BY ROSS PIPPEN, CPESC, CISEC, QSD/P, QISP
In managing a construction site, sediment and erosion control and storm water pollution prevention are all critical parts of the whole. At times, the coordination between Construction General Permit (CGP) consultants and construction managers can be contentious. In order for a CGP compliance program to be effective, there must be frequent and efficient communication. Here are some tips to ensure smooth project progress while maintaining compliance with the CGP.
- Storm water pollution prevention plan (SWPPP) developers and inspectors should ask questions to ensure a complete understanding of the project. They should engage with the site superintendents and project managers. A complete understanding of the project enables the SWPPP developer to write better plans and inspectors to provide more reasonable recommendations.
- Inspectors should speak the construction lingo. This is similar to learning new languages in foreign places, where learning the language and culture can go a long way. There’s a big difference between an inspector who says, “The tractor is leaking oil by the cable in the dirt,” versus “The skid steer is leaking oil by the down guy.” Furthermore, there’s a big difference between paint in the flow line and concrete hardener on a fresh curb.
One case-in point: An inspector called a foreman to discuss final stabilization around “the green box.” The foreman didn’t understand, and on his tight schedule he was not responsive. When the inspector called the foreman back and asked about the pedestal near the transformer, the issue was quickly resolved. Inspectors are more effective when they use the right lingo. Good inspectors should have construction experience to ensure clear and concise communication and understanding on both sides.
3. Inspectors should think ahead. A lot can happen between inspections on an active construction site. An area that was just dirt on Monday might have a storm drain inlet on Tuesday. This creates the potential for an inlet to remain unprotected until the next scheduled inspection. An inspector might see it during or after a storm, but the inlet protection would be too late. Inspectors should ask questions, such as when will the curb and gutter be installed? When will the gutter be connected to external streets? When are wet utilities scheduled? When will inlets be installed? When will the road profile be compacted and at final grade? This information is necessary, as each step of construction can require different Best Management Practices (BMPs). Effective inspectors will understand the project progression and communicate with the site superintendent to ensure BMPs are proactive.
4. Both the inspector and construction manager must understand that the SWPPP is a living document. The developer of the SWPPP may have never set foot on a construction site, and it is very likely that BMPs will need to be changed, removed or altered. The SWPPP should be adjusted to fit the construction site, not the other way around. Good inspectors will evaluate the SWPPP plan often. For example, does the plan call for silt fence in an area that exceeds the maximum drainage area? Maybe plans changed and the grade was shifted. A couple of laps by a scraper and the drainage area to your silt fence can increase drastically.
Learning and navigating the regulations and available BMPs is only half the battle. The inspector must also learn and understand construction. The goal is to keep pollutants from discharging off-site. Working together with an inspector who has construction experience and the right foresight can help to achieve the goal. Some of the tips above will help the team do so.
Ross Pippen, CPESC, CISEC, QSD/P, QISP is a water resources scientist for ALTA Environmental. Ross is an experienced SWPPP developer, inspector and CGP expert. He can be reached at Ross.Pippen@altaenviron.com.