Improving Your Stormwater Pollution Prevention Plans Ryan Alltop, CPESC, DECI Quality Control Manager Overview Regulations SWPPP Erosion Control vs. Sediment Control Standards, Specifications, & Drawings Recommendations What’s New Plan Design Regulations for Erosion and Sediment Control Protection Agency – National Pollutant Discharge Elimination Systems (NPDES) Phase I & II U. S. Army Corps of Engineers County and Municipal Ordinances Environmental National Pollutant Discharge Elimination System (NPDES) Illinois-Construction Activities Clean Water Act Administered by the Illinois EPA through the ILR10-Stormwater Permit for Construction Site Activities Phase II requires permit for projects disturbing one (1) acre or more or projects that are “..part of a larger common plan of development or sale.” Information and forms available at: www.epa.state.il.us and http://www.epa.state.il.us/water/permits/stormwater/construction.htmll Some of the NPDES Requirements (taken from the ILR10 permit and General Permit NO 2) Notice of Intent (NOI)—Submit to IEPA and Local MS4 Community Stormwater Pollution Prevention Plan (SWPPP) Incidence of Non-Compliance (ION) (IL)— submitted electronically to state within 24 hours of incidence Notice of Termination (NOT) (IL) or Notice of Discontinuation (IA) Records Retention—three (3) years from final stabilization SWPPP – Deadlines for Preparation and Signature, Review, and Notification Requirements • SWPPP must be completed prior to submitting your NOI and must provide compliance with schedule of construction activities. The SWPPP shall be signed and be retained on-site at the facility which it is written for. Plan must be available for review by IEPA, IDNR, local agencies, stormwater regulators, municipalities, and the public. Any identified deficiencies must be rectified within 7 days of occurence. SWPPP - Management SWPPP – Keeping Plans Current • The Stormwater Pollution Prevention Plan is intended to be a dynamic document which should change or be modified as necessary to protect receiving waters from pollutants. • The permitee is required to amend the plan whenever there is a change in design that effects the plan or if the plan has been shown to be deficient or ineffective in protecting waters of the state or other off site areas. • Changes is control measures should be noted on the plan in pencil, pen, or marker. Hand drawings or shop drawings are acceptable as modifications to the plan. • Additional contractors should be modified whenever a new contractor comes on site. SWPPP – Keeping Plans Current SWPPP – Contents of the Plan • • • • • • • Site Description Best Management Practices (BMPs) Maintenance Inspections Non-Storm Water Discharges Contractors Signatory Requirements Contents of the Plan – Site Descriptions • Describe construction activity • Sequence of major activities which will disturb the site • Estimate of total acreage of the site and the acreage of disturbance • An estimate of the runoff coefficient of the site after completion • Site Map including drainage patterns, grading changes, stormwater facilities and discharge points, major structural and nonstructural Stormwater pollution controls, and receiveing water bodies. (Civil Drawings and Location Map) • Receiving water bodies and the ultimate receiving waters and aerial extend of any wetlands on-site or as a receiving body should be identified. Contents of the Plan – Site Descriptions • Site soil maps (Web Soil Survey) • RUSLE 2 (Web Soil Survey) Contents of the Plan – Controls • Controls make up the meat of the SWPPP when it is first created and are most often associated with the Erosion Control plan and associated details. • The SWPPP shall include a description of appropriate controls used on site and clearly describe and identify the implementation of the appropriate controls and the timing during the construction process where each control practice will be used. • The description of controls shall at a minimum include: Erosion and Sediment Controls, Stormwater Management, Other Control Measures, and meet the Approval of State or Local requirements. • The Illinois Urban Manual should be used for guidance in selecting and designing your controls in Illinois. • The Iowa Construction Site Erosion Control Manual should be used in Iowa Contents of the Plan – Controls Erosion and Sediment Controls • Erosion Control Practices Description of temporary, interim, and permanent practices including the scheduling and implementation of practices to vegetate or otherwise stabilized exposed soils or protect existing vegetation. Sediment Control Practices Description of practices installed to divert flows from exposed soils, store flows or runoff, and otherwise filter or limit the discharge of pollutants from the site. Contents of the Plan – Controls Storm Water Management • Description of measures and practices that will be installed during the construction process that will serve to control the discharge of pollutants from the site during and after construction operations are complete. • Examples of practices include wet bottom detention basins, sediment basins, sediment traps, vegetated swales, infiltration trenches, and energy dissipation devices at the outfall of stormwater structures (rock lined aprons). Erosion Control-Primary Design Goal Phased Construction Limit Disturbed Area Permanent Stabilization Stabilize-As-You-Go Winter Stabilization Temporary Seeding Mulching/Erosion Control Blanket Velocity Minimization Sediment Control-Secondary Design Goal Barriers Filtration Sediment Containment Systems Velocity Minimization Contents of the Plan – Controls Other Controls and Approved State and Local Plans • Other Controls must ensure that solid materials or other pollutants are contained on-site and disposed of properly. • Spill Prevention and Clean-Up • Waste Disposal • Secondary Containment of Pollutants Erosion & Sediment Control Plan Where do I start? Identify Critical Area Protection Where are my Cut/Fill Areas? Temporary Drainage Conditions Timing and Phasing Time of Season Duration of Construction Standards, Specifications, & Drawings Soil Erosion and Sediment Control (SESC) practices need to be DESIGNED into the project SESC practices need to be treated like any other construction practice (i.e. sanitary sewer, water mains, etc.) There’s more to SESC planning than inserting details Standard Drawings Available in DWF, DWG, DXF, and PDF formats. Most require additional dimensions to be inserted Details Provide details for each SESC practice called out on plans or in notes Fill in required values Provide manufacturer details if necessary If no standard drawings exist use shop drawings or create drawings showing plan view and/or overview of practice Recommendations Visit the site before designing the Soil Erosion and Sediment Control Plan Begin communication early with municipality and all regulatory agencies Create the SESC plan and SWPPP as part of the overall construction plan Visit site after creating plans to determine if they make sense SESC Plan Sheets Clearly display and label all SESC measures Generate more than one SESC plan sheet, if necessary, to clearly show different stages of construction Review existing and proposed drainage to ensure perimeter barriers/fences will function throughout the duration of the project SESC Plan Sheets Show location for erosion control blanket and/or mulch installation Show proposed locations of stockpiles with perimeter barrier Show lined aprons at storm sewer outfalls SESC Plan Sheets Replace straw bale ditch checks Designate location of stabilized construction entrance(s) Notes and Specifications Standard Notes— contact regulating entity or visit website to determine if standard notes exist Provide sequence of events and appropriate SESC measures for work in critical areas Notes and Specifications Clearly explain when various practices should be implemented Accommodate for temporary conditions (between mass grading and final grading and stabilization) Notes and Specifications Permanent and temporary vegetation/stabilization schedule Critical Dates Species List Application Rates Winter stabilization plan Stockpile Stabilization Review site conditions and manufacturer’s specifications to determine if the proper ECB is being used Contents of the Plan – Inspections • Qualified personnel shall inspect the site at least once every seven (7) days or within 24 hours of any rainfall event of ½ inch or greater. • Monthly Inspections during periods of Snow Cover. • Any violation of the SWPPP or discharges to receiving water bodies should be reported by filing an “Incidence of Non-Compliance” (ION) to the IEPA within 24 hours. Contents of the Plan – Maintenance • All practices in the SWPPP must be maintained in good and effective operating condition throughout the duration of the project. Contents of the Plan – Non-Storm Water Discharges • Any sources of nonstormwater listed as industrial activities that shall be combined with stormwater discharges must be clearly identified on the plan. Examples include: • • • • Hydrant Flushing Groundwater Pumping Dust Control Vehicle Washing SWPPP – Contractor Certification Statements • The SWPPP must identify each contractor or subcontractor that will be responsible for implementing each measure in the plan. • All contractors must sign a copy of the Certification Statement and that signed statement shall be included as part of the SWPPP. • The certification statement must also identify the name and title of the person providing the signature, contact information for the contractors’ firm, address or name of site, and the date of certification signing. SWPPP – Delegation Of Authority Owner or General Contractor Sign Off General Comments Complete SWPPP and submit plans for review to appropriate agencies BEFORE project goes out to bid Include Erosion and Sediment Control in your bid. SESC plans are reviewed for both temporary and permanent components Plan for each stage of the project Better to provide too much information than not enough Attempt to get plans correct and effective the first time around, but NEVER be afraid to change or modify the SWPPP or the practices in the SWPPP if they are not being effective. Questions? Ryan Alltop, CPESC, DECI Quality Control Manager ENCAP, Inc. 2585 Wagner Ct., DeKalb, IL 60115 815-748-4500 www.encapinc.net jkoepke@encapinc.net Up Coming Seminars Great Connections 2014 www.greatconnections2014.com