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SWPPP Requirements Have Changed – Are you at Risk of Non-Compliance?

By Ron Etter, Environmental Group Manager, Koontz-Bryant, P.C.

  1. Everyone who has a General Construction Permit (GCP) will need to update their Stormwater Pollution Prevention Plan (SWPPP). The Virginia Stormwater Management Program (VSMP) 2014 GCP for construction activities went into effect July 1, 2014. DEQ has authorized that permit registration, approvals, and oversight of GCPs are now the responsibility of the local authorities. Even though permit holders who renewed their 2009 permit do not have to meet the new technical criteria, they still must meet the other requirements of the 2014 GCP. Koontz-Bryant has been helping clients understand these changes and assisting them to be compliant with the new GCP requirements.
  2. For example, under Part 1 B. Limitations on Coverage, 4. Impaired waters and TMDL limitations, is the following:

    “d. The applicable SWPPP inspection requirements specified in Part II F 2 shall be amended as follows:

    (1) Inspections shall be conducted at a frequency of (i) at least once every four business days or; (ii) at least once every five business days and no later than 48 hours following a measurable storm event. In the event that a measurable storm event occurs when there are more than 48 hours between business days, the inspection shall be conducted on the next business day;


    (2) Representative inspections used by utility line installation, pipeline construction, or other similar linear construction activities shall inspect all outfalls discharging to surface waters identified as impaired or for which a TMDL wasteload allocation has been established and approved prior to the term of this general permit.

    A "measurable storm event" means a rainfall event producing 0.25 inches of rain or greater over 24 hours. Any project that discharges to an impaired water is subject to these inspection requirements, not the typical SWPPP inspections. The typical SWPPP inspection frequencies have changed from calendar days to business days.

  3. The Pollution Prevention (P2) Plan required in the SWPPP (Part II A.4) for non-stormwater pollutants does apply to phased construction projects and can be a real challenge for projects where construction is spread out over a large area. Potential pollutant sources have to be identified and characterized. The locations of use and where they are stored must be indicated in the plan.

  4. The following table is an example of what information needs to be included in the P2 plan:

  5. Material/Chemical
    Physical Description Stormwater Pollutants Location

    Pesticides (insecticides fungicides, herbicides, rodenticides)

    Various colored to colorless liquid, powder, pellets, or grains

    Chlorinated hydrocarbons, organophosphates, carbamates, arsenic

    Herbicides used for noxious weed control


    Liquid or solid grains

    Nitrogen, phosphorous

    Newly seeded areas


    White granules or powder

    Calcium sulphate, calcium carbonate, sulfuric acid

    Building construction

    Cleaning Solvents

    Colorless, blue, or yellow-green liquid

    Perchloroethylene, methylene chloride, trichloroethylene, petroleum distillates

    No equipment cleaning allowed in project limits


    Black solid

    Oil, petroleum distillates

    Streets and roofing


    White solid/grey liquid

    Limestone, sand, pH, chromium

    Curb and gutter, building construction

    Glue, adhesives

    White or yellow liquid

    Polymers, epoxies

    Building construction


    Various colored liquid

    Metal oxides, Stoddard solvent, talc, calcium carbonate, arsenic

    Building construction

    Curing compounds

    Creamy white liquid


    Curb and gutter

    Wood Preservatives

    Clear amber or dark brown liquid

    Stoddard solvent, petroleum distillates, arsenic, copper, chromium

    Timber pads and building construction

    Hydraulic oil/fluids

    Brown oily petroleum hydrocarbon

    Mineral Oil

    Leaks or broken hoses from equipment


    Colorless, pale brown or pink petroleum hydrocarbon

    Benzene, ethyl benzene, toluene, xylene, MTBE

    Secondary containment/staging area

    Diesel Fuel

    Clear, blue-green to yellow liquid

    Petroleum distillates, oil & grease, naphthalene, xylenes

    Secondary containment/staging area


    Pale yellow liquid petroleum hydrocarbon

    Coal oil, petroleum distillates,

    Secondary containment/staging area


    Clear green/yellow liquid

    Ethylene glycol, propylene glycol, heavy metals (copper, lead, zinc)

    Leaks or broken hoses from equipment

    Sanitary toilets

    Various colored liquid

    Bacteria, parasites, and viruses

    Staging area

    Additionally, the site plans need to show locations of concrete washouts and design, locations of portable toilets, fueling areas, fuel storage tanks, and storage areas for any building materials and chemicals stored on the project site. The SWPPP will require modification when the site locations change. The P2 plan has to include the procedures that will be used to manage non-stormwater pollutants and all of this will need to be included with the site inspections.

    To comply with the 2014 GCP requires diligence, knowledge, and experience. Our staff has been following the regulation changes and are well aware of the requirements to guide your project through the entire process from design, application, implementation, maintenance, to completion. For more information contact Ron Etter via email or at 804-200-1920.