Taking a Dip in Your SWPPP What is a SWPPP? Welcome back to our training sessions Part 2 Taking a Dip in Your SWPPP

Training Modules What’s the concern?  What is a SWPPP? Spill prevention & response Materials Management Good Housekeeping Our last session, we went over the concept of watershed, why there is concern over runoff, and then looked at how runoff flows from our facility.

What is a SWPPP? Relation to Clean Water Act & RIPDES Contents of site-specific SWPPP Exercise: What do we do outdoors? Today we’re going to go over just what a SWPPP is: where the requirement to develop one comes from and what it should contain. We’ll end with an exercise that should help relate our SWPPP with what we learned in the last session on how water flows through this site.

Storm Water Pollution Prevention Plan Site (Facility) Specific Facility Staff all have a role in implementation Not to keep you in suspense any longer, SWPPP stands for Storm Water Pollution Prevention Plan. Each DPW, DOT or other institution’s garage should have a site specific plan, and all staff are involved in getting the plan implemented

National Stormwater Discharge Program Phased approach by EPA Phase I – 1990 – large cities Phase II – 1999 – smaller municipalities & “public bodies” This all started with the Federal Clean Water Act; in 1987 Congress amended the Act to require implementation of a comprehensive national program for addressing storm water discharges. The second phase, which began in 1999, requires permits for storm water discharges from most small municipalities and also public bodies, such as RIDOT and URI. Phase II is why we are getting this training today!

GENERAL PERMITS under Rhode Island Pollutant Discharge Elimination System Storm Water Discharge Associated with Industrial Activity (Multi-Sector) Storm Water Discharge from Small Municipal Separate Storm Sewer Systems (MS4) That’s right, storm water is now considered as serious as discharge pipes from a factory, because of the concerns that were noted in the first training module. In RI, DEM is delegated to run the storm water discharge program. RIDEM has developed “General Permits” covering different aspects of the program. Affected businesses, agencies and organizations apply to be covered under the permits, submitting a Plan to show how they will meet the requirements. Public Works garages fall under at least 2 stormwater General Permits.

General Permit Requirement Implement a site-specific Storm Water Pollution Prevention Plan (SWPPP) developed for each facility with “industrial” activity Because we store and handle materials, and maintain vehicles & equipment, the garage has “industrial” activity. So the facility needs to have and implement a site-specific Storm Water Pollution Prevention Plan.

SWPPP requirements Facility Associated with a MS4 Multi-Sector Section IV.B.6.b.5. of MS4 General Permit (Good Housekeeping) Multi-Sector Section IV of Multi-Sector General Permit The requirements for the SWPPP are similar under either General Permit. Because these training modules were developed to help implement the “MS4” program, today’s review of what’s in the Plan follows the SWPPP requirements of the MS4 General Permit. What’s most important to remember is that this facility cannot legally operate without a SWPPP that each one of us implements on a daily basis. So what is required to be in the SWPPP?

SWPPP Contents Site-specific Describe BMPs (Best Management Practices) Structural and non-structural controls for reducing or eliminating discharge of pollutants from operations and facilities Storm water-related: Outdoors Overall, the SWPPP is a site-specific description of the controls for reducing or eliminating the discharge of pollutants from the facility. As we go through, keep in mind that the focus of this is storm water discharge, in other words what’s happening outdoors. Note to trainer: You may want to distribute copies of your facility’s SWPPP (or at least the Table of Contents), so staff can see how remaining presentation relates.

SWPPP must describe COORDINATOR Individual responsible for coordinating and implementing practices, inspections, evaluations and updates The first “control” that must be described is who’s in charge of making sure the SWPPP is developed, implemented, evaluated, updated and reported on. RIDEM is not just looking for a title; they want names, phone numbers and a description of duties as well.

SWPPP must describe FACILITY Address Number of acres Size of impervious areas Number of buildings & what used for Number & types of vehicles Number & location of outfalls Number & location of catch basins There should be a description of the physical facility itself: where it is, how big the property is, how much of it is paved or rooftop, how many buildings there are and what they’re used for. The SWPPP should specify which areas house vehicle maintenance, washing, fueling or sand/salt storage. It should also list the vehicles on site, pipe outfalls and drainage ditches, and catch basins.

SWPPP must describe “EXPOSED” ACTIVITIES Past spills/chronic leaks Handling materials & wastes Fueling, washing, maintaining equipment Underground & above ground storage “Allowable non-storm water discharges” The SWPPP should then go on to describe everything that is done outdoors and where it is done, from dewatering catch basin cleanings to pumping gas to storing the snow plows. “Allowable” discharges should also be listed: things like flushing hydrants, spraying water for dust control, watering the lawn, or uncontaminated flow from footing drains.

SWPPP must include SITE MAP Location of buildings, storage areas & activities Location of drainage system, including BMPs Location of onflows of runoff from adjacent properties Receiving waters All of that information needs to be shown on a map, as well. And, by the way, doesn’t this list sound a lot like the maps we made in the last exercise?

SWPPP must describe MATERIALS & ACTIVITIES Assessment of potential of each to contribute pollutants to storm water discharges The SWPPP needs to describe those materials or activities that might be exposed to storm water, and assess their potential to pollute. The assessment should consider the toxicity and quantity of the potential pollutants, how likely they are to be in contact with storm water, and also the history of any significant previous leaks or spills

SWPPP must describe PRACTICES TO CONTROL POLLUTANTS Good housekeeping practices Preventive maintenance Existing/planned BMPs for activities How salt/sand piles are stored Operating procedures re. fuels Vehicle maintenance operations Erosion controls Other runoff management practices Spill prevention & response procedures Employee training Then we finally get to the actual Plan part: what practices are in place or will be implemented to control those potential pollutants identified in the previous sections. We’ll be going into greater detail on most of these in the remaining modules. And see “employee training” here at the end? We’re implementing our SWPPP right now!

SWPPP must describe PROCEDURES FOR EVALUATION OF COMPLIANCE Visual monitoring Annual site inspections Record keeping & reporting The SWPPP needs to describe routine visual inspections to check for leaks & spills, looking at outfalls after a storm at least quarterly, and a full inspection at least once a year. It also needs to describe how records of spills, leaks, maintenance activities, staff training, etc. will be kept.

SWPPP must be AMENDED as operations/materials/practices change And it’s all subject to change if operations change, or we missed something, or the current plan just isn’t working.

Typical Table of Contents INTRODUCTION MAINTENANCE OF THE PLAN RISK IDENTIFICATION AND ASSESSMENT/ MATERIAL INVENTORY STORM WATER MANAGEMENT CONTROLS COMPREHENSIVE SITE COMPLIANCE EVALUATIONS CERTIFICATION A typical SWPPP table of contents may look like this. In the next training modules, we’ll be looking more in-depth at those stormwater management controls (point to) for which each individual staff member has some responsibility. But we’ll wrap up today by some brainstorming in the risk identification and assessment area (point to) Note to trainer: If you are handing out your SWPPP’s Table of Contents, change the script above to refer to your Table of Contents.

Public Works Facility Operations & Maintenance for Stormwater Management: Employee Training Brought to you by: So, that’s it for show & tell. Now it’s time for another exercise This program was developed by the Southern Rhode Island Conservation District in partnership with the URI Cooperative Extension RI NEMO Program and the Rhode Island T2 Center. Funding was provided by the RI Department of Environmental Management and the RI Department of Transportation under the Phase II Stormwater Education and Outreach Program.

Exercise! What activities are performed outdoors? Locate on map Let’s see if our SWPPP has captured everything we have and do outdoors. Let’s start by listing all our activities See Exercise sheet