Storm Water Pollution Prevention Plan - SWPPP
The heart of a stormwater permit is the Storm Water Pollution Prevention Plan (SWPPP), which contains the best management practics (BMPs). Determining what constitutes compliance with the SWPPP and BMPs can be difficult.
The SWPPP focuses on two primary requirements: (1) providing a site description that identifies sources of pollution in stormwater discharges; and (2) identifying and implementing appropriate measures to reduce potential discharges. The actual details of the BMPs that meet these goals vary widely, depending on local standards and site conditions (BMPs often also fulfill local erosion control requirements as well). Basically, BMPs are a combination of structural and nonstructural measures. Structural measures involve the installation of devices to divert, store or limit runoff, such as sediment traps, inlet protection, or silt fences. Non-structural measures minimize disturbance by specifying good housekeeping practices, such as garbage removal and street sweeping etc.. Stabilization of disturbed soil by covering or maintaining an existing cover is also a standard requirement. This includes seeding, mulch, straw and other materials to prevent soil erosion.
A key aspect of the general permits is the requirement for routine inspections (at least every 7 days and after major storm events) and maintenance of the controls. Once an inspection has been performed, an inspection report must be retained for up to three years after the permit expires or is terminated. The report must identify any incidents of non-compliance with permit conditions or, if none were found, a certification that the site is in compliance with the SWPPP. This requirement is very important as the general permits also require that the SWPPP be amended if inspections or investigations by state or federal officials determine that the SWPPP is ineffective in eliminating or significantly minimizing pollutants in storm water discharges from the construction site. Hence, not only must the existing BMPs be maintained, but their effectiveness must be continually evaluated and changed if they are no longer effective.
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