Developing Your Stormwater
Pollution Prevention Plan
A Guide for Construction Sites
EPA-833-R-06-004
 May 2007


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   Developing Your  Stormwater Pollution  Prevention  Plan
                                 A Guide for Construction Sites

                                              Who?
  Construction site operators (generally, the person who has operational control over construction plans and/or
     the person who has day-to-day supervision and control of activities occurring at the construction site)
                                            Where?
               Construction sites required to comply with stormwater discharge requirements
                                             What?
             A guide to help you develop a good Stormwater Pollution Prevention Plan (SWPPP)
                                              Why?
  Stormwater runoff from construction sites can cause significant harm to our rivers,  lakes, and coastal waters
   A SWPPP is required (by your construction general permit) and will help you  prevent stormwater pollution
                     A SWPPP is more than just a sediment and erosion control plan.
     It describes all the construction site operator's activities to prevent stormwater contamination, control
            sedimentation and erosion, and comply with the requirements of the Clean Water Act
Purpose of this Guidance Document
     This document provides guidance to construction site operators that need to prepare a SWPPP in order to
receive NPDES permit coverage  for their stormwater discharges. The Clean Water Act provisions, EPA regulations
and EPA's Construction General  Permit described in this document contain legally binding requirements. This
document does not substitute for those provisions,  regulations or permit, nor is it a regulation or permit itself. It also
does not substitute for requirements under State law or construction general permits issued by States. It does not
impose legally-binding requirements on EPA, States, or the regulated community, and may not apply to a  particular
situation based upon the circumstances. EPA and State decisionmakers retain the discretion to adopt approaches
on a case-by-case basis that differ from this guidance where appropriate.  Any decisions regarding a particular
construction site will be made based on the applicable statutes, regulations  and/or permit terms. Therefore,  interested
parties are free to raise questions and  objections about the appropriateness  of the application of this guidance to
a particular situation, and EPA—or the applicable NPDES permitting authority—will  consider whether or not the
recommendations or interpretations  in the guidance are appropriate in that situation  based on  the law and regulations.
     This guidance document occasionally uses language describing mandatory requirements for construction
site operators and those covered by  a general permit for stormwater discharges from  such sites. This language
is generally intended to reflect requirements applicable where EPA is the NPDES permitting authority. Although
requirements in jurisdictions where EPA is  not the permitting authority may  resemble these requirements, the reader
should not assume that this guidance  accurately describes those requirements. Rather, the reader should  consult
the applicable regulations and any applicable NPDES permit.

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Contents
Chapter 1:  Introduction	1
    A. Why Should You Use this Guide?	1
    B. What Is Stormwater Runoff and What Are Its Impacts?	2
    C. How Can Construction Site Operators Prevent Stormwater Pollution?	3
Chapter 2:  Getting Started	4
    A. What Are the Federal Requirements for Stormwater Runoff from Construction Sites?	4
    B. Who Is Required to Get NPDES Permit Coverage?	6
    C. What Elements Are Required in a SWPPP?	8
    D. SWPPP Roles and Responsibilities	8
    E. Common SWPPP Objectives	9
Chapter 3:  SWPPP Development—Site Assessment and Planning	10
    A. Assess Your Site and Proposed Project	10
    B. Identify Approaches to Protect Natural Resources	14
    C. Develop Site Maps	15
Chapter 4:  SWPPP Development—Selecting Erosion and Sediment Control BMPs	17
Chapter 5:  SWPPP Development—Selecting Good Housekeeping BMPs	24
Chapter 6:  SWPPP Development—Inspections, Maintenance, and Recordkeeping	28
    A. Describe Your Plans and Procedures for Inspecting BMPs  	28
    B. BMP Maintenance	30
    C. Recordkeeping	30
Chapter 7:  Certification and Notification	31
    A. Certification	31
    B. Notification	32
Chapter 8:  SWPPP Implementation	33
    A. Train Your Staff and Subcontractors	33
    B. Ensure Responsibility—Subcontractor Agreements	34
    C. Implement Your SWPPP Before Construction Starts	34
    D. Conduct Inspections and Maintain BMPs	34
    E. Update and Evaluate Your SWPPP	36
Chapter 9:  Final Stabilization and Permit Termination	37
    A. Final Stabilization  	37
    B. Permit Termination  	38
    C. Record Retention	39
References	40
Appendices
    Appendix A - SWPPP Template (available at www.epa.gov/npdes/swpppguide)	41
    Appendix B - Inspection Report (available at www.epa.gov/npdes/swpppguide)	42
    Appendix C - Calculating the Runoff Coefficient	43
    Appendix D - Resources List	45
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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What is a Stormwater Pollution Prevention Plan (SWPPP)?
A SWPPP may be called many things. Your state may use terms like:
     • Construction Best Practices Plan
     • Sediment and Stormwater Plan
     • Erosion, Sediment, and Pollution Prevention Plan
     • Construction Site Best Management Practices Plan
     • Erosion Control Plan and Best Management Practices
     • Best Management Practices Plan
     • Erosion and Sediment Control Plan

Regardless of the title used in your state, these documents—and the
Stormwater permits that require them—tend to have many common
elements. This guide is intended to help you develop a better SWPPP for your
construction site.
                                                              Example sketch identifying various points to
                                                              address in the SWPPP.
             How to  Use This  Guide
               This guide was developed as a helpful reference guide for construction site operators across
               the country. We have tried to accommodate the wide range of knowledge and experience
               about Stormwater pollution prevention that currently exists among operators—from novice to
               expert.

                 •  If you are relatively new to managing Stormwater at a construction site, you will probably
                    want to read this entire  guide.

                 •  If you are very experienced and familiar with the requirements in your state, this guide
                    may help you brush up on certain requirements or provide you with ideas to improve
                    your SWPPP. You might want to review the table of contents and skip around. Be sure to
                    take a look at the SWPPP template (Appendix A) to see if you can make improvements in
                    the way you develop and maintain your SWPPP.

               This guide is written in a general format and can be used at most construction sites in any
               state, territory, or in Indian country. The document assumes that you will obtain discharge
               authorization under an appropriate  National Pollutant Discharge Elimination System (NPDES]
               construction general permit and use both the permit and this guidance to assist in developing
               your SWPPP. In this guide, we make some references to the U.S. Environmental Protection
               Agency's Construction General Permit for illustrative purposes. You should always consult
               your applicable NPDES permit for the exact requirements that apply to you.

               Remember that you are developing your SWPPP for both your use and for review by the
               regulatory agencies responsible for overseeing your Stormwater controls. As such,  one of your
               goals in developing your SWPPP should be to present the information in a way that clearly
               demonstrates that it meets all the requirements of your NPDES permit.

               You can obtain an electronic copy of this guide (PDF format), the SWPPP template, and
               inspection form (in Microsoft Word) at www.epa.gov/npdes/swpppguide
                                                 Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Chapter L  Introduction
A. Why Should You Use this Guide?
If you are responsible for erosion and sediment control and stormwater management
at a permitted construction site, then this guide may be useful to you. This guide is
designed to walk you through the steps for developing and implementing an effective
stormwater pollution prevention plan (SWPPP). The basic outline of the guide is
presented below:
                                                                 This chapter provides
                                                                 an orientation to this
                                                                 guide and its contents
                                                                 and describes why
                                                                 stormwater controls
                                                                 at construction sites
                                                                 are necessary.
                             SWPPP Development
 Chapter 2
   Getting
   started
V
 Chapter 3
    Site
 assessment
and planning
 Chapter 4
  Selecting
 erosion and
  sediment
control BMPs
 Chapter 5
  Selecting
   good
housekeeping
   BMPs
 Chapter 6
 Inspections,
maintenance,
    and
recordkeeping
                                                           Appendix A
                                                          Tools to assist in
                                                         writing your SWPPP
                                                   SWPPP Implementation
                                                            Chapter 7
                                                      Clarification & Notification
                                  SWPPP Update
    Figure 1. SWPPP Process
                                           Chapter 8  %
                                             SWPPP
                                         Implementation ^
                                           Chapter 9
                                       Final Stabilization and
                                    V   Permit Termination
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Take a Closer Look..
What is a SWPPP?
A SWPPP is a site-specific, written document that:
  • Identifies potential sources of stormwater pollution at the construction site

  • Describes practices to reduce pollutants in stormwater discharges from the
    construction site. Reduction of pollutants is often achieved by controlling the volume
    of stormwater runoff (e.g., taking steps to allow stormwater to infiltrate into the soil).

  • Identifies procedures the operator will implement to comply with the terms and
    conditions of a construction general permit
                                                                             What does this mean to me?
                                                                             Failure to implement your SWPPP
                                                                             could result in significant fines
                                                                             from EPA or a state environmental
                                                                             agency. Therefore, it is important
                                                                             that you develop your SWPPP to
                                                                             address the specific conditions
                                                                             at your site, fully implement it,
                                                                             and keep it up-to-date to reflect
                                                                             changes at your site.
               B. What Is Stormwater Runoff and What
                  Are Its Impacts?
               Stormwater runoff is rain or snowmelt that
               flows over land and does not percolate into the
               soil. Stormwater runoff occurs naturally, in
               small amounts, from almost any type of land
               surface, especially during larger storm events.
                                             Impervious
                                             surfaces, such
                                             as buildings,
                                             homes, roads,
                                             sidewalks,
                                             and parking
   SWPPP Tip!
A SWPPP can have different names
A SWPPP may also be called a "construction
best practices plan," "sediment and stormwater
plan," "erosion, sedimentation, and pollution
prevention plan," or similar term. The SWPPP
(or similarly named plan) is generally required
to comply with EPA's or the state's stormwater
construction general permit.
                                             lots, can
                                             significantly
                                             alter the
                                             natural
                                             hydrology of
                                             the land by
               increasing the volume, velocity, and
               temperature of runoff and by decreasing its
               infiltration capacity. Increasing the volume
               and velocity of stormwater runoff can cause
               severe stream bank erosion,  flooding, and
               degrade the biological habitat of these streams.
               Reducing infiltration can lower ground water
               levels and affect drinking water supplies.

               In addition, as stormwater runoff moves
               across surfaces, it picks up trash, debris,
               and pollutants such as sediment, oil and
               grease, pesticides and other toxics. Changes
               in ambient water temperature,  sediment,
               and pollutants from stormwater runoff
               can be detrimental to aquatic life, wildlife,
               habitat, and human health. Soil exposed by
               construction activities is especially vulnerable
               to erosion. Runoff from an unstabilized
               construction site can result in the loss of
               approximately  35-45  tons of sediment per
               acre each year  (ASCE and WFF, 1992). Even
               during a short period of time, construction
               sites can contribute more sediment to streams
               than would be  deposited naturally over several
decades. Excess sediment can cloud the water
reducing the amount of sunlight reaching
aquatic plants, clog fish gills, smother aquatic
habitat and spawning areas, and impede
navigation in our waterways.

The primary stormwater pollutant at a
construction site is sediment. To control
erosion at a construction site, it is important
to understand the different types  of erosion
that can occur. Erosion begins when raindrops
break down the soil structure and dislodge
soil particles. Runoff carrying the soil particles
becomes sheet erosion which eventually forms
smaller rills and larger gullies. The best way
to stop erosion is to keep the soil  in place
through vegetation, erosion control  blankets,
or other methods that prevent the soil from
becoming dislodged during rain events.

The erosion process is typically influenced
by climate,  topography, soils, and vegetative
cover. Understanding how these factors influ-
ence erosion will help you select and design
appropriate  controls to  minimize erosion from
your construction site.
                                                                 Typical erosion rates
                                                                 land-based activities
                                                                 (soil loss from various land areas
                                                                 in tons per acre per year)
                                                                                                Bare Soil
                                                                                              (e.g., unmanaged
                                                                                              construction sites)
                                                                Figure 2. Typical erosion rates from land-based activities.
                                                                (Dunne, T. and L. Leopold, 1978; NRCS, 2000; NRCS,
                                                                2006; ASCE and WEF, 1992)
                                                     Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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                                              Figure 3. Types of erosion.

                                              Raindrop erosion
                                              Dislodging of soil particles by raindrops
                                              Sheet erosion
                                              The uniform removal of soil without the development of visible
                                              water channels
                                              Rill erosion
                                              So/7 removal through the formation of concentrated runoff that
                                              creates many small channels
                                              Gully erosion
                                              The result of highly concentrated runoff that cuts down into the
                                              soil along the line of flow
                                              Streambank erosion
                                              Flowing water that erodes unstable streambanks
Climate. The frequency, intensity, and
duration of rainfall are the principal factors
influencing erosion from a construction site.
Know the weather patterns in your area and, if
possible, plan your soil disturbance activities
for periods of historically lower rainfall.

Topography. The longer and steeper a
slope, the greater the potential there is  for
erosion from that slope. Use practices such
as diversions or fiber rolls to break up long
slopes. Consider minimizing soil disturbance
activities on steeper slopes.

Soils. Soil type can also impact erosion. Soil
texture, structure, organic matter content,
compaction, and permeability can all
influence erosion rates.

Vegetative cover. Vegetative cover provides
a number of critical benefits in preventing
erosion—it absorbs the energy of raindrops,
slows velocity of runoff, increases infiltration,
and helps bind the soil. Soil erosion can be
greatly reduced by maximizing vegetative
cover at a construction site.

C. How Can Construction Site Operators
   Prevent Stormwater Pollution?
An effective SWPPP is the key! If sediment
and erosion controls and good housekeeping
practices are not followed, construction activity
can result in the discharge of significant
amounts of sediment and other pollutants.
The term Best Management Practices or BMPs
is often used to describe the controls and
activities used to prevent stormwater pollution.
    SWPPP Tipi
  Erosion versus Sedimentation
  Erosion is the process by which the land surface
  is worn away by the action of water or wind.
  Sedimentation is the movement and settling out
  of suspension of soil particles. It is usually easier
  and less expensive to prevent erosion than it is to
  control sediment from leaving a construction site.
BMPs can be divided into two categories—
structural and non-structural BMPs. Structural
BMPs include silt fences, sedimentation ponds,
erosion control blankets, and temporary or
permanent seeding, while non-structural
BMPs include picking up trash and debris,
sweeping up nearby sidewalks and streets,
maintaining equipment, and training site staff
on erosion and sediment control practices.
In this document, the term "BMPs" is used
broadly and includes both structural and non-
structural controls and practices.

A SWPPP is more than just a sediment
and erosion control plan.  Most SWPPPs
are written documents that describe the
pollution prevention practices and activities
that will be implemented on the site. It
includes descriptions of the site and of each
major phase of the planned activity, the
roles and responsibilities of contractors and
subcontractors, and the inspection schedules
and logs. It is also a place to document
changes and modifications to the  construction
plans and associated stormwater pollution
prevention activities.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Chapter  2:  Getting  Started
A. What Are the Federal Requirements for Stormwater Runoff from
   Construction Sites?
The Clean Water Act and associated federal regulations (Title 40 of the Code of Federal
Regulations [CFR] 123.25(a)(9), 122.26(a), 122.26(b)(14)(x) and 122.26(b)(15)) require
nearly all construction site operators engaged in clearing, grading, and excavating
activities that disturb one acre or more, including smaller sites in a larger common
plan of development or sale, to obtain coverage under a National Pollutant Discharge
Elimination System (NPDES) permit for their stormwater discharges. Under the
NPDES program, the U.S. Environmental  Protection Agency (EPA)  can authorize
states to implement the federal requirements and issue stormwater permits. Today,
most states are authorized to implement the NPDES program and issue their own
permits for stormwater discharges associated with construction activities.
    SWPPP Tip!
  Don't forget about "common plans of
  development or sale"
  A common plan of development or sale includes
  larger-scale plans for land development to be
  carried out by one or more entities. Examples
  include housing developments and subdivisions,
  industrial parks, and commercial developments.

  EPA has described this term in the fact sheet
  accompanying its Construction General Permit
  as including: any announcement or piece of
  documentation (including a sign, public notice
  or hearing, sales pitch, advertisement, drawing,
  permit application, zoning request, computer
  design, etc.), or physical demarcation (including
  boundary signs,  lot stakes, surveyor markings,
  etc.) indicating construction activities may occur
  on a specific plot. Each permitting authority may
  review documentation to determine if common
  plan requirements apply.
  Take a Closer Look..
Each state (or EPA, in the case
of states that are not authorized]
issues one or more NPDES
construction general permits. These
permits, generally, can be thought
of as umbrella permits that cover all
stormwater discharges associated
with construction activity in a
given state for a designated time
period,  usually 5 years. Operators
of individual constructions sites
then apply for coverage under this
permit. Before applying for permit
coverage, you should read and
understand all the provisions of the
appropriate construction general
permit and develop a SWPPP.
Because authorized states develop
their own NPDES requirements,
you should carefully read your
state's construction general
permit  and follow the specific
instructions it contains.
This chapter
describes some of
the basic things you'll
want to determine
(Do you need permit
coverage? What
permit applies to
you?), as well as some
of the materials and
information you may
need to develop your
SWPPP. Collecting this
information before
you start will help you
develop your SWPPP
more efficiently. Keep
in mind that you may
also need to gather
this information and
develop your SWPPP
before you complete
your Notice of Intent
(NOD and file for
permit coverage (note
that filing an NOI is
not discussed until
Chapter 7).
  EPA Permits vs. State-Issued Permits
  At the time of publication, EPA was the NPDES permitting authority in
  Massachusetts, New Hampshire, New Mexico, Idaho, Alaska, the District
  of Columbia, Puerto Rico, the U.S. territories (except the Virgin  Islands),
  most Indian country lands, and for federal facilities in four states. For an
  up-to-date list of NPDES permitting authorities, visit www.epa.gov/npdes/
  stormwater/construction or www.cicacenter.org/swrl.html
                    What does this mean to me?
                    Because EPA and state-issued permits can
                    be different, you should make sure you read
                    and apply for the correct permit. Use the
                    links on either of the web sites listed to the
                    left to determine which agency issues NPDES
                    permits where your construction activity will
                    occur.
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Most construction general permits contain
similar elements:
•  Applicability—describes the geographic
   area covered and who is eligible to apply
•  Authorization—describes the types
   of stormwater (and non-stormwater]
   discharges that  are covered
•  SWPPP requirements—outlines the
   elements that should to be addressed to
   prevent the contamination of stormwater
   runoff leaving the construction site
•  Application—includes instructions for
   obtaining permit coverage, usually by filing
   an application or Notice of Intent (NOI) form
•  Implementation—BMP installation,
   inspection, and  maintenance requirements
•  Other requirements—may include
   additional requirements such as spill
   prevention
•  Standard conditions—list of conditions that
   are applicable to most NPDES permits
•  Termination—lists conditions for
   terminating permit coverage after
   construction is complete

What Construction Activities Require NPDES
Permit Coverage?
In this document,  "construction" refers to
actions that result  in a disturbance of the
land, including clearing,  grading, excavating,
and other similar activities. It also includes
"construction-related  activities," areas that
support the construction project such as
stockpiles,  borrow areas, concrete truck
washouts, fueling areas, material storage
areas and equipment storage areas.

Construction activities that do not disturb
land, such  as interior remodeling, generally
do not require NPDES permit coverage.

Are There Situations  Where a Permit Is Not
Needed?
Generally, permit coverage is not required
for activities that are considered routine
maintenance, such as landscaping, road
maintenance, and  maintaining stormwater
BMPs.  Some states and EPA offer the option
of a waiver for small sites (disturbing less
than 5 acres) in areas and times of the year
with low predicted rainfall. To be eligible
for the waiver, you would have to meet the
requirements specified in the regulations.
Local Requirements
Operators of construction sites should keep in
mind that local governments (cities, towns,
counties) often have their own requirements
for construction sites (e.g., local permits for
grading, sediment and erosion,  utilities).
Compliance with local requirements
does not mean compliance with federal
NPDES requirements or vice versa, unless
the authorized state agency or EPA has
specifically designated the local program a
qualifying local program.

Qualifying Local Programs
In some states, the NPDES permitting agency
has identified certain local construction
stormwater control programs that have
requirements that are equivalent or more
protective than the state's requirements. If
one of  these local stormwater programs has
been designated by the permitting agency as a
qualifying local program, the construction site
operator may simply read and follow the local
requirements. The permitting agency  (state or
EPA) might choose to waive the requirement
to file a Notice of Intent (NOI) or similar
application form for small construction
sites operating within the jurisdiction of a
qualifying local program. If waived, these
sites would be covered under the appropriate
construction general permit automatically.
Check  your construction general permit
carefully.

The NPDES permitting authority must
identify any qualifying local programs in the
construction general permit. Violations of
the local requirements are also  considered
violations of the NPDES requirements and
may be enforced accordingly.
    SWPPP Tip!
  Read Your General Permit!
  You should thoroughly read and understand
  the requirements in your general permit. This
  includes requirements on eligibility (whether
  your site qualifies for the general permit),
  application (how to notify EPA or the state that
  you'd like to be covered by the general permit),
  SWPPPs, and termination (stabilizing your site
  and notifying EPA or the state that your project
  is complete). By applying for coverage under
  the general permit, you are telling EPA or your
  state that you will comply with the permit's
  requirements, so read your permit carefully!
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B. Who Is Required to Get NPDES Permit
   Coverage?
Construction site operators are responsible
for obtaining NPDES permit coverage
for their stormwater discharges. Each
state has its own definition of the term
operator.  Operators may include owners
(e.g., developers), general contractors,
independent subcontractors, government
officials,  companies, or corporations. This
section reflects EPA's understanding of most
NPDES permit requirements for stormwater
discharges throughout the country. You
should, of course, consult your construction
general permit for the requirements that apply
to you. In some  cases, states have defined the
operator as a single entity, usually the land
owner or easement holder. In other states,
several entities may meet the definition of
operator. For instance, the owner may control
the project's plans and specifications, and
the general contractor may control the site's
day-to-day operations. In such cases, both
may be defined  as operators.  If a site has
multiple operators, they may cooperate on the
development and implementation of a single
SWPPP. Operators generally obtain coverage
under an NPDES permit, often by filing a form
called a Notice of Intent (NOI).
         EROSION CONTROL
              IN PLACE
          00 NOT DRIVE OVER
            DO NOT PARK ON
            DO NOT REMOVE
              SAND BAGS
Figure 4. Use signage to help educate construction staff.
EPA's Construction General Permit (which
applies only where EPA is the permitting
authority—see Chapter 2 Section A) defines
operator as any party that:
•  Has control over the construction plans and
   specifications
   and/or
•  Has day-to-day operational control of
   the site, including activities necessary to
   implement the SWPPP

Regardless of whether or not the operator is a
corporation or governmental entity, someone
must direct the SWPPP's preparation and
implementation and apply for NPDES permit
coverage for the stormwater discharges. In
most cases, this will be a high-level official,
such as a corporate officer, manager or elected
official, or a principal executive officer. For
specific instructions, refer to the appropriate
NPDES stormwater permit.

Multiple Operators
In many instances, there may be more
than one party at a site performing tasks
related to operational control and more than
one operator may need to submit an NOI.
Depending on the site  and the relationship
between the parties (e.g., owner, developer,
general contractor),  there can either be
a single party acting as site operator and
consequently responsible for obtaining
permit coverage, or there can be two or
more operators  all needing permit coverage.
Exactly who is considered an operator is
largely controlled by how the owner of the
project chooses to structure the contracts with
the contractors hired to design and/or build
the project. The following are three general
operator scenarios (variations on any of these
three are possible, especially as the number of
owners and contractors increases):

•  Owner as sole permittee. The property
   owner designs the structures for the site,
   develops and implements the SWPPP, and
   serves as general contractor  (or has an
   on-site representative with full authority to
   direct day-to-day operations). The owner
   may be the only party that needs permit
   coverage under these circumstances.
   Everyone else on the site may be
   considered subcontractors and might not
   need permit coverage.
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•  Contractor as sole permittee. The property
   owner hires one company (i.e., a contractor]
   to design the project and oversee all aspects
   of the construction project, including
   preparation and implementation of the
   SWPPP and compliance with the permit
   (e.g., a turnkey project). Here, the contractor
   would likely be the only party needing a
   permit. It is under this scenario that an
   individual having a personal residence built
   for his own use (e.g., not those to be sold
   for profit or used as rental property) would
   not be considered an operator. However,
   individual property owners would meet
   the definition of operator and may require
   permit coverage if they perform general
   contracting duties for construction of their
   personal residences.

•  Owner and contractor as co-permittees. The
   owner retains control over any changes
   to site plans, SWPPPs, or stormwater
   conveyance or control designs; but the
   contractor is responsible for overseeing
   actual earth disturbing activities and daily
   implementation of SWPPP and other permit
   conditions. In this case, which is the most
   common scenario, both parties may need
   to apply for permit coverage.

However, you are probably not an operator
and subsequently would not need permit
coverage if one of the following is true:
•  You are a subcontractor hired by, and
   under the supervision of, the owner or a
   general contractor (i.e., if the contractor
   directs your activities on-site, you probably
   are not an operator)
•  The operator of the site has indicated in
   the SWPPP that someone other than you
   (or your subcontractor) is reponsible for
   your activities as they relate to stormwater
   quality (i.e., another  operator has assumed
   responsibility for the impacts of your
   construction activities). This is typically
   the case for many, if not most, utility
   service line installations.

In addition, owner typically refers to the
party that owns the structure being built.
Ownership of the land where construction
is occurring does not necessarily imply
the property owner is an operator (e.g., a
landowner whose property is being disturbed
by construction of a gas pipeline). Likewise, if
the erection of a structure has been contracted
for, but possession of the title or lease to the
land or structure does  not to occur until after
construction, the would-be owner may not be
considered an operator (e.g., having a house
built by a residential homebuilder).

Transferring Ownership
In many residential developments, an
overall developer applies for the stormwater
permit coverage, conducts grading activities,
and installs the basic infrastructure  (e.g.,
utilities,  roads). Individual lots are then sold
to  builders who then construct the houses.
Unless the developer is still responsible for
stormwater on these individual lots (which
is typically not the case), it is likely that the
builder will need to apply for NPDES permit
coverage for stormwater discharges during
home construction.

Subcontractors
It is typically a good idea to include specific
contract  language requiring subcontractors
to  implement appropriate stormwater
controls. Subcontractors should be trained
on appropriate BMPs and requirements in
the SWPPP and should not disturb or remove
BMPs.  Some contractors will include specific
penalties in subcontractor agreements  to
ensure subcontractors  do not damage or
remove BMPs.
  Take a Closer Look..
  Erosion Control vs. Sediment Control
  When developing a SWPPP, it is important to understand the difference
  between erosion control and sediment control. Erosion control measures
  (e.g., mulch, blankets, mats, vegetative cover) protect the soil surface and
  prevent soil particles from being dislodged  and carried away by wind or
  water. Sediment control measures remove soil particles after they have been
  dislodged (typically through settling or filtration). It is usually easier and less
  expensive to prevent erosion than it is to control sedimentation.
                      What does this mean to me?
                      You should try to use erosion control
                      BMPs as the primary means of preventing
                      stormwater contamination, and sediment
                      control techniques to capture any soil
                      that does get eroded. Because no one
                      technique is 100 percent effective, a
                      good SWPPP will use both kinds of BMPs
                      in combination for the best results.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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C. What Elements Are Required in a
   SWPPP?
The SWPPP lays out the steps and techniques
you will use to reduce pollutants in
stormwater runoff leaving your construction
site. Therefore, proper development and
implementation of your SWPPP is crucial.
First and foremost, your SWPPP must be
developed and implemented consistent
with the requirements of the applicable
NPDES stormwater construction permit. The
following discussion describes requirements
that are contained in most of these permits.

Your SWPPP is used to identify all potential
pollution sources that could come into contact
with stormwater leaving your site. It describes
the BMPs you will use to reduce pollutants
in your construction site's stormwater
discharges, and it includes written records
of your site inspections and the follow-up
maintenance that is performed.

Your SWPPP should contain the following
elements:
•  Cover/title page
•  Project and SWPPP contact information
•  Site and  activity description, including a
   site map
•  Identification of potential pollutant sources
•  Description of controls to reduce pollutants
•  Maintenance/inspection procedures
•  Records  of inspections and follow-up
   maintenance of BMPs
•  SWPPP amendments
•  SWPPP certification

Chapters 3-6 of this guide describe how to
develop a SWPPP—from site evaluation and
data collection to selecting  appropriate BMPs
and assigning maintenance and inspection
responsibilities.
D. SWPPP Roles and Responsibilities
The operator has the lead for developing and
implementing the SWPPP and commiting
resources to implement the BMPs. Stormwater
pollution control is typically the job of more
than a single person; the SWPPP development
process provides a good opportunity to
define roles and responsibilities of everyone
involved. Roles and responsibilities are to
be documented clearly in the SWPPP and
subcontractor agreements as necessary. Your
SWPPP should describe:
•  Who is on the stormwater pollution
   prevention team?
•  Who will install structural stormwater
   controls?
•  Who will supervise and implement
   good housekeeping programs, such as
   site cleanup and disposal of trash and
   debris, hazardous material management
   and disposal, vehicle and equipment
   maintenance, and so on?
•  Who will conduct routine inspections
   of the  site to ensure all BMPs are being
   implemented and maintained?
•  Who will maintain the BMPs?
  Who is responsible for documenting
  changes to the SWPPP?
  Who is responsible for communicating
  changes in the SWPPP to people working
  on the site?
When you apply for your stormwater permit,
the application may ask for a SWPPP
contact. This could be the construction
site operator, but in  many cases it's a staff
person (e.g., project superintendent, field
manager, construction manager, stormwater
compliance officer) at the construction site
who is responsible for conducting inspections,
ensuring BMPs are installed and maintained,
and updating the SWPPP when necessary.
    SWPPP Tip!
                                                Erosion Control Certification
                                                Several programs promote the training and
                                                certification of individuals in erosion and sediment
                                                control. Some states have developed certification
                                                programs and require construction sites to have a
                                                certified individual on-site at all times. The Soil and
                                                Water Conservation Society and the International
                                                Erosion Control Association sponsor a national
                                                certification program, the Certified Professional in
                                                Erosion and Sediment Control (www.cpesc.org)
                                     Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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E. Common SWPPP Objectives
The SWPPP outlines the steps you will take
to comply with the terms and conditions of
your construction general permit. Keeping the
following objectives in mind as you develop
your SWPPP will help guide you in addressing
your permit requirements and in protecting
water quality.
•  Stabilize the site as soon as possible.
   Get your site to final grade and either
   permanently or temporarily stabilize all
   bare soil areas as soon as possible. Take
   into consideration germination times for the
   grasses or other vegetation selected, and
   provide additional  stabilization  (mulches,
   matrices, blankets, soil binders) on erosion-
   prone areas such as slopes and drainage
   ways. Also consider seasonal limitations
   to plant establishment and growth, such
   as drought or cold  temperatures, and
   make an effort to ensure that areas that
   are not showing adequate vegetation
   establishment are reseeded or mulched
   immediately. Areas needed for future roads,
   construction, or other purposes should be
   temporarily stabilized (see your permit for
   requirements related to areas of the site
   not currently under active construction).
   Establishing a vegetated cover on as much
   of the site as possible will help to minimize
   erosion and sediment problems. Perimeter
   controls should remain in place until final
   stabilization has been achieved.

•  Protect slopes and channels. Convey
   concentrated  stormwater runoff around
   the top of slopes and stabilize slopes as
   soon as possible. This can be accomplished
   using pipe slope drains or earthen berms
   that will convey runoff around the exposed
   slope. Avoid disturbing natural channels
  Take a Closer Look...
  Incentives to preserve open space
  It should be the goal of every construction
  project to, where possible, preserve open
  space and minimize impervious surfaces
  through practices such as clustering houses.
  Open space preservation can provide
  significant water quality and economic
  benefits to property owners.
     and the vegetation along natural channels,
     if possible.
  •  Reduce impervious surfaces and promote
     infiltration. Reducing impervious surfaces
     will ultimately reduce the amount of
     runoff leaving your site. Also, divert
     runoff from rooftops and other impervious
     surfaces to vegetated areas when possible
     to promote infiltration.

  •  Control the perimeter of your site. Divert
     stormwater coming on to your site by
     conveying it safely around, through, or
     under your site. Avoid allowing run-on to
     contact disturbed areas of the construction
     site. For the runoff from the disturbed
     areas  of the site, install BMPs such as silt
     fences to capture sediment before it leaves
     your site.  Remember—"Divert the clean
     water, trap the dirty water."

  •  Protect receiving waters adjacent to your
     site. Erosion and sediment controls are
     used around the entire site, but operators
     should consider additional  controls
     on areas that are adjacent to receiving
     waters or  other environmentally sensitive
     areas. Remember, the primary purpose
     of erosion and sediment controls is to
     protect surface waters.

  •  Follow pollution prevention measures.
     Provide proper containers for waste and
     garbage at your site. Store hazardous
     materials  and chemicals so that they are
     not exposed to stormwater.

  •  Minimize  the area and duration of exposed
     soils. Clearing only land that will be under
     construction in the near future, a practice
     known as construction phasing, can reduce
     off-site sediment loads by 36 percent for
     a typical subdivision (Claytor 2000).
     Additionally,  minimizing the duration of
     soil exposure by stabilizing soils quickly
     can reduce erosion dramatically.
What does this mean to me?
From a marketing perspective, studies have shown that lots abutting
forested or other open space are initially valued higher than lots with
no adjacent open space, and over time their value appreciates more
than lots in conventional subdivisions (Arendt 1996). For example, lots
in an open space subdivision in Amherst, Massachusetts, experienced
a 13 percent greater appreciation in value over a comparable
conventional development after 20 years even though the lots in the
conventional development were twice as large (Arendt 1996).
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Chapter 3:  SWPPP  Development—Site
Assessment  and  Planning
This chapter describes a number of steps that will help provide a good foundation for
your SWPPP, including:

•  Assessing current conditions at the site
•  Establishing pollution prevention and water quality protection goals for your
   project

•  Developing a framework to help you meet those goals
                                                                                   The first step in
                                                                                   developing a SWPPP
                                                                                   is assessing the
                                                                                   site and identifying
                                                                                   measures to protect
                                                                                   natural features.
                                                               SWPPP Tip!
A. Assess Your Site and Proposed Project
The first step in developing your SWPPP is to evaluate your
proposed construction site. Your SWPPP should describe the
undeveloped site and identify features of the land that can
be incorporated into the final plan and natural resources
that should be protected. Understanding the hydrologic and
other natural features of your site will help you develop a
better SWPPP and, ultimately, to more effectively prevent
stormwater pollution.

Visit the Site
The people responsible for site design and drafting the
SWPPP should  conduct a thorough walk-through of the entire
construction site to assess site-specific conditions such as soil
types, drainage patterns, existing vegetation, and topography.
Avoid copying SWPPPs from other projects to save time or
money. Each construction project and  SWPPP is unique,
and visiting the site is the only way to create a SWPPP that
addresses the unique conditions at that site.
Assess Existing Construction Site Conditions
Assess the existing conditions at the construction site, including topography,
drainage, and soil type. This assessment, sometimes called fingerprinting (see text
box on page 11) is the foundation for building your SWPPP and for developing your
final site plan. In this assessment, use or create a topographic drawing that:
•  Indicates how stormwater currently drains from the site, and identify the location
   of discharge points or areas
•  Identifies slopes and slope lengths. The topographic features of the site are a major
   factor affecting erosion from the site
•  Identifies soil type(s) and any highly erodible soils and the soil's infiltration
   capacity
•  Identifies any past soil contamination at the site
•  Identifies natural features, including trees, streams, wetlands, slopes and other
   features to be protected
                                                             A SWPPP is a detailed plan that:
                                                             • Identifies potential sources of stormwater
                                                               pollution
                                                             • Describes the practices that will be used
                                                               to prevent stormwater pollution. These
                                                               should include: erosion and sediment control
                                                               practices, good housekeeping practices,
                                                               conservation techniques, and infiltration
                                                               practices (where appropriate), and
                                                             • Identifies procedures the operator will
                                                               implement to comply with all requirements
                                                               in the construction general permit

                                                  Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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  Take a Closer Look..
  Fingerprinting Your Site
  When you evaluate your construction site, you should clearly identify
  vegetation, trees, and sensitive areas, such as stream buffers, wetlands,
  highly erodible soils, and steep slopes at your site. You should protect these
  areas from disturbance. Inventorying a site's  natural features is a technique
  called fingerprinting. Fingerprinting identifies  natural features that you can
  protect from clearing and heavy equipment by signage or physical barriers.
                      What does this mean to me?
                      Fingerprinting your site will help
                      ensure that you don't damage natural
                      features such as waterways or wetlands.
                      Conducting construction activity in a
                      waterway or wetland without the proper
                      permits can result in significant penalties.
In most cases, the site designer can compile
all this information on a digitized drawing
that can then be adapted to show the
planned construction activity, the phases of
construction, and the final site plan.

Topographic maps are readily available on
the Internet (e.g., www.terraserver.com or
www.mapquest.com) or by contacting the
U.S. Geological Survey store (http://store.
usgs.gov). If you need help determining
your soil type, contact your local Natural
Resource  Conservation Service (NRCS) office
or extension service office. To find the NRCS
office nearest to your site, visit the U.S.
Department of Agriculture's Service Center
Locator website (http://offices.sc.egov.usda.
gov/locator/app). Soil information is also
available online from NRCS (http://soils.
usda.gov).

Identify Receiving Waters, Storm Drains, and
Other Stormwater Conveyance Systems
Your SWPPP should clearly identify the
receiving  waters and stormwater systems
through which stormwater from your site
could flow. Many states require planning
for a specific storm event or storm events.
These storm events are referred to by their
recurrence interval and duration such as
1-year, 6-hour storm or a 100-year, 24-hour
storm. These events then translate into a
specific rainfall amount  depending on
average conditions in your area.

If your site's stormwater  flows into a
municipal storm drain system, you should
determine the ultimate destination of that
system's discharge. This may be obvious and
easy to document. However, in some systems,
you may have to consult with the local agency
responsible for the storm drain system to
determine the waterbody to which you are
discharging.

If your site's stormwater runs off to areas
not connected to the storm drain system,
you should consider your land's topography
and then identify the waterbodies that it
could reach. Many sites will discharge some
stormwater to a storm drain system and  some
to  other areas not connected to the system.
If your site's stormwater could potentially
reach two or more waterbodies, note that
in  your SWPPP. Remember, stormwater can
travel long distances over roads, parking lots,
down slopes, across fields, and through storm
sewers and drainage ditches.

Describe Your Construction Project
Your SWPPP should contain a brief
description of the construction activity,
including:

•  Project type or function (for example,
   low-density residential, shopping mall,
   highway)

•  Project location,  including latitude and
   longitude

•  Estimated project start  and end dates

•  Sequence and timing of activities that will
   disturb soils at the site

•  Size of the project

•  Estimated total area expected to be
   disturbed by excavation, grading, or other
   construction activities, including dedicated
   off-site borrow and fill areas

•  Percentage of impervious area before  and
   after construction
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites


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Construction Site Pollutants
Areas of Consideration
Clearing, grading,
excavating, and
unstabilized areas
Paving operations
Concrete washout and
waste
Structure construction/
painting/cleaning
Demolition and debris
disposal
Dewatering operations
Drilling and blasting
operations
Material delivery and
storage
Material use during
building process
Solid waste (trash and
debris)
Hazardous waste
Contaminated spills
Sanitary/septic waste
Vehicle/equipment fueling
and maintenance
Vehicle/equipment use
and storage
Landscaping operations
Primary
Pollutant
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                                                                    •  Runoff coefficient1 before and after
                                                                       construction

                                                                    •  Soil types

                                                                    •  Construction site location and any nearby
                                                                       waters or wetlands

                                                                    •  Describe and identify the location of
                                                                       other potential sources of stormwater
                                                                       contamination, such as asphalt and
                                                                       concrete plants, stucco operations, paint
                                                                       and concrete washout, and such


                                                                    Identify Pollutants and Pollution Sources
                                                                    Identify the pollutants and sources that are
                                                                    likely to be found on  the site. The principle
                                                                    pollutant of concern,  of course, is sediment.
                                                                    There are, however, other pollutants that
                                                                    may be found, usually in substantially
                                                                    smaller amounts, in stormwater runoff from
                                                                    construction sites. These can include nutrients,
                                                                    heavy metals, organic compounds, pesticides,
                                                                    oil and  grease, bacteria and viruses, trash and
                                                                    debris,  and other chemicals. After identifying
                                                                    the pollutants and sources,  be as specific as
                                                                    possible in your SWPPP about the BMPs you
                                                                    will use to address them. The table at the left
                                                                    lists the sources of pollutants at construction
                                                                    sites, including sediment, the primary
                                                                    pollutant and other pollutants that may be
                                                                    present at construction sites.
                                                                    Figure 5. Make sure storm drain inlets
                                                                    are protected.
'The runoff coefficient is the partial amount of the total rainfall which will become runoff. Runoff coefficients generally range from 0.95 (highly impervious) to 0.05 (vegetated surface that
 generates little runoff). For more information on calculating the runoff coefficient for your site, see Appendix C.

                                                         Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Non-Stormwater Discharges
Most permits will require you to identify any
non-stormwater discharges in your SWPPP.
Certain non-stormwater discharges may be
allowed under the terms and conditions of
your permit, however, you should make every
effort to eliminate these discharges where
possible. You should identify these sources in
your SWPPP and identify pollution prevention
measures to ensure that pollutants are not
introduced to these discharges and carried to
nearby waterbodies.

EPA's CGP identifies these allowable  non-
stormwater discharges: discharges from
fire-fighting activities, fire hydrant flushings,
waters used to wash vehicles, buildings,
and  pavements where detergents  are not
used, water used to control dust,  potable
water (including uncontaminated water line
flushings), uncontaminated air conditioning
condensate, uncontaminated ground water
or spring water, among others. The permit
goes on to say that non-stormwater discharges
should be eliminated  or reduced to the extent
feasible and that the SWPPP  should identify
and  ensure the implementation of appropriate
pollution prevention measures for these
discharges. More discussion of pollution
prevention measures  for some of these non-
stormwater sources can be found in Chapter 5.

Permanent Stormwater Controls
(Post-Construction)
The  topic of designing, installing, and
maintaining permanent or post-construction
Stormwater controls, although a requirement,
is beyond the scope of this SWPPP guide. A
SWPPP compiled in support of coverage under
EPA's Construction General Permit, however,
needs to include a description of all permanent
Stormwater controls that will be constructed
along with the buildings, roads, parking lots,
and other structures.  You should incorporate
sediment and erosion controls into your
SWPPP for areas where permanent Stormwater
controls, such as wet  ponds, swales, and
bioretention cells are  to be constructed.

Effectively managing Stormwater over the
long-term—long after the actual construction
process is over—is a significant challenge.
Many communities (and a few  states) have or
are developing comprehensive requirements
to better manage permanent  (or post-
construction) Stormwater runoff. To  be most
effective, you should consider integrating your
design process for your permanent Stormwater
controls into your overall design for  your
site. Planning for your permanent Stormwater
controls could affect your decisions about
site design, location of buildings and other
structures, grading, and preserving natural
features. By preserving natural drainage
patterns, trees, native vegetation, riparian
buffers, and wetlands, you might need to
construct fewer or smaller structural storm-
water controls to cope with runoff from your
site. Permanent Stormwater controls  should be
designed with two important goals in mind:
(1) reduction of the volume and velocity of
runoff, and (2) reduction of the pollutants in
the Stormwater that does leave  your  site.

Techniques, such as Low Impact Development,
Better Site Design, or  Conservation
Development, which emphasize addressing
Stormwater where it falls, infiltrating it,
preserving natural drainage patterns, and
  Take a Closer Look...

  Specimen Trees and Natural Vegetation
  Before a site plan is prepared, identify and
  clearly mark  existing trees and vegetation you
  want to preserve. Some communities have tree
  preservation  ordinances, and local extension
  service offices and foresters will often provide free
  advice on tree and plant preservation. Remember
  to notify all employees and subcontractors about
  trees and areas you  intend to preserve and mark
  them clearly.
What does this mean to me?
Large trees and other native vegetation can represent significant value
in the long term to property owners and the community at large.
Many studies document that the presence of trees on residential and
commercial sites provide many benefits including improved aesthetics,
habitat for birds and other wildlife, and energy savings (shade) that
ultimately enhance the economic value of the site. Trees also provide
shade and act as windbreaks,  which can reduce energy costs over the
long term. By protecting existing trees, you can reduce landscaping
costs and improve the appearance of a newly developed property.
According to the National Arbor Day Foundation,  trees around a home
can increase its value by 15 percent or more.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites


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              preserving natural vegetation offer the best
              opportunity to protect nearby rivers, lakes,
              wetlands, and coastal waters. Incorporating
              these ideas and concepts into the design for
              your project before it is built also offers the
              opportunity  to reduce capital infrastructure
              and long-term maintenance costs.

              At the neighborhood or even at the watershed
              scale, Smart  Growth techniques can help
              us design neighborhoods that minimize
              impacts on water quality,  reduce air pollution,
              and improve the general quality of life for
              residents. In  the Resources list in Appendix
              D, you will find a list of suggestions on this
              topic, including how to incorporate Smart
              Growth and  Low Impact Development
              techniques into the design of your site.

              B. Identify Approaches to Protect Natural
                 Resources
              Preservation  of natural areas, waterbodies, and
              open space has numerous economic, aesthetic,
              community, and environmental benefits.
              Preservation  efforts also often increase the
              value of lots  and homes and help to reduce
              overall expenditures on infrastructure.
              Specifically, these kinds of conservation efforts
              can help to significantly reduce the volume
              and velocity  of stormwater runoff and the
              pollutants that may be carried with it.
  SWPPP Tip!
Tree Preservation Resources
For more on tree preservation, contact your
local extension service office or forester. Also,
American Forests has useful information and
tools at their website,
www.americanforests.org/
resources/urbanforests. The
Center for Watershed Protection
in cooperation with the U.S.
Forest Service has developed
a series of manuals on urban
forestry. Part two, titled
Conserving and Planting Trees
at Development Sites will be of
particular interest. You can find
these manuals at www.cwp.org
Protect Nearby Waters
Your SWPPP should describe how you will pro-
tect and preserve any streams, wetlands, ponds
or other waterbodies that are on your property
or immediately adjoining it. Riparian areas
around headwater streams are especially im-
portant to the overall health of the entire river
system. Many states and communities have
buffer or shoreline protection requirements to
preserve sensitive areas around waterbodies.

Many states apply special designations to
high-value or high-quality waters. Check with
your state water pollution control agency to
determine if your project could discharge
to outstanding or special protection waters
[such as  wetlands, or salmon and trout
streams). You might be subject to additional
requirements to protect these waterbodies.

Wetland  areas,  including bogs,  marshes,
swamps, and prairie potholes may be found
in areas adjacent to rivers, lakes, and coastal
waters but may also be found in isolated
places far from other surface waters. Many
types of wetlands are protected under the
Clean Water Act and construction activities
in and around these areas may require an
additional permit from the Army Corps of
Engineers. Construction  site operators should
make every effort to preserve wetlands and
must follow applicable local, state, and federal
requirements before disturbing them or the
areas around them.

To ensure the protection of natural areas
during the construction period, you should
use a combination of techniques, including
temporary fencing,  signage, and educating
staff and subcontractors.

Assess Whether Your Project Impacts an
Impaired Waterbody
Under the Clean Water Act, states are required
to determine if rivers, lakes, and other waters
are meeting water quality standards. When
a waterbody does not meet water quality
standards because of one or more sources
of pollution, the state lists the water as
impaired. When a water  is determined to be
impaired, the state or EPA develops a plan for
correcting the situation. This plan is called
a Total Maximum Daily Load (TMDL). If
stormwater from your project could reach an
impaired water with or without an approved
TMDL (either directly or indirectly through a
municipal storm drain system), your permit

                                                   Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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may include additional requirements to
ensure that your stormwater discharges do
not contribute to that impairment and your
stormwater controls are consistent with plans
to restore that waterbody. Your SWPPP should
describe the specific actions you will take to
comply with these permit requirements for
impaired waters.

You should determine, before you file for
permit coverage, if the receiving waters for
your project are impaired and if so, whether a
TMDL has  been developed for this waterbody.
Visit EPA's  Enviromapper website (www.
epa.gov/waters/enviromapper) or contact
your state environmental agency for more
information.

Assess Whether You Have Endangered Plant or
Animal Species in  Your Area
The federal Endangered Species Act protects
endangered and threatened species and their
critical habitat areas. (States and tribes may
have their own endangered species laws.) In
developing the assessment of your site, you
should determine whether listed endangered
species are on or near your property. Critical
habitat areas are often designated to support
the continued existence of listed species. You
should also determine whether critical habitat
areas have been designated in the vicinity
of your project. Contact your local offices of
the U.S. Fish and Wildlife Service (FWS),
National Marine Fisheries Service (NMFS),
or your state or tribal heritage centers. These
organizations often maintain lists of federal
and state listed endangered and threatened
species on  their Internet sites. For more
information and to locate lists for your state,
visit www.epa.gov/npdes/endangeredspecies

Additionally,  your state's NPDES stormwater
permit may specifically require that you
address whether the activities and the
stormwater discharged by your construction
site have the potential to adversely affect
threatened or endangered species or the
critical habitat areas. You might need
to conduct  a biological investigation or
assessment and document the results of the
assessment in your SWPPP. The state may
reference federal, state,  or tribal endangered
species protection laws  or regulations.

EPA's Construction General Permit contains
detailed procedures to assist construction site
operators in determining the likely impact of
their projects on any endangered species or
critical habitat. Construction site operators in
areas covered by EPA's Construction General
Permit are required to assess the impact of
their activities and associated stormwater
discharges on species and habitat in the
"project area" which may extend beyond the
site's immediate footprint.

Assess Whether You Have Historic Sites that
Require Protection
The National Historic Preservation Act,
and any state, local and tribal historic
preservation laws, apply to construction
activities. As with endangered species, some
permits may specifically require you to assess
the potential impact of your stormwater
discharges on historic properties. However,
whether or not  this is stated as  a condition
for permit coverage, the National Historic
Preservation Act and any applicable state or
tribal laws apply to you. Contact your State
Historic Preservation Officer  (www.ncshpo.
org/stateinfolist/fulllist.htm) or your Tribal
Historic Preservation Officer (grants.cr.nps.
gov/thpo/tribaloffices.cfm).

C. Develop Site Maps
The final step in the site evaluation process
is to document  the results of your site
assessment and your planned phases of
construction activity on a detailed site map
or maps. This includes developing site maps
showing planned construction activities and
stormwater practices for the various major
stages of construction, protected areas,
natural features, slopes, erodible soils, nearby
waterbodies, permanent stormwater controls,
and so on. You  must keep your  SWPPP and
your site maps up-to-date to reflect changes at
your site during the construction process.

Location Maps
A general location map is helpful to identify
nearby, but not adjacent, waterbodies in
proximity to other properties. You can use any
easily available maps or mapping software to
create a location map.

Site Maps
The detailed construction site maps should
show the entire site and identify a number
of features at the site related to  construction
activities and stormwater management
practices.
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        ^^^^_  T \^  JQHH5QN mPP • -^ j
Figure 6. Example site map.
                Map of undeveloped or existing site. For
                many sites, a map of the undeveloped or
                existing site, noting the features that you
                identified in Section A of this Chapter, will
                help you develop your SWPPP and identify
                current site features that you want to
                preserve.  On this map note current drainage
                patterns, storm drains, slopes, soil types,
                waters and other natural features. Also note
                any existing structures, roads, utilities, and
                other features.

                Map or series of maps for construction plans.
                Site maps should show the construction
                activities  and stormwater management
                practices for each major phase of construction
                [e.g., initial grading, infrastructure,
                construction, and stabilization). The site maps
                should legibly identify the following features:
                •  Stormwater flow and discharges. Indicate
                   flow direction (s) and approximate
                   slopes after grading activities, as well as
                   locations of discharges to surface waters or
                   municipal storm drain systems.
                •  Areas and features to be protected. Include
                   wetlands, nearby streams, rivers, lakes,
                   and coastal waters, mature trees and
                   natural vegetation, steep slopes, highly
                   erodible soils, etc.
                •  Disturbed areas. Indicate locations and
                   timing of soil disturbing activities (e.g.
                   grading). Mark clearing limits.
                •  BMPs.  Identify locations of structural
                   and non-structural BMPs identified in
  the SWPPP, as well as post-construction
  stormwater BMPs.
• Areas of stabilization. Identify locations
  where stabilization practices are expected
  to occur. Mark areas where final
  stabilization has been accomplished.
• Other areas and roads. Indicate locations
  of material, waste, borrow, or equipment
  storage.

You should complete your site maps after
reviewing Chapters 4 and 5 and any
applicable BMP design manual to select
appropriate BMPs for your site.

Use Site Maps to Track Progress
Develop and keep up-to-date site maps
showing non-structural BMPs that change
frequently in location  as the work on a
construction site progresses. Your permit
requires that you keep your SWPPP up-
to-date, so mark up the site map with the
location of these BMPs. Indicate the current
location of the following:

• Portable toilets

• Material storage areas

• Vehicle and equipment fueling and
  maintenance areas

• Concrete washouts

• Paint and stucco washouts

• Dumpsters or other trash and debris
  containers

• Spill kits

• Stockpiles

• Any other non-structural non-stormwater
  management BMPs

• Any temporarily removed structural BMPs

• Any changes to the structural BMPs

If a marked-up site map  is too full to  be easily
read, you should date  and fold it, put it in
the SWPPP for documentation, and start a
new one. That way, there is a good hard copy
record of what has occurred on-site.

Construction sites are dynamic. As conditions
change at the construction site, such as the
locations of BMPs, your  SWPPP must reflect
those changes.

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Chapter 4:  SWPPP  Development—Selecting
Erosion  and Sediment  Control  BMPs
                                                                                   This chapter presents
                                                                                   a brief discussion of
                                                                                   erosion and sediment
                                                                                   control principles and
                                                                                   a discussion of some
                                                                                   commonly used BMPs.
This document is not intended as an engineering or design manual on BMPs. The
engineer or other qualified person that develops the details of your sediment and
erosion control plan should be using the appropriate state or local specifications.
The descriptions below provide a kind of checklist of the things to look for and some
helpful installation and maintenance hints.

Erosion and sediment controls are the structural and non-structural practices used
during the construction process to keep sediment  in place (erosion control) and to
capture any sediment that is moved by stormwater before it leaves the site (sediment
control). Erosion controls—keeping soil where it is—are the heart of any effective
SWPPP. Your SWPPP should rely on erosion controls as the primary means of
preventing stormwater pollution. Sediment controls provide a necessary second line
of defense to properly designed and installed erosion controls.

The suite of BMPs that you include in your SWPPP should reflect the specific condi-
tions at the site. The information that you collected in the previous steps should help
you select the appropriate BMPs for your site.
An effective SWPPP includes a combination
or suite of BMPs that are designed to work
together.                                          Erosion Control (keeping the dirt in place) and
                                                 Minimizing the Impact of Construction
Ten Keys tO Effective Erosion dnd                   I-   Minimize disturbed area and protect natural features and soil
Sediment Control (ESC)                            2.   Phase construction activity
The ultimate goal of any SWPPP is to protect
rivers, lakes, wetlands, and coastal waters
that could be affected by your construction
project. The following principles and tips
should help you build an effective SWPPP.
Keep in mind that there are many BMP
options available to you. We have selected
a few common BMPs to help illustrate the
principles discussed in this chapter.
  Take a Closer Look...

  BMPs in Combination
  BMPs work much better when they are used in
  combination. For instance, a silt fence should not be
  used alone to address a bare slope. An erosion control
  BMP should  be used to stabilize the slope, and the silt
  fence should serve as the backup BMP.
                                                  3.   Control stormwater flowing onto and through the project
                                                  4.   Stabilize soils promptly
                                                  5.   Protect slopes
                                                 Sediment Controls (the second line of defense)
                                                  6.   Protect storm drain inlets
                                                  7.   Establish perimeter controls
                                                  8.   Retain sediment on-site and control dewatering practices
                                                  9.   Establish stabilized construction exits
                                                  10.  Inspect and maintain controls
                                                  What does this mean to me?
                                                  Wherever possible, rely on erosion controls to keep sediment
                                                  in place. Back up those erosion controls with sediment
                                                  controls to ensure that sediment doesn't leave your site.
                                                  Continually evaluate your BMPs. Are they performing
                                                  well? Could the addition of a supplemental BMP improve
                                                  performance? Should you replace a BMP with another one
                                                  that might work better? Using BMPs in series also gives you
                                                  some protection in case one BMP should fail.
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                Erosion Control and Minimizing the Impact of
                Construction

                ESC Principle 1: Minimize disturbed area
                and protect natural features and soil. As you
                put together your SWPPP, carefully consider
                the natural features of the site that you
                assessed in Chapter 3. By carefully delineating
                and controlling the area that will be disturbed
                by grading or construction activities, you can
                greatly reduce the potential for soil erosion
                and stormwater pollution problems. Limit
                disturbed areas to only those necessary for the
                construction of your project. Natural vegetation
                is your best and cheapest erosion control BMP.
                                           Protecting and
                                           preserving topsoil
                                           is also a good
                                           BMP. Removing
                                           topsoil exposes
                                           underlying layers
                                           that are often
                                           more prone to
                                           erosion and have
                                           less infiltration
                                           capacity. Keeping
                                           topsoil in place
                                           preserves the
                                           natural structure
                                           of the soils
                                           and aids the
                                           infiltration of
                                           stormwater.
Figure 7. Protect vegetated buffers by using silt fence
or other sediment controls.
                ESC Principle 2: Phase construction
                activity. Another technique for minimizing
                the duration of exposed soil is phasing. By
                scheduling or sequencing your construction
                work and concentrating it in certain areas,
                you can minimize the amount of soil that is
                exposed to the elements at any given time.
                Limiting the area of disturbance to places
                where construction activities are underway
                and stabilizing them as quickly as possible
                can be one of your most effective BMPs.
ESC Principle 3: Control stormwater
flowing onto and through your project. Plan
for any potential stormwater flows coming
onto the project area from upstream locations,
and divert (and slow) flows to prevent
erosion. Likewise, the volume and velocity of
on-site stormwater runoff should be controlled
to minimize soil erosion.

Example BMP: Diversion Ditches or Berms
  Description: Diversion ditches or berms
  direct runoff away from unprotected
  slopes and  may also direct sediment-laden
  runoff to a  sediment-trapping structure.
  A diversion ditch can be located at the
  upslope side of a construction site to prevent
  surface  runoff from entering the disturbed
  area. Ditches or berms on slopes need to be
  designed for erosive velocities. Also, ensure
  that the diverted water is released through a
  stable outlet and does not cause downslope
  or downstream erosion or flooding.

  Installation  Tips:
  •  Divert run-on and runoff away from
     disturbed  areas
  •  Ensure that the diversion is protected
     from erosion, using vegetation,
     geotextiles, or other appropriate BMPs
  •  Divert sediment-laden water to a
     sediment-trapping structure
  •  Use practices that encourage infiltration
     of stormwater runoff wherever possible
  Maintenance:
  •  Inspect diversions and berms, including
     any outlets, regularly and after each
     rainfall
  •  Remove any accumulated sediment
                                                                 Figure 8. Illustration of a construction berm to divert
                                                                 stormwater away from the disturbed construction
                                                                 area.
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ESC Principle 4: Stabilize soils promptly.
Where construction activities have
temporarily or permanently ceased, you
should stabilize exposed soils to minimize
erosion. You should have stabilization
measures in place after grading activities have
ceased (many permits require stabilization
within a specified time frame). You can
provide either temporary or permanent
cover to protect exposed soils. Temporary
measures are necessary when an area of a site
is disturbed but where activities in that area
are not completed or until permanent BMPs
are established. Topsoil stockpiles should also
be protected to minimize any erosion from
these areas. Temporary-cover BMPs include
temporary seeding, mulches, matrices,
blankets and mats, and the use of soil binders
(there may be additional state and local
requirements for the use of chemical-based
soil binders). Permanent-cover BMPs include
permanent seeding and planting, sodding,
channel stabilization, and vegetative buffer
strips. Silt fence and other sediment control
measures are not stabilization measures.
    SWPPP Tip!
  Final Stabilization
  Once construction activity in an area is
  completed and the area is stabilized (typically
  by achieving 70 percent permanent vegetative
  cover), you can mark this area on your SWPPP
  and discontinue inspections in that area. By
  bringing areas of your site to final stabilization,
  you can reduce your workload associated with
  maintaining and inspecting BMPs. For more
  information on final stabilization, see Chapter 9.
     Water regularly, if needed, to ensure
     quick growth
     Maintain backup  BMPs, such as silt fence
     or settling ponds
  Wind Control BMPs
  In areas where dust control is an issue, your
  SWPPP should include BMPs for wind-erosion
  control. These consist of mulching, wet
  suppression (watering), and other practices.
ESC Principle 5: Protect slopes. Protect
all slopes with appropriate erosion controls.
Steeper slopes, slopes with highly erodible
soils, or long slopes require a more complex
combination of controls. Erosion control
blankets, bonded fiber matrices, or turf
reinforcement mats are very effective options.
Silt fence or fiber rolls may also be used to
help control erosion on moderate slopes and
should be installed on level contours spaced
at 10- to 20-foot intervals. You can also
use diversion channels and berms to keep
stormwater off slopes.

Example BMP: Rolled erosion control products
  Description: Erosion control products
  include mats, geotextiles, and erosion
  control blankets and products that provide
  temporary stabilization and help to
  establish vegetation on disturbed soils.
  Such products help  control erosion and help
  establish vegetation and are often used on
  slopes, channels, or stream banks.
Example BMP: Temporary Seeding
  Description: Temporarily seeding an area
  to establish vegetative cover is one of the
  most effective, and least expensive, methods
  of reducing erosion. This approach, as a
  single BMP, might not be appropriate on
  steep  slopes, when vegetation cannot be
  established quickly enough to control erosion
  during a storm event, or when additional
  activities might occur soon in the area.

  Installation Tips:
  •  Seed and mulch area (the mulch
     provides temporary erosion protection by
     protecting the soil surface, moderating
     temperature, and retaining moisture
     while seeds  germinate and grow)
  Figure 9. Illustration of erosion control blankets
  installed on slope.
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                   Installation Tips.-
                   •  Use rolled erosion-control products on
                     slopes steeper than 3 to 1 (horizontal to
                     vertical) and in swales or long channels
                                         •  Trench the top
                                           of the blanket
                                           into the ground
                                           to prevent runoff
                                           from flowing
                                           under the blanket

                                         •  Overlap the lower
                                           end of the top mat
                                           over the top of the
                                           downslope mat to
                                           ensure  that runoff
                                           stays on top of the
                                           blankets and  mats
Figure 10. Illustration of a fiber roll installation
along a slope.
                                           Staple blankets
                                           and mats
                                           according to
                                           specifications
                  Maintenance:
                  •  Periodically inspect for signs of erosion
                     or failure
                  •  Repair the blanket or mat if necessary

                  •  Continue inspections until vegetation
                     is established at the level required to
                     qualify as final stabilization
                ESC Principle 6: Protect storm drain
                inlets. Protect all inlets that could receive
                stormwater from the project until final
                stabilization of the site has been achieved.
                Install inlet protection before soil-disturbing
                activities begin. Maintenance throughout
                the construction process is important. Upon
                completion of the project, storm drain inlet
                protection is one of the temporary BMPs
                that should be removed. Storm drain inlet
                protection should be used not only for storm
                drains within the active construction project,
                but also for storm drains outside the project
                area that might receive stormwater discharges
                from the project. If there are storm drains on
                private property that could receive stormwater
                runoff from your project, coordinate with the
                owners of that property to ensure proper inlet
                protection.
                                                                Example BMP: Storm Drain Inlet Protection
                                                                  Description: Storm drain inlet protection
                                                                  prevents sediment from entering a storm
                                                                  drain by surrounding or covering the inlet
                                                                  with a filtering material. Several types
                                                                  of filters are commonly used for inlet
                                                                  protection: silt fence, rock-filled bags, or
                                                                  block and gravel. The type of filter used
                                                                  depends on the inlet type (for example, curb
                                                                  inlet, drop inlet),  slope, and volume of flow.
                                                                  Many different commercial inlet filters are
                                                                  also available. Some commercial inlet filters
                                                                  are placed in front of or on top of an inlet,
                                                                  while others are placed inside the inlet
                                                                  under the grate.
                                                                                                      Runoff
                                                                     Runoff
                                                                   Figure 11. Illustration of a storm drain inlet with
                                                                   rock-filled bags filtering stormwater.

                                                                  Installation Tips:
                                                                  •  Install inlet protection as soon as storm
                                                                     drain inlets are installed and before
                                                                     land-disturbance activities begin in areas
                                                                     with existing storm drain systems
                                                                  •  Protect all inlets that could receive
                                                                     stormwater from your construction
                                                                     project
                                                                  •  Use  in conjunction with other erosion
                                                                     prevention and sediment control BMPs—
                                                                     remember, inlet protection is a secondary
                                                                     BMP!
                                                                  •  Design your inlet protection  to handle
                                                                     the volume of water from the area being
                                                                     drained. Ensure that the design is sized
                                                                     appropriately.
                                                                  Maintenance:
                                                                  •  Inspect inlets frequently and after each
                                                                     rainfall
20
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  •  Remove accumulated sediment from
     around the device and check and remove
     any sediment that might have entered
     the inlet
  •  Replace or repair the inlet protection if it
     becomes damaged
  •  Sweep streets, sidewalks, and other
     paved areas regularly
  Storm drain inlet protection should never be
  used as a primary BMP! Use erosion control
  techniques such as hydromulching or erosion-
  control blankets to prevent erosion. Use inlet
  protection and other sediment control BMPs as
  a backup or last line of defense.
ESC Principle 7: Establish perimeter
controls. Maintain natural areas and
supplement them with silt fence and fiber
rolls around the perimeter of your site to
help prevent soil erosion and stop sediment
from leaving the site. Install controls on the
downslope perimeter of your project (it is
often unnecessary to surround the entire
site with silt fence). Sediment barriers can
be used to protect stream buffers, riparian
   Figure 12. Illustration of proper techniques to use
   in installing silt fence.
areas, wetlands, or other waterways. They are
effective only in small areas and should not
be used in areas of concentrated flow.

Example BMP: Silt Fence and Fiber Rolls
  Description: A silt fence is a temporary
  sediment barrier consisting of a geotextile
  attached to supporting posts and trenched
  into the ground. Silt fencing is intended to
  retain sediment that has been dislodged by
  stormwater. It is designed only for runoff
  from small areas and  is not intended to
  handle flows  from large slopes or in areas
  of concentrated flow. Fiber rolls serve the
  same purpose and consist of an open mesh
  tubular sleeve filled with a fibrous material
  which traps sediment. Fiber rolls  are
  generally staked to  the ground.

  Installation Tips:
  DO:
  • Use silt fence or fiber rolls as perimeter
    controls, particularly at the lower or
    down slope edge of a disturbed area
  • Leave space for maintenance between toe
    of slope and silt fence  or roll
  • Trench in the silt fence on the uphill  side
     (6 inches deep by 6 inches wide]
  • Install stakes on  the downhill side of the
    fence or roll
  • Curve the  end of the silt fence  or fiber
    roll up-gradient to  help it contain runoff
  DON'T:
  • Install a silt fence or fiber rolls in  ditches,
    channels, or areas  of concentrated flow
  • Install it running up and  down a slope or
    hill
  • Use silt fencing or fiber rolls alone in
    areas that drain more  than a quarter-acre
    per  100 feet of fence

  Maintenance:
  • Remove sediment when it reaches one-
    third of the height  of the fence or one-
    half the height of the fiber roll
  • Replace the silt fence or roll where it  is
    worn, torn, or otherwise damaged
  • Retrench or replace any silt fence or
    roll that is not properly anchored to the
    ground
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                     trap and basin
                  Lenglti = 2x width or more

  • seeded
  • stable outlet
  • maintained
Figure 13. Illustration of a sediment basin.
„• '
ESC Principle 8: Retain sediment ore-site
and control dewatering practices.  Sediment
barriers described in ESC Principle 7 can
trap sediment from small areas, but when
sediment retention from a larger area
is required, consider using a temporary
sediment trap or sediment basin. These
practices detain sediment-laden runoff for a
period of time,  allowing sediment to settle
before the runoff is discharged. Proper design
and maintenance are essential to ensure that
these practices  are effective.

                             You should
                             use a sediment
                             basin for
                             common
                             drainage
                             locations that
                             serve an area
                             with 10 or
                             more acres
                             disturbed
                             at any one
                             time. The
                             basin should
                             be designed
                             to provide
                             storage for
the volume of runoff from the drainage area
for  at least a 2-year,  24-hour storm (or 3,600
cubic feet of storage per acre drained, which
is enough to contain 1 inch of runoff, if the
2-year, 24-hour calculation has not been
performed). Check your permit for exact basin
sizing requirements. Sediment basins should
be located at low-lying areas of the site and
on the down-gradient side of bare soil areas
where flows converge. Do not put sediment
traps  or basins  in or immediately adjacent to
flowing streams or other waterways.

Where a large sediment basin is not practical,
use smaller sediment basins or sediment
traps  (or both)  where feasible. At a minimum,
use silt fences, vegetative buffer strips, or
equivalent sediment  controls for all  down-
gradient boundaries  (and for those side-slope
boundaries deemed appropriate for individual
site conditions).

Dewatering practices are used to remove
ground water or accumulated rain water from
excavated areas. Pump muddy water from
these areas to a temporary or permanent
sedimentation basin  or to an area completely
enclosed by silt fence in a flat vegetated area
where discharges can infiltrate into the ground.
Never discharge muddy water into storm
drains, streams, lakes, or wetlands unless the
sediment has been removed before discharge.

Keep in mind that some states and local
jurisdictions require a separate permit for
dewatering activities at a site.

ESC Principle 9: Establish stabilized con-
struction exits. Vehicles entering and leaving
the site have the potential to track significant
amounts of sediment onto streets. Identify
and clearly mark one or two locations where
vehicles will enter and exit the site and focus
stabilizing measures at those locations.
Construction entrances are commonly made
from large crushed rock. They can be further
stabilized using stone pads or concrete. Also,
steel wash racks and a hose-down system
will remove even more mud and debris from
vehicle tires. Divert runoff from wash areas to
a sediment trap or basin. No system is perfect,
so sweeping the street regularly completes
this BMP.

Example BMP: Stabilized Construction Exit
  Description: A rock construction exit can
  reduce the amount of mud transported onto
  paved roads by vehicles. The construction
  exit does this by removing mud from
  vehicle tires before the vehicle enters a
  public road.
                                                                  filter fabric
                                                                  underliner
                                                                   #2 rock
                                                                 Figure 14. Illustration of a stabilized construction
                                                                 exit.

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  You might also want to install a wheel
  wash when mud is especially difficult to
  remove or space doesn't allow sufficient
  tire revolutions  (four or five are needed]
  before exiting the site. Direct wash water to
  a suitable settling area—do not discharge
  wash water to a stream or storm drain!

  Installation tips:
  •  Ensure that the exit is at least 50 feet
     long (generally, the length of two dump
     trucks) and graded so runoff does not
     enter the adjacent street

  •  Place a geotextile fabric under a layer of
     aggregate at least 6-12 inches thick. The
     stones or aggregate should be 3-6 inches
     in diameter

  •  Train employees and subcontractors to
     use the designated construction exits.
     Empower your employees to provide
     directions to  subcontractors and others
     that are not on the site every day
  Maintenance:
  •  Replenish or  replace aggregate if it
     becomes clogged with sediment

  •  Sweep the street regularly


ESC Principle 10: Inspect and maintain
controls. Inspection and maintenance is just
as important as proper planning, design, and
installation of controls. Without adequate
maintenance, erosion and sediment controls
will quickly fail, sometimes after just one
rainfall, and cause significant water quality
problems and potential violations of the
NPDES construction general permit. Your
permit likely requires you to maintain your
BMPs at all times. To do this effectively,
you should establish an inspection and
maintenance approach or strategy that
includes both regular and spot inspections.
Inspecting both prior to predicted storm
events and after will help ensure that controls
are working effectively. Perform maintenance
or corrective action as soon as problems are
noted. Inspection and maintenance of BMPs
are addressed in more detail in Chapter 6.
Other Sediment and Erosion Control
Techniques
As mentioned at the beginning of this
chapter, there are many other erosion and
sediment control techniques that can be used
effectively. The BMPs highlighted in this
chapter are among those more commonly
used and highlight many general erosion and
sediment control principles for which other
BMPs may be used effectively. Check to see if
your state or local government has developed
a BMP design manual for detailed information
on any BMP you are considering. Appendix D
lists several good BMP design manuals. You
can also find out more about various BMPs
by visiting EPA's Menu of BMPs at www.epa.
gov/npdes/menuofbmps

The following BMPs are also commonly used
at construction sites.

Erosion control measures:
• Surface roughening, trackwalking,
  scarifying, sheepsfoot rolling, imprinting

• Soil bioengineering techniques (e.g., live
  staking, fascines, brush wattles)

• Composting

• Sodding

Sediment control and runoff management
measures:
• Gravel bag barrier

• Compost berm

• Rock or brush filters

• Baffles or skimmers in sediment basins to
  increase effectiveness

• Lowering soil levels near streets and
  sidewalks to prevent runoff

• Level spreaders

• Energy dissipaters

• Check dams
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Chapter 5:  SWPPP  Development—Selecting  Good
Housekeeping  BMPs
Six Key Pollution Prevention Principles for Good Housekeeping
Construction projects generate large amounts of building-related waste, which can
end up polluting stormwater runoff if not properly managed. The suite of BMPs
that are described in your SWPPP must include pollution prevention (P2) or good
housekeeping practices that are designed to prevent contamination of stormwater
from a wide range of materials and wastes at your site. The six principles described
below are designed to help you identify the pollution prevention practices that should
be described in your SWPPP and implemented at your site.
1.  Provide for waste management
2.  Establish proper building material staging areas
3.  Designate paint and concrete washout areas
4.  Establish proper equipment/vehicle fueling and maintenance practices
5.  Control equipment/vehicle washing and allowable non-stormwater discharges
6.  Develop a spill prevention and response plan

P2 Principle 1: Provide for waste management. Design proper management
procedures and practices to prevent or reduce the discharge of pollutants to stormwater
from solid or liquid wastes that will be generated at your site. Practices such as trash
disposal, recycling, proper material handling, and cleanup measures can reduce the
potential for stormwater runoff to pick up construction site wastes and discharge them
to  surface waters.

                                        Provide convenient, well-maintained,
                                        and properly located toilet facilities.
                                        Provide for regular inspections, service,
                                        and disposal. Locate toilet facilities
                                        away from storm drain inlets and
                                        waterways to prevent accidental spills
                                        and contamination of stormwater. Treat
                                        or dispose of sanitary and septic waste in
                                        accordance with state or local regulations.

                                        Proper material use, storage, waste
                                        disposal, and training of employees  and
                                        subcontractors can prevent or reduce
                                        the discharge of hazardous and toxic
                                        wastes to stormwater. Implement a
                                        comprehensive set of waste-management
                                        practices for hazardous or toxic
                                        materials, such as paints, solvents,
                                        petroleum products, pesticides, wood
                                        preservatives, acids, roofing tar, and
                                        other  materials. Practices should include
                                        storage, handling, inventory, and cleanup
                                        procedures, in case of spills (see the
                                        following P2 principles).
Figure 15. Illustration showing construction materials
with secondary containment and overhead cover to
prevent stormwater contamination.
                                                                                   This chapter presents
                                                                                   a brief discussion of
                                                                                   good housekeeping
                                                                                   principles to consider
                                                                                   to ensure your
                                                                                   construction site
                                                                                   does not contaminate
                                                                                   stormwater runoff.

                                                                                   As noted in Chapter 3,
                                                                                   sediment is the
                                                                                   principal pollutant of
                                                                                   concern in stormwater
                                                                                   discharges from
                                                                                   construction sites. But,
                                                                                   EPA's CGP and many
                                                                                   state construction
                                                                                   general permits
                                                                                   require that the
                                                                                   SWPPP describe good
                                                                                   housekeeping measures
                                                                                   for other pollutants
                                                                                   that might be found
                                                                                   on construction sites.
                                                                                   This chapter discusses
                                                                                   these measures.

                                                  Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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  Waste Management Checklist
  Solid or Construction Waste
     •S  Designate trash and bulk waste-collection areas on-site
     •S  Recycle materials whenever possible (e.g., paper, wood, concrete, oil)
     s  Segregate and  provide proper disposal options for hazardous material wastes
     s  Clean up litter and debris from the construction site daily
     •S  Locate waste-collection areas away from streets, gutters, watercourses, and storm drains. Waste-collection areas (dump-
        sters, and such) are often best located near construction site entrances to minimize traffic on disturbed soils. Consider
        secondary containment around waste collection areas to further minimize the likelihood of contaminated discharges.
  Sanitary and Septic Waste
     •S  Provide restroom facilities on-site
     •S  Maintain clean restroom facilities and empty porta-johns regularly
     s  Provide secondary containment pans  under porta-johns, where possible
     s  Provide tie-downs or stake downs for porta-johns in areas of high winds
     •S  Educate employees, subcontractors, and suppliers on locations of facilities
     •S  Do not discharge or bury wastewater at the construction site
     s  Inspect facilities for leaks, repair or replace immediately
  Hazardous Materials and Wastes
     s  Develop and implement employee and subcontractor education, as needed, on  hazardous and toxic waste handling, stor-
        age, disposal, and cleanup
     •S  Designate hazardous waste-collection areas on-site
     s  Place all hazardous and toxic material wastes in secondary containment
     s  Hazardous waste containers should be inspected to ensure that all containers are labeled properly and that no
        leaks are present
P2 Principle 2: Establish proper building
material handling and staging areas.
Your SWPPP should include comprehensive
handling and management procedures for
building materials, especially those that
are hazardous or toxic. Paints, solvents,
pesticides, fuels  and oils, other hazardous
materials or any building materials that have
the potential to contaminate stormwater
should be stored indoors or under cover
whenever possible or in areas with secondary
containment. Secondary containment
prevents a spill from spreading across the
site and include dikes, berms, curbing, or
other containment methods. Secondary
containment techniques should also ensure
the protection of ground water. Designate
staging areas for activities such as fueling
vehicles, mixing paints, plaster, mortar, and
so on. Designated staging areas will help
you to monitor the use of materials  and to
clean up any spills. Training employees and
subcontractors is essential to the success  of
this pollution prevention principle.
                                                       SWPPP  Tip!
  Material Staging Area Measures
  Your SWPPP should include procedures for storing materials that can
  contribute pollutants to stormwater. Consider the following:
  • Train employees and subcontractors in proper handling and
    storage practices
  • Designate site areas for storage. Provide storage in accordance
    with secondary containment regulations and provide cover
    for hazardous materials when necessary. Ensure that storage
    containers are regularly inspected for leaks, corrosion,  support or
    foundation failure, or any other signs of deterioration and tested
    for soundness
  • Reuse and recycle construction materials when  possible
P2 Principle 3: Designate washout areas.
Concrete contractors should be encouraged,
where possible, to use the washout facilities
at their own plants or dispatch facilities.
If it is necessary to provide for concrete
washout areas on-site, designate specific
washout areas and design facilities to handle
anticipated washout water. Washout areas
should also be provided for paint and stucco
operations. Because washout areas can be
a source of pollutants from leaks or spills,
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites


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               EPA recommends that you locate them at
               least 50 yards away from storm drains and
               watercourses whenever possible.

               Several companies rent or sell prefabricated
               washout containers, and  some provide
               disposal of waste solids and liquids along
               with the containers. These prefabricated
               containers are sturdy and provide a more
               reliable option for preventing leaks and
               spills of wash water than self-constructed
               washouts. Alternatively, you can construct
               your own washout area, either by digging a
               pit and lining it with 10 mil plastic sheeting or
               creating an aboveground structure from straw
               bales or sandbags with a plastic liner. If you
               create your own structure, you should inspect
               it daily for leaks or tears in the plastic because
               these structures are prone to failure.

               Regular inspection and maintenance are
               important for the success of this BMP. Both
               self-constructed and prefabricated washout
               containers can fill up quickly when concrete,
               paint,  and stucco work are occurring on large
               portions of the site. You should also inspect
               for evidence that contractors are using the
               washout areas and not  dumping materials onto
               the ground or into drainage facilities. If the
               washout areas are not being used regularly,
               consider posting additional signage, relocating
               the facilities to more convenient locations, or
               providing training to workers and contractors.
   SWPPP Tip!
Washout Area Measures
When concrete, paint, or stucco is part of the construction process,
consider these practices which will help prevent contamination
of stormwater. Include the locations of these areas and your
maintenance and inspection procedures in your SWPPP.
• Do not washout concrete trucks or equipment into storm drains,
  streets, gutters, uncontained areas, or streams
• Establish  washout areas and advertise their locations with signs
• Provide adequate containment for the amount of wash water that
  will be used
• Inspect washout structures  daily to detect leaks or tears and to
  identify when materials need to be removed
• Dispose of materials properly. The preferred method is to allow
  the water to evaporate and to recycle the hardened concrete. Full
  service companies may provide dewatering services and should
  dispose of wastewater properly. Concrete wash water can be highly
  polluted.  It should not be discharged to any surface water, storm
  sewer system, or allowed to infiltrate into the ground. It should not
  be discharged to a sanitary  sewer system without first receiving
  written permission from the system operator
P2 Principle 4: Establish proper equipment/
vehicle fueling and maintenance practices.
Performing equipment/vehicle fueling and
maintenance at an off-site facility is preferred
over performing these activities on the site,
particularly for road vehicles (e.g., trucks,
vans). For grading and excavating equipment,
this is usually not possible or desirable. Create
an on-site fueling and maintenance area that is
clean and dry.  The on-site fueling area should
have a spill kit, and staff should know how
to use it. If possible, conduct vehicle fueling
and maintenance activities in a covered area;
outdoor vehicle fueling and maintenance is a
potentially significant source of stormwater
pollution. Significant maintenance on vehicles
and equipment should be conducted off-site.
    SWPPP  Tip!
  Equipment/Vehicle Fueling and
  Maintenance Measures
  Consider the following practices to help prevent
  the discharge of pollutants to stormwater from
  equipment/vehicle fueling and maintenance.
  Include the locations of these areas and your
  inspection and maintenance procedures in your
  SWPPP.
  • Train employees and subcontractors in proper
   fueling procedures (stay with vehicles during
   fueling, proper use of pumps, emergency shut-
   off valves, and such)
  • Inspect on-site vehicles and equipment daily
   for leaks, equipment damage, and other service
   problems
  • Clearly designate vehicle/equipment service
   areas away from drainage facilities and water-
   courses to prevent stormwater run-on and runoff
  • Use drip pans, drip cloths, or absorbent pads
   when replacing spent fluids
  • Collect all spent fluids, store in appropriate
   labeled containers in the proper storage areas,
   and recycle fluids whenever possible
P2 Principle 5: Control equipment/vehicle
washing and allowable non-stormwater
discharges. Environmentally friendly wash-
ing practices can be practiced at every con-
struction site to prevent contamination of
surface and ground water from wash water.
Procedures and practices include using off-site
facilities; washing in designated, contained
areas only; eliminating discharges to the
storm drain by infiltrating the wash water
or routing  to the sanitary sewer; and train-
ing employees and subcontractors in proper
cleaning procedures.

                                                      Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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  Take a Closer Look..
  Non-Stormwater Runoff
  A construction site might have sources of runoff that are not
  generated by stormwater. These non-stormwater discharges
  include fire hydrant flushing, vehicle or equipment wash water (no
  detergents!), water used to control dust, and landscape irrigation.
              What does this mean to me?
              Take steps to infiltrate these sources of uncontami-
              nated water into the ground. You can also route these
              sources of water to sediment ponds or detention
              basins or otherwise treat them with appropriate BMPs.
    SWPPP Tip!
  Equipment/Vehicle Washing Measures
  The following equipment/vehicle washing
  measures will help prevent stormwater pollution.
  Include the location of your washing facilities and
  your inspection and maintenance procedures in
  your SWPPP.
  • Educate employees and subcontractors on
    proper washing procedures
  • Clearly  mark the washing areas and inform
    workers that all washing must occur in this area
  • Contain wash water and treat and infiltrate it
    whenever possible
  • Use high-pressure water spray at vehicle
    washing facilities without any detergents
    because water can  remove most dirt adequately
  • Do not  conduct any other activities, such as
    vehicle  repairs, in the wash area
P2 Principle 6: Develop a spill prevention
and response plan. Most state and EPA
construction general permits require the
preparation of spill prevention and response
plans. Generally, these plans can be included
or incorporated into your SWPPP. The plan
should clearly identify ways to reduce the
chance of spills, stop the source of spills,
contain and clean up spills, dispose of
materials contaminated by spills,  and train
personnel responsible for spill prevention
and response. The plan should also specify
material handling procedures and storage


  Take a Closer Look.
requirements and ensure that clear and concise
spill cleanup procedures are provided and
posted for areas in which spills may potentially
occur. When developing a spill prevention plan,
include, at a minimum, the following:

•  Note the locations of chemical storage areas,
   storm drains, tributary drainage areas,
   surface waterbodies on or near the site, and
   measures to stop spills from leaving the site

•  Specify how to notify appropriate authorities,
   such as police and fire departments,
   hospitals, or municipal sewage treatment
   facilities to request assistance

•  Describe the procedures for immediate
   cleanup of  spills and proper disposal
•  Identify personnel responsible for
   implementing the plan in the event of a spill
    SWPPP Tip!
  Spill Prevention Measures
  Additional spill prevention measures that will help prevent spills and
  leaks include the following:
  •  Describe and list all types of equipment to be used to adequately
    clean up the spill
  •  Provide proper handling and safety procedures for each type of
    waste
  •  Establish an education program for employees and subcontractors
    on the potential hazards to humans and the environment from spills
    and leaks
  •  Update the spill prevention plan and clean up materials as changes
    occur to the types of chemicals stored and used at the facility
  Spill Prevention, Control and Countermeasure (SPCC) Plan
  Construction sites may be subject to 40 CFR Part 112 regulations that require the preparation and implementation of a SPCC
  Plan to prevent oil spills from aboveground and underground storage tanks. Your facility is subject to this rule if you are a
  nontransportation-related facility that:
  •   Has a total storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons
     and
  •  Could reasonably be expected to discharge oil in quantities that
     may be harmful to navigable waters of the United States and
     adjoining shorelines

  Furthermore,  if your facility is subject to 40 CFR Part 112, your
  SWPPP should reference the SPCC Plan.  To find out more about SPCC
  Plans, see EPA's website on SPPC at www.epa.gov/oilspill/spcc.htm
                What does this mean to me?
                Reporting Oil Spills
                In the event of an oil spill, you should contact the
                National Response Center toll free at 1-800-424-
                8802 for assistance, or for more details, visit their
                website: www.nrc.uscg.mil/nrchp.html
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Chapter  6:  SWPPP  Development—Inspections,
Maintenance,  and  Recordkeeping
A. Describe Your Plans and Procedures for Inspecting BMPs
Earlier discussions in this manual pointed out that the effectiveness of erosion and
sediment control BMPs and good housekeeping and pollution prevention measures
depend on consistent and continual inspection and maintenance. This step focuses on
developing a plan for BMP inspection and maintenance to ensure that a schedule and
procedures are in place.

Inspections
Your responsibility does not stop after BMPs are installed. Your BMPs must be maintained
in good working order at all times. Further, your permit requires that you conduct regular
inspections and document the findings of those inspections in your SWPPP.

Your construction general permit describes the minimum frequency of inspections,
which is typically weekly or bi-weekly and after each rainfall event exceeding one-
half inch. To meet the requirement to maintain all BMPs in good working order, EPA
recommends that you develop an inspection schedule that goes beyond these minimums
and is customized for your site and  the conditions affecting it.

In developing your inspection schedule consider the following:
• Consider using spot inspections. You may want to inspect certain parts of your
  site more frequently or even daily. Target places that need extra attention, such as
  areas around construction site entrances, check nearby streets for dirt, check inlet
  protection, and so on.
                                                                                This chapter
                                                                                describes the
                                                                                inspection and
                                                                                maintenance
                                                                                procedures your
                                                                                SWPPP should
                                                                                include, as well
                                                                                as recordkeeping
                                                                                requirements.
                                              SWPPP Tip!
• Consider using informal inspections. Your
  permit outlines the minimum requirements
  for formal inspections that must be
  documented and included in your SWPPP.
  You can also add informal inspections that
  wouldn't require documentation, unless
  of course, a problem is identified. Always
  document any problems you find and those
  that are  identified by staff.

• Consider adding inspections before or even
  during rain events. Many permits require
  inspections of BMPs after rain events. You
  should consider adding inspections before
  or daring predicted rain events. Consult a
  local weather source  and initiate inspections
  before predicted storm events as a way to
  ensure that controls are operational.

• Train staff and subcontractors. Use your staff and subcontractors to help identify any
  potential problems with your BMPs. Again, document any issues that are confirmed
  problems.

EPA recommends that you develop an inspection schedule that meets the needs of
your site. You'll probably also want to update and refine this schedule based on your
experiences, the findings of your inspections, and the changing conditions at your site.
                                            Inspection Guide
                                            The State of Minnesota has
                                            developed a Stormwater
                                            Construction Inspection Guide to
                                            assist municipal site inspectors
                                            in procedures for conducting
                                            a compliance inspection at
                                            construction sites. This guide can
                                            also be useful for construction
                                            operators conducting self-
                                            inspections. Available at
                                            www.pca.state.mn.us/water/
                                            stormwater/stormwatr-c.html

                                                Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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    SWPPP Tip!
  Selecting BMP Inspectors
  A BMP inspection is only as good as the inspector.
  Therefore, it is important to select qualified
  personnel to conduct BMP inspections. The
  SWPPP should identify who has the responsibility
  for conducting inspections. Personnel selected
  to conduct inspections should be knowledgeable
  in the principles and practices of erosion and
  sediment controls, possess the technical skills
  to assess conditions at the construction site that
  could impact stormwater quality, and assess the
  effectiveness of any sediment and erosion  control
  measures selected.
  Several states and other organizations offer
  training that will help prepare inspectors
  to accurately evaluate BMPs, decide when
  maintenance is appropriate, or when a different
  BMP should be substituted. (Several states
  require that sites be inspected by someone that
  the state certifies as a qualified inspector.) One
  national organization offers two certification
  programs that would be useful for personnel
  who are developing and implementing SWPPPs
  and conducting inspections. These certification
  programs are called: "Certified Professional in
  Erosion and Sediment Control (CPESC)" and
  "Certified Professional in Stormwater Quality
  (CPSWQ)." You can find more information  on
  these programs at www.cpesc.org


Inspection Reports
Complete an inspection report after each
inspection. You should retain  copies of all
inspection reports and keep them with or
in your SWPPP. Generally, the following
information is required to be included  in your
inspection report:
•  Inspection date
•  Inspector information, including the
   names, titles, and qualifications of
   personnel conducting the inspection
•  Weather information for the period
   since the last inspection (or for the first
   inspection since commencement of
   construction activity) including a best
   estimate of the beginning of each storm, its
   duration, approximate amount of rainfall
   for each storm (in inches), and whether any
   discharges occurred. You may create a log
   to record the basic weather information or
   you may keep copies of weather information
   from a reliable local source, such as the
   internet sites of local newspapers, TV
   stations, local universities,  etc.
•  Current weather information and a
   description of any discharges occurring at
   the time of the inspection
•  Descriptions of evidence of previous or
   ongoing discharges of sediment or other
   pollutants from the site
•  Location(s) of BMPs that need to be
   maintained
•  Location (s) of BMPs that failed to oper-
   ate as designed or proved inadequate for a
   location
•  Location (s) where  additional BMPs are
   needed but did not exist at the time of
   inspection
•  Corrective action required, including any
   necessary changes to the SWPPP and
   implementation dates
•  Reference to past corrective actions
   documenting follow-up actions taken

Consider taking digital photographs during
inspections to document BMPs, problems
identified, and progress in implementing the
SWPPP.

Appendix B includes an example storm-
water inspection report. You should use this
report, or a similar  report, to document your
stormwater construction site  inspections.
Check to see if your state or local authority
has developed an inspection  checklist for
your use. The inspection report is broken up
into two main sections—site-specific BMPs
and overall site issues. For the site-specific
BMPs, you should number the structural and
non-structural BMPs in your  SWPPP on a
copy of your site map (preferably in the order
in which you would inspect them on the
site). Then as you conduct your inspections,
you can verify whether each  BMP has been
installed and maintained. If a BMP has not
been installed or needs maintenance, describe
this in the  corrective  action section and list
a date for when the corrective action will
be completed and who will be responsible
for completing the action. The overall site
issues section describes 11  common issues at
construction sites you should inspect for.  You
can customize this  form to meet the needs of
your particular situation.

Make sure  each inspection report is signed
and certified consistent with  your permit's
requirements.

Chapter 8,  Section  D  contains more
information on implementing an inspection
program. Also, see the suggested inspection
report form in Appendix B.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites


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    SWPPP Tip!
 Consider More Effective BMPs
 During inspections, consider whether the installed
 BMPs are working effectively. If you find a BMP
 that is failing or overwhelmed by sediment, you
 should consider whether it needs to be replaced
 with a more effective BMP or enhanced by the
 addition of another, complimentary BMP. Ensure
 that you record such changes in your SWPPP and
 on your site  map.
B. BMP Maintenance
Implementing a good BMP maintenance
program is essential to the success of your
SWPPP and to your efforts to protect nearby
waterways. You should conduct maintenance
of BMPs regularly and whenever an
inspection (formal or informal) identifies a
problem or potential issue. For instance, trash
and debris should be cleaned up, dumpsters
should be checked and covered, nearby streets
and sidewalks should be swept daily, and so
on. Maintenance on erosion and sediment
controls should be performed as soon as site
conditions allow. Consider the following
points when conducting maintenance:
• Follow the designers or manufacturer's
  recommended maintenance procedures for
  all BMPs
• Maintenance of BMPs will vary according
  to the specific area and site conditions

• Remove sediment from BMPs as
  appropriate and properly dispose of
  sediment into controlled areas to prevent
  soil from returning to the BMP during
  subsequent rain events

• Remove sediment from paved roadways
  and from around BMPs protecting storm
  drain inlets

• Ensure that construction support activities,
  including borrow areas, waste areas,
  contractor work areas, and material storage
  areas and dedicated concrete and  asphalt
  batch plants are cleaned and maintained

• Replace damaged BMPs, such as silt fences,
  that no longer operate effectively

You should keep a record of all maintenance
activities,  including the date, BMP, location,
and maintenance performed in your  SWPPP.
C. Recordkeeping
You must keep copies of the SWPPP,
inspection records, copies of all reports
required by the permit, and records of all data
used to complete the NOI to be covered by
the permit for a period of at least 3 years from
the date that permit coverage expires or is
terminated.

Records should include:
•  A copy of the SWPPP, with any
   modifications

•  A copy of the NOI and Notice of
   Termination (NOT) and any stormwater-
   related correspondence with federal, state,
   and local regulatory authorities

•  Inspection forms, including the date, place,
   and time of  BMP inspections

•  Names of inspector(s)

•  The date, time, exact location, and a
   characterization of significant observations,
   including spills and leaks

•  Records of any non-stormwater discharges

•  BMP maintenance and corrective actions
   taken at the site (Corrective Action Log)

•  Any documentation and correspondence
   related to endangered species and historic
   preservation requirements
•  Weather conditions (e.g., temperature,
   precipitation)

•  Date(s) when major land disturbing
   (e.g. clearing, grading, and excavating)
   activities occur in an area

•  Date(s) when construction activities are
   either temporarily or permanently ceased
   in an area
•  Date(s) when an area is either temporarily
   or permanently stabilized

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Chapter  T.   Certification  and  Notification
A. Certification

Signature and Certification
The construction site operator must sign the permit application form, which is often
called a Notice of Intent or NOI. (In some instances, the construction general permit
may not require the submission of an NOI or application. Construction activities may
be covered automatically.]

All reports, including SWPPPs and inspection reports, generally must be signed by
the construction site operator or a duly authorized representative of that person.
The authorized representative is typically someone who has direct responsibility
for implementing the SWPPP. If the operator chooses to designate an  authorized
representative, a signed letter or statement to that effect must be included in the
SWPPP. Check your permit for exact requirements.

Your SWPPP must include the signature of the construction site operator or
authorized representative and the certification statement provided in  the general
permit. An example of the certification language from EPA's Construction General
Permit follows:
  "I certify under penalty of law that this document and all attachments were
  prepared under my direction or supervision in accordance with a system designed
  to assure that qualified personnel properly gathered and evaluated  the information
  submitted. Based on my inquiry of the person or persons who manage the
  system, or those persons directly responsible for gathering the information, the
  information submitted is, to the best of my knowledge  and belief, true, accurate,
  and complete. I am aware that there are significant penalties for submitting false
  information, including the possibility of fine and imprisonment for  knowing
  violations."
                                                                                    This chapter
                                                                                    describes how,
                                                                                    after developing
                                                                                    your SWPPP, you
                                                                                    can obtain permit
                                                                                    coverage for
                                                                                    your stormwater
                                                                                    discharges.
This ensures that the SWPPP was developed and reviewed by a
responsible party with the ability to implement the BMPs and
other commitments described in the SWPPP.
Copy of Permit Requirements
Most general permits require you to keep a copy of the
permit and your NOI with your SWPPP. This allows you to
quickly check the permit if a question arises about a permit
requirement.
                                                                SWPPP Tip!
                                                              Posting a sign at the construction
                                                              entrance
                                                              EPA and many state general permits require that
                                                              you post a sign or other notice conspicuously
                                                              near the main entrance of the construction site.
                                                              EPA's permit requires that the sign contain a
                                                              copy of the NOI, the location of the SWPPP, and
                                                              a contact person for viewing the SWPPP.
Other State, Tribal, and Local Programs
Include in your SWPPP a description of any other federal, state,
tribal, or local requirements for erosion and sediment control
and stormwater management that apply to your site. Many local governments also im-
pose erosion and sediment control requirements; your SWPPP should comply with both
the general permit and any applicable local requirements.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites


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  Making your SWPPP available
  While EPA and most states do not require you
  to submit a copy of your SWPPP for review, your
  SWPPP must be available to these and other
  government agencies for inspection. Your permit
  may also require you to make your SWPPP
  available to the public, if requested. If you have
  the ability, you should consider posting your
  SWPPP on the Internet and publicizing the URL.
  Check your permit for exact requirements.
B. Notification
Now that you have developed your SWPPP
and before you begin construction, you
must begin the process of obtaining permit
coverage from your authorized state or EPA.
Authorized states and EPA use general permits
to cover all construction sites. These broadly
written general or umbrella permits apply to
all construction activities in a given state.

Obtaining Coverage Under a General Permit
Important! Before obtaining permit
coverage, you should read a copy of the
appropriate construction general permit and
develop your SWPPP.

To obtain coverage under a state or EPA
construction general permit, you will typically
need to fill out and submit an application
form, often called a Notice of Intent or NOI.
Submitting this form to  the permitting
authority indicates your intent to be
authorized to discharge stormwater under the
appropriate general permit for construction
activities. Depending on the permit, you may
be authorized to discharge immediately or at
some later time. In some cases, you are not
authorized to discharge until the state has
notified you accordingly. EPA's Construction
General Permit requires a 7-day waiting
period after a complete NOI is received and
posted on EPA's website (www.epa.gov/
npdes/noisearch). The waiting period expires
when the permit's status changes from
waiting to active.
Take a Closer Look...
Information on the Application or Notice of
Intent (NOI)
The NOI provides the permitting authority with
pertinent information about your construction
site, such as owner/operator information, site
location, estimated project start and completion
dates, approximate area to be disturbed,
information about your SWPPP, receiving waters,
and endangered species review certification.
An appropriate person who is  authorized to
represent your organization must sign and verify
that the facts contained  in the NOI are true and
accurate.  For businesses, a certifying official is
typically a corporate officer, such as a president,
vice president, or manager of operations. For
municipalities, it's typically a principal executive
officer or ranking elected official. Check your
permit for exact signature requirements.

In general, the only information you need to
submit to the permitting authority is the NOI.
EPA and most authorized state agencies do not
require you to submit your SWPPP for approval.
However,  many  local governments review and
approve at least the erosion and sediment control
component of your SWPPP.


   What does this mean to me?
   There are significant penalties for failing
   to obtain authorization to discharge or
   for submitting inaccurate information. If
   you are the certifying official, make sure
   you are authorized to discharge before
   construction  activities begin.
  SWPPP Tip!
Deadline for submitting NOIs under
EPA's Construction General Permit
For EPA's construction general permit, the
fastest and easiest way to obtain permit
coverage is to use EPA's electronic permit
application system, called "eNOI" at www.epa.
gov/npdes/stormwater/enoi. Using this approach,
you may be authorized to discharge in as little as
7 days after submission of your electronic NOI.
If you choose to submit your NOI by mail, EPA
recommends that you send it at least one month
before you need permit coverage.

                                       Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Chapter  8:  SWPPP  Implementation
A. Train Your Staff and Subcontractors
Your site's construction workers and subcontractors might not be familiar with
stormwater BMPs, and they might not understand their role in protecting local
rivers, lakes and coastal waters. Training your staff and subcontractors in the basics
of erosion control, good housekeeping, and pollution prevention is one of the most
effective BMPs you can institute at your site.

Basic training should include
•  Spill prevention and cleanup measures, including the prohibition of dumping any
   material into storm drains or waterways
•  An understanding  of the basic purpose of stormwater BMPs, including what
   common BMPs are on-site, what they should look like, and how to avoid damaging
   them
•  Potential penalties associated with stormwater noncompliance

Staff directly responsible for implementing the SWPPP should receive comprehensive
stormwater training, including
•  The location and type of BMPs being implemented
•  The installation requirements and water quality purpose for each BMP
•  Maintenance procedures for each of the
   BMPs being implemented
•  Spill prevention and cleanup measures
•  Inspection and maintenance
   recordkeeping requirements
  SWPPP Tip!
                                      Your SWPPP is your
                                      guide to preventing
                                      stormwater pollution.
                                      However, it is just a
                                      plan. Implementing
                                      your SWPPP,
                                      maintaining your
                                      BM Ps, and then
                                      constantly reevaluating
                                      and revising your BMPs
                                      and your SWPPP are
                                      the keys to protecting
                                      your local waterways.
You can train staff and subcontractors
in several ways: short training sessions
[food and refreshments will help increase
attendance), posters and displays explaining
your site's various BMPs, written agreements
with subcontractors to educate their staff
members, signs pointing out BMPs and
reminders to keep clear of them. Every
construction site operator should try to train
staff and subcontractors to avoid damaging
BMPs. By doing so, operators can avoid the
added expense of repairs.
Train your staff and subcontractors!
Here are a few key things you will want to cover with each person
working on your site:
• Use only designated construction site entrances
• Keep  equipment away from silt fences, fiber rolls, and other
  sediment barriers
• Know the locations of disposal areas, and know the proper
  practices for trash, concrete and paint washout, hazardous
  chemicals, and so on
• Keep  soil, materials, and liquids away from paved areas and storm
  drain  inlets. Never sweep or wash anything into a storm drain
• Know the location and understand the proper use of spill kits
• Know the locations of your site's designated protection areas.
  Keep  equipment away from stream banks, valuable trees and
  shrubs, and steep slopes. Clearly mark these areas with signs
• Keep  equipment off mulched, seeded, or stabilized areas. Post
  signs  on these areas, too
• Know who to contact when problems are identified!
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               B. Ensure Responsibility—Subcontractor
                 Agreements
               At any given site, there might be multiple
               parties (developer, general contractor,
               builders, subcontractors) that have roles and
               responsibilities for carrying out or maintaining
               stormwater BMPs at a given site. These roles
               and responsibilities should be documented
               clearly in the SWPPP (see Chapter 2, Section
               D). In some cases (state requirements vary),
               there may be one entity that has developed
               the SWPPP and filed for permit coverage
               and, therefore, is designated as the operator.
               When other parties at a site are not officially
               designated as operators, many operators are
               incorporating the roles and responsibilities
               of these non-operators in the agreements and
               contracts they have with these companies
               and individuals. This contract language
               should spell out responsibilities implementing
               and maintaining stormwater BMPs, for
               training staff, and for correcting damage to
               stormwater BMPs on the site. Several states
               have  stormwater regulations that hold other
               parties liable even if they are not identified as
               the operator.

               C. Implement Your SWPPP Before
                 Construction Starts
               Once you have obtained permit coverage and
               you are ready to begin  construction, it is time
               to implement your SWPPP. You must implement
               appropriate parts of your SWPPP before
               construction activity begins. This generally
               involves installing storm drain inlet protection,
               construction entrances, sediment basins, and
               perimeter silt fences before clearing, grading,
               and excavating activities begin.

               After construction activities begin, your
               SWPPP should describe when additional
               erosion and sediment controls will be installed
               (generally after initial clearing and grading
               activities are complete). You should also begin
               BMP  inspections once clearing and grading
               activities begin.
    SWPPP Tip!
  SWPPP Tip!
Take Photographs During Inspections
Taking photographs can help you document areas that need
maintenance and can help identify areas where subcontractors might
need to conduct maintenance. Photographs can also help provide
documentation to EPA or state inspectors that maintenance is being
performed.
  Prepare for the rain and snowmelt!
  In some areas of the country, construction
  site operators are required to develop weather
  triggered action plans that describe additional
  activities the operator will conduct 48 hours
  before a predicted storm (at least a 50 percent
  forecasted chance of rain). It is also a good idea
  to stockpile additional erosion and sediment
  control BMPs (such as silt fencing, and fiber
  rolls) at the site for use when necessary.
D. Conduct Inspections and Maintain
   BMPs
As mentioned earlier (Chapter 6), EPA
recommends that you develop an inspection
schedule for your site that considers the size,
complexity, and other conditions at your
site. This should include regularly scheduled
inspections and less formal inspections.
EPA recommends that you develop a plan
that includes inspections before and after
anticipated rain events. You might also want
to inspect some BMPs during rain events
to see if they are actually keeping sediment
on site! Conducting inspections during rain
events also allows a construction site operator
to address minor problems before they turn
into major problems.

Temporarily Removed BMPs
BMPs sometimes need to be temporarily
removed to conduct work in an area of the
site. These temporarily removed BMPs should
be noted on the site plan and  replaced as soon
as possible after the completion of the activity
requiring their  removal. If a rain is forecast,
the BMPs should be replaced  as soon as
possible before  the rain event.

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Recommended Inspection Sequence
You should conduct thorough inspections of your site, making sure to inspect all areas and
BMPs. The seven activities listed below are a recommended inspection sequence that will help
you conduct a thorough inspection (adapted from MPCA 2004).
1. Plan your inspection
  0 Create a checklist to use during the
     inspection (see Appendix B)
  0 Obtain a copy of the site map with BMP
     locations marked
  0 Plan to walk the entire site, including
     discharge points from the site and
     any off-site support activities such as
     concrete batch plants should also be
     inspected
  0 Follow a consistent pattern each time
     to ensure you inspect all areas (for
     example, starting at the lowest point and
     working uphill)

2. Inspect discharge points and. downstream,
  off-site areas
  0 Inspect discharge locations to determine
     whether erosion and sediment control
     measures are effective
  0 Inspect nearby downstream locations, if
     feasible
  0 Walk down the street to inspect off-site
     areas for signs of discharge. This is
     important  in areas with existing curbs
     and gutters
  0 Inspect downslope municipal catch basin
     inlets to ensure  that they are adequately
     protected

3. Inspect perimeter controls and slopes
  0 Inspect perimeter controls such as silt
     fences to determine if sediment should
     be removed
  0 Check the  structural integrity of the BMP
     to determine if portions of the BMP need
     to be replaced
  0 Inspect slopes and temporary stockpiles
     to determine if erosion controls are
     effective

4. Compare BMPs in the site plan with the
  construction site conditions
  0 Determine whether BMPs are in place as
     required by the  site plan
  0 Evaluate whether BMPs have been
     adequately installed and maintained
  0 Look for areas where BMPs are needed
     but are missing and are not in the
     SWPPP

5. Inspect construction site entrances
  0 Inspect the construction exits to
     determine if there is tracking of sediment
     from the site onto the street
  0 Refresh or replace the rock in designated
     entrances
  0 Look for evidence  of additional
     construction exits being used that are
     not in the SWPPP or are not stabilized
  0 Sweep the street if there is evidence of
     sediment accumulation

6. Inspect sediment controls
  0 Inspect any sediment basins for sediment
     accumulation
  0 Remove sediment when it reduces the
     capacity of the basin by the specified
     amount (many permits have specific
     requirements for sediment basin
     maintenance. Check the appropriate
     permit for requirements and include
     those in your SWPPP)

7. Inspect pollution prevention and good
  housekeeping practices
  0 Inspect trash areas to ensure that waste
     is properly contained
  0 Inspect material storage and staging
     areas to verify that potential pollutant
     sources are not exposed to stormwater
     runoff
  0 Verify that concrete, paint, and stucco
     washouts are being used properly and
     are correctly sized for the volume of
     wash water
  0 Inspect vehicle/equipment fueling
     and maintenance areas  for signs of
     stormwater pollutant exposure
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Common  Compliance Problems During Inspections
The following are problems commonly found at construction sites. As you conduct your inspections, look for these problems on your site
(adapted from MPCA 2004).
Problem #1—Not using phased grading or providing temporary or permanent cover (i.e., soil stabilization)
  In general, construction sites should phase their grading activities so that only a portion of the site is exposed at any one time. Also,  disturbed areas
  that are not being actively worked should have temporary cover. Areas that are at final grade should receive permanent cover as soon as possible.
Problem #2—No sediment controls on-site
  Sediment controls such as silt fences, sediment barriers, sediment traps and basins must be in place before soil-disturbance activities begin.
  Don't proceed with grading work out-of-phase.
Problem #3—No sediment control for temporary stockpiles
  Temporary stockpiles must be seeded, covered, or surrounded by properly installed silt fence. Stockpiles should never be placed on paved
  surfaces.
Problem #4—No inlet protection
  All storm drain inlets that could receive a discharge from the construction  site must be protected before construction begins and must be main-
  tained until the site is finally stabilized.
Problem #5—No BMPs to minimize vehicle tracking onto the road
  Vehicle exits must use BMPs such as stone pads, concrete or steel wash racks, or equivalent systems to prevent vehicle tracking of sediment.
Problem #6—Improper solid waste or hazardous waste management
  Solid waste (including trash and debris) must be disposed of properly, and hazardous materials (including oil, gasoline, and paint)  must be  prop-
  erly stored (which includes secondary containment). Properly manage portable sanitary facilities.
Problem #7—Dewatering and other pollutant discharges at the construction site
  Construction site dewatering from building footings or other sources should not be discharged without treatment. Turbid water should be filtered or
  allowed to settle.
Problem #8—Poorly managed washouts (concrete, paint, stucco)
  Water from washouts must not enter the storm drain system or a nearby receiving water. Make sure washouts are clearly marked,  sized ad-
  equately, and frequently maintained.
Problem #9—Inadequate BMP maintenance
  BMPs must be frequently inspected and maintained if necessary. Maintenance should occur for BMPs that have reduced capacity  to treat storm-
  water (construction general permits or state design manuals often contain information on when BMPs should be maintained), or BMPs that have
  been damaged and need to be repaired or replaced (such as storm drain inlet protection that has been damaged by trucks).
Problem #10—Inadequate documentation or training
  Failing to develop a SWPPP, keep it up-to-date, or keep it on-site, are permit violations. You should also  ensure that SWPPP documentation  such
  as a copy of the NOI, inspection reports and updates to the SWPPP are also kept on-site. Likewise, personnel working on-site must be trained on
  the basics of stormwater pollution prevention and BMP installation/maintenance.
                 E. Update and  Evaluate Your SWPPP
                 Like your construction site, your SWPPP
                 is dynamic.  It is a document that must be
                 amended to  reflect changes occurring at the
                 site. As plans and specifications change,
                 those changes should be reflected in your
                 SWPPP. If you find that a BMP is not working
                 and you decide to replace it with another,
                 you must reflect that change in your SWPPP.
                 Document in your SWPPP transitions from
                 one phase of construction to the next, and
                 make sure you implement new BMPs required
                 for that next phase.

                Are Your BMPs Working?
                 You should evaluate the effectiveness of your
                 BMPs as part of your routine inspection
process. An informal analysis of both your
inspection's findings and your list of BMP
repairs will often reveal an inadequately
performing BMP. An inspection immediately
after a rain event can indicate whether
another approach is needed.

You may decide to remove an existing BMP
and replace it with another, or you may add
another BMP in that area to lessen the impact
of stormwater on the original installation.

When you update your SWPPP, you can
simply mark it up, particularly for relatively
simple changes and alterations. More
significant changes might require  a rewriting
of portions of the SWPPP.  The site map should
also be updated as necessary.

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Chapter  9:  Final  Stabilization and  Permit
Termination
Stabilize Disturbed Areas
As your construction project progresses, you must stabilize areas not under
construction. EPA and most states have specific requirements and time frames that
must be followed. Generally, it is a wise management practice to stabilize areas
as quickly as possible to avoid erosion problems that could overwhelm silt fences,
sediment basins, and other sediment control devices.
This chapter describes
what you must do
to stabilize your
construction site and
end permit coverage.
  Stabilize as soon as practicable
  EPA's Construction General Permit states that,
  "stabilization measures must be initiated as soon
  as practicable in portions of the site where con-
  struction activities have temporarily or perma-
  nently ceased, but in no case more than 14 days
  after the construction activity in that portion of
  the site has temporarily or permanently ceased."
Temporary stabilization can be achieved through a variety of BMPs, including
mulching, seeding, erosion control blankets, hydroseeding, and other measures.

Permanent or final stabilization of areas on your site is generally accomplished by
installing the final landscape requirements (e.g., trees, grass, gardens, or permanent
stormwater controls). Once the site has been stabilized, you can terminate your
permit coverage.

Sediment controls, such as silt fence, berms, sediment ponds or traps, alone, are not
stabilization measures. You should continue to use these kinds of measures (e.g., silt
fence around an area that has been seeded) until full stabilization is achieved.
A. Final Stabilization
When you have completed your construction
project or an area within the overall project,
you must take steps to permanently and finally
stabilize it. Check your permit for the specific
requirements you must meet. After a project or an
area in the project has been fully stabilized, you
should remove temporary sediment and erosion
control devices (such as silt fences). You might
also be able to stop routine inspections in these
stabilized areas. However, in some  states such as
Colorado, inspections are required  every 30 days
(after the construction has been completed and the
site is stabilized) until permit coverage has been
terminated. In general, you should be aware that
                                                 Figure 16. Seeding is an effective BMP that can be used to temporarily or
                                                 permanently stabilize disturbed areas.
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final stabilization often takes time (weeks
or even months), especially during times of
low rainfall or during the colder months of
the year. You should not discontinue routine
inspections until you have met the final
stabilization requirements in your permit.

EPA and many states define final stabilization
as occurring when a uniform, evenly
distributed perennial vegetative cover with a
density of 70 percent of the native background
cover has been established on all unpaved
areas and areas not covered by permanent
structures. Some states have a higher
percentage of vegetative cover required (e.g.,
New York requires 80 percent). Please review
your state's construction general permit for
specific requirements.

Native vegetation must be established
uniformly over each disturbed area on
the site. Stabilizing seven of  ten slopes, or
leaving an area equivalent to 30 percent of
the disturbed area completely unstabilized
will not satisfy the uniform vegetative cover
standard.

The contractor must establish vegetation over
the entire disturbed soil area at  a minimum
density of 70 percent of the native vegetative
coverage. For example, if native vegetation
covers 50 percent of the undisturbed ground
surface (e.g., in an arid or semi-arid area),
the contractor must establish 35 percent
vegetative coverage uniformly over the  entire
disturbed soil area (0.70 * 0.50 = 0.35 or
35 percent). Several states require perennial
native vegetative cover that is self-sustaining
and capable of providing erosion control
equivalent to preexisting conditions to satisfy
the 70 percent coverage requirement.

In lieu of vegetative cover, you can apply
alternate measures that provide equivalent
soil stabilization to the disturbed soil area.
Such equivalent measures include blankets,
reinforced channel liners, soil cement,
fiber matrices, geotextiles, or other erosion-
resistant soil covering or treatments. Your
construction general permit might allow
all or some of these alternate measures
for equivalent soil stabilization for final
stabilization;  check your general permit.
B. Permit Termination
Once construction activity has been
completed and disturbed areas are finally
stabilized, review your general permit for
specific steps to end your coverage under
that permit. EPA and many states require
you to  submit a form, often called a notice
of termination (NOT), to end your coverage
under that construction general permit. Before
terminating permit coverage, make sure you
have accomplished the following:
•  Remove any construction debris and trash
•  Remove temporary BMPs (such as silt
   fence). Remove  any residual sediment as
   needed. Seed and mulch any small bare
   spots. BMPs that will decompose, including
   some fiber rolls  and  blankets, may be left
   in place
•  Check areas where erosion-control blankets
   or matting were installed. Cut away
   and remove all loose, exposed material,
   especially in areas where walking or
   mowing will occur. Reseed all bare soil
   areas
•  Ensure that 70 percent of background
   native vegetation coverage or equivalent
   stabilization measures have been applied
   for final soil stabilization of disturbed areas
•  Repair any remaining signs  of erosion
•  Ensure that post-construction BMPs are
   in place and operational. Provide written
   maintenance requirements for all post-
   construction BMPs to the appropriate party
•  Check all drainage conveyances and outlets
   to ensure they were  installed correctly
   and are operational. Inspect inlet areas to
   ensure complete stabilization and remove
   any  brush or debris that could clog inlets.
   Ensure banks and ditch bottoms are well
   vegetated. Reseed bare areas and replace
   rock that has become dislodged
•  Seed and mulch or otherwise stabilize any
   areas where runoff flows might converge or
   high velocity flows are expected

•  Remove temporary stream crossings. Grade,
   seed, or re-plant vegetation damaged or
   removed

•  Ensure subcontractors have  repaired their
   work areas before final closeout

You might also be  required to file an  NOT if
you transfer operational control to another

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  Take a Closer Look..
  Is there a deadline to submit an NOT?
  Many states require a Notice of Termination (NOT) or similar form to indicate that the construction phase
  of a project is completed and that all the terms and conditions have been met. This notification informs
  the permitting authority that coverage  under the construction general permit is no longer needed. If your
  permitting authority requires such a notification, check to see what conditions must be met in order
  to submit it and check to see if there is a deadline for
  submission.  EPA's Construction General Permit requires
                  .. _T                                  What does this mean to me?
  that you submit an NOT when you have met all your permit
                                                        Check your permit carefully for details
  requirements. The NOT is due no later than 30 days after       and condjtjons relatjng to terminating
  meeting these requirements.                               your permit coverage.
party before the project is complete. The new
operator would be required to develop and
implement a SWPPP and to obtain permit
coverage as described above.

EPA and most states allow homebuilders to
terminate permit coverage when the property
has been transferred to the homeowner with
temporary or final stabilization measures in
place. If the transfer is made with temporary
stabilization measures in place, EPA expects
the homeowner to complete the final
landscaping. Under these circumstances, EPA
and most states do not require homeowners
to develop SWPPPs and apply for permit
coverage.
C. Record Retention
EPA's regulations specifies that you must
retain records and reports required in the
permit, including SWPPPs and information
used to complete the NOI, for at least
3 years from the termination of coverage or
expiration of the permit. You should also keep
maintenance and inspection records related to
the SWPPP for this same time frame. General
permits issued by states may have a longer
period for retention.
Figure 17. Make sure inlets, outlets, and slopes are well stabilized before leaving
the site and filing your "Notice of Termination" for ending permit coverage.
Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites
                                                           39

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References
American Society of Civil Engineers (ASCE) and Water Environment Federation (WEF).
    1992. Design and Construction of Urban Storrmvater Management Systems

Arendt, R. 1996. Conservation Design for Subdivisons: A Practical Guide to Creating
    OpenSpaceNetworfcs. American Planning AssociationPlannersBookService. Chicago,
    IL.

Claytor, R. 2000. Practical tips for construction site phasing. Article 54 in The Practice of
    Watershed Protection. Center for Watershed Protection, Ellicott City, MD, pp. 317-322.

Dunne, T. and L. Leopold. 1978. Water and Environmental Planning.

Environmental Protection Agency (EPA). 1993. Guidance Specifying Management
    Measures for Sources of Nonpoint Pollution in Coastal Waters. 840-B-92-002. Office
    of Water. Washington, DC.

Maryland Department of the Environment (MDE). 2000. Maryland Stonmvater Design
    Manual: Volumes 1 and2. Maryland Department of the Environment, Baltimore, MD.
    < www.mde.state.md.us/environment/wma/stormwatermanual >

Minnesota Pollution Control Agency (MPCA). 2004. Stormwater Construction Inspection
    Guide. 

National Arbor Day Foundation. No date. The Value of Trees to a Community.
    < www.arborday.org/trees/Benefits.cfm >

Natural Resources Conservation Service (NRCS). 2000.1997 National Resources Inventory
    Summary Report.
    

Natural Resources Conservation Service (NRCS). 2006. National Resources Inventory 2003
    Annual NRI - Soil Erosion.
    < http ://www.nrcs.usda.gov/Technical/land/nri03/SoilErosion-mrb.pdf >

Robertson, B., R. Pitt, A. Ayyoubi, and R. Field. 1995. A Multi-Chambered Stormwater
    Treatment Train. In Proceedings of the Engineering Foundation Conference:

Stormwater NPDES-Related Monitoring Needs, Mt. Crested Butte, Colorado, August 7-12,
    1994, American Society of Civil Engineers, New York, NY.

Terrene Institute. 2001. Landscapedraingardens offer Stormwater control. Nonpoint Source
    News-Notes 66:18-20.
Acknowledgements
The graphics used in this guide were developed by Tetra Tech, Inc. for the Kentucky
Divison of Water's Erosion and Sediment Control Field Guide.
40                                                 Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Appendix A:   SWPPP Template
An electronic copy of the SWPPP template is available on EPA's web site at:
http://www.epa.gov/npdes/swpppguide
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Appendix B:   Sample Inspection  Report
An electronic copy of the sample inspection report is available on EPA's web site at:
http://www.epa.gov/npdes/swpppguide
42                                    Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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Appendix  C:   Calculating the  Runoff  Coefficient
The following information is largely taken from EPA's 1992 guidance Storrmvater
Management for Construction Activities: Developing Pollution Prevention Plans and Best
Management Practices (EPA 832-R-92-005).

It is important to estimate your development's impact on runoff after construction is
complete. This can be done by estimating the runoff coefficient for pre- and post-construction
conditions. The runoff coefficient ("C" value) is the partial amount of the total rainfall
which will be come runoff. The runoff coefficient is used in the "rational method" which is:

       Q  =  CiA,

       Where Q  = the rate of runoff from an area,
              i = rainfall intensity, and
              A  = the area of the drainage basin.

There are many methods which can be used to estimate the amount of runoff from a
construction site. You are not required to use the rationale method to design stormwater
conveyances or BMPs. Consult your State/local design guides to determine what methods to
use for estimating design flow rates from your development.

The less rainfall that is absorbed (infiltrates) into the ground, evaporates, or is otherwise
absorbed on site, the higher the "C" value. For example, the "C" value of a lawn area is 0.2,
which means that  only 20 percent of the rainfall landing on that area will run off, the rest
will be absorbed or evaporate. A paved parking area would have a "C" value of 0.9, which
means that 90 percent of the rainfall landing on that area will become runoff. You should
calculate the runoff coefficient for conditions before construction and after construction is
complete. It is suggested that a runoff coefficient be calculated  for each drainage basin on
the site. The following is an example of how to calculate the "C" value.

The runoff coefficient or "C" value for a variety of land uses may be found in Table C-l
(NOTE: Consult your State/local design guide, if available, to determine if specific "C"
values  are specified for your area). The "C" values provide an estimate of anticipated runoff
for particular land uses. Most sites have more than one type of land use and therefore more
than one "C" value will apply. To have a "C" value that represents your site you will need to
calculate a "weighted C value."

Calculating  a "Weighted C value"
When a drainage area contains more than one type of surface material with more than
one runoff coefficient a "weighted C" must be calculated. This  "weighted C" will take
into account the amount of runoff from all the various parts of the site. A formula used to
determine the "weighted C" is as follows:
       C  = A,C, +  A2C2 + ... + AxCx
              (A1 + A2 + ... + Ax)

       Where A = acres and C = coefficient.

Therefore, if a drainage area has 15 acres (ac.) with 5 paved acres (C =  0.9), 5 grassed
acres (C = 0.2), and 5 acres in natural vegetation (C = 0.1), a "weighted C" would be
calculated as follows:
C  =  (5 ac x 0.9) + (5 ac x 0.2) + (5 ac x 0.1) = 0.4
               (5 ac  +  5 ac + 5 ac)
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Table C-l.  Typical "C" Values
Description of Area
Business
Downtown Areas
Neighborhood Areas
Residential
Single-family areas
Multi-units, detached
Multi-units, attached
Residential (suburban)
Apartment dwelling areas
Industrial
Light Areas
Heavy Areas
Parks, cemeteries
Playgrounds
Railroad yard areas
Unimproved areas
Streets
Asphalt
Concrete
Brick
Drives and Walks
Roofs
Lawns - course textured soil (greater than 85% sand)
Slope: Flat, 2%
Average, 2-7%
Steep, 7%
Lawns - fine textured soil (greater than 40% clay)
Slope: Flat, 2%
Average, 2-7%
Steep, 7%
Runoff Coefficients
0.70 - 0.95
0.50-0.70
0.30-0.50
0.40 - 0.60
0.60-0.75
0.25-0.40
0.50-0.70
0.50-0.80
0.60-0.90
0.10-0.25
0.20-0.35
0.20-0.40
0.10-0.30
0.70 - 0.95
0.80-0.95
0.70-0.85
0.75-0.85
0.75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
0.13-0.17
0.18-0.22
0.25-0.35

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Appendix  D:   Resources  List
The following are just a few of the many resources available to assist you in developing your SWPPP.
The inclusion of these resources does not constitute an endorsement by EPA.

EPA Resources

EPA Stormwater Construction Website
    http://www.epa.gov/npdes/stormwater/construction
     •  EPA's Construction General Permit (http://www.epa.gov/npdes/stormwater/cgp]
       EPA's general permit that applies to all construction activity disturbing greater than one acre in
       the states and territories where EPA is the permitting authority.

     •  Construction SWPPP Guide, SWPPP Template and inspection form
       [www.epa.gov/npdes/swpppguide]
       A downloadable copy of this guide,  the SWPPP template and inspection form.

     •  Menu of BMPs (http://www.epa.gov/npdes/stormwater/menuofbmps]
       Site containing over 40 construction BMP fact sheets. Also contains fact sheets on other
       stormwater program areas, and case studies organized by program area.

National Management Measures to Control Nonpoint Source Pollution from Urban Areas
    http://www.epa.gov/owow/nps/urbanmm/index.html

Managing  Your Environmental Responsibilities: A Planning Guide for Construction and Development
    http://www.epa.gov/compliance/resources/publications/assistance/sectors/constructmyer/
    index.html

Expedited  Settlement Offer Program for Stormwater (Construction]
    http://www.epa.gov/Compliance/resources/policies/civil/cwa/esoprogstormwater.pdf
    A supplemental program to ensure consistent EPA enforcement of stormwater requirements at
    construction sites for relatively minor violations.

Construction Industry Compliance Assistance
    http ://w w w. cicacenter. org
    Plain language explanations of environmental rules for the construction industry. Links to
    stormwater permits and technical manuals for all 50 states.


Smart Growth and Low  Impact Development Resources
Using Smart Growth Techniques as Stormwater Best Management Practices
    http://www.epa.gov/livablecommunities/pdf/sg_stormwater_BMP.pdf

Stormwater Guidelines for Green, Dense Development
    http://www.epa.gov/smartgrowth/pdf/Stormwater_Guidelines.pdf

Protecting  Water Resources with Smart Growth
    http://www.epa.gov/smartgrowth/pdf/waterresources_with_sg.pdf

Parking Spaces / Community Places: Finding the Balance Through Smart Growth Solutions
    http://www.epa.gov/smartgrowth/parking.htm

EPA Nonpoint Source Low Impact Development site
    http://www.epa.gov/owow/nps/lid/

Better Site  Design: A Handbook for Changing Development Rules in Your Community
    Available from http://www.cwp.org


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State BMP/Guidance Manuals
Kentucky Erosion Prevention and Sediment Control Field Guide
    http://www.water.ky.gov/permitting/wastewaterpermitting/KPDES/storm/
    Easy to read field guide describing erosion and sediment control BMP selection, installation and maintenance.

Minnesota Stormwater Construction Inspection Guide
    http://www.pca.state.mn.us/publications/wq-strm2-10.pdf
    A manual designed to assist municipal construction inspectors in the procedures for conducting a compliance
    inspection at construction sites.

California Stormwater Quality Association's Construction Handbook
    http://www.cabmphandbooks.org/Construction.asp

Delaware Erosion and Sediment Control Handbook
    http://www.dnrec.state.de.us/dnrec2000/Divisions/Soil/Stormwater/StormWater.htm

Western Washington Stormwater Management Manual - Volume II - Construction Stormwater Pollution
    Prevention
    http://www.ecy.wa.gov/programs/wq/stormwater/manual.html

Eastern Washington Stormwater Management Manual
    http://www.ecy.wa.gov/biblio/0410076.html
    A guidance document addressing Stormwater design and management in more arid climates.

Certification Programs
Certified Professional in Erosion and Sediment Control
    http://www.cpesc.org

Virginia Erosion and Sediment Control Certification Program
    http://www.dcr. virginia.gov/sw/estr&crt2.htm

Florida Stormwater, Erosion and Sedimentation Control Inspector Certification
    http://www.dep.state.fl.us/water/nonpoint/erosion.htm

Other Resources
International Erosion Control Association
    http://www.ieca.org
    A non-profit organization helping members solve the problems caused by erosion and its byproduct—sediment.

Erosion Control Magazine
    http ://w w w. erosioncontr ol. com
    A journal for erosion and sediment control professionals.

Designing for Effective Sediment & Erosion Control on Construction Sites by Jerald S. Fifield, PH.D., CPESC.
    Available from Forester Press
    http://www.foresterpress.com
    Book describing proven and practical methods for minimizing erosion and sedimentation on construction sites.

Stormwater Permitting: A Guide for Builders and Developers by National Association of Home Builders (NAHB).
    Available from NAHB http://www.nahb.org
46                                                  Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites

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