Elements of Effective Erosion and Sediment Control Programs
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1 Elements of Effective Erosion and Sediment Control Programs Michael E. Novotney, P.E. Baxter & Woodman, Inc. May 25, 2010 Strategies for Compliance with NPDES Stormwater Regulations Workshop Moline, IL
2 Why is Erosion and Sediment Control Important? Purdue University, Planning with Power Project US Army Corps of Engineers, Buffalo District US Army Corps of Engineers, Buffalo District
3 Source: Schueler and Lugbill, 1990
4 Why is Erosion and Sediment Control Important? 1. ESC reduces runoff volumes, sediment loads and downstream flooding 2. ESC helps mitigate t the impacts of land disturbing activities: 1. Environmental impacts 2. Economic impacts 3. ESC is required(!): 1. Construction Stormwater Program 2. Municipal Separate Storm Sewer System (MS4) Program
5 Top Excuses for NOT doing Top Excuses for NOT doing Erosion and Sediment Control
6 8. The city/county/my brother was supposed to do it
7 7. The water was ponding; it never worked right
8 6. I am working there tomorrow
9 5. It hasn t rained
10 4. It s not me, it s the farmer next door
11 3. The site is flat; there is no runoff
12 2. I just can t afford it Elm Place Avenue For a 1/4 acre lot: -$600 seed & mulch -$ /lot sed. basin -$90/dewatering filter bag -$27/100 ft. silt fence -$100/catch basin - If used all, several times, still < 1% of cost
13 1. The developer is on the run from the FBI
14 Summary of MS4 General Permit Erosion and Sediment Control Requirements DE Department of Natural Resources and Environmental Control
15 Illinois MS4 General Permit Re-issued: February 20, 2009 Develop, implement and enforce a program to reduce pollutants t in stormwater t runoff discharged to your MS4 from construction activities that disturb > 1acre Also from activities disturbing < 1 acre if part of a larger common plan of development (e.g., subdivision)
16 Illinois MS4 General Permit Local ordinance w/ penalties to ensure compliance Requires appropriate erosion and sediment and nonsediment waste controls Requires creation of stormwater pollution prevention plans Site plan review procedures Site inspection & enforcement procedures Receipt & consideration of information submitted by public
17 Developing an Effective Erosion and Sediment Control Program DE Department of Natural Resources and Environmental Control
18 Audience Quiz Where is your community at with its erosion and sediment control program? A) What program? B) Just getting g started C) Have an ordinance in place, but need some help expanding the program D) Doing well - have addressed all of the requirements outlined in the MS4 Permit
19 Challenges You ve Faced Name some of the biggest challenges you have encountered with your local erosion and sediment control program
20 Erosion and Sediment Control: The Reality Implementation can be difficult Local Stormwater Manager Local ESC Program
21 Overcoming the Challenges: Developing a Local ESC Program The 8 Components of Highly Effective Programs: Local Ordinance Erosion and Sediment Control Plan Requirements Plan and Approval Review Process Preconstruction Meetings Inspection Programs Training and Certification Programs Enforcement Tools Demonstration Projects
22 1. Local Ordinance Include Language to Ensure Authority Applicability and exemptions Erosion and sediment control plan requirements Design/performance criteria Acceptable ESC and waste control practices, with reference to a technical manual Measures to protect natural resources such as streams and wetlands Flexibility to change the plan in response to field conditions Plan review and approval process Submittal requirements Authority for inspectors to make regular inspections at construction sites Enforcement measures to ensure compliance
23 2. ESC Plan Requirements Include Elements of Effective ESC Plans Check Requirements of NPDES Construction General Permit
24 Erosion and Sediment Control Plans Can have different names: Stormwater Pollution Prevention Plan (SWPPP) Construction Site Best Management Practices Plan Erosion, Sedimentation and Pollution Prevention Plan Sediment and Stormwater Plan Construction Best Management Practices Plan Etc.
25 Comprehensive guidance on developing Stormwater Pollution Prevention Plans Use with NPDES construction general permit requirements Provides site operators with useful guidance and template
26 Erosion Control Erosion E i control prevents the suspension of soil in stormwater runoff Primary line of defense 1. Minimize clearing and protect natural resources 2. Phase construction activities to limit exposure 3. Promptly stabilize soils (i.e., within 7 days) 4. Protect drainageways and slopes
27 1. Minimize Clearing/Protect Natural Resources
28 2. Phase Construction
29 3 Stabilize Soils 3. Stabilize Soils Hydroseeding: Note the thickness!
30 4. Stabilize Drainageways Apron Check Dam
31 4 Protect Slopes 4. Protect Slopes Erosion Control Blankets
32 Sediment Control Sediment S t Control removes soil once it becomes suspended in stormwater runoff Secondary line of defense 5. Establish perimeter controls (e.g., silt fence) 6. Protect storm drain inlets 7. Use settling devices (e.g., sediment basins) 8. Stabilize construction entrances
33 5 Perimeter Controls 5. Perimeter Controls Silt Fence: Drainage area is too large!
34 5 5. Perimeter Controls Silt Fence: Poorly located!
35 5 5. Perimeter Controls Silt Fence: Poorly installed!
36 6 Protect Storm Drain Inlets 6. Inlet Protection I l t th d nott drain d i tto a sediment di tb i / d Inlets thatt do basin/pond Cannot be the only sediment control due to low efficiency Field/Yard Inlet Protection Curb Inlet Protection
37 6 Protect Storm Drain Inlets 6. Inlet Protection Block & Gravel Inlet Protection Proprietary Products
38 7 7. Settling Devices Silt Fence vs. Sediment Basin/Pond
39 7. Settling Devices Sediment Basins/Ponds 2 cells are often more effective than 1
40 8 Stabilize Construction Entrances 8. Control Off-Site Tracking
41 Non-Sediment Pollutant Control Stormwater Pollution Prevention Plan should also address non-sediment pollution Wastewater discharges Concrete truck or paint pan washout Leachate and liquid waste spills Waste disposal Dispose in dumpsters s No open burning Material storage Fuel tanks within secondary containment Locate stockpiles, drums, containers, etc. indoors/in trailers/away from drainageways and storm drain inlets
42 Non Sediment Pollutant Control Non-Sediment Wastewater Discharges
43 Non-Sediment Pollutant Control Waste Disposal No open burning of waste Do not bury wastes on site Provide a covered dumpster for disposal of construction debris
44 Non-Sediment Pollutant Control Material Storage Leaking lift and fuel tank near pond Secondary containment Spills should be cleaned up when they occur
45 3. Plan Review and Approval Process Make it an Effective Process Discuss ESC in predesign meeting Provide a plan review checklist Promotes consistency during the review e process Helps designers focus on the plan requirements Helps reviewers identify what is missing Ensure plan includes all important elements (short and long term)
46 General Submittal Requirements Information that should be included in a plan submittal: Vicinity map Project description Maintenance and inspection information Clearing & grading plan Location of post-construction Limits of disturbance stormwater BMPs Surface water locations Pollution source control Sensitive areas practices (non-sediment) Soils information Erosion control measures Location of sediment control practices Detail drawings
47 What Should Reviewers Look For? Stormwater Pollution Prevention Plan Did they show limits of disturbance? Are drainage areas delineated & acreage given? Is a narrative provided? Are drawings and specifications provided for all BMPs? Are BMPs site specific? Do BMPs address all phases of construction, ti not just final grade? Does it include non-sediment pollution control BMPs? Who will inspect and maintain each control?
48 4. Preconstruction Meetings Check Relationship Between Plan and Site Before any clearing & grading can begin Contractor, project engineer, inspector & plan reviewer walk the site Walk through may consider: Identifying sensitive areas Delineating limits of disturbance Ensuring all sediment control measures are installed Field changes to plan We should have had a preconstruction meeting!
49 5. Inspection Program Ensure Controls are Working Assess development sites routinely and after storms Prior to construction Routinely (every 7 days) Within 24 hours after a storm event 1/2 or greater Final site inspection Maintain a record of all inspections on site Inspection reports should be both descriptive & prescriptive
50 Inspection Requirements When to inspect Once every 7 days Within 24 hours of a 0.5-inch rainfall Areas to inspect Walk the site perimeter and note areas where sediment is leaving the site All BMPs to assure that t they have been installed as the SWP3 specified, built correctly, and are functional and appropriate Areas where construction vehicles access the site Water resources on the site or which flow through the site Document results!
51 Descriptive vs. Prescriptive Descriptive Writing Describes a situation Provides details and tells a story Prescriptive Writing Describes a situation Prescribes a solution to the problem
52
53 Descriptive vs. Prescriptive Descriptive Slope is not properly stabilized and is eroding. Prescriptive Slope needs to be re-graded, topsoiled and stabilized in accordance with the approved plan. Use straw/coconut erosion control matting as specified on the plan. Complete this work by 10/15/05.
54 Increasing Inspection Capacity Prioritize sites for inspection Watershed Size Track Record Season Use standard inspection checklists/reports Require self-inspections Coordinate erosion and sediment control inspections with building inspections Consider using private inspectors Establish s watchdog hotline
55 6. Training and Certification Programs Need Better Training for Designers and Contractors?
56 6. Training and Certification Programs Increase Local Technical Capacity Objectives Train designers, contractors and inspectors to ensure better plan design and implementation Techniques Formal certification/licensing programs (state, private) Attend training, take exam & receive official certification Regular re-certification required Pre-construction meeting and site inspections Local design/installation workshops Tie certification to particular program elements
57 Training and Certification Programs Example: Delaware Sediment & Stormwater Program State t requires a Certified Construction ti Reviewer (CCR) to provide inspection duties; State provides certification CCR must become familiar with site plan Reports prepared by CCR on weekly basis ESC controls must be in accordance with approved plan and design guidelines Non-compliance must be reported to State State pursues enforcement actions and has ability to revoke certification
58 7. Enforcement Tools Ensure Controls Continue to Work Tied into local ordinance Examples: Written warning with voluntary compliance Written notice of violation ordering compliance Civil penalties Performance bonds Criminal prosecution Compensatory action Cost of abatement of the violation/property liens Stop work order Withhold building permits/certificates % of fees and fines should go back into program
59 Civil Penalties Specified in code Civil fines for specified violations (like a traffic ticket) Requires trained inspection staff to determine when fines should be levied PROS Effective compliance Easier to apply than criminal penalties CONS Political will needed Need control of renegade inspectors Need enough inspectors to document conditions at sites Judges not always sympathetic
60 Performance Bonds Financial surety posted prior to plan approval and/or grading permit Motivator for compliance Usually required in code Allows program authority to cash bond & conduct work if applicant is not in compliance PROS Economic incentive for compliance Good complement to other enforcement tools CONS Administrative burden (compute bonds, inspections, database) Politically & administratively difficult to cash bonds & perform work Bonds need a life span
61 8. Demonstration Projects Set a Good Example Use municipal projects to demonstrate good/innovative practices Illustrate the use, design, installation and maintenance of erosion and sediment control practices Incorporate into local training program PROS Non-threatening, but convincing Allows local l government to set good example and high bar Good outreach potential Grants/funding available CONS Temporary technique Risk factor some projects fail (or don t turn out quite right) Only one piece of the puzzle
62 Helpful Tips 1. Have committed local leadership 2. Re-deploy existing plan review staff from office to field (or training i room) 3. Cross train local development review and inspection staff 4. Require early (pre-design) discussion of erosion and sediment control 5. Prioritize inspections
63 Helpful Tips 6. Require designer to sign off on initial installation of ESC practices 7. Invest in designer, contractor t and inspector training and certification programs 8. Enlist the talents of developers and engineering consultants 9. Reinvent the ESC manual 10.Borrow from existing programs Any others?
64 Contact Information Michael E. Novotney, P.E. Water Resources Engineer Baxter & Woodman, Inc. 39 S LaSalle Street, Suite 816 Chicago, IL P: (312) E: mnovotney@baxterwoodman.com
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