Fall 2009 Got SWPPP? Fall 2009 Got SWPPP? California Construction General California Construction General Stormwater Permit – Reissued October 22, 2009 , Sandy Mathews Larry Walker Associates y
U Use all information with caution ll i f ti ith ti � CGP contains many � CGP contains many new requirements � Permit language is g g subject to interpretation � Support tools are under development
K Key Changes Ch � Risk Determination � Risk Determination � Minimum BMPs � Minimum BMPs � Permit Registration � Numerics (Effluent Documents Limits and Action Levels � Developing SWPPPs � Monitoring g � Implementing � Implementing SWPPPs � Reporting � REAPs s � Terminating a permit e at g a pe t
T Two part risk determination t i k d t i ti � Sediment discharge risk � Sediment discharge risk � Estimate of bare ground soil loss using factors from the Revised Universal Soil Loss Equation (RUSLE) A = (R) (K) (LS) (C) (P) � K and LS factors determined either through State provide GIS tools or site specific RUSLE calculation provide GIS tools or site specific RUSLE calculation � Receiving water risk � Drains to sediment sensitive water � Drains to sediment sensitive water � 303(d) listed or TMDL for sediment-related pollutant � Beneficial Uses of COLD, SPAWN, and MIGRATORY
Permit requirements are tied to risk levels i k l l � Minimum BMPs � Minimum BMPs � Monitoring/Reporting requirements � Compliance assessment � Compliance assessment � REAPs Traditional Project Traditional Project Sedim ent Risk Sedim ent Risk Risk Low Medium High Receiving Low Level 1 Level 2 Water Risk High Level 2 Level 3 Existing projects grandfathered for 2-years at Risk Level 1
R i f ll Rainfall erosivity waiver i it i � Operates as a zero risk level for small projects � Operates as a zero risk level for small projects � Small projects are those between 1 and < 5 acres � Waives permit requirements for projects with an R- p q p j factor of 5 or less � Based on USEPA R-factor waiver in the Phase II stormwater rule � Use the EPA R-factor calculator: htt http://cfpub.epa.gov/npdes/stormwater/LEW/lew // f b / d / t t /LEW/l Calculator.cfm
R-Factor t tool output l t t � Enter project � Enter project location � Address, or � Latitude and longitude � Enter planned construction period � Extremely sensitive E t l iti AN EROSIVITY INDEX VALUE OF 4.66 . to construction HAS BEEN DETERMINED FOR THE CONSTRUCTION PERIOD OF period changes period changes 06/01/2010 - 08/20/2010
Th The new NOI: PRDs NOI PRD � Submit Permit Registration Documents (PRDs) � Submit Permit Registration Documents (PRDs) prior to start of construction � NOI; Risk Determination; Site Map; SWPPP; Fee � Other documents if applicable � Legally Responsible Person must submit PRDs � PRDs are electronically filed into SMARTS SMARTS = Stormwater Multi-Application and Reporting System
D Developing SWPPPs l i SWPPP � SWPPPs must be developed by a Qualified � SWPPPs must be developed by a Qualified SWPPP Developer (QSD) � QSDs must have pre-requisite qualifications as of July 1, 2010, and by September 2, 2011, must complete State-sponsored or approved training � Only a QSD is authorized to make SWPPP Only a QSD is authorized to make SWPPP revisions and amendments � Need to have a QSD assigned throughout term of � Need to have a QSD assigned throughout term of project
I Implementing SWPPPs l ti SWPPP � Each project must assign a Qualified SWPPP � Each project must assign a Qualified SWPPP Practitioner (QSP) � From July 1, 2010, until September 2, 2011, any appropriately qualified individual may serve as a QSP � By September 2, 2011, QSPs must have the pre- requisite qualifications and have completed State requisite qualifications and have completed State- sponsored or approved training QSP- Person assigned � QSPs conduct or oversee QSPs conduct or oversee responsibility to ensure full ibilit t f ll � implementation of BMPs compliance with the permit and implementation of � inspections SWPPP � sampling � development of Rain Event Action Plans
C Can I be a QSD/QSP? I b QSD/QSP? QSDs QSDs QSPs QSPs � Registered CA Professional � Qualified as a QSD Engineer - Civil � Certified Inspection of � Certified Inspection of � Registered CA Professional Sediment and Erosion Geologist or Engineering Control (CISEC) Geologist � Certified Erosion, C tifi d E i � Registered CA Landscape Architect Sediment, Storm Water � Registered Professional Inspector (CESSWI) p ( ) Hydrologist (AIH) � Certified Professional � Erosion & Sediment Control (CPESC) (NICET) (CPESC), (NICET) � Storm Water Quality (CPSWQ)
R i Rain Event Action Plans E t A ti Pl � Rain Event Action � Rain Event Action Plans are required for Risk Levels 2 and 3 sites � Base on templates; p complete template for each rain event � QSP responsible for developing and i implementing REAP l ti REAP
Use NOAA forecasts for REAP t i trigger � Complete REAP template p p 48 hours in advance of a likely rain event � 50% or greater predicted � 50% or greater predicted chance of precipitation in project area � Only use NOAA forecasts � Only use NOAA forecasts http://www.srh.noaa.gov/forecast � Print out and retain forecast
Minimum BMPs are specified in 5 categories 5 t i � Minimum BMPs increase as � Good Site � Good Site Risk Level increases Management � Review the details of all “Housekeeping” minimum BMPs carefully i i BMP f ll � Non-stormwater Management � Erosion Control � Sediment Controls � Run-on and Runoff Controls
Two types of numeric limits assess runoff quality ff lit � Numeric Action Levels - Risk/Type 2 & 3 sites � Numeric Action Levels Risk/Type 2 & 3 sites � NALs assess BMP/SWPPP performance � Based on storm event average g � Turbidity 250 NTU � pH 6.5-8.5 pH units � Numeric Effluent Limitations - Risk/Type 3 sites N i Effl t Li it ti Ri k/T 3 it � Effluent limits are compliance numbers � Exceeding a NEL = permit violation � Exceeding a NEL = permit violation � Based on daily average � Turbidity 500 NTU � pH 6.0-9.0 pH units
Wh When don’t the numbers apply d ’t th b l � pH NEL and NAL only apply construction phases � pH NEL and NAL only apply construction phases when there is a “high risk of high pH discharge” � Utilities phase � Vertical build phase � Any other phase when materials are applied to the land that could alter pH of discharge l d th t ld lt H f di h � NEL Exemptions � St � Storms above designated compliance event, 5-year b d i t d li t 5 24-hour event � Run-on influenced by disaster (e.g. fire) y ( g )
NAL NAL and NEL exceedances d NEL d NAL Exceedance NEL Exceedance Report data within 10 � Report data and submit • days NEL violation report within 24 hours of ithi 24 h f Evaluate BMPs and • identification SWPPP � Identify corrective actions y Implement corrective Implement corrective • • � Augment monitoring actions program Document evaluation and • � May trigger fines M t i fi actions Revise SWPPP • S b Submit NAL report if it NAL t if • requested
Visual monitoring remains i important for all projects t t f ll j t � BMP inspections � BMP inspections � Weekly � Daily during rain events y g � Site visual monitoring � Pre-storm � Post-storm � Quarterly non-stormwater inspections
Water quality monitoring by risk l level – 1 and 2 l 1 d 2 Risk Level 1 Risk Level 1 Risk Level 2 Risk Level 2 � Non-visible pollutant � Non-visible pollutant monitoring as necessary g y monitoring as necessary g y � Stormwater discharge monitoring for pH* and turbidity; other pollutants turbidity; other pollutants required by RWQCB � Non-stormwater * Only required during construction Only required during construction discharges from site phases with high risk of high pH discharge � Contained rainwater when discharged when discharged
Water quality monitoring by risk level – 3 l l 3 Risk Level 3 Risk Level 3 Risk Level 3 (Conditional) Risk Level 3 (Conditional) � Non-visible pollutant � Projects greater than 30 monitoring as necessary acres with direct � Stormwater discharge discharge add monitoring for pH* and � Bioassessment monitoring turbidity; other pollutants required by RWQCB i d b RWQCB � Non-stormwater discharges from site * Only required during construction � Contained rainwater when phases with high risk of high pH discharge discharged � Report all field data within 5 days of storm event
Water quality monitoring for risk l level 3 projects that exceed NEL l 3 j t th t d NEL � Projects exceeding NEL must augment � Projects exceeding NEL must augment monitoring program � Exceed turbidity NEL y � Add SSC to discharge monitoring SSC = Suspended � Start receiving water* monitoring for Sediment Concentration SSC and Turbidity � Exceed pH NEL � Start receiving water* monitoring for pH *Only required if the site has a direct Only required if the site has a direct discharge to a receiving water
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