How to Implement a SWPPP
If you are planning a development project that will involve the disturbance of more than one acre of land then you are required to prepare a Stormwater Pollution Prevention Plan (SWPPP) as part of the permitting process. At Hogan Land Services, we can help you prepare a SWPPP, as well as assist you throughout the submission and approval process. However, once your plan has been developed and approved, how do you go about implementing it? This guide is intended to walk you through some of the most common steps of SWPPP implementation.
First off, it’s important to remember that following your SWPPP to the letter is a crucial step for ensuring the compliance of your project overall. Any strategies, procedures, structures, or processes outlined in the approved SWPPP should be implemented before you start any construction. These implementations could include (but are not limited to) drainage systems, water detention/retention systems, erosion prevention systems, and sediment control systems. If any of these systems are outlined in your SWPPP, then installing them now should be a top priority.
Another pre-construction step you can take is to train your team. There will be a required pre-construction training session that will include the entire stormwater monitoring team; The Legally Responsible Party (LRP) or owner, QSP/QSP (The Hogan LS Team) and anyone else that will assist with the monitoring. In this training session we will cover all the requirements and answer any questions before construction begins. Your stormwater control systems will only work if your team members are aware of how to use them—or, in some cases, how not to get in their way. Also, the SWPPP will likely include requirements or recommendations for on-site behaviors or best practices. You need to make sure that your employees, subcontractors, and anyone else working on the project site are aware of these best practices and how to follow them. Some best practice behaviors may include:
- Install and continuously monitor the perimeter control
- Not clogging storm drains or dumping any materials into them
- Avoiding or preventing damage to stormwater/sediment/erosion control structures
- Using only designated entrances to the site
- Limiting foot or vehicle traffic near silt fences and other sediment control systems
- Knowing where certain materials or substances need to be collected or disposed of during the construction job (washout areas, etc)
- Establishing work areas and avoid sensitive areas (including slopes, stream banks, trees, etc.) that should remain undisturbed during the project
- Avoiding foot or vehicle traffic on seeded or otherwise stabilized areas
It’s essential to make sure that everyone on your team understands how important compliance with these best practices are. Failure to follow these practices can lead to violations of the entire SWPPP, which can, in turn, bring about fines or other severe problems for your development team. Setting up a system of expectations for compliance (and penalties for noncompliance) will show that everyone is expected to share the responsibility of SWPPP compliance. You should also identify a point of contact that team members can reach if a best practice is breached.
These requirements should not only be enforced for your employees, either. On the contrary, if you are bringing in subcontractors for your project, there is a contract agreement included in the SWPPP that requires those subcontractors to shoulder the responsibility of SWPPP too. Outline all the best practices in the contract, so there is no question about what compliance means.
Keep up with Inspection and Maintenance of Your SWPPP
As your project moves forward, make sure you are being vigilant about inspecting your project site and make sure that SWPPP compliance isn’t falling by the wayside. We will create a site map with the locations of key control structures, sensitive areas, and site entrances marked. Make sure these areas are being preserved and are in good condition. If there’s a problem—such as a clogged drain, for instance—fix it immediately.
You should also be inspecting areas where stormwater is being discharged from the site. Assess whether sediment and erosion control practices are working. Do a perimeter walk around the property to see how much sediment is making its way to adjacent properties, sidewalks, roadways, or other spots outside the site. Check silt fences to make sure they are in place and see if sediment needs to be removed. Look for unapproved construction site exits and reprimand your team members if you find any. Make sure trash is being disposed of in the correct areas. These steps will help you spot problems with your SWPPP before you stray too far into noncompliance
Finally, you need to make sure that your team is maintaining or improving control structures, when and where necessary. Replacing torn silt fences, removing sediment from overwhelmed silt fences, refreshing gravel and rock in designated entrances, and sweeping dirty streets or sidewalks near your project site are all smart habits to add to your ‘to do’ list. If you find that compliance obligations are being overlooked, or that control structures are being neglected, make a point of reinforcing best practices with your team.
At Hogan Land Services, we often work with property developers to design compliant SWPPP documents. Hogan Land Services can provide training sessions for onsite staff and provide storm water monitoring year monitoring and storm water sampling as required to maintained compliance.