New Requirements In Effect September 2, 2011
Storm Water Pollution Prevention Plans (SWPPPs) are a requirement of the National Pollutant Discharge Elimination System (NPDES) that regulates water quality when associated with construction or industrial activities. The SWPPP addresses all pollutants and their sources, including sources of sediment associated with construction, construction site erosion, and all other activities associated with construction activity and controlled through the implementation of Best Management Practices (BMPs).
The new Construction General Permit (CGP), effective September 2, 2011, requires SWPPPs to be prepared for construction sites over one (1) acre of disturbed area.
The new Permit requires the following:
1. Qualifications and Training. All SWPPPs must be prepared and certified by a Qualified SWPPP Developer (QSD) and many other SWPPP tasks (i.e. inspections) must either be conducted directly by, or under the supervision of a QSD or Qualified SWPPP Practitioner (QSP). There are extensive qualification and training requirements for both the QSD and QSP.
2. Risk Level Determination. The CGP follows a risk-based permitting approach.
- Each project is evaluated for sediment discharge risk and receiving water risk.
- Permit requirements progressively increase with risk level.
- Risk Level 2 and 3 sites must collect storm water samples and analyze the samples for pH and turbidity.
- The greater the risk level the greater the permitting requirements (i.e. monitoring, sampling, and BMPs).
3. Numeric Action Limits (NAL) and Numeric Effluent Limitations (NEL). Risk Level 2 and 3 sites must test runoff for pH and turbidity.
- Evaluation of BMPs and corrective action is required when NALs are exceeded.
- An NEL exceedance is a violation of the Construction General Permit, which can result in enforcement action by the local Regional Water Quality Control Board (RWQCB).
4. Rain Event Action Plans (REAP).
- A REAP must be prepared for Risk Level 2 and 3 sites 48 hours prior to a rain forecast of 50% probability.
- The REAP is designed to protect the site from erosion and to prevent discharge of pollutants.
- The REAP defines the storm water sampling activities and suggested actions for each construction phase.
- For Risk Level 2 and 3 sites all discharge points must be sampled at least three times a day during rain events.
5. Inspections. Inspections shall be performed:
- Weekly throughout the project, and
- Before and after qualifying rain events, and
- During extended qualifying rain events
- To identify BMPs that need maintenance or could fail. Inspectors shall be the QSP, or be trained by the QSP. Note that some Caltrans Districts require all inspections to be conducted by a QSP.
6. SMARTS (Storm Water Multiple Application Reporting and Tracking System).
- SMARTS is used for processing, reviewing, updating, tracking, and maintaining the status of each discharger.
- Each project’s Legally Responsible Person (LRP) is responsible for certifying project related documents on SMARTS.
- The general public can access SMARTS to review project related materials and track SWPPP compliance.
If you have questions about SWPPPs and whether or not your project requires one, please contact Torin Snyder, QSD/P at 760-918-9444.