SWPPP Plans & SPCC Plans - Should I keep them in one book?

I visit a lot of facilities for inspections, audits, and other reasons. Often I see their SWPPP plan and SPCC plan combined into one notebook or binder. Seems to make sense from the sense of having only one notebook to worry about, but is this a good idea?

Your SWPPP plan is the most common requirement under your facility’s NPDES permit – typically a stormwater discharge permit. Your NPDES stormwater permit requires that you prepare and implement an SWPPP plan to describe your facility and its potential for causing stormwater pollution, as well as the steps and practices you will be implementing to reduce or eliminate that stormwater pollution.

Those steps and practices collectively are called BMPs (or Best Management Practices). In all likelihood, your NPDES stormwater permit has a list of required stormwater BMPs that you must implement, such as stormwater training, inspections – and spill prevention and cleanup.

Virtually all stormwater permit requirements say that if you are subject to the Federal SPCC regulations, you can reference it in your SWPPP as providing sufficient documentation with regards to spill prevention and control; in other words, you don’t need to re-invent the wheel.

However, keep in mind that your NPDES stormwater permit is probably (in the large majority of states in the US) issued by your state or local environmental regulatory agency. Not the Federal USEPA, although they retain oversight capacity. This means, nearly all inspections are made by state and local environmental inspectors.

Your SPCC (Spill Prevention, Control and Countermeasure) plan, conversely, is required by Federal law and not subject to nearly any state or local regulation, although some states and localities do inspect them. In most cases, it would be the Federal USEPA who would review and inspect your SPCC plans.

So should you combine your stormwater plan and SPCC plan into one book?

There's really two ways to look at it:

YES, you should combine them into one book.

• It makes it easier if these two common plans are in the same place.
• Perhaps you might like to conduct common site inspections, for both SWPPP and SPCC purposes.

NO, you should not combine your them into one book.

• Why make it easier for a state inspector to take a look at something that they may not understand or have only limited experience with (remember, the state doesn’t inspect your SPCC plan), while also making it easy for Federal inspectors to look at things they may not have a direct interest in (the EPA guys don’t inspect for SWPPP plans).
• You can easily make two notebooks, and keep them side-by-side on your shelf. Not a big deal.
• They are clearly apples and oranges. Your SWPPP plan includes the need for BMPs including spill prevention and cleanup – all any and all materials capable of spilling or leaking on your site, including chemicals and other non-petroleum products. Your SPCC plan only deals with oil / petroleum stored on your site, and doesn’t include chemicals or materials other than oils. I’ve seen an awful lot of SWPPP where the spill prevention and cleanup BMP section only references an SPCC, neglecting chemicals, solvents, paints, admixtures, etc.
• One meets permit requirements (stormwater permits), and the other doesn’t (SPCC). Why confuse the two?

My advice? Don’t combine them. Two separate notebooks, for two different purposes, and two separate sets of requirements. While there might be some reasons to combine them, I think the negatives clearly outweigh the positives.

If you're just learning about these topics, and would like more information or advice, click here to contact us or give us a call anytime at 609-693-8301 to discuss these regulations and how they impact your operation or facility.