Sheetflow Erosion Control Erosion Control for the CESCL

October 21, 2019

“Means and Methods” vs. Best Management Practices

Demolition of landside crane rail on a shipping container terminal.

In my experience, managing contractor “means and methods” is more important than using the “right” best management practices. When turbidity is the standard for measuring water quality compliance, as in Washington state, site cleanliness is the key to prevention and compliance.

This contract requires that catch basin inserts be installed in all catch basins within the project boundaries. However, inserts are not at all effective in reducing turbidity in runoff. While removing the crane rail on this container terminal project, the contractor could clean up as the work progresses, place all material removed from the trench onto plastic for later removal, load into a Bobcat bucket, and pick up small debris with a shop vac. I can require these things in the contract that the contractor bids. It may cost extra; the extra cost may be worth it if it reduces my risk. If I tell the contractor after the contract is awarded, I will pay more.

I can also make suggestions during the work, pointing out that keeping things really clean will keep them in compliance with their NPDES permit. If framed in a way that shows benefit to the contractor, meaning reducing risk and cost, they will probably follow the suggestion.

January 27, 2013

EPA Construction Site Stormwater Runoff Control

Construction Site Stormwater Runoff Control

Poorly maintained BMPs can result in significant quantities of sediment being discharged to storm drains.  Uncontrolled storm water runoff from construction sites can significantly impact rivers, lakes and estuaries. Sediment in water bodies from construction sites can reduce the amount of sunlight reaching aquatic plants, clog fish gills, smother aquatic habitat and spawning areas, and impede navigation.

Phase II MS4s are required to develop a program to reduce pollutants in stormwater runoff to the MS4 for construction sites disturbing one or more acres. This primarily includes developing:

An ordinance,
Requirements to implement erosion and sediment control best managment practices (BMPs),
Requirements to control other waste at the construction site,
Procedures for reviewing construction site plans,
Procedures to receive and consider information submitted by the public, and
Procedures for inspections and enforcement of stormwater requirements at construction sites.
In addition to the stormwater requirements that Phase II MS4s place on construction sites, construction operators must also apply for NPDES permit coverage if their project disturbs at least one acre and discharges to a waterbody.

A description of these requirements is available at EPA’s stormwater construction website.

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