Erosion and Sediment Control
Project-Specific Environmental Orientation – Who, What, How, and Why
The Construction General Permit (General Permit), be it for the EPA or a State, outlines all the conditions required for compliance with the Clean Water Act (CWA) as it relates to stormwater management on construction sites. A Stormwater Pollution Prevention Plan (SWPPP) must be developed to serve as a roadmap outlining the specific details of how the project will comply with the General Permit. However, creation of the SWPPP is only the first step in being compliant with the General Permit. The implementation of the SWPPP is the true test of your project’s level of compliance. Many times, compliance issues that arise are not due to intentionally ignoring the General Permit, but instead a lack of understanding about what is required.
Properly conducted project-specific environmental orientation provides the contractors with the knowledge needed to understand how their specific duties are impacted by the General Permit. The orientation provides the opportunity to highlight specific aspects of the project that will be affected by the General Permit and what will be expected of the contractors. It also provides the chance to verify that the contractors understand not only what they are supposed to be doing to stay in compliance, but how they should do it and why they should do it in the manner prescribed. Many of the common misconceptions about stormwater management that have been passed down through the years can be easily clarified and corrected with a properly designed and implemented orientation policy.
This presentation will discuss what should be included in a project-specific environmental orientation and provide examples on how to cover these various topics. The topics discussed should include all relevant environmental and non-environmental permits associated with the project as well as any special or sensitive resources. These could include special use waters, 303(d) listings, highly erosive soils, contaminated or impacted soils, high value wetlands or waterways, cultural resources, protected species habitats, etc. BMPs that will be used during construction and those that will be installed for post-construction should be covered. This section should discuss their proper installation and maintenance, how BMPs function to minimize erosion and offsite sedimentation, and why a specific BMP may be used in specific situation, versus a similar alternative. Finally, the responsibilities of the individual contractors should be covered. This should address how their actions can adversely affect the SWPPP and associated BMPs as well as spill prevention control and countermeasures, fire prevention, and general housekeeping.