A common question with the NPDES inspection process regards trash or construction debris and if it relates to the stormwater plan. It absolutely does! Trash and debris directly affect the stormwater plan and is a specific requirement in state Construction General Permits (CGP) to maintain.

Most often attention is given to sediment and hazardous material to determine if a site is in compliance, these are only part of staying in compliance as there are many items throughout state CGPs that go above and beyond the typical sediment, erosion, and hazardous material protection. The definition alone for “discharge1” is a pollutant leaving the site. A pollutant2 can be considered anything other than clean water [A.R.S. § 49-201(29).

For example, Starbucks cups, fast food wrappers, as well as sediment are all considered pollutants. As it states in section 3.5.4.a of the renewed 2020 Arizona CGP under Good Housekeeping Measures: “The operator shall implement good housekeeping procedures to prevent litter, construction debris, and construction chemicals exposed to stormwater from becoming a pollutant source for stormwater discharges…”. The 2020 CGP further states ways you can protect against these pollutants and implement procedures to practice good waste storage handling. Plain and simple, the CGP states you should not litter on the site. The best way to manage onsite debris is to provide trash bins and have a scheduled maintenance for the bins as frequent as necessary, depending on the quantity of trades and activities on your site that produce trash.

1,2 Defintions found 2013 AZPDES Construction General Permit, June 3, 2013 page 45-50