SWPPP Author (NPDES CGP/MSGP)

EPA NPDES Stormwater Clean Water Act United States Environmental

Overview

Author complete Stormwater Pollution Prevention Plan packages for US construction and industrial stormwater programs under EPA CGP, EPA MSGP, California CGO, or state-equivalent permits.

What It Covers

CGP SWPPPs for construction sites disturbing one acre or more, including erosion/sediment controls, inspection schedules, corrective actions, and final stabilization support.
MSGP SWPPPs for industrial facilities, including sector-specific pollutant sources, benchmark monitoring, quarterly visual assessments, routine inspections, and AIM escalation.
California CGO SWPPP amendments and packages with QSD/QSP roles, Risk Level handling, SMARTS-ready artifacts, and post-construction stormwater management.
Shared facility-program integration using facility profile, site plan, SDS inventory, contacts, permits register, incident log, and training records.

Example Conversation

You: We’re starting a 12-acre warehouse build outside Dallas and need the SWPPP before submitting the NOI. We have two outfalls to a creek impaired for sediment, a fuel tank, concrete washout, and a basic site plan.

Agent: I’ll prepare a CGP SWPPP package, first checking the shared facility profile, site plan, SDS inventory, contacts, permits register, and incident log so the SWPPP stays consistent with your broader EHS workspace.

Agent: I found the site plan and contacts, but the receiving-water impairment evidence and signatory authority are incomplete. I’ll list those as missing evidence requests and draft the package with placeholders rather than assuming coverage.

Agent: Created the SWPPP narrative, site-map description, pollutant inventory, BMP catalog, inspection form, corrective-action log, training record, and amendment log. Running swppp_completeness_checker now.

Agent: The checker flagged the non-stormwater discharge evaluation as weak. I added the allowable/prohibited discharge review and reran the checker. The package is ready for QEP/operator review before final certification.

Sample Output Excerpt

Excerpt from a CGP SWPPP package generated with the skill:

3.2 Receiving Waters, Drainage Areas, and Outfalls

Drainage area	Outfall/discharge point	Receiving water	Impaired water/TMDL?	Sampling point	Substantially identical?
North pad and laydown yard	OF-001	Bear Creek	Yes — sediment impairment reported by operator	SP-001 at riprap apron	No
South access road and trailer area	OF-002	Bear Creek tributary	Yes — same receiving-water segment	SP-002 downstream of inlet protection	No

5. Best Management Practices

Pollutant source	BMP/control	Rationale	Inspection criteria	Maintenance responsibility
Disturbed soil at warehouse pad	Silt fence, inlet protection, stabilized construction entrance	Controls sediment before discharge to impaired receiving water	Undercutting, overtopping, tears, sediment accumulation	Site superintendent
Fueling area for construction equipment	Secondary containment, spill kit, no fueling within drainage swale	Reduces petroleum exposure and cross-references SPCC controls	Container integrity, sheen, stained soil, spill-kit inventory	Equipment contractor
Concrete washout	Lined washout area with signage and capacity checks	Prevents high-pH washwater discharge	Freeboard, liner damage, tracking, overflow risk	Concrete subcontractor

8. Corrective-Action Procedures

Deficiencies requiring immediate/interim measures include failed perimeter controls, unauthorized non-stormwater discharge, evidence of sediment discharge, missing BMP maintenance, or a benchmark/AIM trigger in an MSGP context. Permanent corrections must follow the applicable permit deadline and be closed with date, responsible party, and evidence.

What the Tool Validates

swppp_completeness_checker scans a SWPPP file or package directory for:

Universal SWPPP content: SWPPP team, signatory chain, permit coverage, eligibility evidence, receiving waters, outfalls, impaired-waters/TMDL review, site-map narrative, pollutant inventory, BMP catalog, inspections, corrective actions, training, recordkeeping, amendments, and non-stormwater discharge evaluation.
CGP-specific signals: construction sequence, disturbed acreage, stabilization, erosion/sediment controls, and inspection cadence such as every 7 days or every 14 days plus a 0.25-inch rain-event trigger.
MSGP-specific signals: sector/subsector, Part 8 sector-specific requirements, benchmark monitoring, quarterly visual assessments, and Additional Implementation Measures (AIM) escalation.
California CGO signals: QSD/QSP roles, Risk Level determination, SMARTS artifacts, and state-driven monitoring duties.
Shared workspace consistency: references to facility/profile.md, facility/sds-inventory.csv, facility/contacts.md, and related SPCC, Tier II, RCRA, or RMP data where relevant.

The tool returns PASS when required completeness signals are present, or FAIL with the missing areas to resolve before professional review.

Getting Started

Add or update these shared workspace materials before activating the skill:

facility/profile.md with operator, location, NAICS/SIC, and contact basics.
facility/site-plan.md or a site-plan image describing drainage, outfalls, BMPs, and material storage.
facility/sds-inventory.csv for significant materials and pollutant sources.
facility/contacts.md, facility/permits-register.md, facility/incident-log.md, and facility/training-matrix.md when available.

Then ask for the right mode: CGP, MSGP, California CGO, state-equivalent, or amendment. The agent will request missing eligibility evidence instead of inventing it.