2010 CGP Session IV.FINAL - Foley & Lardner and Recording for Qualifying Rain ... – Non-visible pollutants identified in the list ... QRecord time, date, onsite rain gauge reading
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Rain Event Action Plan (REAP)Rain Event Action Plan (REAP)Rain Event Action Plan (REAP)
REAP Requirements– Must document each active phase of construction
Construction activities for each phaseTrades active during each construction phaseTrade contractor informationSuggested actions for each construction phase
– Includes inactive construction sitesInactive areas of construction are areas of construction activity that have been disturbed and are not scheduled to be re-disturbed for at least 14 days.
Rain Event Action Plan (REAP)Rain Event Action Plan (REAP)Rain Event Action Plan (REAP)
REAP Requirements cont.– Minimum Site Information
Site addressCalculated Risk Level (2 or 3)Site Storm Water Manager InformationErosion Control Contractor InformationStorm Water Sampling Agent Information
Visual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain Events
Required 48hrs prior to the qualifying rain eventInspect all drainage areas to identify spills, leaks, or uncontrolled pollutants – Implement and document all corrective actions
Inspect all BMPs to identify proper implementation– Implement and document all corrective actions
Inspect storm water containment areas for presence or absence offloating litter/trash, sheens, discolorations, turbidity, odors
– DocumentationResults PhotosCertification under penalty of perjury
Visual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain Events
Required during the qualifying rain eventConduct inspections each 24hr periodIdentify and record BMPs that need maintenanceIdentify and record BMPs that failed or that could fail
Bad UglyGood
Document repair, modification, and implementation of BMPs
Visual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain Events
Required during the qualifying rain event (cont.)Complete Inspection checklist– Inspection date, date inspection was written– Weather information, estimate of beginning of rain event, duration, time
elapsed since last storm, amount of rainfall– Site information (phase, area exposed during grading)– BMPs evaluated and any deficiencies
Erosion controlSediment controlDrainage controlChemical/waste controlNon-storm water control
– Inspection/observations at all discharge points and downstream locations
– Maintenance activities– Corrective actions taken & photo documentation
Sampling and Analysis Overview for Qualifying Rain EventsSampling and Analysis Overview for Sampling and Analysis Overview for Qualifying Rain EventsQualifying Rain Events
Risk Level 2 and Risk Level 3 storm water sampling guidelines– Minimum 3 grab samples/day of discharge per discharge location
Minimum analytes: – pH (onsite)
– Turbidity (onsite or laboratory)
– Non-visible pollutants identified in the list of potential pollutant sources, including those associated with specific trade activities
– Any additional parameters for which monitoring is required by the RWQCB– Suspended Sediment Concentration
Risk Level 3: if violation of an Numeric Effluent Limit (NEL) for Turbidity
Will require planning!– Where are the sampling points?– Who is responsible for meter calibration and sampling?
Visual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain EventsVisual Monitoring for Qualifying Rain Events
Required after the qualifying rain eventInspection to identify whether BMPs were adequately designed, implemented, and effective– Review the pre-storm - during-storm inspection findings for
information on future designs or implementation
Continue inspection of discharge for all storm water containment areas (e.g., desilting basin)Record time, date, onsite rain gauge reading (including NOAA records)
Thoughts and Suggestions for Successful REAP ImplementationThoughts and Suggestions for Successful Thoughts and Suggestions for Successful REAP ImplementationREAP Implementation
Challenges of REAP PreparationDoes your budget have sufficient resources for the storm event program?Reliability of NOAA websiteAvailability of QSP/QSD to prepare and certify the document
Challenges of REAP ImplementationAvailability of resources and authority to ensure effective implementationAvailability of staff (erosion control contractor, sampling agent, QSP/QSD)
Summary of REAP Implementation– Adequate resources onsite– Pre-determined person of authority (LRP or QSP)– Materials and pre-determined locations for sampling– Type of construction phase– Applicable BMPs installed– Aware of potential pollutants– Qualified Inspector
Thoughts and Suggestions for Successful REAP ImplementationThoughts and Suggestions for Successful Thoughts and Suggestions for Successful REAP ImplementationREAP Implementation
Thoughts and Suggestions for Successful REAP ImplementationThoughts and Suggestions for Successful Thoughts and Suggestions for Successful REAP ImplementationREAP Implementation
Storm Event Source ActionPerson
Responsible
Pre-StormREAP
CSMP
• Site Evaluation • Additional BMP
Implementation• Storm Preparation
LRP & QSP
During Storm
Inspection, Maintenance and
Repair
CSMP
• Site Evaluation• BMP Modification• Sampling
LRP & QSP
Post-StormCSMP
• Site Evaluation• BMP Amendment• Exceedance / Violation
A copy of the PowerPoint presentation and a multimedia recording will be available on our Web site early next week.Continue the discussion! Ask a question or post a comment about the new Construction General Permit on the Whitson CM blog:http://whitson.wordpress.com.