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Getting Your Data Together for a Storm Water Permit

©2002 Dr. B. C. Paul

2

Creating a SWPPP

Step #1 - Formulate Your Team– Need to have someone who is ultimately

responsible• Tempting to get a consultant - helpful but you can

be surprise inspected and need to have someone on site who can answer questions and ferry inspectors around

– Larger facility may use a division manager– Smaller may have chief engineer

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Step #2 Existing Plans

Look at contents of existing permits - may tell you what the issues are - also helps to prevent contradicting yourself– Oil Drums probably already have a spill

prevention and countermeasures plan– Toxic Substances already have plans– May be community emergency response plans– OSHA Emergency Action Plans

4

Check What Discharges Covered

Process Waters have NPDES permit– some commingled waters have to be treated as

process waters and are NPDES• don’t duplicate coverage

Check for restrictions and discharges to municipal sewer cover certain discharges or impose specific conditions

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Step #3 - Site Assessment

Obtain a Base Map of Property - don’t go out for a custom survey– A good enlarged topo– Ariel Photos from IDOT or USDA– Tax Maps– U.S. Soil Conservation Service Mapping– U.S. Fish and Wildlife Service National

Wetlands Inventory Mapping

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Add to the Base Map Drainage Patterns and Flow Directions

– Surface Water Bodies including wetlands• Any water bodies receiving points for storm water• Any place receiving storm water from a storm sewer

– Any Storm Water discharges from property– Any Non Storm Water Discharges

• Locate NPDES discharges and give permit number• Check in dry season when run-off and water bodies more

obvious• State how things were established• Company Official must certify no unpermitted discharges

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Add Location of Process Activ.

Stock Piles Crushers Feed bins Conveyors Fueling Stations and Fuel Tanks Loading Areas Equipment Maint Areas Storage areas

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More Additions

Add all existing storm water management features and structures

9

Source Materials Inventory

A Source Material is Something you handle in your trade or business that could be construed to contaminate material– The fact that many mining operations handle

mostly natural materials is irrelevant (many laws are built on the premise that anything touched by a human process is a sinister environmental contaminant)

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Likely Source Materials

Raw Materials for Trade– All handled inventories or in process inventories of

stone and aggregate materials for a quarry All Intermediate Materials and Finished Products

– May include asphaults or cements All waste or byproduct materials including

decantation ponds

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More Likely Sources

Industrial Machinery and Machinery Yards– Conveyors– Crushers– Screens– Equipment Yards and Facilities– Your Parking Lot

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More Sources

Fuels Solvents and Detergents– Fueling Stations– Fueling Storage– Plant Yards and Repair Stations– The Janitorial Closet

Locations of Previous Spills or Leaks– Any reportable amount of hazardous or non-

hazardous from past 3 years (maybe more)

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Unsources

Some States have Created Guidelines on “Inactive” Materials that cannot be contaminants– Washed Stone (has no fines)– Broken Concrete (recycle is good)– Rip Rap

• Rip Rapping of Channels is considered a best management practice so calling it a contaminant is embarrassing to regulators

14

Water Quality Data

Inventory and include any water quality data pertaining to storm water– May be little initially but likely to grow with

time

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Write a Narrative Description

Mining is a minor source compared to what many regulators are used to

Many know little about mining except for some negative comments from stories and movies where mining companies are the villains

Politely explain how each process works - replace fear of the unknown with understanding