Stormwater Pollution Prevention Plans SWPPPs for NDDOT Construction Projects

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Stormwater Pollution Prevention Plans (SWPPPs)
for NDDOT Construction Projects
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Key Definitions

• Owner (NDDOT) - means the person or party
  possessing the title of the land on which the
  construction activities will occur or if the
  construction activity is for a lease holder, the
  party or individual identified as the lease
  holder or the contracting government agency
  responsible for the construction activity.
• Operator (Contractor) - means the person (usually
  the general contractor), designated by the owner,
  who has day to day operational control and/or the
  ability to modify the SWPPP. The person must be
  knowledgeable in those areas of the permit for
  which the operator is responsible and must
  perform those responsibilities in a workmanlike
  manner.

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NDDOT Standard Specifications
110.03 Preconstruction Conference. The
contractor shall submit in writing, for
acceptance at the preconstruction conference or
before starting work on the construction, a
temporary erosion and pollution control plan.
110.05 Erosion Controls Temporary pollution
control measures shall be used to correct
conditions that develop during construction, that
are needed before installing permanent pollution
control features, or that are needed temporarily
to control erosion during construction. These
temporary measures are not associated with
permanent control features on the Project.
110.06 Method of Measurement and
Payment. Should the Contractor fail to control
erosion, pollution, and siltation, the Engineer
will employ outside assistance or state force to
do the work. The direct costs, overhead costs,
and engineering costs incurred under these
condition will be deducted from payments due the
Contractor for work done on the Contract."
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NDDOT/NDDOHMemorandum of Agreement(MOA)

• Clarify the permit processes and synchronize, to
  the greatest extent practical, permit closure and
  project finalization.
• Acknowledges NDDOT as owner and duly authorizes
  contractor to submit application, without NDDOT
  signature.
• Eliminates transfer requirements to NDDOH.
• NDDOT will submit or direct the contractor to
  submit a NOT after a construction project is
  complete.

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Preconstruction Conference

• 110.03 Preconstruction Conference.
• The contractor shall submit in writing, for
  acceptance at the preconstruction conference or
  before starting work on the construction, a
  temporary erosion and pollution control plan.
• Have commitments been carried forward and
  included in the SWPPP? (specific to erosion
  control on and off the project site?)

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Storm Water Pollution Prevention Plan
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Storm Water Pollution Prevention Plan (SWPPP)

• All construction projects must develop and
  implement a SWPPP!!!
• The objective of the SWPPP is to identify
  potential sources of sediment or other pollution
  from construction activities and ensure practices
  are used to reduce pollution.
• The SWPPP is not only a tool for the regulators
  to review, but for you and your employees to
  review if there are any questions.
• The Storm Water Pollution Prevention Plan is not
  the same as the Storm Water Management Plan.

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• You do not have to use the forms provided by the
  state, but you must include all of the
  information found on the forms.
• Some project plans will have the SWPPP in the
  Erosion and Sediment Control Sheets (NDDOT Plan
  Section 60 Plan and Profile).
• A different SWPPP must be developed for every
  construction project that disturbs 1 acre or
  more.
• Multiple projects located in close proximity to
  each other may require multiple SWPPPs or one
  common SWPPP.
• Information that usually stays the same
• Spill Prevention and Response
• Procedures for Site Inspections and Maintenance
• Methods to Reduce Sediment Tracking
• Methods for Recovering Tracked Sediment
• Methods for Recovering Sediment
• Significant Materials

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• Must incorporate the guidelines of Appendix 1 of
  the general construction permit where
  practicable.
• Must include a site description
• Description of the overall project and type of
  activity
• Estimate of the total area to be disturbed
• Proposed timetable of activities
• Description of the type of soil within the
  disturbed area
• Name of the surface water(s) or municipal storm
  sewer systems at or near the disturbed area
• Site map

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If you have Erosion and Sediment Control details
included in project plans it is OK to refer to
them here or substitute a copy of them here
Only include the BMPs that will be used, and/or
state when they will be used. Items indicated
in the SWPPP that are not in place in the field
will raise questions.
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Best Management Practices (BMPs) Operating
procedures, activity scheduling, non-structural
or temporary controls aimed at reducing impact to
waters Techniques that rely mostly on field
judgment -- rule of thumb sizing
Structural or Engineered Features Designed
according to engineering standards sized to
withstand expected runoff flow Sometimes designed
to meet treatment performance standard (ie
percent solids removal)
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• Significant Materials
• What do you have on site that could be a spill
  or runoff and harm your water resource?
• Lists of common materials are available

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• How do we handle Subcontractors?
• Inform them of SWPPP and have sign as additional
  operator
• Discuss erosion issues at daily or weekly
  meetings
• NDDOT Specification 110.06

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• Other Inspection Record formats can be used to
  suit your project
• Combine with other project inspections, progress
  reports or construction notes
• Required once every 14 days and following ½ inch
  rains (ND only)
• May suspend when shut down for winter or when
  ground is frozen
• Stabilized area frequency may be reduced

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• All inspections must be recorded in writing! If
  theyre not written down then they did not occur.
• Date and time of inspection
• Name of person conducting inspections
• Findings of inspections and recommended
  corrective actions
• Corrective actions taken (include dates, times,
  and party completing maintenance activities)
• Date and amount of rainfall events greater than ½
  inch in 24 hours
• Documentation that the SWPPP has been amended
  when substantial changes are made to ESCs or
  other BMPs
• Know where the records are being kept (District
  office, field office, where?). The records or
  copies of the records must be available at the
  time of inspection.

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• Keep a running list of revisions made to the
  SWPPP. Include
• Item Revised
• Revision Made
• Date
• Initials

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Notice of Termination(NOT)

• At the time of permit closure either the District
  or the General Contractor, directed by the NDDOT
  will submit the NOT.
• If contractor submits NOT, a statement from the
  NDDOT directing the contractor to submit the NOT
  to the NDDOH must be included.

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Project finalized but the permit remains open!

• Inspections and maintenance must still be
  performed.
• Inspections need to be preformed only on those
  areas that have not obtained final stabilization
  and are identified as such in the SWPPP.
• Maintenance requirements will vary depending on
  the site conditions, but must be recorded when
  performed.
• Who is responsible, NDDOT or the contractor?
• Under permit conditions both can be held
  accountable. NDDOT as the owner and the
  contractor as the operator.
• Communication is key to ensuring permit closure.

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Questions?

• Tom Huncovsky
• NDDOT
• Environmental and Transportation Services
• [phone]
• thuncovsky_at_nd.gov
• Dallas Grossman
• NDDOH
• Storm Water Program
• [phone]
• dgrossma_at_nd.gov