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June 20, 2016
Tips for a successful construction stormwater SWPPP
By Emily Remmel, JD, Legal Editor

Sediment and soil runoff from improperly managed construction sites can greatly contribute to surface water degradation and cause detrimental impacts to aquatic life. To minimize the impacts to surface water quality, the U.S. Environmental Protection Agency (EPA) and the states require that construction projects of a certain size follow stormwater regulations. One such regulatory measure for construction activities includes developing a stormwater pollution prevention plan (SWPPP).

The SWPPP identifies all potential stormwater pollution sources and describes the practices implemented to reduce the discharge of pollutants from your site. Construction site operators should always consult their construction general permit for the exact applicable requirements.

As compliance and enforcement progress into the digital era, it is likely that construction SWPPPs will be posted online and made available to the public. (Note: the federal 2015 multisector general permit for industrial stormwater requires SWPPPs be posted online or additional information provided to the agency to release upon public request.)

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Starting with the specifics

The first step in developing a successful SWPPP is taking a comprehensive look at the undeveloped site. Identifying the natural features of the site and understanding where the water will flow on and off the site (i.e., the hydrology) are part of this first step.

These tips will help you create a unique and effective SWPPP for your project:

  • Conduct a site visit to document the site-specific conditions.
  • “Fingerprint” the site by taking inventory of the site’s natural features.
  • Research the site by gathering various topographic maps, and identify receiving waters, storm drains, and stormwater conveyance systems.
  • Describe the construction project in detail, and avoid boilerplate language.
  • Identify all pollutants and their sources likely found on-site.
  • Think ahead, and consider installing postconstruction stormwater controls.
  • Document the results of your site assessment with detailed site maps.

Selecting adequate BMPs

The second step in a successful SWPPP is selecting the correct suite of best management practices (BMPs) to reflect the specific site conditions. Also, keep in mind that BMPs work most effectively when they are used in combination.

These tips will help protect against erosion control and will curtail your project’s overall impact:

  • Minimize the disturbed area on-site and protect the site’s natural features.
  • Phase or stagger construction activity.
  • Divert stormwater coming onto the site from upstream sources.
  • Stabilize soil as soon as activities have ceased.
  • Protect all stormwater drain inlets, and establish perimeter controls.
  • Use sediment traps or sediment basins to control on-site sediment retention.
  • Control vehicles entering and exiting the site.

Keeping house

Often, a wide variety of materials and wastes exist on construction sites. It is important to include pollution prevention or good housekeeping practices on the site and document them in the SWPPP. Good housekeeping measures are designed to prevent stormwater contamination unique to your site.

The following tips will help identify and implement good housekeeping measures on your site:

  • Design a solid or liquid waste management scheme to dispose, recycle, handle, and clean up all wastes.
  • Identify material handling requirements for materials that may be hazardous or toxic, and designate staging areas to monitor and clean up any spills.
  • Designate washout facilities for concrete.
  • Establish equipment and vehicle fueling areas and washing sites.
  • Prepare a response plan in the event of a spill.

An effective SWPPP does not end when the Notice of Intent is submitted. Construction operations risk enforcement actions if the SWPPP is not a fluid document that is updated as things on-site change. Having a thorough and effective SWPPP will not only control sedimentation and erosion and prevent stormwater contamination, but it will also meet part of your compliance obligations under the Clean Water Act.

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