In the world of storm water there are many opinions, acronyms and so called professionals, but I believe it is our job as consultants to remove our opinions and base are recommendations on the regulations (facts) and enforcement experience.
Which leads me into the facts of SWPPP preparation. SWPPP or SWP3 stands for storm water pollution prevention plan. It is also known in some parts of the country as Storm Water Management Plan (SWMP) or Erosion Control Plan (ECP) . The later of the three (ECP) is very confusing, because most civil drawings have an ECP, but as you will read below, it will not meet the requirements set forth by the EPA in the Clean Water Act. I thought it would be naive on my part to assume everyone understands this acronym because the law has been passed for well over a decade on the requirements of having a SWPPP, but each week I find myself engaged in the elementary education of storm water compliance.
If I may, let me first start with what is not a SWPPP….a SWPPP is not one or two sheets labeled in a set of civil engineering plans titled SWPPP or Erosion Control Plan. If one was to be literal then yes, this could be classified as a SWPPP, but it would be important to note, this SWPPP would be grossly deficient. A SWPPP is not a copy of the state regulations with a bit of jargon addressing the BMPs used on-site and a map stuffed in a 3 ring binder. Even though this may seem to be common sense to many of us who have been in the market a while, I am still amazed at how many civil engineers, general contractors and even city officials who still don’t understand this portion of the Clean Water Act.
Most SWPPPs are a one or two inch binder containing the exact plan for preventing pollution from leaving your site when it rains. It will cover the plan of action for every phase (clearing, grading, paving, vertical construction, etc.) and also lay out the exact details of which Best Management Practices (BMP) will be used during each phase. The SWPPP has pages in it that must be executed by an officer of the company (delegation letter, Notice of Intent, etc.) and once it reaches the site, the SWPPP supercedes the drawing in the civil plans titled erosion control plan. In fact, I am actually confused on why ECP’s are still in the requirements, but that is a conversation for another day….
Let me end my posting with providing you a link to the EPA’s website for understanding storm water compliance. They are the best source to ask and don’t be fooled by someone calling themselves a consultant. Our industry has yet to set forth a formal education process and the field is full of “quick start ups” who think they can be Storm Water Consultants. There is an enromous amount of liability tied to storm water compliance, so be sure you have done your research on your consulting or SWPPP preparer.
http://cfpub.epa.gov/npdes/stormwater/swbasicinfo.cfm
Josh Phillips, CESSWI
4 Comments
I agree that the SWP3 is an important aspect of compliance and needs to be developed with care to make sure that the items within this document are the actions that are going to be fulfilled on the poject. It is important to make sure that you read the SWP3 if it is being developed by another person or firm for accuracy. I have been on many sites where my SWP3 stated something that I was not willing to perform due to company protocol, cost, or not required by the general permit. Choose a quailty company to make sure that your SWP3 is properly assembled so you do not have to worry about false information and make sure that you communicate all important site data with that company. Communication, Knowledge and Follow Through is key to compliance with the SWP3 or BMP management.
I was a builder for a large home building company and I can attest that a SWPPP needs to be constructed properly to keep the inspectors happy when they step on your job site. If it is not written right then the inspection is extended and there is a bigger chance for potential fines. Your SWPPP is important!
Joe,
Thanks for your input. If you have any other topics of interest please feel free to submit some suggestions or even write some thoughts yourself.
Have a good week.
Josh Phillips
A SWPPP is the begining of your Stormwater Compliance process. The SWPPP informs you, enforcement officers, trades, and managers of what needs to be done to stay in complaince over the duration of the project. The SWPPP is where you get your information for permitting, inspecting, and to find out who is responsible for performing the corrective actions. I to belive that a site specific detailed SWPPP is one of the most important parts of a sucessful stormwater program.