How to Develop a Stormwater Pollution Prevention Plan

Stormwater managers and construction site operators are responsible for making sure pollutants, such as oil, grease, nitrogen, ammonia, feces or food waste, don’t enter waterways where they can cause harm to humans, animals, property and the environment. To address these risks, it’s essential to evaluate how your existing facility or upcoming construction project might impact the environment or the health and safety of others. As part of this effort, develop and implement stormwater pollution prevention plans alongside stormwater management best practices to ensure your site is prepared to effectively manage the pollution sources you store or generate.

What Is a Stormwater Pollution Prevention Plan (SWPPP) and Who Needs One?

A Stormwater Pollution Prevention Plan is a document that outlines how a facility or construction site will prevent harmful stormwater runoff from entering lakes, rivers and other bodies of water used for drinking, swimming or fishing. Construction site operators and facilities with industrial activity need an SWPPP. U.S. Environmental Protection Agency (EPA) issues general permits for stormwater discharges associated with industrial activity, under the National Pollutant Discharge Elimination System (NPDES) program (as defined in 40 CFR 122.21 and 40 CFR 122.26).

When Is an SWPPP Required?

Developing your stormwater pollution prevention plan has a requirement to obtain a general permit. An SWPPP identifies potential stormwater pollution sources and outlines actions a facility or construction site will take to prevent—and if necessary, remove—pollutants and chemicals from nearby waterways and storm drains.

Developing Your Stormwater Pollution Prevention Plan

Before you start your Stormwater Pollution Prevention Plan, the EPA recommends you understand which type of permit you may or may not be required to obtain for your facility or construction site. Learn more about permit coverage, including situations that do not need permits. Here are the EPA’s SWPPP requirements and recommended steps to develop your plan—including SWPPP BMPs (best management practices):

1. Site Assessment and Planning

   Evaluate your site. Identify features and activities that produce pollutants as well as all nearby waterways and storm drains. Outline goals and methods to protect water quality as part of developing your stormwater pollution prevention plan.

2. Erosion and Sediment Control

   Minimize soil disruption, protect slopes, retain sediment and prevent water from flowing through projects where it can become contaminated. Protect storm drains and inspect them regularly as part of stormwater containment strategies.

3. SWPPP BMPs (Best Management Practices)

   Define good housekeeping practices to prevent stormwater waste, paint runoff and other contamination at your site. Develop a spill prevention and response plan, provide for waste management and establish proper equipment practices for fueling and maintenance.

4. SWPPP Inspections, Maintenance and Recordkeeping

   Develop a plan to maintain your SWPPP BMPs. They must always be in good working order. Create an inspection schedule and write a report after each inspection. Maintain copies of your reports and keep data for at least three years. Incorporate inspections to ensure your stormwater containment measures remain effective.

5. Classification and Notification

   A facility executive or construction site operator must sign the permit application form, called a Notice of Intent (NOI). Keep a copy of your NOI with your stormwater pollution prevention plan. Submit your NOI to the EPA to obtain authorization for safe stormwater discharge.

6. SWPPP Implementation

   Train staff and subcontractors to comply with your SWPPP BMPs and pollution prevention practices. Constantly re-evaluate your site and stormwater management activities. Conduct your own inspections during rain events to detect problems and support your stormwater pollution prevention plans.

7. Final Stabilization and Permit Termination

   If you are a construction site operator whose project is ending, you must achieve stabilization before vacating the site. This may include installing grass, trees, or permanent stormwater controls. Ensure your stormwater pollution prevention plan includes measures for this stabilization stage. You may then terminate your permit with the EPA.

Preparing for an SWPPP Inspection

Annual site compliance inspections are required by general permits and must be conducted by qualified, SWPPP-trained personnel. Some states offer trainings that prepare your organization’s designated personnel to conduct SWPPP inspections. Other states require a state-certified inspector to conduct the audit. For example, in California, a Qualified SWPPP Developer (QSD) or Qualified SWPPP Practitioner (QSP) must inspect your SWPPP BMPs weekly or after each rainfall. You can prepare for a stormwater pollution prevention plan inspection by understanding how the inspector evaluates your site and addressing areas of concern before the inspection. Evaluators must complete the following stormwater inspection checklist:

1. Inspect stormwater drains for pollutants entering receiving waters
2. Evaluate good housekeeping measures, preventive maintenance and spill prevention
3. Evaluate structures, sediment controls and other best management practices
4. Prepare a report summarizing inspection results and next steps
5. Certify if the facility complies with the permit
6. Procure a signed report to be kept on file