The importance of combating environmental pollution is an ongoing concern among builders in the construction industry.
According to one report, nearly 40% of all drinking water pollution can be traced back to construction-related activities.
Construction sites are notorious gluts for water consumption, consuming extensive amounts of water to suppress dust, hydrate workers, and clean equipment. While that is a significant contributor to the amount of pollution generated from these sites, it’s actually the water runoff from rain that mixes with toxic materials like sediment, debris, or paint that leads to rampant pollution of water streams.
As cities like Jackson, Mississippi, and Flint, Michigan, make headlines for their polluted drinking water, environmental agencies nationwide have begun cracking down on stormwater runoff.
One mechanism to accomplish such a task has been using stormwater prevention plans (SWPPPs) designed to limit the number of pollutants that run off into public water supplies during construction-related activity.
We’ll discuss the logistics of developing an SWPPP in this article, including several SWPPP requirements that you will need to follow by law to acquire proper permitting to begin construction activity.
Stormwater Prevention: The Importance of the SWPPP
A stormwater prevention plan or SWPPP is a site-specific document designed to reduce the amount of stormwater pollution generated from construction activity.
The federal government requires that anyone who applies for a National Pollutant Discharge Elimination System (NPDES) permit–a permit allowing work zones to discharge runoff into public water–submit an SWPPP. The SWPPP outlines how your construction zone will reduce stormwater pollution.
The SWPPP also serves as a master document used for training, documentation, and recording purposes to remain legally compliant.
Who Is Required to Apply for an NPDES Permit?
While SWPPPs are required for an NPDES permit, there are special instances where an NPDES permit may or may not be required.
Instances Where an NPDES Permit Is Required
- Any site that discharges from a point source into public waters of the United States.
- Construction areas over an acre in size that disturb the land (i.e., grading, excavating). In this case, a construction general permit will be required.
Instances Where an NPDES Permit Is Not Required*
- Construction sites that don’t disturb land or discharge from a point source (ex., remodeling)
- Construction sites that discharge into municipal sewer systems (varies by location)*.
- Instances when special waivers are awarded.
A construction site manager will be required to develop the SWPPP and apply for an NPDES permit. Construction site managers unfamiliar with SWPPP terminology can work with a qualified stormwater practitioner permitted by their state or the federal government.
20 Essential SWPPP Requirements
The process of developing a stormwater prevention plan is very thorough. Here are twenty essential SWPPP requirements you will need to complete to construct a fully operational plan.
1. Cover/Title Page
Submit a cover letter and title page with important information, such as:
- Site location
- Construction start date and anticipated end date
- Who the SWPPP was prepared for (permitting agency)
- Who the SWPPP was prepared by (qualified personnel)
- Construction site contact information
2. Contact Information
A list of contact information for the construction site manager, your stormwater management team, all subcontractors, and a 24-hour emergency contact will be required.
3. Pollution Prevention Team
Members of your crew responsible for implementing SWPPP control measures will need to be listed and outlined as part of your pollution prevention team. Ensure all team members are properly and continuously trained.
4. Site Description
One of the first things you’ll need to list in your SWPPP is a thorough description of the site. Since each description is specific to your location, you will need to include a variety of characteristics, including:
- Total site size
- General topographic features
- Soil Types
- List of water sources
- Size of impervious area located on the site
- Description of local flora and fauna
- Identify the type of land (e.g., wetland, desert, forest, etc.)
Over time, you will also collect additional data, such as rainfall data and the runoff coefficient after construction activities have ensued.
5. A Topographical Site Map
Add a visual sitemap as part of your description, outlining all slopes and grading employed on the site. This will give a better understanding of vulnerable areas where active controls must be taken to divert or slow the spread of stormwater runoff.
6. Construction Activity Description:
Next, you will need to describe the type of construction activity that will be occurring. Some key characteristics include:
- The type of project (e.g., building a mall, residential housing, etc.)
- Estimated size of the disturbed area
- Types of discharge (e.g., stormwater runoff and other types of waste)
- Materials used
- Construction equipment employed
- Phases to be implemented (this will be listed as a table)
7. List of Discharge Sources
Your SWPPP will require you to submit a list of discharge points and the location of the first waters they discharge to. You will also have to list all “authorized non-stormwater discharges, such as water from fire hydrants or portable bathrooms.
8. List of Pollutant Sources
Listing the amount of potential pollutant sources may require careful work with a qualified consultant. Generally, you should include pollutants from the following sources that may mix with stormwater as it gets discharged into public water sources.
- Hazardous materials
- Solid waste
- Septic waste
- Landscaping, clearing, and grading operations
- Dewatering operations
- Debris from demolition
- Paint and cleaning chemicals
- Vehicle storage and maintenance
- Vehicle transport, fueling, and cleaning operations
9. BMP Control Measures
Next, you will need to identify active steps your worksite will take to eliminate or reduce the amount of pollutants in stormwater runoff. In the industry, these are considered best management practices and are typically divided into erosion and sediment control.
Your SWPPP will require you to list all actions taken to reduce the risk of stormwater pollution, such as dewatering practices, slope grading controls, and much more. We’ve listed some examples of BMPs below for a better understanding of what will be required under your SWPPP.
Examples of Erosion Control BMPS
- Erosion control blankets
- Ripraps
- Slope grading
- Mulching
Examples of Sediment Control BMPs
- Sediment basins
- Storm drain inlet protection
- Silt fencing
- Riparian buffers
10. Site Stabilization Plans
Your SWPPP will require you to list all active steps to stabilize a worksite after construction has ceased, including steps to restore vegetation and treat any polluted water in sediment basins.
11. Material Handling
Material storage and handling of construction materials and equipment is incredibly important in reducing the risk of pollution and required by your SWPPP. Create a list of standard procedures, including designated zones where equipment will be stored and inspection procedures before handling equipment to reduce your risk of pollution and environmental damage.
12. Record-Keeping Reports
All control measures, training material, and amendments to your SWPPP must be meticulously recorded.
We suggest having someone on staff specifically designated to keep track of all relevant SWPPP information throughout a project.
13. Training Materials and Procedures
Create proper training protocols to educate crew members on the dangers of sedimentation and stormwater pollution. Then create repeatable training processes for all new and existing employees to continue their education and always follow best practices.
14. Maintenance and Inspection Procedures
Site operators should work with consultants to inspect and monitor equipment throughout the scope of a project to ensure all BMPs are working properly. Since stormwater runoff can wear away on equipment like fencing and electrical equipment, it’s critical that you perform an inspection at least once a week or after heavy rainfall to detect any damage.
15. Proposed Plan Amendments (Ongoing)
SWPPPs are a living document subject to continuous changes and amendments. Record any proposed amendments to your SWPPP that may evolve due to new equipment or failed procedures that are not yielding the results you intended.
16. Turbidity Monitoring
Federal law requires you to monitor the turbidity of nearby water sources (i.e., how dirty or cloudy they are) to ensure that they are free of sediment runoff and that you are not damaging nearby ecosystems.
17. Accident and Spill Reaction Procedures
In the event of a catastrophic accident at your worksite, you will need to be able to mobilize response crews quickly to reduce any fallout or damage. Ensure you have proper procedures in place and that your staff is properly trained to respond to any emergency situations.
18. Stipulations for Subcontractors
Special guidelines should be drafted for subcontractors who enter a worksite to ensure they follow the same rules as your full-time employees. This will reduce your legal liability and ensure proper, universal SWPPP compliance.
19. Compliance with Federal Laws
Your SWPPP will require documentation outlining your compliance with other federal laws, such as the Endangered Species Act.
20. SWPPP Certification
Finally, you will need to retain a copy of your SWPPP certification for any “qualified personnel,” which helps you draft your SWPPP to submit with your application.
Tips for Creating an Effective SWPPP Plan
Now that you have a basic understanding of each SWPPP requirement, we’ve drafted a few tips to help you draft your next SWPPP.
Be As Thorough As Possible
Get as granular as possible when describing your worksite and all potential pollutants to ensure you are not missing any valuable information. Likewise, the more thorough you are with training procedures and BMPs, the better your SWPPP will be executed.
Schedule Frequent Inspections
While many worksites opt for a rotating schedule of biweekly inspections, we highly recommend conducting routine weekly inspections, especially after extreme weather events.
Use Natural BMPs to Your Advantage
Natural vegetation helps to preserve the topsoil and reduce the flow of stormwater runoff, especially on slopes or grades. It’s one reason many professionals recommend applying mulch to highly pitched slopes where stormwater velocity accelerates, leaving the topsoil vulnerable to erosion.
Use natural vegetation to your advantage by redirecting stormwater through it. Also, be sure to revegetate any disturbed areas to help accelerate your cleanup process.
Prioritize Erosion Control
By preventing erosion control, you can also prevent sediment runoff. Since sedimentation occurs after significant erosion has occurred, reducing the amount of topsoil erosion will save you from having to invest in more expensive sediment control mechanisms.
Work with a Qualified Consultant
Finally, you will need to work with a qualified environmental consultant or “qualified personnel” to help you draft your SWPPP.
At Path Light Pro, we have decades of experience helping companies draft SWPPP documents and comply with local and federal regulations. Contact us today to get started on your SWPPP and to learn more about stormwater prevention.