How do I create a Stormwater Pollution Prevention Plan (SWPPP)?
The Stormwater Pollution Prevention Plan (SWPPP) is your plan and guide to understanding and managing stormwater runoff. This page will tell you what needs to be in your SWPPP and to help you find resources/ideas to meet those requirements.
Step 4a: Review the general requirements of the SWPPP
There are 13 general requirements of the SWPPP:
- Create, implement and maintain SWPPP.
- Update SWPPP before applying for permit coverage.
- Modify previous versions of SWPPPs before applying for permit coverage.
- Identify qualified personnel who are responsible for the implementation and management of the SWPPP.
- Include a section dedicated to mobile activities (if applicable).
- Include additional sector-specific SWPPP requirements from part VII of the permit.
- List personnel appropriately trained to conduct inspections.
- Include records of all inspections conducted.
- Include information pertaining to maintenance to Stormwater Control Measures.
- Document the elimination of unauthorized non-stormwater discharges.
- Include documentation of Spill Prevention and Response Plan.
- Include the Mercury Minimization Plan (if applicable).
- Include Employee Training Program information.
Step 4b: Review additional specific requirements of the SWPPP
There are 7 specific SWPPP requirements:
- Include information about compliance with Stormwater Control Measure requirements.
- Provide a facility description.
- Include facility map(s).
- Provide a facility assessment of activities and materials.
- Include modification requirements-review SWPPP annually and document modifications.
- Availability Requirements-make sure the SWPPP is available to the MPCA upon request.
- Reporting Requirements and Submittals-reflect conditions and changes in the annual report.
For more information, see Part IV of the Industrial Stormwater Multi-Sector General Permit.
Step 4c: Utilize MPCA’s Guidance Tools to create or update your SWPPP
- Template: Industrial Stormwater Pollution Prevention Plan (wq-strm3-28)
- Industrial Stormwater Pollution Prevention Plan checklist (wq-strm3-57)
Step 4d: 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 offer 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 4e: Install BMPs
Assess which BMPs you selected before you begin implementing them. Ask yourself these questions:
- Which ones are the easiest to implement, or take the least amount of time to install?
- Which ones will require the most time/money?
- Which ones will have the most significant impact on improving your stormwater runoff?
It may happen that you will want to choose different BMPs, once you start installing or implementing them. That’s okay! Just be sure to update your Stormwater Pollution Prevention Plan. Information on installing BMPs depends on which BMPs you choose. Check out MPCA's guidebook to get a sense of how to install structural BMPs: Industrial Stormwater Best Management Practices Guidebook (wq-strm3-26)
Start with the simple BMPs first, such as moving materials indoors or under cover.
Many of the recommendations in Step 2: No Exposure will be helpful as non-structural BMPs and simple structural BMPs. Remember, non-structural BMPs must be implemented before applying for permit coverage; facilities have the first full year after applying to implement structural BMPs.
Step 4f: Review additional guidance documents
BMP Links/guidance documents:
- Industrial Stormwater Best Management Practices Guidebook (7/2015)
- Best Management Practices for Industrial Stormwater Pollution Control (Sacramento County, California)
- Best Management Practices for Stormwater Discharges Associated with Industrial Activities (Oregon, 2013)
- EPA’s Developing Your Stormwater Pollution Prevention Plan, a Guide for Industrial Operators