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Thinking Ahead with SWPPPs

By Ronald Etter, Environmental Group Manager, Koontz Bryant Johnson Williams

The permitting process can be complex and differs often by locality and project type. One of the key elements to obtaining a land disturbance permit is a SWPPP – but what does that mean for developers and construction teams? A SWPPP (pronounced “Swip”, aka SW3P or simply the stormwater plan) is exactly what it says it is, a Stormwater Pollution Prevention Plan aimed at protecting the surrounding area of harmful run-off during construction.

It is important to note that SWPPPs are required before a General Construction Permit (GCP) is issued. The land disturbance permit will not be issued until the Virginia Department of Environmental Quality (VDEQ) provides coverage under the GCP. It is not just construction activities that require a SWPPP. Planning for any project that will need a Virginia Pollution Discharge Elimination System (VPDES) permit and must include a SWPPP.

 

Typical projects and facility types include:

  • Facilities subject to effluent discharge standards
  • Heavy manufacturing facilities
  • Coal and mineral mining
  • Oil and gas exploration and processing
  • Hazardous waste treatment storage and disposal facilities
  • Landfills and industrial waste dumps
  • Metal scrap yards, salvage yards, auto junk yards and battery reclaimers
  • Steam electric power generating plants
  • Transportation facilities that maintain vehicles or clean equipment
  • Airport deicing operations
  • Domestic sewage treatment works processing more than 1 million gallons a day
  • Light manufacturing
  • Construction projects that require a General Construction Permit

Understanding the requirement is the first step, but what is a SWPPP? Basically it is a “how to” manual for site operators that sets out the practices and programs to be used to keep stormwater pollution to a minimum during the project. SWPPPs are site-specific and “living documents” that should be reviewed and modified on a regular basis as activities on a site change.

 

In general, SWPPPs include:

  • A site description (general location maps, site maps, etc.)
  • Descriptions of activities that could cause pollution
  • Best Management Practices (BMPs)
  • Control measures for preventing spills and minimizing hazards
  • Spill response plans
  • Procedures for conducting inspections and monitoring
  • A process for training employees
  • Details of the site’s stormwater pollution prevention team, including names or titles of all members.

The details of the stormwater permitting process vary by area and are controlled by the local authorities and the VDEQ. Some projects may have more stringent requirements, such as specific Best Management Practices that must be implemented for discharging into an impaired waterway. Other site conditions can result in more frequent inspections or required detailed engineered plans or other submittals. The SWPPP should be viewed as a toolbox filled with information about your site and details on the specific procedures and structures that will be used to insure that the stormwater leaving the site is as clean as possible. A copy of the SWPPP notebook must be kept on site and be publicly available during construction and activity on site. Understanding its purpose and implementing the SWPPP can help prevent costly delays and protect the environments where we all live, work and play.

To learn more about stormwater permits and stormwater plans and how they impact your location, operation, or facility, click here to send us an email, or give us a call at 804.200.1920. We look forward to talking with you.