In 1972, the Federal Water Pollution Control Act (also referred to as the Clean Water Act, or CWA) was amended to provide that the discharge of pollutants to waters of the United States from any point source is effectively prohibited unless the discharge is in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. The 1987 amendments to the CWA added Section 402 (p), which establishes a framework for regulating municipal and industrial stormwater discharge under the NPDES Program. On November 16, 1990, the U.S. EPA published final regulations that establish application requirements for stormwater permits.
There are three types of regulated stormwater discharge that require NPDES permit coverage:
Municipal separate stormwater systems (MS4); and
- Permit for Construction Activities
The NPDES Stormwater Program requires operators of construction sites of one acre or larger (including smaller sites that are part of a larger common plan of development) to obtain authorization to discharge stormwater under an NPDES Construction Stormwater General Permit.
The Construction General Permit requires the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP) for each development that falls under this permit. The SWPPP must be developed and implemented by a qualified person.
This document must contain information including site map(s) showing construction and stormwater discharge locations, and must also contain a list of best management practices (BMPs) that will be implemented during and after the construction has been completed.
Sampling and analysis of stormwater discharge is also required.
The BMPs are aimed primarily at controlling erosion and sediment transport. Additional controls are aimed at other pollutants such as construction chemicals and solid waste (e.g., litter).
Stormwater runoff from construction activities can have a significant impact on water quality. As stormwater flows over a construction site, it picks up pollutants like sediment, debris, and chemicals. As noted above, polluted stormwater runoff can harm or kill fish and other wildlife. Sedimentation can destroy aquatic habitats, and high volumes of runoff can cause stream bank erosion. The goal of this permit is to protect the quality and beneficial uses of the nation’s surface water resources from pollution in stormwater runoff from construction activities. Low Impact Development (LID) techniques are required for most new construction projects.
Reduce the discharge of pollutants to the “maximum extent possible”;
Protect water quality;
Satisfy the appropriate water quality requirements of the CWA and the Regional Water Quality Control Board’s (RWQCB) Plan.
Education and Outreach;
Public Involvement and Participation;
Illicit Discharge Detection and Elimination;
Construction Site Stormwater Runoff Control;
Pollution Prevention/Good Housekeeping for Permittee Operations;
Post-Construction Stormwater Management;
Water Quality Monitoring; and
Program Effectiveness Assessment and Improvement.
The Municipal Separate Storm Sewer System (MS4) permit requires all permittees (mainly cities and counties) to comply with these requirements. There are different requirements for larger (Phase 1) and smaller municipalities (Phase 2). School districts were listed as non-traditional permittees under the previous MS4 permit, but at this point are not required to comply with these requirements, except for a few districts that obtained permit coverage under the previous permit. All permittees are required to:
Each permittee must develop a program to minimize their potential impact on local water bodies by implementing a variety of elements in their developed programs. Their overall program should result in significant reductions of pollutants discharged into receiving water bodies. Some of the programs they need to include are:
Minimizing the potential of generating polluted stormwater runoff.
Developing and implementing an SWPPP for onsite industrial activities. For school districts this includes vehicle washing, parking, maintenance, and fueling.
Implementing BMPs to decrease the potential of polluted runoff generated by site activities.
To identify potential sources of pollutants that affect stormwater discharge from the site;
To describe the BMPs that will be implemented to prevent or control the release of pollutants in stormwater discharge;
To create an implementation schedule to ensure that the practices described in this SWPPP are in fact implemented; and
To evaluate the plan’s effectiveness in reducing the pollutant levels in stormwater discharge.
Identification of the SWPPP coordinator and implementation team members;
Description of the facility, including information regarding the facility’s location and activities as well as a site description and site map;
Identification of potential stormwater contaminants;
Description of stormwater management control and various BMPs necessary to reduce pollutants in stormwater discharge;
Description of the facility monitoring plan; and
Description of the implementation schedule and provisions for amending the plan.
Industrial facility activities include the handling, usage, and storage of certain materials that are often exposed to rainfall. As stormwater runoff comes into contact with these materials, it picks up the pollutants and transports them to nearby storm sewer systems, which then flow into rivers, lakes, or coastal waters. School districts with transportation facilities are required to comply with this permit process. The goals of the Industrial Permit include:
The development, implementation, and maintenance of the SWPPP will provide school districts with the tools to reduce pollutants contained in stormwater discharge and comply with the requirements of the Industrial General Stormwater Permit. The primary goals of the SWPPP are:
This SWPPP includes all of the following:
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