Tag: SWPPP

---

Download our three-page safety guide to construction, demolition and renovation.

---

Managing stormwater discharges from construction sites is a common challenge, but it is not the only environmental risk out there. Property owners, building managers and general contractors often have similar compliance exposure to a range of other risks. Enforcement and civil consequences can be severe at the company and individual level.

 

Keep the following in mind when working at sites with existing structures or other development.

ASBESTOS

What’s the Risk?

• Asbestos was used in many building products until the late 1970s.
• Asbestos exposure can lead to serious—often fatal—lung diseases.
• The EPA and OSHA regulate companies’ demolition, renovation, processing, handling, and disposal of asbestos-containing material.

Make sure to…

• Identify regulated asbestos-containing material (RACM).
• Verify contractors working with RACM have required training and professional licenses.
• Ensure adherence to all required removal and disposal work practices
• Verify RACM is disposed of in an authorized landfill facility.

 

LEAD

What’s the Risk?

• Lead can be found in construction in surface coatings, piping, flashing, tank linings and conduits.
• Lead is toxic and causes damage to numerous body systems.
• Renovation, repair, and painting of residential structures is strictly regulated.
• Lead paint removal from bridges and other structures may be regulated at the state and local levels.
• Demolition debris of commercial buildings may also be regulated at the state and local levels.

Make sure to…

• Understand the scope of work and applicable requirements before you bid a project.
• Verify required training and professional licenses.
• Adhere to all required removal and disposal work practices.

 

CONTAMINATED SOIL / GROUNDWATER

What’s the Risk?

• Unknown contamination from historical activities may exist.
• Disturbance and improper handling of soil may spread contaminants to ground water or other waterbodies.
• Reuse of soil as fill material may not be authorized.
• Exposure to unprotected workers and public may occur.
• Unauthorized handling, use or disposal can result in civil and criminal enforcement.

Make sure to…

• Verify proper environmental due diligence is conducted for sites with any potentialfor contamination. Phase I and Phase II environmental site assessments are often conducted to identify existing and potential contamination.
• Verify that required work practices are followed for removal, handling, storage and disposal of contaminated soils.
• Only utilize personnel who have required training and proper equipment to perform soil
removal and disposal activities.

 

MERCURY

What’s the Risk?

• Many items inside buildings can contain mercury including fluorescent lamps, mercury vapor lamps,
metal halide lamps, thermostats, various electrical switches and more.
• Mercury is an extremely persistent and toxic threat to human health, as well as the environment.
• Storage and disposal of mercury-containing materials is regulated by EPA and many state agencies under specific rules for “Universal Wastes.”

Make sure to…

• Identify materials that contain mercury.
• Follow Universal Waste regulations, which were designed to promote proper handling and recycling while easing regulatory burdens. However, labeling, handling and disposal requirements must be followed.

 

POLYCHLORINATED BIPHENYLS (PCBs)

What’s the Risk?

• PCB-containing materials were used in builds and renovations between 1950 and 1979 for caulking, electrical transformers, capacitors and fluorescent light ballasts.
• PCBs cause a variety of serious, adverse health effects.
• Storage and disposal of PCB-containing materials is strictly regulated by the EPA.

Make sure to…

• Identify materials that contain or are contaminated by PCBs.
• Ensure required work practices are followed for removal, repair, cleanup, storage and disposal of PCB-containing materials.

 

REMOVAL OF EQUIPMENT & CHEMICALS

What’s the Risk?

• Many items contain oils, fuels, and other chemicals, and improper decommissioning and dismantling can result in releases of these materials.
• Failure to properly remove and dispose of regulated materials can result in environmental contamination and public endangerment.
• Disposal of oils, fuels, refrigerants and other chemical substances is strictly regulated.

Make sure to…

• Identify all potential sources of chemical storage, including underground storage tanks and piping.
• Verify all equipment that is to be dismantled and removed has been properly decommissioned.
• Identify and properly classify all chemical materials that are to be disposed.
• Ensure required work practices are followed for removal, handling and disposal of chemicals and contaminated equipment.

 

All of these risks can be identified and mitigated through proper due diligence, planning and use of safe work practices.

Need assistance on an upcoming project, contact us.

The use, storage, and handling of oils are common occurrences at construction sites. One of EPA’s top priorities is to prevent, prepare for, and respond to oil spills that occur in and around “Waters of the United States.” Authorized under the Clean Water Act, EPA’s oil spill prevention program includes the Spill Prevention, Control, and Counter measure (SPCC) regulations in 40 CFR 112.

Under the SPCC rules, the term “oil” means oil of any kind or in any form. This includes, but is not limited to, the following: fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.

Fuels, paints, greases, and lubricating and hydraulic oils at construction sites can be released into the environment from a variety of sources. Spills and leaks can result in direct discharges, or may be carried to waterbodies by stormwater.

Does SPCC planning apply to my construction project?

A construction site project must meet SPCC (SPCC Plan) regulatory requirements if it meets the following three criteria:

• It stores, uses, transfers, or otherwise handles oil; and
• It has a maximum above ground storage capacity greater than 1,320 gallons of oil (which includes both bulk and operational storage volumes) OR total underground storage capacity greater than 42,000 gallons of oil, and
• There is a reasonable expectation (based on the location of your site) that an oil spill would reach navigable waters or adjoining shorelines of the U.S.

What if my project triggers SPCCP requirements?

You must prepare and implement a SPCC Plan that meets the requirements of 40 CFR 112, in addition to any spill prevention and response procedures required by a construction stormwater permit (SWPPP).

What if my project is not subject to SPCCP requirements?

All construction site projects have some level of legal obligation for preventing discharges of oil into U.S. waters and responding when incidents do occur.

• Sites where construction activities disturb one acre or more of earth must obtain coverage under an NPDES stormwater construction general permit issued by the EPA, a state agency, or an authorized local program. The permit-required stormwater pollution prevention plan (SWPPP) will include spill prevention and response procedures that must be followed.
• Sites that do not trigger SPCCP or SWPPP requirements are still susceptible to legal enforcement if spills or leaks result in an impact to “Waters of the U.S.” Failure to report and respond to discharges to waterbodies can result in swift enforcement and severe penalties.

Best Management Practices (BMPs): 

Regardless of your oil storage capacity startus, implementation of common BMPs will significantly reduce the risk of releases.

Conduct regular inspections of storage and equipment fueling areas, even if you are not required to by a formal SWPPP or SPCCP.

• Don’t let dilapidated equipment sneak onto your site.
• Make sure containers are kept closed when not in use.
• Check for deterioration of, or leaks from, equipment fittings and secondary containment, in addition to the primary container.
• Verify designed safety features are functioning properly.
• Verify rainwater collected in secondary containment is free from oil before draining or discharging.
• Make sure proper work practices are being followed by all on-sire personnel.
• The property owner and construction contractor are both accountable for releases to U.S. Waters.

This is where having a plan, maintaining spill kits, and training personnel show their value. If a leak or spill occurs, take steps to stop the release and prevent impact to the environment. Do not let oil, fuel, or other chemical get carried off-site in stormwater discharges. Dispose of any contaminated soil and clean up materials properly in accordance with regulatory requirements.

Comply with release reporting requirements

Discharges of oil that require immediate reporting under the “Sheen Rule” (40 CFR 110)

• Cause a sheen or discoloration on the surface of a body of water;
• Cause a violation of applicable water quality standards; and/or
• Cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorlines.

Reportable Quantities

Releases of any hazardous substance list in Comprehensive Environmental Response, Compensation, and Liability Act (Superfund) regulations in an amount equal to or greater than the “reportable quantity (RQ),” and all “extremely hazardous substances” listed under Emergency Planning and Community Right-to-Know Act must be reported. In addition to the EPA National Response Center, state and local emergency agencies will also need to be notified if a reportable release occurs.

For more information or an assessment of your spill prevention and control procedures, contact us.

Visit an active commercial building site, and you may see EIFS insulating board being installed. If you see this, you will likely also observe foam pellets, or particulate fines, drifting in the air or scattered on the ground.

These foam pellets are generated by workers performing rasping activities on EIFS siding. As the rasping tool is worked across the surface of EIFS boards, the particles shaved off the surface free-fall to the ground. A slight breeze can cause EIFS fines to drift off-site, particularly with multi-story buildings.

THE ISSUE:

Uncontrolled particulate matter of this nature presents compliance risk across multiple environmental media.

• Stormwater: Discharge of foam particulate in stormwater is not permitted under EPA or state Construction General Permits (CGP). Discharge of this nature to stormwater sewers can impact the quality of receiving waters and are prohibited.
• Waste Management: The moment that these fines are generated, they are considered waste material. Open dumping onto land is prohibited by federal, state and local laws and regulations. Allowing particulate matter from rasping operations to accumulate off-site is considered improper disposal.

A situation like this could bring enforcement action from agency water quality and solid waste departments.

Styrofoam fines released from elevated work areas can be carried significant distances by wind. This presents additional risk exposure for project sites near sensitive environments, landmarks or public gathering places.

Complaints from affected parties could result in costs associated with clean-up, as well as damaged public perception. There is also a possibility for termination of building permits if issues persist.

SOLUTIONS: 

Construction firms installing EIFS products can significantly reduce the impacts of rasping activities with a little planning and diligence. Solutions include:

• Enclosing scaffolding with netting to help contain Styrofoam fines and prevent transport via wind drift.
• Housekeeping measures, including periodic vacuuming of foam particles that fall to the ground or drift out of the containment netting.
• Inspections of nearby areas and housekeeping as needed to reduce off-site impact.

ADDITIONAL NOTES:

• Containing fines at the source of generation provide the best chance at managing the issue.
• Review any potential safety impacts prior to installing any form of containment netting on scaffolding. Some materials may catch wind and cause the scaffolding to become unstable.
• There are commercially available rasping tools with vacuum attachments available for use.
• An approach combining safe enclosure and diligent housekeeping should provide effective control and prevent deposition of fines in waterways, sewers and surrounding properties.

Need assistance with managing EIFS on an upcoming project, contact us.

Dewatering is often needed when stormwater accumulates in trenches, manholes, foundation excavations, and other areas of construction jobsites.

Dewatering requirements and restrictions are typically addressed in the general permit issued by state agencies or the EPA. State stormwater manuals often provide additional specifications on required practices, and local authorities may also impose restrictions.

Dewatering Tips

• Plan a head. Most construction projects will face the prospect of rain, which can cause major work delays. Plan ahead to save both time and money on your project.
• Know your requirements. Make sure you know the federal, state, and local rules and permit requirements, which will require implementation of specific best management practices and discharge restrictions.
• Get organized. Discuss dewatering protocols with affected project personnel and procure necessary equipment and treatment products before they are needed. Stormwater that is contaminated with oil, fuel or other chemicals is a prohibited discharge under NPDES permitting. In some cases, dewatering discharges may need to be chemically treated to meet water quality parameters. know your stormwater pollution prevention plan (SWPPP) requirements and plan accordingly.