Construction Site Inspection. Inspecting to Keep You in Compliance



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Construction Site Inspection Inspecting to Keep You in Compliance

Inspection/Monitoring/Reporting Know if your plan is working Document corrective actions Ketchikan

A Contractor that destroys their site & soils destroys their profits. Slope Stabilization or Flow Management? Barrow

Monitoring ~ Reporting ~ Recordkeeping Permit Compliance Adaptive Management Analysis Risk Management Anchorage

BMP Inspection & Monitoring for Permit Compliance Visual Inspections How, what & where do you inspect Who does inspections Records & Reporting

Qualified Person Inspections must be conducted by a qualified person. Sets a high bar for qualifications ESC Supervisor ESC Monitor Environmental Monitor Anchorage

Certified Erosion & Sediment Control Lead ESC Supervisor Site Inspectors must be Qualified CESCL s may be considered qualified (unless you demonstrate otherwise) CESCLs must be trained by an approved program. (two certified inspectors may be necessary) CESCLs are decision-makers in the project process. CESCLs inspect BMPs & construction areas

ESC Monitor Langley BYLAW 2006 NO 4381 Identified in a letter of appointment During the ESC Permit Application phase Must immediately report failures & Maintenance needs to Owner Must immediately report Permit Violations To the Township of Langley Must maintain a log book

ESC Supervisor Abbotsford BYLAW NO 1989-2010 Identified on the ESC Submission form Responsible for ESC Facilities: Inspection Maintenance Monitoring Must maintain a log book documenting inspections Kongiganak

Inspections Document the procedures for performing site inspections specified by Bylaws, and where necessary, taking corrective actions. Document the following: Person responsible for conducting site inspections; Schedules to be followed for conducting inspections; Any inspection checklist or form that will be used; How corrective action will be addressed. A record of each inspection and of any corrective actions taken must be retained and made available for review.

INSPECTIONS BYLAW 2006 4381 Inspection Frequency Minimum once per week or after each Significant Rainfall Event* whichever is greater *25 mm in a 24 hour period ANC

Average & Extreme Events 25 mm

Probability of 25mm Precipitation

It s been raining everyday for the last week. How many inspections should I have? POP QUIZ Is the truck a permitted discharge?

Inspection Frequency ESC Supervisor Responsibilities Once per week & within 24hrs of significant rain* * 25mm per day Seasonal Variations During extended dry periods, (May-September) Monthly and within 24hrs after significant rainfall Inactive Sites Bi-Weekly (with approval) Requires adequate BMP s and good performance Anchorage

Inspection Frequency: BYLAW NO. 6410-2006 Sch. A Once per day in rainy season (Oct 15-May 15) During significant rainfall* Submit records Bi-Monthly during rainy period Monthly during dry season (May 16-Oct 14) * 25mm per day or 10mm per hour Takotna

Scope of site inspection, 2011 ACGP 6.4.1 Inspect the following : Areas disturbed by construction activity Areas used for storage of materials that are exposed to precipitation Areas where control measures are installed and maintained, BMP s Areas where pollutants have accumulated and may enter storm water Locations where vehicles enter or exit the site; Areas where storm water typically flows; Points of discharge from the site. Portions of the site where stabilization measures have been initiated.

Scope of Inspection Check whether all control measures are installed and operating as intended and determine if any control measures need to be replaced, repaired or maintained Barrow

Scope of Inspection Check for the presence of accumulated sediment near the project area boundary that has a potential for being washed outside of the project boundary on locations such as roadways or parking lots, storm water conveyance systems, storm drain inlets, and discharge points

Scope of Inspection Check for the evidence of, or the potential for spills, leaks, or other accumulations of pollutants on the site entering the storm water conveyance system or water bodies.

Scope of Inspection Describe visible areas where erosion has occurred near the project area boundary that has a potential for being washed outside of the project boundary North Pole

Scope of Inspection Identify any locations where new or modified control measures are necessary to meet the requirements of the Bylaws & Permits

Scope of Inspection Identify all points that discharge from the site and describe the conditions that are contributing to that discharge.

Scope of Inspection Any incidents of noncompliance observed and corrective actions taken.

Make Sure Your Inspection Forms Meet All Your Permit & Contract Requirements!

Inspection Report At a minimum, the inspection report should include: The inspection date; Names, titles, and qualifications of personnel conducting the inspection;

Abbotsford example report

Good site inspectors know the weather information for the period since the last inspection including a general estimate of the beginning day of each storm event, duration of each storm event, and whether any discharges occurred.

Rainfall for Surrey 2009-September 2011 300 290 280 270 260 250 240 230 220 210 200 190 180 170 160 150 140 130 120 110 100 90 80 70 60 50 40 30 20 10 0 Total Rainfall (mm) No. Days >25mm of Rainfall Very few days Above 25mm

Report Location(s) of discharges of sediment or other pollutants from the site; Ft. Yukon

Describe location(s) of control measures that need to be maintained; Emmonak

Identify location(s) where additional control measures are needed that did not exist at the time of inspection; and maintenance required, if any.

The inspection report must be signed in accordance with Bylaws.

MONITORING Water quality must be recorded in the logbook during every inspection: Develop a monitoring plan Obtain representative samples

25 NTU Standard limit 100 NTU after significant event TSS must be below 75mg/L Excessive Turbidity = 20 NTU 25 mg/l Dry weather 75mg/L Wet season

25 NTU 250 NTU Way Over 1000 NTU

Turbidity Meter Measures in NTU s Nephelometric Turbidity Units

Sample analysis Portable Turbidimeter Kits

ph Meter MULTIPLE PARAMETERS ph & EC ppm, ph & EC

All testing data obtained under the monitoring program must be forwarded to the city within 1 week.

Corrective Action Conditions Take corrective actions when, Control measures are not designed, installed and/or maintained as required by ESC plans. Conditions triggering the need for corrective action include: A required control measure was never installed, or installed incorrectly; control measure is not operating as intended or is ineffective. Anchorage

ESC Supervisor Responsibilities Homer Deficiencies identified during site inspections are to be mitigated as soon as practical after the inspection but in no case later than 7 days after the inspection.

Logbook/Inspection Report Requirements ESC Supervisor Responsibilities Report should include the following detail: Remedial actions required, including time frames for the completion of specified works. Remedial actions outstanding from previous inspections. Details of who received the report. Sign off by the ESC Supervisor. Kenai

Bylaw 6410-2006 The environmental monitor will be required to monitor the site and submit a final letter of inspection in accordance with Schedule D of the Watercourse Protection Bylaw before occupancy.

Will this be your Best Defense?

ESC Plan is a Living Document Mark up the plans with changes Date and initial the changes

ESC Site Map Simple Site

ESC Site Map Complex Site

What should the inspection report say? Have you signed reports stating that you are in compliance with the ESC Plan & Permit?

Inspection sites - silt fence

4

High Turbidity & Oil Sheen What do you report?

WHAT BMP s ARE NEEDED FOR COMPLIANCE? What do the grading logs say?

SILT FENCE BLOWOUT SAND BAGS ADDED TO REINFORCE GULLY FORMING

SAME SILT FENCE FROM THE OTHER SIDE IS THERE A PROBLEM? WHAT SHOULD BE IN THE REPORTS?

Fugitive Dust

What is on the inspection report?

Predicting problems takes skills Inspection takes time Observation builds experience!

On DOT&PF projects provide a citation to the BMP Manual or publication used as a source for the BMP, If no published source was used, then the SWPPP or SWPPP amendment must state that No published BMP manual was used for this design. Include a drawing and description when designing a BMP.

Prior to embankment fill: 1- Install Perimeter berm at OHW 2- Place 4 gravel filter layer on berm Upon completion of the approach fill: 1- Place geotextile fabric 2- Place rip rap on slopes See detail Plan sheet xxxxx Describe the sequence and timing of activities that disturb soils and of BMP implementation and removal. Phase earth disturbing activities to minimize un-stabilized areas, and to achieve temporary or final stabilization quickly.

Example DOT&PF BMP 8oz Geotextile filter fabric Berm 4-8 Varies Fill area Washed Pea Gravel Existing Grade OHW No published BMP manual was used for this design. Designed by Danny Dirt PE, AK-CESCL #007

Inspection report Practice Time: Paxson

Is there a detail in the ESC Plan for this?

Inspection: Perimeter Controls Current site Map Note: BMP locations

No Perimeter Control

Unnecessary BMP s Sitka

Exposed Soils Perimeter Controls Fairbanks

End of Sediment Barrier Fairbanks

Inspection Requirements: Recordkeeping Copies of the ESP, inspection records, all reports required by the permit, and records of all data used to complete the permit applications must be retained and provided to authorities upon request.

Inspection: What next? Read Your Bylaws & permits Review ESC Plan for permit compliance Correct within 7 days if necessary Implement / maintain BMPs Within 24 hours / ASAP / 7 days Document BMP maintenance/addition in log book

Now What? Right Product? Installed correctly? Maintained?

Maintain BMPs to assure continuous performance. See specific BMP specifications and maintenance requirements in approved Erosion and Sediment Control Manuals Check sediment control BMPs weekly and after runoff events in dry season and daily in wet season during discharge Advice to inspectors: Remove temporary BMPs 30 days after site stabilization

Bad Stuff: Garbage Perimeter control Bare soil Maintenance Good Stuff: Rain drains Rock driveways Clean streets

Good Stuff: No Tracking Grass Lined Swale Vegetation Established Bad Stuff: Highway Missing in Both Directions Off ramp relocated to Downstream Location Repair Costs???

Photos Courtesy WADOE Self Reporting & Policing

BMP Damage Results In Sediment Discharge

Perimeter Sediment Control & Discharge Point

Indication of Slope Failure Under the Blanket

GUTTERS & RAIN DRAINS? PLASTIC SHEETING ON SLOPES STRAW ON EXPOSED SOILS PERIMETER SILT FENCE

Temporary Rain Drains Plastic Cover Perimeter Silt Fence

Improper Installation: Do the monitoring reports describe & document your permit compliance or non-compliance?

What should be in the monitoring report? What action should be taken?

Visual Inspection: High Turbidity, Why did the tree fall down? Is there a flow rate problem here?

Inspection Locations

Inspection involves walking the line.

& Checking all the BMP s along the way.

Always sample and report accurately and promptly

Define inspection role in contract, and READ THE CONTRACT! Indemnity clause? Some insurers require IC Don t indemnify for more than what your insurance/ professional liability policy covers (unless you have deep pockets). Mutual indemnity

Inspection & Monitoring Review Who? Qualified Individual Identified in pre construction documents What? All disturbed areas, BMP s, outfalls, exits, impacted areas When? Every 7 days or after a significant rain event Where? Safely located & marked locations Why? Permit requirements & risk management

Be Prepared for your Inspections Plan for your Inspections Complete your Inspections

Remember, An inspection is a snapshot of the construction process The records are the movie of the whole process. It is a critical element for defending your position, should you need it.