Optimizing Consistency Between Multiple Industial SWPPP Plans

Larger companies may have several facilities that are subject to stormwater permit requirements and are required to develop site-specific Stormwater Pollution Prevention Plans (SWPPP). Some elements of the SWPPP will likely represent corporate wide programs that apply to all facilities. Companies may also want to “standardize” their SWPPP so that each facility is implementing similar programs; these will allow multiple facilities to share training materials, for example.

If all facilities are located within a single State, the process of standardizing the SWPPP programs is straightforward. Each facility SWPPP will need to include a site specific facility information and evaluation of the potential pollutant sources, but many of the program descriptions can be identical.

If facilities are located in different States, the process of maximizing consistency between SWPPPs requires significantly more thought. One option is to compile the most stringent set of requirements, and use them to develop the SWPPP template. The clear advantage of this approach is that all facilities will be conducting the same programs. The disadvantage is that many facilities will be implementing programs which are well beyond their own State requirements and will be incurring higher costs. Finding the proper balance between consistency and meeting individual State requirements is key.

For those companies that favor a higher degree of consistency between facilities, even at higher cost, there is another factor that should be considered. Overtime, individual State requirements change – on average, 20% of States revise their requirements each year. Therefore, careful consideration must be made to whether or not a change in one State will require that all SWPPPs in all States to be revised. If the answer is no, then over time, the SWPPP programs between States will become more and more different from each other. Therefore, the benefit of consistency that was important in the beginning will be lost.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. Caltha specializes in developing cost effective corporate-wide SWPPP programs covering multiple facilities. Click here to request further information on Stormwater and SWPPP Services.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

New Jersey (NJDEP) No Exposure Industrial Stormwater Permit

In June 2007, the New Jersey Department of Environmental Protection (NJDEP) reissued its general permit for stormwater discharges from industrial sites. The reissued permit did not include stormwater monitoring or sector-specific requirements, which are common in many general stormwater permits being reissued recently around the US.

Rather than including many detailed requirements in the general permit, NJDEP has opted to include a significant performance requirement - once the stormwater pollution prevention plan (SPPP) is implemented, there must be no exposure of source materials and/or industrial activity to stormwater. This requirement is in contrast to other States where exposure to stormwater should be “minimized”. New Jersey permittees must be in compliance with the no exposure requirement by the end of 2008.

NJDEP does offer a conditional exemption from obtaining a discharge permit through a No Exposure Certification; however, the requirements for no exposure are more stringent. In this case the requirement is for Permanent No Exposure – all industrial materials are stored and/or all industrial activities are performed (with limited exceptions) inside a permanent building or permanent structure that is anchored to a permanent foundation and is completely roofed and walled.

Contact Caltha LLP or more information on SPPP templates that meet NJDEP permit requirements.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website