Stormwater Program for Industrial Activity: Steps to Compliance

Step 5: Create SWPPP, choose BMPs

Step 5a: Review the general requirements of the SWPPP:

There are 13 general requirements of the SWPPP:

1. Create, implement and maintain SWPPP.
2. Update SWPPP before applying for permit coverage.
3. Modify previous versions of SWPPPs before applying for permit coverage.
4. Identify qualified personnel who are responsible for the implementation and management of the SWPPP.
5. Include a section dedicated to mobile activities (if applicable).
6. Include additional sector-specific SWPPP requirements from part VII of the permit.
7. List personnel appropriately trained to conduct inspections.
8. Include records of all inspections conducted.
9. Include information pertaining to maintenance to Stormwater Control Measures.
10. Document the elimination of unauthorized non-stormwater discharges.
11. Include documentation of Spill Prevention and Response Plan.
12. Include the Mercury Minimization Plan (if applicable).
13. Include Employee Training Program information.

Step 5b: Review additional specific requirements of the SWPPP:

There are 7 specific SWPPP Requirements:

1. Include information about compliance with Stormwater Control Measure requirements.
2. Provide a facility description.
3. Include facility map(s).
4. Provide a facility assessment of activities and materials.
5. Include modification requirements-review SWPPP annually and document modifications.
6. Availability Requirements-make sure the SWPPP is available to the MPCA upon request.
7. Reporting Requirements and Submittals-reflect conditions and changes in the annual report. 

For more information, see parts IV of the Industrial Stormwater Multi-Sector General Permit.

Step 5c: Utilize MPCA’s Guidance Tools to create or update your SWPPP:

SWPPP tools

• Industrial Stormwater Pollution Prevention Plan Template (PDF Version) (wq-strm3-28)  (04/10)
• Stormwater Pollution Prevention Plan Checklist (PDF Version) (wq-strm3-57) (06/10)

Step 5d: Choose Best Management Practices (BMPs)

How do I choose BMPs?

Identifying BMPs that you will install at your facility is a SWPPP requirement.  You are not required to have structural BMPs implemented by the time you apply for permit coverage.  You have an entire year from the time you apply to install them, but it is recommended to install them as soon as possible. You must document in your SWPPP which BMPs you will be installing at your facility. 

There are 3 different types of BMPs you may choose to implement at your facility:

• Non-structural BMPs (good housekeeping, moving products/wastes indoors, etc)
• “Off-the-shelf” structural BMPs (simple, easy-to-install BMPs)
• Structural BMPs (more complex, may take time and/or money to install)

Many of the recommendations in Step 2 gave some ideas for non-structural BMPs and simple structural BMPs that can be implemented at your facility. Keep a few things in mind as you review the suggestions:

• Are the BMPs appropriate for my facility size/industrial activity/significant material?
• Are the BMPs I’ve chosen the most cost effective to install?
• Is there another BMP that is simpler/cheaper to get the job done?
• Does the BMP have to be maintained and do I have the staff/time to maintain it?
• Is there something I can do to eliminate (prevent) precipitation from coming in contact with my industrial activity/significant material in the first place?

Again, think No Exposure!

Consider simple structural BMPs. The Minnesota Erosion Control Association has a list of structural BMPs and companies that install them.

Step 5e: Review additional guidance documents

BMP Links/guidance documents: 

• Industrial Stormwater Best Management Practices Guidebook (wq-strm3-26) (8/10)
• Best Management Practices for Industrial Stormwater Pollution Control (Sacramento County, California)
• Best Management Practices for Stormwater Discharges Associated with Industrial Activities (Oregon, 2001)
• Industrial and Commercial Handbook for selecting and implementing BMPs (California, 2004)

Go to Step 6