It’s raining, it’s pouring. There’s no time for snoring. Because stormwater management is an issue that environment, health, and safety leaders can’t afford to be ignoring.
With environmental changes affecting weather patterns, while regulations and requirements continue to evolve, stormwater management is a bit of a moving target these days. Developing a future-proof program to effectively manage compliance for the long-term requires a proactive mindset, coupled with an understanding of the current picture and outlook for this important environmental focus.
Today, we’ll try to help you arrive at both.
What is Stormwater Management?
Stormwater management includes the handling of precipitation such as rain, sleet, or melting snow and ice with an aim to prevent pollution, erosion, and other negative consequences. While precipitation frequently absorbs into the soil, stormwater runoff is created when precipitation lands on impervious surfaces. This runoff can pick up and carry any number of chemicals, fertilizers, or other properties and potentially alter the land’s natural hydrology and water supply.
These are all considerations that fall under the umbrella of stormwater management. Programs focus on areas such as:
- Water recycling and supply systems
- Wastewater treatment facilities
- Stormwater management procedures and protocols
- Inspections and sampling
- Permits and compliance
- Employee training and education
As such, the Environmental Protection Agency (EPA) has established industry-specific compliance guidelines, which are enforced at or above those levels by state governments.
Why Is Stormwater Management a Growing Priority?
Just as clouds forming overhead warn of an impending storm, these developments serve as indicators that stormwater management is poised to keep rising as a critical consideration from an EHS standpoint.
Climate Change
Changes to our planet are affecting precipitation patterns in noticeable ways. “As the reality of climate change creates increasingly intense storms, this work is more important now than ever,” argues Sara Churgin, co-chair of the inaugural Stormwater Innovation Expo that occurred late 2019 in Rhode Island.
Evolving Compliance Regulations
Not only are environmental factors upping the urgency, but so too are government regulations, most notably under the National Pollutant Discharge Elimination System (NPDES). Water quality is a fundamental focus for our society, and one that we all can work collectively to improve. Its sustainability impact overlaps and ripples outward — for example, using less chemicals supports both stormwater management and eco-friendly practices in general.
Ethical and regulatory drivers establish stormwater management a clear priority for a wide range of industries, including Food and Beverage, Railroad, Manufactured Goods, Technology, Oil and Gas, and Chem-Pharma. In many cases permits are required for businesses in these sectors, and the permitting parameters are evolving over time (for example, tightening regulation around impaired waterbodies).
In many cases, it’s not enough to stay up with national directives set by the EPA (which themselves can fluctuate depending on the political atmosphere). Some states are becoming more stringent with stormwater regulations, and for those facilities that operate in multiple geographies, this poses new compliance challenges.
While it can sometimes be treated as such, stormwater management is by no means a set-it-and-forget-it aspect of your EHS program.
Prime Your Stormwater Management Program for Long-Term Success
Stormwater management programs should be fully detailed and documented in a Storm Water Pollution Prevention Plan (SWPPP), which can serve as a vital resource and guiding light across the organization.
The EPA describes a SWPPP as a site-specific, written document that identifies potential sources of stormwater pollution, describes practices to reduce pollutants in stormwater discharges, and identifies implementable procedures to comply with pertinent terms and conditions.
EPA adds that, “Failure to implement your SWPPP could result in significant fines from EPA or a state environmental agency. Therefore, it is important that you develop your SWPPP to address the specific conditions at your site, fully implement it, and keep it up-to-date to reflect changes at your site.”
What steps does your organization need to take with regards to an SWPPP? Here’s what you need to consider from a high-level:
Step 1: Assess the Need for an SWPPP
It’s not a requirement for every business and industry. You’ll want to consult EPA-level and state-level guidelines to understand whether a permitting need exists for your organization. However, even if one isn’t required, you might need to file for an exemption.
Step 2: Create or Refine Your SWPPP
If you determine a need for an SWPPP but don’t have it documented yet, creating one will be your next step. If you have one, but haven’t reviewed or re-assessed it in some time, this might be the right time to do so. A comprehensive and up-to-date SWPPP helps your organization take control of the present and plan for the future.
Step 3: Future-Proof Your SWPPP
This isn’t just a document designed to cover the ‘now.’ It should be written as an evergreen fixture for your stormwater management program, with scalability and tightening regulations at top of mind.
Enlisting the help of an experienced environmental consulting firm can be invaluable for such an initiative, because stormwater management is a complex and nuanced subject with guidelines that vary by state, and permitting stipulations that vary by industry. As mentioned earlier, there is a trend in some states toward more progressive and strict regulations. An expert compliance audit can help you understand your gaps and needs to be compliant, now and going forward.
As an example of the consequences that can come about when stormwater management is lacking, in 2015 a railway company was fined $152,000 for violations of the Clean Water Act that stemmed, in part, from an inadequate SWPPP.
Weather the Storm with Future-Proof Planning
At Antea Group, we have substantial experience assisting a broad range of clients with their stormwater management programs. Creation and re-assessment of SWPPP is a primary service offering in this category, and we also can help with National Pollutant Discharge Elimination System (NPDES) compliance, on-site assessments, data analysis, exceedance reporting, Best Management Practices (BMP) implementation, and more.
Don’t wait for the dark clouds to form overhead before giving stormwater management the attention it deserves. It’s important today and will be more important tomorrow. This is an essential priority for EHS leaders everywhere.
