Construction Site Monitoring Program

The State of California has now mandated a Construction Site Monitoring Program for all construction sites greater than one acre in size. Sites of all three risk levels need to take part in this program. While the requirements for the sites of the varying risk levels differ, there is much similarity. This write-up is intended to give you an understanding of the program.

Quarterly Non-stormwater Discharge
Once a quarter - January - March, April - June, July - September, October - December, the permitte is required to conduct one visual observation (inspection). The discharger (permitee) shall ensure to document the presence or evidence of any nonstorm water discharge (authorized or unauthorized), pollutant characteristics (floating and suspended material, sheen, discoloration, turbidity, odor, etc.), and the source. All Risk Level sites are required to perform this quarterly inspection / observation.

Prestorm Baseline Inspections
All risk levels are required to do this. Within 48 hours of a rain forecast predicting a 50% chance of precipitation, a Qualified SWPPP Practitioner ( QSP ) is required to inspect the construction site for the following:

1. All storm water drainage areas to identify any spills, leaks, or uncontrolled pollutant sources.
2. All BMPs to identify whether they have been properly implemented in accordance with the SWPPP.
3. Any storm water storage and containment areas to detect leaks and ensure maintenance of adequate freeboard.

The inspection results are to be recorded and saved in the SWPPP.

Rain Event Action Plan
Risk Level 2 and Risk Level 3 sites are required create these plans as a new requirement effective July 1, 2010.

A QSP is required to create a Rain Event Action Plan ( REAP ) within 48 hours of a rain forecast predicting a 50% chance of precipitation. REAPs are to be customized for all phases or construction (i.e., Grading and Land Development, Streets and Utilities, Vertical Construction,
Final Landscaping and Site Stabilization). The REAP shall at a minumum contain the following information.:

1. Site Address.
2. Calculated Risk Level (2 or 3).
3. Site Storm Water Manager Information including the name, company, and 24-hour emergency telephone number.
4. Erosion and Sediment Control Provider information including the name, company, and 24-hour emergency telephone number.
5. Storm Water Sampling Agent information including the name, company, and 24-hour emergency telephone number.

The REAP shall also contain the following project phase information:

1. Activities associated with each construction phase.
2. Trades active on the construction site during each construction phase.
3. Trade contractor information.
4. Suggested actions for each project phase.

The REAP must be on site no later than 24 hours prior to the projected rain event.

Daily BMP Inspections During Rain Events
All risk levels are required to have the QSP do daily BMP inspections during rain events that take place during business hours and are not deemed unsafe. The QSP is required to inspect the following:

1. All storm water drainage areas to identify any spills, leaks, or uncontrolled pollutant sources. If needed, the discharger shall implement appropriate corrective actions.
2. All BMPs to identify whether they have been properly implemented in accordance with the SWPPP. If needed, the discharger shall implement appropriate corrective actions.
3. Any storm water storage and containment areas to detect leaks and ensure maintenance of adequate freeboard.

Post Storm Inspection
Within two business days (48 hours) after each qualifying rain event, the QSP shall conduct post rain event visual observations (inspections) to (1) identify whether BMPs were adequately designed, implemented, and effective, and (2) identify additional BMPs and revise the SWPPP accordingly.

Stormwater Discharge Samples
Risk Level 2 and Risk Level 3 sites require the QSP to obtain samples from the all discharge locations to get PH and turbidity readings. At least three separate samples are to be taken at different times or locations to be taken to a laboratory certified for such analyses by the State Department of Health Services. The samples should be delivered to the lab within 48 hours from when they were taken.

PH and Turbidity Readings should be within the following tolerances for Risk Level 2 sites.
PH - lower Numeric Action Level (NAL) = 6.5
PH - upper Numeric Action Level (NAL) = 8.5
Turbidity - Not to exceed 250 NTU

For Risk Level 2 sites, exceedances are to be reported to the State Water Board no later than 10 days from the date of the event.

For Risk Level 3 sites, dischargers shall electronically submit all storm event sampling results to the State Water Board no later than 5 days after the conclusion of the storm event.

PH and Turbidity Readings should be within the following tolerances for Risk Level 3 sites.
PH - lower Numeric Action Level (NAL) = 6.5
PH - upper Numeric Action Level (NAL) = 8.5
PH - lower Numeric Effluent Level (NEL) = 6.0
PH - lower Numeric Effluent Level (NEL) = 9.0
Turbidity - NAL 250 NTU
Turbidity - NEL 500 NTU

Risk Level 3 sites are additionally required to perform suspended sediment concentration (SSC) analysis using ASTM Method D3977-97.

Risk Level 3 sites greater than 30 acres in size shall perform bioassessment sampling and analysis. Don’t start work without this one as the fines are $7,500 per missed sample.

Recieving Water Samples
Only Risk Level 3 sites are required to fulfil this requirement only in the event that thier effluent samples show exceedances in thier limits.