What is Annual Storm Water Pollution Prevention Plan Training?
According to the Indiana Department of Environmental Management’s (IDEM) Auto Salvage Recyclers Environmental Self-Audit Workbook and Checklist the topics to be covered for Annual Storm Water Pollution Prevention Plan (SWP3) Training are:
· The purpose and requirements of the Storm Water Pollution Prevention Plan;
· Spill prevention and response procedures;
· Reporting procedures;
· Automotive fluids, used oil and spent solvent management;
· Good housekeeping practices;
· Lead-acid battery management;
· Current and proposed Best Management Practices;
· Parts handling and storage.
As the name suggests, this training is an annual requirement. After the training is conducted, each employee signs a training roster that is maintained on site with the SWP3. The training not only benefits the employees, but if done properly, it will benefit the leadership and the business. We encourage you to use the annual requirements as a means to brush up on the contents of your SWP3. Another annual requirement of the Rule 6 General Storm Water Permit is to complete and submit a State Form 54185 Annual Report to IDEM. The following questions are asked under Part B: General Annual Report Information:
· Were there any changes to the original Notice of Intent letter?
· Were there any changes made to the on-site SWP3?
· Were the changes submitted to IDEM in an amended Notice of Intent Form?
· Were there any changes to the facility?
· Have the changes been included in an amended SWP3?
· Were there any changes to the facility operations?
· Were there any additional potential source pollutants?
· Were there any changes to the facility’s industrial activities?
· Were there any additional Best Management Practices implemented or corrective actions taken, as a result of sampling data analysis?
It is important for you to read your SWP3 at least annually and ensure that no changes have occurred to the industrial process that would require your plan to be updated. You are the expert on what takes place at your yard on a day-to-day basis. If you hired a consultant to write your plan, that plan may not represent any changes you implement at your yard subsequently. We recommend that you take the opportunity once a year to read your plan and outline the training class material based on what your SWP3 says. While you read you can determine if your current operations are still in line with the terms of your SWP3, or if an amendment is called for.
We are starting to struggle to come up with article topics that are interesting, current and helpful to you as recyclers. Usually we develop a topic based on questions we receive from our clients during the two months preceding the article. If we don’t receive any questions, we don’t have a topic. We would like to know what you want to learn about. Our hope is that the articles we write may answer a question you have and hopefully save you time, money and effort in tracking down an answer. If there are any questions or topics, please send them our way!
We hope you are all happy, healthy and business is good. See you all in September at the CMAR Convention. We are excited about meeting in Indianapolis. Enjoy the spring!
This article was originally featured in the June/July 2012 issue of ARI Magazine.