Following are the points
which should be kept in mind while implementing SWPPP:
A. Train Your Staff and
Subcontractors
Your site’s construction
workers and subcontractors might not be familiar with storm water BMPs, and
they might not understand their role in protecting local rivers, lakes and
coastal waters. Training your staff and subcontractors in the basics of erosion
control, good housekeeping, and pollution prevention is one of the most
effective BMPs you can institute at your site.
B. Ensure
Responsibility—Subcontractor Agreements
At any given site, there
might be multiple parties (developer, general contractor, builders,
subcontractors) that have roles and responsibilities for carrying out or maintaining
storm water BMPs at a given site. These roles and responsibilities should be
documented clearly in the SWPPP.
In some cases (state requirements vary), there may be one entity that has
developed the SWPPP and filed for permit coverage and, therefore, is designated
as the operator.
When other parties at a
site are not officially designated as operators, many operators are
incorporating the roles and responsibilities of these non-operators in the
agreements and contracts they have with these companies and individuals. This
contract language should spell out responsibilities implementing and
maintaining storm water BMPs, for training staff, and for correcting damage to
storm water BMPs on the site. Several states have storm water regulations that
hold other parties liable even if they are not identified as the operator.
C. Implement Your Storm water
Pollution Prevention Plan (SWPPP) Before Construction Starts
Once you have obtained
permit coverage and you are ready to begin construction, it is time to
implement your SWPPP. You must implement appropriate parts of your SWPPP before
construction activity begins. This generally involves installing storm drain
inlet protection, construction entrances, sediment basins, and perimeter silt
fences before clearing, grading, and excavating activities begin.
After construction
activities begin, your SWPPP should describe when additional erosion and
sediment controls will be installed (generally after initial clearing and grading
activities are complete). You should also begin BMP inspections once clearing
and grading activities begin.
D. Conduct Inspections and
Maintain BMPs
EPA recommends that you
develop an inspection schedule for your site that considers the size,
complexity, and other conditions at your site. This should include regularly
scheduled inspections and less formal inspections.
EPA recommends that you
develop a plan that includes inspections before and after anticipated rain
events. You might also want to inspect some BMPs during rain events to see if
they are actually keeping sediment on site! Conducting inspections during rain
events also allows a construction site operator to address minor problems
before they turn into major problems.
Temporarily Removed BMPs BMPs
sometimes need to be temporarily removed to conduct work in an area of the
site. These temporarily removed BMPs should be noted on the site plan and
replaced as soon as possible after the completion of the activity requiring
their removal. If a rain is forecast, the BMPs should be replaced as soon as
possible before the rain event. Prepare for the rain and snowmelt. In some
areas of the country, construction site operators are required to develop
weather triggered action plans that describe additional activities the operator
will conduct 48 hours before a predicted storm (at least a 50 percent
forecasted chance of rain). It is also a good idea to stockpile additional
erosion and sediment control BMPs (such as silt fencing, and fiber rolls) at
the site for use when necessary.
Like your construction
site, your SWPPP is dynamic. It is a document that must be amended to reflect
changes occurring at the site. As plans and specifications change, those
changes should be reflected in your SWPPP. If you find that a BMP is not
working and you decide to replace it with another, you must reflect that change
in your SWPPP.
Document in your SWPPP
transitions from one phase of construction to the next, and make sure you
implement new BMPs required for that next phase.
You should evaluate the
effectiveness of your BMPs as part of your routine inspection process. An
informal analysis of both your inspection’s findings and your list of BMP
repairs will often reveal an inadequately performing BMP. An inspection
immediately after a rain event can indicate whether another approach is needed.
You may decide to remove
an existing BMP and replace it with another, or you may add another BMP in that
area to lessen the impact of storm water on the original installation. When you
update your SWPPP, you can simply mark it up, particularly for relatively
simple changes and alterations. More significant changes might require a rewriting
of portions of the SWPPP. The site map should also be updated as necessary.
Author-Bio
Your Storm water Pollution Prevention Plan is
your guide to preventing storm water pollution. However, it is just a plan. Implementing
your SWPPP, maintaining your BMPs, and then constantly reevaluating and
revising your BMPs and your SWPPP are the
keys to protecting your local waterways. To know more insights, visit www.questepa.com.
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