Run-off management, soil stabilization, and sediment control are important facets of storm water pollution prevention
By Don Neff
Storm Water Pollution Prevention Planning (SWPPP) can be the nemesis of many good builders if it is not proactively scheduled into field operations in advance of the next rainy season. Both California and federal agencies can, and will, levy severe fines and penalties, ranging from $10k to $37.5k per day per violation, for non-compliance on projects exceeding one acre in size. Lesser fines are levied for not filing an annual report, not filling out various other forms, or not recording water test results with the state water board. Non-compliance includes turbidity and PH excesses during rain events, as well as failure to post or frequently update the required erosion control plan on the jobsite, and failure to keep paperwork in order and accessible for surprise visits from the regional water quality control board field inspectors.
Keeping these erosion control maps is an important archive priority for the three years following project completion. In anticipation of the next rainy season, below are a few important considerations to avoid receiving a dreaded notice of violation, which can be the first heads up of job site problems.
Ensuring SWPPP Compliance
The stated goal of the Federal Clean Water Act, which dates back to 1948, and was subsequently amended in 1972 and 1977, is to protect fish, shellfish, and wildlife by focusing on the physical, chemical, and biological health of United States waters. In effect, “Waters of the U.S.” need to be swimmable and fishable. These objectives are intended to be achieved through several strategies, such as managing site runoff created during and after construction through implementation of Best Management Practices (BMPs) of varying priorities as a function of the specific site conditions.
The initial focus was on point sources of pollution from large urban facilities such as treatment plants. Over time, the focus has changed to include non-point pollution sources from ever smaller projects including all types of real estate developments, now down to one acre.
The primary BMP systems employed are designed to address:
- Run-off management
- Soil stabilization
- Sediment control
The first of these, run-off management, is akin to handling bulk water flows onto or through your jobsite. This is accomplished by diverting the water through the use of earth dikes, swales, and check dams. It also includes conveying water through grassed beltways and mats, which effectively slow and filter water flows. Drains are also effective in intercepting water flows. Stabilizing slopes through flumes and rock/riprap outlets are also frequently used BMPs.
Erosion Control / Soil Stabilization
The next priority is erosion control, or soil stabilization. Specific proven strategies to accomplish this include vegetative seeding, sod placement, mulching slopes, and/or using biotech solutions such as bonded fiber matrix, jute matting, and straw spreading. Each of these options varies in application based on soil and slope conditions, as well as the size and configuration of the job site.
Sediment / Pollution Control
The third priority is that of sediment, or pollution, control. Effective examples are de-silting basins, chevrons of sand bags, sod barriers, silt fencing, shaker plates, street sweepers, and water trucks. Mass grading a job site is done with large earth-moving equipment, such as scrapers and bulldozers, and smaller equipment is used for contouring fine grading swales around a house. Similarly, the application of each SWPPP BMP or “tool” needs to be matched with those needs. One cannot effectively use a silt fence, for example, to accomplish run-off management because a silt fence is used for sediment control.
Fortunately, most regional water quality control agency field inspectors are somewhat flexible with builders if a sincerely demonstrable effort is being put forth conscientiously by the Legally Responsible Party through their field teams to manage storm flows that may be impacting their jobsites.
A final word of caution is that, in implementing SWPPP BMPs, it’s always better to be perceived as part of the solution than part of the problem.
Don Neff is President of LJP Construction Services, providing Third Party QA Services to clients nationwide. His SWPPP credentials include several active certifications such as CSP, CPESC and CESSWI. For more information, visit www.ljpltd.com