What is a Stormwater Pollution Prevention Plan (SWPPP)?
SWPPP is short for “storm water pollution prevention plan”. Development of a SWPPP is a requirement of a UPDES Storm Water Permit before the application process is completed. A SWPPP is one of the most important requirements of the permit. A SWPPP should be kept at the site and updated as needed to reflect the current SWPPP activities on the site. Among other things it contains a list of contacts at the site, the responsibility of the Owner and Co-Permittees, the nature of construction activity, a site map showing location of BMPs and other important items, details of best management practices (BMPs) or control measures to prevent sediment from leaving the site and erosion from occurring, details about how the storm water facilities installed during the construction process will preserve pre-development flows and mitigate pollutants, all inspection reports done by the permittee, and how non-storm water at the site is managed.
There are two parts, a SWPPP and a State General Construction Stormwater Permit Coverage (State Permit).
• A State permit requires you to control and eliminate stormwater pollution sources through the development and implementation of a SWPPP.
• A SWPPP is a plan required by the State permit. It generally shows possible sources of stormwater pollutants identified and the Best Management Practices (BMPs) that are selected to reduce or eliminate their impacts. BMP's are the most important element of this plan. The aim is to control stormwater sediment and erosion to the maximum extent.
When are a SWPPP and State permit required?
When the proposed land disturbance falls under one of the following permit type descriptions:
• Common Plan Permit (CPP)- applies to single residential lots disturbing less than an acre and located in subdivisions that are an acre or greater.
• Construction General Permit (CGP)- applies to all other lots disturbing an acre or more (or lots that are part of a common plan of development, subdivision, or phased project that disturb an acre or more).
Where do I get a State permit? Also known as filing a Notice of Intent (NOI)?
State permits are filed through the State of Utah. Silver Leaf SWPPP will handle all the filing for you, email us and we take care of it. There is a filing fee which is based on the project area and this is due with your NOI application. You will also need to submit a copy of your SWPPP (Storm Water Pollution Prevention Plan), an erosion and sediment plan, construction drawings, and any other plans that may be required by Silver Leaf SWPPP. Once you have submitted everything, you sit back until we get back to you with the state permit number.
Are we required to have a SWPPP narrative in place before an NOI is submitted?
Yes, when an NOI is submitted, the permittee is certifying that a SWPPP is developed and has been implemented prior to construction.
What documents are required in order to create a SWPPP narrative?
Civil Drawings including: Grading and drainage plan, Erosion Control Plan, Geotechnical Report, and a Request for Information (RFI). Signed permitting documents are added to the completed SWPPP narrative once they are filed.
When installing BMP’s onsite are we required to install exactly what is specified on the civil plans?
No, the Utah General Permit allows the site Operator to make decisions about what BMPs are actually used and where they are used. Often that means deviating from what was specified on the civil drawings. The Operator’s obligation is to make decisions that produce the desired results, and to document them.
What posting requirements does the owner/ operator have?
Notice of Intent (NOI), Construction Site Notice Authorization to Discharge Letter from DWQ,
Postings must be on a sign - specific to the SWPPP. Remember that only an officer of the company is eligible to sign Permitting Documents (Notice of Intent or Construction Site Notice)
Who is required to get a UPDES Construction Storm Water Permit?
Operators of construction activity that disturb 1 acre or greater are required to get a Storm Water Permit from the Division of Water Quality, however many construction sites that disturb less than 1 acre are also required to get a permit. A site that is less than 1 acre is required to get permit coverage if it is part of a “common plan of development or sale” that is over 1 acre.
Who is an operator for a UPDES Construction Storm Water Permit?
An operator at a construction site is:
One who controls the specifications of the facility to be constructed.
One who controls the day-by-day activities at the permitted construction site.
The operator is the owner (or project instigator) or the general contractor for the project.
What is required in a permit?
A permit is needed BEFORE construction starts and must be maintained through final site stabilization which means:
That all disturbed areas have either been built on, paved, re-vegetated or equivalent.
Permanent, physical post construction erosion controls have been placed.
Your permit requires you to control and eliminate storm water pollution sources through the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP). In the Plan, you identify possible sources of storm water pollutants then select Best Management Practices (BMPs) to reduce or eliminate their impacts. BMPs are the most important element of this Plan. The aim is to control storm water sediment and erosion to the maximum extent practicable. Controls can encompass a wide range of structural and non-structural options:
Could include, for example, the installation of a silt fence or the construction of a stabilized construction entrance/exit.
Could include, for example, the maintenance of a vegetative filter strip or education of the general public on the application of fertilizer and pesticides. The permit also requires routine inspection of the BMP controls at least once every 7 days. The inspections should identify whether any of the controls need maintenance and if they are effective. If deficiencies are found during inspections, this is required to be documented and followed up with actions to resolve the deficiencies. Documentation is required to be kept on site and is usually best kept electronically in the SWPPP.
How does one get a Utah Construction Storm Water Permit?
Construction Storm Water Permits can be obtained online by proceeding through the on-line application process on the DWQ Storm Water Website.
Are there Construction Storm Water Permit payment exemptions for local government agencies?
No. City and/or County government entities are not exempt from the permit fee.
Is the oil and gas industry required to apply for construction Storm Water permit coverage?
Only activities (industrial or construction) that result in a discharge of a reportable quantity release or that contribute pollutants to a violation of a water quality standard are subject to permit coverage.
What waivers are available for small (1-5 acres), short duration construction activity?
The only waiver available for construction activity is for small construction activity and is called an Erosivity Waiver. It is based on seasonally low rainfall. The Erosivity Waiver is available for construction activities that have a calculated R-factor of less than 5
How are UPDES Construction Storm Water Permits Terminated?
A permittee can go to the Storm Water Permit Issuance System on the DWQ Storm Water Website and access the account the NOI was originally submitted and proceed through the NOT steps. Additionally, the permittee may go on the DWQ Storm Water Website, download the NOT form, and submit the completed form to DWQ.
A termination inspection will be performed by the local municipality or State to confirm final stabilization.
What is a LTSMP? (Long Term Stormwater Maintenance Plan)
The LTSMP includes a site description and site plan. It is required to list all of the stormwater appurtenances. These include all catch basins, storm drain manholes, drainage swales, detention/retention ponds, underground injection chambers such as CulTec. For each stormwater appurtenance a maintenance schedule must be included with each one. The civil plans must show the location, and number of each stormwater appurtenances. The civil plans must also include instructions for the installation of any underground injection chambers (UICs). The UICs can be detention and/or infiltration. If the UICs are assuming an infiltration they must show with the post storm water calculations the and the infiltration rate used.
What is a LTSMA? (Long Term Stormwater Maintenance Agreement)
These two agreements go hand in hand and must both be submitted to the governing City. The Long Term Stormwater Maintenance Agreement is a legal document stating that the signatory, the owner, or the owner's representative will follow the above LTSMP. Along with agreeing to maintain all of the stormwater appurtenances, the owner or owner's legal representative agrees submit an annual report of the condition of each of the storm water appurtenances in an annual report submitted to the governing City.
What is a Post Construction Inspection?
This is a service offered to assist the owner to maintain compliance with the LTSMA as described above. The site will be thoroughly examined, the functioning level of each BMP will be assessed and photographed. Recommendations for repairs or maintenance to the BMPs will be made. The site is then monitored for other problems that may have developed since construction was completed. A report to the owner will document what was found with recommendations for maintenance, repairs and monitoring schedule. The objective of this service is to assist the owner in maintaining compliance on a yearly basis.
What is a UIC? (Underground Injection Chambers - UIC Class 5 Injection Wells)
Underground Injection Chambers are any storm water system that infiltrates or retains stormwater in an underground infiltration system.
There are three types of UIC Class 5 Injection Wells:
1. Infiltration trenches (if stormwater is directed to any shaft or hole that is deeper than its widest surface dimension or has a subsurface fluid distribution system).
2. Commercially manufactured pre-cast or pre-build subsurface detention vault/infiltration system.
3. Drywell, seepage pit, or improved sinkhole (if storm water is directed to any shaft or hole that is deeper than its widest surface dimension or has a subsurface fluid distribution system).
This UIC form must be submitted to the Utah DEQ and a fee paid. (For the Idaho DEQ UIC Submission, each separate UIC must have it's own description page, and a fee is charged for each system)
What is a SPCC (Spill Prevention, Control and Countermeasure Plan)
Spill Prevention, Control and Countermeasure Tier 1 (Anything above Tier 1 would be along a coastline.) A Tier 1 qualified facility must meet the following criteria:
- If there are more than 1320 gallons you must have a Spill Prevention Control and Countermeasures Plan.
- The storage must also have secondary containment in the event of a leak or spill.
- A total aboveground oil storage capacity of 10,000 U.S. gallons or less
- No aboveground oil storage contained with a capacity greater than 5,000 U.S. gallons
- No single oil discharge greater than 1,000 gallon OR
- No two discharges greater than 42 gallons within any 12 month period to navigable waters or adjoining shorelines in the three years before the SPCC plan is certified.
A Spill Prevention, Control and Countermeasure plan must include spill storage for the entire oil capacity plus the 24 hour storm event.