How do I comply with the annual and monthly permit requirements?
This step will give you guidance on how comply with annual and monthly requirements, including employee training, filling out the annual report, and conducting monthly inspections
Step 8a: Implement annual employee training
Employee training should be a major component of any SWPPP. Employee training is also an integral part of other control measures. In order for the SWPPP to be effective, employees should be informed about stormwater treatment and control measures at the facility. They should understand their role in stormwater pollution prevention at the facility. Employee training for stormwater issues may be done in conjunction with other training programs.
The purpose of a training program is to teach staff at all levels of responsibility the components of the SWPPP. When properly trained, staff are more capable of preventing spills, responding safely and effectively to an accident, and recognizing situations that could lead to accidents. Employee training as a control measure is an ongoing process, which may take some time to implement. All new employees should be trained as soon as possible. The complexity of the BMPs, the turn-around time of the employees, and the effectiveness of the training will affect how often training sessions will need to be scheduled.
Document employee training
Be sure to document within the SWPPP a training schedule and the planned training frequency. Include a record of the trainer and the trainer’s organization (internal or external), as well as the names of trained individual(s) and dates that the individual(s) received training. This documentation can be either in the SWPPP or in a separate record.
The following individuals should be trained at least annually:
- Employee(s) overseeing implementation of, revising, and amending the SWPPP;
- Employee(s) performing installation, inspection, maintenance and repair of BMPs;
- Employee(s) who work in areas of industrial activity subject to the permit; and,
- Employee(s) who conduct stormwater discharge monitoring
Training should cover the components and goals of the SWPPP and include:
- Spill response procedures
- Good housekeeping
- Material management practices
- Stormwater discharge monitoring procedures
- BMP operation and maintenance
Consider these training suggestions:
- Frequently conduct proper training of employees in good housekeeping techniques and proper safety methods to reduce the potential that materials or equipment will be mishandled. It also reduces the chance of injury, loss of materials, and release of contaminants.
- Incorporate information sessions on good housekeeping practices into employee training programs.
- Discuss good housekeeping at employee meetings.
- Promote pollution prevention concepts through posters, brochures, newsletters, etc.
- Post bulletin boards with updated good housekeeping procedure tips and reminders.
- For more information, check out these training requirements: Industrial Stormwater: Annual employee training requirements (4/2015)
Step 8b: Consider attending a University of Minnesota Training Opportunity
The MPCA has joined with the University of Minnesota to offer a variety of training opportunities. For class options and locations, visit the University of Minnesota Erosion and Sediment Control Certification Program.
Upcoming training dates and classes:
- Development of your ISW Annual Training Workshop: May 3, 2018, Chanhassen
- Development of your ISW Annual Training Workshop: May 16, 2018, White Bear Lake
Register today as workshops often fill up 2-3 weeks before the class is held. For additional information or to register for any of these workshops, please visit the University of Minnesota Erosion and Stormwater Management Certification Program website at: www.erosion.umn.edu.
Looking for sector or industry-specific training? Contact The U of M Erosion and Stormwater Management Certification Program directly: 800-646-2282 or 612-625-9733 or email: email@example.com.
Step 8c: Review other states’ Employee Training Resources
- Michigan Department of Natural Resources and Environment Industrial Stormwater Training Manual
- Michigan Department of Natural Resources and Environment Industrial Stormwater Training Video
Step 8d: Fill out the annual report
How do I fill out and submit the annual report?
With annual reports, not only does the information help MPCA understand what is going on at specific facilities, but it gives you an understanding of what’s happening at your facility in regard to industrial stormwater.
What is required of the 2017 Annual Report?
Each Annual Report needs to cover those portions of the previous calendar year that the facility was authorized to discharge industrial stormwater. The Annual Report needs to include the following information:
- A summary of inspection dates, findings, and any BMP maintenance conducted by the Permittee
- If applicable, the results of inspection requirements involving oil and grease
- A confirmation that the SWPPP accurately reflects facility conditions
- A confirmation that newly-exposed significant materials (if any) have been identified and that the SWPPP has been modified to address them
- A confirmation that the Permittee has conducted a review of impaired waters and that the SWPPP has been modified to address applicable permit requirements of Benchmark Monitoring Requirements, if necessary
- A confirmation that the Permittee has conducted a review of USEPA approved TMDLs that may apply to the facility and that may require the Permittee to comply with TMDL requirements
- A description of any SWPPP modification made
- Date(s) of staff training, required at least once per calendar year
- A list of all spills and leaks that occurred at the facility
- If applicable, a summary of all mobile industrial activities conducted by the facility. The summary shall include a description, locations where the mobile industrial activity occurred, and length of time the mobile industrial activity operated at each location.
- To be filled out for the previous calendar year. The 2016 Annual Report is due March 31, 2018.
Tip: BMP maintenance is important and should be documented within your SWPPP and noted on the Annual Report. Examples of BMP maintenance include: remove debris and litter, vegetation management, Structural BMP maintenance, repair mechanical components, etc.
Step 8e: Conduct monthly inspections
All facilities will have to perform monthly inspections of their facility. Inspections must include the following:
- An evaluation of the facility to determine that the SWPPP accurately reflects site conditions as described in Part IV.B.1-4. At a minimum, inspect storage tank areas, waste disposal areas, maintenance areas, loading/unloading areas, and raw material, intermediate product, by-product and final product storage areas
- An evaluation of all structural and non-structural BMPs to determine effectiveness and proper function
- An evaluation of the facility to determine whether new exposed significant materials or activities have been added to the site since completion of the SWPPP
- During an inspection conducted during a runoff event, an evaluation of the stormwater runoff to determine if it is discolored or if other contaminants are visible in the runoff (e.g., oil and grease).
NOTE: At least one inspection must be performed during a runoff event.
Step 8f: Document monthly inspections
All inspections shall be documented and the following information shall be stored with the SWPPP and contain the following:
- Inspection date, time, and weather conditions
- Inspector name
- Inspection findings
- A description of any necessary corrective actions and a schedule for corrective action completion
For more information and guidance, check out the Industrial Stormwater Site Inspection Form (2/15)
Step 8g: Conduct impaired waters assessment
Every year, permittees should assess whether or not the water(s) they discharge to is impaired. No later than 180 days following the approved listing of the impaired water, a facility shall begin the additional monitoring for the pollutant(s) of impairment or its appropriate surrogate. See part V of the Multi-Sector General Permit for more information about monitoring requirements relating to impaired waters and visit the Maps of Impaired Waters search tool for more information on impaired waters.