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Are you one of the people who must, in some capacity, prepare or review stormwater pollution prevention plans? If you work in or around the construction industry, you’re probably very familiar with the SWPPP—and at the same time, perhaps, not as well acquainted with it as you feel you should be.
Most of us are aware of the changes NPDES Phase II has wrought for smaller construction sites. We know we need to comply. It’s possible, though, to go through the motions many times without quite understanding all the nuances; if we got away with a less-than-thorough SWPPP last time, why take the time to learn how to prepare one differently?
As Shirley Morrow, who taught a two-day course at StormCon on preparing SWPPPs, recently pointed out, many people, when asked to produce their SWPPP, simply hand over a map of the site, sometimes with the locations of BMPs marked on it. But as Morrow notes, that’s only a small part of the SWPPP, and it alone won’t satisfy a site inspector. The SWPPP should contain, among other things, a description of the project; information about potential sources of pollution, receiving waters, and the site’s characteristics; and descriptions of the BMPs to be used. Morrow knows about compliance—she has trained thousands of construction managers, prepared the USEPA-approved stormwater training program for Wal-Mart Stores, and prepared more than 100 SWPPPs herself.
But as she and other trainers also realize, the SWPPP is for most contractors one more step in the many, many steps involved in getting the job done. Amid all the scheduling, ensuring materials are delivered on time, maintaining equipment, and making sure safety regulations are met, not everyone feels the same urgency about it.
We all agree—most of us, anyway—on the need for a whole range of practices about which we don’t necessarily feel great enthusiasm. We need to pay our taxes, for example, and we need a driver’s license to operate a vehicle. Accepted forms and procedures exist for accomplishing or obtaining these things—some easier than others to understand. Many of us, it’s true, pay someone else to fill out our tax forms for us, either because we figure someone who does it for a living can do it better, or because we’re afraid of the consequences of getting it wrong. And that, in fact, is an option for the SWPPP as well; plenty of third-party vendors are available, not only for preparing the SWPPP but also for installing and maintaining onsite BMPs, and depending on your circumstances it might be well worth it to hire them. But you shouldn’t have to use them—you should, if you choose, be able to figure the thing out for yourself.
That’s where the EPA comes in. Recognizing that the simpler it is, the more likely it is to be done correctly, the agency has prepared a guide to walk us through the SWPPP. It’s well organized and easy to read, explaining what’s needed in the SWPPP and why and where to find it. Best of all, it comes with a template you can fill out—not nearly as complicated as some of the IRS’s longer schedules. Granted, the template itself runs to 27 pages and will likely be quite a bit longer once you’ve filled in all the required information. But at least it tells you unambiguously what that information is.
You may have done dozens or hundreds of these yourself, or your company might have its own form to follow—but if not, and if you’ve been muddling through or dreading the next SWPPP, the EPA’s guide will save you some time and a few headaches. It’s online at www.epa.gov/npdes/swpppguide.
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Janice an Email
EC - November/December 2007 |
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