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Construction Site Stormwater Compliance Presentation for CALBIG October 9, 2013

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Construction Site Stormwater Compliance Presentation for CALBIG October 9, 2013 Kristin Kerr, P.E., QSD EOA, Inc. on behalf of the San Mateo Countywide Water ... – PowerPoint PPT presentation

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Title: Construction Site Stormwater Compliance Presentation for CALBIG October 9, 2013


1
Construction Site Stormwater Compliance
Presentation for CALBIG October 9, 2013
  • Kristin Kerr, P.E., QSD
  • EOA, Inc.
  • on behalf of the San Mateo Countywide Water
    Pollution Prevention Program

2
Outline of Presentation
  • Overview of Stormwater Regulations
  • MRP Construction Site Inspection Requirements
  • Stormwater Inspection Documentation and Tracking
  • Enforcement
  • Resources

3
Stormwater Regulations 101
  • The Clean Water Act
  • Requires a Permit to discharge into Waters of the
    State from Point Sources
  • Wastewater Treatment Plants
  • Industrial Facilities
  • NPDES (National Pollutant
    Discharge Elimination
    System) Permits

4
1986 Amendments Stormwater Nonpoint Source
  • Requires permits to discharge stormwater from
  • Municipal Separate Storm Drains (MS4)
  • Industrial Facilities
  • Construction Sites
  • NPDES Municipal Stormwater Permits
  • Larger municipalities permits called Phase 1 and
    smaller ones Phase 2

5
Why Regulate Pollutants in Stormwater?
  • A storm drain system is completely separate from
    the sanitary sewer system
  • Water entering storm drains generally receives no
    treatment before discharging to creeks and the
    Bay

6
Municipal NPDES Permitting Authority
7
Stormwater Permits
  • Individual NDPES Stormwater Permits issued by
    Regional Board
  • Municipal Regional Permit (MRP)
  • Statewide NPDES General Stormwater Permits
    issued by State Board
  • Industrial General Permit (IGP)
  • Construction General Permit (CGP)
  • Phase II MS4 General Permit

8
Statewide General Permits
  • NPDES authority issues one permit
  • Used to cover same or similar operations
  • Facilities/municipality applies for coverage
  • Facilities/municipality submits Notice of
    Intent (NOI)

9
Statewide Construction Activities General Permit
  • Revised Permit adopted by State Board effective
    July 1, 2010
  • Applies to projects that disturb 1 acre of land
    Public Private
  • Contains requirements for site BMPs, inspections,
    sampling, SWPPP, reporting, QSP/QSD
  • Compliance inspections enforcement by Regional
    Water Board staff

10
What do you need to know about the Construction
General Permit (CGP)?
  • MRP Inspections looking at SWPPP, QSP inspection
    records, sampling results, etc. may help inform
    your inspection
  • Public projects 1 acre must file for coverage
    under the CGP - will you be involved?
  • Overall site compliance reflects on your
    inspection program
  • You inspect for compliance with local SW
    ordinance
  • Regional Board staff inspects for compliance with
    CGP

11
Municipal Regional Permit (MRP)
  • Regional permit regulating municipal stormwater
    systems
  • Adopted by Regional Water Board October 14, 2009
  • Effective date December 1, 2009
  • Permit renewed every 5 years
  • Applies to cities, counties, and districts in
  • San Mateo, Santa Clara, Alameda, and Contra Costa
    Counties
  • Fairfield and Suisun City (Solano County)
  • Vallejo (Solano County)

12
MRP Permit Provisions
  • C1 Compliance with Discharge Prohibitions
  • C2 Municipal Maintenance
  • C3 New Development and Redevelopment
  • C4 Industrial and Commercial Discharge
  • C5 Illicit Discharge Detection and Elimination
  • C6 Construction Inspection
  • C7 Public Information and Outreach
  • C8 Water Quality Monitoring
  • C9 Pesticide Toxicity Control
  • C10 Trash Reduction
  • C11 Mercury Load Reduction
  • C12 PCBs
  • C13 Copper
  • C14 PBDE and Legacy Pesticides
  • C15 Exempted Conditionally Exempted
    Discharges
  • C16 Reporting

13
MRP Construction Site Inspection Requirements
  • Big Picture Requirements
  • Implement a construction site inspection and
    control program at all construction sites
  • Prevent discharges of pollutants and impacts on
    receiving waters
  • When does this apply?
  • All year long!

14
MRP Construction Site Inspection Requirements
  • During wet season, at least 1 stormwater
    inspection per month for
  • sites disturbing gt 1 acre
  • high priority sites
  • Inspect both Public (e.g. CIP projects) Private
    sites

15
MRP Construction Site Inspection Requirements
  • What is a high priority site?
  • Identified by your municipality
  • Generally, site with lt 1 acre of land disturbance
    that
  • Has a steep slope and/or,
  • Is adjacent to a creek

16
MRP Construction Site Inspection Requirements
  • When is the wet season?
  • October 1st April 30th

17
Construction Site Inspections
  • When construction ends during wet season
  • Continue stormwater inspections until site is
    fully stabilized.
  • If stabilizing with vegetation, assume fully
    stabilized when there is 70 vegetative cover.

18
Construction Site Inspections
  • For every required stormwater inspection, there
    must be a completed inspection checklist.

19
Construction Site Inspections
  • For sites that require monthly wet season
    inspections, data from the stormwater inspection
    checklist must be
  • Tracked (in spreadsheet or database), and
  • Reported (in Annual Report).

20
Construction Site Inspections
  • Tracking table is not submitted in Annual Report
    but is the basis for Annual Report data summaries
  • Regional Board can request tracking table at any
    time
  • Inspection tables should match summaries in
    Annual Report

21
Stormwater Inspection Forms
22
Stormwater Inspection Form
  • Document Problems in 6 BMP categories
  • Erosion control
  • Run-on and run-off control
  • Sediment control
  • Active treatment systems (as needed)
  • Good site management
  • Non-stormwater management

23
Stormwater Inspection Forms
  • Document Illicit Discharges

24
Stormwater Inspection Forms
  • Enforcement Actions
  • Resolution of Problem
  • Problems fixed
  • Need More Time
  • Escalate Enforcement
  • Comments rationale for longer compliance time,
    all escalation in enforcement discussions,
    relevant information

25
Enforcement Options and Reporting
26
Enforcement Response Plan (ERP)
  • Each agency must have and implement an ERP
  • ERP provides framework for consistent and
    effective enforcement
  • ERP must include progressive (escalating)
    enforcement
  • The Program prepared an ERP template in 2010
  • Agencies developed ERPs based on the template

27
Whats in an ERP?
  • Identifies enforcement actions and timeframes for
    correction of violations.
  • Timeframes Violations must be corrected
  • Within 10 business days ,
  • Or before next rain event,
  • OR record rationale for longer compliance.
  • Procedures for escalating the enforcement
    response.

28
Example of Progressive Enforcement
Problem Enforcement Level Options Correct within
Illicit discharge no significant harm to the environment Verbal Warning or Notice of Violation 10 business days or before next rain event
Illicit discharge significant harm to the environment Notice of Violation or Stop Work Notice or Cost Recovery 10 business days or before next rain event
Failure to comply Notice of Violation or Stop Work Notice or Cost Recovery or Legal Action and May refer to Water Board staff 10 business days or before next rain event
29
Documenting Violations
  • Violations identified during inspections (and
    other data) must be recorded on inspection form.
  • The specific category of the violation must be
    indicated.
  • Example on next slides.

30
Documenting Violations Example
31
Documenting Violations Example
32
Documenting Enforcement
  • For all violations Show the level of enforcement
    on the checklist.
  • Should be appropriate to violation and lead to
    timely, corrective compliance.
  • Repeat violations should result in escalated
    enforcement response level.
  • Indicate the timeframe for correcting violation
    on checklist.

33
Lessons Learned from 2013 ERP NOVs
  • Provide field scenarios for each level of
    enforcement.
  • Give timeframes and procedures to verify
    corrective actions implemented within 10 business
    days or before next rain.
  • Include discussion of which staff has authority
    to issue each level of enforcement.

34
Lessons Learned from 2013 ERP NOVs
  • Provide discussion of escalating responses for
    repeat violations.
  • There should be consistent enforcement action in
    the ERP and Annual Report.

35
What else should you know about the MRP?
  • Provision C.13.a. manage waste generated from
    cleaning/treating copper architectural features
    during construction
  • SMCWPPP BMP Fact Sheet

36
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37
What else should you know about the MRP?
  • Provision C.3.h Stormwater Treatment Systems
    Operation Maintenance (OM) Verification
    Inspections
  • Municipalities must maintain a database of
    Regulated Project treatment/HM controls
  • Report on inspections in Annual Report

38
What else should you know about the MRP?
  • SW Treatment Systems OM Inspections continued..
  • specific requirements for number of inspections
    and frequency
  • Inspection of new BMPs within 45 days of
    installation
  • Inspection of at least 20 of all BMPs installed
  • Inspection of at least 20 of total vault-based
    or proprietary systems
  • Inspection of all BMPs at least once every 5 years

39
For More Information
  • Municipal Regional Stormwater Permit
    www.waterboards.ca.gov/sanfranciscobay/water_issue
    s/programs/stormwater/mrp.shtml
  • SMCWPPP Construction BMP Resources
    http//www.flowstobay.org/construction
  • CASQA Construction BMP Handbook Portal (available
    on web by subscription contact your agency
    stormwater coordinator for information on how to
    access the portal) www.casqa.org

40
  • Contact Information
  • Kristin Kerr
  • EOA, Inc.
  • kakerr_at_eoainc.com
  • 510-832-2852, X122
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