| Please add stormwater@enplan.com to your safe sender list | Printer Friendly Version | Can't see images? Click here |
 |
|
| |
SWRCB PERMIT REQUIREMENTS CHANGE |
|
| New Storm Water Quality Constraints for Construction Sites |
| Updated September 15, 2011 |
The California State Water Resources Control Board (SWRCB) recently adopted more stringent General Permit requirements related to storm water runoff from construction sites. The requirements, which went into effect on July 1, 2010, influence construction project design, implementation, and reporting.
The most significant of the changes is the adoption of a quantitative methodology to estimate risk, classify project risk levels, and mandate actions to minimize and monitor impacts of construction activity on the quality of storm water runoff. This is the first time a numeric methodology to monitor runoff quality has been applied by the SWRCB.
It is important that you learn about these new requirements and revise your compliance strategy, as fines of $25,000 to $37,500 per day may be levied for non-compliance.
Limits established
Numeric Action Levels (NALs) and Numeric Effluent Limitations (NELs) for pH and turbidity, a measurement of sediment concentration, as well as numeric limits for Active Treatment System (ATS) discharges, have been established.
Site risk assessment
An assessment must be conducted to determine sediment transport risk and receiving water risk. Several parameters, including proximity to receiving water, project size, soil type, and rainfall erosion potential, are used to determine these risks. |
| |
|
| |
Project design and management
The risk assessment results are used to assign an overall Risk Level to a project. Risk Levels range from 1 (lowest) to 3 (highest). Compliance monitoring, which varies by Risk Level, is required.
| REQUIREMENTS |
Risk Level 1 |
Risk Level 2 |
Risk Level 3 |
| Best Management Practices (BMPs) |
Yes |
Yes |
Yes |
 |
| Visual monitoring |
Yes |
Yes |
Yes |
|
| Site storm water runoff sampling |
Sometimes |
Yes |
Yes |
|
| Receiving waters sampling |
No |
No |
Sometimes |
Reporting
Risk Level 2 dischargers must electronically report storm event sampling results when NALs are exceeded, while Risk Level 3 dischargers must electronically report all storm event sampling results. Exceedance alone does not constitute a violation of the General Permit conditions, but it does obligate the permit holder to undertake immediate corrective action. Additionally, an annual report must be submitted for sites with more than three months of continuous coverage under the General Permit. Annual reports must include site inspection records, results of site sample analyses, corrective actions taken, and documentation of completed training.
Waivers and exceptions
• Permitted construction sites as of July 1, 2010, will be grandfathered in at Risk Level 1 for two years. Once the grandfathering period ends, however, construction sites may be reclassified to a higher risk level (Risk Levels 2 or 3).
• Construction sites from one to five acres in size are exempt from the General Permit requirements if the R value (risk of erosion by rain) is less than or equal to 5 for the site’s location and time frame.
• Construction sites smaller than one acre in size that are not a part of a larger development plan are exempt from the General Permit requirements.
Required training and qualifications
Training is mandatory for individuals preparing storm water plans, performing site inspections, and implementing Best Management Practices (BMPs).
Permit documents
Permit Registration Documents (PRDs) must now be filed electronically; however, the accompanying Permit Fee must be mailed. PRDs include:
• Notice of Intent
• Site Risk Assessment
• Site Map
• Storm Water Pollution Prevention Plan (SWPPP)
• Signed Certification Statement
As of September 2, 2011, all individuals preparing and amending storm water pollution prevention plans (SWPPPs) must have attended a Qualified SWPPP Developer (QSD) training course, have a recognized pre-requisite certification, and passed the QSD state exam to continue preparing and amending SWPPPs. Meanwhile, individuals conducting site inspections, collecting storm water samples, and implementing best management practices (BMPs) must have attended a Qualified SWPPP Practitioner (QSP) training course, have a recognized pre-requisite certification, and have passed the QSP state exam to continue conducting these actions, or be working under the direct supervision of a certified QSP. If you are still seeking certification, please join us at an ENPLAN QSP/QSD training.
Clay Guzi is a certified professional in Storm Water Quality, as well as Erosion and Sediment Control, at ENPLAN. Based in Redding, ENPLAN provides comprehensive environmental compliance services to the construction industry. Clay may be contacted at
530.221.0440 x 115 (Voice), 530.221.6963 (Fax), or stormwater@enplan.com.
|
|
Printer Friendly Version | Can't see images? Click here
© 2011 ENPLAN | www.enplan.com | 530.221.0440 Voice | 530.221.6963 Fax |
| If you wish to no longer receive e-mail announcements, you may unsubscribe here. |
|
|
