Updating and Evaluating your Storm water Pollution Prevention Plan (SWPPP) is an important part of SWPPP Implementation

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 Storm water Pollution Prevention Plan (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 Storm water Pollution Prevention Plan (SWPPP). The site map should also be updated as necessary.

Common Compliance Problems during Inspections

The following are problems commonly found at construction sites. As you conduct your inspections, look for these problems on your site.

Problem #1—Not using phased grading or providing temporary or permanent cover (i.e., soil stabilization)

In general, construction sites should phase their grading activities so that only a portion of the site is exposed at any one time. Also, disturbed areas that are not being actively worked should have temporary cover. Areas that are at final grade should receive permanent cover as soon as possible.

Problem #2—No sediment controls on-site

Sediment controls such as silt fences, sediment barriers, sediment traps and basins must be in place before soil-disturbance activities begin. Don’t proceed with grading work out-of-phase.

Problem #3—No sediment control for temporary stockpiles

Temporary stockpiles must be seeded, covered, or surrounded by properly installed silt fence. Stockpiles should never be placed on paved surfaces.

Problem #4—No inlet protection

All storm drain inlets that could receive a discharge from the construction site must be protected before construction begins and must be maintained until the site is finally stabilized.

Problem #5—No BMPs to minimize vehicle tracking onto the road

Vehicle exits must use BMPs such as stone pads, concrete or steel wash racks, or equivalent systems to prevent vehicle tracking of sediment.

Problem #6—Improper solid waste or hazardous waste management

Solid waste (including trash and debris) must be disposed of properly, and hazardous materials (including oil, gasoline, and paint) must be properly stored (which includes secondary containment). Properly manage portable sanitary facilities.

Problem #7—Dewatering and other pollutant discharges at the construction site

Construction site dewatering from building footings or other sources should not be discharged without treatment. Turbid water should be filtered or allowed to settle.

Problem #8—Poorly managed washouts (concrete, paint, stucco)

Water from washouts must not enter the storm drain system or a nearby receiving water. Make sure washouts are clearly marked, sized adequately, and frequently maintained.

Problem #9—Inadequate BMP maintenance

BMPs must be frequently inspected and maintained if necessary. Maintenance should occur for BMPs that have reduced capacity to treat storm water (construction general permits or state design manuals often contain information on when BMPs should be maintained), or BMPs that have been damaged and need to be repaired or replaced (such as storm drain inlet protection that has been damaged by trucks).

Problem #10—Inadequate documentation or training

Failing to develop a Storm water Pollution Prevention Plan, keep it up-to-date, or keep it on-site, are permit violations. You should also ensure that SWPPP documentation such as a copy of the NOI, inspection reports and updates to the SWPPP are also kept on-site. Likewise, personnel working on-site must be trained on the basics of storm water pollution prevention and BMP installation/maintenance.

Author - Bio

Construction site operators need to prepare a SWPPP in order to receive NPDES permit coverage for their storm water discharges. Quest Consultants provides training which helps to prepare and inform clients about the required information and tasks needed to be SWPPP Clients. For more information, visit our http://www.questepa.com.