Special Topics in Environmental Management

Construction SWPPP Essentials—Information Gathering

SWPPPs are central to compliance with federal, state, and/or local stormwater regulations and permits. As such, they are also complex and require attention to details about many different aspects of a construction project from pre-bid through project completion. As you begin to prepare an SWPPP you should be aware of the variety of information necessary to save you time and money. Although state and local agencies may have unique and more stringent requirements, we will use the federal minimum requirements as a basis for determining the  primary information you will need to develop a federally compliant SWPPP.

Note that your SWPPP must be prepared before you can submit a Notice of Intent (NOI) to apply for a construction stormwater permit and, in most cases, you cannot begin construction without an active permit.

The first section of an SWPPP must contain a concise site description, including:

  • Address,
  • Latitude and longitude,
  • Horizontal reference datum used,
  • Scale of the United States Geological Survey (USGS) map if you use one, and
  • Information about sites on tribal lands, whether the project is part of a public emergency response, and if you are applying as a “federal operator.”

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Following this information, you must include a detailed description of anticipated stormwater discharges that will correspond to the “Discharge Information” section of the NOI. This should include:

  • The name of the first surface water body or bodies receiving your stormwater,
  • If any of the listed waters bodies are listed (by state or tribe) as impaired, what pollutants caused the impairment and what, if any, total maximum daily load (TMDL) requirements are completed,
  • If any of the water bodies are designated as Tier 2, 2.5, or 3 waters by a state or tribe,
  • Whether your site discharges to a municipal separate storm sewer system (MS4), and
  • Whether there are surface waters within 50 feet of construction disturbances.

Next you need to provide a general description of your intended construction activities, with a detailed description of the property and any construction support activities, including:

  • Site size in acres,
  • Total area of disturbed property in acres,
  • Maximum area to be disturbed at any one time (in acres),
  • Type of construction support activity (e.g., asphalt batch plant, equipment staging areas, material storage areas),
  • Contact information for construction report activity, and
  • Location of construction support activity.

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For each phase of construction, you will need to provide both the sequence of phases and applicable timing of activities, including:

  • Stormwater Controls—both timing of installation and operability,
  • All earth-disturbing activities—commencement and duration,
  • Cessation of construction activities—both temporary and permanent on all or any portion of the site,
  • Stabilization of exposed soil areas—both temporary and final,
  • Removal of temporary stormwater conveyances, channels, or control measures,
  • Removal of construction equipment and vehicles,
  • Cessation of any pollutant-generating activities, and
  • Allowable nonstormwater discharges.

Site map(s) must also be provided that show construction phases as well as the undeveloped site and the constructed site. The site map(s) must identify and locate:

  • All earth-disturbing activities, including phasing,
  • Approximate slopes before and after grading activities,
  • Any surface water crossings,
  • Vehicle site exits onto paved roads,
  • Structures and other impervious surfaces after construction,
  • Construction support activities areas,
  • Locations of surface water bodies (and other information required above),
  • Area of federally listed endangered species,
  • Boundaries of natural buffer areas,
  • Site topography, including vegetation, and drainage of storm and nonstorm allowable flows before and after major grading,
  • All stormwater and allowable nonstormwater discharges and the discharge locations,
  • Potential pollutant-generating activities,
  • Stormwater control measures, and
  • Use and storage areas of any polymers, flocculants, or other treatment chemicals.

Again, these are just some of the fundamental requirements. A template for preparing an SWPPP is available from BLR at http://enviro.blr.com/timesavers/environmental-plans/water/Stormwater-Construction-Activities/Construction-Stormwater-Pollution-Pre/.