Erosion and Sediment Control
Preparing and Implementing Stormwater Pollution Prevention Plans for Construction Projects Involving Multiple Scopes of Work: Do’s and Don’ts
Construction projects can be hectic and complicated. There are bid specifications, design drawings, contracts, forms, orientations, certifications, and countless other factors that need to be considered before a project can even break ground. Additionally, there are oftentimes environmental permitting conditions that need to be adhered to. Permitting requirements can make a complicated situation even more complex, especially in cases where construction projects require coverage under a National Pollutant Discharge Elimination System (NPDES) construction general permit, whether it be at the Federal, State, or Local level.
Oftentimes construction tasks and responsibilities are divided and assigned to different contractors with different specialties. For example, tree removal companies clear a construction site, grading contractors move dirt, concrete contractors pour concrete, building contractors build, and restoration/landscaping contractors bring sites to their finals state. Sometimes each individual contractor reports to a general contractor who serves as a project manager, but sometimes contracting situations are much more complicated.
Contractors will come and go when they begin and complete their scope of work. However, the NPDES permit coverage and SWPPP, when required, need to span the life of the project, from installation of best management practice all the way through the completion of site restoration. As the party responsible for permit coverage and SWPPP implementation, how do you prepare and implement the SWPPP to maintain compliance over the lifespan of a complicated project involving multiple, distinct scopes of work? Who is responsible for installing which BMPs? Who is responsible for restoring which disturbed areas? What was in the bid and contract?
This presentation will provide guidance on how to manage and implement SWPPPs to maintain compliance with NPDES permits, with an emphasis on complicated, phased projects with multiple independent contractors involved. The presentation will include project examples where NPDES permit coverage was managed by an engineering firm serving as the either the Owner’s Engineer or as the Engineer, Procure, Construct (EPC) contractor. The engineering firm responsibilities in the examples that will be provided vary from SWPPP preparation only to overseeing the SWPPP from preparation to permit termination. Specifically, the presentation will include lessons learned and “Do’s and Don’ts” based on project experience managing SWPPPs and NPDES permits for a variety of infrastructure projects.
The overall goal of the presentation will be to provide strategies to avoid common pitfalls that can lead to non-compliance and potentially NPDES violations resulting from lack of planning and lack of understanding regarding SWPPP responsibilities. This presentation would be targeted towards a wide audience including consultants, contractors, developers, and regulators.