7 steps to develop an effective SWPPP plan

Construction activities contain many toxic materials that can pollute local water systems via stormwater runoff if not properly controlled.

Stormwater pollution prevention plans (SWPPP) are designed to prevent this type of pollution and keep your worksite legally compliant under federal and state law.

In this guide, we’ll explain the basics of SWPPP planning and provide insider tips to develop an SWPPP plan based on our experience helping companies develop SWPPPs for several years.

What Is an SWPPP?

A stormwater pollution prevention plan (SWPPP) is a site-specific document that outlines all construction activities that may lead to water pollution.

The main goal of an SWPPP is to outline a set of solutions to prevent sedimentation and erosion that leads to water pollution, as well as ways to prevent their discharge into public water systems.

SWPPPs include information about various controls used to prevent soil erosion–otherwise known as BMPs–and information about training procedures to ensure your staff is properly informed.

The Importance of SWPPP Compliance

An SWPPP plan is required to acquire an NPDES permit, which allows construction sites to discharge water safely away from their site into a public water system.

Without proper certification, construction managers will have no way to discharge stormwater as it develops throughout the season, effectively shutting down a project before it begins.

SWPPP compliance is primarily designed to protect the integrity of local ecological systems. However, stormwater pollution prevention goes beyond protecting water systems and includes local habitats and vegetation that may be impacted by stormwater runoff.

Who’s Responsible for Developing an SWPPP Plan?

According to the EPA, construction site operators must develop an SWPPP plan to acquire an NPDES permit.

A construction site operator is defined as anyone with overarching operational control over construction plans or day-to-day operational control.

Site operators can develop a plan independently or work with a company specializing in SWPPP compliance.

If multiple entities are involved in managing day-to-day operations on a construction site, then a permit may be required for each co-operator.

SWPPP Plan Requirements

Every state and municipality will have different SWPPP requirements and regulations, which you will need to research in advance. However, the essential components of any SWPPP plan will include:

  • A cover page
  • Contact information (Site managers and other relevant parties)
  • Record-keeping procedures (inspection and maintenance reports)
  • Construction activity description
  • Site map
  • Training procedures for staff
  • List of all pollution prevention team members (names and responsibilities)
  • Outlines of all potential sources of pollution
  • Outlines of all water discharge points
  • Descriptions of BMPS used to regulate discharge and pollution
  • Procedures for regular maintenance and inspection
  • Plans for reacting to spills and accidents
  • Any recorded plan amendments

Site operators can feel free to adapt this information for their own site-specific purposes and to copy any templates that allow them to be thorough. In addition, your state’s environmental department usually has templates you can borrow online to adapt your plant to.

Developing an SWPPP should take as little as one day, but it will require weekly or monthly ongoing inspections.

With that out of the way, let’s outline seven steps that you or your SWPPP specialist can take to help develop your SWPPP plan.

7 Steps of SWPPP Planning and Implementation

Step 1: Perform a Worksite Assessment

Perform a walkthrough of your entire construction site and write down every possible variable that may be a source of pollution or be disturbed during construction-related activities.

During the assessment, you will collect data on several variables including:

  • Site area (how large is the site)
  • Rainfall data (anticipated rainfall amounts)
  • Soil samples (sediment and contamination data)
  • Runoff coefficient (how much rain will become runoff)
  • Topographical sitemaps (identify slopes and discharge points)
  • Pollution sources/types (areas where sediment erosion is highest)

While this may sound tedious, it is essential for constructing the right BMPs for prevention. For example, soil with a high infiltration capacity located on a slope may require matting and silt fencing, while more stable soils may benefit from vegetation.

Most SWPPP plans will also require fingerprinting, which is taking traces of soil and examining its characteristics.

Site operators can also benefit from working with a designer or a company with an in-house designer that can develop a sitemap detailing all sources of pollution, slopes, and areas where controls will be implemented to include with your plan.

Step 2: Develop a Site Plan

Once a proper site assessment is done, it’s time to start writing down the basics of your proposal. At this stage, you will describe all construction-related activities, identify areas that are most vulnerable to pollution, and list areas where BMPs will be installed.

Step 3: Identify Sediment and Erosion Control BMPs

Next, proper erosion control BMPs must be implemented to prevent fine materials from mixing with stormwater. Note that erosion and sediment controls are often referred to as BMPs.

However, it’s important to differentiate between erosion and sediment control, which refer to two different processes:

  • Erosion Control: Prevents top-soil erosion which leads to sediment displacement and further erosion.
  • Sediment Control: Prevents loose sediment erosion, which can lead to higher levels of water pollution.

Essentially, erosion occurs when the outer layer of soil or rock dissipates, while sedimentation is when the loose particles under topsoil get displaced.

Put another way, erosion control is a first-line defense against runoff and typically includes its own set of BMPs, such as:

On the other hand, sediment control is used when significant erosion has occurred and as a last line of defense. Sediment controls include:

  • Silt fencing
  • Turbidity barriers
  • Inlet protection
  • Sediment basins

Therefore, both BMPs are essential, but site operators can achieve more with fewer resources by prioritizing erosion control early in projects–when possible.

Step 4: Develop Training Procedures Proper BMPs

After proper BMPs are established, it’s time to implement proper training procedures for employees to follow. Simple procedures may include housekeeping practices, spill responses, and material handling practices that achieve the best results.

Ensure all training materials are correctly recorded in your document and available for all employees.

Step 5: Implement “Good Housekeeping” BMPs

Unfortunately, a majority of stormwater pollution occurs because of spills or accidents. Something as simple as a punctured paint container could leak out during a storm without anyone noticing if proper controls are not put in place.

Therefore, site operators need to implement proper housekeeping procedures related to:

  • Material storage and handling
  • Spill clean-up (preferably dry clean-up methods)
  • Spill containment using tarps
  • Waste discharge and recycling

Step 6: Conduct Frequent Inspections

Next, proper procedures for frequent inspection will need to be recorded. Based on state law, inspections can vary from every week to every month and even after every rain storm (above certain inches).

  • Name of inspector/duties
  • SWPPP certification
  • Inspection scope
  • Inspector signature
  • Any incidents or spills
  • Description of active BMPs and their maintenance

Step 7: Stabilize the Area

Once construction activity has ceased, you will need to perform a final stabilization of the area and document this in writing.

Stabilization efforts will include restoring native vegetation and deconstructing all temporary physical BMPs to their natural setting.

Permanent BMPs can be implemented if necessary, depending on the extent of your construction activities.

Maintaining Proper SWPPP Compliance

Stormwater pollution prevention is a massive task for any company and can come with loads of regulatory oversight and red tape.

Avoid these pressures by outsourcing SWPPP compliance to an environmental consultant like Valor Environmental. We specialize in SWPPP planning and development to ensure that your construction site is always within the safe boundaries of the law and NPDES compliance.

Give us a call at 888-328-2567 or fill out the form online to contact us directly, and we will get back to you at our earliest convenience.

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