5 Common Mistakes to Avoid When Developing and Maintaining a SWPPP for Your Construction Site
Developing a SWPPP (Stormwater Pollution Prevention Plan) is a crucial step in ensuring that your construction site stays in compliance with regulations set forth by the EPA and state environmental agencies. A properly developed SWPPP will help you avoid environmental violations and fines, as well as prevent potential harm to surrounding bodies of water. However, there are several common mistakes that can be made during the SWPPP development process. Here are 5 of the most common mistakes to avoid:
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Relying on outdated data sources.
In Texas, stormwater prevention pollution plans need to include local waterways information. Specifically, the water quality and potential pollutants or impairments. Various state and local authorities offer waterway information for free, but it may not be up to date or appropriate for the site plan.
SWP3 developers can find stream impairment information on:
It is important to review the last update made to these portals. Stream impairment information is updated every 2 years. Often interactive map pages aren’t updated with the release of new data.
Developers should use the last APPROVED Texas Integrated Water Quality Report to determine if Stormwater from their construction will flow into a TMDL stream segment. TCEQ has made it clear that the Full Report, which includes category 4 and 5 impaired waterways should be used.
But before we embark on this enlightening journey, let’s make one thing clear: stormwater isn’t just about raindrops falling from the sky. It’s an intricate dance between land, pollution, and the fragile ecosystems of our rivers, streams, lakes, and coastal waters. It’s about protecting these invaluable resources through stormwater controls and best management practices (BMPs) that filter out pollutants and prevent contamination at the source. If there is a specific question, shortcut or resource that you need immediately I suggest reaching out to a stormwater consultant or the TCEQ Stormwater Group.
Not developing proper BMPS
Simply placing a single line of silt fence around a property is NOT appropriate for the majority of construction sites
When Erosion Control Plan Developers do not outline the appropriate amount and type of BMPs needed for a project this can lead to issues during the construction phase of a project.
Imagine you are a developer, you have outlined the cost for every part of your project from accruing land, hiring engineers to organizing you contractors only to be hit multiple times with erosion control bmp maintenance costs, fines for non-compliance or a stop work order because the BMPs designed for the site were not adequate.Not only will the project cost more in equipment, materials and labor there is potential for construction being delayed or subcontractors having to move on to different projects because of timelines.
Follow the requirements for Erosion Controls, Identify appropriate BMPs and appropriately plan for erosion control maintainance.
Be sure that all subcontractors are training in General Stormwater guidelines, and make them contractually obligated to repair any Stormwater BMPs that they impact.
Not taking weather into consideration
Developing a construction site during the rainy season will increase the cost of Stormwater BMPs and maintenance required for the site.
Developing in the summer increase the chances of dust and tracking from the construction site.
Developing in the winter will make is hard for a site to reach final stabilization and to close their NOT for the site.
Developing in the rainy season will increase site closures, sediment tracking from the site and impact the storage of all materials.
Not making it easy for staff to maintain the SWPPP book.
When developing a swppp book take into consideration where the book will be housed.
Will staff have access to a copier?
Can forms be made digital for easy access?
Have you easily provided contact information in case of emergencies, spills or adverse weather events?
Provide a flowchart or checklist to issue that all staff on the site can proper complete any reports or inspections required for the site. The SWPPP must be printed and maintained in English, but with a large amount of construction workers the speak Spanish as a first language, it would be appropriate to provide a guide in Spanish as well.
Not having a Qualifed Person on site.
Developers are required to have a Qualified Person maintain the SWPPP book to manage the stormwater controls for the site.
Often this is outsourced to s third party consultant that will swing by the site 1 or 2 a week. It is a good method to make sure a Stormwater regulation expert is maintaining the site but the General Contractor or appointed personnel should also be a Qualified Person.