Industrial Stormwater Quality Pollution Prevention Plan

Facility site inspection performed as part of SQPP development.
Prime Contractor: 
Period of Performance: 
January, 2013 to December, 2013
Project Description: 

ADH, as a subcontractor to CardnoENTRIX, (CE) assisted a large public utility provider (confidential client) to implement a company-wide Stormwater Quality Protection Program (SQPP) that meets the requirements of the Draft National Pollution Discharge Elimination System (NPDES) Phase II Industrial General Permit at 134 service centers located throughout the state. 

Scope of Services: 


ADH supported CE with preparation of a comprehensive Stormwater Quality Protection Guidance Manual that was developed on a risk level-basis (proximity to sensitive water bodies) for implementation of programmatic and structural best management practices (BMPs). 

Programmatic BMPs included the following:

  • Facility Inspection Program to develop a site-specific Stormwater Management Plan (SWMP) for each facility.
  • Develop a SWMP Team with designated roles and responsibilities at each facility.
  • Good Housekeeping Practices including Awareness Training, Facility Maintenance, Work or Construction Areas, and Fertilizer and Pesticide Management
  • Annual Site Inspection program including: Site Inspection Corrective Action; Incident Report and Corrective Action; BMP Annual Effectiveness Evaluation; and, SWMP Update

Structural BMPs included requirements for service facilities based upon varying risk levels and included management and troubleshooting guidelines for each BMP that included, but was not limited to, the following elements:

  • Stormwater Drainage Systems including curbs, berms, drain inlets, swales, pipes, outfalls, etc.
  • Stockpiles of Granular Materials including sand, road base, cold mix asphalt, etc.
  • Solid Waste and Recycling including garbage, metal recycling, and treated wood. 
  • Outdoor warehousing of treated wood utility poles and cross-arms, and metal parts storage areas.
  • Vehicle and Equipment Wash Areas, specifically with direct (untreated) discharge to the stormwater drainage system.

ADH performed a value-added senior review of the Draft Guidance Manual for CE prior to submittal to the client. ADH assisted CE with the development of 15 individual SWMPs to be implemented at each respective facility as well as to serve as templates for the remaining 119 facilities.

ADH also assisted CE and the client in determining which standards, or BMPs, are applicable to their service centers with a focus on higher risk pollutants that are comparatively cost effective. In support of this purpose. In addition to the above, as part of the development of this SQPP, ADH  participated in the following tasks:

  • Performed assessment of 16 service center Hazardous Materials Business Plans.
  • Developed pre site inspection questionnaire and site inspection form.
  • Performed site inspection visits at several facilities located in client’s central and southern service areas and co-authored respective site visit assessment reports.
  • Ranked the operational activities identified by level of risk.
  • Assisted CE in performing a Failure Mode and Effects Analysis (FMEA) based on the results of the SQPP surveys to allow assessment of relative risks between sites and across the portfolio of surveyed sites identifying priorities at each facility and ranking of facilities with highest risks.
  • Performed BMP Feasibility Study and Cost Benefit Analysis including:
    • Identified BMPs to mitigate the risk of the mid to high risk activities.
    • Benchmarked BMPs to determine whether they are industry standard and industry leading.
    • Classified BMPs as routine operations and maintenance or capital infrastructure improvements/standards with a projected annual cost or installation cost.