The Environmental Protection Agency developed the NPDES permit program to monitor pollutant stormwater discharges from Construction, Industrial and MS4 activities. The goal of the program is to protect our waters and improve water quality. To do this, the NPDES permit program requires each activity to develop and implement a compliance management plan which may include a SWPPP, implementation of control measures, permit coverage, monitoring, maintenance, and stabilization if appropriate.
Industrial Stormwater Management Plan
The industrial stormwater permit (MSGP) requires each Operator to develop a site-specific assessment (SWPPP) of potential pollutant sources and controls measures the facility will implement to minimize the discharge of pollutants in stormwater runoff. The NPDES permit program for industrial activities regulates 11 categories, including but not limited to oil and gas exploration and processing, automobile junkyards, landfills, and mineral mining operations. The plan also addresses maintenance requirements, inspections, training, and periodic reporting.
The factors to consider for each industrial SWPPP vary significantly from site to site and activity to activity. E2RC works with each site Operator to review the factors at each location to develop an effective SWPPP. E2RC will coordinate with each industrial site to perform the varying reporting requirements such as the quarterly visual inspections and annual reporting. E2RC rounds out the compliance management plan by identifying and implementing structural controls if needed, and will work with the site Operators to monitor and perform necessary maintenance or stabilization measures.
Clean Water Act Compliance Plan
Clean Water Act Compliance Plans focus on coordination between the U.S. Core of Engineers, its 401/404 certification and permit, the controlling agency, and the contractor executing its work. They differ from stormwater management plans in their content and focus: this is the ‘what and how’ of the project work to ensure live streams and channels do not suffer negative impacts from the work. The plans provide a mitigation and response process to follow when the product of work – materials – enters the channel. Clean Water Act Compliance Plans also provide specifics for the equipment used in construction and the sequence of activities that will occur to complete the work. The plan concentrates on equipment, materials and performance methods to limit live stream and channel impacts from the work.
Spill Prevention, Control, and Countermeasure (SPCC) Plan
The goal of developing a Spill Prevention, Control, and Countermeasure (SPCC) plan is to prevent oil from reaching the waters of the U.S. Oil includes petroleum, fats, oils or greases from animal, synthetic oils, mineral oils, sludge, oil refuse and others. The SPCC rule covers facilities if 1) due to its location, the facility could reasonably be expected to discharge oil into or upon the navigable waters of the United States, 2) the aggregate aboveground storage capacity exceeds 1,320 U.S. gallons, or 3) the completely buried storage capacity exceeds 42,000 U.S. gallons. Operators that works with oils in a non – transportation manner may be subject to the SPCC rule.
E2RC can help you determine if your facility is indeed covered by the SPCC rule and, if so, work with you to develop a comprehensive SPCC Plan. The plan will include spill prevention practices, necessary controls, spill cleanup measures, and the methods used by your facility to prevent spills from reaching navigable waters. The SPCC Plan will be prepared using good engineering practices and certified by our professional engineers.