Melissa Wenzel, guest author for Mapistry, is the Industrial Stormwater Program Coordinator, Minnesota Pollution Control Agency
I actually enjoy reviewing facilities’ industrial stormwater SWPPPs. Really! That might sound strange, but it gives me a chance to interact with facility staff and it helps me understand where there may be confusion about a specific permit requirement. It also means they may be more comfortable contacting me again if they have additional questions or confusion about our regulations. It also allows me see what a company or facility is doing and how they’re protecting Minnesota’s groundwater and surface waters. With over 10,000 lakes and 72% of Minnesotans getting their drinking water from groundwater sources, we take water protection requirements very seriously. It gives me a one-on-one opportunity to interact with facility staff too. We have 2.5 full-time equivalent technical staff managing every aspect of our statewide industrial stormwater program. With over 3,500 facilities regulated by our permit, it’s a challenge to make sure everyone has all of their needs met. Plus the facilities that ask for me to review their SWPPP are often new facilities, or staff new to industrial stormwater regulations. If facility staff are reaching out to us “early” in their regulatory process, they’ll hopefully reach out to us again if they have questions or have a stormwater management problem.
Every industrial stormwater permittee needs to develop and implement a Stormwater Pollution Prevention Plan (SWPPP). Some of the most complete SWPPPs I’ve reviewed are short and to the point, where incomplete SWPPPs I’ve seen were lengthy, wordy, and filled with unnecessary additions, including sector-specific “chapters” not at all related to the facility’s industrial activities.
I can appreciate that developing a SWPPP for the very first time can seem daunting, but the document is meant to be a practical “playbook,” if you will, for managing stormwater runoff. It’s meant to help you keep track of your employee training, your visual inspection records, your sampling results, managing potential emergencies & spills, and so on. With a nationwide increase in people retiring from the baby boomer generation, new staff are getting hired at companies all the time. I can understand if updating a SWPPP is not a new employee’s first priority.
But it should be a priority. The document contains information about what a facility’s stormwater management practices are, how they work, and when and how they should be maintained. In Minnesota, we require that SWPPPs be updated at least once a year, and we double-check this requirement by asking SWPPP-related questions on our annual report form. At the very least, that reminds facility that they should have reviewed and updated their SWPPP in the previous calendar year. Or review it right now, if that requirement was not done in the previous year.
Speaking of annual reports, in Minnesota we require permittees to summarize their required monthly visual inspections on the annual report, with the originals required to be kept in their SWPPP. I am not thrilled when I see visual inspection summaries with the words “all good” or “everything okay.” Side note: If I were to go to your house right now, would everything be perfect, in showing condition? Unless you’re actually selling your house, probably not. Your facility is probably similar, so think about conducting a visual inspection (or managing any industrial stormwater permit requirement) as if you were going to receive a surprise inspection by the environmental state inspector, TODAY. Pretend you’re looking at your own facility for the very first time and from a regulator’s perspective. What would you find if you’ve never seen your facility and was looking at it from an inspector’s lens?
In Minnesota, we’ve created a checklist that own state regulatory inspectors use. Because we pride ourselves in being a program that is as transparent as possible, we’ve put that same checklist on our website, for any facility (or their consultant) to use as a self-audit tool. Check out our Industrial Stormwater Compliance Inspection Checklist. There should be literally no surprises when our inspectors visit our industrial stormwater facilities!
Back to SWPPP requirements. We’ve also created a SWPPP checklist to help facilities make sure their SWPPPS are complete. It’s the very same checklist I use when I’m reviewing a facility’s SWPPP for either compliance purposes or when I get a request to review a facility’s SWPPP upon request.
Here are some SWPPP Do’s and Don’ts:
- Do review your SWPPP at least once a year. Tie it with other requirements like filling out and submitting your annual reports or other environmental regulations, like hazardous waste reporting, tank inspections, or air permit requirements.
- Do make sure contacts are up-to-date and that everyone listed in the SWPPP knows what their roles and responsibilities are.
- Do make sure you have information about environmental emergencies and spills in your SWPPP and it’s easy to find.
- Do include other types of regulatory requirements like hazardous waste or storage tank information, if it’s helpful for you to have all of your regulatory documentation in one spot
- Do ask your regulatory agency if you can have your SWPPP fully electronic. It’s often easier to update a Word file than an actual piece of paper that likely started out as a Word file. Or check out Mapistry’s digital stormwater solution if you want SWPPP automation and other benefits like mobile updates and notifications.
- Do make sure you know where your SWPPP is.
- Don’t include references and requirements that aren’t needed. What I mean is, if your state issues a multi-sector general permit with sector-specific requirements, be sure to include the sector requirements applicable to your facility. Don’t insert the entire permit as an attachment. You’re wasting space, time and if you print your SWPPP, you’re wasting a LOT of paper.
- Don’t develop your SWPPP once and never update it again. I would bet that from permit cycle to permit cycle, staff have likely changed, activities and materials outside may have changed, and maybe you’ve implemented new stormwater practices that make your facility run more efficiently, more safely.
- Don’t forget to include required submittals in your SWPPP, like visual inspection documentation, sampling results, spill documentation, and maintenance schedules for your Best Management Practices.
- Don’t expect your state to have an example SWPPP. With regulating 29 industrial sectors, each facility’s SWPPP should be just as unique as each facility is. There are concerns that permittees that are copying and pasting someone else’s SWPPP content is not actually addressing with facility-specific environmental issues and are not complying with the requirements appropriately.
While this document is a little old, EPA’s “Developing your Stormwater Pollution Prevention Plan, a guide for Industrial Operators” document is still relevant and helpful. EPA also has a fill-inable SWPPP template you can use; just make sure you include state-specific requirements if you use another state’s SWPPP template or Minnesota’s template and your facility isn’t in Minnesota.
Choosing industry-specific BMPs
In Minnesota, we frequently say that businesses know their facility better than anyone else and can choose the right best management practices that make sense for their facility staff, for their safety needs, and for their budget. But sometimes industry-specific ideas or suggestions are helpful. Our state recently created an industrial stormwater “digital document library” and created industry-specific content for our 28 sectors (Minnesota does not have any coal mining activities, the only sector with zero facilities). Check out the sector-specific content in our Digital Document Library
We understand that creating a SWPPP or complying with other industrial stormwater permit requirements takes time and resources, and other facility priorities may seem more important. But stormwater requirements are meant to protect our lakes, rivers, streams, wetlands and drinking water sources. In Minnesota, we regulators will continue to work with our regulated universe to protect our groundwater and surface waters.
About the Author
Melissa started her environmental career at the Minnesota Pollution Control Agency in 2002 with providing multi-program technical assistance to businesses and consultants, with a focus on hazardous waste regulations. She joined the industrial stormwater program in 2008 and was promoted to program coordinator in 2011. Since then, she’s created a statewide program that emphasizes training and education, assistance and pollution prevention. Her team has created guidance materials and tools that are used in several states and countries. Her greatest strength is partnering with programs and organizations inside and outside the agency to ensure environmental compliance, permittee assistance, and protection of Minnesota’s waters.