Best Management Practices
Wilson understands that a sound pollution prevention approach is one of the most-effective means of controlling the discharge of pollutants in a storm water runoff from industrial facilities into surface waters.
Wilson’s storm Water Pollution prevention plans generally contain various best management practices (BMPs), which may be general, industry-specific, or site-specific. The major objectives of these plans are:
- To identify sources of pollution potentially affecting the quality of storm water discharges associated with industrial activity from the facility;
- To describe and ensure implementation of practices to minimize and control pollutants in storm water discharges associated with industrial activity from the facility and to ensure compliance with the terms and conditions of the general permit.
The general permits prescribe a four-step process for meeting these objectives:
- Formation of a team of qualified plant personnel who will be responsible for preparing the plan and assisting the plant manager in its implementation;
- Assessment of potential storm water pollution sources;
- Selection and implementation of appropriate management practices and control methods; and
- Periodic evaluation of the ability of the plan to prevent storm water pollution and comply with the terms and conditions of the permit.
How does an industrial facility Operator determine whether it needs to obtain an NPDES Storm Water Permit?
Step 1. Determine whether the facility or site discharges storm water to a separate storm sewer system (MS4) or to a stream, lake or other waters of the waters of the United States (check EPA definition, it covers almost everything) If it discharges to one or both, proceed to Step 2, otherwise no permit is needed.
Step 2. Determine if the facility’s industrial activities are listed among the eleven Categories of Industrial Activities (follow link below to find your category) , as defined by the federal regulations. If its activities are listed, proceed to Step 3, otherwise no permit is needed.
Step 3. Determine if the listed facility or site may qualify for an exemption or waiver under the federal regulations.
- No Exposure. Facilities identified as “light industry” (Category (xi)) may be eligible to claim a condition of “no exposure” and be exempted from permitting. No exposure basically means that everything including storage of equipment is indoors. Construction activities are not included.
- ISTEA Moratorium. Is for municipalities with populations less than 100,000 (with some exceptions).
Wilson Environmental has standard templates for writing SWPPPs and can help you come into compliance if you need a storm water permit.
If your facility also needs an SPCC Plan, Spill Prevention Control and Countermeasures Plan, the information in this should overlap with your SWPPP.