Show All Stormwater Program for Industrial Activity: Steps to Compliance
Step 12: Modify/add new BMPs, if needed
Did not pass Benchmark Monitoring Requirements: Now what?
If you did not pass your benchmark monitoring after the end of “year 2 monitoring,” you have year 3 to make modifications to your structural and non-structural BMPs, and update your SWPPP before taking stormwater samples again in year 4. You may need to upgrade or add different BMPs based on monitoring results.
How do I modify/add new BMPs?
First, determine which parameters you will be required to re-sample for, and identify the significant material or industrial activity that the pollutant is connected to. Can you move that material or conduct that activity indoors or within a permanent, storm-resistent shelter? If not, are there other BMPs you can add to minimize or eliminate the contaminants of concern?
If a facility has a stockpile of rusted metal, and the previous BMP of routine sweeping of rusted metal parts didn’t allow the facility to pass their benchmarks because of this material and this BMP, the facility could consider putting the rusted metal into a dumpster or other container so that run-on of stormwater does not come into contact with these materials. Precipitation would still fall into an open dumster; be sure to keep the dumpster closed and holes plugged.
Think of other areas at your facility that may be causing you to not pass your benchmark monitoring requirements and consider what structural and non-structural BMPs you may want implement to help pass your benchmark monitoring requirements. Take a look at the Industrial Stormwater BMP Guidebook for pollutant-specific BMP options, or take a look at the sector-specific guidance materials within the Step 7: Sector-specific requirements, guidance Web page.
Benchmark Monitoring and Impaired waters
Do you discharge to an impaired water but did not pass your benchmark monitoring requirements?
- No later than 30 days past the discovery of the exceedance, modify your SWPPP and document all corrective actions, including improvements to BMPs, necessary to meet the applicable benchmark values during fourth year monitoring. Also include any changes in BMPs and the timeframe for implementation of all corrective actions. Modifications and upgrades of the SWPPP should be within this time frame
- No later than 60 days after discovery of the exceedance, implement necessary non-structural BMPs.
- No later than 180 days after discovery of the exceedance, implement structural BMPs. If the Permittee is unable to complete implementation of structural BMPs within 180 days, the Permittee shall submit a plan to the Agency that includes justification why this requirement cannot be met and a specific schedule for completion. The plan shall be submitted no later than 180 days after discovery of the exceedance.
The following additional resources may help provide information on different BMPs for your facility:
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Resource |
Helpful aspect of resource |
|---|---|
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State Stormwater BMP Manuals (EPA, 2009) |
State-by-state listing of BMP manuals, guidance documents and fact sheets. |
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Stormwater Best Management Practices in an Ultra-Urban Setting: Selection and Monitoring (US Department of Transportation) |
Many structural BMP ideas with diagrams, pollutant removal rates and design and cost considerations. |
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Commercial/Industrial/Manufacturing BMPs by type of Activity (Municipal Research and Services Center of Washington, 2009) |
Series of fact sheets with BMP ideas for specific types of activities/sectors. |
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Series of fact sheets for over a dozen specific industrial activities. |
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University of Minnesota Extension Service Stormwater Education Program |
Provides information on training, manuals, and links to related water quality programs. |
