Storm Water Quality Construction Site Compliance & Controls

Transcription

1 Storm Water Quality Construction Site Compliance & Controls Scott Taylor, P.E. RBF Consulting December 5,

2 Part 1 Compliance with State Regulations Regulations SWPPPs and what to look for on a construction site

3 Agenda Regulatory Background General Construction NPDES Permit & Storm Water Pollution Prevention Plan (SWPPP) Refresher Construction Site Inspection & Enforcement Construction Site Practices What To Look For 3

4 Construction Program Responsibilities Cities are required to inspect construction sites to: Verify that Best Management Practices (BMPs) are in place Enforce City codes and ordinances Landowners of construction sites are required to: Apply for coverage under the State General Construction Permit Develop and implement a SWPPP Submit an NOT when construction activity is terminated 4

5 Key Definitions CWA Clean Water Act NPDES National Pollutant Discharge Elimination System MS4 Municipal Separate Storm Sewer System BMP Best Management Practice SWPPP Storm Water Pollution Prevention Plan EPA Environmental Protection Agency SWRCB State Water Resources Control Board RWQCB Regional Water Quality Control Board BAT/BCT Best Available Technology Economically Achievable/Best Conventional Control Technology 5

6 Regulation is Here in California 6

7 Regulation Structure EPA Clean Water Act NPDES Permits SWRCB Clean Water Act California Water Code General NPDES Permits Appeal Board for Regional Issues S.F. BAY RWQCB MS4 NPDES Permits General NPDES Permit Enforcement Local City MS4 NPDES Permit Implementation Local Water Quality Ordinances Grading & Building Permits LANDOWNER 7

8 Regulation Update SWRCB working to adopt new General Construction Permit (2007?) Possible limits on amount of grading, seasonal restrictions, and advanced sedimentation treatment S.F. Bay RWQCB to adopt new South Bay MS4 NPDES Permit (MRP) 8

9 Let s quickly review with a Quiz! 9

10 Question 1 BMP stands for: a. Better Mitigation Plan b. Bitter Mean People c. Best Management Practice d. Best Management Plan ANSWER: c. Best Management Practice 10

11 Question 2 MEP stands for: a. More Effort Please b. Maximum Extent Possible c. Maximum Extent Practicable d. Maximum Effective Practice ANSWER: c. Maximum Extent Practicable 11

12 Question 3 BAT/BCT is: a. A higher standard than MEP b. Is required in Municipal NPDES Permits c. Is required in Industrial NPDES Permits d. Is unachievable ANSWER: a. and c. 12

13 Question 4 Who Can Enforce CWA Rules? a. City/County agency staff b. State agency staff c. Federal (EPA) agency staff d. Private citizens e. All of the above ANSWER: e. All of the above 13

14 Question 5 ACL fines can be levied: a. On a per violation basis b. By the gallon of polluted discharge c. Only under the CWA d. Only under Porter-Cologne ANSWER: a. and b. 14

15 California General Construction NPDES Permit & SWPPP Refresher 15

16 Construction NPDES Permit What is Covered? Construction activity that disturbs one (1) or more acres of soil Construction activity includes: Clearing and grubbing (land disturbance) Grading / excavation Stockpiling Structure construction Sites < 1 acre also included if part of a larger common development (that exceeds one acre total) 16

17 Permit Requirements Apply for Coverage Under General Permit Develop and Implement a SWPPP Identify pollutant sources Identify / implement BMPs Eliminate or Control Non-Storm Water Discharges E.g. pipe flushing, street cleaning, dewatering Visual Inspections Sampling Strategy Initial and Annual certification 17

18 What Time of the Year do Permit Requirements Apply? SWPPP Must Be Implemented Year-round at an Appropriate Level Non-storm water discharges controlled Sediment BMPs when chance of rain Stockpile materials for sediment and erosion control as well as for spill control 18

19 General Permit Coverage Process Applicant submits Notice of Intent (NOI) State issues receipt letter with Waste Discharge Identification (WDID) Number Applicant constructs project and complies with General Permit Applicant submits Notice of Termination (NOT) at project completion Applicant may submit Change of Information (COI) prior to completion of entire project 19

20 Storm Water Pollution Prevention Plan (SWPPP) Purpose: Prevent discharge of potential pollutants during construction Potential pollutants include: Sediment (erosion) Litter, trash, and debris Paint, plaster, concrete and stucco Fuel, oil, grease and solvents Pesticides and fertilizers Others (see CA BMP Construction Handbook) 20

21 SWPPP Requirements SWPPP document must be available at project site Must have map showing BMPs Required inspections and documentation Before anticipated storm events After storm events Once each 24-hour period during extended storms Include name & number of responsible person for SWPPP 21

22 SWPPP Contents Site / Vicinity Maps Pollution Source and BMP Identification Erosion Control and Sediment Control BMPs Non-Storm Water Management Post Construction Controls Maintenance, Inspection and Repair Training Certification 22

23 SWPPP Maps SWPPP must have map showing where and what BMPs are being implemented Must be updated to reflect changing site conditions Must be on-site 23

24 SWPPP Review Currently no requirement for formal review and approval of SWPPP City, RWQCB and/or EPA may review if desired SWPPP map typically based on Erosion & Sediment Control plan approved by local agency SWPPP not directly available to public Copy must be provided to public but only through request to the SWRCB or RWQCB 24

25 Sites Less Than 1 Acre (under business pollution prevention) 25

26 Let s quickly review with another Quiz! 26

27 Question 1 A Construction NPDES Permit is required for projects: a. 5 or more acres total size b. 5 or more acres disturbed area c. 1 or more acres total size d. 1 or more acres disturbed area ANSWER: d. 1 or more acres disturbed area 27

28 Question 2 True or False? Some projects sites that disturb less than one acre might need a Construction NPDES Permit? ANSWER: True, if they are part of a larger common plan of development that will exceed 1 acre of soil disturbance, or if the disturbance will create a significant water quality impairment. 28

29 Question 3 The SWPPP must: a. Be reviewed and approved by the City. b. Be submitted to the SWRCB. c. Be kept at the project site. ANSWER: c. Be kept at the project site. 29

30 Construction Site Inspection & Enforcement 30

31 Potential Problems 1. Tracking/construction entrance 2. Perimeter controls 3. Pump water 4. Inspection records 5. Sampling strategy 6. Signs of previous contamination 7. Inspections 31

32 Track-Out Un-maintained entrances 32

33 Lack of Site Perimeter Controls Site perimeter controls are the last line of defense 33

34 Pump water that contains contaminants Construction permit only allows discharge of non-stormwater that does not contain pollution 34

35 Lack of Inspection Records Inspections are required before and after rain events, and during rain events that last 24 hrs or longer. PUBLIC WORKS DEPARTMENT TRANSPORTATION AND DEVELOPMENT SERVICES DIVISION EROSION CONTROL CHECKLIST PROJECT NO. & LOCATION DATE: INSPECTOR: Responsible Person/24-Hour Number: REGULAR INSPECTION PRE-RAIN INSPECTION AFTER-RAIN INSPECTION F PROBLEM IS NOTED, KEEP THIS REPORT UNTIL RESOLVED OR REFERRED TO ESD. ATTACH COPY OF WRITTEN WARNING & PHOTO EROSION CONTROL PLAN REQUIRED? EVIDENCE VERBAL WARNING WRITTEN WARNING DATE YES NO OF EROSION RESOLVED? RESOLVED? REFERRED YES NO DATE YES NO DATE YES NO TO ESD HYDROSEEDING OR 3-STEP METHOD MATTING/EROSION CONTROL BLANKETS - **REINSTALL IF DISLOCATED OR FAILED STABILIZED CONSTRUCTION ACCESS - **CHECK FOR TRACKING OF MUD/DIRT ONTO STREETS, SIDEWALK, ETC. STRAW BALE INLET BARRIER SILT FENCE - **CHECK FOR TORN OR COLLAPSED AREAS SEDIMENT TRAP SEDIMENT BASINS - **CHECK SEDIMENT STORAGE ZONE **CHECK THAT DEBRIS HAS BEEN REMOVED FROM WATTLES CATCH BASIN PROTECTION **GUNNY SACKS WITH 1-1/2" - 2" RIVER RUN ROCK *REPLACE CLOGGED FILTER FABRIC IMMEDIATELY ADDITIONAL COMMENTS EROSION CONTROL CHECKLIST (REVISED 6/2006) 35

36 Sampling Plan The General Permit was amended to require a sampling and analysis strategy regardless of whether you plan to sample. A strategy MUST be included in the SWPPP The requirements apply to all construction sites and supplement the Inspection Program required under the General Permit 36

37 Common Construction Site Pollutants 37

38 Visual Evidence of Pollution 38

39 If you get a site inspection. Cooperate with the inspector Discuss corrective actions Implement requested changes Follow up with documentation Run a clean and documented site that has good housekeeping, erosion and sediment controls 39

40 Part 2 Effective Erosion and Sediment Control and Housekeeping 40

41 Construction BMP Categories Temporary Erosion Control (Soil Stabilization) Temporary Sediment Control Wind Erosion Control Tracking Control Non-Storm Water Management Waste Management and Materials Pollution Control 41

42 Temporary Erosion Control (Soil Stabilization) ID EC-1 EC-2 EC-3 EC-4 EC-5 EC-6 EC-7 EC-8 EC-9 EC-10 EC-11 EC-12 EC-13 BMP Name Scheduling Preservation of Existing Vegetation Hydraulic Mulch Hydroseeding Soil Binders Straw Mulch Geotextiles & Mats Wood Mulching Earth Dikes/Drainage Swales & Lined Ditches Velocity Dissipation Devices Slope Drains Streambank Protection Polyacrylamide 42

43 EC-3 Hydraulic Mulch Most types need 24 hours to dry before rainfall occurs Generally good for one wet season (may need reapplication) 43

44 EC-3 Bonded Fiber Matrix (BFM) Last longer than mulch (may get several wet seasons) 44

45 EC-4 Hydroseeding EC-4 Hydroseeding Seed mix must comply with local standards Steep slopes are difficult to protect with temporary seeding Must be established to qualify as a BMP 45

46 EC-5 Soil Binders Generally temporary and may require reapplication Soil type dictates kind of soil binder to use Must be environmentally benign, and should not stain paved or painted surfaces 46

47 EC-6 Straw Mulch A tackifier (glue) is the preferred method of anchoring straw May not be allowed near structures (Fire Regs) Generally short lived (one wet season or less) Excellent performance 47

48 EC-7 Geotextiles & Mats Used when disturbed soil may be difficult to stabilize or drying time an issue Blankets and mats may need to be removed and disposed of prior to application of permanent soil stabilization Natural & synthetic 48

49 How Mulches Rank Mulch Straw Cellulose Fiber Recycled Paper BFM Cost/Acre $2100 $900 $900 $5400 Sediment Reduction (%) Source: Harlow Landphair, Texas A&M 49

50 How RECPs Rank Blanket Type Cost/Acre Sediment Reduction (%) Woven Jute Mesh $6, Excelsior $10, Straw Blanket $9, Coir $13, Plastic Mesh Woven $2,

51 How Hydraulic Soil Stabilizers Rank Material Guar Psyllium, starch Acrylic polymers and co-polymers polyacrylamide Cost/acre $410 $410 $1232 $410 Sediment Reduction (%)

52 Temporary Sediment Controls ID SE-1 SE-2 SE-3 SE-4 SE-5 SE-6 SE-7 SE-8 SE-9 SE-10 BMP Name Silt Fence Sediment Basin Sediment Trap Check Dam Fiber Rolls Gravel Bag Berm Street Sweeping and Vacuuming Sandbag Barrier Straw Bale Barrier Storm Drain Inlet Protection 52

53 Use of Sediment Controls Control Application Flow Type Area Longevity Silt Fence Perimeter Protection Sheet flow <0.5 Ac mo Reinf S.F Sediment Trap Shallow conc ac mo Wattle Perimeter, inlet Sheet <0.5 ac mo Sed. Basin Online/offline Concentrated >10.0 ac Indefinite Inlet Filter Inlet protection Concentrated mo Veg. Strip Perimeter/offisite Concentrated Indefinite Rock Entrance Tracking prevention N/a N/a 1-2 rain events Cattleguard Ent. Tracking Prevention N/a N/a indefinite 53

54 SE-1 Silt Fence Located level on contours, not perpendicular Not for concentrated flow areas unless reinforced Must be keyed in 54

55 Silt Fence Installation 55

56 Removal vs. Detention Time TSS Removal (%) Belton w Exxon w Mirafi A nw Mirafi B nw Amoco w Rock Berm Detention Time (min) 56

57 Silt Fence In Action 57

58 SE-2 Sediment Basin Tributary area 5 to 75 acres Use with erosion control, not instead of Drain in 7 days max Protect outlet from erosion Size per permit criteria 58

59 Sediment Basins Calculations must be in SWPPP and performed by a registered engineer Always have spillway Use anti-seep collars 59

60 SE-5 Fiber Rolls Locate on level contours Use at top and on face of slopes Good for perimeter control Space feet on slopes 60

61 SE-6 Gravel Bag Berm Use for small check dams Use for perimeter control 61

62 SE-10 Inlet Protection Protect active inlets yearround Use where ponding won t encroach into traffic 62

63 Curb Inlet Protection Non-proprietary 63

64 Curb Inlet Protection Proprietary Products 64

65 Inlet Protection Proprietary 65

66 Wind Erosion and Tracking Controls ID WE-1 TC-1 TC-2 TC-3 BMP Name Wind Erosion Stabilized Construction Entrance/Exit Stabilized Construction Roadway Entrance/Outlet Tire Wash 66

67 TC-1: Temporary Construction Entrance / Exit A VERY visible indicator of compliance effort (or lack of) Minimize number of access points Use coarse aggregate over fabric can add plates Year-round 67

68 Non-Storm Water Management BMPs ID NS-1 NS-2 NS-3 NS-4 NS-5 NS-6 NS-7 NS-8 NS-9 NS-10 BMP Name Water Conservation Practices Dewatering Operations Paving and Grinding Operations Temporary Stream Crossing Clear Water Diversion Illicit Connection / Illegal Discharge Potable Water / Irrigation Vehicle and Equipment Cleaning Vehicle and Equipment Fueling Vehicle and Equipment Maintenance 68

69 Non-Storm Water Management BMPs (cont d) ID NS-11 NS-12 NS-13 NS-14 NS-15 NS-16 BMP Name Pile Driving Operations Concrete Curing Concrete Finishing Material and Equipment Use Demolition Adjacent to Water Temporary Batch Plants 69

70 NS-2 Dewatering Likely requires a separate discharge permit from RWQCB Addresses sediment and other permit-specified pollutants 70

71 Dewatering Discharge Options Direct to sanitary sewer (with permission from sewer agency) Retain on site (e.g. use for dust control) Off-site transport & disposal via licensed contractor) 71

72 Dewatering Treatment Options Desilting basin or sediment trap Weir (Baker) tank Dewatering tank Gravity (dewatering) bag Filtration Effectiveness depends on target sediment particle size 72

73 Waste Management and Material Pollution Control BMPs ID WM-1 WM-2 WM-3 WM-4 WM-5 WM-6 WM-7 WM-8 WM-9 WM-10 BMP Name Material Delivery and Storage Material Use Stockpile Management Spill Prevention and Control Solid Waste Management Hazardous Waste Management Contaminated Soil Management Concrete Waste Management Sanitary / Septic Waste Management Liquid Waste Management 73

74 WM-1 Material Storage Cover and contain Keeps site clean Avoids potential sampling 74

75 WM-8 Concrete Waste Provide proper wash-out area Locate away from storm drain/street gutter Empty or provide new wash out when ¾ full 75

76 Common Site Implementation Problems 76

77 STUCCO, CONCRETE & PAINT MIXING AND STORAGE Potential Violations No protection of soil Could get into street

78 STUCCO, CONCRETE & PAINT MIXING AND STORAGE Better Practice Place mixers on liner with berms Cover, berm and contain

79 WASHOUT PITS Potential Violation Not using washout at all Leaking / ineffective washout

80 WASHOUT PITS Better Practice Provide washouts Use them Don t overfill

81 REQUIREMENT Locate a designated concrete washout Do not overfill

82 STUCCO/CONCRETE BAGS Potential Violations When exposed to rain, runoff with high ph can enter storm drain

83 STUCCO/CONCRETE BAGS Better Practice Protect soil Prevent contact with rain

84 MATERIAL BUCKETS Potential Violations No contact with soil Use secondary containment or store in a bin, not on soil

85 MATERIAL BUCKETS Better Practice Prevent contact with rain

86 EQUIPMENT WASHING Potential Violations Not contained Non-storm water discharge

87 EQUIPMENT WASHING Better Practice Use designated washout areas Empty washout when 75% full

88 LEAKING EQUIPMENT Potential Violations Leaks onto ground & no clean up Damaged drip pans Flat oil trays Plastic does not prevent runoff

89 LEAKING EQUIPMENT Better Practice

90 LEAKING EQUIPMENT REQUIREMENT Mortar pan or better Hold all liquids No oil on soil

91 CONSTRUCTION WASTE Potential Violations Good housekeeping is critical

92 CONSTRUCTION WASTE Better Practice Waste/debris and lunch trash must be collected and disposed of

93 REQUIREMENT Cover trash cans/bins when storm is predicted Empty at least every week

94 DIRT TRACKING Potential Violations Dirt tracked onto streets Inadequate/missing stabilized entrances

95 DIRT TRACKING Better Practice Stabilized lot & site entrances Gravel & plates free of excessive dirt Do not avoid stabilization measures use them!

96 REQUIREMENT If dirt is tracked out, contractor must clean up immediately

97 STOCKPILE MANAGEMENT Potential Violations Improper placement No measures to prevent material discharges

98 STOCKPILE MANAGEMENT Better Practice Provide perimeter protection Cover for long periods or before rain events

99 INLET PROTECTION Potential Violations Damaged devices or no protection at all

100 INLET PROTECTION Potential Violations Damaged devices lack of maintenance

101 INLET PROTECTION Better Practice Use products properly Actively maintain Prevent damage to devices Prevent pollutants from entering inlets

102 SAWCUTTING Potential Violation Better Practice Discharge to gutter/storm drain Vacuum saw cut slurry Away from concentrated flow paths Dispose based on local requirements

103 SECONDARY CONTAINMENT Potential Violations Storage of fuel/oils Improper storage No containment

104 SECONDARY CONTAINMENT Better Practice Do not store fuel on site, OR Use proper secondary containment

105 SITE PERIMETER Potential Violations No protection Damaged / ineffective protection

106 SITE PERIMETER Better Practice Proper controls & placement Well-maintained

107 SLOPES & PADS Potential Violations Inactive/completed areas with no EC applied

108 SLOPES & PADS Better Practice Completed / inactive areas protected with EC

109 SILT FENCE Potential Violations Poor installation Lack of maintenance

110 SILT FENCE Better Practice Proper installation Maintained

111 PORTABLE TOILETS Potential Violation Avoid placement in street gutter / flow areas

112 PORTABLE TOILETS Better Practice Placed out of gutters and flow paths 112

113 STREETS & SIDEWALKS Potential Violation Clean regularly dry sweep or vacuum No water unless runoff directed away from drain inlets to pervious areas

114 STREETS & SIDEWALKS Better Practice Well maintained 114

115 SWPPP References 115

116 Best Management Practices (BMPs) References 116

117 Reference Locations CA BMP Construction Handbook: Blueprint for a Clean Bay: rint%20for%20a%20clean%20bay_2003.pdf Erosion and Sediment Control Field Manual Guidelines for Construction Projects 117