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.
Stay ahead of stormwater issues. We share practical stormwater insights, inspection reminders, and compliance tips written specifically for property managers. Join our mailing list to stay informed and reduce risk before problems arise.
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
The Most Expensive Stormwater Risks that Property Managers Overlook (until there's a problem)
Big always starts small.
How unnoticed disjointed pipes lead to sink holes.
How clogged infrastructure leads to flooding.
How eroded dams lead to failed dams.
Too often I have discussions with Project Managers where dangerous comments are made. “If we are not aware of the problem, we are not responsible for it.” “If we find a problem, the property owner is going to be upset.” “We don’t want to get distracted by small issues when we have so many other conversations going.”
It is these attitude types that have caused environmental compliance to tighten. Recently, some facilities are required to move from quarterly inspections to real-time monitoring. The phrase we keep hearing, “We want to see the movie, not a photo.” The four snap shots obtained through quarterly inspections do not tell the whole story. As a result, constant monitoring requirements will continue to strengthen in order to align facilities with climate control.
Furthermore, inspections and monitoring alone are not enough. It’s one thing to see a problem, it’s another to act. When we inspect properties for the land owner we inform them of what the expenses potentially are so they can budget. We also help them prioritize the problem. In other words, if you wait, will it cost more money later? However, it’s not just about managing the checking account. We also need to consider reputation. If a problem creates risk, we inform the property manager about risks other than financial.
Here are three Expensive Risks that a facility cannot afford to overlook:
Illicit discharge: Illicit discharge is not something you generally see. The pollution is parts per million in your stormwater discharge. One easy way to catch this is through discharge monitoring devices. These monitors alert managers of unseeable contamination. However, before this, the monitor acts as a defense mechanism. If claims of contamination are made down stream, how can you prove that the fish kill or pollution did not start on your facility without constant monitoring. Furthermore, the precise measurement reveals trends on site that show you are actively improving your effect on the climate. I have been on a site in Spartanburg County where a once vibrant manufacturing site is no longer in business and the property has been condemned and usable. A wise investment, lost because of unmanaged risks.
Unsound dams: The dam on your stormwater pond will not fail over night. Though you may not notice the incremental deteriorations, consistent inspections provide an opportunity to discover signs that pipes are disjointed, sink holes are forming, or sediment is accumulating. These signs appear when the correction is less distractive and less expensive than a total dam failure. However, the facility delayed repairs until it was too late facing the risk of cease operation demands by the site.
Erosion: On one of our sites we communicated with the plant’s facility manager that the slopes around the loading docs had not been compacted properly. We showed pictures lost soil and explained how it effected nearby structures. We pointed out that sediment accumulation was causing water flow to by-pass stormwater infrastructure which intensified the soil loss. The facility manager did not heed the warning and never gave it a second thought until two loading bays were no longer usable because the back corner of the lot had collapsed. This not only led to more expensive repairs, but more importantly it disrupted production capacity.
As a facility manager, lean into the relationship with your stormwater professional. Let them play a role in your strategy as you manage risks that could be quite costly. Facility managers benefit from follow up conversations with their inspectors. Here’s some questions to ask your stormwater inspector as you manage risks:
Facility Managers are asked to go GREEN
Green when it comes to the environment and money.
What are five simple process shifts that we should consider?
What trends do you see on our site that can be redirected with additional BMP maintenance?
What expenditure should be made under $20k that will help prevent $250k expenditures in the near future?
What are the next large expenditures we need to begin budgeting for?
Stay ahead of stormwater issues. We share practical stormwater insights, inspection reminders, and compliance tips written specifically for property managers. Join our mailing list to stay informed and reduce risk before problems arise.
If you’re a property manager responsible for stormwater compliance, Buck Outdoors LLC provides inspections and maintenance for residential, commercial, and industrial properties across the upstate of South Carolina. Feel free to contact us if you have questions about your site in Oconee, Pickens, Anderson, Greenville, Spartanburg, Cherokee, Laurens, or Greenwood counties. Throughout the country, we install, collaborate, and manage stormwater monitoring devices.
KEYWORDS:: stormwater risks for property managers, stormwater compliance issues, property management stormwater