Storm Water Pollution Prevention Plan (SWPPP)
The State of California requires all new projects involving grading, demolition, new construction or any activity that results in the ground disturbance of more than one acre, to obtain coverage and comply with the terms of the State’s Construction General Permit (Order No. 2009-0009 [effective July 1, 2010]), which is enforced by the State Water Resources Control Board (SWRCB). As part of complying with the General Permit, a Storm Water Pollution Prevention Plan (SWPPP) may be required and implemented prior to commencement of ground-disturbing activities.
The new Construction General Permit also includes a provision which allows for a waiver from the SWPPP requirements for projects less than 5 acres in size and scheduled during dry periods of the year. The waiver is meant to encourage developers to schedule their earthwork activities during periods of low rainfall. We have been able to secure waivers for many projects located in the arid parts of California such as the San Joaquin Valley and the Mojave Desert.
Some local agencies, including the California Department of Transportation (Caltrans), may require that a Local SWPPP (LSWPPP) or Water Pollution Control Program (WPCP) be developed and implemented prior to a Notice to Proceed or issuance of a permit, even if the disturbed surface area is less than one acre. Threat to receiving water is a major consideration with all agencies.
Our Stormwater Objective and Approach
The General Construction Permit takes a tiered approach to stormwater protection, based upon the proximity of the project to sensitive receiving waters and the potential discharge volume of sediment to those waters. Projects are classified as follows:
Risk Level 1: Projects with a low potential to discharge sediment to receiving waters and do not discharge to a sensitive water body. These projects require a SWPPP, NOI, weekly BMP inspections, visual rain event inspections, and do not typically require effluent testing. Most projects in California with construction duration of less the one year will be classified as risk level 1.
Risk Level 2: Projects with either 1) a low potential to discharge sediment to receiving waters but have runoff that discharges to a sensitive water body or 2) a medium to high potential to discharge sediment to receiving waters but these receiving waters are not a sensitive water body. These projects require a SWPPP, NOI, weekly BMP inspections, visual and numerical (pH and turbidity) rain event inspections and testing. Projects in California with construction duration of more than one year, or larger projects which discharge to a sensitive receiving water, will be classified as risk level 2.
Risk Level 3: Projects with a high potential to discharge sediment to receiving waters and have runoff that discharges to a sensitive water body will be classified at risk level 3, the highest level of risk. Fewer than 10% of projects in California will be classified at Risk level 3. These projects require a SWPPP, NOI, weekly BMP inspections, visual and numerical (pH and turbidity) rain event inspections and testing. These sites will have numeric limits on effluent, may require additional testing and active stormwater treatment systems. Large projects in California or construction projects of long duration which discharge to a sensitive receiving water will be classified as risk level 3.
Stormwater Waivers: The EPA allows exemption from these General Permit requirements for projects of short duration on sites smaller then 5 acres. This waiver will require the filing of an NOI with the state, but will exempt the site from inspection and testing. Staging your small project to be constructed during the dryer season will allow you to take advantage of this provision.
|Receiving Water Risk||Low||Level 1||Level 2|
|High||Level 2||Level 3|
Our approach is to achieve full compliance within the framework of the Construction General Permit at minimum expense to you through the duration of the construction period. To achieve this we offer the following:
- Discussion of your project, review of available plans, and conduct a site visit if necessary.
- File a Notice of Intent (NOI) with the State.
- Prepare a Plan that meets the following objectives:
- Identify all pollutant sources including sediment that may negatively affect quality of storm water discharge.
- Recommend implementation of cost-effective Best Management Practices (BMPs) to reduce or eliminate pollutants in storm water (and authorized non-stormwater) discharges from the project site.
- Create an erosion and sediment control plan detailing sediment and erosion control BMPs to be included in the SWPPP. These can be based off of grading plans, improvement plans, utility plans, or topographic surveys, depending on the type of project (hardcopy, PDF, AutoCAD, or Microstation format).
- (If NOI is filed): Upon completion of the project, transfer of ownership, or other change, file all applicable forms such as Change of Information (COI) or Notice of Termination (NOT), as necessary to minimize or omit owner’s liability under the General Permit.
- Assist the site superintendent throughout the construction or demolition process to ensure proper deployment of BMPs.
All Plans include a recommendation of acceptable and cost-effective BMPs to prevent sediment from leaving the site and control erosion. The format and content of our SWPPP’s are based upon industry standard templates that are accepted by the EPA and State.