Pollution Control For Field Office Construction Sites Pollution

Pollution Control: For Field Office Construction Sites

Pollution Control during Construction Objectives: l Provide awareness of NRCS Policy l Provide history of pollution control l Review legal requirements l Become familiar with typical pollution control installations for a conservation practice

NEM and National Pollutant Discharge Elimination System (NPDES) l NRCS Policy – NEM Part 520 l NPDES Permit Requirements - Stormwater runoff from construction sites Use of Best Management Practices (BMP) to manage runoff

Policy (NEM Part 520 Subpart A) • NRCS is to minimize erosion and sediment in construction operations carried out under all programs. • Sediment control measures are included in all work where: – NRCS provides engineering services – NRCS financial assistance is provided • Engineering done by NRCS for individuals and groups is to include satisfactory sediment control measures.

Regulations - NPDES • 1972 Federal Water Pollution Control Act (Clean Water Act – Gave EPA authority for pollution control programs) • Point sources • 1987 Clean Water Act Amendments • Defined Stormwater as a point source • Phased approach

Examples of Point Source Pollution Fire on the Cuyahoga River Jan 8, 1969 Oil covered fishermen on Lake Erie May, 1976

Regulations - NPDES • Phase I of the National Pollution Discharge Elimination System (NPDES) was enacted by EPA in November 1990. Phase I addressed “large construction activities” that disturb areas that are greater than or equal to 5 acres in size. • NPDES Phase II was enacted in December 1999 to include “small construction activities” that disturb areas that are greater than or equal to 1 acre but less than 5 acres in size.

NPDES – Agriculture Exclusion 40 CFR 122. 3 NPDES Permit not required for non-pointsource agricultural activities including: • • • Cultivated crops Orchards Pastures Range lands Forest lands

NPDES and/or State Permit Requirements All permits, regardless of permitting authority, must included requirements for: • Best management practices (BMPs), • Control of specific pollutants, • Development and implementation of a Stormwater Pollution Prevention Plan (SWPPP), • Submittal of a site plan for review that incorporates consideration of water quality impact.

Permittee or Permittees Each operator must obtain a permit. • An operator has control of the plans and specifications • An operator has day to day operational control of those activities at the project necessary to ensure compliance with the SWPPP

Permittee or Permittees • The owner may be the sole permittee • The contractor may be the sole permittee • The owner and the contractor may be joint permittees

What is contained in the SWPPP? • Description of BMP’s Structural and non-structural • Sedimentation basins required • Site layout plan showing location of BMP’s and sedimentation basins • Additional site management BMP’s • Site inspections requirements

Non-Structural BMP’s • Temporary and final seeding • Mulching and/or tackifiers • Preserving and protecting existing vegetation and trees along drainage courses • Stabilized site entrances/exits

Structural BMP’s • • Silt fences (geotextile or straw bales) Earthen diversions Rock check dams Sediment traps Sediment basins Drainage swales Storm drain inlet and outlet protection

SWPPP and NRCS Inspector • SWPPP should be discussed at pre-construction meeting and agree on parties duties • All parties maintain a copy of SWPPP • NRCS should explain BMP requirements • Structural BMP’s installed before construction activity or as part of activity – notify permittee if not installed

SWPPP and NRCS Inspector (continued) • Locate BMP’s per site plan as needed. Recognize need for additional locations based on site conditions • Assist with site inspections if requested or conduct if authorized by QAP • Document installations and inspections in narrative reports

Review Friendly Farmer GSS SWPPP Handout § SWPPP narrative § Construction specifications describing pollution control and/or final stabilization § Site Plan § BMP installation details § Inspection Checklist