What challenges have you faced applying SWPPP regulations to projects?

The initial challenge is ensuring our clients understand what a SWPPP (storm water pollution prevention program) is and how it affects construction.

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Langan provided Qualified SWPPP Practitioner (QSP) services during the construction of the Equinix SV10 development.

SWPPP provides instructions on how to treat stormwater prior to leaving a construction site. This isn’t new. For many years, cities have required sites to have SWPPPs, however the programs were unenforced and remained unopened throughout construction.

In 2009, the state’s General Permit mandated a SWPPP monitoring and compliance program. Every construction site that disturbs over one acre must have a project-specific SWPPP that the state has reviewed. Also, the construction team is responsible for appointing someone to monitor the site for SWPPP compliance throughout construction. SWPPPs may remain in effect for a few months up to several years, depending on the project’s construction timeline.

Some requirements are as simple as collecting trash and storing it in covered bins; while others require intricate systems to divert stormwater and remove sediment prior to entering the storm drain system.

While SWPPP is a great tool, it has created some confusion. Misunderstandings among different levels of government, contractors, and the property owners have placed us, as the consultants, right in the middle.

Part of our “middle man” role is ensuring clients and property owners understand their responsibilities as well as ours. For example, the party who develops and writes the SWPPP does not have to be the same party monitoring and inspecting the site for compliance.

Whether it’s writing the SWPPP, obtaining state approval, or overseeing the contractors during construction, Langan can play all roles, relieving the client from the burden of keeping up with the evolving regulations and staying on top of multiple contractors.

Even though we may be in charge of SWPPP, we still stress that all involved parties know what it is and its intent, which leads to the most common question we get asked: what’s up with all the acronyms? While there are too many to list here (the state’s General Permit lists them all), I provide a few key ones below:

SWPPP­­ — Storm Water Pollution Prevention Program

QSD — Qualified SWPPP Developer (writes the SWPPP)

QSP — Qualified SWPPP Practitioner (oversees the SWPPP inspections)

LRP — Legally Responsible Person (usually the owner or contractor; cannot be QSD or QSP)

REAP — Rain Event Action Plan (instructions for the contractor to follow prior to a rain event)

SMARTS — Storm Water Multi-Application and Report Tracking System (the state’s portal for submitting SWPPP documents)

Answer provided by Vitina Mandella, PE, LEED AP, QSD/P, Senior Project Manager
Vitina manages project teams from design through construction for land development, site design, and infill projects. She has extensive experience with stormwater management throughout the construction process and after completion as well as designing and implementing stormwater controls. Vitina has prepared stormwater pollution prevention plans (SWPPPs) as well as site and off-site plans for street improvements, traffic, LEED designation, Americans With Disabilities Act (ADA) compliance, and historical preservation.

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