SWPPP Inspections Explained: A Practical Guide for Property Managers
SWPPP, pronounced SWIP, is a term that many environmental professionals use. We say SWPPP because it’s fun to say, and because it’s a lot quicker than saying, “StormWater Pollutant Prevention Plan.” The 300 page three-ring binder that is generally found on a book shelf of the EHS director’s office and can be too often forgotten. However, the document is to be updated with changes on the site and inspection reports.
WHEN SWPPP INSPECTIONS ARE REQUIRED
Industrial sites are divided into sectors. Each sector provides different expectations for what is to be included in the SWPPP. However, all sectors are required to give four inspections, one of which should be completed during a rain event that creates discharge. These quarterly inspections are to be completed, documented, and placed in the three-ring binder. They should also be accompanied by at least three photos. I tell my inspectors that we are not on site to solely look for problems.
WHAT INSPECTORS LOOK FOR
Inspectors record what functions as design, what areas need to be monitored as a concern, what repairs or changes should be made, and what is currently failing. The inspector, then is a sword and shield. Defending the property and practices as well and going on the offense with strategic capital improvements.
An inspector’s visit can be simplified through color code.
Gray: He is assesses the structures on site. These structures begin with the outfall pipe, which is connected to the discharge riser in the stormwater basin. Through these two structures, a lot can be told about the site. Sediment accumulation, trash, odor, algea all point to various issues throughout the property. The inspector also looks at riparian buffers, inlet pipes, impervious surfaces, catchbasin, junction boxes, flumes, curbing, downspout tie ins, and other man made BMPs on the site.
Green: These are are often considered low impact development (LID), which includes rain gardens, vegetated swales. the lawn, as well as slopes and hillsides. The inspector is looking for erosion and sediment accumulation. The vegetation density is required to be over 80% throughout the entire site. An inspector may considers plant health. Also around under ground infrastructure, the inspector is looking for divets or other signs of sub-surface soil loss.
Brown: Furthermore, the inspector considers the soil. Is the soil saturated pointing to insignificant water conveyance? Has there been improper soil compaction on site from heavy equipment? Again, looking for sediment accumulation, and erosion. Does the soil have a septic, sweet, or foul odor?
Blue: Finally, the inspector consider water. Lookin for water standing where is should be gone (72 hours after a rain event), looking for oil sheen, or other pollutants in the water. If a body of water is near by, the inspector will look for fish kill. While the inspector may be able to notice extreme turbidity, most water contamination requires sondes. There is increasing pressure for some industrial sites to install electronic monitoring devices. If your site does not currently have them, it might be worth starting those conversations now. Buck Outdoors helps industrial sites throughout the United State design, calibrate, instal and manage monitoring devices.
DOCUMENTATION PROPERTY MANAGERS MUST KEEP
Your SWPPP is a living record. It should be growing each year. In your three-ring binder you should be adding the following documents:
Spill Reports: The SWPPP has a template that should be completed to document what caused the spill, what was spilt, and how the spill was contained and disposed of. You will also document any procedure changes that illuminate the risk.
Inspection Reports: Each quarter, you need to add your inspection report. These should be performed, dated, and signed by a stormwater professional. If your inspector does not include photos, ask for a minimum of three defensible photos (geo & time stamped) from the inspection.
Construction Change: Changes to your facility should be included in your SWPPP. Often time, these changes will require a more indepth edit to your SWPPP. For instance a new building or parking lot will require such an edit.
HOW OUTSOURCING SWPPP INSPECTION REDUCES STRESS
The EPA, or your state, requires that a stormwater professional inspect quarterly. By bringing in a third-party inspector, there is a person on site who has not grown accustomed to the faculty’s condition. A fresh set of eyes, tends to give a more in depth and comprehensive evaluation. However, the third party inspection does not mean that the facility manager should be released of his own inspections. We provide EHS Directors and Facility Managers a checklist that can be used after rain events. These are simple observations that should be used to supplement the quarterly, third-party inspections.
If you would like to be better prepared to manage your site’s stormwater infrastructure, visit our page for facility managers.
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If you’re a property manager responsible for stormwater compliance, Buck Outdoors LLC provides inspections and monitoring for industrial properties the United States. Feel free to contact us if you have questions about your site.
KEYWORDS: SWPPP inspections, stormwater compliance services, industrial stormwater inspections