April 1, 2025 • 29 mins
Storm Water Pollution Prevention Plans (SWPPPs) can be confusing - but they don’t have to be. In this episode of Tank Talk, we’re diving into the different types of SWPPPs, how they apply to various industries, and what you need to know to stay compliant. With the 2025 Multi-Sector General Permit (MSGP) expected for Alaska soon, it’s the perfect time to brush up on the basics.
Join us as we break down the differences between CGP, MSGP, and MS4 permits, the importance of SIC/NAICS codes, and why a "No Exposure Certification" might not be the easy way out you think it is. Whether you're managing compliance for a bulk fuel facility, a construction site, or an airport, this episode will help you navigate the stormwater regulations with confidence.
🔗 Helpful Resources:
📌 ADEC MSGP
📌 ADEC CGP
📌 ADEC MS4
📌 EPA NPDES
📌 Integrity Training
Tune in now and keep your SWPPP straight!
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Haley Hall (00:09):
Welcome to Tank Talk with Integrity Environmental.
Join us as we sit down withfounder, principal consultant
and bulk fuel storage expert,Shannon Oelkers, to explore
regulations, safety andessential tips for navigating
the bulk fuel storage industry.
Join us as we explore theunique joys of work and life in
Alaska with industry experts,including our team, vendors we
(00:30):
work with and the companies wesupport.
Shannon Oelkers (00:34):
Hello, welcome to Tank Talk.
This is Shannon Oelkers, andtoday I wanted to talk about
SWPPPs, and you may be wondering, dear listener, what a SWPPP is
.
I think most people have heardof it, but just to be super
clear, a SWPPP is an acronym fora Stormwater Pollution
Prevention Plan, and SWPPPs aregenerally permits to prevent
(00:54):
pollution from enteringstormwater.
However, in our SWPPP's, can bevery confusing for people in
the bulk fuels industry andindustry in general, and there
is a good reason as to why HaleyHall is going to join us today.
Haley, what do you know aboutSWPPP's?
Haley Hall (01:13):
You know I'm still learning Shannon and I'm excited
to dig in today, but what I'mreally wanting to know is what
is the reason why our clientsare so confused about SWPPP'S?
Shannon Oelkers (01:23):
The EPA! Podcast over.
Just kidding - the EPA reallyis the reason why our clients
are so confused about SWPPP's.
Swifts are part of the CleanWater Act, which is an old
regulation with lots of what Iwould call "nested regulations
within it.
So, it goes all the way back tolike the end of World War II.
In 1948, there was a federalwater pollution control act
(01:44):
passed and then over the yearsthat eventually turned into the
clean water act in 1972.
And that's the modern versionof stormwater pollution control
and that clean water act.
There's a fun fact well, a notso fun fact, if you will.
The clean water Act was passedbecause of the Cuyahoga River
Fire in 1968.
(02:06):
And if you love history and youwant to be incredibly depressed
, Google the Cuyahoga River Fireof 1968 and watch the YouTube
videos, because it's a very sad,impactful lesson on the dangers
of polluting our rivers andletting them catch on fire.
But once the Clean Water Actwas passed in 1972, there was
regulations that were passed toensure that the mandates of the
(02:29):
Clean Water Act were being met,and the one that covers SWPS in
general is 40 CFR 122.
And then the way the federalprogram works you can have state
primacy, the feds can haveprimacy, and then some states
share, so they have stateprimacy.
The feds can have primacy andthen some states share, so they
have state primacy for stateareas and the federal group has
(02:50):
the federal permitting in theirarea.
That gets a little confusingmaybe too confusing for this
podcast, but for the averageperson both the state and
federal groups, so the EPA andthen your state environmental
group, they all have agency andcan assess violations and they
can do inspections and they canassess fines.
How do SWPPPs fit into all this?
They're the bottom of thisnesting.
(03:12):
So under the federal programthere's something called a
national, it's called the NPDsprogram, but I got to like look
up all the letters because it'shard to keep these straight and
if you're listening to this,this is about to be alphabet
soup, so I apologize.
The NPDs program is the NationalPollutant Discharge Elimination
System program, NPDs and thenin the state of Alaska, where we
(03:33):
have a lot of our clients, it'sthe Alaska Pollutant Discharge
Elimination System or the APDsprogram.
Those two programs have twoways to issue permits for people
who are operating in certainindustries so that they can
control the amount of pollutantsthat stormwater is exposed to.
One of those ways is anindividual permit, which we'll
(03:54):
talk about in a little bit, andthen the other way is in a
general permit, and the generalpermit is like a pre-approved
limit for specific kinds ofindustries.
So the EPA and the state satdown and thought about all these
different industries and said,for these specific industries,
these are the rules aboutstormwater exposure.
So once we get to that, I guessPDs level.
(04:17):
But for the sake of thisconversation, since a lot of our
listeners are focused on thestate of Alaska, let's focus on
the APDs program.
Under the APDs program, thereare three general permits and
then, of course, the individualpermit program.
Right, those three generalpermits are the multi-sector
general permit, the constructiongeneral permit and then there's
(04:38):
something called an MS4, whichis super fun, An MS4 is a
municipal separate storm sewersystem.
So the four refers to the fourS's that we are not saying,
which I am thankful for, becauseI could not say a S, that would
be a lot.
So there's those three, andthen the individual permit and
then the three general permitsissue SWPPPs underneath them,
(05:00):
and I think that's where a lotof the confusion comes from,
because we've got threedifferent areas.
All those general permits dodifferent things.
For example, the MS4, I thinkpeople who live in Anchorage or
maybe in Fairbanks would be morefamiliar with it.
It's a system of public.
It's like a city sewer or asuburban area sewer.
It's a system of publicly ownedditches, pipes and other
(05:21):
features that collect and managestormwater in urban and
suburban areas.
Alaska has relatively few.
If you live in the state ofWashington or Oregon, every
community has an MS4.
But in Alaska we only have one.
Well, there's a few others, butthe big ones are the
municipality of Anchorage, theFairbanks, north Star Borough
and the Port of Alaska.
Those MS4 permittees.
(05:42):
They're required to develop astormwater management plan for
the whole city or the wholesuburban or urban area.
And then if you have aconstruction SWPPP or a
multi-sector SWPPP within theMS4, you have to meet the MS4
requirements in addition to themore general conditions under
MSGP or GP.
So that's a lot of GP Haley.
Haley Hall (06:02):
So a GP for municipalities seems
straightforward, as most largercities have a stormwater
drainage system.
But what is the real differencebetween a CGP and an MSGP?
Shannon Oelkers (06:14):
I think this is the heart of the confusion.
I mean, a lot of people havedriven on roads and they've seen
big signs nailed into theground that says SWPPP permit
information here.
They've seen that posted andthey've seen them posted on lots
during construction projects.
The easiest way I found to keepthe CGPs and MSGPs separate in
my mind is that a constructiongeneral permit applies to
(06:35):
construction projects andthere's sort of a short term and
duration.
They mainly focus on preventingrunoff, erosion and
sedimentation in addition topollution prevention during
construction activities.
And then your control measuresand best management practices
change frequently, sometimesdaily or even hourly.
If you have a big storm eventor bad weather that affects all
(06:56):
the things you have planned andthey sort of address immediate
needs and require constantmonitoring.
And when you look at themulti-sector general permit,
that's basically an operatingpermit for industry facilities
where stormwater could come intocontact with pollutants as they
perform their daily tasks.
But these tasks rarely change.
The control measures rarelychange and they often stay the
(07:18):
same.
Once they're installed theyjust need maintenance and
operations.
You're not going to havesomebody say oh, I need to pull
out this manual operated valveand throw some straw waddles on
today because it's raining sohard they would just.
The controls are alreadyaccounting for that and they
just need to maintain them.
The MSGP usually doesn't dealwith sedimentation and erosion
as a major concern.
It can happen, especially ifyou change your outfall location
(07:40):
or something for a containmentarea, but it's nothing like the
focus that the constructiongeneral permit has, because
you're, you know, creating a newroadway or pulling up an
existing roadway and putting anew one down.
There's a whole lot moreerosion and sediment control
with construction.
I do want to point out, though,that the biggest problem that
our firm sees with SWPPPs isthat we will sometimes go to
(08:04):
facilities and they'll pull outa SWPPP for us to review, and
whoever wrote that SWPPPborrowed heavily from the
construction general permit, andI understand that because a lot
of people in the industry haveworked in construction and
worked at main facilities andthey're both called SWPPPs.
No big deal.
SWPPP from here, SWPPP to there, nuts to bolts I got soup right
.
That's not how it works,because the background of the
(08:27):
two permits is so different, andso the assumptions that go into
a construction permit.
You know that there's a settime these will be in place and
then there'll be removed andthat the project itself will
progress and move down theroadway and then at some point
no longer be needed and beremoved completely, are so
different to the multi-sectorgeneral permit, which assumes
infinite operation.
(08:48):
And then there's ongoing monthlyyou know, ongoing maintenance
and operation and record keeping.
And so when you borrow partsfrom the construction permit,
the general permit, and stuff itinto an MSGP, it doesn't meet
the MSGP at all.
They're two different thingsand so firms like ours, we write
(09:09):
both no big deal.
We understand the regulationsunderneath, but I want our
listeners to be aware andunderstand the difference
between the two.
So when you're hiring aconsultant or you're trying to
do it yourself, you're gettingthe permit coverage that you
need.
You need to go to the MSGP siteand read that permit for how
your permit coverage is going tobe written under in the SWPPP,
which is the chapter underneathMSGP.
You can't just borrow from theconstruction permit,
(09:32):
unfortunately.
Haley Hall (09:33):
I think that makes sense.
But, Shannon, are operationalSWPPPs under the MSGP the same
across every industry?
Yes and no.
Don't you love that answer.
The multi-sector general permithas 10 sections that are
general and apply to allfacilities, and then they have
sector specific requirementsthat have different conditions
(09:56):
based on the kind of industrialactivity you're doing.
So it's a yes and no.
I'm sorry, wait, but what's asector?
Ooh, a sector is another termyou have to know if you're going
to do stormwater.
So write that one down, becausewe need some more words in this
alphabet soup.
Sectors are 29 identifiedindustrial areas included in the
(10:18):
MSGP.
It's Appendix D.
Each sector describes the typeof facilities included in that
sector, the typical pollutantsincluded in that sector, the
typical pollutants associatedwith the sector and types of
stormwater control measures thatyou should be using to minimize
the discharge of pollutionspecific to the industry type.
Each one of these sectors hasdifferent things and it's
related to the types ofactivities that they're doing.
So a really good example ofthis Sector S.
(10:39):
It applies to aircraftmaintenance at airports and
operations.
They have quite a fewrequirements related to de-icing
fluid, which you aren't goingto see de-icing fluid in any of
the other sectors.
It's just specific to aircraftand that sector.
So how do you know if you're one of the 29 sectors
and you need an operationalSWPPP?
Shannon Oelkers (10:59):
You are going to get an owl down your chimney
with a special invitation atmidnight.
Just kidding, Harry Potter andSWPPP's don't mix.
It's based on your SIC or NAICScode.
Weirdly, that SIC or NAICS codecomes from your insurance
documents.
Sector P, for example, includescodes for land transportation
(11:19):
and warehousing.
It also includes codes forrailway operations, the post
office and most bulk fuelstorage.
For example, bulk petroleumfacilities are SIC code 5171.
You can go to Appendix D of theMSGP and you can see a list of
each applicable SIC code foreach sector and it's fun.
(11:39):
You can look up and see if yourfacility's in there.
I also want to give people aheads up just to make.
Some facilities can havemultiple SIC codes going at once
.
So you could have a bulk fuelfacility like a bulk fuel farm,
but it's connected to a serveyourself aviation fueling
(12:00):
station at an airport, in whichcase you would have to meet both
sector P and sector Srequirements at that facility.
So there's nothing like onlyone can apply.
It's not like the Highlander,like, oh, if you've got sector P
, then you don't have to meetsector S, there can be only one.
No, no, no, you have to meetall of them.
You can designate certain areasas your industrial areas for
(12:21):
sector S and your industrialareas for sector P, but they
still both have to be addressed.
Wow, there's a reason.
It's confusing.
See, it's the EPA.
We'll just blame it on the EPAtoday.
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Haley Hall (13:17):
I've also heard people talk about NPDs and APDs
individual permits under theClean Water Act.
How are SWPPPs different fromAPDs and NPDs individual permits
?
Shannon Oelkers (13:27):
Yeah, you picked up on that.
So remember way back when Isaid APDs had four sections and
one was individual.
And then there was those threegeneral permits.
Think of SWPPPs as thepre-approved off-the-shelf
permit available under a generalpermit.
Those individual permits underthe APDs or NPDs program, those
are individually developedpermits for specific conditions
(13:49):
or industries.
They're typically prettyexpensive to develop because
you're creating it from scratchand getting it reviewed by
someone at the state or the EPA.
They are also more expensive tomaintain.
They often require analyticalwater samples instead of more
qualitative measures like visualsurveillance, and your facility
usually has some really trickycomponents that make you
(14:11):
ineligible for the off-the-shelfpermit and that's why you're
pursuing an individual permit.
Individual permits areexpensive.
The only reason someone wouldpursue it is either because they
have something that makes themineligible for SWPPP or they
were part of a previouscompliance effort where they had
some bad problems in thehistory of the facility and one
(14:34):
of the resolutions to thatcompliance issue was that they
obtain an individual permit andmonitor Outside of like being
naughty at some point in thehistory.
Most facilities have anindividual permit if the
groundwater or the surroundingwaters that they discharge to
are impacted by pollution.
So if you've got groundwaterthat's got petroleum hydrocarbon
pollution in it or thesurrounding waters that they
(14:54):
discharge to are impacted bypollution.
So if you've got groundwaterthat's got petroleum hydrocarbon
pollution in it and it'sintermingling with your
stormwater in the ditches, youmight have an APD's permit for
that, because you know the wateris becoming contaminated as it
mingles, or you're dischargingclean water to dirty water, so
to speak.
So those types of situationsare where you would see an
individual permit come in.
(15:15):
And that's what people aretalking about when they speak
about an individual permit.
The SWPPP is saying I have theright kind of industry, I've got
the right kind of water, I'vegot the right kind of operations
and I can do the controlmeasures that are needed to meet
all of these things.
I meet all the pre-approvedstuff.
Therefore, I'm eligible forthis SWPPP and I can just go get
this off the shelf and makesure I meet all the conditions.
Haley Hall (15:36):
Wow, I can't lie.
Shannon In my head, I keepthinking plans and permits and
sectors -Oh my!
Shannon Oelkers (15:44):
We'll follow the yellow brick road to the
water outfall.
Haley Hall (15:48):
Here's another big question what is the workload
like for an MSGP SWPPP?
Shannon Oelkers (15:54):
Yeah, it's less than an individual permit, I
can tell you that, but it'sstill a good chunk of work for
your on the ground staff.
I can kind of just run throughit if you want.
There's some typical sectors.
If you have a SWPPP and you'relistening to this, you should
grab it, because these are allsections in your SWPPP.
All SWPPPs require routineinspections.
Those usually are monthly orquarterly.
(16:15):
Your SWPPP may have somethingdifferent written in it though,
because they can vary.
I would make sure and check.
There's also quarterly samplingof stormwater outfalls.
Some sectors require what wecall qualitative sampling, so
there's no numbers like a visual, a photo, looking for evidence
of certain things.
Others have quantitativemeasures, which would be numbers
(16:36):
, so you have to take a sampleand you have to show that the
sample numbers are below acertain bit.
On top of routine inspectionsand quarterly sampling, there's
also annualdepth inspection andreporting actions to verify that
all the pieces of yourstormwater plan are still
working and in good order andyou're attesting that to the
(16:57):
state of Alaska.
You also need to provide anddocument and I'm going to repeat
, and document regularmaintenance of your control
measures and BMPs, because a lotof those go undocumented.
They fix the valve, but theydon't write it down anywhere.
That needs to be included inyour quarterly reviews.
And then, lastly, if somethinggoes wrong, you can fix it, but
(17:18):
you have to log it in acorrective action log and then
that corrective action trackingneeds to be reported at the end
of the year.
Corrective action is a fancyway of saying we logged that, we
fixed it.
Haley Hall (17:31):
You know I've actually seen this question from
clients a lot.
What are corrective actions?
Shannon Oelkers (17:36):
There's a very long and hard to read section in
MSGP about conditions requiringa review and revision to
eliminate problems.
The plain English version Ithink I'm just going to go to
that.
You can read section eight ofthe MSGP if you want to get deep
in the weeds.
But the plain English versionis if something happens at the
facility that exposes stormwaterto pollutants or could have
(18:00):
exposed stormwater to pollutants, you need to log it in the
corrective action.
So examples of this would be aspill or a leak or a discharge
occurs at the facility tocontainment, to the parking lot,
at the truck rack, even if itdoesn't get discharged to the
waters of the US, you still needto log that your control
measure failed, somethinghappened and fuel was released
where stormwater was and how youcorrected it.
(18:24):
The other thing about thestormwater plan that I think is
often misunderstood is itapplies to all sorts of things
that are part of your sector.
It's not just fuel.
It's not like the SPCC where itonly applies to all sorts of
things that are part of yoursector.
It's not just fuel.
It's not like the SPCC where itonly applies to fuel.
You'll see in like sector P,for example.
They talk about battery storage, waste solvent management, used
oil management.
They have all these otherthings they want you looking at
(18:46):
as part of your stormwaterprocess, because that stuff
can't be left outside to befilled up when it rains right or
to be leached off of as itrains.
So discharges for the stormwaterplan include more than fuel and
I do think that that getsoverlooked by a lot of our
clients.
A discharge violates theallowable contamination limits
under the permit.
So, like I said, some havenumbers, some have visuals.
(19:07):
So if it's very cloudy or avery strange color, that would
be a corrective action.
Even if you don't have a numberfor it.
You can say it's not supposedto be orange and it's orange
today.
I need to log that and figureout why it's orange.
True story in the summer, ifyou have a high algae bloom,
your stormwater outfalls can beorange.
Haley Hall (19:27):
Wow.
Shannon Oelkers (19:29):
Bright, virulently, looks like neon dye
orange, but it's algae.
And then the last piece ofcorrective action is that
control measures are noteffective anymore and that they
need repair or replacement orsomething like that.
And a really good example ofthis is drainage valves on
secondary containment areas.
(19:49):
They are closed over time dueto rust or sediment and then,
instead of replacing that valvebecause it's expensive, you end
up buying a sump pump and yourun the sump pump over the edge
of the containment and you'repumping out to the same place,
but it's not the valve thatyou've got described in your
stormwater plan, it's this newsump pump.
And so you need to update yourSWPPP log the corrective action,
(20:10):
and then explain what you'redoing and make sure that it
matches.
Otherwise that's going to be aviolation, and that's a very
common violation.
I'm probably one of our top five.
So that's corrective actions.
It's something that throwspeople off, but it's a log
tracking things that you fixedat the facility and then you
turn it at the end of the year.
You made it sound so much moreclear than the actual jargon
(20:39):
that we see in the plan, so Iappreciate that.
Conditions requiring review andrevision to eliminate problems
I love the EPA.
They can use 10 words.
They'll use 10.
Haley Hall (20:47):
So incoming buzzword .
My last client-based question -what is a no exposure
certification?
Shannon Oelkers (20:56):
Everybody's favorite Hail Mary.
I'm going to get me a noexposure certification.
I don't need this SWPPP.
The multi-sector general permitapplies to every industrial
facility included in the 29sectors.
However, if you meet certaincriteria, you can file for this
no exposure certification andyou're exempt from the reporting
and monitoring requirements ofthe MSGP SWPPP because you have
(21:19):
attested that no pollution caninteract with stormwater at your
facility.
Haley Hall (21:24):
That seems pretty straightforward, but why did you
say it was a Hail Mary then,Shannon?
Shannon Oelkers (21:29):
Well, so you remember that word I said
attested, that's a legal word.
That means that you areverifying that these statements
are true at all times, and sothe conditions for no exposure
in reality are very difficult tomeet and a single event, such
as a spill to a secondarycontainment that can disqualify
(21:49):
you from no exposurecertification.
We see a lot of companies applyfor that no exposure
certification but when they getaudited by the state or the EPA
it turns out they do not meetthe no exposure requirements.
They're forced to immediatelyget a SWPPP and then they face
violations and penalties forsaying they attested that the no
exposure conditions were true,but they were in fact not true.
(22:09):
For our clients that do file forno exposure certification, we
set them up with an annualreporting system, record keeping
forms and like a housekeepingchecklist, and so it sort of
documents that they arecontinuously meeting the no
exposure conditions.
So it's not really a trueexemption.
For most facilities you stillhave to document that you're
meeting the requirements of theno exposure to meet that
(22:32):
attestation piece of it.
So it's still work Maybe not asmuch work as a SWPPP with the
quarterly visuals and thecorrective action log and all
that stuff, but it's still like75% of the work of a SWPPP.
Actually, Haley, we shouldprobably do a whole podcast on
no exposure in the future.
Because it looks so simple onthe surface, lots of people sign
up for it and they have no ideahow tricky that can be on the
(22:54):
back end.
Haley Hall (22:54):
Absolutely Well, we've talked about so much.
Could you provide us a goodsummary of what we just talked
about to just wrap up thisepisode?
Shannon Oelkers (23:02):
okay, hold on, let me crack my knuckles in my
neck.
It's going to take me a minutebecause I did cover a lot.
So SWPPPs are tricky, but Ithink if you understand that
there can be multiple thingscalled a SWPPP and they're
different depending on whatpermit they're under, that's
part of untangling this.
So under the Federal CleanWater Act, stormwater is
protected from pollution andthat protection comes in the
(23:24):
form of permits and there aregenerally two kinds an
individual permit or a generalpermit.
And then under the generalpermit, there are three kinds of
general permits theconstruction general permit, the
MS4, and the multi-sectorgeneral permit.
Those individual permits that Imentioned are individually
negotiated with the state or theEPA and they're typically
(23:45):
referred to as NPDs or thestate-specific acronym, which
for Alaska would be APDs.
General permits arepre-approved permits for
specific industrial sectors andthey fall under that
multi-sector construction or MS4, so under one of those columns.
And then for bulk fuelfacilities, shipyards and
airports which in utilities kindof covers a lot of our
(24:08):
listeners the MSGP will apply toyour facility operations.
If your industry is subject tothe MSGP, you have to have
either a SWPPP or a no exposurecertification in place, and I
want everyone listening to hearme say you have to have one or
the other, you cannot have none.
So if your SIC code is listedin Appendix D, you have to have
one of the two of these in placeand perform the required record
(24:30):
keeping and monitoring.
I think that's a nice summary.
I get everything With a littlebow on top.
I even referenced Appendix Dand our SIC codes again.
Haley Hall (24:40):
Well, shannon, thank you so much for sorting out
SWPPPs for me and our listeners.
I'm sure there is so much moreto learn, as always, but do you
have any recommendations forthose looking to learn more now?
Shannon Oelkers (24:51):
Thank you, Haley.
Yes, there are some goodresources.
If you need to learn more aboutstormwater plans, I'm going to
list references that cost moneyand are free, because a lot of
people are doing this for theirjobs, right.
So theoretically there's somemoney for training If you are
responsible for a constructiongeneral permit, SWPPP.
The Alaska Association ofGeneral Contractors has a
(25:12):
stellar training program.
It's called the AlaskaCertified Erosion and Sediment
Control Lead, aka CECLcertification.
It's great, all of our stafftake it that perform work in the
field and we write those SWPPPsfrom that training.
But keep in mind this trainingis only good for construction
SWPPPs and they do have somebrief mentions of MSGP as it
(25:34):
applies to constructionfacilities.
So you might have, like, anasphalt batch plant that needs a
sector something I think it's Jor G while it's operating.
Or you might have a gravel pullthat's going to require a
sector J while it's in effect,but it only touches on those
very small things.
It's not covering MSGPfacilities in like long term.
(25:56):
It's all related back to thatCGP short term.
So if you do have a facility,integrity Environmental does
have a training program.
We have both an in-person oneif that's your jam, but we also
have an online training.
You can sign up for an initialfor the MSGP and you can pick
the sectors that apply to you.
We have modules for those.
(26:16):
And then, after that initial,we also have an annual refresher
that meets the requirements ofMSGP section 4.2.9, which
requires an annual review ofyour SWPPP.
We created that for our clients, to help them document that
these annual trainers andinitial trainings for your
stormwater pollution preventionteam were all occurring.
So those are two greatresources.
They do cost money, though, butI do have some free resources
(26:38):
because I know people love thatfree stuff.
There's two general sources offree information the state of
Alaska, since a lot of ourclients operate there, and then
also the EPA stormwater sites.
So let's start off.
The state of Alaska, funnilyenough, has a page for every
single one of the options underthe APDs program.
So there's a page for the MSGP,there's a page for the CGP,
(27:01):
there's a page for the MS4, andthere is a page for the
individual permit, which tiesnicely into our categories.
We will include links to eachone of those pages if you want
to check them out, based onwhere you think your facility
falls or what your interestfalls under SWPS, the EPA.
They have two websites.
One is the NPDs just regularNPDs, and it sort of sorts out
(27:25):
general permits and individualsthere.
But we also included the MSGPunder the NPDs EPA website
because that one talksspecifically about state and
federal facilities that aresubject to the EPA MSGP, which
is different than the statespecific ones.
And then, lastly, I included afun little free resource.
It's the EPA NationalStormwater Calculator and you
(27:48):
can put in all sorts of placesfacilities, roadways, your own
house and you can kind of seeyour stormwater exposure or the
anticipated stormwater exposure.
It also will give you ideas onhow to lessen stormwater runoff,
like by planting rain gardensor doing fun things like that.
So you know, I use this with mykids when we're homeschooling
during COVID.
(28:08):
It's a super fun little site.
I would recommend playingaround with it.
It's fun.
Haley Hall (28:13):
Awesome.
Shannon Oelkers (28:14):
All right.
Well, thank you, Haley, forhelping me straighten out SWPPPS
.
It's something that reallyconfuses people and I thought if
we put this podcast out there,if you are sitting in a seat and
you're trying to figure outSWPPPS for the first time,
hopefully this will at leastgive you a place to start.
And, as always, if you havefurther questions or podcast
(28:34):
ideas, go ahead and give us anemail at the link in our show
notes and we're happy to takethat into consideration.
Haley Hall (28:38):
Thanks, Shannon.
Shannon Oelkers (28:39):
Yeah, thank you .
Hi there, this is ShannonOelkers and, as the owner of
Integrity Environmental, Iwanted to take a minute here at
the end of the podcast to makesure that you knew the following
this podcast is forinformational purposes only and
should not be considered legalor regulatory advice.
We are not responsible for anylosses, damages or liabilities
(29:00):
that may arise from the use ofthis podcast.
This podcast is not intended toreplace professional regulatory
or legal advice, and the viewsexpressed in this podcast may
not be those of the regulatoryor legal advice, and the views
expressed in this podcast maynot be those of the host that
would be me or IntegrityEnvironmental.
Thank you very much forlistening and if you do need
professional regulatory advice,we'd be happy to help you as
(29:21):
part of our consulting services.
Welcome to Tank Talk with Integrity Environmental.
Join us as we sit down withfounder, principal consultant
and bulk fuel storage expert,Shannon Oelkers, to explore
regulations, safety andessential tips for navigating
the bulk fuel storage industry.
Join us as we explore theunique joys of work and life in
Alaska with industry experts,including our team, vendors we
(00:30):
work with and the companies wesupport.
Shannon Oelkers (00:34):
Hello, welcome to Tank Talk.
This is Shannon Oelkers, andtoday I wanted to talk about
SWPPPs, and you may be wondering, dear listener, what a SWPPP is
.
I think most people have heardof it, but just to be super
clear, a SWPPP is an acronym fora Stormwater Pollution
Prevention Plan, and SWPPPs aregenerally permits to prevent
(00:54):
pollution from enteringstormwater.
However, in our SWPPP's, can bevery confusing for people in
the bulk fuels industry andindustry in general, and there
is a good reason as to why HaleyHall is going to join us today.
Haley, what do you know aboutSWPPP's?
Haley Hall (01:13):
You know I'm still learning Shannon and I'm excited
to dig in today, but what I'mreally wanting to know is what
is the reason why our clientsare so confused about SWPPP'S?
Shannon Oelkers (01:23):
The EPA! Podcast over.
Just kidding - the EPA reallyis the reason why our clients
are so confused about SWPPP's.
Swifts are part of the CleanWater Act, which is an old
regulation with lots of what Iwould call "nested regulations
within it.
So, it goes all the way back tolike the end of World War II.
In 1948, there was a federalwater pollution control act
(01:44):
passed and then over the yearsthat eventually turned into the
clean water act in 1972.
And that's the modern versionof stormwater pollution control
and that clean water act.
There's a fun fact well, a notso fun fact, if you will.
The clean water Act was passedbecause of the Cuyahoga River
Fire in 1968.
(02:06):
And if you love history and youwant to be incredibly depressed
, Google the Cuyahoga River Fireof 1968 and watch the YouTube
videos, because it's a very sad,impactful lesson on the dangers
of polluting our rivers andletting them catch on fire.
But once the Clean Water Actwas passed in 1972, there was
regulations that were passed toensure that the mandates of the
(02:29):
Clean Water Act were being met,and the one that covers SWPS in
general is 40 CFR 122.
And then the way the federalprogram works you can have state
primacy, the feds can haveprimacy, and then some states
share, so they have stateprimacy.
The feds can have primacy andthen some states share, so they
have state primacy for stateareas and the federal group has
(02:50):
the federal permitting in theirarea.
That gets a little confusingmaybe too confusing for this
podcast, but for the averageperson both the state and
federal groups, so the EPA andthen your state environmental
group, they all have agency andcan assess violations and they
can do inspections and they canassess fines.
How do SWPPPs fit into all this?
They're the bottom of thisnesting.
(03:12):
So under the federal programthere's something called a
national, it's called the NPDsprogram, but I got to like look
up all the letters because it'shard to keep these straight and
if you're listening to this,this is about to be alphabet
soup, so I apologize.
The NPDs program is the NationalPollutant Discharge Elimination
System program, NPDs and thenin the state of Alaska, where we
(03:33):
have a lot of our clients, it'sthe Alaska Pollutant Discharge
Elimination System or the APDsprogram.
Those two programs have twoways to issue permits for people
who are operating in certainindustries so that they can
control the amount of pollutantsthat stormwater is exposed to.
One of those ways is anindividual permit, which we'll
(03:54):
talk about in a little bit, andthen the other way is in a
general permit, and the generalpermit is like a pre-approved
limit for specific kinds ofindustries.
So the EPA and the state satdown and thought about all these
different industries and said,for these specific industries,
these are the rules aboutstormwater exposure.
So once we get to that, I guessPDs level.
(04:17):
But for the sake of thisconversation, since a lot of our
listeners are focused on thestate of Alaska, let's focus on
the APDs program.
Under the APDs program, thereare three general permits and
then, of course, the individualpermit program.
Right, those three generalpermits are the multi-sector
general permit, the constructiongeneral permit and then there's
(04:38):
something called an MS4, whichis super fun, An MS4 is a
municipal separate storm sewersystem.
So the four refers to the fourS's that we are not saying,
which I am thankful for, becauseI could not say a S, that would
be a lot.
So there's those three, andthen the individual permit and
then the three general permitsissue SWPPPs underneath them,
(05:00):
and I think that's where a lotof the confusion comes from,
because we've got threedifferent areas.
All those general permits dodifferent things.
For example, the MS4, I thinkpeople who live in Anchorage or
maybe in Fairbanks would be morefamiliar with it.
It's a system of public.
It's like a city sewer or asuburban area sewer.
It's a system of publicly ownedditches, pipes and other
(05:21):
features that collect and managestormwater in urban and
suburban areas.
Alaska has relatively few.
If you live in the state ofWashington or Oregon, every
community has an MS4.
But in Alaska we only have one.
Well, there's a few others, butthe big ones are the
municipality of Anchorage, theFairbanks, north Star Borough
and the Port of Alaska.
Those MS4 permittees.
(05:42):
They're required to develop astormwater management plan for
the whole city or the wholesuburban or urban area.
And then if you have aconstruction SWPPP or a
multi-sector SWPPP within theMS4, you have to meet the MS4
requirements in addition to themore general conditions under
MSGP or GP.
So that's a lot of GP Haley.
Haley Hall (06:02):
So a GP for municipalities seems
straightforward, as most largercities have a stormwater
drainage system.
But what is the real differencebetween a CGP and an MSGP?
Shannon Oelkers (06:14):
I think this is the heart of the confusion.
I mean, a lot of people havedriven on roads and they've seen
big signs nailed into theground that says SWPPP permit
information here.
They've seen that posted andthey've seen them posted on lots
during construction projects.
The easiest way I found to keepthe CGPs and MSGPs separate in
my mind is that a constructiongeneral permit applies to
(06:35):
construction projects andthere's sort of a short term and
duration.
They mainly focus on preventingrunoff, erosion and
sedimentation in addition topollution prevention during
construction activities.
And then your control measuresand best management practices
change frequently, sometimesdaily or even hourly.
If you have a big storm eventor bad weather that affects all
(06:56):
the things you have planned andthey sort of address immediate
needs and require constantmonitoring.
And when you look at themulti-sector general permit,
that's basically an operatingpermit for industry facilities
where stormwater could come intocontact with pollutants as they
perform their daily tasks.
But these tasks rarely change.
The control measures rarelychange and they often stay the
(07:18):
same.
Once they're installed theyjust need maintenance and
operations.
You're not going to havesomebody say oh, I need to pull
out this manual operated valveand throw some straw waddles on
today because it's raining sohard they would just.
The controls are alreadyaccounting for that and they
just need to maintain them.
The MSGP usually doesn't dealwith sedimentation and erosion
as a major concern.
It can happen, especially ifyou change your outfall location
(07:40):
or something for a containmentarea, but it's nothing like the
focus that the constructiongeneral permit has, because
you're, you know, creating a newroadway or pulling up an
existing roadway and putting anew one down.
There's a whole lot moreerosion and sediment control
with construction.
I do want to point out, though,that the biggest problem that
our firm sees with SWPPPs isthat we will sometimes go to
(08:04):
facilities and they'll pull outa SWPPP for us to review, and
whoever wrote that SWPPPborrowed heavily from the
construction general permit, andI understand that because a lot
of people in the industry haveworked in construction and
worked at main facilities andthey're both called SWPPPs.
No big deal.
SWPPP from here, SWPPP to there, nuts to bolts I got soup right
.
That's not how it works,because the background of the
(08:27):
two permits is so different, andso the assumptions that go into
a construction permit.
You know that there's a settime these will be in place and
then there'll be removed andthat the project itself will
progress and move down theroadway and then at some point
no longer be needed and beremoved completely, are so
different to the multi-sectorgeneral permit, which assumes
infinite operation.
(08:48):
And then there's ongoing monthlyyou know, ongoing maintenance
and operation and record keeping.
And so when you borrow partsfrom the construction permit,
the general permit, and stuff itinto an MSGP, it doesn't meet
the MSGP at all.
They're two different thingsand so firms like ours, we write
(09:09):
both no big deal.
We understand the regulationsunderneath, but I want our
listeners to be aware andunderstand the difference
between the two.
So when you're hiring aconsultant or you're trying to
do it yourself, you're gettingthe permit coverage that you
need.
You need to go to the MSGP siteand read that permit for how
your permit coverage is going tobe written under in the SWPPP,
which is the chapter underneathMSGP.
You can't just borrow from theconstruction permit,
(09:32):
unfortunately.
Haley Hall (09:33):
I think that makes sense.
But, Shannon, are operationalSWPPPs under the MSGP the same
across every industry?
Yes and no.
Don't you love that answer.
The multi-sector general permithas 10 sections that are
general and apply to allfacilities, and then they have
sector specific requirementsthat have different conditions
(09:56):
based on the kind of industrialactivity you're doing.
So it's a yes and no.
I'm sorry, wait, but what's asector?
Ooh, a sector is another termyou have to know if you're going
to do stormwater.
So write that one down, becausewe need some more words in this
alphabet soup.
Sectors are 29 identifiedindustrial areas included in the
(10:18):
MSGP.
It's Appendix D.
Each sector describes the typeof facilities included in that
sector, the typical pollutantsincluded in that sector, the
typical pollutants associatedwith the sector and types of
stormwater control measures thatyou should be using to minimize
the discharge of pollutionspecific to the industry type.
Each one of these sectors hasdifferent things and it's
related to the types ofactivities that they're doing.
So a really good example ofthis Sector S.
(10:39):
It applies to aircraftmaintenance at airports and
operations.
They have quite a fewrequirements related to de-icing
fluid, which you aren't goingto see de-icing fluid in any of
the other sectors.
It's just specific to aircraftand that sector.
So how do you know if you're one of the 29 sectors
and you need an operationalSWPPP?
Shannon Oelkers (10:59):
You are going to get an owl down your chimney
with a special invitation atmidnight.
Just kidding, Harry Potter andSWPPP's don't mix.
It's based on your SIC or NAICScode.
Weirdly, that SIC or NAICS codecomes from your insurance
documents.
Sector P, for example, includescodes for land transportation
(11:19):
and warehousing.
It also includes codes forrailway operations, the post
office and most bulk fuelstorage.
For example, bulk petroleumfacilities are SIC code 5171.
You can go to Appendix D of theMSGP and you can see a list of
each applicable SIC code foreach sector and it's fun.
(11:39):
You can look up and see if yourfacility's in there.
I also want to give people aheads up just to make.
Some facilities can havemultiple SIC codes going at once
.
So you could have a bulk fuelfacility like a bulk fuel farm,
but it's connected to a serveyourself aviation fueling
(12:00):
station at an airport, in whichcase you would have to meet both
sector P and sector Srequirements at that facility.
So there's nothing like onlyone can apply.
It's not like the Highlander,like, oh, if you've got sector P
, then you don't have to meetsector S, there can be only one.
No, no, no, you have to meetall of them.
You can designate certain areasas your industrial areas for
(12:21):
sector S and your industrialareas for sector P, but they
still both have to be addressed.
Wow, there's a reason.
It's confusing.
See, it's the EPA.
We'll just blame it on the EPAtoday.
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(12:41):
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Haley Hall (13:17):
I've also heard people talk about NPDs and APDs
individual permits under theClean Water Act.
How are SWPPPs different fromAPDs and NPDs individual permits
?
Shannon Oelkers (13:27):
Yeah, you picked up on that.
So remember way back when Isaid APDs had four sections and
one was individual.
And then there was those threegeneral permits.
Think of SWPPPs as thepre-approved off-the-shelf
permit available under a generalpermit.
Those individual permits underthe APDs or NPDs program, those
are individually developedpermits for specific conditions
(13:49):
or industries.
They're typically prettyexpensive to develop because
you're creating it from scratchand getting it reviewed by
someone at the state or the EPA.
They are also more expensive tomaintain.
They often require analyticalwater samples instead of more
qualitative measures like visualsurveillance, and your facility
usually has some really trickycomponents that make you
(14:11):
ineligible for the off-the-shelfpermit and that's why you're
pursuing an individual permit.
Individual permits areexpensive.
The only reason someone wouldpursue it is either because they
have something that makes themineligible for SWPPP or they
were part of a previouscompliance effort where they had
some bad problems in thehistory of the facility and one
(14:34):
of the resolutions to thatcompliance issue was that they
obtain an individual permit andmonitor Outside of like being
naughty at some point in thehistory.
Most facilities have anindividual permit if the
groundwater or the surroundingwaters that they discharge to
are impacted by pollution.
So if you've got groundwaterthat's got petroleum hydrocarbon
pollution in it or thesurrounding waters that they
(14:54):
discharge to are impacted bypollution.
So if you've got groundwaterthat's got petroleum hydrocarbon
pollution in it and it'sintermingling with your
stormwater in the ditches, youmight have an APD's permit for
that, because you know the wateris becoming contaminated as it
mingles, or you're dischargingclean water to dirty water, so
to speak.
So those types of situationsare where you would see an
individual permit come in.
(15:15):
And that's what people aretalking about when they speak
about an individual permit.
The SWPPP is saying I have theright kind of industry, I've got
the right kind of water, I'vegot the right kind of operations
and I can do the controlmeasures that are needed to meet
all of these things.
I meet all the pre-approvedstuff.
Therefore, I'm eligible forthis SWPPP and I can just go get
this off the shelf and makesure I meet all the conditions.
Haley Hall (15:36):
Wow, I can't lie.
Shannon In my head, I keepthinking plans and permits and
sectors -Oh my!
Shannon Oelkers (15:44):
We'll follow the yellow brick road to the
water outfall.
Haley Hall (15:48):
Here's another big question what is the workload
like for an MSGP SWPPP?
Shannon Oelkers (15:54):
Yeah, it's less than an individual permit, I
can tell you that, but it'sstill a good chunk of work for
your on the ground staff.
I can kind of just run throughit if you want.
There's some typical sectors.
If you have a SWPPP and you'relistening to this, you should
grab it, because these are allsections in your SWPPP.
All SWPPPs require routineinspections.
Those usually are monthly orquarterly.
(16:15):
Your SWPPP may have somethingdifferent written in it though,
because they can vary.
I would make sure and check.
There's also quarterly samplingof stormwater outfalls.
Some sectors require what wecall qualitative sampling, so
there's no numbers like a visual, a photo, looking for evidence
of certain things.
Others have quantitativemeasures, which would be numbers
(16:36):
, so you have to take a sampleand you have to show that the
sample numbers are below acertain bit.
On top of routine inspectionsand quarterly sampling, there's
also annualdepth inspection andreporting actions to verify that
all the pieces of yourstormwater plan are still
working and in good order andyou're attesting that to the
(16:57):
state of Alaska.
You also need to provide anddocument and I'm going to repeat
, and document regularmaintenance of your control
measures and BMPs, because a lotof those go undocumented.
They fix the valve, but theydon't write it down anywhere.
That needs to be included inyour quarterly reviews.
And then, lastly, if somethinggoes wrong, you can fix it, but
(17:18):
you have to log it in acorrective action log and then
that corrective action trackingneeds to be reported at the end
of the year.
Corrective action is a fancyway of saying we logged that, we
fixed it.
Haley Hall (17:31):
You know I've actually seen this question from
clients a lot.
What are corrective actions?
Shannon Oelkers (17:36):
There's a very long and hard to read section in
MSGP about conditions requiringa review and revision to
eliminate problems.
The plain English version Ithink I'm just going to go to
that.
You can read section eight ofthe MSGP if you want to get deep
in the weeds.
But the plain English versionis if something happens at the
facility that exposes stormwaterto pollutants or could have
(18:00):
exposed stormwater to pollutants, you need to log it in the
corrective action.
So examples of this would be aspill or a leak or a discharge
occurs at the facility tocontainment, to the parking lot,
at the truck rack, even if itdoesn't get discharged to the
waters of the US, you still needto log that your control
measure failed, somethinghappened and fuel was released
where stormwater was and how youcorrected it.
(18:24):
The other thing about thestormwater plan that I think is
often misunderstood is itapplies to all sorts of things
that are part of your sector.
It's not just fuel.
It's not like the SPCC where itonly applies to all sorts of
things that are part of yoursector.
It's not just fuel.
It's not like the SPCC where itonly applies to fuel.
You'll see in like sector P,for example.
They talk about battery storage, waste solvent management, used
oil management.
They have all these otherthings they want you looking at
(18:46):
as part of your stormwaterprocess, because that stuff
can't be left outside to befilled up when it rains right or
to be leached off of as itrains.
So discharges for the stormwaterplan include more than fuel and
I do think that that getsoverlooked by a lot of our
clients.
A discharge violates theallowable contamination limits
under the permit.
So, like I said, some havenumbers, some have visuals.
(19:07):
So if it's very cloudy or avery strange color, that would
be a corrective action.
Even if you don't have a numberfor it.
You can say it's not supposedto be orange and it's orange
today.
I need to log that and figureout why it's orange.
True story in the summer, ifyou have a high algae bloom,
your stormwater outfalls can beorange.
Haley Hall (19:27):
Wow.
Shannon Oelkers (19:29):
Bright, virulently, looks like neon dye
orange, but it's algae.
And then the last piece ofcorrective action is that
control measures are noteffective anymore and that they
need repair or replacement orsomething like that.
And a really good example ofthis is drainage valves on
secondary containment areas.
(19:49):
They are closed over time dueto rust or sediment and then,
instead of replacing that valvebecause it's expensive, you end
up buying a sump pump and yourun the sump pump over the edge
of the containment and you'repumping out to the same place,
but it's not the valve thatyou've got described in your
stormwater plan, it's this newsump pump.
And so you need to update yourSWPPP log the corrective action,
(20:10):
and then explain what you'redoing and make sure that it
matches.
Otherwise that's going to be aviolation, and that's a very
common violation.
I'm probably one of our top five.
So that's corrective actions.
It's something that throwspeople off, but it's a log
tracking things that you fixedat the facility and then you
turn it at the end of the year.
You made it sound so much moreclear than the actual jargon
(20:39):
that we see in the plan, so Iappreciate that.
Conditions requiring review andrevision to eliminate problems
I love the EPA.
They can use 10 words.
They'll use 10.
Haley Hall (20:47):
So incoming buzzword .
My last client-based question -what is a no exposure
certification?
Shannon Oelkers (20:56):
Everybody's favorite Hail Mary.
I'm going to get me a noexposure certification.
I don't need this SWPPP.
The multi-sector general permitapplies to every industrial
facility included in the 29sectors.
However, if you meet certaincriteria, you can file for this
no exposure certification andyou're exempt from the reporting
and monitoring requirements ofthe MSGP SWPPP because you have
(21:19):
attested that no pollution caninteract with stormwater at your
facility.
Haley Hall (21:24):
That seems pretty straightforward, but why did you
say it was a Hail Mary then,Shannon?
Shannon Oelkers (21:29):
Well, so you remember that word I said
attested, that's a legal word.
That means that you areverifying that these statements
are true at all times, and sothe conditions for no exposure
in reality are very difficult tomeet and a single event, such
as a spill to a secondarycontainment that can disqualify
(21:49):
you from no exposurecertification.
We see a lot of companies applyfor that no exposure
certification but when they getaudited by the state or the EPA
it turns out they do not meetthe no exposure requirements.
They're forced to immediatelyget a SWPPP and then they face
violations and penalties forsaying they attested that the no
exposure conditions were true,but they were in fact not true.
(22:09):
For our clients that do file forno exposure certification, we
set them up with an annualreporting system, record keeping
forms and like a housekeepingchecklist, and so it sort of
documents that they arecontinuously meeting the no
exposure conditions.
So it's not really a trueexemption.
For most facilities you stillhave to document that you're
meeting the requirements of theno exposure to meet that
(22:32):
attestation piece of it.
So it's still work Maybe not asmuch work as a SWPPP with the
quarterly visuals and thecorrective action log and all
that stuff, but it's still like75% of the work of a SWPPP.
Actually, Haley, we shouldprobably do a whole podcast on
no exposure in the future.
Because it looks so simple onthe surface, lots of people sign
up for it and they have no ideahow tricky that can be on the
(22:54):
back end.
Haley Hall (22:54):
Absolutely Well, we've talked about so much.
Could you provide us a goodsummary of what we just talked
about to just wrap up thisepisode?
Shannon Oelkers (23:02):
okay, hold on, let me crack my knuckles in my
neck.
It's going to take me a minutebecause I did cover a lot.
So SWPPPs are tricky, but Ithink if you understand that
there can be multiple thingscalled a SWPPP and they're
different depending on whatpermit they're under, that's
part of untangling this.
So under the Federal CleanWater Act, stormwater is
protected from pollution andthat protection comes in the
(23:24):
form of permits and there aregenerally two kinds an
individual permit or a generalpermit.
And then under the generalpermit, there are three kinds of
general permits theconstruction general permit, the
MS4, and the multi-sectorgeneral permit.
Those individual permits that Imentioned are individually
negotiated with the state or theEPA and they're typically
(23:45):
referred to as NPDs or thestate-specific acronym, which
for Alaska would be APDs.
General permits arepre-approved permits for
specific industrial sectors andthey fall under that
multi-sector construction or MS4, so under one of those columns.
And then for bulk fuelfacilities, shipyards and
airports which in utilities kindof covers a lot of our
(24:08):
listeners the MSGP will apply toyour facility operations.
If your industry is subject tothe MSGP, you have to have
either a SWPPP or a no exposurecertification in place, and I
want everyone listening to hearme say you have to have one or
the other, you cannot have none.
So if your SIC code is listedin Appendix D, you have to have
one of the two of these in placeand perform the required record
(24:30):
keeping and monitoring.
I think that's a nice summary.
I get everything With a littlebow on top.
I even referenced Appendix Dand our SIC codes again.
Haley Hall (24:40):
Well, shannon, thank you so much for sorting out
SWPPPs for me and our listeners.
I'm sure there is so much moreto learn, as always, but do you
have any recommendations forthose looking to learn more now?
Shannon Oelkers (24:51):
Thank you, Haley.
Yes, there are some goodresources.
If you need to learn more aboutstormwater plans, I'm going to
list references that cost moneyand are free, because a lot of
people are doing this for theirjobs, right.
So theoretically there's somemoney for training If you are
responsible for a constructiongeneral permit, SWPPP.
The Alaska Association ofGeneral Contractors has a
(25:12):
stellar training program.
It's called the AlaskaCertified Erosion and Sediment
Control Lead, aka CECLcertification.
It's great, all of our stafftake it that perform work in the
field and we write those SWPPPsfrom that training.
But keep in mind this trainingis only good for construction
SWPPPs and they do have somebrief mentions of MSGP as it
(25:34):
applies to constructionfacilities.
So you might have, like, anasphalt batch plant that needs a
sector something I think it's Jor G while it's operating.
Or you might have a gravel pullthat's going to require a
sector J while it's in effect,but it only touches on those
very small things.
It's not covering MSGPfacilities in like long term.
(25:56):
It's all related back to thatCGP short term.
So if you do have a facility,integrity Environmental does
have a training program.
We have both an in-person oneif that's your jam, but we also
have an online training.
You can sign up for an initialfor the MSGP and you can pick
the sectors that apply to you.
We have modules for those.
(26:16):
And then, after that initial,we also have an annual refresher
that meets the requirements ofMSGP section 4.2.9, which
requires an annual review ofyour SWPPP.
We created that for our clients, to help them document that
these annual trainers andinitial trainings for your
stormwater pollution preventionteam were all occurring.
So those are two greatresources.
They do cost money, though, butI do have some free resources
(26:38):
because I know people love thatfree stuff.
There's two general sources offree information the state of
Alaska, since a lot of ourclients operate there, and then
also the EPA stormwater sites.
So let's start off.
The state of Alaska, funnilyenough, has a page for every
single one of the options underthe APDs program.
So there's a page for the MSGP,there's a page for the CGP,
(27:01):
there's a page for the MS4, andthere is a page for the
individual permit, which tiesnicely into our categories.
We will include links to eachone of those pages if you want
to check them out, based onwhere you think your facility
falls or what your interestfalls under SWPS, the EPA.
They have two websites.
One is the NPDs just regularNPDs, and it sort of sorts out
(27:25):
general permits and individualsthere.
But we also included the MSGPunder the NPDs EPA website
because that one talksspecifically about state and
federal facilities that aresubject to the EPA MSGP, which
is different than the statespecific ones.
And then, lastly, I included afun little free resource.
It's the EPA NationalStormwater Calculator and you
(27:48):
can put in all sorts of placesfacilities, roadways, your own
house and you can kind of seeyour stormwater exposure or the
anticipated stormwater exposure.
It also will give you ideas onhow to lessen stormwater runoff,
like by planting rain gardensor doing fun things like that.
So you know, I use this with mykids when we're homeschooling
during COVID.
(28:08):
It's a super fun little site.
I would recommend playingaround with it.
It's fun.
Haley Hall (28:13):
Awesome.
Shannon Oelkers (28:14):
All right.
Well, thank you, Haley, forhelping me straighten out SWPPPS
.
It's something that reallyconfuses people and I thought if
we put this podcast out there,if you are sitting in a seat and
you're trying to figure outSWPPPS for the first time,
hopefully this will at leastgive you a place to start.
And, as always, if you havefurther questions or podcast
(28:34):
ideas, go ahead and give us anemail at the link in our show
notes and we're happy to takethat into consideration.
Haley Hall (28:38):
Thanks, Shannon.
Shannon Oelkers (28:39):
Yeah, thank you .
Hi there, this is ShannonOelkers and, as the owner of
Integrity Environmental, Iwanted to take a minute here at
the end of the podcast to makesure that you knew the following
this podcast is forinformational purposes only and
should not be considered legalor regulatory advice.
We are not responsible for anylosses, damages or liabilities
(29:00):
that may arise from the use ofthis podcast.
This podcast is not intended toreplace professional regulatory
or legal advice, and the viewsexpressed in this podcast may
not be those of the regulatoryor legal advice, and the views
expressed in this podcast maynot be those of the host that
would be me or IntegrityEnvironmental.
Thank you very much forlistening and if you do need
professional regulatory advice,we'd be happy to help you as
(29:21):
part of our consulting services.
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