Documentation is an essential part of any company’s stormwater management program. It serves as proof that you have met all legal requirements.
In the case of an audit or incident, government inspectors will want to see your documentation of continuous compliance throughout construction (as opposed to a snapshot of the site’s compliance status, based on visual observations of site conditions made on the date of the inspection).
NO RECORD = IT DIDN’T HAPPEN!
U.S. EPA recently updated its Stormwater Pollution Prevention Plan (SWPPP) “template” to comply with the new and more detailed stormwater control “limits” required by EPA’s Dec. 2009 Effluent Limitations Guidelines (ELG) rule. In addition, at U.S. EPA’s invitation, AGC’s Environmental Forum Steering Committee members have worked with Agency staff to develop customizable “templates” to help contractors document the site inspections and corrective actions required by both federal and state Construction General Permits.
Take notice and get prepared: EPA’s 2012 CGP (which serves as a model for the nation) includes new provisions that—
AGC and EPA have teamed up to present a webinar on Dec. 18 to show AGC contractors how to use the Agency’s new “template” documents to keep their projects in compliance.
It is a legal REQUIREMENT to have a SWPPP on every single project! It should include written records of your site inspections and the follow-up “BMP” maintenance and corrective actions taken at the jobsite.
A company that has adequate documentation showing a history of compliance with stormwater requirements can avoid unpleasant inspections, enforcement actions, and devastating penalties of up to $37,500 per day per violation.
Environmental Scientist, Water Permits Division, U.S. Environmental Protection Agency
Erika Farris is an Environmental Scientist in the Water Permits Division at EPA Headquarters. Erika is part of EPA’s stormwater team, and works on EPA’s Construction General Permit (CGP), EPA's Multi-Sector General Permit (MSGP), and the National Stormwater Rulemaking. Erika earned her MA degree in Urban Affairs and Public Policy (2009) and BS degree in Natural Resource Management (2006) from the University of Delaware.
CPESC, QSP/QSD, Storm Water Pollution Prevention Inspector at Vali Cooper & Associates
Over ten years experience working on public works and infrastructure projects, including roles in construction management, quality assurance, contract administration, and environmental compliance.
Bridget Supple’s background in enforcement of California environmental regulations (Regional Water Quality Control Board, State Water Board Division of Water Rights, California Coastal Commission) and as a consultant to organizations (such as the California Department of Transportation, various cities, and PG&E) gives her a unique perspective on the common pitfalls many contractors fall into when being investigated for possible violation of stormwater regulations. Most contractors are unprepared for a visit from regulatory authorities and lack a strategy to establish a solid defense that can quite effectively quell any potential enforcement efforts. With just a little bit of preparation and effort to keeping documentation of stormwater compliance activities, contractors can drastically reduce their potential for getting into trouble.
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