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Storm Water Pollution Prevention Plan Risk Management: For the Construction Industry

Professionals working in the construction industry know the extent of permits and mountains of requirements that have to be followed for every project, so it’s not surprising that environmental practices inevitably slip through the cracks. Storm Water Pollution Prevention Plans (SWPPPs) were initially developed during the 1990s to minimize the impact and consequences of soil disturbance and construction activity on the environment. SWPPPs are mainly formed around five best management practices (BMPs): Soil stabilization Sediment control Tracking control Non-storm water management Waste management and material storage and use. But these BMPs only work if they are implemented properly. In 2007 independent assurance auditor Mike L. Peters, QSD, CPESC, was consulting for a client in the mountains of West Virginia when he became aware that the nearby streams and rivers were still “dead” due to the effects of coal mining and other industrial activity of the past. Seeing firsthand the importance of environmental stewardship, he set out to create a reference guide for developers and construction engineers that would ensure adhering to sustainable environmental practices would not only be the right thing to do, but also an easy and profitable path to follow. Water Pollution Control Plans (WPCPs) are used when there is less than an acre of disturbed soil on a project. Many of these WPCP projects may have major deficiencies stemming from not implementing 401 Water Quality Certification monitoring correctly when applicable. Additionally, the Non Storm Water (NS) and Waste Management (WM) BMPs are quite often not implemented properly, resulting in deleterious and egregious deficiencies due to hazardous waste and materials not being properly controlled, stored or implemented. While there may be little or no chance for failure of soil stabilization or sediment control BMPs due to minimal disturbed soil area, there are quite often multiple Non Storm Water and Waste Management BMP deficiencies because these BMPs are neglected or not implemented properly. There can be just as much chance of BMP implementation failure on a smaller WPCP project as on a larger SWPPP project. The Non Storm Water and Waste Management BMPs must be taken as seriously as the soil stabilization, sediment control, tracking control and wind erosion control BMPs. In California, a Qualified SWPPP Practitioner (QSP) can write or develop a WPCP, one does not have to be a Qualified SWPPP Developer (QSD) to write a WPCP. If the QSP does not have the knowledge or experience to manage the risk of writing, developing and properly implementing a WPCP, things can be out of compliance before the project starts. Take the writing of a WPCP or a SWPPP seriously and judiciously because the QSP or QSD is developing the actual plan for Storm Water Permit compliance. The language of the WPCP / SWPPP must be compliant with the body and language of the applicable project permits. Be sure of this before starting work. There are Owners (Legally Responsible Person or Entity) of projects that approve or accept the Contractor's WPCP or SWPPP without knowing that it is congruent and compliant with the applicable permits. Have the promulgating agencies of the applicable permits review the WPCP or SWPPP and get them on board with the scope of work, means and methods of the order of work for the project. It is prudent to initiate transparency with these agencies than to hope that they won't know or care about your project. There's an old contractor saying in the construction industry that "It's better to ask for forgiveness than permission." Risk management in the storm water pollution prevention plan and water pollution control plan industry would use an old quote from Clint Eastwood that was used in the Dirty Harry era series of movies..."I only have one question...do you feel lucky?" Manage and control your risk.