By Johnathan Clayton // 2020-08-04
As many homebuilders have noticed, there has been an increase in NPDES regulatory inspections across the state of Florida. Whether the regulatory inspections are completed by state, county or municipality, it can be very stressful for site supervisors and others involved with NPDES compliance. In most instances, a regulatory inspector will notify the responsible authority of an upcoming inspection. The advanced notice should be used to ensure that all BMPs onsite, as well as the SWPPP, are up to date and in compliance with the CGP.
During the recent increase in regulatory inspections, it was found that many of the item’s inspectors focused on were consistent between sites. Inspectors always look to make sure the most recent NPDES permit is posted in the SWPPP as well as a conspicuous location for public viewing. The construction schedule is another item that is always checked during a regulatory inspection. As stated in the Florida CGP, the construction schedule should contain the start and proposed end date for “each major activity such as land clearing, grubbing, grading, cut and fill, dewatering operations, installation of erosion and sediment controls, installation of stormwater management systems, paving, final or temporary stabilization”. (FDEP) The BMP map is inspected to make sure the required information is recorded and updated on the map. Some of the major items that should be marked on the map include: construction entrance/exit, locations of construction activities and dewatering operations, structural and non-structural control locations, areas where soil stabilization practices will occur, surface waters and wetlands and the location(s) of site discharge points.
Inspectors will go through the site and ensure all BMPs are properly installed and in compliance. Perimeter BMP’s such as silt fence or construction entrances tend to be inspected closely, as they are the last point of control that will keep sediment/discharge from leaving a site. It is important to have a detail in the SWPPP for each BMP that is being used on site. Inspectors will look for BMP details for each BMP that is being used on site and make sure they are installed and maintained per the detail. Site discharge points are important areas that will be inspected. Discharge points should be clear of trash and debris, and if discharging, water cannot exceed 29 NTU over background conditions.
These inspections can be stressful but, they offer those involved with NPDES compliance a great learning experience and opportunity to pinpoint exactly what the inspectors are looking for during their inspections. Though a few state regulations were addressed in this article, there are many more regulations and requirements that regulating agencies expect builders to adhere to. Earthworks Environmental specializes in helping builders maintain a compliant NPDES program so their main focus can be on building houses.
Florida Department of Environmental Protection (FDEP), NPDES Generic Permit For Stormwater Discharge from Large and Small Construction Activities, 2015, https://floridadep.gov/sites/default/files/Construction_Generic_Permit_0.pdf