When Does SWPPP Need To Be Prepared? - New Facility Start-up

New facilities that require an NPDES stormwater discharge permit are required to prepare and implement a stormwater pollution prevention plan (SWPPP). In the sequence of constructing and beginning operations at a new facility, when does the SWPPP need to be completed?

For many new facilities, the period of construction through startup will actually require two SWPPPs - one during construction phase and one for the on-going industrial activities.

Regarding the industrial permit phase, the specific requirements will differ somewhat from State-to-State. In general, the SWPPP will need to be prepared and implemented prior to submitting a Notice of Intent (NOI) for permit coverage. This is because the NOI will typically require certification the the SWPPP has been completed and implemented. Therefore, because many States require the NOI to be submitted well in advance of start-up, the SWPPP may need to be completed several weeks or even months prior to start-up.

In some cases, especial for discharges to impaired water or other special waters, the SWPPP document may also need to be submitted along with the NOI.

Caltha LLP provides expert technical support to clients nationwide in addressing stormwater permitting and SWPPP requirements.

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