CONSTRUCTION PROJECT Storm Water and Soil Erosion Control

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1 CONSTRUCTION PROJECT Storm Water and Soil Erosion Control November 30, 2006

2 Are Polluted Waters Really a Problem? According to the U.S. EPA, Forty percent of all U.S. waters are not fishable or swimmable. Even a partial accounting shows that hundreds of millions of dollars are lost each year.due to urban stormwater pollution Natural Resources Defense Council 2

3 Introduction One gallon of oil has the potential to contaminate up to one million gallons of water Over 180 million gallons of motor oil are illegally discharged each year more than 16 times the amount spilled by the Exxon Valdez. StormWater/CleanWater protection program 3

4 Introduction Sediment, the most common pollutant washed from construction sites, clogs the gills of fish, blocks light transmission and increases ocean water temperature..harming aquatic life, and disturbing the food chain 4

5 Introduction Satellite photo of sediment flowing into Santa Monica Bay after 1 rain event 5

6 Regulatory Framework 1972 Federal Clean Water Act (CWA) Principal legislation for control of storm water discharge Amend to Prohibit Any Discharge of Pollutants from a Point Source The main focus was sewage treatment plant and industrial facilities 1987 Amendments to the CWA Added Section 402(p) requiring the EPA to develop regulations for municipal storm water discharge (including construction sites) 1990 EPA Published Phase I Regulations Populations over 100, EPA Published Phase II Regulations Populations under 100,000 6

7 Regulatory Framework Who s Affected By the Regulations? Municipalities Cities & Counties, DOTs Construction Projects Industries Factories, refineries, airports, rail, trucking 7

8 Regulatory Framework The Federal Clean Water Act (CWA) allows the Environmental Protection Agency (EPA) to delegate its NPDES permitting authority to the states The Porter-Cologne Act is the principal legislation for control of storm water discharge in California Authorizes the State Water Resources Control Board (SWRCB), through its nine Regional Water Quality Control Boards (RWQCB) to regulate and control the discharge of pollutants into the waters of the state and tributaries. 8

9 Regulatory Framework The California State Water Resources Control Board (SWRCB) has issued the following three General NPDES permits: Industrial Activities Permit (CAS000001) Construction Activities Permit (CAS000002) Caltrans Permit (CAS000003) The General Construction Activities Permit regulates construction projects that encompass one or more acres of disturbed soil area Develop and implement a SWPPP Must apply for coverage by filing an Notice of Intent (NOI) to the SWRCB Eliminate or reduce non-storm water discharges Perform inspections of all BMPs Develop a Sampling and Analysis Plan (2001 Modification) 9

10 Regulatory Framework The California Regional Water Quality Control Boards (RWQCB) issues Municipal Separate Storm Sewer System (MS4) NPDES permits In Los Angeles County, an MS4 Permit was issued to the Los Angeles County Flood Control District Permittee and 84 cities in the county Co Co-Permittee and requires: This MS4 Permit requires Permittee to control runoff from all construction sites Reduce pollutants in storm water runoff including erosion from slopes and channels by applying Best Management Practices (BMPs) Prohibit non-storm water discharges into the storm drain system Eliminate illegal and illicit discharges to the storm drain system The City of Long Beach was issued a separate MS4 Permit 10

11 Who Enforces These Laws? EPA SWRCB and RWQCB Fish & Game Local Agencies Private Citizens NRDC Baykeepers Other Watchdog Groups 11

12 How Do We Comply? Develop and implement water pollution control elements, including: Preparation of a SWPPP Implement BMP s per approved SWPPP and Special Provisions Inspection and maintenance of BMPs Construction of permanent BMPs Completion of the Annual Compliance Certification Liaison between Contractor, Owner/Agency, and Regulatory Agencies 12

13 Contract Documents SECTION STORM WATER POLLUTION PREVENTION PLAN PREPARING, IMPLEMENTING, & MONITORING THE SWPPP COMPLIANCE WITH LOCAL, STATE AND FEDERAL REGULATIONS PAYMENT OF APPLICATION AND ANNUAL RENEWAL FEES TO SCRCB CERTIFICATION OF PROJECT COMPLIANCE WITH STORM WATER PERMIT 13

14 Storm Water Handbooks / Manuals California Stormwater Quality Association (CASQA) Stormwater BMP Handbooks New Development and Redevelopment Construction Industrial and Commercial Municipal Get Manuals online at 14

15 Storm Water Handbooks / Manuals Caltrans Storm Water Quality Handbooks Project Planning and Design Guide SWPPP / WPCP Preparation Manual Construction Site BMPs Manual Get Manuals online at Los Angeles County Department of Public Works Construction Site Best Management Practices (BMP) Manual Additional Resources at 15

16 Storm Water Pollution Prevention Plan (SWPPP) What is a SWPPP? Detailed Document Required on jobs with soil disturbance of 1 acre or more Jobs with soil disturbance under 1 acre may also require a SWPPP In or near a water body Phase or segment of a larger project Covers Requirements of the NPDES Permit How long will it take? First Time- It can be a struggle. Once you get the hang of it Days to gather information, make calculations, prepare drawings s and text. 16

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20 Preparing a SWPPP 3 Ring Binder with Dividers and Tabs SWPPP Sections Title Page Section 100 Certifications and Approvals Section 200.Amendments Section 300.Introduction/ Project Description Section 400.Reference Section Section 500.Body of SWPPP Section 600 Monitoring Program and Reports Appendices 20

21 What Are Best Management Practices (BMPs)? Any program, technology, process, operating method, measure, or device that controls, prevents, removes, or reduces pollution 21

22 What Are Non-Storm Water Discharges?? What is Non-Storm Water? Water that doesn t originate from a storm Wash Water Concrete and concrete slurry Water used for dust control Septic Waste Chemical Spills Dewatering Groundwater 22

23 Section 500 Body of SWPPP Water pollution Control Drawings (WPCDs) Construction site perimeter Site topography before and after construction: roads, paved areas, buildings, slopes, drainage areas, surface waters, etc. Outline of all areas of disturbed soil (grading) Location of selected BMPs Include detailed sheets showing construction BMPs that will be used Location of non-storm water discharges and activities Identified location of contaminated soils Contractor s yard Monitoring locations (new) 5 5 Permanent post-construction BMPs Sample WPCD

24 Types of BMPs Source Controls Designed to keep pollutants from coming in contact with storm water Treatment Controls Designed to capture and remove pollutants from storm water 24

25 Construction Site BMP Basics Six BMP Categories 1. Temporary Soil Stabilization ( Erosion Control) 2. Temporary Sediment Control 3. Wind Erosion Control 4. Tracking Control 5. Non-Storm Water Management 6. Waste Management and Materials Pollution Control 25

26 A Very Important Concept: Erosion Vs Sediment The Permit Requires:.an effective Combination of Erosion and Sediment Control for all disturbed areas during Construction 26

27 Erosion Control and Sediment Control What s s The Difference? Erosion Controls Prevent/Reduce Erosion Sediment Controls Capture/Contain Sediment 27

28 Why Aren t t Sediment Controls Good Enough Anymore? Erosion Control (Covering the Soil) Is Typically 90-98% effective Sediment Basins ( A sediment Control) Can be 70-90% effective Traditional Sediment Controls (Silt fence, Sand bags, etc.) are typically 40-50% effective when properly installed and maintained 28

29 Construction Site BMPs Erosion Control ID SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 BMP Name Scheduling Preservation of Existing Vegetation Hydraulic Mulch Hydroseeding Soil Binders Straw Mulch Geotextiles, Plastic Covers, & Erosion Control Blankets/Mats Wood Mulching Earth Dikes/Drainage Swales & Lined Ditches Outlet Protection/Velocity Dissipation Devices Slope Drains 29

30 Construction Site BMPs SS-1 1 Scheduling Example of Graphical Schedule Rainy Season Oct 15 to Apr 15 30

31 Construction Site BMPs SS-7 Geotextiles,, Plastic Covers, Erosion Control Blankets/Mats Used when disturbed soil may be difficult to stabilize Materials selected by the contractor must be approved by the Engineer Blankets and mats must be removed and disposed of prior to application of permanent soil stabilization Erosion Control Blankets 31

32 Construction Site BMPs SS-9 9 Earth Dikes/Drainage Swales/Lined Ditches Conveyances shall be stabilized Not suitable for trapping sediment Do not divert runoff onto other property 32

33 Construction Site BMPs Sediment Control ID SC-1 SC-2 SC-3 SC-4 SC-5 SC-6 SC-7 SC-8 SC-9 SC-10 BMP Name Silt Fence Desilting Basin Sediment Trap Check Dam Fiber Rolls Gravel Bag Berm Street Sweeping and Vacuuming Sandbag Barrier Straw Bale Barrier Storm Drain Inlet Protection 33

34 Construction Site BMPs SC-1 1 Silt Fence Not effective unless keyed in Don t use in streams, channels or anywhere flow is concentrated 34

35 Construction Site BMPs SC-7 7 Street Sweeping and Vacuuming Do not use kick brooms or sweeper attachments Visible sediment tracking should be swept and vacuumed daily Dispose of sweeper waste at an approved dumpsite 35

36 Construction Site BMPs SC-10 Storm Drain Inlet Protection Use where ponding will not encroach into traffic For use in areas where sediment laden runoff may enter an inlet 36

37 Construction Site BMPs Wind Erosion Control ID WE-1 BMP Name Wind Erosion Control 37

38 Construction Site BMPs Tracking Controls ID TC-1 TC-2 TC-3 BMP Name Stabilized Construction Entrance/Exit Stabilized Construction Roadway Entrance/Outlet Tire Wash 38

39 Construction Site BMPs TC-1 1 Stabilized Construction Entrance/Exit Crushed rock and/or steel plates used as a stabilized entrance/exit. 39

40 Construction Site BMPs TC-1 1 Stabilized Construction Entrance/Exit Lack of stabilized entrance/exit 40

41 Construction Site BMPs Non-Storm Water Management ID NS-1 NS-2 NS-3 NS-4 NS-5 NS-6 NS-7 NS-8 NS-9 NS-10 NS-11 NS-12 NS-13 NS-14 NS-15 NS-16 NS-17 BMP Name Water Conservation Practices Dewatering Operations Paving and Grinding Operations Temporary Stream Crossing Clear Water Diversion Illicit Connection/Illegal Discharge Detection and Reporting Potable Water/Irrigation Vehicle and Equipment Cleaning Vehicle and Equipment Fueling Vehicle and Equipment Maintenance Pile Driving Operations Concrete Curing Concrete Finishing Material and Equipment Use Over Water Structure Demolition/Removal Over or Adjacent to Water Temporary Batch Plants Streambank Stabilization 41

42 Construction Site BMPs Waste Management and Material Pollution Control 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 42

43 Inspection of BMPs Who is Responsible? Primary responsibly is the Contractor District provides assistance and oversight. Project Team OEHS RWQCB Third-Party / Watchdog Groups 43

44 Inspection of BMPs Contractor Inspect for BMP effectiveness Inspect for BMP maintenance If BMPs are inadequate - implement corrective action, amend SWPPP, as necessary Report discharges and make corrections so that discharges are not repeated Provide required reports 44

45 Inspections of BMPs Frequency Prior to anticipated storm events During extended storm events (once each 24-hour period) After actual storm events As specified in the Contract 45

46 Inspection of BMPs LAUSD Inspect for compliance with: Specifications SWPPP General Construction Activities Permit MS4 Permit Ordinances Inspections conducted by: IOR OEHS 46

47 Inspection of BMPs RWQCB The RWQCB is responsible for inspecting private projects for compliance with the General Permit The RWQCB may inspect any project for compliance with the General Permit 47

48 What if We Do Not Comply? Contractual Sanctions in LA County Notice of Non-Compliance Cease and Desist Order Withhold $1,000 per day Local Ordinances / Fines Los Angeles County Code Section Class 3 Misdemeanor Punishable by no more than $1,000 or by imprisonment for a period of not more than six 6 months 48

49 What if We Do Not Comply? RWQCB EPA Porter Cologne Act: $10k per day + $10 per gallon + Cost of RWQCB s time to inspect Fines administered by Administrative Civil Liability (ACL) CWA Section 309(c)(4) $27,500 per day and/or 2 years imprisonment Third Party Lawsuits Current Regulatory Atmosphere - The Learning Curve is Over 49

50 Conclusion Please take these final thoughts with you Read the water pollution control documents Understand the requirements Prepare a SWPPP Use an effective combination of erosion and sediment control BMPs Utilize appropriate non-storm water controls Use resources available to you Be proactive not reactive Inspect / monitor / control 50

51 it s s 4 the Kids!! You can make a difference Water pollution control: Helps preserve valuable habitat Protects scenic resources and recreational water uses Protects water resources for future generations to enjoy Questions / Answers 51

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