When it comes to stormwater compliance, the way a Pollution Prevention Team (PPT) is trained can make the difference between a $1m+ lawsuit and smooth sailing. You can roll through a video or a few slides with most folks half-asleep or you can have a professional trainer engage with stormwater staff to create an interactive, site-specific training session that will boost your stormwater program. The mark of a successful training session is to leave the stormwater team discussing ways to improve their program themselves….not the trainer telling them what to do. All this takes is a little nudge in the right direction and some passion for stormwater. In this blog, we will explore the top 3 topics that should be covered in detail during stormwater training with your PPT.
#1 Best Management Practices (BMPs)
Best management practices (BMPs) are extremely important to review with not only the PPT but all staff (aka general awareness training). Minimum BMPs such as good housekeeping and preventative maintenance are key to preventing pollutants from contaminating stormwater. We find the more staff (yes, that means mechanics, technicians, and the big boss) that are aware that their facility is operating under a stormwater permit and that understand that BMPs must be implemented on a regular basis, the cleaner their stormwater sampling results. This translates immediately to less time for the environmental team, less risk, and lower costs….what business does not want that.
If you had a rough start and your facility begins to enter Level 1 and Level 2, training on additional BMPs or more structural BMPs like treatment systems is required to be completed by a Qualified Industrial Stormwater Practitioner (QISP). The importance of this training grows at this stage because the costs of non-compliance can be severe (lawsuits, fines, and even jail…..yup, if you don’t complete your inspection forms or collect samples and falsify them later, you might be committing fraud….). Even when facilities remain in Baseline status, training should be done at least once a year and should, at minimum, cover BMPs.
We highly suggest even if you are in Baseline, and want to stay there, that you have a stormwater professional conduct the training. We suggest that a professional trainer do your annual stormwater training (stormwater team and general awareness) and that the in-house environmental or environmental, health and safety (EHS) staff conduct quarterly “tailgate” style sessions, which should be tailored around a topic that keeps coming up or an issue identified during inspections.
In California under the Industrial General Permit (IGP) monitoring of the facility is required on a monthly basis as well as during sampling events. Monthly monitoring is conducted during a dry day so that any issues or non-stormwater discharges (NSWD) that could cause exposure of industrial pollutants to stormwater can be fixed prior to a rain event.
Sampling visual observations are monitoring of the stormwater that is discharged during sample collection. Every time a facility collects a sample the stormwater must be monitored for signs of pollutants such as; odor, oily sheen, discoloration, turbidity, trash/debris, suspended materials, floating materials, and non-stormwater discharges. Monitoring of the samples can give clues to what pollutants might be in the stormwater (i.e. oily sheen could cause oil and grease exceedances) and where they could be sourcing from.
A practice inspection on the facility is a great way to end a training session, where the instructor can walk with the stormwater team (PPT) and point out some problem areas or how BMPs can be improved. It is the hands-on site-specific application of the permit knowledge from the classroom that really can drive home the requirements for the team. As the trainer, you want to challenge the stormwater team to point out potential pollutants and BMP deficiencies as part of this site walk to get them comfortable with their responsibility while in a learning environment. The goal here is to empower staff to conduct monitoring, especially routine monthly or quarterly inspections, in a thorough insightful manner to prevent problems appearing in the stormwater sample results.
Sampling is where the BMPs and monitoring all come together to decide what additional actions need to be taken, if any. Even when BMPs and monitoring are implemented correctly, proper sampling techniques need to be taught and implemented to ensure the stormwater sample is truly representative of what is discharging. Sampling techniques is arguably the most important training topic, because if stormwater sampling is done incorrectly, the implementation of BMPs and visual monitoring will not show up in the stormwater sample results. For example, if there was never training on how to properly collect a sheet flow stormwater sample from a dirt surface, the soaking wet dude or dudette doing the sampling might scoop up the dirt into their lab bottles…..and cause a TSS exceedance. Though this is not necessarily “representative” of what their stormwater discharge is from the facility, the samples must still be reported and could cause the facility to enter Level 1 or Level 2 all because they were not trained on proper sampling techniques.
During training, stormwater team members should see how to collect samples correctly and where there could problems. In addition, if pH meters are used, calibration should be covered. If you are using litmus paper for pH measurement, the training should include a discussion of what could signal problems (e.g. pH less than 6 or over 9) and why litmus paper can be read incorrectly (e.g. it’s old, it got wet, it is too dark out, you are color blind, etc.).
Training is one of the most important stormwater best management practices (BMPs) at a facility, and is why it should be conducted annually. All staff should, at minimum, be aware that the facility is under a stormwater permit and that there are BMPs that everyone is required to abide by, if not implement. The stormwater team needs to know about BMPs, visual monitoring, sampling, reporting, and the risks of non-compliance or mistakes. A mix of classroom/online and field-based training is usually most effective at reinforcing key points and applying the principles to their facility. Choosing the right stormwater professional to conduct the training is key to ensuring compliance and correct techniques for BMP implementation, monitoring, and sampling. If your trainer is not bringing the heat (passion) for stormwater and your training looks like nap time for pre-schoolers, it is time to get real and change things up. Stormwater training can be fun, scary, and informative all at the same time.