Annual requirements - employee training, reports and inspections

AskEnvironmental team strives to achieve environmental excellence in providing Environmental Consulting services to its customers. Through the execution of its Environmental Management Procedure, AskEnvironmental continue every day a high standard of environmental responsibility and performance. This is a complicated permitting process AskEnvironmental is  highly experienced in maintain  all its clients in compliance with the local, state and federal agencies avoiding fines and penalties for stormwater violations. This is one of the reason why it is so important to have an established, reputable Environmental Consultant firm complete your Plans, Training, Laboratories with Analysis, Monitoring,Inspections and Environmental Legal representation. The most important reason is that, Askenvironmental  is offering you peace of mind and saving time in all your  Environmental needs and official requirements .

Implement annual employee training

Employee training should be a major component of any SWPPP. Employee training is also an integral part of other control measures. In order for the SWPPP to be effective, employees should be informed about stormwater treatment and control measures at the facility. They should understand their role in stormwater pollution prevention at the facility. Employee training for stormwater issues may be done in conjunction with other training programs.

The purpose of a training program is to teach staff at all levels of responsibility the components of the SWPPP. When properly trained, staff are more capable of preventing spills, responding safely and effectively to an accident, and recognizing situations that could lead to accidents. Employee training as a control measure is an ongoing process, which may take some time to implement. All new employees should be trained as soon as possible. The complexity of the BMPs, the turn-around time of the employees, and the effectiveness of the training will affect how often training sessions will need to be scheduled.

Document employee training

Be sure to document within the SWPPP a training schedule and the planned training frequency. Include a record of the trainer and the trainer’s organization (internal or external), as well as the names of trained individual(s) and dates that the individual(s) received training. This documentation can be either in the SWPPP or in a separate record.

The following individuals should be trained at least annually

  • Employee(s) overseeing implementation of, revising, and amending the SWPPP;
  • Employee(s) performing installation, inspection, maintenance and repair of BMPs;
  • Employee(s) who work in areas of industrial activity subject to the permit; and
  • Employee(s) who conduct stormwater discharge monitoring 

Training should cover the components and goals of the SWPPP and include

  • Spill response procedures
  • Good housekeeping
  • Material management practices
  • Stormwater discharge monitoring procedures
  • BMP operation and maintenance

Consider these training suggestions

  • Frequently conduct proper training of employees in good housekeeping techniques and proper safety methods to reduce the potential that materials or equipment will be mishandled. It also reduces the chance of injury, loss of materials, and release of contaminants.
  • Incorporate information sessions on good housekeeping practices into employee training programs.
  • Discuss good housekeeping at employee meetings.
  • Promote pollution prevention concepts through posters, brochures, newsletters, etc.
  • Post bulletin boards with updated good housekeeping procedure tips and reminders.
  • For more information, about Industrial Stormwater Annual Training Requirements  

Fill out the annual report

With annual reports, not only does the information help the  City  and State understand what is going on at specific facilities, but it gives you an understanding of what’s happening at your facility in regard to industrial stormwater.

Each Annual Report needs to cover those portions of the previous calendar year that the facility was authorized to discharge industrial stormwater. The Annual Report needs to include the following information:

  • A summary of inspection dates, findings, and any BMP maintenance conducted by the Permittee
  • If applicable, the results of inspection requirements involving oil and grease
  • A confirmation that the SWPPP accurately reflects facility conditions
  • A confirmation that newly-exposed significant materials (if any) have been identified and that the SWPPP has been modified to address them
  • A confirmation that the Permittee has conducted a review of impaired waters and that the SWPPP has been modified to address applicable permit requirements of Benchmark Monitoring Requirements, if necessary
  • A confirmation that the Permittee has conducted a review of USEPA approved TMDLs that may apply to the facility and that may require the Permittee to comply with TMDL requirements
  • A description of any SWPPP modification made
  • Date(s) of staff training, required at least once per calendar year
  • A list of all spills and leaks that occurred at the facility
  • If applicable, a summary of all mobile industrial activities conducted by the facility. The summary shall include a description, locations where the mobile industrial activity occurred, and length of time the mobile industrial activity operated at each location.
    •  Annual Report Form — NPDES/SDS General Stormwater Permit for Industrial Activity . To be filled out for the previous calendar year. The 2015 Annual Report is due March 31, 2016.
    •  Industrial Stormwater Annual Report Newsletter/Instructions 

Tip: BMP maintenance is important and should be documented within your SWPPP and noted on the Annual Report. Examples of BMP maintenance include: remove debris and litter, vegetation management, Structural BMP maintenance, repair mechanical components, and the analysis of your facility sampling, etc.

Conduct monthly inspections

All facilities will have to perform monthly inspections of their facility. Inspections must include the following:

  • An evaluation of the facility to determine that the SWPPP accurately reflects site conditions. At a minimum, inspect storage tank areas, waste disposal areas, maintenance areas, loading/unloading areas, and raw material, intermediate product, by-product and final product storage areas
  • An evaluation of all structural and non-structural BMPs to determine effectiveness and proper function
  • An evaluation of the facility to determine whether new exposed significant materials or activities have been added to the site since completion of the SWPPP
  • During an inspection conducted during a runoff event, an evaluation of the stormwater runoff to determine if it is discolored or if other contaminants are visible in the runoff (e.g., oil and grease).

NOTE: At least one inspection must be performed during a runoff event.

Document inspections

All inspections shall be documented and the following information shall be stored with the SWPPP and contain the following:

  • Inspection date, time, and weather conditions
  • Inspector name
  • Inspection findings
  • A description of any necessary corrective actions and a schedule for corrective action completion

For more information and guidance,   

Conduct impaired waters assessment

Every year, Permittees should assess whether or not the water(s) they discharge to is impaired. No later than 180 days following the approved listing of the impaired water, a facility shall begin the additional monitoring for the pollutant(s) of impairment or its appropriate surrogate. See part V of the Multi-Sector General Permit for more information about monitoring requirements relating to impaired waters and visit the Maps of Impaired Waters search tool for more information on impaired waters.


How do you comply with the annual and monthly permit requirements?