with AZPDES MSGP 2010. Even better, when ADEQ knocks on your door to conduct a surprise inspection, you’ll be prepared!
Envirosure Solutions has a team of environmental compliance specialists who can assist you in all facets of your storm water pollution prevention plan – from designing, writing, and implementing your plan to general contracting and structural improvements that will ensure you total compliance. We make the process easy, sometimes even fun! Our prices are very reasonable. If you have questions or would like more information – including a free quote, give us a call.